ML19325C397

Informs Commission of Readiness to Load Fuel at Plant & Recent SALP Evaluation Process & Proposed Rept.Expresses Concern That Info & Finding Brought to Attention of Board Deliberately Excluded & Given False Impression Re Plant

ML19325C397
Person / Time
Site:	Comanche Peak
Issue date:	10/04/1989
From:	NRC
To:	NRC COMMISSION (OCM)
Shared Package
ML19325C388	List: ML19325C387 ML19325C396 ML19325C397 ML19325C398 ML19325C401 ML19325C408
References
NUDOCS 8910160165
Download: ML19325C397 (44)

Text

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f OCT 4 1989 Nemorandum Fort chairman, U. 8. Nuclear Regulatory commission Washington, D. C.

20555 a

From:

WRC Staff Inspectors subjects comanche peak's Fuel Load Readiness and the Systematic Assessment of Licensee J

performance (8 ALP) 1 This memorandum is to inform the commission abou4 the readiness to load fuel at Comanche Peak, and the recent SALP uvaluation process and the proposed report.

As.NRC inspectors, it is our concern that the pending SALP report is neither accurate.nor complete reflection of-TU Electric's perf ormance during this S ALP period.

i We believe that the commission should be aware of what we view as manipulation and the exclusion of f actual information.- !! such l

o Information were properly considered and evaluated, it would indicate a less than satisfactory performance rating in some areas, a need for increased attention and applicant action prior J

L to WRC approval to load fuel.

i The SALP conclusion, which gives the applicant a rating of

• 2" in every area and identifies no adverse performance trends.is i'

incorrect'and invalid.

Ten NRC managers made up the SALP Board.

Three were Region IV managers who had no direct and siginificant involvement with the site.

Two other board members were involved i

with site matters but they administered their pro $ect management o

l and licensing duties from their White Flint offices.

NRC Senior 1

Resident / Resident and Consultants who were entirely knowledgeable I

of licensee performance had no vote on the board.

All of the recommendations for below average, coming from those who were knew the real performance, were outvoted by managers on the SALP Board.

Additionally, information and findings brought to the attention of the SALP Board were deliberately excluded, giving a false impression about the plant.

For example, j

i 1.

The SALP Board did not adequately consider the full l

implications of certain ASME issues identified during -

reporting period by staff inspectors.

2.

The SALP Board did not adequately consider the inability of the applicant to recognize conditlocs potentially or actually adverse to quality as demonstrated by events surrounding service water system and the auxilarv feedwater system (check valves and motors).

3.

The SALP Board did not adequately consider the inability of the applicant to identify and evaluate root causes of of deficiencies and program failures necessary f or effective corrective action.

s 3910160165 891011 FDR ADOCK 05000443 A

PDC Encl 0Sure 1

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l In order to provide.the Commission evidence of some of the issues that are not being properly considered, we are attaching exemple pages f rom draf t inspection reports and internal menos.

Although other areas were also improperly considered, we believe these examples will support our concerns and provide the Commission a chance to correct this situation.

our greater concern, which is shared by many TU Electric's site i

personnel-1s that Comanche peak is simply not yet ready to load fuel.

In addition to the TU Electric's poor performance in some areas, TU Electric has a large number of open and unresolved items i

and a large construction / engineering staf f on site who are and will continue working on Unit 1.

This indictes they are not ready to load fuel.

Disregarding financial considerations, both the NRC

- and TU Electric know that a realistic fuel loading date is about six months from now, i f no additional major problems are found.

An additional consideration is TU Electric's excessive over reliance on contract personnel.

We are concerned that the applicant's unrealistic schedule to load fuel in October 1989 will l

compromise the agency's inspection efforts and the applicant's progress since 1984.

1

' Attachmentst (1) pages of-Draft Reports (2) Memoranda l

l cc: Corimes, Director OSP JTaylor, Deputy EDO BGarde, 2:1. Garde Law Office i

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o, INSPECTION PLAN FOR COMANCHE PEAK OPERATIONAL READINESS ASSESSMENT (ORAT) INSPECTION l

i 1.

Objective This inspection is being performed in accordance with draft Inspection Proce-dure IP 93806, ' Operational Readiness Assessment Team Inspections,' which is included as Attachment 1.

The objectivt of this inspection is to pruvide a i

tajor input and basis for a NRC determination of the startup readiness of the Comanche Peak Steam Electric $tation (CPSES). Operational readiness assess-l ucnts are required before issuance of the low power license, and before issuance of the full power license or during power escalation.

The major focus t

of the inspection will be the verification of an appropriate operating attitude j

well before fuel loading and initial criticality.

In addition, programs that control construction completion, procedural use and work assignments should have been phased out or merged with operational control programs. The inspec-i tion will also em action programs, phastae the effectiveness of manapement oversight, corrective root cause analysis, and the resdiness to support operations.

At the conclusion of the inspection we will provide a recommendation on whether t

the applicant can safely procetd to fuel loading and low power testing.

!!. _ Background I

The Comanche Peak Steam-Electric Station (CPSES) Units 1 and 2 are owned by

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TexasUtilitiesElectricCompany(TUEltetric)bPA),andTex-LaElectric a subsidiary of Texas Utilities Company (TUCo), Texas Mmicipal Power Agency (

Cooperative of Texas, Inc. (Tex-La).

TMPA is in the process of transferring i

their ownership interest to TU Electric and Tex-La is transferring their ownership to TU Electric in the near future.

The lead applicant is TU Elec-tric which has been cesignated Agent for CPSES by the owner-applicants. The facilityisastandard1160MWWestinghousefour-looppressurizedwaterreactor with a steel lined, reinforced concrete containment. The units are located in Glen Rose. Texas, approximately 40 southwest of Fort Worth, Texas.

The appitcant received a Construction Permit in December 1974 and had essen-l tially completed construction and preoperational testing and turned the systems over to operational control in 1984. The original architect-engineer was Gibbs and Hill; however, they were replaced by Stone and Webster after 1985.

Ebasco and Impe11 have also provided engineering support since 1965.

In 1982 numerous adverse allegations were received, most of which concerned construction adequacy and quality assurance.

These istues have been subsequently referred to as the 'Walsh-Doyle* issues.

In 1983 an NRC Construction Appraisal Team confirmed these allegations and the ASLB determined that TU Electric was not in accordance with Appendix B of 10 CFR 50.

TheOfficeofNuclearReactorRegulation(NRR)assem6ledaTechnicalReview Team (TRT)onsitein1984. The TRT included 50 technical experts from the NRC, national laboratories, and consulting organizations.

The TRT spent four months investigating the allegations and documented their findings in five supplementalSafetyEvaluationReports(SERs).

In addition, numerous concerns about the design and construction of the plant evolved through contentions before the NRC s Atomic Safety Licensing Board (ASLB) and the Comanche Peak Independent Assessment Program review conducted by Cygna Energy Services.

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In response to the concerns, the applicant imploranted the Comanche Peak Response Team (CPRT) in 1984 to address all relevant issues, existing and future. This program involved a re verification of the design and re-inspection of the construction of selected engineering disciplines.

In 1985 the design review was initiated. Based on the extent of deficiencies identi-f16d, TU Electric developes the Corrective Action Program (CAP) in 1987 to require a cosplete design re verificttion; hardware validation, including hardware re-inspection and modificationst and design and "as-bailt" reconcilia-tion in a broad number of areas. The development and implementation of the CAP for design and construction deficiencies typifies the aggressive and thorough approach that TU Electric management has applied to safety issues. This attitude is regularly demonstrated by TU Electric managers, several of whom are former NRC employees, but not always by the working staff.

In 1987, the NRC Office of Special Projects (0$P) was formed to ensure compre-hensive and timely resolution of complex regulatory concerns with a strength-ened and integrated staff organization and direct lines of mancgement responsibility and authority and appropriate high level direction. This Office was incorporated into the Office of Nuclear Reactor Regulation (NRR) in January i

1969 as the Associate Directorship of Special Projects and retains responsibility for all licensing and inspection activities.

j There has only been one recent escalated enforcement case completed.

In February 1989, the staff cited TU Electric with a Level !!! Violation for failure to submit a timely application for extension of the Unit I construction permit. The applicant had inadvertently allowed the original permit to expire.

There have been slightly over 1000 allegations received by the staff concerning Comanche Peak.

411 of the allegations received prior to formation of OSP have been closed. Of the remaining, approximately 13 remain open.

In July 1988, TU Electric reached an agreement with the remaining intervenor (i.e., Citizens Associated for Sound Energy) and the ASLB hearings were dismissed. As a result, Ms. Juanita Ellis, became a member of the Operations Rcriew Comittee and TU Electric compensated CASE for previous expenses.

In August 1988, a new group, the Citizens for Fair Utility Regulation (CFUR), and an individual, Mr. Joseph Macktal, are attempting to gain status as intervenors.

The extensive corrective action effort to correct the numerous design and construction deficiencies has been underway at CPSES over the past several years. This program has resulted in a significant number of modifications to bring the plants into conformance with NRC requirements.

In March 1988, the applicant temporarily suspended work on Unit 2 to concentrate resources on Unit 1 completion. The applicant is currently nearing completion of the i

corrective actions and has comitted to re-perform greater than 90 percent of the preoperational tests as the Prestart Ttst Program.

Hot functional testing (HFT) and integrated leak rate testing on Unit I was completed in July (Unit 1 previously underwent HFT in 1985).

The applicant has committed to begin a two-week operational readiness period following completion of construction end testing. The project status report currently shows a fuel load readiness date and the beginning of this " quiet time" on October 2, 1989. The applicant is running about two-weeks behind I

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i schedules therefore, the earliest they should be ready for licensee issuance is during the setend week of our inspection.

!!!. Inspection Plan A.pb,iectives b

The inspection has three r.ajor.ocjectives:

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(1) Independently assess the Comanche Peak Steam Electric $tation (CP$ts) power ascension, operations, and operations support prograsenatic and staffing readiness for operations.

(2) Nonitor daily activities in the areas of oNty assurance in order torations, t engineering and technical support, and qua assess whether the applicant is ready to operate the f acility safely.

(3) Evaluate the status of the prestart testing program to detersiine whether testing has been essentially completed.and that outstanding construction deficiencies will not adversely affect the safe operation of the plant.

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8. Scope The emphasize of the inspection will be sn independent assessment'of the effectiveness of management oversight, cocrective action prograsis, root cause analysis, and the readiness to support operations. The inspection will verify i

that the applicant has estabitshed an appropriate operating attitude well before fuel loading.

s In order to focus the inspection effort we will limit our detailed review of safety-related activities, system alignm,ents, material condition, surveillance testing, and operational procedures to the following systems:

(2) Decay Heat Removal.

(1 High Pressure Injection.

l

)) Auxiliary Feedwater.

(3 (4

Diesel Generators.

i (5)) Station Batteries.

This inspection plan b s been developed to address the applicant's operational readiness in the six functional areas. A detailed evaluation criteria for each

.of the areas is provided in Appendix A.

Any suggested changes should be provided to the team leader. The functional areas are:

1 Plant Operations.

2 Surveillance and Testing.

3 Facility Management Organization.

4 Power Ascension Test Program (PATP).

5 Maintenance.

.6 Engineering and Technical Support.

T C. Team Members In order to accomplish this inspection the team will be divided into two sections -- operations and operational, support. The operations section will 3

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focus on operations department activities and control room observations and the operations support section will focus on the system walkdowns and the opera-j tional readiness and support of the remaining departments. Continuous control room coverage is anticipated for at least 72-hours (Tuesday through Saturcay) i of.thefirstweekonsite).

In addition, the operations support section will perform walkdowns of the selected systems during the same time period. On j

Sunday (October 22) the entire team will reconvene to determine the direction of the remainder of the inspection. The team members are listed below, i

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Chris A. VanDenburgh - Team Leader - NRR - (30)) 492-0965 Dwight D. Chamberlain - Asst. Team Leader - Region IV - (817) 860-8249 [ Pe i W /

i geratlonsSection JayR. Ball-DisciplineLead-NRR-(301)492-0962 W 11 0; O. O h,;n - % t: !Y/C M O: -(0;7)00?-1500 M d*F e i

Jackie E. Bess - Region;IV/STP-SRI - ($12) 972-2507 l

Larry R. Veeder - Prisuta-Beckman Associates. Inc. - (412) 872-9157 i

Robert L. Lewis - Prisuta-Beckman Associates, Inc. - (412) 872-9157 BruceW. Deist-Consulting $cryices-(301)972-1973 I

Operations Support Section i

Thomas 0.McKernon-DisciplineLead-RegionIV/DRS-(817)8608153 Donald C. Kosloff - Region !!!/ Davis-Besse - (419) 898-2765 Donald A. Beckman - Prisuta-Beckman Associates, Inc. - (412) 872-915a7 Gary G. Rhoads - Prisuta-Beckan Associates Inc. - (412) 872-9157 Paul E. Harmon - Region II/Sequoyah-RI - (615) 842-8001 D. Team Assignments The inspection report is required to be issued within 45 days of the end of the l

inspection.

To simplify the development of the report, I have assigned the following topics for development and documentation. These assignments have been made based on er understanding of each inspector's experience and back-ground and I have attempted to evenly distribute the workload.tional topics are. id If an I will make the required changes.

These assignments are not final and any questions i

or suggestions should be identified as soon as possible.

'l An inspection report out1 Int will be provided during the inspection which will be similar to the topics identified in Appendix A.

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_0perations Operations Support i

Shift Professionalism McKernon - Facility Management Ball Procedure Adherance Outstanding Construction Deficiencies Harmon - Post Trip Review Process Kosloff - Power Ascention Program Shif t Comununications Surveillance and Testing Shift Routine / Turnovers HTE Control l

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e Bess -

Operability Determinations Beckman - Maintenance l

Response to Annunciators Housekeeping Off normal Conditions Room and Area Turnovers i

t Station Vital Drawings l

Veeder.- Equipment Out of-service Rhoads -

Engineering & Tech. Support System Status Control & Logs 50,59 Safety Reviews LCO Tracking Technical Specifications Lewis -

Operating Procedures Johnson - self-Assessment. Program s

Abnormal Procedures System Valve Lineups Event Reporting Lessons Learned Programs I

Deist -

Organization & Staffing Staff Stability and Experience Operator Training j

Attachments 2 and 3 contain background information on the facility provided by i

NRR's Special Project's Division and current organization chart.

In addition I have included a copy of the Shoreham ORAT inspection Report (50 322/89 80),

which will be the model for our inspection report.

Also included are copies of theinspectionreportfortheAugmentedInspectionTeam.(50-446/89-30 50 446/89 30) and resultant Information Notice 8g-62 conducted follow;ng recent i

problems with Borg-Warner check valves at Coo.anche Peak.

This inspection identified several weaknesses with the cperation of the facility. These concerns were communicated to the applicant and are included as Attachment 4 And finally, I have included copies of recent inspections (50-445/8g 58; 50-446/8g-58 and 50-445/89-43 60446/89-43) concerning the implementation of the emargency plan *which identified several problems concerning the knowlege J

1evel of the operators.

I will be forwarding system descriptions and selected plant procedures after I complete the pre-inspection visit during the first week of October.

In the meantime, please familiarize yourself with information provided and communicate afy suggestions for organizing our task directly to me.

t IV.

Inspection Schedule A. Inspection Preparation Sept. 25 Receive ORAT inspection planner.

i Oct. 2 provide comments to team leader by C08.

Oct. 10 Receive pre-inspection review material.

8. Inspection Oct. 15 Arrival at setel.

Oct.16(8:00am)

Arrive onsite at Comanche Peak - Badging, entrance and site orientation.

Oct. 17-25 Perform system walkdowns, sonitor control room activities, t

review procedures, and conduct interviews, i

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s Oct.26(1:00pm)

Conduct NRC sianagement briefing and practice applicant exit.

Oct.27(8:00am)

Conduct exit.

C. Inskction Report Preparation Oct.30(8:00am)

Arrive at NRC White Flint Offices.

Oct. 30 - Nov. 3 Entire team complete and approve draft inspection report.

Nov. 6 Submit draft inspection report to technical editurs.

Nov.'14 Submit draft inspection report to Section Chief, l

Nov. 21' Submit draft inspection report to Branch Chief.

Nov. 29 Submit draft inspection report to Division Director.

Dec. 6 Submit approved inspection rept"*, to Projects Division.

i Dec. 11

!ssue ins t

meeting. pection report 45 dap from inspection exit V.

Travel Itinerary Reservations for fourteen single rooms at the government rate have been made in I

sy nahm at the Plantation Inn in Granbury, Texas, for October 15 - November 3.

Directions to the CPSES are included as Attachment 5.

Pleasecall(817) 573-8846 by September 4 to individually confire and guarantee your reservation.

2 plan to arrive at the motel on October 10 at approximately 6:00 pm.

The entire team will meet on October 16 at 7:00 am in the hotel lobby.

I anticipate departing the site on October 27 at approximately noon, therefore I

your departure reservations should be made accordingly.

t We will begin work on the inspection report on the Monday (October 30) follow-ing the conclusion of the inspection. The entire team will participate in this effort. Please plan on beginning work at the NRC White Flint offices at 4:00 an on October 30. The draft inspection report will be completed by COB November 3 and the inspection report will be issued within 45 days of the conclusion of the inspection, t

Reservations for ten single rooms at the government rate have been made for October 29 - Noves6er 10 under a group reservation (i.e. NRC Group.

Van 0enburgh)attheGuestQuartersInnlocatedat7335WIsconsinAvenue, Bethesda, MD, 20814. The motel is within one block of the Bethesda station of the Metro Red Line. Please call 414-2900or(301)961-6400 by October 16 to individually confirm and guarantee your reservation.

Please inform me of your travel itinerary for both trips, including rental cars plans, before COB October 10.

VI.

Inspection Routine Normal working hours will be 8:00 AM to 5:00 PN while onsite, including the first Saturday (October 4). All NRC employees should arrange to suspend their 6

compressed and flexible time work schedules for the duration of the inspection.

Overtime will be approved on a case basis by the team leader.

Team meetings will be held daily at 8:00 am. All team mester's observations will be provided on Appendix 6 in sufficient detail to support their observa.

tions and conclusions. The team leader will meet with the applicant daily following the team meeting.

The status of outstanding concerns and significant observations developed from the previous day's Appendix B forms will be i

discussed.

The inspection will be effectively over by noon on October 26. - All further team efforts will be devoted to pro the exit meeting with the licensee.pering f.r the NRC management briefing and i

The inspection report nunter is l

60-445/89200._ NRC personnel should charge their time to the following:

Docket Number 50 445 Inspection Report Number 89200 i

InspectionProceduro(IP) 93806 i

Inspection Procedure Element OA Item of Major Interest (IMI) (IPE) 10HI l

i Please contact me at (301) 492 0965 upon receipt of your review materials and for confirmation of assignments.

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Chris A. VanDenburgh. Team Leader l

Special Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation l

A tachments.

)pDraftInspectionProcedureIPg3806 I

Comanche Peak Background Information h

l Comanche Peak Organizational Chart i

(h NRC concerns Regarding Operations Response to Check Valve Failures Maps to CPSES 7

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1 APPENDIX A OPERATIONAL READ!kESS ASSES $ MENT EVALUATION CRITERIA

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. Plant Operations Operations organization and staffing Staff stability and morale Operations experience and training (including remote shutdown training)

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Operating shift professionalism Methods for. operability determination i

i Post-trip review Lessonslearned(processrootcause) programs

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Performance of safety evaluations Event reporting Response to annunciators and off-normal conditions i

i Nuisance alarm and indication controls shift routine and turnover Equipment out-of-service controls System status control and logs Operating and emergency operating procedures Procedure adherence Verificationofsystemline-ups(includinguseoflocalvalveposition l-indications)

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Housekeeping and material control I

Communications with other departments t.

Surveillance and Testine Organization and staffing I

. Qualifications and training Interface between operations and startu Completionofprestart(preoperational)ptestingorganizations testing Observations of surveillance performance l

Technical Specification technical adequacy Technical Specification surveillance LCO tracking and control Performance of 10 CFR 50.5g safety reviews-i Calibration of installed and portable measuring and test equipment Surveillance procedure review Surveillance training of operators Management and quality assurance overview Facility Management Organization Organization and staffing Qualifications and training Management oversight activities and goals Applicant's operational readiness assessments (internal and external)

Onsite safety review committee Lessons learned from previous new plant operating experience Root cause and corrective action programs A-1

4 i

j Power Ascer.sion Test Program (PATP) l PATP organization and staffing-i Qualifications and training Approval for plateau changes Quality assurance controls for PATP Staffing prerequisites for testing Program change controls Test status and scheduling Maintenance.

i Maintenance organization and staffing 1

-Qualifications and training:

Construction deficiency " punch-list" items Maintenance work observation i

Material-condition and labeling of systems and components Predictive amintenance programs

. Post-maintenance testing

-i Work planning and prior'tiaation-Parts and material control Engineerire and Technical support Engineering organization and staffing Qualifications and training Systeniengineering

'2 Vendor manual control Review of generic cormunications Modification controls

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Configuration controls Temporary modifications 1

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APPENDIX B l

Subject :

Observation ko. :

Revision :

References :

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Discussion :-

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Significance:

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Required Actions :

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INSPECTION PROCEDURE 93806 DPERATIONAL READINESS ASSESSMENT TEAH INSPECTIONS l

t PROGRAM APPLICA8!LITY: 2514 i

9380E-01 INSPECTION OBJECTIVE The objective of this procedure is to provide guidance on conducting Operational Readiness Assessment Team (ORAT) inspections for new plants.-

Results from.these inspections will provide a major input and basis for a NRC determination of startup readiness.

93806-02 INSPECTION REQUIREMENTS 02.01 Inspection Plannino.

Conduct of Operational Readiness Assessments is required before issuance of the low power license, before issuance of the full-power license, or during power escalation.

The inspection schedule and scope are to bs tailored to the individual plant circumstances.

The i

inspection should coecentrate on perceived weaknesses and areas important to plant operations which have not yet been sufficiently reviewed. Attachment 1 provides an outlihe of the areas that may be covered during assessment of the reaoiness for power operation.

4 02.02 Plant inspection.

The following specific items, in addition to those

-listed in Attachment 1,.should be considered during ORAT inspections:

s.

Focus the inspection on safety-significant activities such as fuel loading, reactor startup, heatup/cooldown, and surveillances.

Direct observations of activities are preferred and should be supplemented by personnel interviews and document reviews.

Systems should be selected for walkdown and inspection on the basis of their potential to cause challenges to safety systems.

(The results of similar unit design or generic probabilistic risk assessment studies should be used, if available.)

b.

Evaluate licensee management transitional controls.

Construction deficiency

" punch" list iter.s transferred to the operations organization for completion are either subject to contractor disposition or are converted to maintenance work order items.

These items constitute incomplete construction phase work fnr which management controls are required to ensure readiness for operation. Issue Date: XX/XX/XX

3 e

Evaluate management oversight of and involvement in daily work and preparation activities.

Review licenste perfomance in conducting preventive-maintenance i

activities and controls over deferred preventive maintenance, Review the licensee's program for operating experierce feedback and c.

verify implementation.

implement lessons learned and that research the safety, significan

)

problems that have developed during the startup of similarly designed

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plants.

Select and review in detail, several operational prob ems i

experienced by the licensee,during the preoperational or startup test i

phase and assess whether the problem was fully reviewed and understood prior to further testing.

WDREG-1275 and applied lessons learned.Detemine if the licensee has reviewed Evaluate whether procedural i

problems.related to operations are being effectively identified and expeditiously corrected.

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Examine the licenste's self-assessment capability as it relates to d.

readiness for. operation including the root cause analysis process, the corrective action pr,ogram, and the trending and generic applica-bility review of self-identified problems.

Determine the adegaacy of t

the deficiency reporting system, including thresholds, and evaluate i

the effectiveness of prioritiration of the identified problems.

Review the root cause analysis training program.

Assess the involvement of 0A and engineering in problem resolution.

e.

Determine whether operator training, including simulator usage, includes beginnirg of-life core characteristics and s Through operator interviews, control room observations,ystem response.and the review of alarm response procedures, detemine whether' shift personnel are prepared to respond to abnomal plant conditions, instrumentation and control setpoint and display anomalies, and the potential for a high number of challenges to safety systems during testing.

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Evaluate whether there is any change in the Quality Assurance (OA) program effectiveness due to the differences in the QA organizational interactions with other station departments under operational controls s

versus what existed when under construction controls.

Verify whether program requirements exist for quality assurance / quality control i

(QA/QC) to be present during back shifts, and assess

~

adeouacy. personnel g.

Determine whether the licensee has implemented an effective Technical Specification Appraisal process.

Verify that plant procedures accurately reflect the applicable Technical Specification sectinns.

Verify the adequacy of administrative controls to complement startup testing activities under Technical Specification constraints, as opposed to the latitude for " troubleshooting" problems that exist under preoperational testing controls, h.

Detemine whether the licensee has implemented an effective program to review and focus attention on balance-of-plant (80P) operations to reduce the frequency and severity of plant transients.

Issue Date: XX/XX/XX 2-g3806

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Evaluateithe edequacy of licensee - plans to resolve material e

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personnel accesss and work -control problems once the radiologically J

controlled ~ areas - (RCAs F and-protected / vital areas are estab ished.

j f,1.

Evaluate-the status: of control room annunciators alarms, and recorders.. Verify thou adequacy of the licensee's.m,ethodology for compensatory measures. for those-indications not operating properly.

k.

- Evaluate the: licensee's. program to-review and evaluat'e the impact of the. maintenance work ' request backlog on operational readinets.

including - the collective impact on safety system availability and operability..

Determine if safety-related work is being accom by. means other than the written administrative controls (e.g.,plished tickets").

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-1.

Review the qualifications and comercial operating-experience of key

. managers and operators and whether organizational' responsibilities and

.b, interfaces exist to support an operating unit.

Determine whether the L

licensee has staffed the: organization to levels which are capable of p

successfully operating and. supporting the unit.

L Review the startup testing schedule and status of completion to ensure m.

that the startup-testing comitted to in the final safety analysis report- (FSAR) is, or' will be, actually performed.

If tests are de-L

.leted or modified ensure that an adequate 10 CFR 50.5g review was pg.rformed and forwarded to NRC for review.

s Review the ' method for ~ keepi6g track of entry into and exit from m.-

Technical' Specification action statements.

Ensure that the operators are aware of all action statements in effect and their cumulative

. implications.

t Twenty four-hour inspection coverage of shift operations is necessary at various times during the startup. sequence.

Such coverage is routinely

. provided.'during: initial criticality and other periods of si.artup testing.by.

regional / resident personnel in the conduct of the NRC Inspection Manual Chapter 2514 inspection program.

Judgment must. be exercised in balancing

-isuch btnefits against the requirement for additional inspection resources to conduct around-the-clock shift coverage.

02.03 Menagement Meetings.

Frequent NRC management meetings with licensees

=are recomended before andx after the ORAT inspection to maximize the effectiveness of the Operational Readiness Review process.

Throughout the first few months of initial comercial operation, the NRC should review with 1

the " plant: management and staff the root causes of all reportable events and l planned licensee corrective actions at such periodic meetings.

The ORAT exit Laeeting. should emphasize the continuing nature of the NRC readiness review (process.-

93806-03 INSPECTION GUIDANCE 03.01-General Guidance.

Previous NRC evaluations and Office for Analysis and. Evaluation of Operational Data (AEOD) studies have shown that effective management of. the transitiots from construt: tion to operations and of the feedback of operating experience from other plants (and similar plar.ts) can I -93806-Issue Date: XX/XX/XX

_ ~- _ - - --

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. significantly enhance. early' performance.c This -inspection procedure' provides -

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general guidance L on. the scope, content. problem areas, and verifications -

5 relevant to the conduct of.ORAT inspections, a

DRAT: inspections will emphasize the effectiveness' of manageme'nt oversight, i

I corrective action programs, root cause analysis,.and the readiness-to support i

operations.

The following-major points should be assessed:

the establish.

ment of ce basic framework.of management programs to support the operation of

-the -unit; the-establishment and implementation of a prograin to gather and

-)

apply lessons learned from industry experience; the ability of the management

]

team to establish a proper working atmosphere in which to operate.the unit; the involvement of both -site and corporate engineering in the operation of J

the-unit; and the depth of QA involvement in plant operations and problems.

For new plants it is essential that the licensee identify lessons learned from previous new plant operating experience and communicate these lessons to the senior management of the new plant.

New plants-that have come on line have shown significant improvement after establishing effective root cause F

analysis and corrective action programs. Effective station goals and actions that result from self-assessment demonstrate the readiness of the plant for safe operation and ~ the readiness of its personnel for the conduct of the plant's safe operation.

LHowever, one common element supports all Operational Readiness Reviews, including ORAT verification activities, and that is the fundamental need for the-establishment of an appropriate operating attitude well before initial i

criticality.

Programs that control construction completion should be phased D

out or merged with operational control programs in order to minimize the confusion associated.with duplicate systems of controlling work. The same is also true for procedural use and personnel work assignments.

Operational controls should be implemented as early as possible to allow for personnel accilmation-and training.

It is also important that such operational controls, particularly in the

areas of maintenance and modifications, be consistent with both the original bases of the plant design and the good work practices used during plant construction.

The planning for this inspection is an important element.

Selection of the

~

inspection team is.a very important function during the planning phase.

l Operating experience of-team members should be a primary consideration for selection, especially for the control room observations. The use of resident inspectors-from similar sites and experienced regional / Nuclear Reactor Regulation inspectors should be emphasized.

The inclusion of a licensing examiner may also be beneficial in evaluating operational readiness.

Consideration should'also be given to including a team member with expertise in management and organizational theory and/or human factors engineering, if applicable to the inspection scope. The size of the team will vary depending on the scope and duration of the inspection.

1 i

03.02 Specific Guidance a~

Inspection Requirement 02.01.

The scheduling of the ORAT inspection shall be based upon the previous licensee experience and operating history as may t,e applied to the specific plant. An inspection of the first nuclear unit for a utility may require more lead time before the Issue Date: XX/XX/XX 93806

1

'i e

sq yqr

)

R projected fuel load"date than is needed for inspections of subsequent v

nuclear units.. The timing'of the inspection must be well' coordinated i

with other NRC and third party-inspection activities, such as:

1 (1) Inspection Procedure 94300' status report requirements.

(2) ' Issuance: of :the' proof and review copy of the Technical Specifications.

(3) Regionali Office conduct of a team inspection for a Technical-o Specification Review in accordance-with Inspection Procedure 71301.

s

.i (4) Conduct 'of-the INPO Preoperational Assistance visit at the site, (5) Conduct of utility self-assessment activities and availability of the resulting report (s).

- Prior licensing and plant restart experience indicates that ORAT inspections can be optimally conducted about 3 months before issuance u.

of the: initial license.

In the case of full-power operation for a new plent. another evaluation should be condccted 3 to 6 months after P

receipt t

of the full-power license to observe actual operational activities.

p b;

The areas :of review should also be based on the previous experience

' of the-licensee

• For example, the inspection plan for the thir:t unit-i in a three-unit station will differ considerably from -the inspection plan for the station's first unit.

i b.

Inspection Requirement 02.02. - For newly licensed plants, the status of the operational preparedness phase of the Preoperational Testing L

l=

Program -(NRC Inspection Manual Chapter 2513, Appendix B) 'should be-reviewed to determine which inspections are incomplete and whether L

problems have been identified in the areas previously_ inspected.

The - NRC Inspection Manual Chapter 2513. Program Inspection Procedures t

that are -incomplete or - that resulted in identification of problems

.can be utilized to develop areas for review during the operational i;

readiness team ~ inspection.

Current procedures exist in'the following inspection areas, as listed in the NRC Inspection Manual Chapter 2513, Appendix 8:

(1) Operations (2) Maintenance (3) Fuel Receipt and Storage L

(4) Fire Protection l

g (5) Surveillance l

(6) Plant Water Chemistry Controls l-(7) Radiological Controls L

93806 Issue Date: XX/XX/XX

~ r, L ;, ~

>t i

(8)Securityand. Safeguards

.t

'(g) Quality Assurance--

t Theoperations-phaseinspectionprogram(NRCInspectionManualChapter y' '

s

' 2515) also contains inspection procedures that can be used to develop areas - for_' further. review-of operational readiness.

The - following represent = current, applicable procedures listed under the respective inspection functional areas that'they support:

(1)' Plant Operations.

42700' Plant Procedures

^

64704 Fire Protection / Prevention Program w

71707 Operational Safety Verification L"

71710 ESF System Walkdown

'4 (2) Maintenance / Surveillance-61700 Surveillance Procedures and Records n

61726 Monthly Surveillance Observation L

61725 Surveillance Testing and Calibration Control o

Program L

62700 Maintenance Program Implementation p

62702t Maintenance Program 62703 Monthly Maintenance Observations t

62704

-Instrument Maintenance

-62705 Electrical Maintenance L

(3): Engineering and Technical Support 37700 Design. Design Changes, and Modifications

37701 Facility Modifications 72701 Modification Testing L

(4). Safety Assessment /Ouality Verification i

35701 QA Program < Annual Review 40500 Evaluation of Licensee Self-Assessment Capability

$2720' Corrective Action (5) Security 81XXX Physical Security (81000 series procedures) 1 81018 Security Plan and Implementing Procedures 81020-Management Effectiveness - Security Programs 8107X

-Access Control (81070 series procedures) 81088 Consunications (6) Emergency Preparedness E ',

82701 Operational Status of the Emergency Preparedness Program Issue Date: XX/XX/XX 93806

~.

0 w

x L

(7)1 Radiation Controls

?

837501

-Occupational Exposure, shipping, and Transportaticr.

'84750-Radioactive Waste Systems; Water Chemistry; Confirma-tory Measurements. and Radiological Environmental Monitoring o

.c..

Inspection Reevirement 02.03.

The scope of the ORAT inspection must be flexible enough to accomodate both the unique plant design and ythe plant inspection 'istory. ' including - systematic assessment of j

licensee performance (Slip).

Thus, departures from standard nuclear steam supply system (NSSS) designs and first-of-a-kind plant features may provide areas for-specific review at a new plant. ;Both the NRC Open items List and the licensee's-internal.

• punch" lists should be-reviewed for.. planning. input' and to identify areas in which work may not be completed before criticality is achieved.

Also, the results of past NRC team. inspections at the plant should be considered not only.

to understand past problem areas, but also to review the effectiveness of licensee corrective action progises.

The licensee's responsiveness h

to previously identified problems and issues provides one indicator of the licensee's progress toward developing a proper operating attitude i

.and ensuring a high_ degree of readiness for conducting criticality-and

. power operations.

Just ias the scope of any ' Operatienal ' Readiness Review must be i

flexible, so must the ORAT inspection be adaptable to-changes in direction and emphasis.

Frequent team meetings are essential not only to identify any generic problems or concerns that may exist in the

' different inspection areas, but also to _ redirect inspection resources away, from areas in which no problems are evident.

Identification of acceptable areas should be made to allow-the inspectors the latitude i-3

and time to thoroughly investigate the causes of identified l

l

. problems.. The-ORAT inspection should be flexibly structured to adapt to the -necessary changes in direction and scope that occur through j

the use of perforinance-based inspection techniques, i

L

-93806-04 RESOURCE ESTIMATE This inspection is estimated to require 560 direct inspection hours of regional and headquarters resources.

Actual inspections at a specific plant may require substantially more or fewer resources, depending on the

inspection scope.

t 93806-05.

REFERENCES 1

L NUREG-1275, ' Operating Experience Feedback Report - New Plants." July 1987

'HUREG/CR-5151, " Performance-Based Inspections." June 1988 NRC Inspection Manual Chapters 2513 and 2515 i

l Memorandum. J.

Sniezek to Regional Administrators, dated April 23, 1987 l

(NUDOCS 68863/046).

1 i

END l

93806 Issue Date: XX/XX/XX 1

1, c 9

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' Attachment I

+

j OPERATIONAL READINESS REVIEWS-1..

Plant Operations A.

System Status Contrn1 and Logs j

8.

Organization and Staffing C. -

Shift Routine and Turnover D.'

. Training E.

Response.to annunciators and Off-normal Conditions F.

Housekeeping end Material Condition G..

Control Room Decorum H.

-Reportability Requirements and Implementation Comunications with Interfacing Departments J.

Fitness for Duty Program 1

i K.

Overtilae Controls L.

Procedure Adequacy / Adherence

II.-

Maintenance / Surveillance A.-

Maintenance Management and Organization B.

Observation of Work Activities C.

Temporary Modifications D.

Preventive Maintenance Program E.

Failure Trendisig and Predictive Maintenance F.

Post-Maintenance Testing-L G.-

Work Planning and Prioritization Processes H.

Training I.

Comunications with Interfacing Departments J.

Rework: Identification and Control i

K..

Implementation of TS Surveillance Requirements l.

L..

Observation of Surveillance Activities M.

Procedure Adequacy / Adherence p

I:

III.

-Engineering and-Technical Support 3..

Modification Controls L

B.

Support to Operations and Maintenance C.

Configuration Controls D.

Interface with ALARA Program E.

Licensing: Activities and Technical-Specifications Management IV.-

. Safety Assessment /Oua11ty verification A.

Management Oversight Activities and Goals B.

Self-Assessment Capabilities (PORC 50RC. ISEG)

C.

Quality Assurance /Ouality control Involvement D.

Corrective-Action Programs E.

Post-Trip Review Process

- F. -

Operating Experience Feedback G.

Independent Verification Policies H.

Licensee Readiness Assessment g3806 A1 1 Issue Date: XX/XX/XX

.1

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. Radiation Protection-V

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.. Health Physics: Organization and-Staffing.

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8.

1 Radiological Controls tC.,

LEffivent/ Waste Controls' 1

.D..

ALARA.

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/E. " Materials and Contamination Control t

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~ Surveys and Monitoring i

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LG..

Respiratory Protection f

F..

Training?

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VI.

--Security /

A.1 f organizatica and Staffing i

i

. B.

Security Plan Implementation

'i C.

Access Controls.

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Alam. Response I

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E.

Communications.

F.;

Training.

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y VII.1 Emergency Preparedness' A.,

_ Emergency Plan and Implementing Procedures 8.

Energency Facilities. Equipment Instrumentetion..

l'

,C.: : Organization innd_ Management Control and_ Supplies-E p

D.

Training 4

b.;

E.

Independent Reviews / Audit Ia p;

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1ssue Date

XX/XX/XX Al-2. g3806

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,h ATTACHMENT NO.'2

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1 8ACKGROUND INFORMATION ON-COMANCHE PEAK STEAM ELECTRIC STATION-(CPSES)

Utility: Texas Utilities Electric Company (97.81 Ownership)

J (TU Electric / Applicant or Applicants)

Location: 40 miles SW of.Ft. Worth, Texas Somervell County, Texas

~

Unit 1 Unit 2 Docket No.:

50-445 50-446 CP 1ssued:

12/19/74 12/19/74 Low Power License:

Est. 10/89 Not Scheduled 4

Full Power License:

50% 18/sq Initial Criticality:

w u/gg Elec. Energ, 1st Gener:'

l Commercial Operation:

Reactor Type:-

PWR Same l

Containment Type:

Steel-lined, Same L

reinforced concrete Power Level:

3411 MWT; 1159 MWE Same Architect / Engineer:

Original - Gibbs & Hill Same Current - Reverification and redesign effort by Stone and Webster, Ebasco, l

and Impe11 NSSS Vendor:

Westinghouse Same Constructor:

Brown & Root Same l

Turbine Supplier:

Allis-Chalmers Same L

. Condenser Cooling Method:

Circulating Water System Same Condenser Cooling Water:

Squaw Creek Reservoir Same i

Licensing Project Manager:-

(seeProfectsgroupbelow)

NRC. Responsible Office:

Associate Director for Special Projects, H0 l

Dennis M. crutchfield, Associate Director (492-0722)-

Comanche Peak Project Division. OSP christopher Grimes, Director (492-3299)'

n.n Mp = w,0-p.:,, :: = tr (102 ??01)

CPPD Prajects:

Assistant Director for Projects James Wilson, Assistant Director (492-3306)

Melinda Malloy, LPM (492-0738)

Mel Fields, LPM (492-0765)

~

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1

,. Comanche Peak Steen Electric Station

-2.

CPPD Technical Review:- ~ Assistant Director for Technical Programs James Lyons, Assistant Director (492-3305)

CPPD Inspections:

Assistant Director for Ins section Procrams y

Robert Warnick, Assistant 31 rector (817)897-1500 CP Site Section Chiefs:-

'HerbertLivermore(817)897-1500 Joel Wiebe (817)-897-1500

- ) -

Senior Resident Inspectors:

Sh:r;;;Eillip;(0;;;tr.;;ie,)k817l897-1500

'017' 0;7-;7,00 M;JeenW'" h:; arri; (Operations)

Resident Inspectors:

Michael Runyan (C/S) (817) 897-1500 St9ygnB,itter{0g)

[8,17l897-1500 Robert Latta ll5ec)liii}89I5566 i

L Recion IV. Arlincton TX:

Responsible for Operator Licensing Activities, i

L Emergency Planr.ing Activities, and Radiation Safety and Safeguards Inspections L

' Robert Martin, Regional Administrator (8-728-8225)

E John Montgomery. Deputy Regional Administrator (8-728-8226)

. Director I.

Division of Reactor Safety (8-728-8183)

A. Bill Beach. Director.

Division of. Radiation Safety and Safeguards (Ba728-8248)-

William Fisher, Chief Nuclear Materials Safety Branch i

(8-728-8215)

Blaine Murray, Chief Reactor Programs Branch (8-728-8126)

Donald Driskill, Director Office of Investigations Field Office (8-728-8110) o D

4

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,. J Comanche Peak Steao Electric $tation> j

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~

q TU Electric CorArate Management Personnel (Dallas.~ Texas)

. Jerry S. Farrington, Chaiman of The Board a' Chief Executive, Texas Utilities Co.

Erle A. Nye, President. Texas Utilities Co.

and Chaiman and Chief. Executive, Texas Utilities Electric Company William G.~ Counsil,= Vice Chaiman-

'TU Electric Michael D. Spence, President TU Electric Generating Division TU Electric' Corporate Management' Personnel (Site) l William J. Cahill Executive Vice President, 1

Nuclear 1 H. D. -(Buz) Bruner, Senior Vice President

- i Nuclear Engineering and.0perations-1 R. A'. Werner, Manager L

Safeteam l

TU Electric Management Personnel - Operations (Site)

A. B. - Scott, Jr., Vice President Nuclear Operations J. J. Kelley, Jr., Plant Manager L

J. V. Donahue, Operations u

B. W. Wieland, Maintenance-

6. J. Laughlin, Instrumentation and Controls M. R. Blevins, Plant Support M. J. Riggs, Plant Evaluation J. S. McMahon, Training T. L. Gosdin, Administrative Services

8. T. Lancaster, Plant Services

}:

R. Daly, Startup L

D. L. Davis, Results Engineering S. L. Ellis, Test 1

D. W. Stonestreet, Outage Planning

,?.yl 4, a 21 l

. Comanche Peak Stead Electric Station-

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lManacement Personne1'. CPSE$ Nuclear Enc'inserino/Engineerine Construction l

walias Fsite1 -

L L. D. Nace Vice PresidentL

-J.-W. Beck..Vice President,-

p Nuclear Engineering

..)

?

J. 8. George, Vice President, m,

Support-t R.'D.. Walker, Manager Nuclear Licensing J. F. Streeter, Director u

Quality Assurance A. Husain, Director l

Reactor Engineering

0. W. Lowe, Director-

-Engineering T. G. Tyler, Director Projects D. M. Reynerson. Director Construction W. R. Deatherage, Director Enginsering Administration J.-W.Muffett,ManagerofEngineering(CECO)

J. E. Krechting, Director Technica1' Interface j

Workforce As of April-8,1989:-

Ornanization Onsite Total 1

Eng. & Eng. Admin.

2351 2508 Construction 3694 3694 Projects 604 619 o

Operations-1686 1700 Nuclear Engineering 739 841 Support Services 275 277 NE0 Administration 26 45 TOTAL 9375 9684

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w mg Comanche ~ Peak Stes3 Electric Station -

j J

,j O eactor Operators-R

SR0s-Operating.

.19 R0s.

Operating:

24

~

. Staff; '

24 Staff.

1 Total 7

Total 7

~ 15 SR0s and 10 R0s~ are required to operate Unit l' V

. Work Shifts 6 Shift Manning Cycle 3 shifts working

-1 shift.in. training 2 shifts extra.and off.

'~As' reflected in current proposed Technical Specifications.

l each~ shift will-be comprised of the following staff

• t For one. unit operation:-

ShiftSupervisor(SRO)'-

L-1AssistatitShiftSupervisor(SRO)~-

2. Reactor Operators 5 Auxiliary Operators Shift Technical Advisor (SR0/STA)-

i l'

For two-unit operation:

~

E ShiftSupervisor(SRO)

L 2 Assistant.ShiftSupervisors(SRO) t E

4 Reactor Operators 10 Auxiliary Operators..

~ShiftTechnicalAdvisor..(SR0/STA) 1 I

4 1

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! ;Comanihe Peak: Steam Electric; Station'

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LReactor Operator Exams Administered by the Rooton i

1 Date of:.

'baberof

.)

W Exam Applicants' Passed

. Failed

.j

,12/21/88* ~

~5RD 1

1 0

~

R0 '.

0~

0

'0' 1

4

-06/06/88.'

SR0 7

5 2:

R0.

6 3

3

,.;r y

12/15/87.-

SRO-0:

0 0

R0-5 3

2 07/13/87

_SRO 8

-7 1

R0 4-4 0

'09/23/86 SRO.

5' 3

2 l

R0 7-6 1

j 04/01/85 SR03 2

2 0

R0 5-4 1

09/11/84-SR0 5

4 l'

RO-17 8

9 L

04/03/64 SRO 12

.7 5

R0 13 8

5 E

07/18/83 SRO 29 23 6

R0

'10 3

7 j

t p

136 91 45 j,

Totals-L

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Recualification Exams Administered by the Region.

Date: of Number of Exam Applicants Passed Failed i '

09/23/86

.SRO -14 10 4

R0' 7

3-4 04/01/85

'SRO 7

4 3

l l'

RO 3

2 1

I Totals 31 19 12

-Next Examination Scheduled for:

July 3-7. 1989 Requalification Exams L

Number of Applicants:

SRO 8

RO 4

Total 12

• TMs was a retake exam including the " Administrative Topics" and " Control Room Systems / Facility Walkthrough" sections of the operating exam.

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Comanche Peak-Steam' Electric Station 28-4 Allecations;_(continued)

The staff has received 45 allegations since the formation of OSP.

-As of.May 15, 1989, 10 allegations remain open. All of the allegations have been reviewed by the CPPD Allegation Review Comittee to es-tablish the necessary follow-up action required for closecut. All totaled, approximately 130 allegers have reported concerns about Comanche Peak.

Emergency Preparedness The staff documented its review.of Revision 8 (FSAR Amendment 48) to the Emergency Plan in $$ER 6 (11/84). On the basis of a review of the Applicant's Emergency Plan against the (1) Planning Standards of.

10 CFR 50.47(b). (2) requirements of Appendix E to 10 CFR $0, and (3) guidance criteria in NUREG-0654. Revision 1 (11/60). " Criteria for-i Prepsration and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (Regulatory Guide 1.101, Revision 2),-the staff concluded that the Emergency Plan for CPSES Units-1 and 2 provides an. adequate planning basis for an acceptable state of emergency preparedness and meets thS requirements of Appendix E to 10 CFR 50. The Applicant provided Revision 9 to the Emergency Plan in FSAR Amendment 58 (6/86) and with Revision 10 (8/88), the Plan was separated from the FSAR and will be maintained as an independent report.

The staff's review of the changes to the Plan was: completed in February 1989 i

and aftirmed the staff's prior conclusions on the plan's acceptability.

In addition to.the Emergency Plan review, the staff. completed an appraisal (September. 6 through October 7,1983) of the Applicant's implemented emergency preparedness program (Inspection Reports 50-445/83-33 and 50.446/83-17 dated February 8, 1984). Also, the Applicant's performance was observed during a full-participation exercise (December 12-15,1983) with participation by the applicant, the State of Texas, and Hood and Somervell Counties (Inspection Reports 50-445/83-46.and 50-446/83-21 dated January 23.1984).

l

'By memorandum dated November 29, 1984 FEMA provided findings based on the review of the original and revised offsite Emergency Plans and the results of the December 14, 1983, full-participation exercise.

FEMA determined that:

offsite radiological emergency plans and preparedness for the Comanche Peak Steam Electric Station have been determined to be adequate. Consequently, there is reasonable assurance that j

appropriate measures can be taken offsite to protect the health and safety of the public living in the vicinity of the Comanche Peak Steam Electric Station.

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' Comanche Peak Steam Electric Station _ :

' I 9

o f

Plant Simulator-V t

- Ths-simulator.was operational-in 1985 and is Comanche Peak Plant specific.

It'is located in the Nuclear Operations Support Facility.

on-site and the~ vendor is Singer-Link..

Systematic Assessment of Licensee Performance (SALP)

The SALP process was suspended in February 1985, because of the TRT and

- Region IV special attention.- The SALP process was resumed by the NRC for-the period September 1, 1987 through-August 31, 1988.

The final SALP report

. (see Attachment 3), Inspection Report 50-445/87-40 and 50-446/87-31, was issued on December 9, 1988.

Overall, the recent SALP concluded that 'while there have been some deficiencies in the complete implementation of Comanche Peak programs. TV.

Electric has established a solid foundation for excellent performance.

1 Escalated Enforcement Actions On February 28. 1989, the staff cited TU Electric with a Level !!! Violation '

(EA-88-278) fer failure to submit a timely application for extension of

- the Unit I construction pemit. No civil penalty was imposed in consideration

-of:the applicant's-extensive corrective action programs, the. age of the a

violation. and overall safety significance of the violation.

Investigation / Allegations Status OI Investinations OI has issued 14 investigation reports, 29 inquiries and 5 assists to Region IV. Areas include welding, QC, electrical, inspections, intimidation, procedures, management, NCRs, coatings, pipe hangers, firings, falsification of records, and construction practices.

OSP/CPPD has referred 5 requests for-investigation to 01. 01 currently has 1 open investigation.

Allegations Slightly.over 1,000 allegations have been received by the staff on

- Comanche Peak. The evaluations of the majority of them (approximately 600) were documented by the NRC's Technical Review Team in SSERs 7-11 in the following areas: electrical / testing, civil, protective coatings, mechanical, and QA/QC. Approximately J

200 allegations (rtreeived after the SSERs mentior.ed above were issued, but before September 15,1985) in the areas of electrical, civil, mechanical, and QA/QC have been evaluated and documented.

The QA/QC allegations were closed out in inspection reports, and the electrical, civil, and mechanical allegations are addressed in SSERs 14-20. From September 15, 1985 until the formation of the Office of Special Projects (OSP) in February 1987, Region IV processed cons-truction and QA/QC-related allegations; 14 allegations were received during this time period. All of the allegations received prior to the formation of OSP have been closed.

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1 0;y;x Comanche' Peak Steam Electric Station

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j The staff has' reviewed:the FEMA fin'ings and' determined that'they support d

the staff's recommendation that there 's an adequate state of onsite and offsite emergency _ planning and preparedness for full-power licensing for the Comanche Peak Steam Electric Station.

l-

. FEMA transmitted its findings In a subsequent letter dated July 15, 1985

'and-determination in accordance with the FEMA rule (44 CFR 350).- FEMA

- detemined that:

\\

the Texas-State and local plans and preparedness for the Comanche Peak Steam Electric Station are aveguate to protect-the health and

,i safety of the public in that there is reasonable assurance that the-(

appropriate protective measures can.be taken offsite~in the event

l of a radiological emergency. The adequacy of the public alert and notification system has also been verified by FEMA in accordance with the criteria in FEMA rule 44 CFR 350; Appendix 3 of NUREG-0654/.

FEMA-REP-1. Rev.1; and the " Standard Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants" (FEMA-43).

Further, consistant with the Comission's Statement of Polic regarding-arrangementsforoffsiteemergencymedicalservices,theAppficant,by letter dated February 20.1986, confirmed that the Emergency Plans of the involved offsite response jurisdictions contain s list'of medical service

)

facilities. The existence of such a list in the pertinent plans has also been confirmed by FEMA. Further, the Applicant has comitted to' fully comply with the Comission's final response to the Court's remand.

The last full-participation exercise was conducted in November 19A4.' A t

- full-participation emergency exercise'is scheduled for July 25-26, 1989.

l In a_ letter to FEMA dated March 24, 1989, NRC requested FEMA to (1) provide its evaluation of the upcoming 1989 full-participation exercise, (2) confirm that any revisions-to the' State and local plans since 1984 have not degraded the effectiveness of those plans and (3) confim that the emergency plans of the involved emergency response jurisdictions meet current regulatory re-quirements and guidance.

7 Emeroency Response Facilities The Applicant's Emergency Plan and Emergency Response Facilities (ERFs) provide for a Technical Support Center (TSC) which is separate from the Control Room but located adjacent to and'above it. The TSC has the capability to display and transmit data and data sumaries describing plant status to the Control Room and the Emergency Operations Facility (E0F). There is space in the TSC for management and technical personnel L

to perform their functions. The radiological-habitability of the TSC is the seme as the Control Room and communications are provided between the Control Room, the' Operational Support Center (OSC), the EOF, the NRC, and other offsite agencies. The use of semi-portable continuous monitoring instrumentation is.available to detemine dose rate and radioactivity levels in the TSC.

The TSC appears to be capable of supporting reactor control functions, evaluating and diagnosing plant conditions, and serving as the main comunications link between the Control Room, the OSC, the EOF, and the l'

NRC. The TSC can carry out the EOF functions until the EOF is staffed.

17 ' A,j

,7 l

Comanche Peak Steam Electric StationL 1 e

1 4

' 'Emeroency pesconse Facilities (continued)

The Comanche Peak OSC is presently located in the Maintenance Building and provides a place where operations support personnel can assemble and report in en emergency as well as receive-instructions from the operating staff. With Revision 10 to the Plan, the OSC is being relocated to the Radiation Control Access Office; the Maintenance Building will serve as an alternate OSC. The OSC has connunications with the. Control Room, the

~

TSC. and the EOF.

The EOF is attached to the Nuclear Operations Support Center which is

-located within 1.2 miles from the Comanche Peak Steam Electric Station and has a Protection Factor of greater than 15. An alternate EOF is provided 3

in Granbury (10 miles). There is space in the EOF for management and-technical personnel to perfom their functions. There are connunications links between the EOF and the Control Room, the TSC, the OSC. the NRC, and o

L other offsite agencies. The EOF appears-to be capable of coordinating all-the Applicant's onsite and offsite activities for reactor emergency

'situa tions. -

In SSER 3 (3/83) and 6 (11/84), the staff concluded that the Applicant's emergency facilities and equipment are adequate to meet the requirements of 10 CFR 50.47 and= Appendix E to 10 CFR 50 on an interim basis, subject to an onsite post-implementation review. This onsite post-implementation review will_also be used to determine the adequacy of the final ERFs in accordance with the requirements and procedures given in Supplement 1 of' NUREG-0737.

Sionificant Licensee Accomo11shments j

'Thedevelopmentandimplen;entationoftheCorrectiveActionProgram:(CAP) for design and construction-deficiencies typifies the aggressive'and thorough approach that TU Electric management applies to safety issues.

TU Electric's-commitment to excellence is evident in their improvements to the security systems and emergency preparedness facilities. _This H

.connitment is regularly demonstrated by TU Electric managers, several of whom are former NRC employees, but not always by the working staff.

Plant Status Schedule In March 1989, the Applicant formally announced that the current schedule forUnit1fuelloadingis"threemonthsbehind[our]...mid-1989 schedule" which was announced in March 1988. Based on current construction activity schedules. TU Electric estimates that Unit I will be ready to load fuel in October 1989. Unit 2 construction was suspended in March 1988. TU Electric estimates that the Unit 2 fuel load date will be approximately two years after Unit 1 fuel load.

b

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X Comanche Peak Steam Electric Station'

11 -

j 4

-Plant Status (continued)

.Hearino-Status

Comanche Peak'has been a heavily contested proceeding since-1981. 'On

-July 1.-1988 the Applicant intervenor'(Citizens Association for Sound Energy), and the NRC staff filed a Joint Motion for dismissal of the

. proceedings based on a Joint Stipulation describing the terms of a c

settlement agreement under which CASE Presidento Ms. Juanita Ellis would become a member of the Operations Review Committee and TU Electric would compensate whistleblowers. The Joint Motion applied to the-

, l admitted contentions:in both the OL an: Unit 1 construction pemit t

amendment (CPA) proceedings.- At a special prehearing conference on:

July:13. 1988. the ASL8 issued a Memorandum and Order dismissing.the o

proceedings..

.On August 11. 1988, the Citizens for Fair Utilitj Regulation (CFUR) filed, with-the ASL8. a Request for Hearing and Petition for Leave to Intervene in both the OL and CPA proceedings in place of CASE. That petition was denied by the Commission in CLI-88-12. Mr. Joseph Macktal' filed a motion on December 30, 1988 requesting the Comission to recon-sider CLI-88-12. and CFUR petitioned the U. S. Court of Appeals for the Fifth Circuit in New Orleans on-February 15. 1989 to review the decision.

L

'On January 19. 1989 Mr. Macktal filed a motion before the U..S. Court of Appeals for the D. C. Circuit to overturn CLI-88-12. which the Commission-has moved.that the Court dismiss.

His December 30. 1988 motion was denied l;

by the Comission'on April 20.1989(CLI-89-06).

l AE00 Analysis of Ooerational Data N/A-NRR Ooeratino Reactor Assessment N/A l

L Public Issues o

Except for the safety-issues associated with the hearings, public sentiment in the Dallas and Fort Worth area, as: reflected in newspaper articles, editorials and television news is principally concerned with L

the plant's cost increases and the state's energy balance.

Attachmeds s

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1. ~ Figures lost e

SALP ort (In ion Re 50-44 7-40 a 50-44 87-31 e ed Oct 1.1988).

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' DRAFT.

Resumes.of:the key TU Electric /CP$ES personnel in-the.following M 1 c

order

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. Larry. $.~ ' Barnes;

' shift Operations Manager

..ORAFTt

DRAFT; John W.iteck' Vice President. Nuclear Engineering;

' DRAFT:

' Michael.R. Blevins

~ Manager of, Nuclear-Operations Support 5 DRAFT lDudley Me Sosesan Chemistry and Environeontal' Manager

-DRAFT i

=M.-D."Bruner

' Senior Vice President'

(

, ; DRAFT' William J. Cahill, Jr.. Executive Vice President, Nuclear T * ' DRAFT

= Richard Daly, Jr.-

Manager. Startup

'i fQ

. DRAFT Doug:L.< Davis.

= Manager. Technical Support 1

DRAFT David E. Deviney Deputy Director. Quality Assurance j

DRAFT;

Joseph W. Donahue Manager. Operations-u

' DRAFT-

$tephen.L. Ellis Perforeance and Test Manager i

. DRAFT-Joe B. George:

Vice President. Support

-9 DRAFT iPh1111p E. Halstead-Manager. Ous11ty Control L

DRAFT Chuck Nogg-Chief Engineer

DRAFT Ausef Musain

= Director. Reactor Engineering

' DRAFT-

-James'J. Kelley. Jr.

Plant Manager DRAFT John't. Krechting.

Director. Technical Interface

. DRAFT.

Dobby T. Lancaster Manager Plant Support DRAFT-G.' Jay Laughlin Instrument and Controls. Manager

? DRAFT Owen W.':. owe-Director of Design Engineering and

DRAFT' Configuration Control l

~ DRAFT.

. David ~R. Moore Manager. Work Control

' DRAFT.

James:W. Muffett-Manager of Engineering-(CECO)

DRAFT:

Robert J. Prince Assistant Radiation Protection DRAFT Manager

. DRAFT

' Michael J. Riggs.

Plant Evaleation Manager DRAFT tric'J.-Schmitt Radiation' Protection Manager DRAFT Austin B. Scott Vice President. Nuclear Operations

[:

DRAFT'

. Peter 8. Stevens Manager of Operations Support DRAFT Engineering Group p_ r f

13.1A-1 Draft Version

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Operators-and startup failure to follow procedures.

Valving errors to start the 2 backflow events.

PT-0102, PT-3701, and PT6403-A

. - 2. -

Operators' lack of sensitivity to the position of valves.

Changing-the AFW valves out of the proper order of sequence.

.3.-

Operators' failure to recognize the significance of the checkvalve backleakage dur< ng the precursor event.

"4.-

Operators' failure to make sure supervision was aware of the 3 check valves that had significant backleakage (precursor event).

l5.

Supervisors' failure to stay informed of plant evolutions and

. problems (the system flushing to solve the chemistry problem and the RHR valving problem during the remote shutdown test.

If checkvalve-had failed,-it would have put RCS water to the RWST.)-

6.

Failure to accurately and adequately document the extent of a problem.

(The precursor event Work Request said " repair check valve leakage.")

No TDR on RHR event. No TDR on PT 4401 and QA person doing surveillance l

did not issue a surveillance deficiency.

7.

Weakness in the documentation of equipment problems in the shift log.

8.

Failure to recognize inoperable' equipment.

9.

Failure to-recognize and document equipment out-of-service.

10.

Lack of adequate comunications between the operating shifts.

11.1 -Weakness in the exchan e of information at shift turnover.

(Precursor event and A ril 23 event)

12. Supervision / Management review of problems documented on work requests. (Precursor event)

13. Failure of persons with knowledge of the precursor check valve problems to raise the information to management.

14.

The slowness and lack of direction initially demonstrated by TUE

,i following the April 23 event.

{'

15; The perception that " Projects and the Schedule" were driving decisions at the time of the precursor event and the start of HFT.

16.

The perception that the Operations staff are not in control of the plant.

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