IR 05000445/1992053

Insp Repts 50-445/92-53 & 50-446/92-53 on 921102-06.No Violations or Deviations Noted.Major Areas Inspected:Isi Activities,Feedback of Operational Experience Info & Followup of Previously Identified Insp Findings

ML20128C066
Person / Time
Site:	Comanche Peak
Issue date:	11/30/1992
From:	Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20128C051	List: IR 05000445/1992053 ML20128C047
References
50-445-92-53, 50-446-92-53, NUDOCS 9212040216
Download: ML20128C066 (9)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection Report:

50-445/92-53; 50-446/92-53 Operating License:

NPF-87 Construction Permit: CPPR-127 Licensee:

TV Electric Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Facility Name:

Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 Inspection At: CPSES, Glen Rose, Sommervell County, Texas Inspection Conducted:

November 2-6, 1992 Inspectors:

L. D. Gilbert, Reactor Inspector, Maintenance Section, Division of Reactor Safety L. E. Ellershaw, Reactor inspector, Maintenance Section, Division of Reactor Safety M

///J b'/C Approved:

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l'. f.~Stetka, Chief, Maintenance Section Date

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Division of Reactor Safety Jnspection Summary Areas Insoected (Unit 1):

Routine, announced inspection of inservice inspection activities, feedback of operational experience information, and followup of previously identified inspection findings.

Areas Inspected (Unit 21:

N. inspection of Unit 2 activities was performed.

Resultt:

The inservice inspection program was well documented and effectively implemented, with performance of nondestructive examinations observed to be good (paragraph 1).

• The operational experience information program, with minor exceptions, was well defined and was being implemented (paragraph 2;

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9212040216 921130

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Summat/ of Inspection Findinas:

e Violation 445/9204-01 was closed (paragraph 3).

e Inspection Followup Item 445/9231-03; 446/9231-03 was closed

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(paragraph 4).

Attachment:

e Attachmrint 1 - Persons Contacted and Exit Meeting e

Attachment 2 - Identification of Evaluated Operational Experience-Reports

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-3-DETAILS

INSERVICE INSPECTION - OBSERVATION (73753)

The objectives of this inspection were to ascertain whether inservice examinations, repair, and replacement of Class 1, 2, and 3 pressure retaining components are performed in accordance with the Technical Specifications, the applicable American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, correspondence between NRR and the licensee concerning relief requests, and requirements imposed by NRC/ industry initiatives.

1.1 Discussion The inspectors observed the inservice inspection activities associated with the nondestructive examination of four pipe welds in the safety injection system and a pipe support for the reactor coolant system.

The inspectors were informed that no ASME Code Section XI repair or replacement activities had-been scheduled for the outage.

The inspectors observed liquid penetrant and/or ultrasonic examinations performed on the four pipe welds.

Liquid penetrant examinations were performed on three welds that were identified as TBX-1-4103-1. TBX-2-2566-35, and TBX-2-2566-36, using Procedure TX-ISI-11. " Liquid Penetrant Examination,"

Revision 3, and an approved procedure field change request, FC-001.

The ultrasonic examinations performed included the calibration and examination of Welds TBX-1-4103-1 and TBX-2-2565-36, using Procedure TX-ISI-207, " Ultrasonic Examination of Similar and Dissimilar Metal Welds in Austenitic Stainless Steel Piping Systems,"' Revision 1.

The inspectors also observed the visual inspection, VT-3 of Pipe Support TBX-1-4109-HS, using Procedure TX-ISI-8,

" Visual Examination," Revision 2.

The inspectors verified that the examinations were performed using approved procedures and qualified personnel certified as Level 11 examiners for the nondestructive examination method used.

For the liquid penetrant examinations, the inspectors also verified that procedure limitations were met for surface temperature and penetrant material contaminants.

For that portion of the ultrasonic examination observed by the inspectors, the ultrasonic-system was calibrated, the temperature of the calibration block and component was measured, the distance amplitude curves were established, and the examination covered the required volume.

The examinations were observed to be performed in full accordance with the requirements of the nondestructive examination procedures and the 1986 edition of Section XI of the ASME Code.

The inspectors also reviewed the Comanche Peak Steam Electric Station 10-Year Inservice Inspection Plan, Revision 1 and Interim Change Request No. ISI-Rl-001, and verified that examinations were-accom)11shed as scheduled for the current inspection period.

During this review, tie inspectors noted that the issuance of the inservice inspection plan and changes thereto was

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-4-performed by document control. The responsibilities for review, approval, and distribution of the plan and changes were specified in Procedure STA-703,

" Inservice Inspection Program," Revision 6.

In reviewing the approval status of the inservice inspection plan for the first interval, which covers the period from February 8, 1990, to February 8, 2000, the inspectors determined that Revision 0 of the plan was approved by an NRR Safety Evaluation dated October 1,1992. The licensee issued Revision 1 to the plan on August 25, 1992, which was submitted to NRR on September 14, 1992.

1.2 Conclusions The inservice inspection program was well documented and effectively implemented.

Performance of nondestructive examinations were judged to be good.

2 FEEDBACK OF OPERATIONAL EXPERIENCE INFORMATION (90700)

The purpose of this inspection was to determine the effectiveness of the licensee's program to assess and disseminate operational experience information pertinent to plant safety, which originated outside the organization.

2.1 Proaram Verification The plant analysis group is responsible for the program, which is controlled and described in Nuclear Overview Department Procedure NQA 2.30, " Industry Operating Experience Report Review Program," Revision 1,ber 30, 1992.

dated August 20, 1992, through Document Change Notice (DCN) 01 dated Octo This procedure provided the specific details regarding the receipt, prioritization, tracking, evaluating, and closure of industry operating experience reports (10ERs), such as information notices received from the NRC, and the various categories of 10ERs received from the institute of Nuclear Power-Operations (INP0).

The methodology specified for performing evaluations, making recommendations, obtaining technical review and approval, and verifying that recommended actions have been completed, was well planned.

The inspectors noted a minor procedural weakness in that it did not provide an escalation policy for those instances where requested responses from other organizations were overdue. A management escalation policy would preclude potential neglect and facilitate timely reviews of received operating experience information. This did not appear to be a problem at present,-in that there were currently six 10ERs overdue, with the oldest being 3-months late.

The inspectors * review of the 10ERs determined that there was no urgency associated with any of the six.

Revision 1 to Procedure NQA 2.30 was considered a major revision with a number of program enhancements, including (1) the establishment of a review of the effectiveness of the program's implementation and (2) a review of recurring significant event reports with a concurrent evaluation of the effectiveness of

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-5-corrective and areventivu actions previously taken in response to 10ER assessments.

11e procedure addressed the performance of an effectiveness review of significant operating event report (50ER) implementation by the independent safety engineering group (ISEG) manager.

The procedure further provided that the effectiveness review could be limited to the 75 SOER recommendations categorized by INP0 in their document, INPO 91-007, as being

"of such a nature or importance that they should be retained and reviewed on an on-going basis." The inspectors were informed that ISEG had performed a Unit 2 completions assessment, which included a section that addressed a review of the 75 SOER recommendations, with 47 receiving a detailed review.

These efforts were documented in ISEG Assessment Report No. IAR 92-09, dated September 25, 1992, which was reviewed by the inspectoes.

Station Administration Manual Procedure STA-509, " Commitment Tracking System,"

Revision 6 dated June 1,1992, established the guidelines and general format for the commitment tracking system (CTS), which was utilized to ensure that all commitments, whether regulatory or internal, are satisfied and maintained.

The use of the CTS for 10ERs, such as NRC information notices and certain categories of INP0 reports, was part of a major enhancement to the process when Revision 1 to Procedure NQA 2.30 was issued.

2.2 Proaram Implementation Procedure NQA 2.30 referenced Section 1.C.5 in NRC Document HUREG-0737,

" Clarification of THI Action Plan Requirements."Section I.C.5, " Procedures for feedback Of Operating Experience To Plant Staff." required each licensee to establish procedures pertaining to specific elements of an operating experience feedback program. One element required that periodic internal audits be performed to assure that the operating experience feedback program functions effectively at all levels. The inspectors requested information to support the licensee's accomplishment of internal audits in this area.

Operations Quality Assurance Audit Report QAA-91-104, "Nonconformance and Corrective Action Program," which was performed during January 28 through February 7, 1991, was provided to the inspectors.

The inspectors review of the report revealed that it was an assessment of the corrective action process in terms of plant incident evaluations, root cause analysis, industry operating experience reviews, and in-house operating and trending data. The inspectors considered the audit to be an in-depth assessment of the program.

The audit's conclusion determined that the program was satisfactory and was being implemented as required.

Three observations were identified in the areas of tracking, assuring timely completion of recommended actions, and utilization of lessons learned.

The inspectors noted that procedure revisions have addressed these concerns.

Review of audit schedules and frequencies showed that the industry operating experience review program is on a biennial audit frequency and is currently scheduled for the first quarter of 1993.

The inspectors reviewed the "10ER Log Sheet" in order to determine the status-of 10ERs and to make a selection of both open and closed reports to evaluate program implementation (see Attachment 2). A total of eight closed reports, including five NRC information notices, two INP0 significant event

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reports (SERs), and ono )otential 10 CFR Part 21 report, were selected and reviewed in terms of tecinical assessments, responses from cognizant individuals and grou)s, and establishment of internal commitments and their incorporation into tie CTS.

The inspectors also verified that the committed actions had been implemented by review of documentation associated with those actions (e.g., preventive maintenance tasks, procedural revisions, training lesson plans, and training attendance sheets)luding one NRC information The inspectors also selected

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seven reports that were shown to be open, inc notice, one INP0 operating plant experience report, one INP0 SER, and four INP0 SOERs.

The purpose for selecting open reports was to verify that they were being actively tracked and that actions / evaluations were in-process.

The inspectors also noted that the four SOERs had been previously closed, but recently reopened with respect to Unit 2.

Several review efforts had been undertaken, including ISEG's assessment (IAR 92-09) and plant analysis'

September / October 1992 10ER Review, to assess 10ER completion status and potential impact on Unit 2.

These reviews determined that certain recommendations contained in eight SOERs had been closed based on actions taken with respect to Unit 1, but consideration had not been given towards Unit I and 2 differences.

Therefore, those specific recommendations were reopened and are awaiting actions such as development of preventive maintenance procedures, test procedures, completion of baseline data, and training activities.

These items, considered highly visible by management, were 5eing tracked by plant analysis as part of their normal function.

Procedure HQA 2.30 required the issuance of a monthly report, "Open 10ER Recommendations," to senior station management in which the status of all open 10ER recommendations were to be presented.

The inspectors reviewed the monthly reports for July, August, and September 1992, and found them to be consistent and accurate.

The inspectors also reviewed the background and technical qualifications of the plant analysis personnel responsible for performing assessms_ts and

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evaluations of incoming 10ERs and determined that all of the personnel were well qualified.

The inspectors noted a proactive posture with respect to the 10ER program.

One example had to do with a review, by plant analysis, of 10ERs applicable'to refueling outages and the compilation of " lessons learned" into a document which became part of the refueling manual being used for the current Unit I refueling outage (IRF02).

2.3 Conclusions With the exception of the minor procedural weakness noted in paragraph 2.1, the inspectors considered the 10ER program to be well defined and to be effectively implemented.

As previously noted, the program recently underwent a major revision, which included a number of program enhancements -

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FOLLOWUP DN CORRECTIVE ACTION FOR A VIOLATION (92702)

1[losed) Violttion 445/9204-01:

Failure to Scan the Weld in Both Circumferential Directions durina Ultrasonic Examination of a Pioina Weld for Inigrvice Insocction The inspectors reviewed ONE form FX92-155 and the corrective actions taken by the licensee in response to the violation. The corrective actions included the re-examination of the weld during the second Unit I refueling outage and the review of all examination data sheets performed during Unit I refueling outage by a TV Electric Level 111 inspector to ensure all incomplete

examinations are documented on limitation sheets.

The inspectors witnessed the satisfactory ultrasonic examination of the weld on November 4,1992, in addition, the inspectors reviewed the corrective actions taken to preclude recurrence, which included an audit of the inservice ins)ection and testing programs and two surveillance activities documented by tie independent safety engineering group.

The audit and surveillance activities were documented in TV Electric Operations QA Audit Report QAA-92-123 and Independent Safety Engineering Group Field Note Sheets ISEG-FN-267 and 270.

The corrective actions were satisfactorily completed by the date specified in the response to the violation.

4 FOLLOWUP (92701)

(Closedi_Jainsction followuo item 445/9231-03: 446/9231-03: Review of Licensee's Actions Recardino Generation. Trackina and leolementation of Internal Commitm6nts Associated With Industry Operatina Experience Reports.

The inspectors reviewed Nuclear Overview Department Procedure HQA 2.30,

' Industry Operating Experience Report Review Program," Revision 1 dated August 14, 1992.

This revision established the responsibilities and requirements for tracking internal commitments resulting from operating experience information in the commitment tracking system.

The inspectors selected 15 10ERs - 8 closed and 7 open - (see Attachment 2)

and verified that the internal commitments initiated as a result of the 10ERs had been entered into the commitment tracking system and had been, or were being, tracked.

The inspectors also verified that-the actions required by closed internal commitments had been implemented.

Based on'the-results of the inspectors' review, it appears that the licensee had implemented the requirements established by Revision 1 to Procedure NQA 2.30.

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s ATTACHMENT 1 1 PERSONS CONTACTED 1.1 Licensee Personngl

• L. Bradshaw, Stipulation Activities

• H. Bruner, Senior Vice President

• H. Blevins, Director of Nuclear Overview

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• D. Davis, Manager, Plant Analysis

• D Dillinger, Staff Engineer

• N. Harris, Licensing Engineer

• K. Kirwin, Senior Engineer

• F. Hadden, Manager, Hechanical Engineering

• R. Hays, Supervisor, Hechanical Codes and Standards

• D. McAfee, Manger, Quality Assurance

• J. Huffett, Manager, Design

• D. Pendleton, Unit 2 Regulatory Services Manager

• D. Ranstrom, Quality Engineering Supervisor

• C. Rau, Unit 2 Project Manager

• W._Riess, Special Projects Supervisor

• H. Riggs, Special Projects Manager

• S. Sawa, Unit 2 Projects

• C. Terry, Vice President, Nuclear Engineering and Support 1.2 Stone & Webster Enaineerina Company

• J. DeBouis, Codes and Standards, ISI

• F. Maggio, Special Projects 1.3 (ASE

• 0. Thero, Consultant 1.3 NRC Personnel

• W. Jones, Senior Resident inspector

• D. Graves Senior Resident inspector

• P. Goldberg, Reactor Inspector

• H. Runyan. Reactor Inspector

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• R. Vickrey, Reactor inspector

• Denotes those personnel who attended the exit meeting conducted November 6, 1992.

2 EXIT HEETING-An exit meeting was conducted on November 6, 1992. -During this meeting, the inspectors reviewed the scope and findings of the inspection.

The_ licensee did not identify as proprietary, any information provided to, or reviewed by the inspectors.

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ATTACHMENT 2 IDENTIFICATION OF EVALUATED 10ERs CLOSED SER 24-91 SER 25-91 IN 89-92 Supplement 1 IN 90-49 IN 91-13 IN 91-82 IN 92-43 10 CFR Part 21 Report from Fisher Controls dated March 5, 1991 OPEN IN 91-83 OE 5088 SER 05-92 SOER 86-03 SOER 88 03 SOER 89-Oi SOER 90-01

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