ML20011E437
| ML20011E437 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/20/1989 |
| From: | Travers W Office of Nuclear Reactor Regulation |
| To: | Sniezek J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20011D121 | List:
|
| References | |
| NUDOCS 9002140039 | |
| Download: ML20011E437 (74) | |
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4 De:e@er 20,1989 ~
5 FIFORANM1' TC4 : Jarnes H. Sniezek. Deputy Director
.0ffice of Nuclu r F:eactor Regulatior F R0! :'
1;illiam D. Travers, Assistant Director'
.for..Special Projects Divisior cf Peactor Projects - III, IV, Y and Special Projecti
' Office of' Nuclear Reactor Regulation Ralph E. Architzel, Plar.t Systems Branch Divisior. cf Engineering Technology Of fic,e of Nuclear Reactor Regulatior
SUBJECT:
P.FPORT ON_SPECIAL REVIEW ASSIGNMEh1 l~
Reference (1) Special Review Assignmerit memorandum, dated November 2, l:
1989 f ror J. Sniezek to W. Travers and R. Architzel (2) Letter addressirig Comanche Peak's Fuel Load Readiness arid the Systematic Assessment of Licensee Performatice (SALP),
dated October 4,1989 from NRC Staff Inspectors to the L
Chairman, USNRC j
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(3) Letter addressing SALP for TU Electric (September 1, i
1986 - July 31, 1969), dateo November 20, 1989 from Billie L
Pirner Garde, Attorney for CASE to James H. Taylor, Acting Executive Director for Operations At your direction-(reference 1), we were assigned to conduct a-special, indepen-dent review of the differences between certain draft and final inspection and i
SALP.. re ports. The assignment directed, in part, that we-(1) detemine the 1
issues that-differ between the draft and final reports, (2) determine, based on our experience anc-knowledge of' NRC requirements and programs, whether there i
is a reasonable basis for such differences and whether the differences have any practical safety significance, and (3) determine and recommend an appropriate.
mecharism for resolving differences that are not explainable and pose potential safety questions.
As' background for this assignment we were provided a Jai ference2),_
- apparently prepared by anonymous NRC staff inspectors, that4ddressed differences
-in_ draft SALP and inspection reports as ona of the factors purporting to show
- that the in-process SALP for the Comanche Peak Steam Electric $tation was
.neither a factual nor a complete reflection of the applicant's performance.
It was noted_that t5e agency had established a Differing Professional Opinion
-review panel to evaluate this memorandum, and that the results of our special review would be provided to the panel. We were also informed that Ms. Billie Garde, attorney for the Citizens Association for Sound Energy (CASE), had in her possession copies of various draft reports that would be made available for our review.
(Apparently the anonymous inspectors provided copies of draf t renach in CEF J We were told that CASE would allow us to review draft N
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- Jeres H._Snierek ~ reports Under their contrni proviott we adherec' to the concitions specifiec. In
. the Specisi keview Assignrnent nernorandura (ref erence } }.
These conditions were ecreec to.by Es. Garde and Mr. Snierek.
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- l.'e travelled to the~ vicinity of the site on November 8-10, on hovember 1F 17 end acain or December 11 13, 1989 to review the documentatien and to meet with CASE representatives, in addittor. to providir.g craf t SAtt ard. draf t Augrrented Jr.spection leam ( AIT) report docunnts for our review lis, Garde inforced us that CASC was in,the process of anal)2ing oifferences among the same dref t reports. (The resuits of the CASE analysis of draft SALP reports were essen.
Rieily included in a November 20, 1989 CASE letter to the Acting IDO
('refererte ?)). These draft reports were the only reports available through CASE at this tirne. Ms. Garde indicated, however, that additicral draft inspection reports in Cases' possessier nay be made available for. NRC review at some future date, it was also roted that CASE had not yet started a review of these accitiorici drafts. The craft reports which were proviced for our review remainec in CASE's possession throughout this assignu nt. Ms. Garce and Mr. H.
- 5. Fhillips, a technical cor.sultant to CASE, were extremely cooperative in arranging for our review of the documents and we would like to note here our appreciation for their assistance.
(Note: Mr. Phillips was previously Senior Resident inspector for inspection Progract, Comanche Peak Project Divisier Office of Nuclear Fcactor Regulation, USNRC, until retirement in July 1989).
In our discussions we asked the CASE representatives whether or not they hac identified, based on their review of the documents or from any other informatier ir. their possession, specific safety issues not' being addressed by NRC programs.
Ms. Garde indicated that, to date, CASE had not identified such safety concerns.
It was noted that CASE's review to that point included, a detailed review of the draf t SALP _ documents, a preliminary review of the AIT report draf t and final documents, and limited discussion with some of the anonymous NRC inspectors.
The-issues which had been identified in CASE's review of the draft SALF documents were characterized as " process" issues.
(CASE had not yet made a determination
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on the existence of any " process" concerns related tc the AIT report documents.)
Ms. Garde indicated that these SALP " process" concerns related principally to unwarranted changes tc draft reports such as,. deletion of negative information en applicant performance, addition of positive information, and changes resulting L
fn a more positive or a less. negative characterization of the reports. These l
issues are discussed in Ms. Garde's letter to the Acting Executive Director for J
- Operations dated November 20,1989(reference 3).
It was also noted that although CASE-had r.ot yet begun to analyze any additional draf t inspection reports, potertial concerns related to those reports were also anticipated to be.* process" concerns. According to the CASE representatives, their discussions with some of the anonymous NRC inspectors supported the identification of
" process" rather than specific safety issues. They noted, however, that CASE had not yet been able to discuss this issue witt all of the anonymous inspectors, and that the NRC would be informed if specific safety issues were identified
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in the future.
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'The fo11cwing setticos. of this reraoranouti report provice; 3) a discussion of th approach used in our review, 2)~ a detailed discussion of the changes nette 1
fir'the draf t SALP reports, 3) a.discutsion of our review of the draf t All
.I report end t) our overell conclusiers resultinc hom these reviews.
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REVIEW ArFROACH l
-A.
SALP Report CASE had-f our draf t versions of the SALP report availaLit f er 'our reviw.
i Diete: Th SALP repcrt for the period of Septenter 1,1988, through ALgust 31,_19E9 bas not beer. issued by the agency.) These included:
(1) Draft A dateo August 19, 1989 (2) Draft B dates! Septen;ber 8, 1905
_(3) Draf t C which was apparently provided to the SALP. board it, advance of the boarc inetting, dated September 13, 1989, and (4) Draft 0, undated, noted to be a version prepared following the board meeting and marked "Not Final Revision 2.'
l Note: The SALP Board met on September 19, 1989.
4 D
We were aise provided ar. acency copy of the draf t SALP report as it 1
existed on November 3, 1989, which we called Draft E.
In addition we were afforded the opportunity to review CASE?s analysis of the differences
.noted among drafts A through D.
This analysis was in a tabular matrix
-form and reflected issues identified starting with Draft A, and noted selsted changes in subsequent drafts.
.Tbt initial approach to our review consisted of a cursory read-through of the various versions _to obtain a preliminary impression of the changes.
We determined that the most substantive change occurred between the pre-and post-board versions of the SALP report (i.e. Drafts C and D). Draft A appeared to'be an early site-prepared. version which lacked a. substantial amount of inferration contained in later drafts. Draft B was a marked-up L_
version that was essentially equivalent to Draft C as marked. We-determined that, although editorial changes and additions occurred, L
deletions of substantive issues and recharacterization of the issues was.
L minimal between drafts A, B, and C.
In addition, we compared Draft D to the Draft E version. Since the Draft E version was provided by the staff, through your office,-this version remained in our possession and was available for a detailed in-office review. We determined that Draft D and Draft E, with only a few changes noted, were essentially equivalent.
Based on this information we decided to carryout our review based on a detailed analysis of the differences between the draft report provided to the' board (Draft C) and the Draft final SALP received from the Comanche Peak P_roject Division (Draf t E).
A detailed.line-in, line-out comparison of the two drafts was prepared ano is presented in the attachment to this memorandum.
It should be noted that Draft E was used as the baseline or starting point for the development of l
the comparison. This was the most efficient approach since Draft F was the l
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3 Nartt 5 H. Sr,1er t 1 4-orly sersior 1r our possession. Text which was deicted from Draft C appears es ree-lir.t" additions to the text of Draf t E.
Additional tcyt c
E added to Dreft E is notec as strikeout text in the comparison.
In a few ceses, in creer to f acilitete our review, text wet relocated within the e
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correrative version, Any relocation bes been notec in the margin commerts.
l Notes it, the margin cf the comparbtive text beve also been er.ade to it.dicate sp cific comrerts about the noteo ch6r.ges.
A surrery of the char.ges between draft C (*areft SALP report") and, draft E (* fir.a1 draf t SALP report") and our ar.elysis of their significence is
~incluccc in the Discussion section of this report.
B.
Augter ted inspection Teart. Report CAST had three draf t versions of the AIT report aveilable for our review.
(Note: The llT report related to auxiliary feedwater backflow events at Corranche Feal was issued July. 10,1905.)
The crafts were reviewed ano compared ageinst the issued report.. Changes were noted but a detailed line-in, line.out comparisen was not prepared.-
Adcitienally, ir a raeeting with CASE representatives, information regarding changes between the drafts and the issued report, was exchanged between NRC and CASE. - This inf ornation was limited to the exchange of i
icertified changes noted scrarately by CASE and NRC. During this exchange the CASE representatives noted that their review of the documents had net been conpleted.
A discussion of the changes noted between the drafts and the issued AIT t
report is preser.ted in the following Discussion section,
- 11. DISCL'SSION A.
SALP Report
~A review of the draft and final draft SALP. reports indicated that the draf t was substantie11y rewritten following the SALP Board meeting. The numerous changes include rearrangement of infor1 nation, editorial rephrasing, and the addition and deletion of positive, negative and neutral consents on applicant performance..However, the overall characterization of the applicant's performance during the period is not significantly different in the two draft reports. Although a few of the changes are substantial enough to potentially impact the assessment in one of the eight functional I
areas, the majority of changes to the draft report are not significant to the assessment.- Accordingly,.the changes are not indicative of an overt 11 reversal from a negative to-a positive evaluation of the applicant's performance or vice versa. The changes, as reflected by the completeness
.and the written quality of the draft final report, also evidence the type of evolutionary process which is typical in the development of a SALP report.
For each functional area a section-by-section discussion of the changes between the draf t and the draf t final reports follows:
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1.
Construction and Corrective Actinn Progran.s h
A large number of char.ges were nace to the drait 5 ALP in this functior4i l:
6 tee. To the treatest extent, however, the changes are editerial anc c0
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not result ir a substar.tial chance in the characterizatier of the erplicant's performance in Construction and Corrective tction Prograr:.
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Aceitionally, changes between thc draf t and final draf t StlP report, includine relocation of information, addition of specific examples erc E
celetion cf information, do not significantly alter the.cverall asse ssment in this f unctional eree.
i The surrary stetements rer.eined' unchanged betweer the draf t ene final l-draft versions in nearly all of the subsectiers.
For example, the subsec.
I tien associatea with " Assurance nf Quality" (NRC Panual Chapter, 0516 I
Table 1) is sumarized-(paragraph A3), in part, in both versions of the 5tlP report as follows-
"Hanagement involvement in assuring quality for these areas was generally evidenced by prior planning and assignment of priorities in all areas reviewed.
Procedures for the control of activities
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were stated and defined." Sirilarly, the sumary statements related to encineering eveluations, constructior activity records, technical issue resolution, resolution of flRC concerns and staf fing (paragraphs A4, AS, A7,-AB and A10), were either not changed or changed insigrificantly. The t
changes that were made within these subsections involved examples, corrents cr other information which did not-result in changes to the overall E
sumaries for these criteria. The overall significance of the changes is net great-for this functional area.
Within the evaluation of construction activity records (parecraph A5) the sumary staterert that these activities "...were generally complete ano
.adequetely maintained..." is unchanged. Two follow-on coments are, however,. deleted in the final draft report. The coments state that in l
some instances "... records were not readily retrievable..." and that this was,.in part, due to "... records not being processed through the records management system and to excessive reliance on personal knowledge to
' locate cata...".
These comments were replaced in the subsection with a coment that "...the retrievability of records could be improved."
Additionally, a coment stating that the applicant "...should review the cortrol of documents to determine methods to improve their retrieval time" was added to the Board Recomendations section of this functional area in the' final draft report It appears that-these changes were focused on eliminating the NRC speci-fication or speculation of the cause of the noted problem, and on adding j
en emphasis that the utility should review the issue and determine how best to resolve it. This approach is considered appropriate and is often used in agency inspection and SALP reports to 1dentify problems and to comunicate the need for utility action. The changes within this subsection are not considered significant to the characterization of the applicant's performance in this functional area.
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teletior, or crarpes of negative inf erration in the craf t SALP was specif1 cally considertd throughout this review, 1105t negative information is t
retait.tt' between the oref t and firal draf t, for example, elthough a negative coreent regarding pipe-support calculations and seatr weld def ects
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appetr5 to be deleted (paragreph A4), it has actua11) teen includec in Sectier, lY.B (paragraph B5) ar.d is refererced in this section (peregraph
-t A(). pre negative comient thet -was deleteo (paragraph A10) involveo e
. concern regardino the extent of the applicent's reliance on contretters anc the " indeterminate" impact of pierr.ed post-corstructier recuttiura 4r
'contrtct personriel. Although examination of the dreft 5 ALP docun'erts does not provide the beses for this celetiur., the coment appears to te speculative and may not appropritte for incicsion in a SAlp report.
Additionally, a portiun (f the-concern is presented in Section IV.B l
(paragraph B10) lastly, it should be noted that the sumary statement for this evaluation criterion (" Staffing" (hRC ttanual Chapter 0516 lable 1) was not changee and concluded staff 1 rig to be adequate. Accordingly, the inclusier. or exclusion of this ccreent is not judged sigrificant.
i-tiegetive corrents were deleted in a few other instances, in e discussiori regarding recurring problems of unrepaired or unauthorized wer6
'(paracraph A6) a coment that applicant actions "...were not always effective in correcting root causes..." was deletea f rom the firal draf t.
The bases for this change is not clear frota a review of the documents.
However, the change is not viewed as significant to the assessment of this functioral area since; 1) the specifics of the " recurring problems" are retained in the final draft report and, 2) the deleted statement is not worded to indicate that this preblem is pervasive, in another instance, in a discussion of the applicant's technical issue resolutions, a deleted negative example was replaced (paragraph A7) with a different negative example. These deletions ano changes are not significant to the SAlp conclusions-for this functional area.
2.
Engineering and Technical Support The assessment of this functional area was substantially rewritten between the draft and the final draft versions of the report. The changes included numerous additions, deletions, rephrasing and s.ovement of discussion into and out of this section. Although a number of subsection sununary statements and conclusions remained unchanged, and many of the changes which were made were not significant, a few of the changes in certain subsections g
' involved a substantial shift from a more negative to a more positive assessment within this functional area. While these changes may be appropriate and may actually present a more correct evaluation of these activities, the bases / appropriateness for the changes cannot be determined from an examination of the draft documents. When considered as a whole, these changes could be considered to result in a more positive characteri-zation of the applicant's performance in this functional area.
(i.e. The assessment in the draft could have supported a rating of Category 3 rather
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ther the Category 2 rating-listec in the draf t final version). The cheroes do oct, however, raise safet) questions but involvt differences in the characterizatier cf the applicant's perferrance in known areas.
A discussion uf the applict:4's subtrittels and responses to NRC request 5 for infornation regarding fSAR amendments ard technicel specifitctions (paraoraph M) was.sutstantially rewritte7..
Sever'el strongly ne96tive corr..t nts were cfleted from this subsection. Although some aspects of these deletcc statements are reflected in the final report, the character-12atior, of this subsection appears to be more positive as a result of tht chanets. The bases for changes tre not apparent from a review of the r
doc ur.ient s. However, the 1ersuage in the draft report does indicete some j
incertistency 1r. that, while the sumary statements are generally l
t positise, the discussion / examples of the activities are, generally, l
strertly negative, The final draft language, conversely, is consistent with pnerally pesitive sumary statenents and less negative cements.
In the subse: tion addressing assessment of the configuration control program (paragraph B8) it was noted thet the applicant has "... difficulties l
in ir;,lementing e truly effective configuration control program [which) hate rewlted in repetitive trinor vio16tions." This statement is replaced L
ir. the final draf t with statements that the applicant "...has implemented an effective configuration cortrol prograr..." and "[o]nly a few riner discrepancies have been identified..." Additionally, the final draf t 1
added that programatic enhancements had been made-to address the problems.
These cFanges appear to result-in a more favorable assessment of the applicant's performance in this area. Although the bases for these changes are not clear from a review of the documents, it appears that the Board concluded that the " repetitive minor violations" noted in the draft version were not indicative of the over.nl1 effectiveness of the program, A strongly negative coment regarding the procurement program wss deleted.
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inthefinaldraft(paragraphB9). Although the statement that noted
... ether procurement problems...have~resulted in the staff's impression that the applicant appeared to be meeting only minimal requirements..."
was rot supported with examples and may be covered to some extent-by the addition, in the final draft, of noted problems in the removal of coatings in the service water systers, the bases for deleting this coment is not clear from a review of the documents. A statement indicating that correc-tive actions were being implemented at the end of'the SALP period was added to the final draf t and may represent updated information on this issue.
A number of other changes, which did not significantly change the subsec.
tion assessments, were also made. For example, changes to a discussion of the statistical aspects and the programatic significance of violations (paragraph B5) were made. This appears to be based on additional or updated information not reflected in the draft report. There is, however, no supporting data, such as an inspection report / violation matrix, which would permit cross checking of these numbers.
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Mary-of the subsections retain the sane conclusions notwithstanding the relocetions are rewording.
For erartplc, the final draf t discussion of the AFW chtcl valve event (paragraph B7) remairis critical cf performance eithough f er e of the detEils of the everit are orr.itted. Specific boarc recommendations for applicant action in this area were added to the fir 41 j
dratt report. Tbt staffing and traininC ciscussiois (paragrephs BIO enc Bil) wtre essentielly unchanged although e substantiel portion of the writt up was mover! ' rom-two other functierel area sections. A disression I
of an acrtinistrative organi:stional change without advance procedures wc!
omittec f ror-the draf t final. This omission (p6ragraph C10) appeart 6propriate 91\\en the context of the discussior- (croup rematrito irtact...re confusion evident... procedures promptly written ano t
implemented), and is net a significant change to the assesstnent.
3.
Safety Assessment and Quality Verification A large number of-changes were made to the draft SALP report in this functional area.- The rnost significant chances were the ir clusion of irformatior. in the final draf t SALP which was not previously covered in the earlier draft SALP. A number of editorial changes and a few deletiert were riso noted in this functional area. The overall effect of these differtrices, however, is' that they do not substantially change the SAlp rcrort assessitent of this functional area.
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/A number of additions were made and included in the craft final SALP, A R
paragraph (paragraph C7) was added identifying, by title, the applicant's self evalu'ation organizations anc programs. The overall adequacy of tb(se organizations and programs was also noted. A paragraph (paragraph C9)
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discussing the applicant's response to an NRC Information Notice was also b,
added. This information appears to update and support the draft-SALP 1
(paragraph C7)_ discussion and conclusion regarding applicant p
resporsiveness.
A' comunent was 'also added (paragraph C10) indicating that l-3 violations in this functional area "... appeared to be isolated anu not
- indicative of a programatic problem." The draft SALP contained no coment regarding the prograsunatic significerce of-the noted violations.
L Twoadditions(paragraphsC13andC14)weremadeinthefinaldraft version assessing staffing and training. The draft SALP report did not discuss these criteria. Their' inclusion in the draft final provides additional essessment information within this functional area. The generally positive'information presented in these additions is consistent with the overall assessment of other evaluation criteria within this foretional area. The addition of this information does not significantly change the evaluation presented in the draft final SALP report.
Anegativeparagraph(paragraphC12)regardingtheapplicant'ssometimes ineffective QA/QC was added to the final draft SALP report. A differert negative paragraph (between paragraphs C6 and C7), however, was deleted in the' final draf t version. - Although it cannot be determined whether the additional'parapraph was added as a replacement for the deleted paragraph, o
l the two changes do not appreciably alter the assessment within this functional area.
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1115 t erificert to note tbH rearly all turmary statteents in tbt i
esalu6 tion criteria subsecticts within this f unctict.a1 area ternaiu esser.
tia'1y unchangte betweer. Or draf t and final draf t versions of the report.
Fer e>arnple, both versions (tte paragrapt C6) note that the ... applicant't.
propret 1er the idertificatier. and corrtction of non. conforming er deficitri ccrditions wts ef f ecitu." Sur'r.ary tt6tements rtlated to stanagement t
involvertrt, prior planning and assignrnent of pri.oru ter, resoluticr, cf ceficier cies, respersiveness tc f3C issuet end hRC assessrtent of ttt plant evaluatiot group, were alst substantially unchanged. The mocificatict t that were inact to the draft $ Alp inclucir$; 1) additions anc or4 deletion previoutly noter:, 0} rumerous ecitorial charges, and 3) deletion of two positive corner 15 (paragrapts C3 anc CA), did not restit in char 4ts to the subsection surraries and do not significartly change the character 126tict
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of thit functional area in the $ Alp report, e
4 plant Operation This section underwent a substantial reworking between the draft and draft fit.61 $ Alp reperts. For the rest part the changes were editorial in reture anc oo not appeer to substantively change the assessinent of the applicant's performance in this functior.a1 area.
Statutical changes were noted in the analysis of violations (parecraph D7). Tte lack of cata, such at a matrix of inspection reports included and violations, does not allow cetermination of the basis for the changes, however, the statem;nts only represent a factual tabulation of violaticrs, therefort this change is not considered significant.
A discussion of an NRC inspection of operating arocedures was rewritten (paragraph 05). Both drafts were critical of tSe quality of the procedures as inspected and noted that corrective actions had beer initiated; however, a strongly negative statement in the draf t to the effect that precedures were not at a quality level necessary for plant operation was deleted.
The basis for deletion of this statement is not apparent from a review of prior drafts. However, since both versions ibdicated existing problems with procedures and that the applicart had initiated corrective actions, the change does no; significantly impact the characterization of this issue. Additionally, the final draft did add a Board recoseendation specifically aimed et corre tion of procedures.
Iriitiation of corrective actior.5, coupled with the board's recommencation, may have been the basis for the deletion of the coseent, h
A major discussion (paragraph D8) regarding the applicant's poor performance relative to several auxiliary feedwater check valve backleakage events was 2
rewritten. Both writeups remained critical of the applicant's performance regarding this series of events. The changes are essentially editorial.
However, the final draft notes a subsequent increased sensitivity te events and provides an example (not in the draft) to substantiate the co8 ment.
Several subsections in the draf t final report were aeded, including a positivediscussionoftheprestarttestgroup'sperformance(paragraph Dg) and a neutral discussion of the training program for operations and supportpersonnel(paragraphD11), Several positive coseents in the draft
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report were deletec it the draf t finel (eg. petagregt. b3 regarding atility to meet sctievles ant pt.ragraph LC regarding control roort modificatiers art access cCt.trols).
The ctanges between the drtit er.d finel 5 ALP reporte tid not appear to be substet>tive and art not cons 1ctred to havt e significabt effect er. t%
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l'ainter.ence and Survtillanct 1 1erge nurber of changt! Were madt to the draft SALP report is, this furttional eree. As discussed below, however, the changes art not
. significtrt and do net change the characteritation of the applicar.t's performance tii this functici.61 area.
The changes in this section are principall) editorial, f or 'exemple, two discussitt.s (paragraph [3) of applicant weaknesses and related viointions are retainec in the final craf t version but have been rewordet. Another
' discussion (paragraph E6), irvolving positive coments about NRC observation o' aintenance activities is also reworced in the final draf t report. Tbtse aid a f ew other minor changes do not significantly af f ect l
the report, j
/, teletion (paragraph between Ed and ES) of infortnation noting that the l,
arplicant ceseloped and ir.plemented an appropriate maintenance cuality assurance program, and that a significant problem was identified by the 1
prograrr, and is being corrected, appears to be covered in the filial draf t (paragraph E3) with a simple statement th6t the quality assurance main-tenence program is 'adeovate. A positive coment about maintenance activities using up-to-date procedures was also deleted (paragraph E4).
This coisnent,)however, also appears to substantially addressed elsewhere (paragrapFE6 in the assessment. Again, these are not significant chenpes to the report.
6.
Security This functional area underwent a moderate revision between the draf t and the draft final SALP reports. Many of the changes are editorial in nature. For example, a statistical discussion of violations was deleted (paragraphF2;noviolationsinthisarea),
it should be noted that l
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statistict on violations were uniformly deleted in the functional area
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text sections, yet retained in Section V, Supporting Data and Sumaries, i.
Table 1.
In addition changes were made that appear to reflect additional factual infomation or celetion of specific information. For example (paragraph details of specific security problems being experienced as the FS)licant entered the final phase of a staged lockdown of the protected app and vital areas were deleted.
In place of these details, the final draf t l
report addressed applicant acknowledgement of r ablems during this transi-l tion and plans to perform a self-evaluation to :dentify and correct deficiencies. A positive statement on the basii for the security program was also toned down (excellent to acceptable).
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. Jernes F. Sidetek The ctanges weu'r ret siprificantly thttpe the cheretter126ticr cf the agplicant't perf ormer.ce in this f ur.ctior al arte, nor would they subster..
i 11 ally alter the SALP cor.tlusions.
7.
Faciologiu.1 Controls i
This section was miratrally revisec betweer. tre draf t anc craf t 11:41 ! Att reports. The maKrity cf the rtanges were rc,inor and ettitorial in f.eture, i
l in eccition, neutral backgrouno inf ormation describing the recietion prctectionpretratastatustravagraphGil)wasdeleted.
The or.ly substantist change appears in the ctletion ci two paragraphs 6ceressing the app 11c6nt's performance on sutaittels (between paragraphs 1
GE erd G9). One paragraph 6.as very negative addressing comunications probleris, incomplett responses, and an apptrent request to only enert fMnitelly acceptable stancards. The subsequent paragraph assessed the t
applictrit's perf ormance for the Raciological Effluent Technical Specifica.
tions ane Of f sitt Dose Calculational t'arval as very positivt (*cutstandirg performance *).
1he deletier cf the two ptragraphs results in an j
essertially balanced offsetting of positive and negative cce ents, bewner, the basis for delttion of these paragrapts is not apparent. A plausitit ration 61t iray be the relocation of all discussion on applicant submittels to the Engineering and Technical Support Aree (paragraph E,t.) in the final draft report.
[Itshouldbenotedthattheseparticular deletiens occurred between Drafts 0 and E, and would not have been evident duringareviewcfearlierdrafts).
Overall, there are no changes in this functional area that would have any significant efftet on the SALp conclusions.
8.
Emergency preparedness Only a few changes were made to the assessment of this functional area.
Most of these changes were editorial. As discussed below the chances to the draft SAlp report do not alter the characterization of the applicant's performance in this functional area.
One change involved the substitution of "open items
- for ' exercise weak.
rtsses" in the discussion of the applicant's performance during the pre licensing emergency exercise (paragraph H7)(.
Since these findings are defined differently in NRC Hanual Chapter 0610 i.e., ' exercise weakness
- g isamoresignificantfindingthan"openitem')thebasesforthischange is not clear from examination of the draft and draft final reports.
However, the use of ' exercise weakness
- does not appear to be appropriatt as used in this subsection. Since an ' exercise weakness" is a finding that the applicant's performance 'could have precluded effective is91emen-tation of the emergency plan in the event of an actual emergency..., the use of this te 1n is inconsistent with the unchanged conclusion in the report that *...the inspection team concluded that the applicant had demonstrated the ability to implement the emergency plan in order to protect the health and safety of the public.' Accordingly the change fror'
- exercise weakness' to "o wn item
- appears to be appropriate and does not significantly alter the claracterization of the licensee's performance in this functional area.
,1 j
serrs H. Scie:06
- I? -
i B.
Auertraed Inspection Teart Feport A review of the dref ts (proviceo by Cast) erd the isst,tc inspectior report trcitated trat relatively few charte s to the drof t versions had been r..et't,
i A nun.ber o' the changes 1 4volvt-d ttr additier. cf it.formatier which suitit-l rherts discuffion in the croft reports.
For exertpit, discussich of an adcitterti potentiti tailurt n.ede of the AFK system 15 presented in ite section (2.8) related to tht erelysis of safety significance, f(cition-all, it the sectier. (2.4.1.3) related to iraestigetive actiori, tt,tple.
3 rantary trf ortnation about radiographic tertir.g of check salves was ecctc te the final report.
A ftv regativt corments werr reted to have been dropped froft the draft ver$1ons. For exarrie in the section (2.5.1) discussir.g operator actions the f ellowing coment was deleted; *(ilt would appear that mar.agen,ent wet cr. a fast track for HfT".
teditionaily, a coirpert that "... operability should have been an en.ptesized concept", was dropped fron the final repert, r
Our review detern.ir.ed that the few changes that were made did not signifi-cantly alter the enalysis presented in the draf t reports. The conclusions and recorrerdetions of the report remained essentially unchanged. Tht thanges which were made appear to bt typical of changes made curing an inspection report review precess. The scopf: of issues covered.in the report eid not change and differences noted between the draft ar.d final reports do not raise safety issues.
111. CONCLUS!Of:S The changes made to the draft finel version of the SALP report, generally, do not significant1) alter the characterization of the applicant's perfor.
mance during the assessment period. While there are numerous changes, i
nany are editorial anc most changes (e.g., deletion of some negative ar.d positive coments) appear to be int.ignificant in the context 0" the evalua-tion. Many of the sumary or conclusory statements within the functional arest remained entirely unchanged between the two draft versions. Most negative cossents are also substantially retained in both draf ts. Although relocated, expanded or some negative discussion is rephrased, abbreviated,ignificant to the added, the impact of most of these changes is not s evaluation presented in the report.
k The charges made to the draf t version appear to be typical of the evolu-W tionary process associated with the development of a SALP report. Many of the changes, for example, provide additional discussion and examples which are relevant to the evaluation.
In some instances summary or conclusory statements, missing in the draft, have been added to the draf t final report to characterize a functional area or a subsection within a functional area.
Adcitionally, many of the changes are editorial and appear to te focused on improving the overall civality of the report.
A few of the changes do appear to have a potentially significant impact in one of the eight functional areas of the report. Several negative coments, which were either rephrased or deleted, toulo be considered to result in a more positive assessment of one functional area in the final draft report.
(i.e., The language in the draft coulo have supported a rating of Category 3
Jet ti P. $nie:ti. in *Engiu trine ard 7t chnical SLitort" rather than the Cetegory 2 rating listed 11 tre draft fitti report.) Althoupt J is less negative charetteri-Ittien may bt ocre correct Prd warrantec, the bases for the chariges are not apperent beset solely on a rtTiew of the dccuments. Such changet tre nt,t etypical during SALP covelopment ano appear to represent a differer.cr of stems about the significance 01 the noted issue,s. Accitict. ally, the changes do rtt raise a sefety questier. but reflett a different assesstirrt of perturmance bestd on conslotration of similar information.
Dvtre11. the char.ges to the dref t SAlp report do not arrear to be f ocused on ut.ilateral irrprovement it, the characterization 01 the applictr.t's per'ormance.
At. r,oted, most of the changes do not substantially irrprove or cirnnish the eveluation.
Jr. several instances, ih fact, nepetive characteri2atict.s have been added or strengthened ir the draft final versior.,
Although the bases for some of.the changes are not apparert from a review of the draits, the changes appear to be characteristic of the SALF cevelopment precess.
Inhertntly that process, which is a step ty-step 53rthesitation of "... HEC senior management's observations 400 judgernerts..."
(hRC Manual Chapter 0516), is subject te change and refinement as adeitier41 expertise and manageinent experience is incorporated. The types of changes noted in the drafts, including those in the most significantly affected furttional area, do not raise safety quest 1ons art appear to reflect tht-reasor,able incorporation of additional instehts and experience.
Very few changes were made to the draf t versions of the AIT report. The changes which were made are insignificant to the analysis presented in the draft reports. The conclusions, recors.encations and the characterizatier of events in the report remain essentially unchanged. Most importantly the changes, which appear to be typical of the agency inspection repcrt review process, do not raise safety questions.
RECOMMENDATIONS The Special Review Assignsent memorandum (reference 1) directed that we provice recommendations for resolving safety concerns arising from the review of the various draft reports. We have concluded that none of the differences noted in the draft SALP and AIT reports have any practical safety significance; therefore, no recossendations are provided in this context.
However, we recorrend that the DP0 review panel, which has been established to consider the concerns of anonymous NRC inspectors (Reference 2),
)
attempt to determine the bases for a few $ ALP-related changes noted in this memorandum report. Specifically, these changes include, those in the Engineering and Technical Support section of the draft $ ALP report and the change related to the quality of plant procedures noted in the Plant Operation section of the draft $ Alp report. These changes are discusseo in detail in sections 11.A.2 and 11sA 4 of this report. Although these changes do not raise safety questions and may be warranted, our limited review could not determine a clear bases for the changes. An understanding of the bases for these changes would be useful in assessing the validity of the concerns which have been raised by anonymous NRC inspectors.
j James F. $rierek
- I I.
f tccittor.611), our review icentifirf two triner ciiferencet for which we cc have recorrendet 4hs that tr6y ethance tbt final report.
(These recorrer,-
dattr rs reay be gerrric to the 5t!P procest.)
(1) The lrtrocuttiori (Section 1) lists both StLP Board members anc j
sti.a ra tei) e list of perscr.rel who eitn participatto in the St.tt Board process. Ttt latter list changed dering the orttts, both celetirp and addir,g persuhr.(1 and changirig the characterizeticr. f ror.
acciticrel attercance at the r:.eeting to rcrticipation in the precess, lhe ccrrent charetterizatier is obviously incomplete: inany rnere ir.cividuals than thost listed participated in the process, itcludir.g site, headouarters, and regior-based indisicuals. We believe it would t'e dif ficult and of litritec value to capture a certplete list of participants. We recomenc that the fir.e1 SALP report reflect all attendence et the meeting (in addition to Board members).
(2) The Supporting Data ano Sumaries (Sectier. V) provices a tabulation cf NRC er.forcement activity for each functicnal area di, ring the assessaient period (Tabit 1). This tabic changed durit.g the drafts; however dete is not provideo thet would allow a determir.ation of which inspection reports were includte for statittical purposes, etc.
In additict., although the table provides a ir. atrix of total enforcernert attivity sorteo by severity level and functional erea, there is no way to tell which particular violatier was categorized in any srtcific functicinal area. We recomend that the fir.61 SALP report provide e list of enforcemert actions issued, including the corresponding report and associated identitying number, the severity level, and a cryptit description of tbc action. A clarifying corment should also be added that other (non-issued) enforcernent actions have been consicered in the assessment, if this is true.
Regarding the latter recorantndation, the Commenche Peak SALP report coes conform to the guidance for Supporting Data provided ir F.C 0516.
hlL=T -lM'N-%
William D. Travers, Assistant Director for Special Projects Division of Reactor Projects - 111, IV, Y and Special Projects Office of Nuclear Reactor Regulation i
Ralph E. Archittel Plant Systems Branch Division of Engineering Technology Office of Nuclear Reactor Regulation t
I L
Enclosure:
l As stated i
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1 Attachrent i
UNITED STATES l
NUCLEAR REGULATORY COMMISSION De cl.e t s :
LO-445,'BE-FL LD-44C/6E-!.1 l
Mr.
W.
J.
Cahl)), Jr.
Executive Vice President, Nuclear 7exas Utilities Electric Company 400 North Olive Street, Loch Box 81 i
Dallas, Texas 70201
Dear Mr. Cahil):
?
l' t
This forwards the initial report of the Systenatic Assessment of Licensee Performance (SALP) for Comanche Peak l
Steam E3ectric Station (CPSES) Units 1 l
Text appearing a. n and 2.
The SALP Board met on September redline was i
19, 1989, to evaluate CPSES performance deleted and text for the period of September 1,
- 1988, appearing in through August 31, 1989. The performance t...
""'""'y,,
analyses and resulting evaluations are added between the documented in the enclosed draft. n ;, ; e,.
draft and draft SALP Report.
final reports 1'
\\
In accordance with NRC policy, I have reviewed the SALP l'
Board' Assessment. I concur with the ratings.
This assessment was conducted in accordance with NRC Manual Chapter 0516.
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l A management. meeting is scheduled with you and your staff on October ify 12, 1989, at 1:00 p.m..to review the results of the SALP report.
Within 30 days following this meeting, you are requested to provide your comments, if any, to this office.
Comments which you submit are not subject to the clearance procedures of the office of Management and Budget as required by the Paper Work Reduction Act of 1980, PL 96-511.
A copy of your written comments will be included in the final distribution of the SALP report.
Sincerely, D. M.
0;nni; M. Crutchfield, Associate Director for special Projects Office of Nuclear Reactor Regulation cc w/ enclosures:
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U.S.
NUCLEAR REGULATORY COMMISSION OTTICE OF NUCLEAR REACTOR REGULATION l
COMANCHE PEAK PROJECT DIVISION r
b SYSTEMATIC ASSESSMENT OF LICENSEE PERTORMANCE Inspection Report 50-445/88 50-446/88-81 Texas Utilities Electric Company (TV Electric)
Comanche Peak Steam Electric Station
- Units 1 and 2 0;;h:t; 50 4 5; ;0 440 Unit; ; :nd September 1, 1988 - August 31, 1989 I
s 6
1.
I NTR ODt'CT 3 ON The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available-observations and data on a periodic basis and to evaluate applicant performance on the basis of this information.
The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations.
It is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback to the applicant's management regarding the NRC's assessment of the facility's performance-in each functional area.
A NRC SALP Bo'ard, composed of the staff members listed below, met on September 19 to review the observations and data on performance and to assess applicant performance, in accordance with NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." The guidance and evaluation criteria are summarized in Section III of this report.
The Board's findings and recommendations were forwarded to the #RC Associate Director for Special Projects, Office df Nuclear Reactor Regulation, for approval and issuance.
This report is the NRC's assessment of the applicant's safety performance at Comanche Peak for the period September 1,
1988, through August 31, 1989.
The SALP Board for Comanche peak was composed of:
Chairman:
C. I. Grimes, Director, comanche Peak Project Division Members:
A. B. Beach, Director, Division of Radiation safety and safeguards, Region IV T. P. Gwynn, Deputy Director, Division of Reactor Projects, Region IV J. P. Jaudon, Deputy Director, Division of Reactor P
safety, Region IV i
i H. H. Livermore, Lead Senior Inspector, comanche Peak Project Division J. E. Lyons, Assistant Director for Technical Programs, Comanche Peak Project Division P. F. McKee, Ohi:f, C:f ;;;rd; Dr:7.;h, O!!ic cf
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(T;r;;r-Deputy Director,. Comanche Peak Project Divisient l
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P. Warnick, Assistant Director for Inspection Programs, Comanche Peak Project Division J.
S. Wiebe, Senior Project Inspector, comanche l
Peak Project Division J.
H. Wilson, Assistant Direc' tor for Projects, Comanche Peak Project Division r
L.
A.
'.'; n d; 1 1, reputy Dir;;t r, Divici;n of P;distien 0;fety and 0;f;;;;rd;, 0;;i n I" i
i The following L
EARLIER DRAPTS NOTED ATTENDENCE AT Personnel also s
participated in the MEETING HERE (ATTENDENCE IS MORE SALP Board process.
APPROPRIATE THAN A PARTI AL LIST OF PARTICIPANTS IN PROCESS) 5 J. L. Birmingham, RTS Consultant (Quality Control), Comanche Peak Project Division S.
D. Bitter, Resident Inspector (Operations),
Comanche Peak Project Division S.
P. Burris, Senior Resident Inspector
~;
(Operations)
..-...j;;t; Oivici;n
....i;r ;;;it;;t Ir.;;;;t r, Comanche Peak Project Division)
R. M. Latta, Resident Inspector (Electrical),
Comanche Peak Project Division W. D. Richins, Parameter Consultant (Civil Structural), Comanche Peak Project Division Y-M. F. Runyan, Resident Inspector (Civil
/
Structural), Comanche Peak Project Division P. Stanish, Parameter Consultant (Mechanical),
Comanche Peak Project Division W. P. Chen, Parameter consultant ( 6 cal),
Comanche Peak Project Division J. R. Dale, RGGG Consultant (Civil Structural),
s I
Comanche Peak Project Division W.
D. Johnson, Senior Resident Inspector (Operations), Comanche Peak Project Division i
B. Murray, Chief, Radiological Reactor Prograrc Branch, Region IV J.
L. Taylor, Parameter Consultant (Electrical),
Comanche Peak Project Division 4
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(Narrative overview of applicant's performance will be j
provided including noted strengths and weaknessess.)
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9 runctiona) Area Performance Performance Trend 1
l Construction & Corrective
)
Action Programs **
2 Action Prc r r;--
2 2
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2
.iping ;y;. i ;;pp;rt; O
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2 i
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N;n:
Safety Asses, & Quality Ver.
2 2
N;n:
Plant operation 2
M;n:
Maint, & Surveillance NR N;n:
Security 1
M;n;
+
i Radiological Controls NR 0
N;n; i
0 N;n; NOTE NR = Not Rated: N/A = Not Applicable Performance Trend:
Applicant performance during the last guarter of the assessment period is examined to determine if a trend exists that could be'used to predict applicant performance during the first few months of the next
.<__.._<_.'. 3 di;;;rnib'; t;;nd in t'.; :pp'i;;nt';
assessment period.
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It is reserved for those instances when it is necessary to focus NRC and applicant attention on an area with a declining performance trend, or to acknowledge an improving trend in performance.
cumulative average of performance categories of construction and CAP activities from 1987 SALP.
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10 I31. Criteria Applicant performance is assessed in selected functiona) areas, depending on whether the facility is in a construction or operational phase.
Functional areas normally represent areas significant to nuclear safety and the environment.
Some functional areas.may not be assessed because of little or no applicant activities or lack of meaningful NRC observations. Special areas may be added to highlight significant observations.
The following evaluation criteria were used, as applicable, to assess each functional area:
Assurance of quality, including management involvement and control:
Approach to the resolution of technical issues from a safety standpoint:
Responsiveness to NRC initiatives:
Enforcement history:
Operational and construction events (includin'g response to, analyses of, reporting of, and corrective actions for):
Staffing (including management); and Ef fectiver,ess of training and qualification program.
However, the NRC is not limited to these criteria and others may have been used where appropriate.
On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definitions of these performance categories are as follows:
y A.
cateaorv i Applicant management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements.
Applicant resources are ample and effectively used so that a high level of plant and personnel performance is being achieved.
Reduced NRC
x 11 i
?
attention may be appropriate.
l B.
Catecorv 2 Applicant management attention to and involvement in
[
the performance of nuclear safety or safeguards activities are good.
The applicant has attained a level of performance above that needed to meet regulatory requirements. Applicant resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved.
NRC attention may be maintained at normal levels.
f i
C.
Cateaorv 3
' Applicant management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficient.
The applicant's performance does not significantly exceed that needed to meet minimal regulatory requirements.
Applicant resources appear to be strained or not effectively used.
NRC attention should be increased above normal levels.
t 1
i
I 12 j
l IV.
Ectferrance Analysir I
A.
Ernstruction and Corrective Action Proorars i
1.
Analyses This functional area includes all applicant activities associated with the i
Al erection of structures and the installation of those systems and Paragraphs were equipment required for the operation of numbered alphanumerically the Comanche Peak plant.
Further, it j
addresses the compliance of those by section using activities with design specifications, the after board industry standards, and regulatory draft report recieved on requirements.
The majority of NRC inspection efforts in this functional November 3, 1989 erea involved the evaluation of TU Electric's C;rr: tiv: Acti;n Tregr;;
Editorial change (CAPty including the Peet-0;n:ts;;;ien only "Ordu r: V: lid;ti;n Tr;; ram-4PCHVPtv as well as completion of the construction program.
The CAP is the applicant initiated program to address and resolve specific C;;.:nch: P :t 0 :p;n;; T:::
(CPRTt and other external source issues.
The PCHVP is the portion of the CAP which validates the final acceptance attributes for safety-related hardware.
The NRC staff assessment of this functional area included the inspection of electrical equipment, cables, instrumentation, mechanical components, piping and pipe supports, HVAC, h:: ting, v:ntil;ti;n :nd ;ir ;;nditi ning G VAC),
structural-steel, concrete structures, and other safety-related items.
s
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13 rifty Nnc in;p:: tion; cf : n;;ruction
- nd: CAP ::tavitica, including thr : tece A;
STATISTICAL in;p ti;g;, deter 7 ged th;t i
een;t rett a en ::t avat a;; u;r
- n;r;441 pggeygggog op VIOLATIONS
- II P;TI;5;;d "Eth ;$;5;;t; PREVIOUSLY IN A9
$0;";;ot;ti;U OCd ;" ;FFT;F;;;t#
- nv;)v ::nt ;f qu;1ity :;ntr:1. Ext.ri4t-e
'f ";$1 E;TI T;;d COU;tii;t500
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ADDED SECT
SUMMARY
-'llVita.;; "Ato;;;;d ?T AL;E;; tid Di th; INCLUDING QA AND EXAMPLES Or WELL NEC ?I;II iG;P;;t;T; AU;2-f;d COU;;;t; pgprogggp 7:p:;r eng-pj;;;;:nt ;;tavatig; r:10ted i;E
- t";;C FT';;si OEd th; ;;i;Ei;ldini ";1I;'
10 CONSTRUCTION i;i ;;;;;ot OI l
- "d; Y A
i ACTIVITIES etructurel ;t;:1 b;1te, :nd b;;; plet in;tell;ti;n.
ll;u:v;r, occasional mir or programmatic breakdowns did occur.
A pipe support angularity problem identified by the NRC resulted in reinspection of over 5,000 pipe supports and necessitated a significant amount of rework.
r;r ;;;;;;;, : pip: ;;;;;rt ngul;rity pr;bl r id;ntifi;d by th: NDO n:::;;iteted ; rein;p:: tion by th:
- pplicent ;f ev;r 5,000 pip: ;;pp;rt; and 7:; ult;d in eignific;nt r;u;rh.
Management involvement in assuring quality for these areas was generally A3 evidenced by prior planning and assignment of priorities in all areas NO CHANGE IN reviewed. Procedures for the control of
SUMMARY
activities were stated and defined.
Deficiencies were noted in some TEXT REWORDED No procedures such as structural steel l
SUBSTANTIVE CHANGE platform inspection procedures, a seal i
welding procedure which had no requirement for verifying any resulting valve stem angle changes, and a check valve backleakage test procedure.
These procedures were subsequently revised to l
adequately address NRC identified concerns.
Corporate management involvement was usually effective in all construction disciplines.
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eeneeenes--Management involvement was
- 1;;
vid;nt d: in; OvideneGS Dy frequent status meetings with NRC
o-i 14 i
inspectors to provide updates regarding proposed or ongoing plant activities.
One example of management involvement was the effective corrective actions taken to address deficiencies in L
concrete attachment spacing.
In general, engineering evaluations were determined to be technically adequate A4 and corp 3ete during team inspections of the CAP.
Within the electrical ares, NO CHANGE IN the increased er(Saris on identifying SUKP.ARY No CHANGE TO ROOT the root cause Ot' leficiencies and establishing adequate corrective action CAUSE IDENTIE2 CATION indicated an improved management
__g;,
pg.;;;d-pg NOTED AS A commjtmenttoqua1{ty.
d:
POSITIVE
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e Aet4 ;n Pr;;r;;;r i
In the piping and pipe supports area, bowever, a violation as issued due to DOLD COMMENTS NOTED aultiple examples of ineffective reviews IN B5 ALREADY AND of calculations.
In this case, RETERENCE TO THAT IS ALSO NOTED HERE management was slow to recognize that a (SEE ABOVE PARA.)
gen *ric problem existed, even though the problem had been identified in several NRC inspection reports, in Technical Audit Program audits, and Engineering Functional Evaluation audits.
Amether violation was issued for ma inadequat) sagineering evaluation of seam weld defects in tube steel.
In addition, some design change authorisations (DCA) and nonconformance reports in the civil / structural area initially had inadequate technical evaluations.
Corrective actions were implemented and staff review of calculations performed later in the SALP period indicated an improvement. C;;s;;tiv; ;;ti;n; ;;r;
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Records of construction activities were generally complete and adequately A5' - NO CHANGE IN maintainedi however, in some cases the
- suggAny.
records were not readily retrievable.
OFE PLAUSIBLE This is due, in part, to records not REASON FOR RECORD being processed through the records RETRIEVAL PROBLEM management system and to excessive WAS DELETED.
reliance on personal knowledge to locate 1
HOWEVER BOARD data in a timely nanner. r-ee RECOMMENDED THAT i;tTI;V;bi25tY ;'
- sd; ;;;1d b; APPLICANT EXAMINE AND IMPROVE Ef;;V;da RETRIEVAL -
CONTPASTS WITH NRC SPECITICATION OF CAUSE OF PROBLEM 6
(
Corrective actions for identified deficiencies were,not always effective A6 in correcting root causes, as evidenced ROOM WALKDOWN by recurrence of some issues. A DISCUSSION MOVED recurring problem M ;;rring ps;il;;; of TO A6 FROM DRATT unrepaired damage or unauthorized work RECURRING PROBLEM was an issue that resulted in the RETAINED BUT ROOT CAUSE LANGUAGE applicant p ggng ].;g{i r;{,ig {,;_gn DROPPED (HOWEVER r r - - ';;.- " 5 - ;;, -"- -,7
, - 1', :
ROOT CAUSE
---"--i-"~"-"i-------"----r---
t in;^>;r t; ;F;;;tiene Performing e LANGUAGE IS detailed walkdown of-rooms and areas to CONSISTENT WITH identify deficiencies.
An WRC CATEGORY 2 MC inspection performed late in the SALP 0516) period of two rooms, for which the walkdown was complete, identified
- n s
- 1 numerous deficiencies in the electrical conduit installations as well as two potential mechanical snubber problems ;hich h;d 7.;t i;;r. id
- r.ti'i;d by th; ;;pli;;.nt, g'he existence of these types of deficiencias which were not identified in the applicant's room walkdown process was identified as a violation.
This violation toeted that improvements'~1n the t's walkdown process was no Problems sometimes reou re they were affactively resolvagu... __ fit 1:n, QC inspection errors during the evaluation of structural steel under the
f.
i 6
16 j
5 i
CAP program were identified in several l
n NBC inspection reports before action was taken by the applicant to evaluate and resolve the concern.
Th; MOO i; continuing to evaluate the pplicant's
- TT;;tiV; 015 L.
?'
The applicant's resolutions of 0;;hni;;l 5;;;;; IE;I'd509 ;;I'I id;I'III5;d A7 NO CHANGE IN
+
d'I5CI;DC$i; ";T; 9;^;T;I i #;I;;;5L;d
SUMMARY
- ONE t; bc ;ff;;tav;. ; elf-identified NEGATIVE EXAMPLE deficiencies were generally acceptable, i
DROPPED; ANOTHER The final responses to these self-
'i NEGATIVE EXAMPLE identified issues were generally sound ADDED - ADDITION and acceptable but occasionally lacked IS SOMEWHAT MORE thoroughness and precision.
For i, -
pggg77pg example, NRC review of a significant deficiency action report (SDAR) identified an incorrect groundwater elevation was used in a structural evaluation of the service water intake structure. Typi;;11y, th; ;ppli;;nt ;;;d v;r;t ;;;; er ;;n;;rv;tiv; ;;;;;pti;n; ah;n pr;;i;; 1;;d; er ;;nditi;n;-eewtd not b; 4;;; rain;d. In ; f;; in;t;n;;;
~,
- h ;; th; piping ;;pe;rt ;;;;;;d u;1dju;1d it ap p
- ;h!;;, it ;;;
n;;;;;;ry f;r th; NOC t: ;;;;;
- dditi;nal
- ngin:: ring it reti;n; bef;r en ;d;;;;t; r;;;;;ti;n ;f th; f;11 t;;hni;;; i;;;; ;;; d;;;n;tr;t;d.
Resolutions of NRC concerns were generally viable ;;ti;f;;t;ry but A8 NO CHANGE IN occasionally lacking in thoroughness or
SUMMARY
- ROOT depth, ;;;h th;t ;;ppi;;;nt:ry r;;;;;;;;
CAUSES ADDRESSED
- r; r;;;;;;d. Acceptable resolutions were generally proposed but supplementary responses were sometimes required.
The applicant wee-bas occasionally ;;;; 0; ; der;;; fully shown a reluctance to fully address the generic implications and/or root causes of NRC concerns in-depth.
This was evident by the applicant's responses to 4
violations for problems with QC inspections of structural steel platforms, QC measurement techniques, f
service water tube steel supports, and undersized welds on duct supports.
Repeated meetings between the NRC and the applicant's representatives were required before acceptable resolutions
i 17 r
to these issues were achieved.
WRC personnel performed inspections of construction and CAP activities A9 resulting in 50 reports imeluding three PARAG ON QC team inspections of the CAP.
Other NRC INSPECTION ERRORS inspections were performed which, in MOVED TO CB BOLD TEXT MOVED To part, also evaluated construction or CAP activities.
The NRC inspections A2 resulted in the issuance of 12 THIS PARAG MOVED violations and one deviation.
Seven of TROM BEGINNING Or the violations were for QC inspection SEC A IN DRATT.
errors and appear to have been isolated.
SPECITIC NO. OT However, most of the remaining VIOLATIONS DROPPED d fICI!7CI'8_[9[j,OE,f[f[jf}f;Qf,,_,,__
f BUT SEVERAL
-"'--'-"v NOTED - N/C RE:
ISOLATED I{_k9fiffikf(([T((^![fifk^j[i,})f30 CASES /PROGRAMMATI C
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ppostggs g were for programmatic problems such as, EXAMPLES - ADDED field verification methods (TVMs)
+
INTO RE:
failing to provide sufficient SATISTACTORILY instruction for verification of RESOLVED inaccessible attributes and QC measurement techniques being inadequate to correctly identify valve stem angles.
59.f. i. 5.,..b If. E.I. I. s 5, -5. I. _.!.f.." 5'.2
- "i Staffing +e-in the various disciplines appears adequate as evidenced by the AID majority of construction activities PARAG ON MINOR remaining ;;;;nti;1'y nearly on PROGRAMMATIC schedule.
Key management {ositions are BREAKDOWNS MOVED TO A2 AND BB - N/C
- ' -- ---" -- r---"-
Adentified, and the responsibilities of
SUMMARY
-DROPPED each position are defined. The staff's DISCUSSION OF evaluation of the applicant's INDETERMINATE IMPACT OF PIANNED performance determined that the technical expertise to support REDUCTIONS.
construction and CAP activities is l-GENERAL DISCUSSION available.
However, the impact of OF TECH SUPPORT planned reductions to the number of AND USE OF construction and engineering parsonnel, CONTRACTORS IN B10 subsequent to completaon of construction and CAP activities, is indeterminate.
The level of reliance on consultants and contract personnel is hip.^
ile applicant personnel are i in major issues, it is apparett t
consultants take the lead iving many technical issues to table conclusion.
Examples inclu8e the
~-
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o i
1 1B corponent cooling water pipe jacking and other piping issues, as well as the ATW check valve issue.
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2.
Perfernance Ratina The applicant's rating is performance Category e in this area.
t 3.
Board Recommendations 1
a.-
Recommended NRC Action Mener 1
l b.
Recommended Aeolicant Action i
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4 NRC reviews of engineering and technical support activities eee.;rred= generally B2 arise during performance of other NRC LARGE, GENERALLY inspections of construction / CAP, plant POSITIVE SECTION Operations, and reviews of applicant ADDED WITH responses to NRC findings or SUPPORTING 2__
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2D Corporate management wee is frequently involved in site activities as evidenced 33 by actions showing their interest in and THIS PARAG MOVED knowledge of t;;hni;;; ;;n;;rn; :nd ypog ggp oy 37 t he i r r;;;1M-te+w TSAR commitments.
EDITORIAL CHANGE
.~..s The applicant's submittals for TSAR amendments or revisions to the proposed B4 technical specifications are generally THE DRATT "C" technically sound and clearly described.
LINEOUT DISCUSSION The quality of the submittals ON SUBMITTALS WAS demonstrates that the applicant has an ALSO IN OTHER experienced and qualified staff, SECTIONS; However, in many instances. when the NRC INCLUDING B, C,
staff requested clarification or AND G NOCHkNGEIN additional justification, the applicant's responses were received late l
SUMMARY
- OVERALL and often provided little or no PARAG WAS REWORDED additional justification.
This problem AND SHORTENED!
was especially noted in the amendments DEEMPHASIZING SOME for auxiliary systems and the initial OF THE HARSHER SPECITIC EXAMPLES.
startup test program.
The applicant relied on meeting the "mininua" NRC THIS APPROACH requirements, as determined by the APPEARS CONSISTENT WITH INITIAL applicant, as a basis for not performing certain important preoperational tests CONCLUSION BUT MAY (instrument air) rather than providing RESULT IN A an adequate technical justification.
SUBSTANTIAL CHANGE The staff notes that further revision to IN the FSAR will be required for some q
CHARACTERIZATION items.
However, in a July meeting OF SECTION between the NRC staff and the applicant, certain issues for section 6 of the proposed technical specifications were tentatively resolved.
Final NRC approval will be based on an acooptable incorporation of these proposed resolutions into a future PSAR amendment.0; ring th; r; ting p;;i;d, th;
- ppli;;nt ;;b;itt;d 1;r;; r^^";r ;f I"59$5;i35_3; $ f 5 3 55$ 225[iE!;d
)
" ' 1 "1r "Tx :1..-
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- ?T-- ::=::== - :-
Desponse to NRC requests for information-ensually timely and technically o
~
Poe th; ;;;; p;rt, th;;; ;;hn.ttd.; :nd r;;;;n;;;.;r; ;1;;r, ti;;1y, :nd
- rt;d by ;;und t;;hnic;l j;;tifi;;ti;n.
However, in th; ;r;;; ;f l
- y' j
s t
21 techni;;;
p :ifi;;ti;n ::velepr:nt :nd th: ;;vi;u ;f the p:: p:::ti;n;; t;;;ing prograr, ;;n;id:r:51; ;ffort ';;
- p;nd;d by th; ;t
- ff t; ;;;;r
- th;t en
- i;q
- ;t: t;;hnic L::i; ---...--..,
p1;;;d on th; d;;h:t..during interaction I
with the applicant for the Proof-and-Review and final draft technical specifications, it was noted that the applicant, at times, provided inadequate justification for changes.
Subsequent to being notified that the justification i
was inadequate, the applicant resubmitted the proposed changes repeating the justification.provided in the earlier submittal.
It appeared that the applicant either did not understand the staff's position on these issues, or the applicant was attempting to minimally attempting to meet NRC requirements.
The applicant's response to the NRC MORE DETAILED request for identification and justification of preoperational tests DISCUSSION DELETED that would not be repeated was not FOR ABOVE CITED timely and required considerable NRC gxxgptg offert to obtain resolution.
In addition, the applicant's response to the request-for additional-justification for eliminating certain startup testing plateaus was lacking in thoroughness and depth and required considerable NRC effort to obtain resolutions.
+
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22 Th; NRC id;ntifi;d th;;; vivistien; th;t W;T; Ps'iT;- ;ti; in ^;I;E; ?"d I";
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STATISTICS: SUCH r--i AS A vicistion; in 1;d:d;As a result of these VIOLATION /INSPECTI NRC actions, eight violations were ON REPORT KATRIX issued.
Five of these violations ARE LACKING TO appeared to be isolated occurrences SUBSTANTIATE THESE while three were programmatic in nature.
CHANGES: HOWEVER For example, engineering inappropriately THE CHANGES DON'T allowed the use of low-strength bolting i
APPEAR To (A-307) in snubbers; also design reviews SUBSTANTIALLY failed to identify and correct numerous ATTECT THE minor deficiencies found in pipe support
]
CONCLUSIONS calculationst-end.
In another case, the applicant inappropriately accepted STATEMENT certain welds based on stress analyses 3
CONCERNING provided by engineering in lieu of H
ADEQUATE CORRECTIVE ACTIONS
[ggui{ednonggsp{uctiyeeppminations.
TAKEN FOR "rr*-r
- d;;i2;'tIF t;h;" I;; th;;; i;;;;;' IU PROGRAMMATIC addition, the NRC AIT Tperformed a i
VIOLATIONS ADDED detailed inspection of activities i
related to backleakage problems of Borg-Warner check valves installed in the ATW system.
As a result of that inspection, four violations were identified, two for l
deficiencies in plant operations and two l
l for the failure of engineering and technical support to take appropriate and timely corrective actions.
T=;
pp;;;nt vi;;;ti;;; f;r i;;;;;;;
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- :_1":11
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ADDED PEGARDING
- AI;i;;;;30 ;;;;;;'
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SEVERAL VIOLATIONS di;;;;;;d f;;th;r :,n C;;ti;n IV.D,
""l;nt Op;;;ti;T.: "
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py 23 Procedures for control of activities are stated and defined; however, when the 37 initial Startup Technical Support group DISCUSSION OF LACK was transferred-to the manager of OF PROCEDURES Technical Support, procedures were not DURING in Place to control the applicable REORGANIZATION actions of the new organization. In-
= DROPPED; HOWEVER addition, there was little evidence of THIS WAS ALSO management involvement, prior planning, ADDRESSED IN A and assignment of priorities during the MORE THOROUGH initial technical evaluation of the AFW FASHION IN B10. IN check valve leakage event.
CONTEXT THERE WAS NO SIGNIFICANT PROBLEM WORTH
-DISCUSSING HERE I
i i
The que.lity ;nd ;;;p;n;ie;n;;; cf th
" 8" DISCUSSION'Oh
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-FOR:AFW CHECK VALVES. TRANSFERRED
- ;'j :"_ :';- "', '_, : -';_ :- : _- 7_- _ :r'j _, _
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DROPPED'
- rr;;;ie; ;;ti;n."In the area of engineering and technical support for maintenance, the staff had concerns for the applicant's control of required post-maintenance testing.
For. example, the removal and reinstallation of check valve internals without post-maintenance testing.
The applicant also identified this as a problem area and is pursuing corrective actions.
l 1
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i The vendor supplied maintenance ALTHOUGH REVISED procedure for these valves was not adequate to provide proper adjustment.
AFW WRITE UP.
REFERS TO SECTION As a. result, the applicant's technical understanding of the method for IV.D, SOME OT adjusting the Borg-Warner check valves THESE SPECIFIC DETAILS WERE NOT was lacking.
No post-modification testing was conducted after the valve.s INCORPORATED were modified in 1983 and, in addition, i
THERE; HOWEVER BOARD RECOMMENDED the preoperational. test program did not include testing to demonstrate that ACTION-IN THIS check valves would prevent backleakage.
AREA As a result the failure of the ATW check
. valves was not identified until several-backloakage events occurred.
!;pr;v ;;nt ir, th; t;;hr.i;;l ;;pp;rt t
I i
[f'f3ff9_ffi_f ff-}[_;[fffI'2_!flIfi f PARAGRAPH B3 ON' CORPORATE I'
- ";::::"","I m !" _ :
' _ '/._"
MANAGEMENT
":'J " :: :; _ :::,",_ _: d:: ;;.:- ', _ _
- t. ;t
r'""
INVOLVEMENT MOVED
" --**'1y ;;h ';v;d. Corrective action FROM HERE was not taken for several precursor L
NEW COMMENTS events to the AFW check valve leakage
.ADDRESSLAPPARENT events CURRENT CORRECTED STATUS; PREVIOUS COMMENTS ADDRESSED ORIGINAL STATUS THAT. ALLOWED RECURRENCE; TONE SHIFT g
1 e
s w
26 Th; ;ppliccnt h;; i;p1;;;nt;d en Off;;tiV; ;;;fii seti; 003tT;1 FseiTO
.B8
^ith ;;;;i000
- lio; ioI;s;;ti;L Ood DISCUSSION FROM Eili;hl; ;;th;$; I;T ;9EiLi L;;;;;;TF DRAFT BEFORE All ADDRESSED MINOR Ch;Li;;'
031Y ; I;" Elo;; di;;;;F******
h;^; h;;O id;otifi;d s;i;sdi;i thi; PROGRAM BREAKDOWNS
- h ;;Also, difficulties in
- NOW SPLIT.
pr;;;;;,
implementing a truly effective-BETWEEN SECTS A2 configuration control program have AND B8 resulted in repetitive minor violations.
SIGNITICANT TONE One example of inadequate configuration-SHIFT CASTS A MORE control was a valve stem that was POSITIVE LIGHT; rotated and left out of angular HOWEVER SAME specification as the result of a seal EXAMPLE STILL USED. PROGRAMMATIC Ygld application.
((;;gr;;;;
ENHANCEMENTS NOT I ' "_' y : : ';; 7 - _ " - ' _ _ - : " _ -- - - - - - - - - - - -
r-------'
ADDRESSED ORIGINALLY In the area of procurement, the staff noted that the applicant had revised the B9 procedural program for procurement'to REWORDED PARAG Provide increased accountability and STILL NOTES assurance that safety-related seew****r PROCUREMENT parts and equipment were of the desired PROBLEM WITH SOME quality and met industry standards and EXAMPLES; HOWEVER regulatory requirements.
- However, MINIKAL MEETING implementation of the program indicates CONCLUSION NOW that the revised program is not fully CHANGED TO NEED understood by-all affected departments.
TOR IMPROVEMENT, For example, an applicant audit WITH CORRECTIVE ACTIONSLBEING igenpified that ^^.gigg'_.'g{.-
IMPLEMENTED (NOT
- ;; i r- - : _- _ -",, _ m _ _
- ------ -----"i ---- -"- ---'--- "----
ADDRESSED-Oy;t;; (O'c?O ) piping end the installation PREVIOUSLY) of valve internals which were procured as nonsafety related into a safety-
..._...z.
-. m x related valve.
Additionally, other procurement problems, both of services and hardware, have resulted in the staff's impression that the. applicant appeared to be meeting only the minimal requirements for a procurement program.
Ar" ;;nt;;l v;1v; 70 1:1, indi;;t;d th; n;;d f;r i;pr;;;;;nt; t; th; p;;;;;;;ing
- nt pr;;;;;.
- rr;;;iv; ;;ti;;; ^^;;; b; i;p1;;;nt;d 00 th;
- nd Of th; ;;;;;;;;nt p;ri;d.
4 26' t
Staffing levels for engineering and.
technical support organizations are BIO THE CONTEXT-OF THE ample, although many of the individuals -
are contractors.
Positions and a
COMMENT ON responsibilities for the technical L
ORGANIZATIONAL support of operations, preoperational E
MOVE, CONTRASTED WITH THE ORIGINAL testing, and startup testing are well-defined.
Although the responsibility EVALUATION for the technical. support of startup
- COMMENT, testing was moved from the manager of SUBSTANTIATES GOOD startup to the manager of technical JUDGEMENT IN support, the group remained intact.
No DELETION OF THIS confusion was evident even though DISCUSSION.
through an oversight, the group did not COMMENT ON have administrative procedures that TRAINING FROM All.
applied to their new organizational-unit.
After identification of the problem by the NRC, administrative procedures were promptly written and implemented. During NCO in;p;;ti;n;, th; qu;1ifi;;ti;n; :nd tr;ining of
- ngin;; ring nd ;;pp;rt p;r;;rn;l ;;re in;p;;t;d and d;t;rzin;i t; be
- tief;;tery.
NRO in;;;;ti;n; cf ngin;; ring end t;;hni;;l input t; th:
CAP cnd pr;;p;r;ti;n:1 t;; ting identifi;d i;;l;t;d in;t;n;;; wh;r; in;d;;u;;; training a;; d;termin;d to b;
- ;;u;;.
"h;n th;;; in;t;n;;;
- r:
id;ntifi;d, th; ;ppli;;;t t;;%
- ppr;prict; ;;ti;;; t
- ;;r ::t th; d;fici;nci;;.
Th; NEO ;;n:lud:d th;t ev;r:11 tr;ining ;;tiviti;; a;r;
- ti;f;;tery.
The training and qualification program for preoperational and startup testing Bil EDITORIAL CHANGES personnel is adequate.
Technical support procedures are rarely violated.
ONLY, EXCEPT The applicant's licensed operator-POSITIVE STATEMENT training program has been significantly ON PROCEDURAL improved since the last SALP rating ADHERENCE DELETED.
DISCUSSION OF period.
Thi; ;;; ;vid:n;;d by : 1000 LICENSED OPERATOR p;;; ret; for This is evidenced by the fact that 100% of the candidates passed i
TRAINING MOVED the NRC administered requalification HERE FROM SEC D examination. The training staff is composed of fully qualified individuals possessing the necessary skills and expertise for an effective training organization The training staffr-Appli;;nt ;;n;;;;;nt displayed a willingness and desire to establish and
o..
s
'27 e
r maintain a highly-motivated training organization.
2-Perforrance Ratina The applicant'; reting is considered to be in performance Category e in-this area.
3.-
Board Recommendations a.
Recommended NRC Action NeMer b.
Recommended Aeolicant Action 1--
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REFERS TO PARAG B7
'"""'T 7"-
DISSCUSSION i;;hi'i;;I ;-PE;;I IOC OE;ietlO '; ;'"i;I;
- n order to reacive t;;hnicci ;;;uc;
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28.
'C.
Eafety Assessrent and Ouality Verification-1.
Analysis
[
This functional area includes all J
applicant review activities associated C1 with the implementation of applicant NO CHANGE -
SUMMARY
safety policies; activities related to ADDED ROOT CAUSE ANALYSIS OF PLANT eX*mPtion and relief requests; response to generic letters and bulletins; and EVENTS resolution of Three Mile Island (TMI) items and other regulatory initiatives, and self-assessment activities, applicant activities related to amendment, exemption and relief requests; response to generic letters, bulletins, and information notices; and it also includes. applicant activities related to the resolution of safety issues, 10 CFR 50.59 reviews, 10 CFR 21 assessments, safety committee and self-assessment activities, analyses of industry's operational experience,-eeet
- analy;;; cf pl;nt ;v;nt;, use of-feedback from plant quality assurance and quality control reviews, and participation in self-improvement programs.
It includes the effectiveness of the applicant's quality verification function in identifying and correcting I
substandard or anomalous performance, in identifying precursors of potential problems, and in monitoring the overall performance of the plant.
L NRC. personnel performed inspection b
activities which resulted in the issuance of 12 inspection reports of DISCUSSION OF 3 quality programs, however other.
Cth;r VIOLATIONS MOVED NRC inspections provided input TO C10 FROM C2 p;r;p;;t;;; regarding the adequacy of L
the applicant's performance of safety assessment and quality verification.
(
The-staff determined that management involvement in safety assessment and
/
C3
. quality verification was apparent in NO CHANGE -
SUMMARY
most activities.
Evidence of this lI POSITIVE EXAMPLE inv lvement was demonstrated by DROPPED management participation at meetings requested by the NRC or in presentations to the NRC of updates or changes to the applicant's programs. in th; C;ni;r ^t.
l
.. ~.._ _. _ ___ __ _ _
U
.,o i
29 s.
overview carnitt'cc and in man;;; ment's inv;1vement in th: 7 ::1uti n ;f' t;;hnic;1 i ::::.
Additionally,' staff review of documents such as applicant.
audits, corrective action reports
't (CARS), or end-SDARs indicated that items with potential generic Lapact-
- pplic bility were-addressed by appropriate management personnel.
For i
example, audit TSV-89.01'when reviewed by management, generated a. revision to the procurement program.
Evidence of prior planning and the assignment of priorities'was apparent
'y C4 during staff reviews of in th; schedules No CHANGE -
SUMMARY
for audits and surveillances, the DROPPED POSITIVE, performance of preoperational tests, and l
COMMENT the-completion of construction activities.
In general, these schedules were found to be comprehensive.
Applicant reviews performed to assess l
program compliance with the schedules L
and the need for schedule adjustments were effective.
f Resolutions of deficiencies were, in general, adequate though :lth;;gh C5 occasional repetitions in ef-identified NO CHANGE -
SUMMARY
deficiencies indicated that root cause CHANGE MADE assessments and corrective' actions were JAPPEARS TO not always effective.. One example of
[
ELIMINATE this was that corrective actions to RIDUNDANCY.
i audit deficiencies issued for minor design calculation ~ errors'found'in the-CAP were not effective in' correcting the root cause problem.
An ;;;;;1: Of thi v;; ;in;r d;;ign ;;1;;1;ti;n ;rr;r; f;;nd in th: OA".
After the NRC identified the same problem during inspections, held meetings with TU Electric management, and issued a violation for the same issue, the applicant took adequate corrective actions.
f' The applicant's program for the identification and correction of i
C6 nonconforming or deficient conditions j
NO CHANGE -
SUMMARY
was effective.
An excellent example of en ff;;tiv; self-evaluation and corrective action resulted from audit TSU-89-01 in which the audit team 1
~... ~
e.:
c I
30 utilized ongoing activities.of the HTT to perform =real-time assessmentsLof testing-activities.
The auditors ewett identified that the programs for engineering, procurement, and testing failed to prevent unapproved valve
-internals being installed as permanent plant equipment in flow control valve 1-FCV-121.
The audit deficiency resulted.
in management action in all of the affected. departments.
{
s'
~
Procedural changes during the SALP l
APPARENTLY. DROPPED period have, at times, resulted in CERTAIN' ASPECTS deficiencies not being fully addressed.
RETAINED IN C10 For example,~an NRC violation issued for failure to perform an evaluation of i
o reportability for certain unsatisf actory QC inspection reports was due to the effect of a' procedural change not having been fully evaluated before implementation.
Th; :ppli;;nt h;; ;;ny ;;1f ;v;1acti n C7 029031;0ti03; OCd ET0iT;;;'
Th;;;
k f _ff[_3)f_02ff f t[.hifff;Cff __,,__.._
l ADDED - MOSTLY FACTUAL
?-":: ;:-"i_:",7: : ;L.T,"';
_T !"C'
-INFORMATION
--""'t't;;
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"-'i;;
(0000), th; Op;;;t;;n; n;v 0;;;;t (On0), th; Ind;p;nd:nt 0;f;ty-a Ingin;; ring Orcup (! 50), th: J: int T;;t 0;;;p (JTC), th; T;;t 0;Vi;W Or;;p (TRO), th; T;;hni;;l Audit Pr;gr;;
(TAP),'Ingin;; ring Tun;;i;n;1' Ev;l;;ti;n;, Op;r;ti;n; 0;; din;;;
A;;;;;;;nt, Pl;nt Ov;1;;ti n Or;;p, ;nd 0:ni;r OA Ov;rvi;; 0;;;itt;;.
0;n;r:11y, th;;; pr;;r;;; :nd
- rg;ni;;ti;n; p;rf;r;;d ;d;;;;t
- 1y.
Op;;ifi: ;;;;p1;; ch;;; th:3 did n t id;ntify :nd ;;rr;;t 0;fici;n;i;; er; n;t;d in th; :p;;ifi; fun;ti;n;1 ;r;;;
- f thi; r;p;rt.
The applicant's responsiveness to NRC i
Bulletins and Information Notices was C8 NO CHANGE -
SUMMARY
generally timely and thorough.
Examples MOVED FROM SEC A of this were responses to NRC Bulletin 88-10 (involving molded case circuit
}
OF DRAFT P. 21-22 l
breakers) and NRC Bulletin 88-01 l
(pertaining to inspections of Westinghouse DS series circuit breakers used in Class IE applications).
l l.
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- 31 In r;;p;n;; te N"O In'er;;ti;n N; tic; mm om
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.ADDED; APPEARS TO
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BE AN UPDATE ADD-T'--I;tIOC' Ih; ;701;;t503; $;I;TE50;d-AG;;
ON TO CB-th;t th; pri;;ry ;r;; ;' ;;;;;rn 4;;.th; j
pet;ntiel th;t ;;n;truction ;;tivity in th; cr;; a;y h;v; d;;;;;d th; ";pten kn;;l;ti;n.
Th; Oppli;;nt initiet;d eerr;;t;v; ;;ti;n; in;luding d;t;iled in;p;; tion nd ;l;;ning ;f th; in;al tion prier t; th; inst:11; tion of pret;;tiv; ;;ble trey ;;ver;.
Although in;;ppi;t; t th; :nd Of th; CAL" p;ried, th; Oppli;;nt'; ;;rr;;tiv;
- ti;n; u;r; ;ppr;pri;t;ly ;ddr;;;ing th; ;;n;;rn; id;ntifi;d h-th; in';rm;ti n n;t+eet i
Three violations were identified:
(1) inadequate performance of preoperational ego test surveillance, (2) inadequate ADDED.
interpretation of a radiographic-CLARIFICATION
- FACTUAL?
indication, and (3) a procedural change resulting in the failure to perform reportability evaluations for'certain unsatisfactory QC inspection reports.
Th;;; vielstion; pp;;r:d tw b; i;;1;;;d
- nd n t indi;;tiv; c' ; pregr;r ;ti;
___u,_._
v.ww.w-.
L An NRC assessment of the plant i
evaluation group indicated that the C11 NO CHANGE -
SUMMARY
group was' adequately structured and staffed to provide. evaluation of plant EDITORIAL CHANGE operations and maintenance activities.
The group-is responsible for reviewing issues such as: industry operating experience reports, emerging regulatory issues, and site performance.
The ultimate purpose is to identify ~
precursors to potential problems.
The group has taken timely actions to address recent industry issues such as mid-loop operations during drainage of the RCS and the increasing concern for r
the adequacy of instrument air systems.
m___
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- ff;;tiv;.
Ter
- pl;, during pl;nt l,
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- SUBMITTALS.
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Performance Ratinqt The applicant's rating is Performance Category in i
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This functional area consists chiefly of the control'and. execution of activities D1 directly related to operating plant EDITORIAL CHANGE systems 77. prig ((}{,ggggpg{gggg{ ONLY
- tivitic;.
It is intended to include activities suen es system startup, shutdown, and linrups.. Thus, it a includes activities such as pre;pe r;ti n:1-t;; ting, monitoring and logging plant conditions, pr:rcqui;ite normal operations, prestartup test operations, response to transient and off-normal conditions, plant-wide housekeeping, control room professionalism, end-interface with activities that support operations, and operator training. NRC personnel performed inspections resulting in 14 inspection reports of D2 EDITORIAL CHANGE precp;r; tion;l t;;tir.; gnd operations-related activities. This number ONLY included a team inspections of operational procedures and another team , m o., u, inspection of emergency operating procedures. Other NRC inspections provided additional input to the assessment of plant operstions. Management-involvement wee-is apparent in the preplanning and assignment of D3 activities for task completion. This POSITIVE SCHEDULE involvement is evidenced-by the COMMENT DELETED continued ability to meet schedules. Other evidence of management involvement z.-- included v;; ;vid:nt in the development and implementation of a Readiness for Operations program, implementation of the Trip Reduction program, inclusion of the initial Startup program under the 3 direct control of the operations department, and tr;ining, in handling of selected events for practice under the requirements of 10 CFR 50.72 and 10 CFR 50.73 as if the plant were licensed u;ing ;;l;;t;d ;v:nt;. Management involvement was not apparent
L ' j 35 i I 'in the ln'itial identification and assessment of backleaking ATW check D4 valve failures prior to HFT. As a EDITORIAL CHANGE result a significant check valve ONLY. backleakage event occurred. Management involvement was also peee-not apparent in the initial follow-up, assessment,. and corrective action for this event. As a result, a second event that was more severe occurred 12 days later. Th Nn0 t ;r in p :ti;n ;f Oper; tion: ET;;;d;T;; d;t;T io;d th;t DS Od ini;ts;tiV; ;;3tT;I Es;;;das;; V;T; REWORDED; ORIGINAL not ther;ughly Procedures for control of VERY NEGATIVE WITH administrative activities are poorly RESPECT TO stated and not well understood as 0PERATIONAL evidenced-by inconsistencies and READINESS (OMITTED contradictionse between upper-tier IN FINAL DRAFT; policy procedures.and lower-tier HOWEVER BOTH implementing procedures. Plant
- VERSIONS NOTED operating procedures were not at a IMPLEMENTATION OF quality level necessary for the CORRECTIVE ACTION) operation of a plant that is nearing a low power license.
In addition, Et
- pp r
th:t the administrative review cycle did net appear to be effectively catching these errors and mistakes wee not effective in id:ntifying and l
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- 1;rg; n;;b;r ;f v
L deficienci;; within the plant p;r ting pr;;;dur;;. Da;;ple: cf fi:1d pre;;dur;; th:t a:r: in ;;nflict with th:
- nts;11ing pregs;;;;ti; pre;;dur
- J;r f;und.
Once this issue was identified to plant management, the' applicant initiated corrective action to address th::: the staff's concerns. Operational decisions were generally conservative and made with the emphasis-D6 Placed on plant safety. Some failures NO CHANGE .to document operational events or identified preoperational problems were noted. However, when these issues were escalated to senior management attention, the issues were resolved. The applicant was almost always responsive to NRC concerns and questionsr and in En-those instances where the response was slow, menagement took immediate corrective action to resolve the issues.
~
- e:
-36 n Thr;; vi;10 tion; a:r; i;;;;d in th; er;; Of FZ;;F;i;ti;;;l t;;t F;sI;;;;U;;; 000 D7 STATISTICAL CHANGES $?5,[if[3,25}},F[f[;5(($?f?559I5 HARD-TO TRACK; NO -'**---"-3' ICII;" ET;;;d;i;;' Ih;;; I"; h;d SUBSTANTIVE CHANGES
- V;T;I ;;;;El;; 000 0FF;;;;0 I; h; th;-
'HERE r;; ult ;f p;;r qu;1ity pr;;;;;;ti:n:1 t;;t pr;;;dur;; :nd hurrying er th; part of ep;r;ter;. An ;;;;r:nt vielsti;n
- ict;d with th; Ar" ;y;t;; 5;;hf1;w
-;v;nt u;; id;ntifi;d. An opp;;;nt viel; tion i; ; rep;titi;n ;f th: failur; t; f;110w pr;;;dur; vi:1; tion di;;;;;;d b;1:w :nd i; ; p;nding n!;r;;;;nt eeewerThe NRC inspections resulted in the issuance of six violations. One violation was issued regarding deficiencies in the records management and storage and three violations were issued in the area of preoperational test performance. Additionally, two violations for plant operations were issued as a result of the AIT report. Those violations concerned failure to properly perform testing of Borg-Warner check valves.in the AFW system and for repeated improper valve lineups during HFT. ~.... . A-ew-Several instances of a f ailure to follow pro;edures by operators and test -DB engineers were noted during the MORE NEGATIVE preoperational-test program. In n; WRITEUp. i;;t;;;;* th; I;il;;; I; I;II;'" th; INCORPORATED pre;;dur; ;;;;1t;d in initicting h t ...m vet;r b;;hf1;; !::: th; :t;;; g;n;r;ter; int; AT'/ piping i;;;;;; ;;;;r:1 ch;;h velv;; f;il;d t: ;;;t. The applicant's performance relative to thi; ;;;rcti;n;1 ;v:nt v;; n:t
- ti;f;;tery. operational events and the identification of deficient conditions is still considered marginal.
This is based on the applicant's handling of the auxiliary feedwater check valve issue and preoperational testing personnel failure to identify all of the problems found during testing. Prior to HPT, AFW check valves were determined to be experiencing backleakage; however, the significance was not understood. As a Y
m 6 / 1 b result, a backflow event occurred during the hot functional test. This event was . KAJOR REWORDING, Poorly identified and its significance BUT SUBSTANTIVE-MESSAGE RE: POOR As a result, a second C not understood. backflow event occurred that was more PERFORMANCE IS serious than the first. The second STILL;THE SAME: event was not identified and reported to HOWEVER-TINAL DRAFT ADDS LATER Plant management for,more than a week. mu_ ,__st__ _u__t u_2 u___ EXAMPLE ---"_'_---"_'u_'_.._-__u-'_'. 22__.
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- n. u.._.:_
2... r.......-.... r...-.- mesmer r i The number of ;v;il;bl; sperators and shift supervisors that the gpplicant has exceedes ;x;;;d:d the minimum number i required for single-unit operation and wee-is adequate for two-unit operation. / i
38 The additional shift personnel were-are-being used to assist in the Unit 1 D10 preoperational and initial startup EDITORI AL CHANGE testing. Although the licensed ONLY PREVIOUS-LICENSED operators, as a general rule, do not have much power. plant operating TRAINING DISCUSSION 'NOW IN SEC Bil experience, senior management recognizeds this v;;%n;;; :nd t;;h deficiency and has taken steps to remedy this condition by obtaining het operating experience for th: 0;;;n:h; P;;k ;p;r;ter; at similar facilities.
- m in;p;;ti;n of th; ppli;;nt'e Iff[$!,'SN20SICEICECEAZOIiOI'CAI'$.fff[i[}fftf((f9 IIOiI I
- D11 IOL NEUTRAL WRITE UP
? " _ : 1..;._.1 - - " ; "3. _ N '., r: 1....".'j- ' _ ';- - -- - " NOT IN DRAFT - ry. -r p;r;;nn:1 f;ilur; t; f;11;u pre;;dur;; h;v; r;; ult;d in r;tr;ining. Operations personnel maintained a professional demeanor in the control D12 room. Lines of authority were-are NO CHANGE--
SUMMARY
clearly established and are always REWORDED To DELETE maintained by the on-shift personnel. A POSITIVE ASPECT Name tags clearly ;d:ntif;;d identify each operator by name and position. Preshift briefings and turnovers are performed in a professional manner and 1 contain the necessary detail to assure that an adequate transfer of' knowledge is accomplished within.the control room. Recently, the applicant finished modification of the control room ceiling and floors by the addition of<the qualified ceiling tile-and color coded carpeting. Access to the at-the-controls portions of the control room is restricted at all times. 2. Performance Ratino The applicant'; r; ting is considered to be Performance category e in this program area. 3. Board Recommendations l
- rv.
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'n r.- De 40 E. Maintenance and Surveillance 1. Analysis This functional area includes all activities associated with either gg diagnostic, predictive, preventive or NO CHANGE corrective maintenance of plant structures, systems, and components; procurement, control, and storage of components, including qualification controls; installation of plant-modifications; and maintenance of the plant physical condition. It-includes conduct of all surveillance (diagnostic) testing activities as well as all in-service inspection and testing-activities. Examples of activ'ities included are instrument calibrations; equipment operability tests; post-maintenance, post-modification, and post-outage testing; special tests; in-service inspection and performance tests of pumps and valves; and all other in-service inspection activities.- Also included in this assessment are activities associated with lay-up of systems _which are not in use. 9he-input for the assessment of the applicant's performance in this E2 functional area was derived from various-DISCUSSION OF NRC inspections including the team VIOLATION MOVED TO inspection of operations and maintenance E3 FROM El-procedures. t !n d:pth r;^/i;L cf th; ;; int;;;n;; ^.'. - - " " i i'; d t h ; t t h ; E 2 0 i s ; ; " ; ; E3 r'"v'-"
SUMMARY
" ADEQUACY"
- d
- sact;.
Although maintenance procedures w;r; in ;;; er.d appeared to ADDED (SEE E4-ES) be technically adequate, numerous REWORDED UPDATE discrepancies in the procedures, their -NOTES CORRECTIVE format, and their control have weakened ACTIONS BEGUN AT their effectiveness u;;; r.;t;d. A END OF SALP PERIOD violation was issued-for the applicant's failure to properly incorporate all of the applicable administrative controls for in-process instrumentation and control documents. In ;ddition, w;;h
- ntrol of in pre;;;; ir.;tru;;nt; tion
tsa *'. -f 41 g 59$,$f 735"b_E".b,5f"f5$"_55 fib 3ff f.9_" I ' I' ' !" : ' I' _'" * " I.".1 T E5 ' ' I':: _'. Z T E _
- 1. r. '. I.'l.. :. ". :. " ?. m.' ~.11".. '. ' I m ' ", r.;. ' l! ' ' T.'.' '.
~ 7... In another case NRC's inspection of; procedures for post work. testing found that the applicant had identified a number of missing post-work test completion reports. The applicant was implementing-corrective actions at the end of the SALP period. 'n;th;; one-violation was issued for +n-this-area concerning the substitution.of carboli f steel bolts for silicon bronze bolts on the auxiliary feedwater pump actor. The actual substitution occurred in 1987 and appeareds-not to reflect the current maintenance program. Plant tours and observations indicate that maintenance activities 1are being E4 conducted using up-to-date procedures DROPPED POSITIVE and approved work practices. No COMMENT discrepancies were identified in this j " ADEQUATELY" ADDED area. Th; ;ppi;;;nt ;ur ;;11;n;; t;;t .TO PROGRAM This program wee-is complete and wee-is -( in the process of being implemented. The program ed;;;;tely addresseds the procedures, methods, and rules for scheduling, tracking,'statusing,. performing, reviewing,-and managing the surveillance tests. 'The staff has reviewed the' maintenance QA program in depth _and-has determined' l DROPPED; GENERALLY that the applicant has developed and POSITIVE,-SOME implemented'the QA program'in accordance-NEGATIVE; with proposed technical specifications, ESSENTIALLY regulatory guidelines, industry COVERED IN E3 IST standards, and commitments. A ' SENTENCE significant problem with the procurement of replacement parts for a safety related flow control valve was identified by an applicant audit. Corrective action is being taken by TV Electric to improve the procurement process. 1
. 42 Staffing levels for maintenance 6nd surveillance activities appeared to be E5 NO CHANGE -
SUMMARY
adequate. Although a backlog of maintenance work orders existed, the applicant has taken effective action to reduce the overall number. Management has taken an active role in E6 the area of maintenance training. The NO CHANGE -
SUMMARY
staff is especially impressed with the EDITORIAL CHANGE applicant's maintenance training. opty facility i; p;rticularly n;t:wcrthy. 1 Tours of this facility, interviews with - maintenance training personnel,. J interviews with maintenance managers, and observations of field work practices g indicated that the maintenance organization is wel'1 trained. Plant tours and observations indicate that caintenance activities'are being conducted using up-to-date procedures l and approved work practices. No l discrepancies were identified in this l area. Nnc st;;rv;ti:n ;f ;;inten;n : 1
- tivitic; r;v
- 1
- d th;t ;;inten n;;
per;;nnel w r kn;wl;dg:;ti; cf prs;;durel r;;uir;;:nt; nd a r; a;rking te curs;nt pre;;dur;;. 7;r;;nn:1 p;rferning r; quired ;;rv; iller,eee-weee L cl;; f;und t; 5 kn;ul;d;;;ti; cf I
- quir;;;nt; nd acrking t: ;;rr;nt pre;;dus;;.
Th; ;;ti;f;;tery p;rf;r;;;;; Of ;; int;;;;;; ;;d curveillen;; p;r;;nn:1 w;; indi;;tiv; cf
- ;;ti;f;;tery tr;ining pregs;;.
2. Performance Ratina y The applicant's rating is Performance Category 9 in L this area. 1 l 3. Board Recommendations ) h (a) Recommended NRC Actions } l Ntmer H 1 (b) Recommended Aco),1 cant Action Nemer c
i ?* 43 i F. Security 1. Analysis This functional area includes all activities that ensure the security of-73 NO CHANGE the plant including all aspects of access control, security background i checks, safeguards information protection, and fitness-for-duty activities and controls. Five preoperational inspections were conducted by Region IV based physical F2 STATISTICAL security inspectors during this DISCUSSION OF. assessment period. Several minor VIOLATIONS problems were identified. The applicant has corrected most of the identified UNIFORMLY DELETED FROM FUNCTIONAL problems and is working on resolution of the remainder. No violations or AREAS deviations were identified in this program area during this assessment period. The applicant'; ;;;;rity ;rg ni;;ti;n 73 has implemented an aggressive quality ' EDITORIAL CHANGE assurance audit program for the self-ONLY identification of security problems to ensure compliance with th; r;quir;;;nt; ef-10 CFR Part 73. requirements.
- nd th; l _~
Phy;i;;l 0;;;rity Fl;n (PCP). l Corrective actions initiated as s result of the-applicant's audit program or NRC identified problems have been technically correct and effective. Plant and corporate management has been ~ l supportive and actively involved in providing timely solutions to issues o H identified by the security staff. The applicant has been responsive to NRC initiatives. i The applicant appears to have a sufficient number of security supervisors, fully qualified security l officers, and security support personnel assigned to the security department to implement a proper security program during normal operations during the
o j Cd? i 1 L ' 44-e transition from construction to operation. However, during th; 74 REWORDED; t ;O;iiiOL I;;; ;;C;t;;;ti;L 10 Op; ret;;n; the overtime use appeareds to INFORMATION ADDED CONCERNING ACTION beepyess{veggdi_t}g{_yp{1},{jj;; -" -------i ----* TO HIRE MORE STAFF "-i--*:- -"r--- eff;;tre n;;;. While the amount of overtimeoi:s probably a result of I f implementing the security program with a large number of personnel and. construction traffic in the protected area, it is indicative of a need for more' security personnel, at least at this time.- Appli;;nt ;;n;;;;;nt h;; r;;;gni;;d thi; pr;bl;; end h;; initict;d ;;ti;n; t; hir; ;;r; ;;;;rity p;r;;nn 1. The lines of authority i within the security force are clear and well understood. No problems were identified with the security training program. A more accurate assessment of-the training program will be possible L following the completion of lockdown, but it appears that security force personnel have a good understanding of the applicant's policies and procedures. The applicant has established the necessary procedures to provide for the L implementation of a proper security L program. -The transition to a security organization responsible-for safeguarding an' operating nuclear power plant from a long-term security organization responsible for industrial protection has not been implemented to a degree that has permitted the inspectors to fully. establish the assurance of acceptable performance in this area. Overall, the applicant's security program appears ready tor implement security requirements for an operatinc i nuclear power plant. However, the applicant must find ways of alleviating () the present guard force workload in order to establish its ability to handle physical security plan requirements upon licensing. The applicant initiated a three-stage phased lockdown of the protected and vital areas on July 1, 1989. Ph;;; I w;; ;;;pi;ted ;nd porti;n; Of Ph;;; 2 W;r; ;;;;;pli;h;d
r ~.i .a 45 prior-t; th; :nd hf thi; ;;;;;;;;nt p;ri;d. As of August 31, 1989, all i F5 preoperational requirements for security J l - MAJOR REWRITE: are in place except for access control THRUST APPEARS-THE S AME; DETAILS OF of personnel. The applicant intends to continue issuing temporary l SPECIFIC-SECURITY badges /keycards to uncleared personnel L pgoggggg until fuel load, at which time all ELIMINATED REPLACED WkTH A. personnel within the protected area will be either cleared for. unescorted access 4 L STATEMENT i or escorted. It ;pp;;r; th;t Oppi;;;nt CONCERNING
- 000^0E000 dI "0I C;;0 CI;' Th00 th; L
APPLICANT i l ACKNOWLEDGING PIont "0; DOI 20007 10 '0 't0 T lLIO th; i L ' PROBLEM AND PLANS [f[fl^$fff,j$51f,Iff)f;j9[i h01m$0; j TO PERFORM A SELF-I;;_ : " :'- ? :,, : :: _ _,'22,__ T rr : ': ;' _' _" _ _;;r, " ::: _ _ _ r; *, * -', "_ _' "_',,, EVALUATION TO. r,':;' '_' ; -- :: *
- 3_ _ [ :: * - "',, - - '_ ' _
IDENTIFY AND ---'-^-"-'--' -*---'-",' -- --**--' -"3f.f..f.[tf.[f.~ff.59.d[ff'2..[f..'._3)i,[ -CORRECT DEFICIENCIES .... y i; F ;Uh;".Of th; F;;;F;~0tIOC01 I POSITIVE STATEMENT an;p;;ti;n This failure to implement a i ON BASIS FOR timely "hard" lockdown is contrary to L SECURITY PROGRAM the applicant's commitment in the TONED DOWN Physical Security Plan and say impact on (EXCELLENT TO the NRC's ability to assess the ACCEPTABLE) operational readiness of the security force. Presently, temporary construction personnel who have not had L general employee training are L responsible for hundreds of alarms each L day. The security force is presently. inundated in responding to the alarms and providing admittance control (package, personnel, and vehicle searches).- In fact, many alarms are not i responded to by security officers and many vehicles are not searched in order 1 to not delay construction activities. It is difficult for NRC to extrapolate future performance based on the applicant's current security force workload. D;;;d en th; pr;;p;r;ti:n;1 in;p;; tion; ;;;pi;t;d t; d;t;, it It eppears the applicant has established ( the basis for an ;;;;pt;bi; excellent / security program. The applicant's submittals with respect to safeguards matters were technically sound and consistent. These submittals indicate that the applicant has well-developed policies and procedures for
46 l control of security related activities. During thi; ;;;;;;;;nt the interaction T6 Period, there was consistent evidence of EDITORIAL CHANGE Prior planning and involvement.by ONLY utility management, including corporate, and this is reflected in the quality and size of the security organization. 2. Performance Ratina. The applicant's rating is Performance Category e in this area. Th; ch;ng; in reting f rom ; Cet;;;ry 1 'l;;t O'.LP p;ried)-te ; C;t;;;ry 2 d;;; not n;;;;;;rily r:flect ; _u____ ___st___. mu_ ,__.,,, m w ywa a w a cuw a a = w s aae= ewww w g u a.i 4 wiaw.syw asa we yy. a g. u a u w reting u;; b;;c4=gri;;rily ;n th; ;; qui;iti;n, installation, nd ;;tiv; tion ;f ;tet; cf th; crt
- urity ; quip;;nt which d;;;n;tr;t;d'th; Opplicent';
- mit';;nt; t; th; ;;;urity progr
- m.
.Th; opplic;nt had n;t y;t impi; ment;d th; ;;;;rity pl;n. Th; pree;nt -i, m __.:__ : _ u___2 _222. t.. Dn us + w w a a ry aw wwwww wa s w w w a w a vi ew s wwwar awaww s tw w w w w w e g te denen;tr;t; irpl;;;nteti;n of th; phy;i;;l ;;;;rity i ,,, m ___: _2 2 _2 ._ _ _ _.. _.. __ m u.. w_ _m .. _ _ _ _ u.. w_ w.., r ..u.. r * * * *" ww. w w""* ww w.ww ww wwwwa w. w.. -ww yw.i nd;d. t t 3. Board Recommendations a. Recommended NRC Action NofNM-b. Recommended Aeolicant Action L l. k,I _ - _ vs.w. l' u 1-l' h i l i 1 6 f 1 l l \\ u
47 G. Radiolooical Controls 1. Analysis-j The assessment of this functional area-consists of activities directly related G1 to radiological controlu, including EDITORIAL CHANGE occupational radiation safety (e.g., ONLY occupational radiation protection, radioactive materials and contamination controls, radiation field control, radiological surveys and monitoring, and as-low-as--is-reasonably-achievable ( ALAnA) programs), radioactive waste j management (i.e., processing and onsite storage of gaseous, liquid, and solid 1 waste), radiological effluent control and monitoring (including gaseous and liquid effluents, offsite dose calculations, radiological environmental monitoring, and confirmatory measurements), veter ch;;iatry ;;ntrel and transportation of radioactive materials (e.g., procurement of packages, preparation for shipment selection and control of shippers, receipt / acceptance of shipments, periodic maintenance of packagings, and point-of-origin safeguards activities). The occupational radiation safety 'i program was inspected-twice during the G2 assessment period by region-based EDITORIAL CHANGE radiation specialist inspectors. No ONLY violations or deviations were i identified. Several open items were identified involving; spent fuel transfer tube radiation levels, installation of health physics instrumentation, ALARA personnel involvement with planned work activities, hot particle identification and control, skin exposure from Xenon, and startup shield surveys. The applicant's responsiveness to NRC \\. initiatives and the resolution of / technical issues has been good. The applicant has maintained a stable, experienced r; diction r......i:n staff. The personnel turnover rate within the occupational radiation pr t;;ti;n ;t:ff safety area during the assessment period
v. e 48 was below 15 percent and vacancies were G3 routinely filled in a timely manner. EDITORIAL CHANGE Management involvement and control is opty evident by the prior planning'and assignment of priorities. In order to maintain a proper level of applied experience, the applicant has routinely sent radiation safety personnel to work at operating power reactors during both outage and nonoutage ;;tiyitic; operations. The applicant's radiochemistry and water chemistry programs were inspected.Once G4 EDITORIAL CHANGE during the assessment period. Five open ONLY items were identified involving: corporate technical support for the onsite chemistry group, primary chemistry and secondary sampling system testing, completion of chemistry laboratory facilities, and completion of the testing and operations of the post-accident sampling system operation and testing. ~ ~~ The applicant's transportation program-G5 - radic;;tiv; u;;t; m;r.;;;;;.t was ICT EDITORIAL CHANGE inspected once during the asses.2, ment ONLY period. The applicant had the necessary organization, training, and procedures I in place to i.mplement a proper radioactive-transportation program. The radioactive waste management program = - ' - - = = - - = = - i G6 was inspected once during the assessment NO CHANGE period. Seven open items were identified concerning the radwaste -program. These items involved the organization and staffing of the. operations radwaste g.,roup; liquid radwaste system preoperational tests gaseous radwaste preoperational tests and calibration of effluent monitors; solid radwaste spent resin transfer system modification, testing, sampling, and process control program; air cleaning system preoperational tests and system balancing; radiation monitoring instrument calibration and functional-tests; and a comprehensive audit of the radwaste program. The radiological environmental
.n-e 49-i monitoring program was not inspected G7 during this assessment period. This .NO CHANGE area has been reviewed annually since the early 1980s and all open items and-commitments have been completed. The Offsite Dose Calculation Manual, .t l l Revision 0, dated March 1989, had'been approved by the office of. Nuclear i Peactor Regulation (NRR). l e other reviews conducted by NRR staff included several'open items, an issue G8 EDITORIAL CHANGE concerning the qualification of the ONLY manager of Radiation Protection, and i FSAR amendments to Chapter 12 through Amendment 66, and the review of changes affected by FSAR Amendment 76. These l-issues were resc,1ved by requests for i additional information, teleconferences, meetings and a plant walkdown. Some difficulty was experienced in NEGATIVE AND communication and correspondence with POSITIVE PARAG'S the applicant. The staff noted that: ON'SUBMITTALS documentation of commitments frequently DELETED did not clearly define proposed actions ALTHOUGH for resolution of en issue;-responses DISCUSSION ON Were not always complete;Eand the SUBMITTALS WAS applicant expressed the opinion'that, APPARENTLY for certain issues, they shouldLbe held to a standard which the.NRC found. CONSOLIDATED IN B4, TONE AND hinimally acceptable in other license reviews. The NRR staff determined that EXAMPLES CALLED at least one additional amendment to the FOR HERE WERE NOT RETAINED FSAR appears necessary to address certain issues, such as en increased activity level for a calibration source and potential new issues.due to-a ghanged radiation protection ~~o e,rganisation~. The-performance 5of4the1 applicant's' staff -POSITIVE PARAG ON uring M C acceptance of1the j SUBMITTALS adiological Effluent Technical cificationDand the~'Offsite Dose DELETED; THRUST IN IFith TU Electric,'"a;an/yery positive. iculation Manual,was H MARKED CONTRAST r(example',Iduring onsite[ discussion AND INCONSISTENT decie SDreached WITH PRECEDING iring major. Changes: FWorking PARAG eft.n.LHowaver,Ethe' app s able reviseithe entike irer t, 'ein~requiredTepproval sue the Anal.. draft;for>NRC subs _ hin a
50 'l 10 day period. The NRR staff determined that the TV Electric performance in this particular area to be outstanding. A quality assurance The :ppli;;nt's internal audit-program for radiological G9 control activities has been in effect i EDITORIAL CRANGE opty. for several years. The applicant supplements quality assurance personnel with corporate or_ vendor technical specialists. All audits have included a team member with technical experience in the area being audited. Station procedures have been developed and are'in place for most radiological G10 control activities associated with plant ' EDITORIAL CRANGE ONLY operations. Those procedures not y;t imple :nted still requird are in the development stage and are scheduled for completion prior to criticalitym The applicant has established good lines of communication between the training department, other station groups, and the radiological control group. No major problems were identified in the radiological controls area regarding the Gil effectiveness of the training and BACKGROUND INFORMATION qualification program. The applicant's staff appears adequate to implement the DELETED - NOT SUBSTANTIVE; radiologica1 controls program. Byen though the NRC had identified open POSITIVE CONCLUSION TONED issues / items in several areas of the DOWN Spplicant's radiation' protection program (several issues had also been previously identified by the applicant and corrective actions were being' developed pr planned) ~, they are not" expected to pose a: significant: problem;inJthe ppplicant's progress'toward aifacility operating 111 cense'-.These' identified $tems/iesues~are considered? typical of a
- h. mar, term : operating 11icensifacility.
The applicant's' overall readiness 'and- )~ capability to support plant operations is ;;n;id;r:d t; b; ;d;;;;t;iat?a very ~ high level. 2. Performance Ratino The applicant's rating is Performance Category e in this area. ~
(:' '. L I I hl j s i i _ u __a __. t. w. wv,..... __ _, i g t.: _ w ra h a ei,n i ..w.v,4 v. e F3 7 ...sy .. w .w. va s w. ..,r.....,.. 2 _ _ - r r. 2._._ _... ,r..r.__ ...w,, .s -.+ __u_2. _ _,_ _ _.. w : ,A._,_.r.-....:__ 2.: _w . + 7.v ___._2 7... v.... l 3. Board Recommendations a. Recommended NRC Action I h l b. Recomnended Applicant Action i h b a
52 H. rreroenev Preraredness 1. Analysis ...m_.. .......m.._. This functional area includes activities related to the establishment and H1 implementation of the emergency plan and NO CHANGE implementing procedurest such as, onsite and offsite plan development and coordination; support and training of onsite and offsite emergency response organizations applicant performance during exercises and actual events that test emergency plans; administration and implementation of the plan (both during drills and actual events); notification; radiological exposure control, recovery; protective actions; and interactions with onsite and offsite emergency response organizations during exercises and actual events. Two team inspections were performed during the assessment period invo'1ving H2 NOTE: CONSISTENT emergency preparedness. One was an ener9ency preparedness implementation REMOVAL or VIOLATION COMMENTS appraisal and the other was an evaluation of the applicant's performance during an emergency exercise. No violations or deviations were identified. ~- ' =- - ~ ~ ~ ~ " A review of the applicant's emergency preparedness staff showed that their H3 NO CRANGE -EUMMARY q: lifi :ti;n: pCademic back p nd and experience were edequeh satisfactory. The applicant's description of the ..,......... ~........... emergency response organization identified organizational response elements but needs further clarification ) of its structure regarding the assigned responsibilities. The applicant has the necessary staff in place to support emergency preparedness activities. An ;;;rg:ncy pr:p:r:dn;;;
- of
$he training program sh. . :the program had hee-been est dr. hHowever, qualification requirements for
o + 53 each position were not clearly specified and practical training was not required. H4 A large portion of the training for the EDITORIAL CHANGE emergency responders had been provided, opty but the changes to the emergency organizational structure and the ongoing work on some plant systems will require further training. In addition, a small number of emergency responders hee-had not received training consistent with their duties at the time of the appraisal. Those portions of the emergency response facilities that had been completed were satisfactory; however, some emergency facilities (e.g., technical support center) were still in various stages of completion, and some equipment and supplies were not in place. 0; men;treti;n ;f pPersonnel accountability and evacuation of the H5 No CHANGE -
SUMMARY
protected area and evacuation of the owner-controlled area have not been MORE PRECISE WORDING adeguataly demonst{ated. __y;_{g_ ggt pr;p;r:dn;;; ;;;;;T.;;. The appl'icant ._y..... has a unique situation in this regard due to a large number of workers in the protected and owner-controlled areas. Specific deficiencies were found in some procedures, mainly in the procedure used for making protective action recommendations. These deficiencies included the absence of operational assessment of plant conditions, and the inclusion of extraneous considerations which may impact on the timely release of protective action recommendations. The relatively small number of findings ..... ~ .m. that resulted from the appraisal H6 EDITORIAL CHANGE indicate that the applicant has made a strong commitment to the emergency opty 1 preparedness program. Wowever,Aho 9%e significant findings identified ^'in the appraisal need to be corrected in order for the applicant to implement an adequate emergency preparedness program. An emergency exercise inspection was also conducted during this assessment period. the inspection' tea M 9entified
54 seven excercise weaknesses. Althcugh e;V;U Oi'; U it;;; ";s; id;UIIII;d 0;iIL9 H7 the execrcice, the The inspection team CHANGED WEAKNESS concluded that the appli. cant had To opEN ITEM demonstrated the ability to implement the emergency plan in order to protect the health and safety of the public. In addition, the inspect 1on team concluded that the applicant's internal assessment program was able to identify and properly characterize its own deficiencies. The applicant has demonstrated a strong commitment to provide management support H8 to the development of a quality NO CHANGE emergency preparedness program. This commitment invokses training program improvements, installation of state-of-a the-art facilities and equipment, and moving the operational support center to a better location. In addition, the applicant has implemented an aggressive and 39 comprehensive audit program to identify No CHANGE potential problem areas. Applicant audits conducted since August 1988 have resulted in a relatively small number of significant findings. The applicant's ongoing interaction with H10 offsite agencies appears to be continuous and adequate. The applicant EDITORIAL CHANGE ONLY has developed the necessary emergency implementing procedures to ensure that emergency activities are properly addressed. 2. Performance Ratina The applicant's rating is Performance category 2 in this area, h 3. Board Recommendations 4. Recommended NRC Action NefHrr b. Recommended Aeolicant Action l
f: y-55 =. . t e--.-a a t... an
- -- : e:..
2--- 2s--a %V4 6 www %aus F 4 p ri d 4 4hwia e # Iy er a w* I s b s u._.--. :., er3 b 4 sw w p'p' a be d F W 4 e 4 a e i ___._.___._m.____.__ __________m_ . ~. _ _ _ _ _ _ _. _ _ _ _ _. _ _ _ _ _ _ _ _ _. _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _. _ _ _ _ _. _. -
56 V. Surnertina Dat a and Surreries A. Aeolicant/NRC Activities ~ MOVED TROM BEGINNING OF DRATT "C" The previous SALP report was for the period September 1, 1987, through August 31, 1988. Applicant activities evaluated in that SALP report were primarily design and construction activities prescribed by the CPSES Corrective Action Program (CAP) to correct deficiencies identified by the Comanche Peak Response Team (CPRT) and other sources. By letter dated January 22, 1988, the NRC staff approved both the CPRT program plan (Revision 4) and the CPSES CAP ns the means by which TV Electric could (1) identify design and construction deficiencies, (2) develop end implement appropriate corrective and preventive actions, and (3) conduct these activities with effective management controls. During the present thfe-assessment period, C;pt;;.b;r 1, 1000, thr; ugh Augu;t 31, 1000, the applicant has been engaged in both those activities necessary to complete the Corrective Action Program (CAP) and those activities necessary to demonstrate the op'erational readiness of Unit 1. 9he-Those activities required to complete the CAP are described in TU Electric Project Status Reports (PSRs) which address 11 specific areas of design and construction. The PSRs present the results of the Design Validation Program and describe the actions of the Post-Construction Hardware validation Program (PCKVP). The PSRs also provide for a final reconciliation of the validated design and the validated hardware to assure that the as-built plant is consistent with the validated design. Phe-Those activities performed to demonstrate the operational the readiness of Unit 1 consisted primarily of (1) the completion of prerequisite and preoperational testing, (2) the performance of HRC required exercises such as the NRC graded Bite g Emergency Test Pr:p;r:dn;;; Ox rci;;, and (3) the pr;p;r;ti;n iglementation of site Radiation Protection and Site Security' programs. Major tests performed during the SALP period included performance of the Hot runctional Test (HFT), the ASME VT-2 Pressure Test of the Reactor Coolant System (RCS) which was conducted as a supplement to the previous cold Hydrostatic test of the RCS, the Containment Integrated Leak Rate Test ( CI LRT), and the Integrated Test Sequence (ITS). 4 _ca.u--_--_w_____.-___m__.m._. ._~__,_.__.m_m____y.,___m,,. _x.,,_m _,,_,,__,,_,,,,m j
c -57 At the end of the assessment period, Unit I construction was essentially complete. Construction + activities on Unit 2 have been limited by the applicant to those activities required to support Unit 1 operation and to minimize Unit 2 construction personnel in Unit I areas after Unit 1 goes into operation. Construction of Unit 2 is ;ppr;xirstely 85% complete. This assessment is applicable to pplic;nt '; ;;tivitic:- en b:th Unit I and Unit 2. B. NRC Direct Inseeetion and Review Ac tivities MOVED TROM TRONT OF DRATT NRC inspection activities during this SALP evaluation period are documented in 91 inspection reports with over 21,000 direct inspection hours expended. The majority of the NRC inspections covered the applicant's activities for the construction program, the CAP, and the preoperational test program. The NRC inspections included specific activities of the applicant to demonstrate operational readiness. Other NRC inspections performed included three team inspections of the CAP, and team inspections of equipment qualification, pump and valve operability, seismic qualification, graded emergency exercise, emergency preparedness, emergency operating procedures, and operations and maintenance procedures, ;nd li;;n;;d
- per; tor ;;;;;1ific;ti;n ;x;nineti;n;.
The NRC also conducted specific inspections of the Radiological controls Program, the Security-Program, chemistry and l radiochemistry, and the Preservice Inspections (PSI) program. In November 1988 the NRC staff issued evaluations of the applicant's CAP relative to the technical disciplines of mechanical,. civil /structurait electrical, instrumentation and control (I&C); and HVAC. Additionally, supplemental Safety Evaluation Report (SSER) 20 (t; N"n:C 0707), also issued in November, addressed the staff's evaluation of the f implementation of the CPRT Program Plan and the Issue-Specific Action Plans, as well as CPRT assessments of l certain CPSES programs and hardware, l reviewed the applicant's investigatla @on and in ".;y ;f 1000, ;An NRC M9-Augmented Ins on Team (AIT) i corrective actions related to ArW check valves wh4eh l determined to have failed during the HFT. l I o
M-In April 1989, the NRC staff issued SSER 21 which reports the status of certain li;;n;ing-issues that had not been resolved when earlier supplements of the Safety Evaluation Report were published. This supplement also lists new issues identified since GGER SER-Supplement 12 was issued and includes evaluations of licensing items resolved in the interin period. C. Enforcerent Activity No civil pensities were proposed or issued during the assessment period. On November 9, 1988, an enforcenent conference was held to discuss NRC findings regarding coating removal frem the service water piping system and the applicant's performance for: (1) procuring contractor services for the removal, (2) controlling the special process used for the removal, (3) inspecting and monitoring the process, and (4) taking prorpt and effective corrective actions fee-as identified deficiencies in the coating removal process occurred. Alth;;gh ;;;;1et;d :nfor;;;;nt ;;ti;n ;;;
- n;id;r;d, No civil penalty was issued although four Severity Level IV violations were issued.
These issues are still open and the results of a fo)1ow-up inspection are under review in NRC Headquarters. On February 28, 1989, a Severity Level III violation was issued for the past failure in 1**', to submit a timely request for extension of the Unit 1 construction permit. No civil penalty was issued b;;;;;; ;f th; c;rr;;tiv; ;;ti n th;t ;;; t;k n, th; ;;; ;f th; vici; tion, ;nd th; 1;;;;r ;;f;ty ;ignifi;;n;; ;f th; vi;;;ti;n. A; ; r;;;1t ;f th; A;;;;nt;d in;;;;ti;n ,ms.s ,__.._2 i --e NOT INCLUDED IN ,.m'"..'".,.*m.r---.. ..,,--.. i mm_ m.m. -~"-e-' ---e-" --is DRAFT A'd;;tiIi;d thT;; 0 Fili;;t Vi;10ti;;; ;I IMPORTANT MCO ;;;;;;t;ry r;;;ir;;;nt;. Th;
- t;;;n;; ;; th; th;;; ;;;;;;;;
vi;;;ti;n; h;; b;;n ;;;;;ni;;t;d 0; th;
- ppli;;nt during ;n MOO ;;nthly ;;it
- ting h
- 1d 0;pt;;i;r ",
1^0^, but n; vi;;;ti;n; h;v; y;t i;;n i;;;;d p;nding en :nf;;;;;;nt ;;nf;;;n;;. Alth;;;h n:t ) f;;;tily i;;;;d-4;;ing th; ;;;;;;;;nt p;ri;d, th; thr;; ;;;;r:nt vi;1;ti;;;.
- rr
- d in thi; ;;;;;;;;nt p;;i;d.
Table I provides a tabulation of NRC enforcement activity for each functional area during the assessment period. 'll'll'lll B ' Ii' - '
no-59 i + 1 i j D. confirration of Action Letters On May 5, 1989, a confirmation of action letter was issued regarding backleakage through the failed check ] valves in the ATW system that had occurred during the i J Unit 3 HTT. The letter confirmed the actions that the NRC understood TV Electric to be taking regarding the issue in pr per; tion Fer--the Fnc A+T. In brief, the l -letter required the following: the gathering of all l pertinent documents, performance of required testing and corrective actions, consideration of generic implications, and involvement of the NRC AIT in ongoing l activities. Act;vities Results of the Augmented Inspection Team that ev;1usted th
- ppli;;nt'; f;11
- a up :: tion; :r: d;;;n:nted witnessed the above actions i
have been issued in NRC Inspection Report 50-445/89-3 30; 50-446/89-30. y E. A31ecations The applicant has continued to demonstrate sensitivity towards allegers and employee concerns. As part of the Joint Stipulation to di;;i;; th; AOLS pr;;;;dir.g: resolve issues before the ASLB, the applicaut provided Ms. Billie Garde, attorney for citizens Association for Sound Energy, ;ddr;;;;d the opportunity to address all applicant and contractor supervisors and managers regarding employee concerns. Over a two month period, Ms. Garde gave a two-hour presentation to 25 classroom-size groups of supervisors and managers to increase their understan61ng and awareness of the importance of the proper handling of employee concerns. The applicant has methods in place by which employee concerns are received and resolved in a controlled manner. Employees are encouraged to take their concerns Aaa supervision, to the management hot line, to SAFETEAM, or to the NRC. At the beginning of the assessment period there were 29 open allegations. During the assessment period 26 allegations were received and 44 allegations were closed. At-the conclusion of the assessment period, 11 allegations, remained open. The low number of ) allegations received by the NRC indicates that the applicant is trying to build the plant correctly and that the applicant's programs for addressing employee concerns are effective.
.9 f 60 7ABLE I* EtiTORCEME!;T ACTIVITY l COMPARED AGAI!;ST DRATT "B" (1;O7 -21J l DRATT "C" 1 l i I et " t Dk i, off6 te. 4 IV 111 Il t Coastr ttica & tt'tettivt e action trog'a-$ i ? 10 0 0 0 i tag' hee *ih5/te:Paic o t sugw t 0 1 67 0 0 0 taf et, assessnent /Dselit y 0 0 3 0 0 0 Plomt Operettom 0 1 ib 0 0 0 maintenance /$s*veittence 0 0 fi 0 0 0 Security 0 0 0 0 0 0 toutetogicet Contrels 0 0 0 0 0 0 inergenc, prepa'cowss 0 0 0 0 0 0 -4 Other" 0 0 0 1 0 0 Totals i 4 Ni6 1 0 0 l. This table of enforcement activity does not include three apparent violations resulting from the AIT findings and included-in the exit meeting conducted on September 5, 1989. These apparent violations have not yet been issued. This violation occurred in 1986'and was due to the failure of TU Electric to submit a timely request to maintain the construction permit for Unit 1. Although the violation was issued in this SALP period, it does not reflect the performance of the applicant during this SALP period. 1 L l-l m _,.._n.,y- .c -.,.}}