ML20235P693
| ML20235P693 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/22/1989 |
| From: | Hale C, Livermore H Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20235P674 | List: |
| References | |
| 50-445-89-03, 50-445-89-3, 50-446-89-03, 50-446-89-3, NUDOCS 8903020329 | |
| Download: ML20235P693 (16) | |
See also: IR 05000445/1989003
Text
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APPENDIX B
U.
S. NUCLEAR REGULATORY COMMISSION
OFFICE OF. NUCLEAR REACTOR REGULATION
NRC Inspection Report:
50-445/89-03
Permits: CPPR-126
50-446/89-03
CPPR-127
,
Dockets: 50-445
Category: A2
50-446-
Construction Permit'
Expiration Dates:
Unit 1: August'1, 1991
Unit:2: August 1, 1992
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Applicant:
TU Electric
Skyway Tower
400 North Olive Street
Lock-Box 81
Dallas, Texas
75201
. Facility Name:
Comanche Peak Steam Electric Station (CPSES),
Units 1 &
2'.
Inspection At:
Comanche Peak Site, Glen Rose, Texas
Inspection Conducted:
January 11 through February 7, 1989
Inspector:
_6_ /
OA2k9
C. J . (Hyle , Reactor Inspector
Datd
Consultant:
J. Birmingham, Parameter
(paragraph 5)
Reviewed by:
..//19AN/M9 /
o2 522 89
H. H.
Livermore,~ Lead Senior Inspector
/ Dat/
8903020329 890222
ADOCK 05000445
g
PDL
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Inspection Summary:
Inspection Conducted: January 11 through February 7,
1989 (Report
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50-445/89-03; 50-446/89-03)
Areas Inspected: Unannounced, resident safety inspection of
applicant actions on previous inspection findings, use of
clarification memoranda, package closure review, procurement of
commercial grade items, unsatisfactory inspection reports, and
applicant meetings.
Results:
Within the areas inspected, one violation (failure to
perform evaluation for 10 CFR 50.55(e) deportability on
unsatisfactory inspection report deficiencies, paragraph 6) was
identified.
One weakness was noted (paragraph 2), prompt action in
an area of potential quality problems was not taken.
No other
weaknesses or significant strengths were identified.
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DETAILS
1.
Persons Contacted
- R.
W.
Ackley, Jr., Director, CECO
- M.
Alexander, Manager of Materials Management, TU Electric
- J.
L.
Barker, Manager, Engineering Assurance, TU Electric
- D.
P.
Barry, Sr., Manager, Engineering, Stone & Webster
Engineering Corporation (SWEC)
- J. W. Beck, Vice President, Nuclear Engineering, TU Electric
- H.
D.
Bruner, Senior Vice President, TU Electric
- J.
Buck, Senior Review Team
- W.
J.
Cahill, Executive Vice President, Nuclear, TU Electric
- J.
T.
Conly, APE-Licensing, SWEC
- W.
G.
Counsil, Vice Chairman, Nuclear, TU Electric
- C.
G.
Creamer, Instrumentation & Control (I&C) Engineering
Manager, TU Electric
- G.
G.
Davis, Nuclear Operations Inspection Report Item
Coordinator, TU Electric
- D.
E. Deviney, Deputy Director, Quality Assurance (QA),
TU Electric
- J.
C.
Finneran, Jr., Acting Manager, Civil Engineering,
TU Electric
- C.
A.
Fonseca, Deputy Director, CECO
- W.
G.
Guldemond, Manager of Site Licensing, TU Electric
- T.
L. Heatherly, Licensing Compliance Engineer,
TU Electric
- J.
C.
Hicks, Licensing Compliance Manager, TU Electric
- C.
B. Hogg, Engineering Manager, TU Electric
- S.
D.
Karpyak, Nuclear Engineering, TU Electric
- J.
J. Kelley, Manager, Plant Operations, TU Electric
- J.
J.
LaMarca, Electrical Engineering Manager, TU Electric
- 0.
W.
Lowe, Director of Engineering, TU Electric
- J.
W.
Muffett, Manager of Engineering, TU Electric
- W.
E. Nyer, Consultant, TU Electric
- E.
F.
Ottney, Program Manager, CASE
- S.
S.
Palmer, Project Manager, TU Electric
- W.
J.
Parker, Project Engineering Manager, SWEC/ CECO
- A.
Pereira, Assistant to Deputy Director, QA, Ebasco
- D.
M. Reynerson, Director of Construction, TU Electric
- A.
B.
Scott, Vice President, Nuclear Operations, TU Electric
- C.
E.
Scott, Manager, Startup, TU Electric
- J.
C.
Smith, Plant Operations Staff, TU Electric
- C.
L.
Terry, Unit 1 Project Manager, TU Electric
- R.
G.
Withrow, EA Systems Manager, TU Electric
- D.
R. Woodlan, Docket Licensing Manager, TU Electric
The NRC inspectors also interviewed other applicant employees
during this inspection period.
- Denotes personnel present at the February 7,
1969, exit
meeting.
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2.
Applicant Action on Previous Inspection Findings (92701)
(Closed) Unresolved Item (445/8863-U-01):
Review the
applicant's assessment of the 22 recommendations concerning
the three onsite records storage facilities to determine if
any represent violations of the requirements in NFPA 232-1975
or ANSI N45.2.9.
The TU Electric assessment has been completed and documented
in memorandum IMT-0210-044-0087 dated November 15, 1988.
In
summary, of the 22 recommendations, 11 were not included in
either NFPA 232 or ANSI N45.2.9, but are considered
enhancements to the records storage facilities.
The remaining
11 recommendations were included in NFPA 232, 4 as
requirements and 7 as recommendations (3 of the
7 recommendations were required by ANSI N45.2.9).
As of this
inspection report period, all 22 recommendations have been
satisfactorily dispositioned or implemented.
The four
NFPA 232 requirements (storage of unnecessary combustibles in
one vault and new vault doors in all three vaults) were
completed on August 8, 1988 (combustibles removed) and
December 27, 1988 (vault doors installed).
The three
recommendations required by ANSI N45.2.9 (proper fistallation
of fire extinguishers) were implemented by October 3, 1988.
Since all actions concerning this item are now sat?.sfactorily
completed, no further inspection is planned and the unresolved
item is closed; however, timeliness of the projects response
to a recognized need is of concern to the NRC inspector.
The
following is a chronology of correspondence and actions
associated with this matter.
December 29, 1986
Records management requests engineering
assistance in a fire protection evaluation
of the operations records storage
facility.
January 20
1987
Engineering directs Impell to perform
evaluation.
February 3,
1987
Impell estimates project completion date,
July 6,
1987.
March 2, 1987
Engineering directs Impell to include an
evaluation of the engineering records
vault.
March 31, 1987
Impell requests extension to October 30,
1987, due to preparation for NRC audit of
fire protection.
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January 13, 1988
Records management request evaluation to
include the new project records storage
facility.
March 18, 1988
NRC February inspection report issued with
open item related to vault certification.
March 30, 1988
Engineering directs Impell to complete.
June 2,
1988
Impell issues calculation 0210-063-0086
(Fire Protection Review of CPSES Records
Vaults) with 22 recommendations.
July 27, 1988
Engineering provides records management
with the results of the fire protection
evaluation of records storage facilities.
August 5, 1988
Records management requests
engineering
and
involvement in the disposition and
August 17, 1988
implementation of the recommendations.
October 26, 1988
NRC September inspection report closing
various open items and opening unresolved
item relative to Impell recommendations.
December 27, 1988
Last of recommendations completed.
As shown above, 1.5 years following the initial request, the
evaluation was performed; then, 6 months later, the
recommendations coming out of that evaluation.were completed.
This lack of responsiveness by the project to quality related
concerns may be indicative of misplaced priorities by the
applicant, but in any event is viewed by the NRC inspector as
a weakness in not providing prompt action in an area of
potential quality problems.
3.
Use of Clarification Memoranda (35061)
In November 1988, the NRC inspector identified a document
being used by quality engineers (QEs) to answer questions
raised by QC.
The document appeared to be an informal means
of obtaining answers and clarifications to Electrical
Specification ES-100 and was similar in many respects to the
request for interpretation / clarification (RFIC).
Because of
the potential for misuse of the RFIC, its.use was discontinued
by memorandum TUQ-3730 from the QC manager in March 1986.
Therefore, the QC manager was asked to provide further
information about this document that is now being used.
During this report period, the QC manager was provided the
results of a study he requested from QC engineering.
The
following summarizes the actions that resulted.
By memorandum (TUQ-7019) dated December 15, 1988, the quality
work planning manager directed all QC engineering to
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discontinue the use of these memoranda requesting
clarification.
Further, each QC engineering discipline was
requested to ersluate all clarification memoranda that had
been initiated to determine if specification changes were
necessary and if so, initiate the necessary change request to
the appropriate engineering group.
This evaluation has been
completed and the results documented in a memorandum from the
quality work planning supervisor dated January 17, 1989.
The
evaluation found that the use of the clarification memoranda
was limited to the electrical discipline and.related
principally to Electrical Specification ES-100.
The
evaluation did not identify any instance where a clarification
memorandum required an ES-100 change; however, in some cases a
change was made for clarification.
The NRC inspector reviewed the related documents of this
evaluation including 18 clarification memoranda; a total of
approximately 25 memoranda were issued.
The NRC inspector
found no fault in the evaluation conducted.
The NRC inspector
noted that QC management took prompt and decisive action when
this matter was brought to their attention.
No violations or deviations were identified and no further
inspection of this matter is planned.
4.
Package Closure Review (35061)
Packages of documents are generated as a result of numerous
onsite activities including design, fabrication, construction,
and inspection.
Several package closure groups (PCGs) have
been established onsite as a final review of these document
packages (DPs) to assure that the DPs contain all the required
documents and that they were completed properly before
transmittal to the records management group for vaulting.
During this inspection period, these PCGs were inspected.
A
description of the process and the results of these PCG
inspections follow.
a.
Construction PCG
This PCG reviews all non-ASME construction work packages
for both quality and nonquality related activities with
the primary focus on. construction documentation.
As
fabrication, construction, and inspection activities are
completed for a given segment of work, the DP is reviewed
by a construction engineer (CE) to assure that all
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required documents are in the package, all inspections
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have been completed, and all documents in the package
have been completed properly.
When the CE has determined
that the DP is ready for closure, it is sent to the PCG
for a final review before vaulting.
When the
construction PCG receives the DP: (1) the Management
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Information Tracking System'(MITS) is updated (statused)
to reflect 'the . custody and responsibility of: the DP,
(2) the MITS is checked to assure that the Package
Inventory Card (PIC) contained in the DP is current, and
-(3) the DP.is either assigned to a PCG reviewer or
temporarily held in a~ fireproof file cabinet for later
review.
During the in-house review, the DP isl controlled by use
of a document transmittal form attached to the DP.
In
this manner, the DP can be retrieved or located at any
time during the~PCG in-house' review.
If it is necessary
to return the DP.to the CE for further work, the MITS is'
again statused to reflect-custody and responsibility of
the DP.
The-control and-review of the DP are conducted in
accordance with Procedure.ECC 2.13-6, " Construction Work
Review and Statusing."
Each DP is. reviewed for
construction completeness of all work assignments as
dictated by.the referenced design documents, and.that'all
required documents are in the DP and listed on the PIC.
If documents are found missing, incomplete, or in. error,
theLDP.is' returned to the responsible group for action.
When the necessary action is taken, the DP is. processed
again.
If the DP is found acceptable by the PCG, it
takes one of two paths. _If the DP involved nonquality
related activities, itJis transmitted directly to the
records turnover coordinator at'the' records vault.
If
-the DP' involves quality related activities, it is sent to
the quality.PCG for further review.
The PCG monitors DPs requiring correction on a daily
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basis. .This information is trended by the PCG'and'any
resulting concerns are reviewed with the appropriate
personnel to resolve the adverse trends identified.
This PCG was established in June 1988 to improve the
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quality.of.the DPs coming from the construction
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department.
The PCG has been effective in identifying
problems with DPs'and getting them corrected, thus
enhancing the quality of the vaulted DP.
As of
January 13, 1989, there were 86,042 DPs opened against
Unit 1 and common, and of these 45,154 had been processed
and vaulted.
b.
Quality PCG
This PCG is located in the same building as the
construction PCG (CRG), beginning their review of the
quality-related DP when the CRG review has been
satisfactorily completed.
While the total DP is reviewed
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by this PCG, the primary focus is a review of work
process control documents for completion of inspection
requirements.
This review is conducted in accordance
with Procedure NQA 3.09-0,04, " Review of Work Process
Control Documents."
The review approach used by this PCG is the same in most
respects to that used by the CRG except for the
following:
When problems are identified resolution is obtained
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with the responsible quality engineer or QC
inspector.
While a document correction form is used to list
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these problems, when repetitive or historical
programmatic documentation problems become apparent,
they are documented on a Standard Documentation
Deviation Resolution (SDDR) for correction.
The
SDDRs and an SDDR log are maintained within the PCG.
When the quality PCG review finds a DP acceptable
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for vaulting, it is returned to the CRG processing
cluster.
The MITS is statused and the DP is sent-to
the records vault,
c.
ASME PCG
This PCG, also referred to as the Paper Flow Group (PFG),
is the processing center for DPs pertaining to ASME Code
items and some non-ASME mechanical items.
The procedure
controlling this process is AAP-18.3, "ASME Component
Documentation Verification and N-5 Certification."
Procedure AAP-18.3 relates primarily to ASME Section III
work, mainly Unit 2, while ASME work on Unit 1 is
essentially ASME Section XI; consequently, this procedure
does not describe clearly all work on Unit 1 DPs.
The
following is a description of the ASME document
verification process which is grouped by DP type;'i.e.,
hangers and piping / mechanical equipment supports.
When all field work and inspections are completed on a
specific hanger, the DP is delivered to a construction
engineer (CE) in the PCG.
The CE assures that all
required dccuments are completed and contained in the
package.
A walkdown engineer then verifies the hardware
configuration.
When this step is satisfactorily
completed QA/QC personnel review tha hanger package again
to assure legibility, completeness, and accuracy. After
this, they sign the required forms in the package and
forward the package to the Authorized Nuclear Inspector
(ANI).
One form prepared by QA/QC is the Hanger Index
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Report (HIR) which is an inventory of all the required
documents in the hanger packages and which provides a
basis for the NIS-2 report documenting ASME Code
compliance.
The ANI completes his review of the package,
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signs the appropriate forms, and forwards the package to
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the PFG. The PFG sends the package to the records
turnover coordinator for vault storage.
The PFG also
assures that the MITS is statused properly.
When construction and inspection has completed their work
on a package for piping or mechanical equipment supports,
the completed DP is sent to the Field Distribution
Station (FDS) and the MITS is statused.
These DPs are
processed in another PCG similar to the hanger PCG.
A CE
reviews the DP and when that review is complete, if-
welding was involved, the DP is sent to a welding
engineer (WE) for further review.
have assured the construction and welding documents are
proper and complete, the package is sent to QA/QC
nersonnel for further review and the preparation of the
Pressure Boundary Index (PBI) form.
When the QA/QC
review has been satisfactorily completed, the required
forms are signed and the DP is sent to the ANI.
When the
ANI completes his review and signs the appropriate forms,
the DP is returned to the PCG, the MITS is statused, and
the DP is sent to the records turnover coordinator for
storage.
When during either process described above an error is
identified or a document is missing, the DP is not
processed further until the item is resolved.
While a
PIC exists in the DPs described above, the HIR and the
PBI forms are prepared for each of the DPs and provides
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the inventory of the required documents in the package.
The PBI and HIR forms are also used by the ANI and QA/QC
in the preparation of the NIS-2 forms, which is the
owner's report of ASME Code compliance for repairs to and
replacement of code items.
When a system has been
completed, or when directed by the owner, the NIS-2 form
is completed and sent to Comanche Peak Engineering where
the NIS-2 forms (attestation of ASME Section XI code
compliance) are referenced to the N-5 forms (Section III
code compliance) and then vaulted.
d.
Inspection Results
Each of the procedures identified above were reviewed by
the NRC inspector.
The NRC inspector also interviewed
personnel in each of the PCGs described above and one ANI
concerning their knowledge of the controlling procedures
and their responsibility.
The NRC inspector selected
20 DPs that the PCGs had completed and inspected them for
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compliance with the controlling procedure.
The NRC
inspector identified no violations or deviations but did
make the following observations.
As noted above, the controlling procedure for the ASME
PCG (AAP-18.3) does not describe clearly the processing-
review for Unit 1 DPs.
Beginning in early February 1989,
the ASME and non-ASME construction personnel involved in
the package closure process will be combined.
While
their functions will remain essentially the same, this
reorganization and/or relocation of construction
personnel will require revision of procedures.
These
revisions should provide a more clear description of the
ASME document closure process.
To assure this process is
adequately described in the revised procedures, this item
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will be followed as an open item (445/8903-0-01).
The vast majority of DPs have package numbers relating to
hardware; i.e, systems or components.
A few DPs were
reviewed by the NRC inspector that had document numbers
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on the DP;
Since the.DP
numbers above do not identify a system or component, the
NRC inspector asked the records turnover coordinator for
a listing of all documents affecting the components to
which the DCAs applied.
Using the component numbers
identified in the DCAs, the MITS printout of documents
affecting the components did not list the DCAs from which
these component numbers were obtained.
This appeared to
the NRC inspector as a problem in document retrieval for
items completed that have subsequent modification.
The
NRC inspector discussed this concern with construction
management who advised the NRC inspector of an
enhancement that would provide MITS with the added
capability to cross reference the DCA packages to the
affected component.
This enhancement to MITS is already
underway together with a program to backfit those DPs
previously completed and sent to the turnover
coordinator.
The NRC inspector plans no further formal
or scheduled inspection of this specific item, but it
will continue to be monitored during the conduct of other
inspections.
5.
Procurement of Commercial Grade Items (38703, 35746)
In NRC Inspection Report 50-445/88-80; 50-446/88-76, the NRC
inspector reported that the applicant had developed a program
for the procurement and control of commercial grade items
intended for use in basic components;
i.e.,
safety related.
The NRC inspector determined that the program was based on
current industry standards and was in compliance with NRC
requirements.
The NRC inspector's determination was based on
review of procedures and discussions held with applicant
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personnel in procurement engineering, procurement QA, and
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receipt inspection.
During this report period the NRC inspector reviewed:
(1) procurement packages prepared for purchase of commercial
grade items, (2) corrective action reports (CARS) prepared to
address identified deficiencies in the past procurement of
commercial grade items, (3) procedures governing the
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applicant's review of incoming information relative to the
quality of procured material, and (4) procedures detailing the
applicant's methods for receipt, storage and issue of procured
items.
The results of the above reviews follow:
The documents prepared for the procurement of items and
services to be used at CPSES are compiled in procurement
document review packages (PDRPs).
At the time of this
inspection, only two PDRPs relative to commercial grade items
had been prepared under the current program.
Of these two
packages, one was prepared for the purchase of 100 bags of
non-shrink grout, while the other was a change order to
upgrade certain fuses for use in safety-related equipment.
The PDRP for grout contained:
(1) a requisition on
procurement, (2) a procurement document review summary (PDRS),
(3) a commercial grade item evaluation, (4) critical
characteristics identification, and (5) both a recommended
verification plan from engineering and a final verification
plan from procurement QA approved by engineering for technical
adequacy.
These documents were in accordance with procedural
requirements.
The final verification plan contained
attributes to (1) assure that the item received was the item
specified in the procurement documents, and (2) verify by
performance of compressive strength tests that the item would
perform its safety-related function.
The verification plan
also assured that the grout was received in an acceptable
condition and was accompanied by a certificate of conformance.
The NRC inspector's review of the PDRP for the fuses
determined that it had been rejected by procurement QA and
returned to procurement engineering for clarification.
The
NRC inspector concurred with procurement QA that the package
did not provide a clear presentation of the critical
characteristics and may not have considered seismic and
environmental qualifications for the fuses.
Since the package
had been rejected by procurement QA, the NRC inspector
discussed the package preparation with the responsible
engineer and expressed a concern to the applicant about the
quality of packages.
The applicant informed the NRC inspector
of a recent meeting held to discuss, among other items, the
improvement of packages sent to procurement QA from
engineering.
The NRC inspector found that the meeting was an
appropriate method of addressing the concern.
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In order to assess the past program, the NRC inspector
performed a review of CARS initiated by the applicant.
The
CAR list showed that CAR 86-002 and CARS 88-34, -35, and -36
addressed deficiencies in past procurement
of commercial
grade items.
CAR 86-002 addressed the improper procurement of
replacement parts by Operations.
Due to a lack of
understanding of requirements, the replacement parts were
purchased to an incorrect code classification.
The corrective
actions being taken for CAR 86-002 appear appropriate although
the CAR is still open.
CARS 88-34, -35, and -36 were issued
to address safety concerns for material procured from a
supplier of fasteners currently suspected of falsifying
material certification.
These three CARS are open and
applicant actions to address the concerns are not yet
complete.
NRC review of the CARS and the applicant's actions
taken to resolve the safety concerns will be followed and
reported in a subsequent report.
This is an open item
(445/8903-0-02; 446/8903-0-01).
The NRC inspector was informed by the applicant that a review
of the effects of past commercial grade procurement was being
performed.
Per discussions with the task manager for this
review, the review was to determine if past procurement of
commercial grade items used in safety-related applications may
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have occurred without the benefit of dedication in compliance
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with 10 CFR Part 21.
At the time of this report, that review
was in the developmental stage.
Although the review is being
performed to determine if a problem exists and whether formal
action such as a CAR is warranted, NRC inspection of the
review results is appropriate and will be reported.when the
review is complete.
This is an open item (445/8903-0-03;
446/8903-0-02).
The NRC inspector determined that the program for evaluating
industry experience relative to commercial grade items was not
yet complete.
While procedures such as ECE 5.19 " Review of
Vendor Documents," NEO-2.29, " Industry Operating Experience
Review," and NEO 4.01, " Correspondence with the NRC and Other
Regulatory Agencies," define the responsibilities for review
and evaluation of this data from sources, such as the NRC, the
ASME, or the applicable vendor, no procedure has been
developed to define the responsibilities for review of data
from industry sources, such as the Nuclear Plant Reliability
Data System (NPRDS) program.
Discussions held with applicant
personnel determined that a procedure to establish the NPRDS
program was in draft status.
This was deemed acceptable to
the NRC inspector in that CPSES is under construction while
the NPRDS program is primarily designed to enable an exchange
of reliability data for operating plants.
As regarding review
of information arising from within CPSES, the NRC inspector
determined that station administrative procedures, such as
STA-503, " Plant Incident Report," and STA-504, " Problem
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Report," provided methods by which operations personnel would
report information on significant failures cf plant equipment
to Results Engineering for evaluation of adverse impact on
plant operations.
During the construction phase, hardware
nonconformances are documented on unsatisfactory irs and NCRs
and are evaluated by engineering if applicable.
The NRC inspector reviewed warehouse procedure
for both
responsibilities and activities of warehouse pq) define the
construction and operations.
Those procedures
rsonnel.
The
procedures provided requirements for the separaition of
e
safety-related and nonsafety-related items and notification ,6f
QC for receipt inspection of safety-related equi ment.
,
Further, the operations procedures required the p eparation
and attachment of a QA Acceptance Tag for all safehy-Jslated
items.
Data provided on the QA Acceptance Tag included:
(1) the purchase order number and the item number from the
purchase order, (2) a TU Electric Stock Number (TSN),
(3) shelf life expiration date, and (4) the heat number if
applicable.
The procedure specifically provided a requirement
that different lot shipments of identical items not be mixed.
Also, maintenance requirements and special handling
requirements are reviewed and notifications are to be provided
to the responsible department (s) when items are to be issued
from warehouse stock.
Procedure WHS-003, " Issues and Returns," provides for the
recording of information similar to the information recorded
on the QA Acceptance Tag.
The information is recorded on a
Warehouse Issue Request and a copy is sent to the TU Electric
Operations Record Center.
The NRC inspector determined that
the operations procedures provided a method by which an item
on a particular purchase order could be traced to its point of
installation.
This ability would be necessary if subsequent
information indicated that procured items were defective.
.
r
Special provisions were made to assure the traceability of
items issued in bulk;
e.g.,
oil, grease, or bolting.
Those
provisions appeared satisfactory to the NRC inspector.W
L
Warehouse activities for construction are controlled by B&R
Procedure CP-CPM-8.1, " Receipt, Storage, and Issuance of
Items."
This procedure provides for actions similar to those
found in the operations procedure; however, the process by
which items are identified, issued for use, and tracked to
point of installation differs from the operations process.
The construction process requires intended use to be
identified on a material requisition form, but allows
deviations from the intended use if approved by QC.
Further,
bulk items, such as pipe, pipe fittings, gaskets, nuts, bolts,
etc., are not required to be identified by purchase order
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number.
These two procedural allowances mean that
accountability of issued items back to the purchase order may
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not be possible in some cases.
This practice is not unusual
for plants under construction but does not provide sufficient
information to assure identification of all locations where an
item is installed.
The effect of the above practice will be
considered during follow-up on the above open item
(445/8903-o-03; 446/8903-0-02).
In summary, the NRC inspector determined from review of the
program procedures, review of a sample of commercial grade
procurement packages, and discussions with personnel involved
in the various phases of procurement that an adequate program
for commercial grade procurement exists.
The NRC inspector
notes that some portions of the program are in a developmental
stage and that few packages were available for review.
Since
commercial grade procurement for items to be used in
safety-related equipment is normally most necessary during the
operations phase of a power. plant, especially in preparation
for outage work, this program will be reinspected after
turnover to plant operations.
No violations or deviations were noted during this review.
Two open items were identified for assessment of the
applicant's review of the past commercial grade procurement
program and to assess the adequacy of corrective actions
relative to the supplier that provided fasteners with
questionable certifications.
6.
Unsatisfactory Inspection Reports (92700)
During a plant tour, the NRC inspector noted an apparent
deficiency on a pipe hanger for which the post construction
hardware validation program had been completed.
The
deficiency had been documented on an Unsatisfactory Inspection
Report (Unsat IR) in accordance with Procedure AAP-16.1,
" Controlling Nonconforming Items."
The NRC inspector reviewed
further the use of the Unsat IR and found the following:
Section 4.1 of Procedure AAP-16.1 defines the Unsat IR as the
primary deficiency reporting mechanism used by B&R for
reworking components (including replacement) to conform to
prior specified requirements in accordance with approved
project procedures, specifications, drawings and the ASME
Code.
This document and its processing are essentially the
,
same as the Construction Deficiency Report whose use was
discontinued by the applicant in late 1987.
B&R, whose scope
includes all ASME Code work, began using the Unsat IR in July
1988 and to date have issued just less than 3,000 Unsat irs.
This Unsat IR should not be confused with the inspection
reports generated by the QC inspector during the in-process
inspection of record activity which also document both
satisfactory and unsatisfactory conditions.
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In most all respects the Unsat IR is processed the same as an
NCR dispositioned as " rework" or " scrap" with one notable
exception; there is no evaluation for deportability.
' Paragraph 50.55(e)(1) of 10 CFR Part 50 states, in part, "If
the permit is for construction of a nuclear power plant, the
holder of the permit shall notify the Commission of each
deficiency found in design and construction, which, were it to
have remained uncorrected, could have affected adversely the
safety of operations .
at any time throughout the expected
.. .
To assure such deficiencies
"
lifetime of the plant
1
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are evaluated for deportability, the applicant implemented
Procedure NEO 9.01, " Evaluation and Reporting of Adverse
Conditions Under 10CFR21 and 10CFR50.55(e)," which states in
paragraph 5.1.2, "All TU Electric organizations under the EVP
NEO [ Executive Vice President, Nuclear Engineering and
operations) shall develop lower-level implementing procedures,
as required, to evaluate Adverse Conditions'for
deportability."
Adverse conditions are defined to include
such' terms as deficiency, defect, and deviation.
Contrary to the above, Procedure AAP 16.1 authorizes the use
of Unsat irs for documenting and correcting certain types of
deficiencies; however, this procedure does not direct the
. required evaluation be performed nor is.there evidence that
such evaluations have been or will be performed.
This is
considered a violation (445/8903-V-04; 446/8903-V-03).
7.
Applicant Meetings (92700)
The NRC inspector attended applicant meetings concerning site
activities and implementation of various site programs.
Meetings attended during this reporting period included:
QA Overview Committee
.
Recommendation Review Group
.
While these meetings reflect management's involvement in
day-to-day activities and attention to potential problems,
no
violations or deviations were identified.
8.
Open Items
open items are matters which have been discussed with the
applicant, which will be reviewed further by the inspector,
and which involve some action on the part of the NRC or
applicant or both.
Three open items disclosed during the
inspection are discussed in paragraphs 4.d and 5.
9.
Exit Meeting (30703B)
An exit meeting was conducted February 7,
1989, with the
applicant's representatives identified in paragraph 1 of this
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report.
No written material was provided to the applicant by
the inspectors during this reporting period.
The applicant
did not identify as proprietary any of the materials provided
to or reviewed by the inspectors during this inspection.
During this meeting, the NRC inspectors summarized the scope
and findings of the inspection.
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