IR 05000445/1992062
| ML20034E448 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/16/1993 |
| From: | Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20034E446 | List: |
| References | |
| 50-445-92-62, 50-446-92-62, NUDOCS 9302260172 | |
| Download: ML20034E448 (16) | |
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i APPENDIX B j
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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Inspection Report:
FO-445/92-62
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50-446/92-62 i
Operating License: NPF-87 j
Construction Permit:
CPPR-127 l
Expiration Date: August 1, 1995 lj Licensee: TU Electric Skyway Tower s
400 North Olive Street j
Lock Box 81 j
Dallas, Texas 75201
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Facility Name: Comanche Peak Steam Electric. Station, Units 1 and 2 j
i Inspection At: Glen Rose, Texas
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Inspection Conducted: December 14, 1992, through January 21, 1993 Inspectors:
W. B. Jones, Senior Resident Inspector l
G. E. Werner, Resident Inspector l
l Approved:
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L. A. Yandell, ~ Chief,7roject Section B Date Division of Reactor Proj: cts j
Inspection Summary
i Areas Inspected (Units 1 and 2): Special, announced inspection to review l
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programmatic and implementation concerns with the station temporary j
modification program. The ' inspection also reviewed the effectiveness of j
previous corrective actions to correct repetitive deficiencies with the j
temporary modification program.
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Results (Units 1 and~2):
i A violation was identified for the failure to establish adequate i
e measures to assure that vital station drawings, located in the j
work ' control center and clearance processing cente'r,.were posted j
with active temporary modifications- (Section 2.1.1).
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The licensee did not promptly initiate appropriate compensatory
measures, including a review of active clearances and temporary
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modifications, to adequately assure personnel safety. and protection of-i plant equipment'(Section'2.1.1).
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A violation with four examples was identified for the failure to take
prompt and effective corrective action to prevent repetitive temporary modification program and implementation deficiencies (Sections 2.1.1, 2.1.2, and 2.2.1).
Immediate corrective action recommendations made by the Operation
notification and evaluation (ONE) form originator were not promptly considered to assure that plant systems were configured in accordance with the clearance report (Section 2.1.1).
A violation was identified for the failure to implement adequate
administrative procedures for controlling equipment status (Section 2.1.2).
The Independent Safety Engineering Group identified numerous
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deficiencies with implementation of the temporary modification program; however, they were not effective in assuring that these deficiencies were resolved. The Unit 2 task team performed an effective review of the construction temporary modification program (Section 2.3.1).
The licensee's trending of outage configuration control issues was not
sufficiently selective to identify the adverse trend with the temporary modification program implementation. The offsite review committee
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demonstrated an appropriate awareness for emerging temporary modification program concerns (Section 2.3.1).
The licensee's interim corrective actions have been effective in
preventing further temporary modification program implementation problems (Section 2.4.1).
Summary of Inspection Findings:
Violation 445/9262-01; 446/9262-01 was opened (Section 2.1.1).
- Violation 445/9262-02; 446/9262-02 was opened (Sections 2.1.1, 2.1.2,
and 2.2.1).
Violation 445/9262-03 was opened (Section 2.1.2).
- Unresolved Item 445/9247-03 was closed (Section 2.6).
- Attachment:
Attachment - Persons Contacted and Exit Meeting
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I DETAILS I
1 PLANT STATUS (71707)
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t At the beginning of this inspection period, Unit I was in' Mode 3 with the j
second refueling outage activities in progress.. Unit 1 entered Mode 2 on
December 25 and Mode-1 on December 26, 1992.
Reactor power was at 100 percent j
at the.end of the-inspection period.
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During this inspection period for Unit 2, the preoperational test program was
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essentially completed, with test and retest deferrals identified and-approved.
All systems, buildings, rooms, and; areas were turned over to nuclear -
j operations. The radiological control area was expanded to include the Unit 2 containment and safeguards buildings. All site activities, as of December 21, 1992, came under the control of Nuclear 0perations programs, with the exception of identified and management approved items previously initiated j
under construct;on and/or startup programs, i
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2 TEMPORARY MODIFICATION (TM) PROGRAM FOLLOWUP (92702)
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i During a previous inspection period,- October 11 through November 25, 1992, the l
inspectors noted that several configuration control implementation issues-had been identified by the licensee. The scope of these' issues is identified in
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NRC Inspection Report 50-445/92-47; 50-446/92-47,. paragraph-2.3. Based on an
initial review of these issues, Unresolved Item 445/9247-03 was initiated to determine whether the licensee's corrective action program was effective in promptly identifying and correcting repetitive configuration control issues.
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i This special inspection was conducted to review programmatic-and
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implementation concerns with the station temporary modification program and to
evaluate the adequacy of-interim corrective actions to assure that potential
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safety concerns-were being resolved.
t The inspectors noted that the TM program appeared to have a significant number
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of challenges to the system which had resulted in implementation deficiencies.
i On December-30' the inspectors met with licensee management personnel.. to review
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the specific areas of concern. The inspectors noted that there appeared to be
several recurring implementation deficiencies with the TM program.
2.1 TM Program Implementation The licensee implemented Station Administrative Procedure STA-602, " Temporary
Modifications," to establish the requirements and methods for controlling activities that temporarily alter the design function of a system or component. The procedure also provided for the periodic review of TMs.to verify their accuracy and applicability.
Revision 10 to this procedure was approved by the Station Operations Review Committee on February 19, 1992, and became effective May.II, 1992. This revision ~was in effect during this
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inspection period.
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On December 30 the inspectors reviewed TM 92-1-103, Revision 1.
This TM provided a connection from the temporary boric acid batching tank to increase the boric acid batching capability for refilling the boric acid storage tanks (CPX-CSATBA-Ol[02]).
This TM was installed on December 11, 1992, as authorized by Work Order 4-92-030366-00.
During this review, the inspectors noted that the TM affected vital station Drawings M1-0257, " Chemical and Volume Control System," and M1-0259, " Boron Recycle System." The inspectors verified that the controlled drawings in the
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main control room reflected the TM. However, it was noted that the controlled drawings in the work control center (WCC) only identified the configuration
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changes on vital station Drawing M1-0257.
Criterion VI of Appendix B to 10 CFR Part 50 and Comanche Peak Steam Electric Station Final Safety Analysis Report, Amendment 81, Section 17.2.6, " Document Control," state that measures shall be established to control the issuance of documents such as instructions, procedures, and drawings thereto, which
prescribe all activities affecting quality.
These measures shall assure that i
documents, including charges, are reviewed for adequacy and approved for release by authorized personnel and are distributed to, and used at the location where, the r,rescribed activity is performed.
The inspectors
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determined that Administrative Procedure STA-602 did not establish adequate measures to as.sure the drawings, posted with active TMs, were maintained at
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the location where the prescribed activity is performed. The inspectors i
identified the failure to establish adequate measures for issuing documents, including changes for use at the location where the prescribed activity is performed, as a violation of Criterion VI of Appendix B to 10 CFR Part 50 (445/9262-01; 446/9262-01).
Operations shift order dated October 20, 1992, established a separate WCC (clearance processing center [CPC]) in the turbine building. The CPC provided for clearance preparation, authorization, issuance, and acceptance.
Responsible. work organizations were to receive work order authorization from the CPC for noncritical path-work activities. The responsible work organization would walk down the clearance and the CPC was responsible for resolving any problems. After the work activity was completed, the CPC would review the work order and remove the clearance.
On December 30, 1992, the inspectors identified that the CPC controlled vital station drawings, used to impact and verify clearances and work orders, had not been posted with TMs.
The failure to establish measures at the CPC for issuing vital station drawings, including changes resulting from active TMs,
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is identified as a second example of violation (445/9262-01; 446/9262-01).
The.licensco was promptly notified of both findings. The WCC vital station drawing, M1-0259, was revised to' reflect TM 92-1-103. Although this issue was
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identified December 30, ONE Form 93-082 was not issued until January 8, 1993,
to address the concern that a WCC vital station drawing had not been posted l
with the TM change.
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The licensee initiated ONE Form 93-012 to address the use of. controlled
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drawings'in the CPC which were not posted with the TM changes. ONE Form 93-012 was initiated on December 30, 1992, at 4:27 p.m. and the shift supervisor signed it the following day at 5:39 a.m.
In the ONE form condition description and comments section, the originator identified two specific corrective actions which should be taken. These were to:
(1)-identify current TMs on CPC drawings; and (2) review clearances that were processed in
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the CPC to assure that no adverse impact was caused by a TM. The inspectors learned that the vital station drawings in the CPC were not updated until
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January 4,1993.
It was noted that clearances continued to be processed i
through the CPC from December 30 through January 4. -The impact review for the i
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66 installed Units 1 and 2 clearances was not completed until January 7.
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The inspectors reviewed ONE forms and licensee oversight documents which i
identified deficiencies related to posting active TMs.to the WCC and control i
room vital station drawings. These findings spanned a period of approximately i
7 months and identified examples where TMs were not: accurately posted to the
vital station drawings.
ONE Form 92-651 was initiated on July 10',' 1992,'concerning TM'92-1-13. An.
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active TMs in the control room (ISEG Field Note 92-192). He identified that j
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control room-vital station Drawing M1-0235 had a working copy drawing attached
which showed a blind flange downstream of Valve XSF-0202 and a flush bonnet
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upstream of the valve. The TM did not' include a blind flange or flush bonnet
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by Valve XSF-0202. This ONE form was dispositioned by correcting the drawing.
ONE form 92-652 was initiated at the same time because three active TMs that impacted control room vital.- station drawings were not posted. This ONE form was dispositioned by updating the effected drawings.
ONE form 92-821 was. initiated on August 19, 1992, as a' result of the.
operations department review of the TM program. This review identified 11 control room vital station drawings which were impacted by six TMs but were
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- not identified on the vital station drawings.
Similar: deficiencies were found-for the WCC vital station drawings wnere 11 drawings were not posted. for five TMs.
In addition, two'open TM packages'were found missing from the control room.
On September 30,1992,.ISEG performed a followup review (ISEG Field.
Note 92-248) which identified additional problems with vital station drawings not reflecting active TMs.
ONE Form 92-981 identified' findings.from October 8,1992, that control. room
' vital station' drawings were' not being maintained to reflect active'TM status.
xTM,92-2-003 was. posted on Drawing El-0076, sheet-33, although it was not
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installed. An additional 21 drawings were found marked up-to reflect
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l TM 91-001037, although it was not installed.
The WCC review committee
indicated that the nuclear oversight department would research the ONE form l
history for TM issues and then review the findings with the ONE form committee
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l to determine the appropriate corrective actions. On October 10, 1992, j
l document control issued all new vital station drawings for the control room.
i The drawings were then updated to reflect active TMs. An October 21, 1992, due date was established to disposition the ONE form.
QA Audit QAA-92-129, " Document and Record Control Program," was~ performed s
during the period of October 12-26, 1992.
Based on a review of 28 TMs, four i
control room and seven WCC vital station drawings were identified as not having been marked up to reflect 9 TMs.
The audit team concluded that the
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document and record control program was being satisfactorily implemented.
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Increased management attention was recommended in the area of " intermediate
storage of QA documents," as described in ONE Form 92-1258.
Also, the audit i
team recommended that some of the Comanche Peak Steam Electric Station
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organizations needed to improve in meeting the 60-day requirement for vaulting
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I QA records and on maintaining their controlled documents current.
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the report identified several examples where vital station drawings were not being adequately maintained, the report concluded that administrative services
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was doing an effective job of implementing the document and record. program and in supporting the project with its needs in these areas. The audit report TM i
findings were added to ONE Form 92-981 findings and the resolution assignment changed to that of a QA deficiency. The due date was extended to January 6, 1993. The inspectors noted that, as of January 8, the corrective actions to resolve the QA deficiency specified in ONE Form 92-981 had not been identified and returned to the QA organization. Based on a discussion with the QA manager, the corrective actions would be developed from the TM task force.
The inspectors noted that an extension to the due date had not been m "mted.
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ONE Form 92-1561 was initiated on December 17, 1992, when an ISEG engineer
performed a review of three TMs associated with Unit 2 and determined that the
control room vital station Drawing M2-0249-02A was not posted with TM 92-2-15.
l This ONE form was closed based on the deficiency being corrected. On January 7,1993, it was identified by the inspectors and the licensee that vital station Drawing M2-0249-02A (issued on December 21, 1992) had not been posted with active TM 92-2-15.
The licensee determined that the TM had been incorrectly posted against Unit 1 vital station Drawing M1-0249-02A. This-later finding is documented in ONE Form 93-065.
l On January 4,1993, plant engineering performed an audit of the vital station drawings in the control rocm, WCC, and CPC. The results identified 12 drawings which were not marked up to identify the active TM. The audit results-also identified the need to provide the CPC with Unit 2 active TMs.
i The drawings were updated later the same day.
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Criterion XVI of Appendix B to 10 CFR Part 50 and Comanche Peak Steam Electric
Station Final' Safety Analysis Report, Amendment 85, Section 17.2.16, j
" Corrective Action. " state that measures shall be established to assure that j
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conditions adverse to quality such as failures, malfunctions, deficiencies, j
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i deviations, defective material and equipment, and nonconformances are promptly i
identified and corrected.
In the case of significant condition adverse to j
quality, measures shall assure that the cause of-the condition is determined j
and corrective action taken to preclude repetition, j
U The inspectors identified the failure to take adequate corrective actions to assure controlled vital station drawings accurately reflected active TMs as a i
violation of. Criterion XVI of Appendix B to 10 CFR-Part 50 (445/9262-02-446/9262-02).
2.1.2 TM Impact on Clearances On November 11, 1992, electrical maintenance personnel were preparing to begin work on safety-related Transformer CPI-ECTRET-02, in accordance with Work
Order 1-92-000911-00. Clearance 1-92-01073 was implemented to deenergize the
transformer. After electrical maintenance had performed a walkdown and
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accepted the clearance, the technicians identified, at the ~startL of the work
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activity, that the transformer was still' energized.
It was then identified
that TM 92-1-66 had been installed and was supplying temporary power to-the transformer. The TM.had been installed after the clearance impact was -
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performed. The clearance was not reviewed again prior to being implemented to l
determine if an active TM would require the clearance boundary to be modified.
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ONE Form 92-1214 was initiated-to document this event. The immediate corrective actions taken were to review Train ~ A electrical. clearances against
active temporary modifications to determine if any of them required revision.
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No'further corrective actions were. initiated to determine the cause for the TM
not being reviewed against-the clearance or if:a programmatic concern' existed.
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On December 3,1992, electrical maintenance personnel identified <that -
nonsafety-related Train C Transformer CPX-EPMLNB-21 was: energized because of
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TM 92-X-43-3.
Clearance Order X-92-02849 had been' accepted by electrical i
maintenance in preparation to' perform Work Order 3-92-324011-01. The.TM was identified following acceptance of the clearance. Again, the clearance had j
not been reviewed after it was initially prepared to determine if it was
impacted by-~an active TM.
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Technical Specification 6.8.la requires that written procedures shall be
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established, implemented, and maintained covering the _ activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978.
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Appendix A to Regulatory Guide 1.33, paragraph la, requires.that
admi'nistrative procedures.be developed for controlling equipment' status (e.g.,
locking and tagging). Administrative Procedure STA-605, Revision 11,.
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" Clearance 'and Safety Tagging," Section 2.2, establishes the ' applicability of this procedure tol identify the established forms, tags, and documents that are necessary for the~ users of this' procedure to adequately impact, prepare,. hang, log, and restore clearances. Section.4.2 defines the ~ clearances as assurance:
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that a component, subsystem, or ' system 'is isolated or configured as specified on the. clearance report. The inspectors' identified the' failure to' establish adequate plantistatus controls as required by Technical Specification 6.8.'la,
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Regulatory Guide 1.33, and implemented by Administrative Procedure STA-605, l
Revision 11, as a violation (445/9262-03).
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ONE Form 92-1420 was initiated to document the event. The licensee subsequently identified that Transformer CPX-EPMLNB-24, which had been tagged out using the same clearance, was energized because of TM 92-1-30.
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licensee identified that the corrective action associated with this ONE form
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is to be addressed as part of ONE Form 92-1214.
No additional corrective
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actions were identified. The inspectors noted the failure to take adequate
corrective actions to identify and correct the cause for the safety-related
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Transformer CPI-ECTRET-02 being energized on November 11, 1992, after
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Clearance 1-92-01073 was implemented, contributed to the repetition of the i
problem on December 3, 1992. This is identified as an additional example of a
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violation of Criterion XVI of Appendix B to 10 CFR 50 (445/9262-02; j
446/9262-02).
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2.1.3 Conclusions i
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A violation _was identified for the failure to establish adequate measures to i
assure that vital station drawings, located in the WCC and CPC were posted l
with active TMs. This deficiency also included vital station drawings located
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in the control room.
- The corrective action recommendations to adequately assure personnel safety and protection of plant equipment were not appropriately considered for the
CPC control drawing deficiency.
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A violation was identified.for the failure to take prompt and effective corrective action to prevent repetiti"- TM program and implementation j-deficiencies. Numerous examples were identified bylthe licensee where vital
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station drawings were not being maintained to reflect active temporary
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modifications. This finding was also identified by the QA organization but did not_ result in prompt' corrective actions being taken. A second example-involved the failure to identify and correct-the deficiencies, which resulted in the transformers remaining energized after the clearances to deenergize
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them were implemented.
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A violation was identified for the failure to implement adequate administrative procedures for controlling equipment status.
i 2.2 Adeauacy of Previous Corrective Actions
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.2.2.1 Discussion The licensee initiated ONE Form 91-0555, on April 18, 1991. The conditions description and comments section. identified that several concerns regarding the-TM process were: identified during the mid-cycle outage.
It was requested that this ONE. form be-dispositioned as a plant incident report and resolved.-
per Administrative. Procedure STA-422,. " Processing of Operation Notification and Evaluation (ONE) Forms."
An additional concern noted in the.ONE form,
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1-9-based on discussion with operators, was that during the preparation of clearances in work control, the active TMs had not been available for review.
Also, it was requested that the plant incident report resolution include a review of TMs performed during the midcycle outage to identify any additional concerns. The inspectors reviewed the ONE form and supporting documentation
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and noted that the due date was May 19, 1991. At the end of the inspection period, the plant incident report had not been dispositioned, nor was it apparent that any corrective actions specific to the plant incident report had been taken. The failure to disposition and implement corrective action to resolve the deficiencies identified in Plant Incident Report 91-0555 is an additional example of a violation of Criterion XVI of Appendix B to 10 CFR Part 50 (445/9262-02; 446/9262-02).
The licensee initiated ONE Form 92-0668 on July 14, 1992, to document a potential TM configuration concern.
TM 91-1-052 had been implemented to isolate leakage from Unit 1, Loop 1, steam generator blowdown line Valve MS-0663. This TM was installed at two locat.ons along the line to effectively isolate the leakage, however, only one isolation point was removed and the TM closed. The presence of the second isolation point was not documented. During a visual inspection (VT-2) inside the containment prior to completion of the first refueling outage, the second isolation point was identified and a work request initiated to replace the pinched line. The WCC review committee identified two actions to be completed to resolve the design deficiency and to affect the design / engineering resolution. The first item was specified to mechanical maintenance to rework the line. The second item was assigned to plant engineering to revise TM 91-1-052 to reflect the second isolation point. An August 15, 1992, due date was established for both actions.
On November 16, 1992, while attempting to drain Steam Generator 1, it was
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found that the line downstream of the flex hose was crimped and a TM 91-1-052
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tag was hung in the area. ONE Form 92-1254 was initiated to address the procedural deficiency and to rework the pipe.
The resolution to ONE Form 92-1254, completed on December 7, concluded that there were no generic concerns. No reference to ONE Form 92-0668 or the WCC committee recommendation for design / engineering to revise TM 92-1-052 was provided.
Although not a plant safety significant condition, this failure to resolve the deficiency documented in ONE Form 92-0668, which resulted in the inability to drain the steam generator, is identified as an additional example of a violation of Criterion XVI of Appendix B to 10 CFR 50 (445/9262-02; 446/9262-02).
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2.2.2 Conclusions A violation was identified for the failure to disposition and implement corrective actions to resolve the deficiencies identified in the Plant Incident Report. A violation was identified for the failure to resolve a deficiency documented in a ONE Form. This was caused, in part, by the failure to appropriately consider the recommendation of the WCC review committe _
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2.3.1 Discussion
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The inspectors reviewed the latest QA audit which addressed the Unit 1 design modification process.
This audit was performed June 3 through July 3, 1991,
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and the results are documented in Operations QA Audit File QAA-91-124. The
audit team found that the Unit I design control program was satisfactory. The
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audit team documented that they reviewed two TMs.
Based on their observations, the audit team concluded that TMs were being implemented in accordance with Procedure STA-602 requirements.
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The ISEG surveillance activities identified several TM implementation concerns in July 1992. Later, ISEG identified that the administrative concerns had been addressed, but several implementation deficiencies were still occurring.
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These deficiencies involved control of vital station drawings to accurately
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.eflect active TMs.
In December 1992 ISEG identified an additional example where control room vital station drawings did not reflect an active TM. Th5
inspectors noted that ISEG surveillance activities during the second refueling outage did not include the TM program, an area which was expected to be significantly challenged.
During an inspection conducted July 27-30, 1992, an inspector identified that a TM installed under the construction TM program, was not identified in the control room TM index. Additional TMs were identified which had been removed
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t but had not been removed from the control TM index. The results of this inspection are documented in NRC Inspection Report 50-445/92-28; 50-446/92-28,
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Section 2.2.
The violation of the licensee's construction TM procedure was identified as a noncited violation.
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The licensee initiated a task team on September 23, 1992, to evaluate a list i
of deficiencies identified in TU Evaluation Form 92-6302. This TU Evaluation
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identified recurring deficiencies with the Unit 2 TM program.
The report was
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subsequently issued on October 20.
Several weaknesses were identified with the Unit 2 TM program. The significance of the deficiencies was determined to
be Category 3 (marginal consequences). The task team recommended that the plant analysis manager include the results from the task team in the evaluation of the Unit 1 TM program. This report was transmitted to the plant analysis manager on October 26, 1992. The inspectors noted that the task team I
report was issued at approximately the same time Unit 1 entered the second refueling outage.
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The licensee initiated Analysis of Repetitive Concerns 92-11-01, on November 13, 1992, because of an increasing number of ONE forms associated with configuration control issues.
Based on a review of the trend graph and a listing of the associated ONE forms, the licensee initiated regularly scheduled plan-of-the-day breakout meetings. The inspectors attended the breakout meeting held on November 13, 1992, which concluded that the ONE forms
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in this area would be closely monitored by the ONE form committee during the outage and that an assessment of the concern would be conducted following the
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outage.
On November 16 the Vice President, Nuclear Plant Operations issued Memorandum CPSES-9242536 on configuration control. This memorandum identified that, although none of the issues alone represented a significant threat to configuration control, an adverse trend was developing.
Interim actions were established to review the clearances against the Train A TM for the pending Train A outage; the engineering and nuclear overview organizations would evaluate the hardware and implementation issues to determine if action was required, and the WCC and nuclear overview would continue to monitor the trend
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and provide feedback to management.
In addition, it was identified that a task team would be formed after the outage to review the configuration control issues.
The inspectors leviewed the offsite review committee meeting minutes (92-05)
for the December 9 and 10, 1992, meeting. During the previous offsite review committee meeting, an action was initiated to identify deficiencies in the TM program. During the latest meeting, the system engineering manager provided an overview of TM problems and the corrective actions being implemented. The overview identified both administrative and technical problems with implementing the TM program. The administrative problems / corrective actions taken or pending were as follows:
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Problem - TMs were open greater than 90 days without additional
justification. Action - Delete requirement in next procedure revision.
Problem - TMs not reviewed by station onsite review committee (SORC)
within 14 days of being implemented. Action - Consider providing SORC review prior to implementing TM.
Problem - No engineering postimplementation review.
Action - Training
provided.
Problem - Expected duration of TM exceeded. Action - Delete requirement i
because TM package provides the technical requirements for installation and/or removal.
Problem - System engineering semi-annual TM walkdowns not completed in a
timely fashion. Action - Reemphasize managements' priorities.
The technical problems / corrective actions taken or pending were as follows:
Droblem - TMs not accurately reflected on vital station drawings in the
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control room or WCC. Action - Increase awareness and self audit.
Feviewing improved process for next procedure revision.
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I Problem -- TM not installed in accordance with the design requirements.
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Action - flone; this was considered an isolated event.
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Problem - Plant equipment unexpectedly deenergized because TM-interface i
not adequately identified. Action - Training conducted and all TMs
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reviewed for proper tagging and operations procedure impact.
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Problem - Pending clearances not properly impacted after TM installed.
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Action - Electrical TMs were "re-impacted" after second. incident and l
i shift order issued to specify management expectations.
Problem - TM not properly restored. Action - None; this was considered
an isolated event.
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2.3.2 Conclusions
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't The ISEG organization identified. numerous deficiencies with_ implercentation of-l the TM program; however, they were.not effective in assuring these
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deficiencies were resolved. The Unit 2 task team performed an effective-
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review of the construction TM program.
The licensee's trending of outage configuration control issues was not i
sufficiently selective to identify the adverse trend with the TM. program implementation. The offsite review committee demonstrated an appropriate-awareness for, emerging TM program concerns.
2.4 Interim Corrective Actions
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2.4.1 Discussion
On January 15, 1993, a management meeting (open for public. observation)
was held at the NRC staff's request to review the TM deficiencies' and the
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corrective actions taken. The licensee provided an assessment of the TM
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implementation deficiencies and their interim corrective actions to prevent recurrence until the TM task. team findings are finalized and long-term corrective actions are implemented. This is documented in NRC Meeting Summary
dated January 22,-1993. The licensee identified that the following' interim improvements had been implemented.
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i Establish a dedicated TM coordinator with no other collateral duties.
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Provide. daily' reports to operations.on vital station drawings affected
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Conduct shiftly reviews of vital station drawings affected by TMs in i
control room and' clearance processing center.
Conduct daily. review'of vital station drawings affected by-TMs in'WCC.
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SORC approval is now required prior to TM implementation.
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All TMs must now have an engineering technical review performed.
Additional verification is required of TM implementation.
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t Operations support personnel will review TMs prior to shift supervisor I
" installation complete" signature.
- i TM coordinator will review all TM packages to assure administrative
I compliance.
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Operations will evaluate TM impact on all " accepted" and " prepared"
clearances prior to shift supervisor authorization for installation.
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Operations has evaluated " accepted" c1'earances for impact by installed'
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TMs. No deficiencies such as the energized transformer events were
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identified.
The licensee indicated that all interim corrective actions were in place and being implemented as of January 8,1993. The inspectors subsequently verified
that the identified interim corrective actions were in place and'being
performed.
2.4.2 Conclusions
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t The licensee's interim corrective actions have been effective in preventing i
repetitive TM program implementation problems.
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The licensee was not effective'in identifying and correcting repetitive TM i
program implementation deficiencies which occurred during the second refueling outage. Similar deficiencies had been identified as early as May 1991 but were not appropriately dispositioned. Although the observed deficiencies did
not result in significant challenges to the plant, personnel safety was
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adversely impacted because established equipment status controls did not account.for equipment configuration changes resulting 'from implementing TMs.
l 3 FOLLOWUP (92701)
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(Closed) Unresolved Item 445/9247-01: Configuration control The : inspectors reviewed the three configuration control events which were identified-in NRC Inspection Report 50-445/92-47; 50-446/92-47 as Unresolved Item 445/9247-03.
Based on this review, it was' determined that the licensee
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was addressing the configuration control issues as-part of the' task force
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identified on November 16,_1992. However, it was also identified that the
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licensee's evaluation and corrective actions; associated with the TM program j
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-14-deficiencies were not adequate and have been classified as violations of NRC regulatory requirements and documented as such in this inspection report.
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ATTACHMENT I-i 1 PERSONS CONTACTED j
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1.1 TU ELECTRIC
I 0. Bhatty, Site Licensing
R. D. Bird, Jr. Manager, WCC i
- M. R. Blevins, Director of Nuclear'0verview
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W. J. Cahill, Group Vice President, Nuclear Engineering and Operations R. R. Carter, Assistant to Manager, Maintenance
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J. R. Gallman, Trend ' Analysis Manager W. G. Guldemand, Manager, Independent Safety Engineering Group l
T. A. Hope, Site Licensing Manager l
- J. J. Kelley, Vice President, Nuclear Operations
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J. J. LaMarca, Manager, Engineering Outage
B. T. Lancaster, Manager, Plant Support
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D. M. McAfee, Manager, QA
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S. S. Palmer, Stipulation Manager
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D. J. Reimer, Manager, System Engineering E. J. Schmitt, Operations / Engineering Training Manager i
L. H. Strope, Plant Analysis i
B. B. Taylor, Staff Assistant, Plant Operations i
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R. O. Taylor, Manager, Administrative Services
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l C. L. Terry, Vice President, Nuclear-Engineering and Support
R. D. Walker, Manager of Regulatory Affairs for Nuclear Engineering j
t 1.2 NRC Personnel t
L.-A. Yandell, Chief, Project Section B D. N. Graves, Senior. Resident Inspector, Construction
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The personnel listed above attended the inspection findings status meeting.
l In addition to the personnel-listed above, the' inspectors contacted other personnel during this inspection period.
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- Attended the January 21, 1993, exit meeting.
2 MANAGEMENT AND EXIT MEETING
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The licensee was provided with an inspection finding status on December 30, l
1992, during the exit meeting for NRC Inspection Report 50-445/92-59; j
50-446/92-59.
A management meeting was' held on January 15, 1993, to review
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the licensee's management assessment of the inspection findings and their l'
interim corrective actions. The exit meeting was conducted on January 21, 1993. During this meeting, the inspectors reviewed the scope and findings of
the report. The licensee did not identify as proprietary, any information
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provided.to,-or reviewed by the inspectors.
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