ML20011E445
| ML20011E445 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/25/1989 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20011D121 | List:
|
| References | |
| NUDOCS 9002140054 | |
| Download: ML20011E445 (4) | |
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....,v ett avan PLARA onws. Surfs wee Anuwovow texas et INF 25 m MEMORANDUM FOR: -Dennis M. Crutchfield. Associate Director for Special Projects. NRR t
FROMt J. E. Gagliardo, Chief. Operational Programs Section Region !Y
SUBJECT:
COMANCHE PEAK SALP REPORT l
l This confirms our telephone conversation of October 23, 1989. regarding information that should be constdered for inclusion in the Comanche Peak SALP 3
report.
As I noted in our conversion, I do not have a differing opinion with the information and the analyses provided in the draft report, nor do I have a i
differing opinion with tie conclusions drawn by the SALP board.
My question regards the fact that the report does not describe some of the concerns that were identified by the E0P (EF.G) Inspection Team in their inspection of August 14-25. 1969.
In fairness to the SALP board, the E0P l
inspection report (50-446/89 59) was not issued until September 29. 1989. The only information available to the board from this inspection was that included in our-September 9,1989, memorancum to Bob Warnick (copy attached). As you will note from this inpu't, the board did not have sufficient details to adequately speak to the concerns addressed by this inspection.
Since we now have the specifics of the E0P inspection effort. I believe the team's findings should be reflected in the final report.
I have also attached pages 16 and 17 from the E0P inspection report, which you may with to consider for inclusion in the SALP report. My recoinnendations are that the board consider adding a statement on page 11 of the draft report regarding our concerns on the engineering review of the ERGS.
!=also recommend that the board consider add'ng a statement on page 16 of the draft report regarding the concerns we had with the applicant's QA involvement in the review of the ERGS as they were being developed and implemented.
I have no objections if the SALP board chooses not to include these statements because I do not believe that these findings change the conclusions drawn by the board.
9 01 Nd54 pp s
i e
Dennis Crutchfield 1-l
! would be pleased to discuss this material is more detail with you or the SALP board, f
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J. E.
fardo, Chief l
berati 1 Programs Section
Attachment:
(asstated) cc:-
R. D. Martin i
L. J. Callen C. 1. Grimes T. P. Gwynn J. P. Jaudon H. H. Livermore J. E. Lyons P. F. McKee R. F. Warnick J. S. Wiebe J. H. Wilson L. A. Yandell l
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. i inspection.
In addition. the A0s conducted plant walkoowns of ERG attach-i monts and local action steps to ensure consistency with plant nomenclature and familiarity with required actions.
The training provided to the A0s L
appeared to be seequate for familiariting them with t3e acti4ns required
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t in their areas of responsibility during accident situations.
2.7 Onooine tvaluation of ER6s (26592) (Task B) i Section 6.2.3 of WRIG-0899 reevires that licensee's establish a program for the ongot g evaluation of E0Ps that the ongo og eve 194 tion program (ERGS).
WRft-0899 further requires include the evaluation of the technical adequacy of t e ESPs on the bas's of operational experience and use, training experience, simulator percises, and centrol room walkthroughs.
l The team noted that in a memorandum dated June 8.19d9, the applicant l
directed all operations department employees to notify the appropriate personnel of any procedural changes t14t are considered to be necessary.
Procedure 00A 207. ' Guidelines for the Preparation and Review of Operations l
Procedures.' Revision 2. August 18. 1987. r operations procedures (including the F.R6s) equired (Step 6.1.6) that all l
be revised against the design basis durieg the development of a revision or every 2 years. All of the active ERGS had been revised in 1989 and had been schedulee for this next biennial review. Procedure 00A-207 provided a form (Figure 7.1) that was to be useo as a checklist for verifying the adequacy of a new or revised procedure.
Section 6.3 of Procedure 00A 207 provided guidelines and a form (Figure 7.2) to be used for reccounending changes or im The team reviewed selected foms (Figure 7.2)provements in procedures.
on which individuals had recom-mended changes to the ERGS. The recernendations had been entered into the applicant's tracking system, and printouts were routed to the managers and supervisors of the operations department. Applicant representatives interviewed stated that the Figure 7.2 fem was not always returned to the individual submitting the recommendation.
They noted that if the recommen-dation was incorporated into the procedure. it would appear in the next revision, but if the recomendation was not opproved, the individual making the receumandation was usually notified. Some of the individuals interviewed noted that they had not yet received feedback on recessendations submitted. An applicant representative stated that the status of an employee recommendstion was shown on the printout of the tracking system.
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but it was apparent that some of the supervisors receiving the printouts were not sharing them with all of their employees. Measures were needed to ensure that the originators were made aware in a timely manner of the resolution of recommendations. Failbre to do so can be a disincentive to individuals continuing to submit reconnendations.
The applicant had also issued Procedure 00A-204. " Preparation of Emergency I.
Response Guidelines." Revision 7. on July 18. 1989. In Sections 6.2 and i
6.3 of Procedure 004-204, guidelines were provided for submitting l
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recomendations for changi g the ERGS using Procedure Fom 00A 204-2. The team noted, however, that or all of the recommeneations reviewed the fors in procedure 0DA 207. Figure 7.2. was used and not procedure Form 00A-204 2.
The appilcant needs to resolve this issue and define which foto is to be used for seking roccamendations for changing the (R$s.
j The team reviewed the applicant's process for reviewing the original ERGS and changes therete. Recent revisions of Procedure 00A 204 required a 1
multidisciplirary review of ERGS and changes to the ERGS before the fall of 1988 however, the engineerini department had little or no involvement in the review of the ERGS. At that ties, the applicant developed a process for reviewing all of the ERGS to determine actual or potential differences i
i between the ER$s and the applicable design basis documents. Engineering personnel identified a total of 294 inconsistencies that required further review and evaluetton. At the time of this inspection approximately half I
of the inconsistencies had been resolved. The applicent committed to resolve all of the differences or provide justification for the inconsistencies before fuel load. This is an open item that will be reinspected before fuel. load (445/8969-03). The applicant also comitted to have those inconsistencies, that require revision of the ERGS incorporated into the applicable ER6 and the appropriate trainin Mode 2 operations. Thfs is an open ites (g completed before achieving 446/446/8999-04).
The team found that QA personnel had been involved -in the review of the ERGS since 1584. In the 1984 reviews, the 0A reviewer had used a checklist based on NUREG-2005 that was generally completed with the exception of that portion of the checklist requiring a control reen/in-plant walkdown.
The team found that GA personnel had been perfotsing only table-top reviews I
of the ERGS and had not performed in plant or control room walkdowns. The taas also noted that for the reviews performed in 1985 and 198g. the NUREG-2005 checklist had not been used. The QA reviewer interviewed stated that he used Procedure 004 204 as a guideline for the review. The team also found that the resolution of the QA reviewer's cessents had not been forwarded to his and he was not aware of their resciution. The team considers a review without walking down at least portions of the procedure to be only minies11y acceptable.
The tese also reviewed the QA audit and surveillance activities relating to the E0Ps. The applicant had perfomed an audit (TUS 8912) of the ERGS and controlling documents in June 1989 but the audit did not include a walkdown of the ERes. The audit did include a review of the operator
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training progree related to the ERGS, but not the monitoring of actual training on the ERSs. The team found that no QA surveillances had been performed that monitored the training of the operators on the ERes.
Applicant representatives consitted to include en annual audit of the ERGS in their master audit plans and to perfore a semiarnwal surve111sece of simulator training on the ERGS. They also cosmitted to walk down future revisions to the EIGs.
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