IR 05000445/1989032: Difference between revisions

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{{Adams
{{Adams
| number = ML20245E076
| number = ML20247R619
| issue date = 06/19/1989
| issue date = 07/31/1989
| title = Insp Repts 50-445/89-32 & 50-446/89-32 on 890503-0606. Violations Noted.Major Areas Inspected:Actions on Previous Insp Findings,Followup on Violations/Deviations,Action on 10CFR50.55(e) Deficiencies & Preoperational Testing Audits
| title = Ack Receipt of 890714 & 28 Responses to NRC Re Violations Noted in Repts 50-445/89-32 & 50-446/89-32
| author name = Bitter S, Hale C, Livermore H, Mckernon T
| author name = Warnick R
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee name =  
| addressee name = Cahill W
| addressee affiliation =  
| addressee affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| docket = 05000445, 05000446
| docket = 05000445, 05000446
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-445-89-32, 50-446-89-32, IEC-80-22, IEIN-85-024, IEIN-85-24, NUDOCS 8906270319
| document report number = NUDOCS 8908080068
| package number = ML20245E072
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 3
| page count = 31
}}
}}


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L 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 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 gDR ADOCK 05000445 b PNU
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     (paragraphs 2,3,4,5,7,8
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JUL. 31 1989  l
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(U '   - J. - Dale, 'EG&G :(paragraph 13);
In Reply Refer To:
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Dockets: 50-445/89-32 50-446/89-32 Mr. W. J.ECahill,.Jr.
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Reviewed by:.
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H..H..Livermore, Lead Senior Inspector Date s


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Executive Vice President TU Electric 400 North Olive, Lock Box 81 Dallas, Texas 75201
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l Inspection Summary:   l Inspection Conducted: May 3 through June 6, 1989 (Report 50-445/89-32; 50-446/89-32)
==Dear Mr. Cahill:==
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, ,
.1 Thank you for your letter of July 14, 1989, and July 28, 1989,.
records, tests and experiments, and measuring and test equipment; J and applicant meeting Results: Within the areas inspected, one violation was identifie During a startup test, a procedural step was not performed and the j startup test engineer did not initiate a deficiency report or ;
  .in response to our letter dated June 19, 1989.- We have reviewed your replies and. find them responsive to the concerns raised lintour Notice of Violation. We will review the implementation of your-corrective and preventive actions during a future inspection ~to-determine if full compliance has been achieved and will.be I
procedure change. This error was noted by surveillance personnel ;
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but no deficiency was issued (paragraph 5).  )
maintained.     )!
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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) .
Sincerely, I    ' ORIGINAL SICNED BY R. F. WATJECK -
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R. F.lWarnick,' Assistant: Director ]
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for Inspection Programs Comanche Peak Project Division'
Office of Nuclear Reactor Regulation cc:
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1 DETAILS 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
  *F. E. Halstead, QC Manager, 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
  *J. F. Streeter, Director, QA, TU Electric
  *C. L. Terry, Unit 1 Project Manager, TU Electric The NRC inspectors also interviewed other applicant employees ,
during this inspection perio * Denotes personnel present at the June 6, 1989, exit meetin . Applicant Action on Previous Inspection Findings (92701) (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 condition 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 require 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 disposition This evaluation resulted in Engineering Assurance issuing one deficiency and three observation 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 performe 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 close ;
i 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-87-10 NRC inspection of the  .;'
applicant's actions for SDAR-CP-87-109 appears in paragraph 4. of this repor 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 issue 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 close . 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 steam generator 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 '
IP:CPPD:N /g AD:IP:CPPD:NRR I
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 i
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 L
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CHale Hiivermor i RWarnick R/56 7/3l/89' 7/3(/89 7/ 3//89  ;
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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.
8908080068 89G731 7 PDR ADDCK050g445    fgo/ :
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I 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 onl 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 complete . Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant (92700)
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(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 performe 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 involvemen 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 appropriat 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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; <r,6+e na  UNITEO STATES o,,
,8 ,, s n NUCLEAR REGULATORY COMMISSION
$ ;  WASHINGTON, D. C. 20666 t, / .
w.....a JUL 31 1989 In Reply Refer To:
Dockets: 50-445/89-32 50-446/89-32 Mr. W. J. Cahill, Jr.


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Executive Vice President TU Electric 400 North Olive, Lock Box S1 Dallas, Texas 75201
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CAR 87-7 The NRC inspector has reviewed the preventive ;
==Dear Mr. Cahill:==
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Thank you for your letters of July 14, 1989, and July 28, 1989, in response to our letter dated June 19, 1989. We have reviewed your replies and find them responsive to the concerns raised in our Notice of Violation. We will review the r
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
implementation of your corrective and preventive actions during a future inspection to determine if full compliance has been achieved and will be maintained.
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close . 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 implemente {
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 frequencie ,
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To assess the implementation of the audits and surveillance, the NRC inspector reviewed two audits and three surveillanc 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 implemente 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 deficiencie Surveillance Report 05-89-0041,


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Sincerely, RF WM R. F. Warnick, Assistant Director:
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for Inspection Programs . I Comanche Peak-Project Division Office of Nuclear Reactor Regulation cc:
  (See attached)
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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 implemente . 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 manne 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 improvemen The Plant Evaluation group is divided into numerous sections that cover the following programs (areas):
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  .~ Trip reduction progra '
  . Emergency exercise scenario development, and exercise i control and evaluatio . Industry operating experience review progra . . Human performance evaluatio . Reporting of operations performance indicator . Tracking of NRC open items for Nuclear Operation l l
  . Nuclear Networ 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 trend )
By conducting in-depth special' studies and evaluations, the- I
  . Plant: Evaluation group can make specific recommendations directly to the Vice President, Nuclear Operation 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 Operation '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' bulletin . In-house operating experience - This is gathered j extensively from Plant Incident Reports and Licensee Event j Report I I
  -. 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 Cente l
  . Nuclear Network - This is basically an information )
 
exchange system that CPSES can sccess to learn of industry m= ____ _ _ _ = -    I
 
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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 interes . Monitoring ^of plant activities - This is accomplished by
,    direct observation of plant activities by performance assessment specialists.. These individuals have specifi experience in the areas of' electrical and mechanical maintenance,. instrumentation and-control, chemistry, f radiation protection, and operation 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 formulate 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 repor .- 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 CPSE . 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 bas ,
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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 indicator . 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 ;
review i l
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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 closur j
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The NRC inspector performed a detailed analysis of selected  #
issue 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 paragraph l
      , 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 provide 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 68-8 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 opinion 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; 50-446/88-4 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 valve I These seven SERs became a major part of the input for an l


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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 closur 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 84-42 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 implemente 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 recommendation These recommendations addressed training, procedures, level indication, temperature  i
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indication, and RHR system performance monitorin 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 event c. Instrument air system problems: This issue is an example of a situation in which the applicant successfully
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, .* W. J. Cchill, Jr. j cc: ,     i Roger D. Walker  TU Electric
e-l-  14 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 syste Finally, the review recommended specific corrective actions:
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  .. Assigning overall responsibility' and accountability for instrument air system reliability to a single
Manager, Nuclear Licensing c/o Bethesda Licensing TU Electric 3 Metro Center, suite 610 Skyway Tcwer Bethesda, Maryland 20814 400 North Olive Street, L.B. 81 Dallas, TX 75201 E. F. Ottney P. O. Box 1777 Juanita Ellis Glen Rose, Texas 76043 President - CASE 1426 South Polk Street Joseph F. Fulbright Dallas, TX 75224 Fulbright & Jaworski 1301 McKinney Street Susan M. Theisen Houston, Texas 77010 Assistant Attorney General Environmental Protection Division George A. Parker, Ch6ieman <
!  individual or grou . Repairing / calibrating specific component . Installing additional air receiver capacity in the
P.O. Box 12548, Capitol Station Public Utility Committee j Austin, TX 78711-1548
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plan . Modifying specific portions of the syste . Making numerous program and practice change 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.
Senior Citizens Alliance of Tarrant County, Inc.
 
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The manner in which this issue was resolved has resulted in a significantly more reliable instrument air syste 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 testin It is significant that the Manager, i I
Plant Evaluation, attributes the improved system reliability mainly to the establishment of the system engineer as the central point of responsibility for system reliabilit 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 i
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over the.last several' year 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 Operation 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 grou 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 ISE 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 report No violations or deviations were identified in this area of the inspectio '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 audit The NRC inspector reviewed Section 17.2.18 of the CPSES FSAR and Section 6 of the CPSES proposed technical specification 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 procedure 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 repor 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 procedure 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 audit 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 audit 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 audite 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 l
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17  4 technical specifications.- If implemented, such a change should enhance the current progra 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 manne ,
Correspondence and closeout of the one audit deficiency for !
TUG-88-22 was also timel 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 meetin The NRC inspector discussed the failure to obtain signed receipt acknowledgement forms with the QA audit superviso 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 addresse 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 r
reviewed the corrective actions and actions to prevent L
recurrence specified by DR C-89-0049. Those actions included providing more time between audits for preparation of reports
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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 l
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TUG-88-23 was still not issued for over two months after being identified as delinquent in DR C-89-004 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 progra No violations or deviations were noted during this inspectio . 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 implemente 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 procedure 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 organization 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 qualit 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 distributio 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 departmen To assess'that the~ documents maintained at these locations were l ' current, the NRC inspector' reviewed four aperture cards and 1 L
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26. drawing 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 provide 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
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being vital to safe plant operation are required to be maintained.within two days of' receipt of drawing. revisions or design: change 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 distributio 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 contro No violations or deviations were identified during this inspectio . 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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E with proposed technical. specifications, regulatory requirements, industry standards, and written commitment 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, 198 . Procedure STA-711, Revision 2, "ASME Section XI, Pump and Valve Inservice Testing," dated April 6, 198 .- Procedure STA-605, Revision 6, " Clearance and Safety Tagging," dated June 22, 198 . Procedure STA-606, Revision 9, " Work Requests and Work E  Orders," dated November 21, 198 . Procedure CP-SAP-6, Revision 15, " Control of Work on Station Components After Release From Construction to Startup," dated November 20, 198 . Operations Department Administrative Manual ODA-308, Revision 0, "LCO Tracking Log," dated September 27, 198 . Electrical Maintenance Manual EMP-210, Revision 0, $
  " Troubleshooting Guidelines," dated December 31, 198 . 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, 198 . 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, 198 . Mechanical Maintenance Procedure MMI-811, Revision 0,
  " Fisher Globe Control Valve Rework," dated February 4, 1985, with Work Order C890000546, dated January 25, 198 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 establishe 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 establishe Furthermore, provisions for designating quality control l
 
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I  inspection hold points have been proceduralized along with the methods and responsibilities for postmaintenance functional testin 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 superviso Provisions and procedures for tagging equipment and independent verification inspections have been established and implemente Furthermore, the applicant has provided detailed instructions
,  for the control of special processes, cleanliness, and housekeepin 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 consideratio 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:
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  . surveillance activities (testing, calibration, and !
inspection) required by Section 4.0 of the CPSES Technical Specification _
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  . Calibration of safety-related instrumentation not specifically controlled by Technical Specification . Inservice inspection of pumps and valves as described in 10 CFR Part 50.55a(g).


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, Inspection of the surveillance test program: For
GDS Associates, Inc. 6048 Wonder Drive  i 1850 Parkway Place, Suite 720 Fort Worth, Texas 76133 1 Marietta, GA 30067-8237 Jack R. Newman, Esq.
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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 state For tracking, scheduling, and statusing the surveillance requirements, three different reports are generated from the MMCP. These reports are described belo . Surveillance. Activity Verification Report. This report lists, by procedure number, the surveillance requirement, the required frequency, the applicability (Plant mode), and the responsible plant grou . 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 complete 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:
Lanny A. Sinkin  Newman & Holtzinger, P.C. ,
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Christic Institute Suite 1000 1324 N. Capitol Street 1615 L. Street N.W.
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Washington, DC 20002 Washington, D.C. 20036 Ms. Billie Pirner Garde, Esq.
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  . Established a master schedule (via the MMCP data base / reports) for tracking surveillance activitie This schedule addresses required frequencies, plant group responsibilities, and surveillance activity statu This schedule, comprised of the three reports described above, is described in STA-702 and STA-677, " Preventive Maintenance Program."


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Garde Law Office 104 East Wisconsin Avenue Appleton, WI 54911 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 William A. Burchette, Esq.
  . 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 requirement STA-702 states, furtier, that the individual Nuclear Operations managers are responsible for schedule development, implementation, and review / approval of surveillance test result . Established formal requirements for conducting surveillance' tests, calibrations, and inspections in accordance.with approved procedure STA-702 requires each assigned department to develop procedures required by the MSTL to meet the requirements of the assigned surveillanc Furthermore, STA-702 states'that each surveillance activity shall be accomplished in accordance with the applicable procedur . Defined formal methods and responsibilities for reviewing and evaluating surveillance test dat 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 activitie . 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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Counsel for Tex-La Electric Cooperative of Texas Heron, Burchette, Ruckert & Rothwell 1025 Thomas Jefferson St., NW Washington, DC 20007
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l calibration of these instruments by using Procedure i STA-677, " Preventive Maintenance Program," Revision 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 MMC 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 historie 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 statu . Assigned in writing the responsibility for maintaining the master calibration schedule up-to-dat 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 managemen . Established formal requirements for performing component calibrations in accordance with approved procedures that include acceptance criteri . Assigned responsibility for assuring that required component calibration schedules are satisfied, for which the I and C manager is responsibl 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 a -_ . - _ _ _ . - . .
 
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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 progra 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 performe 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 activitie The reports, described previously, call out the required test frequencies, the plant groups responsible for performing, and the test statu . 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 test . 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 ,
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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 procedure 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
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L  . Assigned responsibility for assuring that required schedules for all inservice activities are me '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 progra In summary, no violations or deviations were identified in the areas inspected. One minor weakness was, however, identified by.the applicant during the inspectio 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 Basically, the applicant'had addressed only those
 
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 log 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 operatio . Records Program for Operations (35748)
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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 sam .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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..C I  27 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 result 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 syste 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 know 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 coordinato 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 progra 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 Inde 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 personne The majority of the records are stored in open face rolling file 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 returne 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 exampl The NRC inspector. selected 14 types of records for inspectio 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 require The NRC inspector found the program for accumulation and storage of operations records to be in accordance with requirements, technical specifications, and FSAR commitment No violations or deviations were identified during the inspection of the implementation of this progra . 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, 198 . STA-418, Revision 0, " Joint Test Group," dated February 2, 198 . STA-602, Revision 5, " Temporary Modifications," dated April 3, 198 . NEO 3.12, Revision 1, " Safety Evaluations," dated March 1, 198 During the review, the NRC inspector verified that the l
applicant has established measures for the review of proposals i
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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I FSA 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 50.5 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
      '
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 standard 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 operatio 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 inspectio . Applicant Meetings (92700)
The NRC inspectors attended applicant meetings concerning site activities and implementation of various site program Meetings attended during this reporting period included the QA Overview Committee meeting and an exit meeting for audit EFE 89-0 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 prope No violations or deviations were identifie _
 
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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 1 . 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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Latest revision as of 20:19, 30 January 2022

Ack Receipt of 890714 & 28 Responses to NRC Re Violations Noted in Repts 50-445/89-32 & 50-446/89-32
ML20247R619
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/31/1989
From: Warnick R
Office of Nuclear Reactor Regulation
To: William Cahill
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8908080068
Download: ML20247R619 (3)
v • d • e


Text

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JUL. 31 1989 l

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In Reply Refer To:

Dockets: 50-445/89-32 50-446/89-32 Mr. W. J.ECahill,.Jr.

Executive Vice President TU Electric 400 North Olive, Lock Box 81 Dallas, Texas 75201

Dear Mr. Cahill:

.1 Thank you for your letter of July 14, 1989, and July 28, 1989,.

.in response to our letter dated June 19, 1989.- We have reviewed your replies and. find them responsive to the concerns raised lintour Notice of Violation. We will review the implementation of your-corrective and preventive actions during a future inspection ~to-determine if full compliance has been achieved and will.be I

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maintained. )!

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Sincerely, I ' ORIGINAL SICNED BY R. F. WATJECK -

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R. F.lWarnick,' Assistant: Director ]

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for Inspection Programs Comanche Peak Project Division'

Office of Nuclear Reactor Regulation cc:

(See attached) q

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CHale Hiivermor i RWarnick R/56 7/3l/89' 7/3(/89 7/ 3//89  ;

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$ ; WASHINGTON, D. C. 20666 t, / .

w.....a JUL 31 1989 In Reply Refer To:

Dockets: 50-445/89-32 50-446/89-32 Mr. W. J. Cahill, Jr.

Executive Vice President TU Electric 400 North Olive, Lock Box S1 Dallas, Texas 75201

Dear Mr. Cahill:

Thank you for your letters of July 14, 1989, and July 28, 1989, in response to our letter dated June 19, 1989. We have reviewed your replies and find them responsive to the concerns raised in our Notice of Violation. We will review the r

implementation of your corrective and preventive actions during a future inspection to determine if full compliance has been achieved and will be maintained.

Sincerely, RF WM R. F. Warnick, Assistant Director:

for Inspection Programs . I Comanche Peak-Project Division Office of Nuclear Reactor Regulation cc:

(See attached)

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, .* W. J. Cchill, Jr. j cc: , i Roger D. Walker TU Electric

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Manager, Nuclear Licensing c/o Bethesda Licensing TU Electric 3 Metro Center, suite 610 Skyway Tcwer Bethesda, Maryland 20814 400 North Olive Street, L.B. 81 Dallas, TX 75201 E. F. Ottney P. O. Box 1777 Juanita Ellis Glen Rose, Texas 76043 President - CASE 1426 South Polk Street Joseph F. Fulbright Dallas, TX 75224 Fulbright & Jaworski 1301 McKinney Street Susan M. Theisen Houston, Texas 77010 Assistant Attorney General Environmental Protection Division George A. Parker, Ch6ieman <

P.O. Box 12548, Capitol Station Public Utility Committee j Austin, TX 78711-1548

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Senior Citizens Alliance of Tarrant County, Inc.

GDS Associates, Inc. 6048 Wonder Drive i 1850 Parkway Place, Suite 720 Fort Worth, Texas 76133 1 Marietta, GA 30067-8237 Jack R. Newman, Esq.

Lanny A. Sinkin Newman & Holtzinger, P.C. ,

Christic Institute Suite 1000 1324 N. Capitol Street 1615 L. Street N.W.

Washington, DC 20002 Washington, D.C. 20036 Ms. Billie Pirner Garde, Esq.

Garde Law Office 104 East Wisconsin Avenue Appleton, WI 54911 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 William A. Burchette, Esq.

Counsel for Tex-La Electric Cooperative of Texas Heron, Burchette, Ruckert & Rothwell 1025 Thomas Jefferson St., NW Washington, DC 20007

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