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| {{Adams
| | #REDIRECT [[IR 05000445/1989032]] |
| | number = ML20245E076
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| | issue date = 06/19/1989
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| | 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
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| | author name = Bitter S, Hale C, Livermore H, Mckernon T
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| | author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
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| | addressee name =
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| | addressee affiliation =
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| | docket = 05000445, 05000446
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| | license number =
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| | contact person =
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| | document report number = 50-445-89-32, 50-446-89-32, IEC-80-22, IEIN-85-024, IEIN-85-24, NUDOCS 8906270319
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| | package number = ML20245E072
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| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
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| | page count = 31
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| }}
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| See also: [[see also::IR 05000445/1989032]]
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| | |
| =Text=
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| {{#Wiki_filter:m ,
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| L
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| L APPENDIX B
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| '
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| U..S.-NUCLEAR REGULATORY COMMISSION
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| 't OFFICE OF NUCLEAR REACTOR REGULATION-
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| .NRC iaspection Report: 50-445/89-32 Permits: CPPR-126
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| 50-446/89-32 CPPR-127
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| Docketsr. 50-445 Category: A2
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| 50-446
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| Construction Permit
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| Expiration Dates:
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| Unit 1: August 1, 1991
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| Unit 2: August 1, 1992
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| Applicant: TU Electric
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| Skyway Tower
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| 400 North Olive Street
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| Lock Box 81
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| Dallas, Texas 75201
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| Facility Name:. . Comanche Peak.Steaut Electric Station (CPSES),
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| Units 1 & 2
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| Inspection At: . Comanche Peak' Site, Glen Rose, Texas
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| Inspection' Conducted: May.3-through June 6, 1989
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| Inspectors: , d V T 9
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| C.J. e,i Reactor Inspector Date
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| (pa raphs 8, 11 and 14)
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| 6 . D. M % &/n/99
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| S. D. Bitter, Resident Inspector Date
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| (paragrap s.6 and 10)
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| 0 '
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| Q -
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| YA-/ l0 ~
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| T. O. ycKernon, Reactor /14hpector D&te
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| (pa m;raphs 9 and 12)
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| 8906270319 890619 r
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| gDR ADOCK 05000445 b
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| PNU
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| " C'onsultantsi .'J. Birmingham, RTS
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| 1
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| i
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| -
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| (paragraphs 2,3,4,5,7,8
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| '
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| L'. .. and'14)
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| (U ' - J. - Dale, 'EG&G :(paragraph 13);
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| AAr h ' Nth lo ~ Ik- h ~
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| Reviewed by:.
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| H..H..Livermore, Lead Senior Inspector Date
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| ,_ _ - _ _ - _ _ _ . _ _
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| - 1
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| 3
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| Inspection Summary: l
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| Inspection Conducted: May 3 through June 6, 1989 (Report
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| 50-445/89-32; 50-446/89-32)
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| Areas Inspected: Unannounced, resident safety inspection of
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| applicant's actions on previous inspection findings; follow-up on
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| violations /deviatiors; action on 50.55(c) deficiencies; the
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| operations quality programs for preoperational testing audits and
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| surveillance, quality verification function, audits, document
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| control, maintenance, surveillance testing and calibration control, ,
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| records, tests and experiments, and measuring and test equipment; J
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| and applicant meetings.
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| Results: Within the areas inspected, one violation was identified.
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| During a startup test, a procedural step was not performed and the j
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| startup test engineer did not initiate a deficiency report or ;
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| procedure change. This error was noted by surveillance personnel ;
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| but no deficiency was issued (paragraph 5). )
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| ,
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| One strength and two weaknesses were noted. The Plant Evaluation
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| Group has made significant improvements in their program for
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| identifying and preventing plant operations problems (paragraph 6).
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| The internal audit program continues to have difficulty in timely
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| issuance of reports (paragraph 5). The distribution of revised
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| documents to controlled locations is not tinely (paragraph 8) .
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| 1
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| l 1
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| 1
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| _ _ _ _ _ _ _ _____ __ __.__.________ J
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| ..,
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| .*
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| .
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| 4
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| 1
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| DETAILS
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| 1
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| 1. Persons Contacted
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| *M. Axelrad, Newman and Holtzinger
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| *D. P. Barry, Senior., Manager, Engineering, SWEC
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| *D. Bize, License Support, TU Electric
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| *H. D. Bruner, Senior Vice President, TU Electric
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| *W. J. Cahill, Executive Vice President, Nuclear, TU Electric
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| *H. M. Carmichael, Senior QA Program Manager, CECO
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| *J. T. Conly, APE-Licensing, SWEC
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| *W. G. Counsil, Vice Chairman, Nuclear, TU Electric
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| *S. Ellis, Performance and Testing, TU Electric
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| *F. E. Halstead, QC Manager, TU Electric
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| *C. B. Hogg, Engineering Manager, TU Electric
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| *R. T. Jenkins, Manager, Mechanical Engineering, TU Electric
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| *J. J. Kelley, Manager, Plant Operations, 'U Electric
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| *J. J. LaMarca, Electrical Engineering Manager, TU Electric
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| *0. W. Lowe, Director of Engineering, TU Electric
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| *S. G. McBee, NRC Interface, TU Electric
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| *B. Packo, Licensing Engineer, TU Electric
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| *S. S. Palmer, Project Manager, TU Electric
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| *P. Raysircar, Deputy Director, Unit 2, CECO
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| *D. Real, Dallas Morning News
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| *D. M. Reynerson, Director of Construction, TU Electric
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| *J. C. Smith, Plant Operations Staff, TU Electric
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| *R. L. Spence, TU/QA Senior Advisor, TU Electric
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| *J. F. Streeter, Director, QA, TU Electric
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| *C. L. Terry, Unit 1 Project Manager, TU Electric
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| The NRC inspectors also interviewed other applicant employees ,
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| during this inspection period.
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| * Denotes personnel present at the June 6, 1989, exit meeting.
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| 2. Applicant Action on Previous Inspection Findings (92701)
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| a. (Closed) Open Item (445/8716-O-04; 446/8713-O-03): This
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| open item concerned the overall review of field deficiency
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| reports (FDRs) for proper use and closure, and the
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| specific review of those test deficiency reports (TDRs)
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| that received an engineering disposition. This open item l
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| was issued since Comanche Peak Response Team results and
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| other sources indicated that these documents may have been
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| used inappropriately to document and disposition
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| nonconforming conditions.
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| The applicant has addressed the above issues and has
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| performed a review of FDRs and TDRs. The NRC inspector
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| reviewed the following information relative to these
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| issues.
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| _______ J
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| __ - - - _ - - - __ . _ _ _ . __ _ _ _ _ _ _ _ _ _
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| ! ;.
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| 5
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| ,
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| In regard to the use of FDRs, the NRC inspector reviewed
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| office memorandunt QQD-909, which documents the review of
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| FDRs performed by Quality Engineering. The review was
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| performed on all known FDRs to determine those cases where
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| the FDRs were improperly used or closed. Discrepant
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| conditions were then transferred to a nonconformance
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| report (NCR) or deficiency report (DR).
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| The NRC inspector had previously performed'a sample review
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| of the FDRs and based on that review concurs with the
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| applicant's approach,and resolution of this issue. Since
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| the use of FDRs was discontinued in 1982 and the current
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| program for control of nonconformances and deficiencies
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| appears adequate, the NRC inspector feels that no other
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| preventive action regarding FDRs is required.
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| In regard to the review of TDRs for adequate engineering
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| dispositions, the NRC inspector reviewed engineering
| |
| memorandum NE-26068 which documents the method used to
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| review TDRs. NE-26068 documents that approximately
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| 700 TDRs were identified that received engineering
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| dispositions. These 700 TDRs were then evaluated to
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| determine the adequacy of the engineering dispositions.
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| This evaluation resulted in Engineering Assurance issuing
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| one deficiency and three observations.
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| Based upon inspection of the checklist used to perform the
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| engineering assurance evaluation, the NRC inspector deems
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| that an adequate review of those TDRs has been performed.
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| In October 1987, Procedure CP-SAP-16, " Deficiency and
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| Nonconformance Reporting," was revised to require that
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| Design Change Authorizations.(DCAs) be used to request
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| engineering assistance for TDR dispositions. This
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| requirement was included in the startup procedure to
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| assure proper involvement of engineering in TDR
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| dispositions. Since those TDRs with engineering !
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| dispositions have been evaluated and the revision to
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| CP-SAP-16 provides preventive action for this problem,
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| this open item'is closed. ;
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| i
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| Although not included as part of this open item, an i
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| evaluation of those TDRs that did not receive an l
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| engineering disposition was also performed by the
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| applicant. That evaluation was performed as part of the
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| resolution of SDAR-CP-87-109. NRC inspection of the .;'
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| applicant's actions for SDAR-CP-87-109 appears in
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| paragraph 4. of this report.
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| b. (Closed) open Item (445/8810-0-10; 446/8808-0-10): This
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| item was opened for NRC review of a TU Electric procedure
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| that would provide the controls to assure that the prior
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| 6
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| education and experience of TU Electric employees
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| performing work at CPSES would be confirmed. This open
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| item was identified during an NRC inspection of
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| engineering qualifications relative to the corrective
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| ' Action Program. The results of that. inspection determined
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| that.TU Electric had been performing appropriate actions
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| to confirm the prior education and experience.of
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| TU Electric engineers. 'Those actions, however, had not
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| been placed under procedural control. Since the NRC
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| inspector was informed at that time that a procedure to
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| control this activity was pending, the inspector issued an
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| open item to review the procedure when issued.
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| Personnel Procedure PERS-02, " Confirmation of Education
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| and Experience Background for Personnel Performing Work at
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| or for CPSES," has been issued and is currently at
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| Revision 1.- The procedure provides for verification of
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| education and experience backgrounds of personnel hired by
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| TU Electric to' perform quality related work at or for
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| CPSES prior to the performance: of that quality related
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| work. The NRC inspector determined that PERS-02 meets the
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| intent of NRCLIE Circular 80-22, " Confirmation of Employee
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| Qualifications," and provides assurance that personnel
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| performing quality related work have appropriate education
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| and experience backgrounds; accordingly, this item is
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| closed.
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| -3. Follow-up on Violations / Deviations (92702)
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| (Closed) Violation-(445/8718-V-02): .This violation concerned:
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| (1) contrary to the requirements of NCR M-2320, the material
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| identity of certain shims installed on the Units 1 and 2 steam
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| generators was'not provided with the NCR, and (2) contrary to
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| the requirements of NCR M-2320,-certain shims and associated
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| bandings.were missing or improperly installed on the Unit 2
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| steam generators.
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| The applicant provided the following information relative to
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| the shims installed on the Unit 1 steam generators: (1) all
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| shims installed under NCR'M-2320 on the Unit 1 steam generators
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| were 'less than 1/8 inch in thickness; (2) as regards supports, ;
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| '
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| the site is committed to the 1974 edition, winter addendum of
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| the ASME Boiler and Pressure Vessel Code which does not address '
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| the issue of material identity of shims; (3) the 1980 edition
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| aof the ASME Boiler and Pressure Vessel Code, Section III,
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| Division I does address the use of shim material in component
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| L supports except that material identity of shim material less
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| i
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| than 1/4 inch is not required providing certain requirements of
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| paragraph NF-2121 are met; (4) the shim material used to
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| implement the disposition of NCR M-2320 for Unit 1 steam
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| ,
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| '
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| generators meets the requirement of' paragraph NF-2121 and
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| therefore,-material identity of the shim material is not a Code
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| L
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| __ -____ _ - - - _
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| ;
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| 'i.
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| 7
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| requirement; and (5) reinspectic of the applicable bolting on
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| the Unit 1 steam generator supp-ses verified that the gap
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| between the bolts and the lower support ring were within design
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| criteria.
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| I
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| The NRC inspector reviewed the above data including the
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| applicable sections of the ASME Code and the NCRs that document
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| the_ reinspection of the bolting. The NRC inspector agrees with
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| the applicant's conclusion that material identity for the
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| Unit I steam generators is not required and that based on the
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| inspection of the bolting installed on the lower support rings,
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| the gaps meet design requirements; accordingly, this violation
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| is closed for Unit 1 only.
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| Corrective actions for the Unit 2 steam generators have not, as
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| yet, been performed by the applciant. NRC inspection of the
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| corrective actions for the Unit 2 steam generators will be
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| performed and reported when those actions are completed.
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| 4. Action on 10 CFR Part 50.55(e) Deficiencies Identified by the
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| Applicant (92700)
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| (Closed) SDAR CP-87-109, " Inappropriate Deficiency
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| Documentation": This item, determined by the applicant to be
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| reportable, involved numerous types of documentation that may
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| have been used to: (1) improperly identify deficient
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| conditions, (2) inappropriately change the design, or
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| (3) incorporate design changes without a proper design review
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| being performed. Examples of such documents were the Request i
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| ~
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| for Information/ Clarification (RFIC), Item Substitution Request
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| (ISR), and Alternate Hanger Detail (AHD).
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| <
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| Initially, a review of all known historical type documents for
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| which engineering was involved was conducted by comanche Peak
| |
| Engineering (CPE). CPE performed this review utilizing office
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| memorandum NE-14126, " Guidance to be Used for Review of
| |
| Requests for Engineering Services." As a result of this
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| review, 15 document types were identified. Corrective Action
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| Request (CAR) 87-73 was then initiated to provide a 100% review
| |
| of those 15 document types having engineering involvement.
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| During implementation of CAR 87-73, additional document types
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| were identified and reviewed. Discrepant conditions identified
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| by these reviews were addressed on NCRs, DRs, or DCAs as
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| appropriate.
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| The NRC inspector has revicwed NE-14126, CAR 87-73, and other
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| associated documentation. Based on those re 'iews, it appears
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| that the applicant has performed an appropriately detailed
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| review of those document types determined to have been used
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| improperly and has taken appropriate corrective actions for
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| identified deficiencies. Preventive actions for each type of
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| documentation determined to have been misused is d.etailed in
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| c
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| _ _. _ _ _. .. _ _ _ _ - __
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| i
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| l
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| L \;
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| 8
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| CAR 87-73. The NRC inspector has reviewed the preventive ;
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| '
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| actions and concurs that most of the. discrepant document types
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| were historical and that current procedures should prevent
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| similar discrepancies from occurring; accordingly, this SDAR is l
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| '
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| closed.
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| 5. Preoperational Testing Audits and Surveillance (35301)
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| This NRC inspection was performed to ascertain: (1) that the I
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| applicant has developed an audit and surveillance program for I
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| assuring that preoperational test activities are consistent
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| with the CPSES FSAR and regulatory requirements, and (2) that
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| the applicant's audit and surveillance program for i
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| .preoperational test activities is satisfactorily implemented. {
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| The NRC inspector reviewed the applicant's procedural controls
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| for the performance of audits and surveillance. These
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| controls were found to be contained in Procedures NQA 3.07,
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| " 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
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| performed within required frequencies. ,
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| !
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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
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| audits were determined to .e 4: sed on appropriate design and
| |
| procedural requirements. Furtaer, the checklists and evidence
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| observed supported the conclusions drawn by the auditors. The !
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| NRC inspector found the audit portion of the QA program to be
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| satisfactorily implemented.
| |
| The NRC inspector reviewed preoperational test surveillance:
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| (1)'0S-89-0041 performed for Preoperational Test
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| 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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| 1
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| 1
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| ___
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| _ _ -. - - . -- .- _ _ _ . _ _ _
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| ,
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| .. i
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| *
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| ''
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| )
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| .- 1
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| l
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| 9
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| 1
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| l
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| however, noted that certain steps of Test Procedure f
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| 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
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| 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'
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| "open" until the valve changed to the desired position. The
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| 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):
| |
| .. 1
| |
| | |
| p -
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| ,
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| -
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| t'
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| , ;. +
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| -,.
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| U- 10
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| -l
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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.
| |
| -
| |
| . Tracking of NRC open items for Nuclear Operations. l
| |
| l
| |
| . 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
| |
| 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 Center.
| |
| l
| |
| . Nuclear Network - This is basically an information )
| |
| 1
| |
| exchange system that CPSES can sccess to learn of industry
| |
| m= ____ _ _ _ = - I
| |
| | |
| '
| |
| :is.
| |
| ] 'qL*f.
| |
| . >
| |
| . .g# s _
| |
| < #
| |
| g , 4
| |
| 11~
| |
| 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. ,
| |
| )
| |
| . Data is collected on NRC, INPO, and CPSES performance l
| |
| indicators. This. data is reported monthly in the Nuclear l
| |
| ,
| |
| 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
| |
| l
| |
| "
| |
| B . All NRC open items that are assigned to nuclear operations
| |
| are tracked and statused on a regular basis. This ensures ]
| |
| L l
| |
| 1
| |
| !
| |
| .
| |
| W -__-_____w. - _ _ _ _ _ _
| |
| | |
| - - _- _ _ _ . _ _ _ _ _ _
| |
| _ _ - _
| |
| -..
| |
| .,
| |
| -
| |
| ;. .
| |
| r ..
| |
| 12
| |
| 1
| |
| 1
| |
| )
| |
| that the items are reviewed in a timely manner to
| |
| determine their readiness for presentation to the NRC for
| |
| closure. j
| |
| !
| |
| 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
| |
| ,
| |
| 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
| |
| l
| |
| 1
| |
| %m-- _mmi_. _
| |
| | |
| _ - _ _ _ _ _ _ .
| |
| L .<
| |
| .
| |
| ,.. +
| |
| e
| |
| 13
| |
| 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
| |
| ~
| |
| 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
| |
| __. ._. .___________________-_-___N
| |
| | |
| _ - -
| |
| .
| |
| ,
| |
| w +-
| |
| 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 system. Finally, the review recommended
| |
| specific corrective actions:
| |
| l
| |
| '
| |
| .. 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
| |
| '
| |
| 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.
| |
| I
| |
| '
| |
| 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
| |
| I
| |
| 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
| |
| '
| |
| reviewing plant records, the NRC inspector has concluded
| |
| that the quality verification process has greatly improved
| |
| i
| |
| !
| |
| _ _ _ - - _ -
| |
| | |
| _i }
| |
| .s
| |
| .
| |
| 4. %
| |
| ..-
| |
| 15
| |
| 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- '
| |
| .
| |
| 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
| |
| __
| |
| | |
| ___
| |
| .
| |
| .<
| |
| -.-
| |
| .s'
| |
| *.
| |
| 16
| |
| 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
| |
| '
| |
| 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
| |
| l
| |
| l
| |
| | |
| !.
| |
| -
| |
| . .
| |
| '
| |
| . ,
| |
| ,... - 1
| |
| ..
| |
| 17 4
| |
| 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
| |
| 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
| |
| ,
| |
| 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
| |
| l
| |
| ._
| |
| | |
| .
| |
| -,
| |
| ,4
| |
| .-
| |
| 18
| |
| 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
| |
| _-
| |
| | |
| . - - - - _ _
| |
| .
| |
| .- G i
| |
| A4 .+ '
| |
| 7n*.
| |
| .. ;
| |
| s
| |
| l'' 19 j
| |
| i
| |
| t
| |
| '
| |
| (
| |
| 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
| |
| L
| |
| '
| |
| 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
| |
| ~
| |
| implemented a quality assurance program that is in conformance
| |
| _
| |
| | |
| _-
| |
| .;
| |
| +
| |
| 9 %
| |
| .
| |
| 20
| |
| E
| |
| with proposed technical. specifications, regulatory
| |
| requirements, industry standards, and written commitments.
| |
| During the inspection, the NRC inspector reviewed the following i
| |
| '
| |
| procedures and maintenance work packages:
| |
| . Procedure STA-623, Revision 3, " Post Work Testing," dated
| |
| September 15, 1988.
| |
| .
| |
| '
| |
| . 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
| |
| l
| |
| | |
| ~~
| |
| ( . .
| |
| R. .*
| |
| l .g
| |
| ;.,,
| |
| 1 :*
| |
| ''
| |
| 21
| |
| 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.
| |
| | |
| _
| |
| , , . .
| |
| . .
| |
| ,
| |
| + ..
| |
| ~4
| |
| 22
| |
| . Calibration of safety-related instrumentation not
| |
| specifically controlled by Technical Specifications.
| |
| . 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,
| |
| 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:
| |
| {
| |
| l {
| |
| ! I
| |
| | |
| -
| |
| .*
| |
| .
| |
| . g
| |
| e
| |
| ., 23
| |
| . 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 .
| |
| (
| |
| l
| |
| L___=_ l
| |
| | |
| c-_,m_
| |
| 4 *
| |
| y,*Em l
| |
| ..
| |
| 24
| |
| l
| |
| 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
| |
| a -_ . - _ _ _ . - . .
| |
| | |
| -
| |
| I, .+
| |
| ,
| |
| -
| |
| . 'i
| |
| '
| |
| w
| |
| 25
| |
| 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
| |
| _ _ _
| |
| | |
| _ _ _ _ __
| |
| u,
| |
| y '* :'
| |
| .
| |
| ,
| |
| '
| |
| lf*
| |
| V :o l
| |
| ,
| |
| 26
| |
| .
| |
| 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
| |
| >
| |
| '
| |
| 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
| |
| *
| |
| .
| |
| 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
| |
| - _- __
| |
| | |
| _ - _ _
| |
| .*
| |
| .
| |
| ,
| |
| * e
| |
| ..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 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
| |
| !
| |
| 4
| |
| | |
| -
| |
| *
| |
| ,+
| |
| .
| |
| 28
| |
| 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
| |
| 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 g*
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| e,
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| 1
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| '
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| ,
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| 29
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| I
| |
| 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
| |
| '
| |
| 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
| |
| _ _ _
| |
| | |
| p
| |
| s e] '
| |
| o'c
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| ^
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| \
| |
| j
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| ( 30
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| l
| |
| -
| |
| [ 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.
| |
| _
| |
| | |
| _ _ _ _ _ _ _ _ _ _ _ _
| |
| /. 6, k '. <
| |
| . .e
| |
| E ;.i ;* 7
| |
| F
| |
| -c-
| |
| '
| |
| '
| |
| ;. 31
| |
| ,
| |
| 115. Lopen' Items
| |
| open items are matters which have been' discussed with'the
| |
| applicant, which.will be reviewed 1further by the inspector,'and
| |
| :
| |
| '
| |
| 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
| |
| " '
| |
| of the inspection.
| |
| I i
| |
| 1
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| '/
| |
| l
| |
| l
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| ,
| |
| I
| |
| . . . . - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - . _ _ _ - . _
| |
| }}
| |