ML20245E076
| ML20245E076 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/19/1989 |
| From: | Bitter S, Hale C, Livermore H, Mckernon T Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20245E072 | List: |
| References | |
| 50-445-89-32, 50-446-89-32, IEC-80-22, IEIN-85-024, IEIN-85-24, NUDOCS 8906270319 | |
| Download: ML20245E076 (31) | |
See also: IR 05000445/1989032
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L APPENDIX B
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U..S.-NUCLEAR REGULATORY COMMISSION
't OFFICE OF NUCLEAR REACTOR REGULATION-
.NRC iaspection Report: 50-445/89-32 Permits: CPPR-126
50-446/89-32 CPPR-127
Docketsr. 50-445 Category: A2
50-446
Construction Permit
Expiration Dates:
Unit 1: August 1, 1991
Unit 2: August 1, 1992
Applicant: TU Electric
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas 75201
Facility Name:. . Comanche Peak.Steaut Electric Station (CPSES),
Units 1 & 2
Inspection At: . Comanche Peak' Site, Glen Rose, Texas
Inspection' Conducted: May.3-through June 6, 1989
Inspectors: , d V T 9
C.J. e,i Reactor Inspector Date
(pa raphs 8, 11 and 14)
6 . D. M % &/n/99
S. D. Bitter, Resident Inspector Date
(paragrap s.6 and 10)
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T. O. ycKernon, Reactor /14hpector D&te
(pa m;raphs 9 and 12)
8906270319 890619 r
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" C'onsultantsi .'J. Birmingham, RTS
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(paragraphs 2,3,4,5,7,8
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(U ' - J. - Dale, 'EG&G :(paragraph 13);
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Reviewed by:.
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H..H..Livermore, Lead Senior Inspector Date
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Inspection Summary: l
Inspection Conducted: May 3 through June 6, 1989 (Report
50-445/89-32; 50-446/89-32)
Areas Inspected: Unannounced, resident safety inspection of
applicant's actions on previous inspection findings; follow-up on
violations /deviatiors; action on 50.55(c) deficiencies; the
operations quality programs for preoperational testing audits and
surveillance, quality verification function, audits, document
control, maintenance, surveillance testing and calibration control, ,
records, tests and experiments, and measuring and test equipment; J
and applicant meetings.
Results: Within the areas inspected, one violation was identified.
During a startup test, a procedural step was not performed and the j
startup test engineer did not initiate a deficiency report or ;
procedure change. This error was noted by surveillance personnel ;
but no deficiency was issued (paragraph 5). )
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One strength and two weaknesses were noted. The Plant Evaluation
Group has made significant improvements in their program for
identifying and preventing plant operations problems (paragraph 6).
The internal audit program continues to have difficulty in timely
issuance of reports (paragraph 5). The distribution of revised
documents to controlled locations is not tinely (paragraph 8) .
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DETAILS
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1. Persons Contacted
- M. Axelrad, Newman and Holtzinger
- D. P. Barry, Senior., Manager, Engineering, SWEC
- D. Bize, License Support, TU Electric
- H. D. Bruner, Senior Vice President, TU Electric
- W. J. Cahill, Executive Vice President, Nuclear, TU Electric
- H. M. Carmichael, Senior QA Program Manager, CECO
- J. T. Conly, APE-Licensing, SWEC
- W. G. Counsil, Vice Chairman, Nuclear, TU Electric
- S. Ellis, Performance and Testing, TU Electric
- C. B. Hogg, Engineering Manager, TU Electric
- R. T. Jenkins, Manager, Mechanical Engineering, TU Electric
- J. J. Kelley, Manager, Plant Operations, 'U Electric
- J. J. LaMarca, Electrical Engineering Manager, TU Electric
- 0. W. Lowe, Director of Engineering, TU Electric
- S. G. McBee, NRC Interface, TU Electric
- B. Packo, Licensing Engineer, TU Electric
- S. S. Palmer, Project Manager, TU Electric
- P. Raysircar, Deputy Director, Unit 2, CECO
- D. Real, Dallas Morning News
- D. M. Reynerson, Director of Construction, TU Electric
- J. C. Smith, Plant Operations Staff, TU Electric
- R. L. Spence, TU/QA Senior Advisor, TU Electric
- C. L. Terry, Unit 1 Project Manager, TU Electric
The NRC inspectors also interviewed other applicant employees ,
during this inspection period.
- Denotes personnel present at the June 6, 1989, exit meeting.
2. Applicant Action on Previous Inspection Findings (92701)
a. (Closed) Open Item (445/8716-O-04; 446/8713-O-03): This
open item concerned the overall review of field deficiency
reports (FDRs) for proper use and closure, and the
specific review of those test deficiency reports (TDRs)
that received an engineering disposition. This open item l
was issued since Comanche Peak Response Team results and
other sources indicated that these documents may have been
used inappropriately to document and disposition
nonconforming conditions.
The applicant has addressed the above issues and has
performed a review of FDRs and TDRs. The NRC inspector
reviewed the following information relative to these
issues.
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In regard to the use of FDRs, the NRC inspector reviewed
office memorandunt QQD-909, which documents the review of
FDRs performed by Quality Engineering. The review was
performed on all known FDRs to determine those cases where
the FDRs were improperly used or closed. Discrepant
conditions were then transferred to a nonconformance
report (NCR) or deficiency report (DR).
The NRC inspector had previously performed'a sample review
of the FDRs and based on that review concurs with the
applicant's approach,and resolution of this issue. Since
the use of FDRs was discontinued in 1982 and the current
program for control of nonconformances and deficiencies
appears adequate, the NRC inspector feels that no other
preventive action regarding FDRs is required.
In regard to the review of TDRs for adequate engineering
dispositions, the NRC inspector reviewed engineering
memorandum NE-26068 which documents the method used to
review TDRs. NE-26068 documents that approximately
700 TDRs were identified that received engineering
dispositions. These 700 TDRs were then evaluated to
determine the adequacy of the engineering dispositions.
This evaluation resulted in Engineering Assurance issuing
one deficiency and three observations.
Based upon inspection of the checklist used to perform the
engineering assurance evaluation, the NRC inspector deems
that an adequate review of those TDRs has been performed.
In October 1987, Procedure CP-SAP-16, " Deficiency and
Nonconformance Reporting," was revised to require that
Design Change Authorizations.(DCAs) be used to request
engineering assistance for TDR dispositions. This
requirement was included in the startup procedure to
assure proper involvement of engineering in TDR
dispositions. Since those TDRs with engineering !
dispositions have been evaluated and the revision to
CP-SAP-16 provides preventive action for this problem,
this open item'is closed. ;
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Although not included as part of this open item, an i
evaluation of those TDRs that did not receive an l
engineering disposition was also performed by the
applicant. That evaluation was performed as part of the
resolution of SDAR-CP-87-109. NRC inspection of the .;'
applicant's actions for SDAR-CP-87-109 appears in
paragraph 4. of this report.
b. (Closed) open Item (445/8810-0-10; 446/8808-0-10): This
item was opened for NRC review of a TU Electric procedure
that would provide the controls to assure that the prior
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education and experience of TU Electric employees
performing work at CPSES would be confirmed. This open
item was identified during an NRC inspection of
engineering qualifications relative to the corrective
' Action Program. The results of that. inspection determined
that.TU Electric had been performing appropriate actions
to confirm the prior education and experience.of
TU Electric engineers. 'Those actions, however, had not
been placed under procedural control. Since the NRC
inspector was informed at that time that a procedure to
control this activity was pending, the inspector issued an
open item to review the procedure when issued.
Personnel Procedure PERS-02, " Confirmation of Education
and Experience Background for Personnel Performing Work at
or for CPSES," has been issued and is currently at
Revision 1.- The procedure provides for verification of
education and experience backgrounds of personnel hired by
TU Electric to' perform quality related work at or for
CPSES prior to the performance: of that quality related
work. The NRC inspector determined that PERS-02 meets the
intent of NRCLIE Circular 80-22, " Confirmation of Employee
Qualifications," and provides assurance that personnel
performing quality related work have appropriate education
and experience backgrounds; accordingly, this item is
closed.
-3. Follow-up on Violations / Deviations (92702)
(Closed) Violation-(445/8718-V-02): .This violation concerned:
(1) contrary to the requirements of NCR M-2320, the material
identity of certain shims installed on the Units 1 and 2 steam
generators was'not provided with the NCR, and (2) contrary to
the requirements of NCR M-2320,-certain shims and associated
bandings.were missing or improperly installed on the Unit 2
The applicant provided the following information relative to
the shims installed on the Unit 1 steam generators: (1) all
shims installed under NCR'M-2320 on the Unit 1 steam generators
were 'less than 1/8 inch in thickness; (2) as regards supports, ;
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the site is committed to the 1974 edition, winter addendum of
the ASME Boiler and Pressure Vessel Code which does not address '
the issue of material identity of shims; (3) the 1980 edition
aof the ASME Boiler and Pressure Vessel Code,Section III,
Division I does address the use of shim material in component
L supports except that material identity of shim material less
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than 1/4 inch is not required providing certain requirements of
paragraph NF-2121 are met; (4) the shim material used to
implement the disposition of NCR M-2320 for Unit 1 steam
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generators meets the requirement of' paragraph NF-2121 and
therefore,-material identity of the shim material is not a Code
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requirement; and (5) reinspectic of the applicable bolting on
the Unit 1 steam generator supp-ses verified that the gap
between the bolts and the lower support ring were within design
criteria.
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The NRC inspector reviewed the above data including the
applicable sections of the ASME Code and the NCRs that document
the_ reinspection of the bolting. The NRC inspector agrees with
the applicant's conclusion that material identity for the
Unit I steam generators is not required and that based on the
inspection of the bolting installed on the lower support rings,
the gaps meet design requirements; accordingly, this violation
is closed for Unit 1 only.
Corrective actions for the Unit 2 steam generators have not, as
yet, been performed by the applciant. NRC inspection of the
corrective actions for the Unit 2 steam generators will be
performed and reported when those actions are completed.
4. Action on 10 CFR Part 50.55(e) Deficiencies Identified by the
Applicant (92700)
(Closed) SDAR CP-87-109, " Inappropriate Deficiency
Documentation": This item, determined by the applicant to be
reportable, involved numerous types of documentation that may
have been used to: (1) improperly identify deficient
conditions, (2) inappropriately change the design, or
(3) incorporate design changes without a proper design review
being performed. Examples of such documents were the Request i
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for Information/ Clarification (RFIC), Item Substitution Request
(ISR), and Alternate Hanger Detail (AHD).
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Initially, a review of all known historical type documents for
which engineering was involved was conducted by comanche Peak
Engineering (CPE). CPE performed this review utilizing office
memorandum NE-14126, " Guidance to be Used for Review of
Requests for Engineering Services." As a result of this
review, 15 document types were identified. Corrective Action
Request (CAR) 87-73 was then initiated to provide a 100% review
of those 15 document types having engineering involvement.
During implementation of CAR 87-73, additional document types
were identified and reviewed. Discrepant conditions identified
by these reviews were addressed on NCRs, DRs, or DCAs as
appropriate.
The NRC inspector has revicwed NE-14126, CAR 87-73, and other
associated documentation. Based on those re 'iews, it appears
that the applicant has performed an appropriately detailed
review of those document types determined to have been used
improperly and has taken appropriate corrective actions for
identified deficiencies. Preventive actions for each type of
documentation determined to have been misused is d.etailed in
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CAR 87-73. The NRC inspector has reviewed the preventive ;
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actions and concurs that most of the. discrepant document types
were historical and that current procedures should prevent
similar discrepancies from occurring; accordingly, this SDAR is l
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closed.
5. Preoperational Testing Audits and Surveillance (35301)
This NRC inspection was performed to ascertain: (1) that the I
applicant has developed an audit and surveillance program for I
assuring that preoperational test activities are consistent
with the CPSES FSAR and regulatory requirements, and (2) that
the applicant's audit and surveillance program for i
.preoperational test activities is satisfactorily implemented. {
The NRC inspector reviewed the applicant's procedural controls
for the performance of audits and surveillance. These
controls were found to be contained in Procedures NQA 3.07,
" Quality Assurance Audit Program," and NQA 3.23, " Surveillance
Program." Each of these procedures provided appropriate
controls to establish audits and surveillance of
preoperational test activities. A review of the audit and
surveillance schedules indicated that audits and surveillance
of preoperational testing activities were scheduled and
performed within required frequencies. ,
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To assess the implementation of the audits and surveillance,
the NRC inspector reviewed two audits and three surveillance.
Audits reviewed by the NRC inspector were TUG-88-23 on
operations testing and EFE-89-01 concerning design data
utilization during preopero ional testing. Both of these
audits were determined to .e 4: sed on appropriate design and
procedural requirements. Furtaer, the checklists and evidence
observed supported the conclusions drawn by the auditors. The !
NRC inspector found the audit portion of the QA program to be
satisfactorily implemented.
The NRC inspector reviewed preoperational test surveillance:
(1)'0S-89-0041 performed for Preoperational Test
1CP-PT-44-01 SFT, " Steam Generator Blowdown Valve Functional
checks," (2) OS-89-0057 performed for Preoperational Test
1CP-PT-37-01 SFT, " Auxiliary Feedwater System," and
u (3) 0S-89-0033 performed for Preoperational Test
1CP-PT-64-02 SFT, " Reactor Protection System Operational
t Checks." These three surveillance were determined to be
{ adequately prepared, with appropriate preoperational test
witness or hold points assigned. Further, the narrative
discussion provided by the QA test log indicated that the
surveillance personnel were alert and cognizant of test
objectives. Typically, the issued surveillance report properly
documented the test results and identified any noted
surveillance deficiencies. Surveillance Report 05-89-0041,
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however, noted that certain steps of Test Procedure f
ICP-PT-44-02 SFT could not be performed as written. For I
example, step 7.9.13 of the test procedure required a position
change of valve 1HV-2397A by " momentarily" placing the q
controlling handswitch 1HS-2397A to "open." When this step i
could not be completed as written, the STE apparently !
instructed the reactor operator to hold the handswitch as 1'
"open" until the valve changed to the desired position. The
surveillance report stated that "The abnormality will be
included in the test report," indicating that the STE would )
include the occurrence in the summary of the preoperational
test report. Since the STE did not properly document the
unsatisfactory condition, the surveillance technician should .
have documented the condition as a surveillance deficiency in l
accordance with'Section 6.4 of NQA 3.23. The NRC inspector
considers this item to be a violation (445/8932-V-01).
In summary, the NRC inspector determined that an adequate audit
and surveillance program exists to assure that preoperational
testing activities are performed in accordance with regulatory
requirements. Further, with the exception of the above
violation, the QA program appears to be satisfactorily
implemented.
6. Quality Verification Function (35702)
The purpose of this inspection was to assess the effectiveness
of the applicant's quality verification organizations in
identifying technical issues and problems having safety
significance and in following up to ensure that issues and
problems are resolved in a timely manner.
CPSES has numerous organizations that verify quality. These
include but are not limited to Quality Assurance, Quality
Control, Engineering Assurance, Station Operations Review
Committee (SORC), the offsite Operations Review Committee
(ORC), and Plant Evaluation. The activities of most of these
groups have been evaluated, directly or indirectly, in numerous
NRC inspection reports. One group, however, has not been
inspected to the same degree as the others. Furthermore, this
group, Plant Eva2uation, plays a unique role in the quality
verification process. The Plant Evaluation group is designed
to monitor and assess plant operations and maintenance
activities, review and assess nuclear industry operating
experience, identify emerging regulatory issues, and develop
and critique site-specific emergency exercises. The purpose of
the group is to. identify precursors to potential problems and
to advise the Vice President, Nuclear Operations of areas that
need improvement.
The Plant Evaluation group is divided into numerous sections
that cover the following programs (areas):
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.~ Trip reduction program. '
. Emergency exercise scenario development, and exercise i
control and evaluation.
. Industry operating experience review program.
. . Human performance evaluation.
. Reporting of operations performance indicators.
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. Tracking of NRC open items for Nuclear Operations. l
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. Nuclear Network. l
Personnel working in these programs (areas) are trained in root a
cause and event analysis techniques and are sensitive to i
recognizing related operating experiences and emerging trends. )
By conducting in-depth special' studies and evaluations, the- I
. Plant: Evaluation group can make specific recommendations
directly to the Vice President, Nuclear Operations. Then, the
vice president can direct various department managers to
' implement action plans to prevent incidents and events. The
Plant Evaluation group follows-up on these action plans and
tracks them to completion. The Manager, Plant. Evaluation,
reports directly to the Vice President, Nuclear Operations.
'This ensures that Plant Evaluation group recommendations
receive more than a cursory review by the applicable department
manager. Furthermore, this reporting arrangement ensures that
the Manager, Plant Evaluation, is seldom placed in the position
of directly criticizing his supervisor.
L Inputs to the evaluation process come from many sources not
directly related to any single quality verification ,
organization. Examples of these inputs include:
. Industry operating experience reports - These include
USNRC Notices and Bulletins, INPO Significant Event
Reports (SERs) and Significant Operating Event Reports
(SOE2s), and various vendor technical' bulletins.
. In-house operating experience - This is gathered j
extensively from Plant Incident Reports and Licensee Event j
Reports. I
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-. Regulatory issues 'These include generic letters, USNRC ]'
Office for Analysis and Evaluation of Operational Data
(AEOD) reports, and reports from industry groups such as
EPRI and Nuclear Safety Analysis Center.
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. Nuclear Network - This is basically an information )
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exchange system that CPSES can sccess to learn of industry
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events.- Essentially,'the network serves as a means for
L nuclear utilities to communicate with one another
concerningl areas of-industry interest.
. Monitoring ^of plant activities - This is accomplished by
, direct observation of plant activities by performance
assessment specialists.. These individuals have specific.
experience in the areas of' electrical and mechanical
maintenance,. instrumentation and-control, chemistry, f
radiation protection, and operations. j
Once these inputs are received, they are analyzed from a plant
performance perspective; i.e., are.they indicative of'past,
present, .or future plant problems? LIf so, then recommendations
to correct or avert problems can be formulated.
The performance analysis activities take many, forms:
. The Independent Safety.' Evaluation Group'(ISEG) can conduct
a' nuclear safety issue review. From this,.the ISEG can-
make specific recommendations. ISEG activities and the
status of ISEG' recommendations are addressed in a monthly
activity status report.
.- The Human Performance Review group can conduct a human
performance evaluation. This entails performing a i
root-cause analysis using INPO guidelines. .'From the
evaluation,-specific recommendations are made. The
results of the evaluation together with the-
recommendations'are fed back to the INPO data base as well
as directly to CPSES.
. Industry' Operating-Experience Reviews (IOERs)'can be
conducted. From these reviews, " lessons learned" can be
extracted and specific recommendations can be'made to
address the given issues. 'Mcreover, feedback from the
reviews is made available to CPSES personnel by means of a
monthly report and a " video magazine." Review results are
also put into the Industry Operational Experience Report
data base. ,
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. Data is collected on NRC, INPO, and CPSES performance l
indicators. This. data is reported monthly in the Nuclear l
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Operations Monthly Report on performance indicators.
. Plant Trip Reduction reviews are conducted as a part of
the effort to improve plant reliability. Performing
single-point failure analyses is one aspect of these ;
reviews. i
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B . All NRC open items that are assigned to nuclear operations
are tracked and statused on a regular basis. This ensures ]
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that the items are reviewed in a timely manner to
determine their readiness for presentation to the NRC for
closure. j
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The NRC inspector performed a detailed analysis of selected #
issues. In doing so, his aim was to understand the issues, to
determine why the issues did or did not lead to plant problems, !
and to determine what roles the Plant Evaluation group and i
CPSES upper management. played in addressing the issues. The j
issues are discussed in detail in the following paragraphs. l
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a. Failure of protective coatings in pipes and heat
exchangers: This issue is an example of a situation in ;
which the applicant failed to relate the significance of a
particular industry event to CPSES. This issue arose from
an INPO SER (68-83). This SER identified a pipe-coating .
failure at the Palo Verde Nuclear Station. The applicant ]
received the SER, performed an IOER review, and resolved '
the issue as not being a problem at CPSES. The
justification for this stemmed from an architect-engineer
opinion for which no sound technical basis was provided.
Moreover, the applicant missed another opportunity to
appreciate the significance of the issue. This
opportunity occurred during the applicant's review of NRC
Information Notice 85-24, " Failure of Protective Coatings
in Pipes and Heat Exchangers." Essentially, the applicant
relied merely on the earlier resolution of the initiating
report, SER 68-83.
The NRC, in inspection report 50-445/88-34; 50-446/88-30,
documented these shortcomings in the Plant Evaluation
group's evaluation process.as an open item (445/8834-0-02;
446/8830-0-02). The applicant resolved the open item by
raising the Plant Evaluation group's standards to demand
technical bases instead of accepting opinions.
Furthermore, the applicant rereviewed more than 750 NRC
Information Notices to ensure.that they were addressed to
the new standards. Based on a review of these two
actions, the open item was closed in NRC Inspection Report
50-445/88-47; 50-446/88-42.
b. Loss of decay heat removal problems: This is an example
of 9 situations in which the applicant identified
potential operational problems involving decay heat l
removal before the decay heat removal issue required ]
regulatory response. The applicant initially became l
concerned when a series of five SERs involving operation !
at reduced reactor vessel level was received between 1981 l
and 1984. Simultaneously, two SERs were received in 1981 l
and 1984 that detailed events involving RHR pump damage j
due to inadvertent closures of RHR pump suction valves. I
These seven SERs became a major part of the input for an
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INPO study (SOER 85-4) on the loss of RHR capability in
pressurized water reactors. Based on this study, the
applicant decided to review operations, maintenance, and
surveillance procedures for RHR conditions related to
mid-loop operations. Furthermore, the applicant added an
alarm to indicate RHR suction valve closure.
Meanwhile, in 1984 CPSES experienced two events involving
the RHR system: "RHR Pump Damage Due to Suction Valve
Closed," Problem Report (PR)84-495; and " Failed - Open
RER Relief Valve During the 1984 HFT Program," PR 84-428.
These two in-house events spurred the applicant to perform
an ISEG review (85-96) that dealt with overpressure
protection during RHR operation. From this review, five
recommendations were issued and implemented.
Later, in 1986, numerous SERs'were received that detailed
more events dealing with operation at reduced reactor
vessel level. These were documented by the NRC in
Inspection and Enforcement Notice (IEN)86-100, " Summary
of Loss of RHR Events Due to Loss of Fluid Level in
Reactor Coolant Systems." Shortly thereafter, NUREG 1269,
"Diablo Canyon Loss of RHR Event, April 1987," was issued
by the NRC. This NUREG identified the possibility of
sudden core uncovery during mid-loop operation. The
applicant used the input from this NUREG and from
IEN 86-101 in conducting ISEG review 87-01. This ISEG
review studied the applicant's control of reactor vessel
level during shutdown. From it came fifteen
recommendations. These recommendations addressed
training, procedures, level indication, temperature i
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indication, and RHR system performance monitoring.
Therefore, when the NRC issued Generic Letter (GL) 87-12,
which requested information from licensees on mid-loop
operation practices, the applicant was ready with a
response. Shortly after the GL was issued, the NRC issued
another IEN (88-36). It notified licensees of the
possibility for sudden loss of RCS inventory during low
coolant level operations. By the time GL 88-17 was
issued, which set forth NRC requirements for actions on
loss of decay heat removal, the applicant had already
determined that improved level instrumentation and a
correlation of vessel level with loss of pump suction were
needed. Following the 1989 HFT program, the applicant
completed an RHR vortexing test to correlate the vessel
level with pump suction indications. The timeliness with
which the applicant performed the vortexing test can be
attributed to the applicant's prompt reaction to the
RHR-related events.
c. Instrument air system problems: This issue is an example
of a situation in which the applicant successfully
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resolved a significant issue. This issue arose from
numerous prs that documented a variety of instrument air
system problems, numerous industry events (including the
TMI accident), and two previously conducted ISEG reviews
(one dealing with loss of cooling from the refueling
cavity and the other dealing with the loss of feedwater).
Based on these inputs, an ISEG review, " Instrument Air
System Reliability Review" 86-01 was initiated. This
review quantitatively identified the contributors to the
unreliability of the instrument air system. The review
concluded that the surveillance, testing, and maintenance
activities on the instrument air system had not been
sufficient to maintain reliable system operation. The [
review also concluded that the expertise and coordination
necessary to ensure reliability had not been effectively
applied to the system. Finally, the review recommended
specific corrective actions:
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.. Assigning overall responsibility' and accountability
for instrument air system reliability to a single
! individual or group.
. Repairing / calibrating specific components.
. Installing additional air receiver capacity in the
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plant.
. Modifying specific portions of the system.
. Making numerous program and practice changes.
These recommendations were sent to the Vice President,
Nuclear Operations. After consulting with all affected
managers, the vice president ensured that each
recommendation was resolved. In all cases, each
recommendation was specifically implemented or an
acceptable alternate course of action was taken.
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The manner in which this issue was resolved has resulted
in a significantly more reliable instrument air system.
This is evident from the greatly reduced number of plant
incident reports dealing with the system and from the fact
( that the 1989 HFT program was completed without the system ,
delaying testing. It is significant that the Manager, i
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Plant Evaluation, attributes the improved system
reliability mainly to the establishment of the system
engineer as the central point of responsibility for system
reliability.
By interviewing the Manager, Plant Evaluation, and by l
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reviewing plant records, the NRC inspector has concluded
that the quality verification process has greatly improved
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over the.last several' years. The Manager, Plant
Evaluation, attributes this mainly to a greater management i
awareness of the quality verification process. Basically,. 4
this greater awareness has resulted in a major change in
philosophy in how plant management deals with
recommendations. No longer are recommendations issued- '
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directly to individual line managers; instead, they are
issued directly to the Vice President, Nuclear Operations.
Also, over the last several years, the individual line
managers have increasingly recognized and supported the
role of the Plant Evaluation group. This has resulted in
a more rapid resolution and implementation of
recommendations made by the Plant Evaluation group.
It is significant that'as the nuclear industry's view of the
role of independent evaluation groups has matured,.the
applicant has made changes to the Plant Evaluation program to
maintain its effectiveness.- One exarple of a change to the
Plant Evaluation group was the removal of the ISEG from direct
control of the Plant Evaluation group.- The ISEG now reports to
the Director of Technical Interface. This individual, in turn,
reports to the Vice President, Nuclear Engineering. This
change should further strengthen the independent overview
capability of the ISEG.
In summary, the NRC' inspector has concluded that the
applicant's quality verification process at the Plant
Evaluation level has improved significantly over the last
several years. Again, this conclusion was reached without a J
reexamination of the other " quality" groups. Those groups have
been the subject of previous NRC inspection reports.
No violations or deviations were identified in this area of the
inspection.
'7. Audit Program for Operations (35741)
The purpose of this NRC inspection was to ascertain whether the
applicant has developed and begun the implementation of a
program for auditing operations activities that is in
conformance with regulatory requirements. This objective was
accomplished by the review of site procedures for controlling
audits related to these activities, audit schedules,
qualifications of audit personnel, and a detailed review of two
recently completed audits.
The NRC inspector reviewed Section 17.2.18 of the CPSES FSAR
and Section 6 of the CPSES proposed technical specifications.
The FSAR p:tovided commitments consistent with the applicable
portions cf Regulatory Guide 1.33 and ANSI N45.2.12. The CPSES
technical specifications, while still under NRC review,
appeared to provide appropriate commitments for the audit of
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operation's activities. The audit program is further
delineated'in Section 18.0 of the TU Electric Quality Assurance
Manual (QAM) and lower tier procedures.
For this inspection, the NRC inspector reviewed the following
documents: (1) the TU Electric QAM; (2) Procedure NEO 3.07,
" Management Response to Audit Deficiencies"; (3) Procedure
NQA 3.07, " Quality Assurance Audit Program," and (4) Procedure
NQA 1.16, " Indoctrination, Training and Certification of
Auditors and Lead Auditors." These procedures were determined
to provide appropriate requirements and methods for a
comprehensive audit program. This audit program was required
to be performed by trained and qualified auditors and lead
auditors who were sufficiently independent of the activity j
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being audited. Further, these procedures provided that the
audits be performed utilizing prepared checklists and that
written reports of audit results be issued to the management of
the audited organizations. Deficiencies identified during the
performance of audits were required to be communicated to
management at post audit meetings and documented as audit
deficiencies in the audit report.
Written response from the audited organization is procedurally
required unless the audit deficiency was determined to have
been adequately addressed during the audit. The NRC inspector
determined that the above requirements, and the designation of
personnel responsible for the performance of the above
requirements, were adequately delineated in the procedures.
To verify proper implementation of the above requirements, the
NRC inspector reviewed: the audit schedule for 1989,
documentation relative to two recently completed audits, and
evidence of the lead auditor's qualifications for each of the
two audits.
Review of the 1989 audit schedule showed that an annual audit
schedule was issued that included audits of all areas required
by the QA program. Further, the audit schedule is updated
quarterly to assess the need for additional or supplemental
audits. Review of the audit schedule also indicated that
audits were completed in accordance with the schedule, or as in
the case of three TAP audits, were rescheduled due to
insufficient progress in the area to be audited.
Procedure NQA 3.07, " Quality Assurance Audit Program,"
Revision 1, provides for the auditing of those areas
specifically required by Section 6 of the proposed CPSES
Technical Specifications. The NRC inspector considers this
provision to be adequate; howcVer, discussion with audit '
personnel indicates that the applicant is considering a more
comprehensive program for the assurance of conformance to the
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technical specifications.- If implemented, such a change should
enhance the current program.
The two audits selected for review by the NRC inspector were
audit TUG-88-22 on nonconformance and deficiency reports, and
audit TUG-88-23 on test control and operations testing. The
NRC inspector determined from review of applicable
documentation that: (1) each of the audits had been performed
by lead auditors and auditors qualified to the requirements of
ANSI N45.2.23 (1978),-(2) audit checklists were sufficiently
detailed and addressed compliance with applicable regulatory
requirements as well as procedural compliance, and (3) audit
TUG-88-22 was completed and issued in a timely manner. ,
Correspondence and closeout of the one audit deficiency for !
TUG-88-22 was also timely.
During the NRC inspector's review of the above audits, two
deficient conditions were noted. Contrary to the requirements
of NQA 3.07: (1) signed receipt acknowledgement forms were not
being obtained from all audited organizations. and (2) the
audit report for TUG-88-23 was not issued wit: :n 30 days of the
post audit meeting.
The NRC inspector discussed the failure to obtain signed
receipt acknowledgement forms with the QA audit supervisor.
The supervisor provided the following information: (1) as shown
by'the distribution list, copies of the audit report were sent
to each audited organization; (2) signed receipt
acknowledgement forms were obtained from those organizations
with deficient conditions; and (3) an office memorandum had
been issued by the audit department to address this issue. The
NRC inspector reviewed the' distribution list and'the office
memorandum and agreed that the issue appeared to be adequately
addressed.
Regarding the failure to issue the audit report for TUG-88-23
in a timely manner, the NRC inspector determined the following:
(1) the lead auditor is normally responsible for preparation of
the audit report, (2) the lead auditor for TUG-88-23 had been
transferred from the audit department prior to the audit report
- being issued, (3) Deficiency Report (DR) C-89-0049, issued in
j February 1989, noted that issuance of audit report TUG-88-23
j and 11 other audit reports were delinquent, and (4) that audit
report TUG-88-23 was ismaed May 2, 1989. The NRC inspector j
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reviewed the corrective actions and actions to prevent
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recurrence specified by DR C-89-0049. Those actions included
providing more time between audits for preparation of reports
,
and issuing a memorandum to the audit staff reemphasizing the
l need to comply with the time requirements of NQA 3.07. The NRC
inspector deems those actions to have been appropriate;
however, the NRC inspector believes a significant weakness in
the audit program may still exist in that the audit report for
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TUG-88-23 was still not issued for over two months after being
identified as delinquent in DR C-89-0049.
In summary, with the exception of the untimely issuance of j
audit report TUG-88-23, it appeared that the applicant had 4
established and implemented an adequate audit program.
No violations or deviations were noted during this inspection.
8. Document Control for Operations (35742)
During this inspection period, the NRC inspector performed a
review of the CPSES QA program to ascertain whether
administrative controls for the control, issuance, and
maintenance of required documents had been established and that
those controls were being implemented.
As reported in NRC Inspection Report 50-445/88-27;
50-446/88-23, the NRC had inspected in detail the CPSES program
for the control of manuals and procedures. Also, the applicant
is currently reviewing the maintenance and control of
procedures and manuals under CAR 89-02. Therefore, the NRC
inspector focused this inspection on the program for control,
issua.;ce, and maintenance of those drawings routinely used by
plant operations organizations.
The NRC inspector reviewed such documents as the CPSES FSAR,
the proposed technical specifications, and the TU Electric QA
manual to verify.that the applicant had provided for the
establishment of a document control program that was in
conformance with regulatory requirements. The NRC inspector
determined that the applicant had provided for the
establishment of a document control program that was in
conformance with the requirements of Appendix B of 10 CFR
Part 50, Regulatory Guide 1.33, and industry standard ANSI
N18.7 (1976). These documents require that measures be
established to control the approval, issuance, distribution,
and, as necessary, revision of documents affecting quality.
Further, these docuTrnts require that such documents be
available and used at the location where prescribed activities
are. performed. The details of the applicant's document control
program for the operations phase are currently contained in
STA-306, "liuclear Operations Document Control," PC 2.13-02,
" Distribution Control," and NEO 5.15, " Control of Vital Station
Drawings." Other procedures such as ECE 2.13-01, " Document
Control Instructions," and ECE 2.13-02, " Processing of Field
Det.ign Changes," provide requirements and methods by which
engineering provides approved drawing revisions or design '
changes to the document control group for distribution.
The NRC inspector reviewed these procedures and determined that
they provided adequate delineation of the responsibilities and
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the methods by which approved drawing' revisions and design i
changes are:'(1) entered into the CPSES document control data l
base;-(2). issued, as needed, to work groups and updated when i
design changes or revisions affect the issued document; and
(3) distributed and maintained at locations such as the !
i . operations control room and'the maintenance department. To
assess'that the~ documents maintained at these locations were
l ' current, the NRC inspector' reviewed four aperture cards and 1
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26. drawings. These drawings and aperture cards had been issued
to eight different control locations.- Four of these controlled
locations-were located-in maintenance and four were in the
- control room, lDf the 30 documents inspected, the NRC inspector
found one aperture card and six drawings that were not at the
current revision. .This: condition was discussed with personnel
from.the operations' document control. center (Operations DCC)
and the'following information was provided. In accordance with
STA-306, the operations'DCC11s responsible to maintain all
drawings and design changes in a timely manner. Vital station
. drawings, those drawings determined by Nuclear Operations as
.
being vital to safe plant operation are required to be
maintained.within two days of' receipt of drawing. revisions or
design: changes. Further, prior to3using the controlled
drawings issued to' the maintenance (n: control room groups, the
user is required to verify the status of the drawing by
accessing the Field Design" Change and-Review Status Log
(FDCRSL) data base. 'This.last requirement-is included in
STA-306 to~ assure that the user will be informed of the most
current status of the drawing and if'there are any outstanding
DCAs against the drawing. The NRC inspector then reviewed the
six drawings and the one aperture card against the recorded
date when Operations DCC had received the documents, all had
.been distributed within the two day' time requirement of
STA-306. .A weakness was noted in this area.- Of the seven
documents identified above, all were released or issued by
engineering at least seven days before being received by
Operations DCC for distribution.
The applicant has established a document control program for
Operations that meets regulatory requirements and the
-implementation of the program appears satisfactory. On this
basis, . the NRC inspector determined: that the applicant's
document control program for Operations was satisfactory for
the area of drawing and design change control.
No violations or deviations were identified during this
inspection.
9. Maintenance Program for Operation (35743) l
This portion of the inspection involved a maintenance program
review to ascertain whether the applicant has developed and
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implemented a quality assurance program that is in conformance
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with proposed technical. specifications, regulatory
requirements, industry standards, and written commitments.
During the inspection, the NRC inspector reviewed the following i
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procedures and maintenance work packages:
. Procedure STA-623, Revision 3, " Post Work Testing," dated
September 15, 1988.
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. Procedure STA-731, Revision 0, "ASME Section XI, Repair
and Replacement Activities," dated September 7, 1988.
. Procedure STA-711, Revision 2, "ASME Section XI, Pump and
Valve Inservice Testing," dated April 6, 1988.
.- Procedure STA-605, Revision 6, " Clearance and Safety
Tagging," dated June 22, 1988.
. Procedure STA-606, Revision 9, " Work Requests and Work
E Orders," dated November 21, 1988.
. Procedure CP-SAP-6, Revision 15, " Control of Work on
Station Components After Release From Construction to
Startup," dated November 20, 1988.
. Operations Department Administrative Manual ODA-308,
Revision 0, "LCO Tracking Log," dated September 27, 1988.
. Electrical Maintenance Manual EMP-210, Revision 0, $
" Troubleshooting Guidelines," dated December 31, 1987.
. Surveillance Test Procedure INC-7757A, Revision 4, " Analog
Channel Operational Test and Channel Calibration - Reactor
Coolant System Wide Range Temperature, Cold
Overpressurization System and Wide Range Pressure
Channels 413B, 423B, 433A, 443A, and 403," dated August 3,
1988.
. Mechanical Maintenance Procedure MSM-CO-6843, Revision 0,
"Limitorque SMB-000 w/HBC Maintenance," dated January 30,
1989, with Work Order C880001416, dated March 23, 1988.
. Mechanical Maintenance Procedure MMI-811, Revision 0,
" Fisher Globe Control Valve Rework," dated February 4,
1985, with Work Order C890000546, dated January 25, 1989.
Review of the above procedures and work packages by the NRC
inspector verified that procedures for initiating requests for
routine and emergency maintenance have been established.
Criteria for review and approval of maintenance requests, the
basis for designating the work as safety /nonsafety related, and
requirements for inspection activities have been established.
Furthermore, provisions for designating quality control
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I inspection hold points have been proceduralized along with the
methods and responsibilities for postmaintenance functional
testing. In addition, administrative controls for maintenance
activities requiring maintenance records to be prepared,
assembled,.and reviewed prior to transferring to storage have
been established. Procedures and responsibilities for review
of completed maintenance work packages have been assigned along
with responsibilities for the identification of deficiencies,
trending, and problem analysis. Controls for equipment release
during maintenance activities have been implemented such that
technical specifications are reviewed and sole responsibility
for release control resides with the shift supervisor.
Provisions and procedures for tagging equipment and independent
verification inspections have been established and implemented.
Furthermore, the applicant has provided detailed instructions
, for the control of special processes, cleanliness, and
housekeeping. j
During the above review, the NRC inspector noted that the
applicant's procedural requirements for ASME Section XI repair
and replacement activities require the completion of ASME
Section XI Form.NIS-2 subsequent to work accomplishment. The
applicant's procedures for preparing the periodic ASME
Section XI summary report require identifying the quality
control inspector that witnessed the specific
repair / replacement activities; however, the NIS-2 form does not
presently require identifying the QC inspector. Revising the
NIS-2 form to include the QC inspector would simplify the
summary report preparation process. This observation was
presented to the applicant for consideration.
In addition, the NRC inspector reviewed procedures related to
post work testing and a recent audit TUG-88-23. The NRC
inspector concluded that the applicant's present measures for
post work test report (PTR) tracking may not fully and
adequately address the complete dispositions of PTRs. As noted
in audit TUG-88-23, the applicant identified a number of
specific PTRs for which documentary evidence could not be
substantiated. The resolution of these PTRs and measures for
adequate and effective tracking of PTRs shall remain an open
item (445/8932-0-02).
10. Surveillance' Testing and Calibration Control Program for
Operation (35745)-
The purpose.of this inspection was to determine whether the
applicant has developed programs for the control and evaluation
of:
(
. surveillance activities (testing, calibration, and !
inspection) required by Section 4.0 of the CPSES Technical
Specifications.
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. Calibration of safety-related instrumentation not
specifically controlled by Technical Specifications.
. Inservice inspection of pumps and valves as described in
During this inspection, the NRC inspector determined that the
applicant uses a computer program (data base), the Managed
Maintenance Computer Program (MMCP), to store, track, retrieve,
and update data related to surveillance testing, calibrations,
and in-service inspections. Using this program, the applicant
generates numerous status reports and schedules for these
activities,
a. Inspection of the surveillance test program: For
surveillance test program purposes, in addition to the
various reports and schedules generated by the MMCP, the
applicant uses a controlled document, the Master
Surveillance Test List (MSTL), as a line-by-line listing
of each of the Technical Specifications, Section 4.0,
surveillance requirements. For each listing, the required
frequency, applicable procedures, and applicable plant
modes are stated.
For tracking, scheduling, and statusing the surveillance
requirements, three different reports are generated from
the MMCP. These reports are described below.
. Surveillance. Activity Verification Report. This
report lists, by procedure number, the surveillance
requirement, the required frequency, the
applicability (Plant mode), and the responsible plant
group.
. Surveillance Activity Monitoring Report. This report
serves as a "look-ahead" schedule for those
surveillance activities that are scheduled for the
next six weeks. This schedule lists a due date, the
date the activity is to be performed, and the
extended date due (considering the time tolerance
permitted).
. Surveillance Activity Applicability Report. This
report is used to ensure that prior to changing plant
modes, all required surveillance activities have been
completed.
The inspector reviewed the three reports described above
and the procedure that establishes the requirements for
the surveillance test program, STA-702, " Surveillance Test
Program," Revision 7. In the review, the inspector
i concluded that the applicant has:
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. Established a master schedule (via the MMCP data
base / reports) for tracking surveillance activities.
This schedule addresses required frequencies, plant
group responsibilities, and surveillance activity
status. This schedule, comprised of the three
reports described above, is described in STA-702 and
STA-677, " Preventive Maintenance Program."
!
. Assigned in writing the responsibilities for
maintaining the master surveillance test schedule
up-to-date. STA-702 states that the Surveillance
Test Coordinator is responsible for the day-to-day
coordination and oversight of the Surveillance Test
Program and ensuring compliance with the applicable
requirements. STA-702 states, furtier, that the
individual Nuclear Operations managers are
responsible for schedule development, implementation,
and review / approval of surveillance test results.
. Established formal requirements for conducting
surveillance' tests, calibrations, and inspections in
accordance.with approved procedures. STA-702
requires each assigned department to develop
procedures required by the MSTL to meet the
requirements of the assigned surveillance.
Furthermore, STA-702 states'that each surveillance
activity shall be accomplished in accordance with the
applicable procedure.
. Defined formal methods and responsibilities for
reviewing and evaluating surveillance test data.
Sections 6.5 and 6.7 of STA-702 address the
review / approval of surveillance activity results as
well as the failure to meet acceptance criteria or
the failure to perform surveillance activities.
. Assigned responsibility for assuring that required
schedules for all activities are satisfied. These
responsibilities are addressed in Section 5.0 of
STA-702. Basically, the individual Nuclear
Operations managers are responsible for developing
and implementing the schedule. The surveillance Test
Coordinator is responsible for the day-to-day
coordination and oversight of the surveillance test
program and for ensuring compliance with the
applicable requirements,
b. Inspection of calibration activities for those
safety-related components not identified in Technical
Specifications: Essentially, these components are
instruments used to meet the Technical Specifications -
surveillance requirement. The applicant controls the .
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calibration of these instruments by using Procedure i
STA-677, " Preventive Maintenance Program," Revision O.
For the tracking and statusing of these calibrations, the
Instrumentation and Control (I and C) department uses a
report generated by the MMCP. This report describes the
instrumentation calibration requirements, lists the
required frequencies, describes the equipment status, and
lists the applicable procedure and responsible plant
group. For scheduling purposes, a report entitled
" Backlog Analysis Listing" is generated from the MMCP.
This report lists the instruments, by.name and tag number,
and gives a calibration due date. For statusing purposes,
the MMCP can generate a report that contains equipment
histories.
The NRC inspector reviewed Procedure STA-677 and the
various reports that the MMCP can generate. In this
review, the inspecror concluded that the applicant has:
. Established a master schedule (via the MMCP data
base / reports) for the tracking of calibrations needed
for instrumentation used to meet CPSES Technical
Specification requirements. These reports, described
previously, call out the required calibration-
frequencies,.the plant groups responsible for
performing the calibration, and the calibration
status.
. Assigned in writing the responsibility for
maintaining the master calibration schedule
up-to-date. STA-677 states that the I and C manager
is responsible for scheduling, executing, and
documenting the completion of the instrument
celebrations. STA-677 states, further, that the
Results Engineering manager is responsible for
overall preventive maintenance (including instrument
calibration activities) program management.
. Established formal requirements for performing
component calibrations in accordance with approved
procedures that include acceptance criteria.
. Assigned responsibility for assuring that required
component calibration schedules are satisfied, for
which the I and C manager is responsible.
c. Inspection of the program for performing inservice
inspection of pumps and valves required by 10 CFR
Part 50.55a(g): The applicant uses the Inservice Test
(IST) program plan as a controlled document that lists the
Class 1, 2, and 3 pumps and valves that are subject to
inservice testing. This document contains the basic
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requirements, the required frequencies, and the
requirements for relief-from-testing. In addition to this
document, the applicant uses procedure STA-711, "ASME
Section XI Pump and Valve Inservice Testing," Revision 2,
to describe the implementation of tne ASME Section XI pump
and valve IST program.
-For tracking, scheduling, and statusing, the applicant
uses reports and schedules generated by the MMCP. These
reports and schedules describe the test requirements, list
the required frequencies, list the applicable procedures
and responsible groups, and give the due dates and the
date the activity is to be performed.
The NRC inspector reviewed Procedure STA-711 and the MMCP
generated reports. In the review, the NRC inspector
determined that the applicant has:
. Established a master schedule (via the MMCP data
base / reports) that' tracks inservice test activities.
The reports, described previously, call out the
required test frequencies, the plant groups
responsible for performing, and the test status.
. Assigned in writing the responsibility for
maintaining the master inservice test schedule
up-to-date. STA-711 states that the Results
Engineering manager shall appoint a Nuclear
Operations IST program coordinator (IST coordinator)
to implement the IST program in accordance with
Procedure STA-711. Furthermore, STA-711 states that
the Results Engineering manager is responsible for
ensuring that the IST program is controlled as part
of the Surveillance Test Program. Finally, STA-711
states that the IST program coordinator is
responsible for the implementation of the IST program
and is also responsible for developing and j
coordinating the input to schedule all required ASME '
Section XI pump and valve tests.
. Established formal requirements for conducting
inservice tests in accordance with approved
procedures that include acceptance criteria. As
described in paragraph 10.a, above, STA-702,
" Surveillance Test Program," Revision 7, requires
that each assigned department develops the procedures ,
'
required by the MSTL to meet the requirements of the
assigned surveillance. STA-702 also states that each
surveillance activity shall be accomplished in
accordance with the applicable procedures.
Therefore, because the IST program is controlled as a
portion of the surveillance test program (STP), the
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applicant'has adequately established formal
. requirements for conducting IST activities as well as
surveillance activities in accordance with approved.
procedures.that include acceptance criteria.
L . Assigned responsibility for assuring that required
schedules for all inservice activities are met.
'Again, because the IST program is controlled as a
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portion of the STP, the individual Nuclear Operations
t managers are responsible for.IST schedule
implementation. The IST program coordinator is
responsible for overall implementation of the IST
program.
In summary, no violations or deviations were identified in
the areas inspected. One minor weakness was, however,
identified by.the applicant during the inspection. Catts
weakness involved the applicant's failure to adequately
Laddress the review of-technical specification-based
operator,. chemistry,.and. health physics logs in' Procedure
STA-702,1" Surveillance Test Program," Revision 7.
Basically, the applicant'had addressed only those
14
surveillance activities that involved: surveillance work
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orders. The applicant has corrected this by adding,.to
section 6.5'of STA-702, a. paragraph.that addresses the
review of operator, chemistry, and health physics logs.
Essentially, the logs will be reviewed by either
Operations engineering, or Results engineering. The.NRC
inspector is satisfied with the applicant's. resolution of
this weakness and:has no further concerns. It should be
noted that while this' inspection has dealt with the
control and evaluation of the surveillance safety-related
calibration, and inservice inspection programs,.the
implementation of these~ programs will be the subject of an
NRC inspection to occur within the first six-month period
of plant operation.
11. Records Program for Operations (35748)
<
ThiF 2nspection WaS to verify that the applicant has
estat11shed a program for the control of records generated
during preop testing, startup, and plant operation. The
Records-Management Program (RMP), which is related to both
- . construction and operation records, has been previously
inspected by the NRC (Inspection Report 50-445/88-10;
50-446/88-08, and subsequent follow-up reports). While '.his
, inspection is related more to operations, the facilities and .
. procedures are the same.
.The types of records to be accumulated and maintained are
identified in the Operations Master Records Index. The types
of records listed in this index include those that would be
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generated during, and in support of, plant operations; e.g.,
operating logs, recorder charts and computer printouts, plant
modifications and changes, test results, reportable items and
events, personnel documents, preop and startup tests, various
committee meeting minutes, and special test experiment results.
The Records Type List (RTL) described and presented in
Section 2 of the Records Management Program Manual, is divided
into nine major functional areas. .These functional areas are
further subdivided such that all classifications of records can
be uniquely identified using an alpha-numeric numbering system.
The RTL provides a description of each record type, the
organization releasing the record, the facility where the
record is stored, the medium of the stored record (film, hard
copy, etc.), the record retention time, and the requirements
for retention. Each record in the Operations Master Record
Index is cross referenced to the RTL, thus retention times are
readily known.
Procedures control the activities of.each organization that
generates records. A section in each of these controlling
procedures identifies the records that must be retained through
implementation of the procedure. Within each organization, an
individual is designated as the records turnover coordinator.
In accordance with Procedure RMP 1.3.1, " Records Turnover
Specifications and Turnover of Records," this coordinator
prepares documents generated within their organization for
transfer to RMP personnel. This process assures that the
required records are captured and provided to the records
program.
As described in a previous NRC Inspection Report 50- 4 5/88-10;
50-446/88-08, there are three records storage facilit.sr
currently onsite: Operation Record Center (ORC), Project
Records Center (PRC), and Engineering Records Center (ERC).
Previous NRC inspections found the records centers to be in
compliance with requirements and commitments. Each records
center has a designated custodian. Those records generated by,
or in support of, operations are retained in the ORC, together
with some construction and engineering records. Radiographs
and microfilm are stored in a room within the ORC that provides
a temperature and humidity controlled environment. The ORC
records custodian is responsible for the control and
maintenance of the Operations Master Records Index.
As with all records centers, the OFC restricts access to the
storage area to RMP personnel. When necessary, others are
permitted in the storage area, but only in the continuous
presence of RMP personnel.
The majority of the records are stored in open face rolling
files. The records are placed in folders in these files. An
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alpha-numeric system of filing is used throughout for ease of
retrieval. Only for justifiable reasons, and with management
approval. may records be removed from RMP control. When this
does occur, the records are inventoried prior to release, then
reinventoried and inspected when the records are returned.
Procedure RMP 1.2.4, " Destruction of Records Retention Time
Complete," describes the controls for the eventual destruction
of some records. When the required retention time for a record
has been satisfied, notice is given to all related
organizations of the intent to dispose of the record. All
organizations must approve before the record is destroyed. A
similar process is employed when such records are held by
others, a vendor for example.
The NRC inspector. selected 14 types of records for inspection.
The records selected included plant incident reports, deferred
test reports, safety review committee meeting minutes, startup
reports, deficiency reports, corrective action reports, and
special test reports. These records were properly classified,
readily retrievable, properly filed, and stored as required.
The NRC inspector found the program for accumulation and
storage of operations records to be in accordance with
requirements, technical specifications, and FSAR commitments.
No violations or deviations were identified during the
inspection of the implementation of this program.
12. Tests and Experiments for Operations (35749)
This portion of the inspection involved the review of the
applicant's quality assurance program related to testing and
experiments. During the inspection, the NRC inspector reviewed
the following procedures:
. STA-401, Revision 15, " Station Operations Review
Committee," dated March 16, 1989.
. STA-418, Revision 0, " Joint Test Group," dated February 2,
1988.
. STA-602, Revision 5, " Temporary Modifications," dated
April 3, 1989.
. NEO 3.12, Revision 1, " Safety Evaluations," dated March 1,
1989.
During the review, the NRC inspector verified that the
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applicant has established measures for the review of proposals
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for conducting plant tests and experiments involving
safety-related components, systems or structures, and
, operational conditions which differ from those described in the
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FSAR. Test and experiment proposals are reviewed, approved and
authorized by responsible plant managers and performed in
accordance with approved written procedures. Adequate controls
have been established to assure complete, comprehensive review,
and approval of test procedures and the accomplishment of
written safety evaluations pursuant to 10 CFR Part 50.59.
Furthermore,_the applicant has assigned responsibilities for
assemblage and conductance of the station operations review
committee (SORC) and for periodic summary reporting of 10 CFR 1
Part 50.59 type tests and experiments. During the above I
review, the NRC inspector noted that whereas Procedure STA-401,
defines criteria which constitute a quorum of the SORC, the .
procedure did not specifically require that the responsible j
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discipline SORC member / alternate attend the SORC review (e.g.,
the. electrical maintenance manager / alternate should be present
1 during 10 CFR Part 50.59 safety evaluation reviews involving
electrical issues). This concern was noted to the applicant as
an observation. In addition, the NRC inspector noted that the
applicant's procedures involving 10 CFR Part 50.59 safety
evaluations do not reflect the guidances set forth in the
NUMARC/NSAC 10 CFR Part 50.59 guidance document. In d.iscussion
with applicant personnel, this matter is under review and
revisions to existing procedures will be made. Review of the
revised procedures (e.g., STA-401, STA-602, NEO-312, et.al.)
for adequacy and action concerning the SORC quorum will remain
an open item (445/8932-0-03).
13. Measuring and Test Equipment Program for Operations (35750)
During this report period, the NRC inspector reviewed and
verified that the QA program developed and implemented by the
applicant relating to the control of measuring and test
equipment (M&TE) is in conformance with reg?>1atory
requirements, commitments (in the application) and industry
standards.
The NRC inspector reviewed the following TU Electric procedures
developed to ccmply with the requirements of 10 CFR Part 50,
Appendix B, Criterion XII, and described in Chapter 17 of the
FSAR:
NEO-328, " Control of Measuring and Test Equipment."
NQA-3.28, " control of Measuring and Test Equipment."
STA-608, " Control of Measuring and Test Equipment."
These procedures provide the required control of the facility's
M&TE lab both during the construction phase and subsequent
plant operation. Included in these procedures were
requirements for: identification for each item and the
calibration status; traceability to a calibration source;
as-found calibration data; identification of standards used;
identification of calibration procedures used; limitations on
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[ use; date of calibration and next required calibration date;
! and name of individual performing calibration. The NRC
inspector verified the calibration standards used and their
traceability to nationally recognized standards. In all cases
reviewed by the NRC inspector, the instrument used as a
calibration standard had an error rate several times less than
the instrument being calibrated, controlled calibration
procedures were available, and records indicated a well
established calibration schedule. TU Electric personnel are
currently assimilating Brown and Root's M&TE responsibilities
and equipment into their program. This influx of equipment is
being entered on TU Electric's computer aided tracking system
which records (through bar code identification) the
log-in/ log-out of all M&TE equipment; limitations on use; the
identification of all end user personnel; and present status
(i.e., lost, stolen, out of calibration, etc.).
The NRC inspector-reviewed 12 M&TE packages and associated
equipment'and found them to be an accurate representation of
the above requirements; however, the NRC inspector did have a
question concerning the apparent failure of TU Electric to
issue M&TE equipment to only qualified and authorized
personnel. TU Electric explained that only authorized QC
inspector personnel could sign off those items requiring M&TE
equipment usage and that this is controlled by the appropriate
QC procedures. The NRC inspector reviewed QC procedures and
concurs with-this explanation. No violations or deviations
were identified in this inspection.
14. Applicant Meetings (92700)
The NRC inspectors attended applicant meetings concerning site
activities and implementation of various site programs.
Meetings attended during this reporting period included the QA
Overview Committee meeting and an exit meeting for audit EFE
89-04.
Audit EFE 89-04 dealt with the incorporation of validated
design data into the applicant's programs for testing and
maintenance. The audit team presented the results of their
audit by first establishing the design basis documents which
contain the validated design data and second reviewing the
applicable implementing test or procedure to determine that the
design data or requirements were properly included. The audit
covered approximately 15 review sheets originally prepared by
Stone and Webster Engineering during their EFE activities. The
.NRC inspector determined that the information provided at the
exit indicated that the audit had been performed to an
appropriate depth and the audit conclusions were proper.
No violations or deviations were identified.
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115. Lopen' Items
open items are matters which have been' discussed with'the
applicant, which.will be reviewed 1further by the inspector,'and
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which involveLsome action on the part.of the.NRC or applicant
orEboth.. Two open items disclosed during the inspection are
discussed.in. paragraphs 9 and 12.
-16. Exit' Meeting (30703)
An exit meeting was. conducted June 6, 1989, with the
applicant's: representatives ~ identified in paragraph 1 of this
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- l
meeting, the NRC inspectors. summarized the scope'and findings
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of the inspection.
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