ML20245E076

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

ML20245E076
Person / Time
Site:	Comanche Peak
Issue date:	06/19/1989
From:	Bitter S, Hale C, Livermore H, Mckernon T Office of Nuclear Reactor Regulation
To:
Shared Package
ML20245E072	List: ML20245E069 ML20245E073 ML20245E076
References
50-445-89-32, 50-446-89-32, IEC-80-22, IEIN-85-024, IEIN-85-24, NUDOCS 8906270319
Download: ML20245E076 (31)

See also: IR 05000445/1989032

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L APPENDIX B

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U..S.-NUCLEAR REGULATORY COMMISSION

't OFFICE OF NUCLEAR REACTOR REGULATION-

.NRC iaspection Report: 50-445/89-32 Permits: CPPR-126

50-446/89-32 CPPR-127

Docketsr. 50-445 Category: A2

50-446

Construction Permit

Expiration Dates:

Unit 1: August 1, 1991

Unit 2: August 1, 1992

Applicant: TU Electric

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

Facility Name:. . Comanche Peak.Steaut Electric Station (CPSES),

Units 1 & 2

Inspection At: . Comanche Peak' Site, Glen Rose, Texas

Inspection' Conducted: May.3-through June 6, 1989

Inspectors: , d V T 9

C.J. e,i Reactor Inspector Date

(pa raphs 8, 11 and 14)

6 . D. M % &/n/99

S. D. Bitter, Resident Inspector Date

(paragrap s.6 and 10)

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T. O. ycKernon, Reactor /14hpector D&te

(pa m;raphs 9 and 12)

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(paragraphs 2,3,4,5,7,8

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(U ' - J. - Dale, 'EG&G :(paragraph 13);

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Reviewed by:.

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H..H..Livermore, Lead Senior Inspector Date

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Inspection Summary: l

Inspection Conducted: May 3 through June 6, 1989 (Report

50-445/89-32; 50-446/89-32)

Areas Inspected: Unannounced, resident safety inspection of

applicant's actions on previous inspection findings; follow-up on

violations /deviatiors; action on 50.55(c) deficiencies; the

operations quality programs for preoperational testing audits and

surveillance, quality verification function, audits, document

control, maintenance, surveillance testing and calibration control, ,

records, tests and experiments, and measuring and test equipment; J

and applicant meetings.

Results: Within the areas inspected, one violation was identified.

During a startup test, a procedural step was not performed and the j

startup test engineer did not initiate a deficiency report or  ;

procedure change. This error was noted by surveillance personnel  ;

but no deficiency was issued (paragraph 5). )

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One strength and two weaknesses were noted. The Plant Evaluation

Group has made significant improvements in their program for

identifying and preventing plant operations problems (paragraph 6).

The internal audit program continues to have difficulty in timely

issuance of reports (paragraph 5). The distribution of revised

documents to controlled locations is not tinely (paragraph 8) .

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DETAILS

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1. Persons Contacted

• M. Axelrad, Newman and Holtzinger

• D. P. Barry, Senior., Manager, Engineering, SWEC

• D. Bize, License Support, TU Electric

• H. D. Bruner, Senior Vice President, TU Electric

• W. J. Cahill, Executive Vice President, Nuclear, TU Electric

• H. M. Carmichael, Senior QA Program Manager, CECO

• J. T. Conly, APE-Licensing, SWEC

• W. G. Counsil, Vice Chairman, Nuclear, TU Electric

• S. Ellis, Performance and Testing, TU Electric

• F. E. Halstead, QC Manager, TU Electric

• C. B. Hogg, Engineering Manager, TU Electric

• R. T. Jenkins, Manager, Mechanical Engineering, TU Electric

• J. J. Kelley, Manager, Plant Operations, 'U Electric

• J. J. LaMarca, Electrical Engineering Manager, TU Electric

• 0. W. Lowe, Director of Engineering, TU Electric

• S. G. McBee, NRC Interface, TU Electric

• B. Packo, Licensing Engineer, TU Electric

• S. S. Palmer, Project Manager, TU Electric

• P. Raysircar, Deputy Director, Unit 2, CECO

• D. Real, Dallas Morning News

• D. M. Reynerson, Director of Construction, TU Electric

• J. C. Smith, Plant Operations Staff, TU Electric

• R. L. Spence, TU/QA Senior Advisor, TU Electric

• J. F. Streeter, Director, QA, TU Electric

• C. L. Terry, Unit 1 Project Manager, TU Electric

The NRC inspectors also interviewed other applicant employees ,

during this inspection period.

• Denotes personnel present at the June 6, 1989, exit meeting.

2. Applicant Action on Previous Inspection Findings (92701)

a. (Closed) Open Item (445/8716-O-04; 446/8713-O-03): This

open item concerned the overall review of field deficiency

reports (FDRs) for proper use and closure, and the

specific review of those test deficiency reports (TDRs)

that received an engineering disposition. This open item l

was issued since Comanche Peak Response Team results and

other sources indicated that these documents may have been

used inappropriately to document and disposition

nonconforming conditions.

The applicant has addressed the above issues and has

performed a review of FDRs and TDRs. The NRC inspector

reviewed the following information relative to these

issues.

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In regard to the use of FDRs, the NRC inspector reviewed

office memorandunt QQD-909, which documents the review of

FDRs performed by Quality Engineering. The review was

performed on all known FDRs to determine those cases where

the FDRs were improperly used or closed. Discrepant

conditions were then transferred to a nonconformance

report (NCR) or deficiency report (DR).

The NRC inspector had previously performed'a sample review

of the FDRs and based on that review concurs with the

applicant's approach,and resolution of this issue. Since

the use of FDRs was discontinued in 1982 and the current

program for control of nonconformances and deficiencies

appears adequate, the NRC inspector feels that no other

preventive action regarding FDRs is required.

In regard to the review of TDRs for adequate engineering

dispositions, the NRC inspector reviewed engineering

memorandum NE-26068 which documents the method used to

review TDRs. NE-26068 documents that approximately

700 TDRs were identified that received engineering

dispositions. These 700 TDRs were then evaluated to

determine the adequacy of the engineering dispositions.

This evaluation resulted in Engineering Assurance issuing

one deficiency and three observations.

Based upon inspection of the checklist used to perform the

engineering assurance evaluation, the NRC inspector deems

that an adequate review of those TDRs has been performed.

In October 1987, Procedure CP-SAP-16, " Deficiency and

Nonconformance Reporting," was revised to require that

Design Change Authorizations.(DCAs) be used to request

engineering assistance for TDR dispositions. This

requirement was included in the startup procedure to

assure proper involvement of engineering in TDR

dispositions. Since those TDRs with engineering  !

dispositions have been evaluated and the revision to

CP-SAP-16 provides preventive action for this problem,

this open item'is closed.  ;

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Although not included as part of this open item, an i

evaluation of those TDRs that did not receive an l

engineering disposition was also performed by the

applicant. That evaluation was performed as part of the

resolution of SDAR-CP-87-109. NRC inspection of the .;'

applicant's actions for SDAR-CP-87-109 appears in

paragraph 4. of this report.

b. (Closed) open Item (445/8810-0-10; 446/8808-0-10): This

item was opened for NRC review of a TU Electric procedure

that would provide the controls to assure that the prior

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education and experience of TU Electric employees

performing work at CPSES would be confirmed. This open

item was identified during an NRC inspection of

engineering qualifications relative to the corrective

' Action Program. The results of that. inspection determined

that.TU Electric had been performing appropriate actions

to confirm the prior education and experience.of

TU Electric engineers. 'Those actions, however, had not

been placed under procedural control. Since the NRC

inspector was informed at that time that a procedure to

control this activity was pending, the inspector issued an

open item to review the procedure when issued.

Personnel Procedure PERS-02, " Confirmation of Education

and Experience Background for Personnel Performing Work at

or for CPSES," has been issued and is currently at

Revision 1.- The procedure provides for verification of

education and experience backgrounds of personnel hired by

TU Electric to' perform quality related work at or for

CPSES prior to the performance: of that quality related

work. The NRC inspector determined that PERS-02 meets the

intent of NRCLIE Circular 80-22, " Confirmation of Employee

Qualifications," and provides assurance that personnel

performing quality related work have appropriate education

and experience backgrounds; accordingly, this item is

closed.

-3. Follow-up on Violations / Deviations (92702)

(Closed) Violation-(445/8718-V-02): .This violation concerned:

(1) contrary to the requirements of NCR M-2320, the material

identity of certain shims installed on the Units 1 and 2 steam

generators was'not provided with the NCR, and (2) contrary to

the requirements of NCR M-2320,-certain shims and associated

bandings.were missing or improperly installed on the Unit 2

steam generators.

The applicant provided the following information relative to

the shims installed on the Unit 1 steam generators: (1) all

shims installed under NCR'M-2320 on the Unit 1 steam generators

were 'less than 1/8 inch in thickness; (2) as regards supports,  ;

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the site is committed to the 1974 edition, winter addendum of

the ASME Boiler and Pressure Vessel Code which does not address '

the issue of material identity of shims; (3) the 1980 edition

aof the ASME Boiler and Pressure Vessel Code,Section III,

Division I does address the use of shim material in component

L supports except that material identity of shim material less

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than 1/4 inch is not required providing certain requirements of

paragraph NF-2121 are met; (4) the shim material used to

implement the disposition of NCR M-2320 for Unit 1 steam

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generators meets the requirement of' paragraph NF-2121 and

therefore,-material identity of the shim material is not a Code

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requirement; and (5) reinspectic of the applicable bolting on

the Unit 1 steam generator supp-ses verified that the gap

between the bolts and the lower support ring were within design

criteria.

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The NRC inspector reviewed the above data including the

applicable sections of the ASME Code and the NCRs that document

the_ reinspection of the bolting. The NRC inspector agrees with

the applicant's conclusion that material identity for the

Unit I steam generators is not required and that based on the

inspection of the bolting installed on the lower support rings,

the gaps meet design requirements; accordingly, this violation

is closed for Unit 1 only.

Corrective actions for the Unit 2 steam generators have not, as

yet, been performed by the applciant. NRC inspection of the

corrective actions for the Unit 2 steam generators will be

performed and reported when those actions are completed.

4. Action on 10 CFR Part 50.55(e) Deficiencies Identified by the

Applicant (92700)

(Closed) SDAR CP-87-109, " Inappropriate Deficiency

Documentation": This item, determined by the applicant to be

reportable, involved numerous types of documentation that may

have been used to: (1) improperly identify deficient

conditions, (2) inappropriately change the design, or

(3) incorporate design changes without a proper design review

being performed. Examples of such documents were the Request i

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for Information/ Clarification (RFIC), Item Substitution Request

(ISR), and Alternate Hanger Detail (AHD).

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Initially, a review of all known historical type documents for

which engineering was involved was conducted by comanche Peak

Engineering (CPE). CPE performed this review utilizing office

memorandum NE-14126, " Guidance to be Used for Review of

Requests for Engineering Services." As a result of this

review, 15 document types were identified. Corrective Action

Request (CAR) 87-73 was then initiated to provide a 100% review

of those 15 document types having engineering involvement.

During implementation of CAR 87-73, additional document types

were identified and reviewed. Discrepant conditions identified

by these reviews were addressed on NCRs, DRs, or DCAs as

appropriate.

The NRC inspector has revicwed NE-14126, CAR 87-73, and other

associated documentation. Based on those re 'iews, it appears

that the applicant has performed an appropriately detailed

review of those document types determined to have been used

improperly and has taken appropriate corrective actions for

identified deficiencies. Preventive actions for each type of

documentation determined to have been misused is d.etailed in

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CAR 87-73. The NRC inspector has reviewed the preventive  ;

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actions and concurs that most of the. discrepant document types

were historical and that current procedures should prevent

similar discrepancies from occurring; accordingly, this SDAR is l

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closed.

5. Preoperational Testing Audits and Surveillance (35301)

This NRC inspection was performed to ascertain: (1) that the I

applicant has developed an audit and surveillance program for I

assuring that preoperational test activities are consistent

with the CPSES FSAR and regulatory requirements, and (2) that

the applicant's audit and surveillance program for i

.preoperational test activities is satisfactorily implemented. {

The NRC inspector reviewed the applicant's procedural controls

for the performance of audits and surveillance. These

controls were found to be contained in Procedures NQA 3.07,

" Quality Assurance Audit Program," and NQA 3.23, " Surveillance

Program." Each of these procedures provided appropriate

controls to establish audits and surveillance of

preoperational test activities. A review of the audit and

surveillance schedules indicated that audits and surveillance

of preoperational testing activities were scheduled and

performed within required frequencies. ,

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To assess the implementation of the audits and surveillance,

the NRC inspector reviewed two audits and three surveillance.

Audits reviewed by the NRC inspector were TUG-88-23 on

operations testing and EFE-89-01 concerning design data

utilization during preopero ional testing. Both of these

audits were determined to .e 4: sed on appropriate design and

procedural requirements. Furtaer, the checklists and evidence

observed supported the conclusions drawn by the auditors. The  !

NRC inspector found the audit portion of the QA program to be

satisfactorily implemented.

The NRC inspector reviewed preoperational test surveillance:

(1)'0S-89-0041 performed for Preoperational Test

1CP-PT-44-01 SFT, " Steam Generator Blowdown Valve Functional

checks," (2) OS-89-0057 performed for Preoperational Test

1CP-PT-37-01 SFT, " Auxiliary Feedwater System," and

u (3) 0S-89-0033 performed for Preoperational Test

1CP-PT-64-02 SFT, " Reactor Protection System Operational

t Checks." These three surveillance were determined to be

{ adequately prepared, with appropriate preoperational test

witness or hold points assigned. Further, the narrative

discussion provided by the QA test log indicated that the

surveillance personnel were alert and cognizant of test

objectives. Typically, the issued surveillance report properly

documented the test results and identified any noted

surveillance deficiencies. Surveillance Report 05-89-0041,

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however, noted that certain steps of Test Procedure f

ICP-PT-44-02 SFT could not be performed as written. For I

example, step 7.9.13 of the test procedure required a position

change of valve 1HV-2397A by " momentarily" placing the q

controlling handswitch 1HS-2397A to "open." When this step i

could not be completed as written, the STE apparently  !

instructed the reactor operator to hold the handswitch as 1'

"open" until the valve changed to the desired position. The

surveillance report stated that "The abnormality will be

included in the test report," indicating that the STE would )

include the occurrence in the summary of the preoperational

test report. Since the STE did not properly document the

unsatisfactory condition, the surveillance technician should .

have documented the condition as a surveillance deficiency in l

accordance with'Section 6.4 of NQA 3.23. The NRC inspector

considers this item to be a violation (445/8932-V-01).

In summary, the NRC inspector determined that an adequate audit

and surveillance program exists to assure that preoperational

testing activities are performed in accordance with regulatory

requirements. Further, with the exception of the above

violation, the QA program appears to be satisfactorily

implemented.

6. Quality Verification Function (35702)

The purpose of this inspection was to assess the effectiveness

of the applicant's quality verification organizations in

identifying technical issues and problems having safety

significance and in following up to ensure that issues and

problems are resolved in a timely manner.

CPSES has numerous organizations that verify quality. These

include but are not limited to Quality Assurance, Quality

Control, Engineering Assurance, Station Operations Review

Committee (SORC), the offsite Operations Review Committee

(ORC), and Plant Evaluation. The activities of most of these

groups have been evaluated, directly or indirectly, in numerous

NRC inspection reports. One group, however, has not been

inspected to the same degree as the others. Furthermore, this

group, Plant Eva2uation, plays a unique role in the quality

verification process. The Plant Evaluation group is designed

to monitor and assess plant operations and maintenance

activities, review and assess nuclear industry operating

experience, identify emerging regulatory issues, and develop

and critique site-specific emergency exercises. The purpose of

the group is to. identify precursors to potential problems and

to advise the Vice President, Nuclear Operations of areas that

need improvement.

The Plant Evaluation group is divided into numerous sections

that cover the following programs (areas):

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.~ Trip reduction program. '

. Emergency exercise scenario development, and exercise i

control and evaluation.

. Industry operating experience review program.

. . Human performance evaluation.

. Reporting of operations performance indicators.

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. Tracking of NRC open items for Nuclear Operations. l

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. Nuclear Network. l

Personnel working in these programs (areas) are trained in root a

cause and event analysis techniques and are sensitive to i

recognizing related operating experiences and emerging trends. )

By conducting in-depth special' studies and evaluations, the- I

. Plant: Evaluation group can make specific recommendations

directly to the Vice President, Nuclear Operations. Then, the

vice president can direct various department managers to

' implement action plans to prevent incidents and events. The

Plant Evaluation group follows-up on these action plans and

tracks them to completion. The Manager, Plant. Evaluation,

reports directly to the Vice President, Nuclear Operations.

'This ensures that Plant Evaluation group recommendations

receive more than a cursory review by the applicable department

manager. Furthermore, this reporting arrangement ensures that

the Manager, Plant Evaluation, is seldom placed in the position

of directly criticizing his supervisor.

L Inputs to the evaluation process come from many sources not

directly related to any single quality verification ,

organization. Examples of these inputs include:

. Industry operating experience reports - These include

USNRC Notices and Bulletins, INPO Significant Event

Reports (SERs) and Significant Operating Event Reports

(SOE2s), and various vendor technical' bulletins.

. In-house operating experience - This is gathered j

extensively from Plant Incident Reports and Licensee Event j

Reports. I

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-. Regulatory issues 'These include generic letters, USNRC ]'

Office for Analysis and Evaluation of Operational Data

(AEOD) reports, and reports from industry groups such as

EPRI and Nuclear Safety Analysis Center.

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. Nuclear Network - This is basically an information )

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exchange system that CPSES can sccess to learn of industry

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events.- Essentially,'the network serves as a means for

L nuclear utilities to communicate with one another

concerningl areas of-industry interest.

. Monitoring ^of plant activities - This is accomplished by

, direct observation of plant activities by performance

assessment specialists.. These individuals have specific.

experience in the areas of' electrical and mechanical

maintenance,. instrumentation and-control, chemistry, f

radiation protection, and operations. j

Once these inputs are received, they are analyzed from a plant

performance perspective; i.e., are.they indicative of'past,

present, .or future plant problems? LIf so, then recommendations

to correct or avert problems can be formulated.

The performance analysis activities take many, forms:

. The Independent Safety.' Evaluation Group'(ISEG) can conduct

a' nuclear safety issue review. From this,.the ISEG can-

make specific recommendations. ISEG activities and the

status of ISEG' recommendations are addressed in a monthly

activity status report.

.- The Human Performance Review group can conduct a human

performance evaluation. This entails performing a i

root-cause analysis using INPO guidelines. .'From the

evaluation,-specific recommendations are made. The

results of the evaluation together with the-

recommendations'are fed back to the INPO data base as well

as directly to CPSES.

. Industry' Operating-Experience Reviews (IOERs)'can be

conducted. From these reviews, " lessons learned" can be

extracted and specific recommendations can be'made to

address the given issues. 'Mcreover, feedback from the

reviews is made available to CPSES personnel by means of a

monthly report and a " video magazine." Review results are

also put into the Industry Operational Experience Report

data base. ,

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. Data is collected on NRC, INPO, and CPSES performance l

indicators. This. data is reported monthly in the Nuclear l

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Operations Monthly Report on performance indicators.

. Plant Trip Reduction reviews are conducted as a part of

the effort to improve plant reliability. Performing

single-point failure analyses is one aspect of these  ;

reviews. i

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B . All NRC open items that are assigned to nuclear operations

are tracked and statused on a regular basis. This ensures ]

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that the items are reviewed in a timely manner to

determine their readiness for presentation to the NRC for

closure. j

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The NRC inspector performed a detailed analysis of selected #

issues. In doing so, his aim was to understand the issues, to

determine why the issues did or did not lead to plant problems,  !

and to determine what roles the Plant Evaluation group and i

CPSES upper management. played in addressing the issues. The j

issues are discussed in detail in the following paragraphs. l

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a. Failure of protective coatings in pipes and heat

exchangers: This issue is an example of a situation in  ;

which the applicant failed to relate the significance of a

particular industry event to CPSES. This issue arose from

an INPO SER (68-83). This SER identified a pipe-coating .

failure at the Palo Verde Nuclear Station. The applicant ]

received the SER, performed an IOER review, and resolved '

the issue as not being a problem at CPSES. The

justification for this stemmed from an architect-engineer

opinion for which no sound technical basis was provided.

Moreover, the applicant missed another opportunity to

appreciate the significance of the issue. This

opportunity occurred during the applicant's review of NRC

Information Notice 85-24, " Failure of Protective Coatings

in Pipes and Heat Exchangers." Essentially, the applicant

relied merely on the earlier resolution of the initiating

report, SER 68-83.

The NRC, in inspection report 50-445/88-34; 50-446/88-30,

documented these shortcomings in the Plant Evaluation

group's evaluation process.as an open item (445/8834-0-02;

446/8830-0-02). The applicant resolved the open item by

raising the Plant Evaluation group's standards to demand

technical bases instead of accepting opinions.

Furthermore, the applicant rereviewed more than 750 NRC

Information Notices to ensure.that they were addressed to

the new standards. Based on a review of these two

actions, the open item was closed in NRC Inspection Report

50-445/88-47; 50-446/88-42.

b. Loss of decay heat removal problems: This is an example

of 9 situations in which the applicant identified

potential operational problems involving decay heat l

removal before the decay heat removal issue required ]

regulatory response. The applicant initially became l

concerned when a series of five SERs involving operation  !

at reduced reactor vessel level was received between 1981 l

and 1984. Simultaneously, two SERs were received in 1981 l

and 1984 that detailed events involving RHR pump damage j

due to inadvertent closures of RHR pump suction valves. I

These seven SERs became a major part of the input for an

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INPO study (SOER 85-4) on the loss of RHR capability in

pressurized water reactors. Based on this study, the

applicant decided to review operations, maintenance, and

surveillance procedures for RHR conditions related to

mid-loop operations. Furthermore, the applicant added an

alarm to indicate RHR suction valve closure.

Meanwhile, in 1984 CPSES experienced two events involving

the RHR system: "RHR Pump Damage Due to Suction Valve

Closed," Problem Report (PR)84-495; and " Failed - Open

RER Relief Valve During the 1984 HFT Program," PR 84-428.

These two in-house events spurred the applicant to perform

an ISEG review (85-96) that dealt with overpressure

protection during RHR operation. From this review, five

recommendations were issued and implemented.

Later, in 1986, numerous SERs'were received that detailed

more events dealing with operation at reduced reactor

vessel level. These were documented by the NRC in

Inspection and Enforcement Notice (IEN)86-100, " Summary

of Loss of RHR Events Due to Loss of Fluid Level in

Reactor Coolant Systems." Shortly thereafter, NUREG 1269,

"Diablo Canyon Loss of RHR Event, April 1987," was issued

by the NRC. This NUREG identified the possibility of

sudden core uncovery during mid-loop operation. The

applicant used the input from this NUREG and from

IEN 86-101 in conducting ISEG review 87-01. This ISEG

review studied the applicant's control of reactor vessel

level during shutdown. From it came fifteen

recommendations. These recommendations addressed

training, procedures, level indication, temperature i

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indication, and RHR system performance monitoring.

Therefore, when the NRC issued Generic Letter (GL) 87-12,

which requested information from licensees on mid-loop

operation practices, the applicant was ready with a

response. Shortly after the GL was issued, the NRC issued

another IEN (88-36). It notified licensees of the

possibility for sudden loss of RCS inventory during low

coolant level operations. By the time GL 88-17 was

issued, which set forth NRC requirements for actions on

loss of decay heat removal, the applicant had already

determined that improved level instrumentation and a

correlation of vessel level with loss of pump suction were

needed. Following the 1989 HFT program, the applicant

completed an RHR vortexing test to correlate the vessel

level with pump suction indications. The timeliness with

which the applicant performed the vortexing test can be

attributed to the applicant's prompt reaction to the

RHR-related events.

c. Instrument air system problems: This issue is an example

of a situation in which the applicant successfully

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resolved a significant issue. This issue arose from

numerous prs that documented a variety of instrument air

system problems, numerous industry events (including the

TMI accident), and two previously conducted ISEG reviews

(one dealing with loss of cooling from the refueling

cavity and the other dealing with the loss of feedwater).

Based on these inputs, an ISEG review, " Instrument Air

System Reliability Review" 86-01 was initiated. This

review quantitatively identified the contributors to the

unreliability of the instrument air system. The review

concluded that the surveillance, testing, and maintenance

activities on the instrument air system had not been

sufficient to maintain reliable system operation. The [

review also concluded that the expertise and coordination

necessary to ensure reliability had not been effectively

applied to the system. Finally, the review recommended

specific corrective actions:

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.. Assigning overall responsibility' and accountability

for instrument air system reliability to a single

! individual or group.

. Repairing / calibrating specific components.

. Installing additional air receiver capacity in the

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plant.

. Modifying specific portions of the system.

. Making numerous program and practice changes.

These recommendations were sent to the Vice President,

Nuclear Operations. After consulting with all affected

managers, the vice president ensured that each

recommendation was resolved. In all cases, each

recommendation was specifically implemented or an

acceptable alternate course of action was taken.

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The manner in which this issue was resolved has resulted

in a significantly more reliable instrument air system.

This is evident from the greatly reduced number of plant

incident reports dealing with the system and from the fact

( that the 1989 HFT program was completed without the system ,

delaying testing. It is significant that the Manager, i

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Plant Evaluation, attributes the improved system

reliability mainly to the establishment of the system

engineer as the central point of responsibility for system

reliability.

By interviewing the Manager, Plant Evaluation, and by l

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reviewing plant records, the NRC inspector has concluded

that the quality verification process has greatly improved

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over the.last several' years. The Manager, Plant

Evaluation, attributes this mainly to a greater management i

awareness of the quality verification process. Basically,. 4

this greater awareness has resulted in a major change in

philosophy in how plant management deals with

recommendations. No longer are recommendations issued- '

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directly to individual line managers; instead, they are

issued directly to the Vice President, Nuclear Operations.

Also, over the last several years, the individual line

managers have increasingly recognized and supported the

role of the Plant Evaluation group. This has resulted in

a more rapid resolution and implementation of

recommendations made by the Plant Evaluation group.

It is significant that'as the nuclear industry's view of the

role of independent evaluation groups has matured,.the

applicant has made changes to the Plant Evaluation program to

maintain its effectiveness.- One exarple of a change to the

Plant Evaluation group was the removal of the ISEG from direct

control of the Plant Evaluation group.- The ISEG now reports to

the Director of Technical Interface. This individual, in turn,

reports to the Vice President, Nuclear Engineering. This

change should further strengthen the independent overview

capability of the ISEG.

In summary, the NRC' inspector has concluded that the

applicant's quality verification process at the Plant

Evaluation level has improved significantly over the last

several years. Again, this conclusion was reached without a J

reexamination of the other " quality" groups. Those groups have

been the subject of previous NRC inspection reports.

No violations or deviations were identified in this area of the

inspection.

'7. Audit Program for Operations (35741)

The purpose of this NRC inspection was to ascertain whether the

applicant has developed and begun the implementation of a

program for auditing operations activities that is in

conformance with regulatory requirements. This objective was

accomplished by the review of site procedures for controlling

audits related to these activities, audit schedules,

qualifications of audit personnel, and a detailed review of two

recently completed audits.

The NRC inspector reviewed Section 17.2.18 of the CPSES FSAR

and Section 6 of the CPSES proposed technical specifications.

The FSAR p:tovided commitments consistent with the applicable

portions cf Regulatory Guide 1.33 and ANSI N45.2.12. The CPSES

technical specifications, while still under NRC review,

appeared to provide appropriate commitments for the audit of

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operation's activities. The audit program is further

delineated'in Section 18.0 of the TU Electric Quality Assurance

Manual (QAM) and lower tier procedures.

For this inspection, the NRC inspector reviewed the following

documents: (1) the TU Electric QAM; (2) Procedure NEO 3.07,

" Management Response to Audit Deficiencies"; (3) Procedure

NQA 3.07, " Quality Assurance Audit Program," and (4) Procedure

NQA 1.16, " Indoctrination, Training and Certification of

Auditors and Lead Auditors." These procedures were determined

to provide appropriate requirements and methods for a

comprehensive audit program. This audit program was required

to be performed by trained and qualified auditors and lead

auditors who were sufficiently independent of the activity j

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being audited. Further, these procedures provided that the

audits be performed utilizing prepared checklists and that

written reports of audit results be issued to the management of

the audited organizations. Deficiencies identified during the

performance of audits were required to be communicated to

management at post audit meetings and documented as audit

deficiencies in the audit report.

Written response from the audited organization is procedurally

required unless the audit deficiency was determined to have

been adequately addressed during the audit. The NRC inspector

determined that the above requirements, and the designation of

personnel responsible for the performance of the above

requirements, were adequately delineated in the procedures.

To verify proper implementation of the above requirements, the

NRC inspector reviewed: the audit schedule for 1989,

documentation relative to two recently completed audits, and

evidence of the lead auditor's qualifications for each of the

two audits.

Review of the 1989 audit schedule showed that an annual audit

schedule was issued that included audits of all areas required

by the QA program. Further, the audit schedule is updated

quarterly to assess the need for additional or supplemental

audits. Review of the audit schedule also indicated that

audits were completed in accordance with the schedule, or as in

the case of three TAP audits, were rescheduled due to

insufficient progress in the area to be audited.

Procedure NQA 3.07, " Quality Assurance Audit Program,"

Revision 1, provides for the auditing of those areas

specifically required by Section 6 of the proposed CPSES

Technical Specifications. The NRC inspector considers this

provision to be adequate; howcVer, discussion with audit '

personnel indicates that the applicant is considering a more

comprehensive program for the assurance of conformance to the

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technical specifications.- If implemented, such a change should

enhance the current program.

The two audits selected for review by the NRC inspector were

audit TUG-88-22 on nonconformance and deficiency reports, and

audit TUG-88-23 on test control and operations testing. The

NRC inspector determined from review of applicable

documentation that: (1) each of the audits had been performed

by lead auditors and auditors qualified to the requirements of

ANSI N45.2.23 (1978),-(2) audit checklists were sufficiently

detailed and addressed compliance with applicable regulatory

requirements as well as procedural compliance, and (3) audit

TUG-88-22 was completed and issued in a timely manner. ,

Correspondence and closeout of the one audit deficiency for  !

TUG-88-22 was also timely.

During the NRC inspector's review of the above audits, two

deficient conditions were noted. Contrary to the requirements

of NQA 3.07: (1) signed receipt acknowledgement forms were not

being obtained from all audited organizations. and (2) the

audit report for TUG-88-23 was not issued wit: :n 30 days of the

post audit meeting.

The NRC inspector discussed the failure to obtain signed

receipt acknowledgement forms with the QA audit supervisor.

The supervisor provided the following information: (1) as shown

by'the distribution list, copies of the audit report were sent

to each audited organization; (2) signed receipt

acknowledgement forms were obtained from those organizations

with deficient conditions; and (3) an office memorandum had

been issued by the audit department to address this issue. The

NRC inspector reviewed the' distribution list and'the office

memorandum and agreed that the issue appeared to be adequately

addressed.

Regarding the failure to issue the audit report for TUG-88-23

in a timely manner, the NRC inspector determined the following:

(1) the lead auditor is normally responsible for preparation of

the audit report, (2) the lead auditor for TUG-88-23 had been

transferred from the audit department prior to the audit report

being issued, (3) Deficiency Report (DR) C-89-0049, issued in

j February 1989, noted that issuance of audit report TUG-88-23

j and 11 other audit reports were delinquent, and (4) that audit

report TUG-88-23 was ismaed May 2, 1989. The NRC inspector j

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reviewed the corrective actions and actions to prevent

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recurrence specified by DR C-89-0049. Those actions included

providing more time between audits for preparation of reports

,

and issuing a memorandum to the audit staff reemphasizing the

l need to comply with the time requirements of NQA 3.07. The NRC

inspector deems those actions to have been appropriate;

however, the NRC inspector believes a significant weakness in

the audit program may still exist in that the audit report for

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TUG-88-23 was still not issued for over two months after being

identified as delinquent in DR C-89-0049.

In summary, with the exception of the untimely issuance of j

audit report TUG-88-23, it appeared that the applicant had 4

established and implemented an adequate audit program.

No violations or deviations were noted during this inspection.

8. Document Control for Operations (35742)

During this inspection period, the NRC inspector performed a

review of the CPSES QA program to ascertain whether

administrative controls for the control, issuance, and

maintenance of required documents had been established and that

those controls were being implemented.

As reported in NRC Inspection Report 50-445/88-27;

50-446/88-23, the NRC had inspected in detail the CPSES program

for the control of manuals and procedures. Also, the applicant

is currently reviewing the maintenance and control of

procedures and manuals under CAR 89-02. Therefore, the NRC

inspector focused this inspection on the program for control,

issua.;ce, and maintenance of those drawings routinely used by

plant operations organizations.

The NRC inspector reviewed such documents as the CPSES FSAR,

the proposed technical specifications, and the TU Electric QA

manual to verify.that the applicant had provided for the

establishment of a document control program that was in

conformance with regulatory requirements. The NRC inspector

determined that the applicant had provided for the

establishment of a document control program that was in

conformance with the requirements of Appendix B of 10 CFR

Part 50, Regulatory Guide 1.33, and industry standard ANSI

N18.7 (1976). These documents require that measures be

established to control the approval, issuance, distribution,

and, as necessary, revision of documents affecting quality.

Further, these docuTrnts require that such documents be

available and used at the location where prescribed activities

are. performed. The details of the applicant's document control

program for the operations phase are currently contained in

STA-306, "liuclear Operations Document Control," PC 2.13-02,

" Distribution Control," and NEO 5.15, " Control of Vital Station

Drawings." Other procedures such as ECE 2.13-01, " Document

Control Instructions," and ECE 2.13-02, " Processing of Field

Det.ign Changes," provide requirements and methods by which

engineering provides approved drawing revisions or design '

changes to the document control group for distribution.

The NRC inspector reviewed these procedures and determined that

they provided adequate delineation of the responsibilities and

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the methods by which approved drawing' revisions and design i

changes are:'(1) entered into the CPSES document control data l

base;-(2). issued, as needed, to work groups and updated when i

design changes or revisions affect the issued document; and

(3) distributed and maintained at locations such as the  !

i . operations control room and'the maintenance department. To

assess'that the~ documents maintained at these locations were

l ' current, the NRC inspector' reviewed four aperture cards and 1

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26. drawings. These drawings and aperture cards had been issued

to eight different control locations.- Four of these controlled

locations-were located-in maintenance and four were in the

control room, lDf the 30 documents inspected, the NRC inspector

found one aperture card and six drawings that were not at the

current revision. .This: condition was discussed with personnel

from.the operations' document control. center (Operations DCC)

and the'following information was provided. In accordance with

STA-306, the operations'DCC11s responsible to maintain all

drawings and design changes in a timely manner. Vital station

. drawings, those drawings determined by Nuclear Operations as

.

being vital to safe plant operation are required to be

maintained.within two days of' receipt of drawing. revisions or

design: changes. Further, prior to3using the controlled

drawings issued to' the maintenance (n: control room groups, the

user is required to verify the status of the drawing by

accessing the Field Design" Change and-Review Status Log

(FDCRSL) data base. 'This.last requirement-is included in

STA-306 to~ assure that the user will be informed of the most

current status of the drawing and if'there are any outstanding

DCAs against the drawing. The NRC inspector then reviewed the

six drawings and the one aperture card against the recorded

date when Operations DCC had received the documents, all had

.been distributed within the two day' time requirement of

STA-306. .A weakness was noted in this area.- Of the seven

documents identified above, all were released or issued by

engineering at least seven days before being received by

Operations DCC for distribution.

The applicant has established a document control program for

Operations that meets regulatory requirements and the

-implementation of the program appears satisfactory. On this

basis, . the NRC inspector determined: that the applicant's

document control program for Operations was satisfactory for

the area of drawing and design change control.

No violations or deviations were identified during this

inspection.

9. Maintenance Program for Operation (35743) l

This portion of the inspection involved a maintenance program

review to ascertain whether the applicant has developed and

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implemented a quality assurance program that is in conformance

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with proposed technical. specifications, regulatory

requirements, industry standards, and written commitments.

During the inspection, the NRC inspector reviewed the following i

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procedures and maintenance work packages:

. Procedure STA-623, Revision 3, " Post Work Testing," dated

September 15, 1988.

.

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. Procedure STA-731, Revision 0, "ASME Section XI, Repair

and Replacement Activities," dated September 7, 1988.

. Procedure STA-711, Revision 2, "ASME Section XI, Pump and

Valve Inservice Testing," dated April 6, 1988.

.- Procedure STA-605, Revision 6, " Clearance and Safety

Tagging," dated June 22, 1988.

. Procedure STA-606, Revision 9, " Work Requests and Work

E Orders," dated November 21, 1988.

. Procedure CP-SAP-6, Revision 15, " Control of Work on

Station Components After Release From Construction to

Startup," dated November 20, 1988.

. Operations Department Administrative Manual ODA-308,

Revision 0, "LCO Tracking Log," dated September 27, 1988.

. Electrical Maintenance Manual EMP-210, Revision 0, $

" Troubleshooting Guidelines," dated December 31, 1987.

. Surveillance Test Procedure INC-7757A, Revision 4, " Analog

Channel Operational Test and Channel Calibration - Reactor

Coolant System Wide Range Temperature, Cold

Overpressurization System and Wide Range Pressure

Channels 413B, 423B, 433A, 443A, and 403," dated August 3,

1988.

. Mechanical Maintenance Procedure MSM-CO-6843, Revision 0,

"Limitorque SMB-000 w/HBC Maintenance," dated January 30,

1989, with Work Order C880001416, dated March 23, 1988.

. Mechanical Maintenance Procedure MMI-811, Revision 0,

" Fisher Globe Control Valve Rework," dated February 4,

1985, with Work Order C890000546, dated January 25, 1989.

Review of the above procedures and work packages by the NRC

inspector verified that procedures for initiating requests for

routine and emergency maintenance have been established.

Criteria for review and approval of maintenance requests, the

basis for designating the work as safety /nonsafety related, and

requirements for inspection activities have been established.

Furthermore, provisions for designating quality control

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I inspection hold points have been proceduralized along with the

methods and responsibilities for postmaintenance functional

testing. In addition, administrative controls for maintenance

activities requiring maintenance records to be prepared,

assembled,.and reviewed prior to transferring to storage have

been established. Procedures and responsibilities for review

of completed maintenance work packages have been assigned along

with responsibilities for the identification of deficiencies,

trending, and problem analysis. Controls for equipment release

during maintenance activities have been implemented such that

technical specifications are reviewed and sole responsibility

for release control resides with the shift supervisor.

Provisions and procedures for tagging equipment and independent

verification inspections have been established and implemented.

Furthermore, the applicant has provided detailed instructions

, for the control of special processes, cleanliness, and

housekeeping. j

During the above review, the NRC inspector noted that the

applicant's procedural requirements for ASME Section XI repair

and replacement activities require the completion of ASME

Section XI Form.NIS-2 subsequent to work accomplishment. The

applicant's procedures for preparing the periodic ASME

Section XI summary report require identifying the quality

control inspector that witnessed the specific

repair / replacement activities; however, the NIS-2 form does not

presently require identifying the QC inspector. Revising the

NIS-2 form to include the QC inspector would simplify the

summary report preparation process. This observation was

presented to the applicant for consideration.

In addition, the NRC inspector reviewed procedures related to

post work testing and a recent audit TUG-88-23. The NRC

inspector concluded that the applicant's present measures for

post work test report (PTR) tracking may not fully and

adequately address the complete dispositions of PTRs. As noted

in audit TUG-88-23, the applicant identified a number of

specific PTRs for which documentary evidence could not be

substantiated. The resolution of these PTRs and measures for

adequate and effective tracking of PTRs shall remain an open

item (445/8932-0-02).

10. Surveillance' Testing and Calibration Control Program for

Operation (35745)-

The purpose.of this inspection was to determine whether the

applicant has developed programs for the control and evaluation

of:

(

. surveillance activities (testing, calibration, and  !

inspection) required by Section 4.0 of the CPSES Technical

Specifications.

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. Calibration of safety-related instrumentation not

specifically controlled by Technical Specifications.

. Inservice inspection of pumps and valves as described in

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:

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. Established a master schedule (via the MMCP data

base / reports) for tracking surveillance activities.

This schedule addresses required frequencies, plant

group responsibilities, and surveillance activity

status. This schedule, comprised of the three

reports described above, is described in STA-702 and

STA-677, " Preventive Maintenance Program."

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. Assigned in writing the responsibilities for

maintaining the master surveillance test schedule

up-to-date. STA-702 states that the Surveillance

Test Coordinator is responsible for the day-to-day

coordination and oversight of the Surveillance Test

Program and ensuring compliance with the applicable

requirements. STA-702 states, furtier, that the

individual Nuclear Operations managers are

responsible for schedule development, implementation,

and review / approval of surveillance test results.

. Established formal requirements for conducting

surveillance' tests, calibrations, and inspections in

accordance.with approved procedures. STA-702

requires each assigned department to develop

procedures required by the MSTL to meet the

requirements of the assigned surveillance.

Furthermore, STA-702 states'that each surveillance

activity shall be accomplished in accordance with the

applicable procedure.

. Defined formal methods and responsibilities for

reviewing and evaluating surveillance test data.

Sections 6.5 and 6.7 of STA-702 address the

review / approval of surveillance activity results as

well as the failure to meet acceptance criteria or

the failure to perform surveillance activities.

. Assigned responsibility for assuring that required

schedules for all activities are satisfied. These

responsibilities are addressed in Section 5.0 of

STA-702. Basically, the individual Nuclear

Operations managers are responsible for developing

and implementing the schedule. The surveillance Test

Coordinator is responsible for the day-to-day

coordination and oversight of the surveillance test

program and for ensuring compliance with the

applicable requirements,

b. Inspection of calibration activities for those

safety-related components not identified in Technical

Specifications: Essentially, these components are

instruments used to meet the Technical Specifications -

surveillance requirement. The applicant controls the .

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calibration of these instruments by using Procedure i

STA-677, " Preventive Maintenance Program," Revision O.

For the tracking and statusing of these calibrations, the

Instrumentation and Control (I and C) department uses a

report generated by the MMCP. This report describes the

instrumentation calibration requirements, lists the

required frequencies, describes the equipment status, and

lists the applicable procedure and responsible plant

group. For scheduling purposes, a report entitled

" Backlog Analysis Listing" is generated from the MMCP.

This report lists the instruments, by.name and tag number,

and gives a calibration due date. For statusing purposes,

the MMCP can generate a report that contains equipment

histories.

The NRC inspector reviewed Procedure STA-677 and the

various reports that the MMCP can generate. In this

review, the inspecror concluded that the applicant has:

. Established a master schedule (via the MMCP data

base / reports) for the tracking of calibrations needed

for instrumentation used to meet CPSES Technical

Specification requirements. These reports, described

previously, call out the required calibration-

frequencies,.the plant groups responsible for

performing the calibration, and the calibration

status.

. Assigned in writing the responsibility for

maintaining the master calibration schedule

up-to-date. STA-677 states that the I and C manager

is responsible for scheduling, executing, and

documenting the completion of the instrument

celebrations. STA-677 states, further, that the

Results Engineering manager is responsible for

overall preventive maintenance (including instrument

calibration activities) program management.

. Established formal requirements for performing

component calibrations in accordance with approved

procedures that include acceptance criteria.

. Assigned responsibility for assuring that required

component calibration schedules are satisfied, for

which the I and C manager is responsible.

c. Inspection of the program for performing inservice

inspection of pumps and valves required by 10 CFR

Part 50.55a(g): The applicant uses the Inservice Test

(IST) program plan as a controlled document that lists the

Class 1, 2, and 3 pumps and valves that are subject to

inservice testing. This document contains the basic

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requirements, the required frequencies, and the

requirements for relief-from-testing. In addition to this

document, the applicant uses procedure STA-711, "ASME

Section XI Pump and Valve Inservice Testing," Revision 2,

to describe the implementation of tne ASME Section XI pump

and valve IST program.

-For tracking, scheduling, and statusing, the applicant

uses reports and schedules generated by the MMCP. These

reports and schedules describe the test requirements, list

the required frequencies, list the applicable procedures

and responsible groups, and give the due dates and the

date the activity is to be performed.

The NRC inspector reviewed Procedure STA-711 and the MMCP

generated reports. In the review, the NRC inspector

determined that the applicant has:

. Established a master schedule (via the MMCP data

base / reports) that' tracks inservice test activities.

The reports, described previously, call out the

required test frequencies, the plant groups

responsible for performing, and the test status.

. Assigned in writing the responsibility for

maintaining the master inservice test schedule

up-to-date. STA-711 states that the Results

Engineering manager shall appoint a Nuclear

Operations IST program coordinator (IST coordinator)

to implement the IST program in accordance with

Procedure STA-711. Furthermore, STA-711 states that

the Results Engineering manager is responsible for

ensuring that the IST program is controlled as part

of the Surveillance Test Program. Finally, STA-711

states that the IST program coordinator is

responsible for the implementation of the IST program

and is also responsible for developing and j

coordinating the input to schedule all required ASME '

Section XI pump and valve tests.

. Established formal requirements for conducting

inservice tests in accordance with approved

procedures that include acceptance criteria. As

described in paragraph 10.a, above, STA-702,

" Surveillance Test Program," Revision 7, requires

that each assigned department develops the procedures ,

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required by the MSTL to meet the requirements of the

assigned surveillance. STA-702 also states that each

surveillance activity shall be accomplished in

accordance with the applicable procedures.

Therefore, because the IST program is controlled as a

portion of the surveillance test program (STP), the

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applicant'has adequately established formal

. requirements for conducting IST activities as well as

surveillance activities in accordance with approved.

procedures.that include acceptance criteria.

L . Assigned responsibility for assuring that required

schedules for all inservice activities are met.

'Again, because the IST program is controlled as a

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portion of the STP, the individual Nuclear Operations

t managers are responsible for.IST schedule

implementation. The IST program coordinator is

responsible for overall implementation of the IST

program.

In summary, no violations or deviations were identified in

the areas inspected. One minor weakness was, however,

identified by.the applicant during the inspection. Catts

weakness involved the applicant's failure to adequately

Laddress the review of-technical specification-based

operator,. chemistry,.and. health physics logs in' Procedure

STA-702,1" Surveillance Test Program," Revision 7.

Basically, the applicant'had addressed only those

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surveillance activities that involved: surveillance work

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orders. The applicant has corrected this by adding,.to

section 6.5'of STA-702, a. paragraph.that addresses the

review of operator, chemistry, and health physics logs.

Essentially, the logs will be reviewed by either

Operations engineering, or Results engineering. The.NRC

inspector is satisfied with the applicant's. resolution of

this weakness and:has no further concerns. It should be

noted that while this' inspection has dealt with the

control and evaluation of the surveillance safety-related

calibration, and inservice inspection programs,.the

implementation of these~ programs will be the subject of an

NRC inspection to occur within the first six-month period

of plant operation.

11. Records Program for Operations (35748)

<

ThiF 2nspection WaS to verify that the applicant has

estat11shed a program for the control of records generated

during preop testing, startup, and plant operation. The

Records-Management Program (RMP), which is related to both

. construction and operation records, has been previously

inspected by the NRC (Inspection Report 50-445/88-10;

50-446/88-08, and subsequent follow-up reports). While '.his

, inspection is related more to operations, the facilities and .

. procedures are the same.

.The types of records to be accumulated and maintained are

identified in the Operations Master Records Index. The types

of records listed in this index include those that would be

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generated during, and in support of, plant operations; e.g.,

operating logs, recorder charts and computer printouts, plant

modifications and changes, test results, reportable items and

events, personnel documents, preop and startup tests, various

committee meeting minutes, and special test experiment results.

The Records Type List (RTL) described and presented in

Section 2 of the Records Management Program Manual, is divided

into nine major functional areas. .These functional areas are

further subdivided such that all classifications of records can

be uniquely identified using an alpha-numeric numbering system.

The RTL provides a description of each record type, the

organization releasing the record, the facility where the

record is stored, the medium of the stored record (film, hard

copy, etc.), the record retention time, and the requirements

for retention. Each record in the Operations Master Record

Index is cross referenced to the RTL, thus retention times are

readily known.

Procedures control the activities of.each organization that

generates records. A section in each of these controlling

procedures identifies the records that must be retained through

implementation of the procedure. Within each organization, an

individual is designated as the records turnover coordinator.

In accordance with Procedure RMP 1.3.1, " Records Turnover

Specifications and Turnover of Records," this coordinator

prepares documents generated within their organization for

transfer to RMP personnel. This process assures that the

required records are captured and provided to the records

program.

As described in a previous NRC Inspection Report 50- 4 5/88-10;

50-446/88-08, there are three records storage facilit.sr

currently onsite: Operation Record Center (ORC), Project

Records Center (PRC), and Engineering Records Center (ERC).

Previous NRC inspections found the records centers to be in

compliance with requirements and commitments. Each records

center has a designated custodian. Those records generated by,

or in support of, operations are retained in the ORC, together

with some construction and engineering records. Radiographs

and microfilm are stored in a room within the ORC that provides

a temperature and humidity controlled environment. The ORC

records custodian is responsible for the control and

maintenance of the Operations Master Records Index.

As with all records centers, the OFC restricts access to the

storage area to RMP personnel. When necessary, others are

permitted in the storage area, but only in the continuous

presence of RMP personnel.

The majority of the records are stored in open face rolling

files. The records are placed in folders in these files. An

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alpha-numeric system of filing is used throughout for ease of

retrieval. Only for justifiable reasons, and with management

approval. may records be removed from RMP control. When this

does occur, the records are inventoried prior to release, then

reinventoried and inspected when the records are returned.

Procedure RMP 1.2.4, " Destruction of Records Retention Time

Complete," describes the controls for the eventual destruction

of some records. When the required retention time for a record

has been satisfied, notice is given to all related

organizations of the intent to dispose of the record. All

organizations must approve before the record is destroyed. A

similar process is employed when such records are held by

others, a vendor for example.

The NRC inspector. selected 14 types of records for inspection.

The records selected included plant incident reports, deferred

test reports, safety review committee meeting minutes, startup

reports, deficiency reports, corrective action reports, and

special test reports. These records were properly classified,

readily retrievable, properly filed, and stored as required.

The NRC inspector found the program for accumulation and

storage of operations records to be in accordance with

requirements, technical specifications, and FSAR commitments.

No violations or deviations were identified during the

inspection of the implementation of this program.

12. Tests and Experiments for Operations (35749)

This portion of the inspection involved the review of the

applicant's quality assurance program related to testing and

experiments. During the inspection, the NRC inspector reviewed

the following procedures:

. STA-401, Revision 15, " Station Operations Review

Committee," dated March 16, 1989.

. STA-418, Revision 0, " Joint Test Group," dated February 2,

1988.

. STA-602, Revision 5, " Temporary Modifications," dated

April 3, 1989.

. NEO 3.12, Revision 1, " Safety Evaluations," dated March 1,

1989.

During the review, the NRC inspector verified that the

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applicant has established measures for the review of proposals

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for conducting plant tests and experiments involving

safety-related components, systems or structures, and

, operational conditions which differ from those described in the

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FSAR. Test and experiment proposals are reviewed, approved and

authorized by responsible plant managers and performed in

accordance with approved written procedures. Adequate controls

have been established to assure complete, comprehensive review,

and approval of test procedures and the accomplishment of

written safety evaluations pursuant to 10 CFR Part 50.59.

Furthermore,_the applicant has assigned responsibilities for

assemblage and conductance of the station operations review

committee (SORC) and for periodic summary reporting of 10 CFR 1

Part 50.59 type tests and experiments. During the above I

review, the NRC inspector noted that whereas Procedure STA-401,

defines criteria which constitute a quorum of the SORC, the .

procedure did not specifically require that the responsible j

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discipline SORC member / alternate attend the SORC review (e.g.,

the. electrical maintenance manager / alternate should be present

1 during 10 CFR Part 50.59 safety evaluation reviews involving

electrical issues). This concern was noted to the applicant as

an observation. In addition, the NRC inspector noted that the

applicant's procedures involving 10 CFR Part 50.59 safety

evaluations do not reflect the guidances set forth in the

NUMARC/NSAC 10 CFR Part 50.59 guidance document. In d.iscussion

with applicant personnel, this matter is under review and

revisions to existing procedures will be made. Review of the

revised procedures (e.g., STA-401, STA-602, NEO-312, et.al.)

for adequacy and action concerning the SORC quorum will remain

an open item (445/8932-0-03).

13. Measuring and Test Equipment Program for Operations (35750)

During this report period, the NRC inspector reviewed and

verified that the QA program developed and implemented by the

applicant relating to the control of measuring and test

equipment (M&TE) is in conformance with reg?>1atory

requirements, commitments (in the application) and industry

standards.

The NRC inspector reviewed the following TU Electric procedures

developed to ccmply with the requirements of 10 CFR Part 50,

Appendix B, Criterion XII, and described in Chapter 17 of the

FSAR:

NEO-328, " Control of Measuring and Test Equipment."

NQA-3.28, " control of Measuring and Test Equipment."

STA-608, " Control of Measuring and Test Equipment."

These procedures provide the required control of the facility's

M&TE lab both during the construction phase and subsequent

plant operation. Included in these procedures were

requirements for: identification for each item and the

calibration status; traceability to a calibration source;

as-found calibration data; identification of standards used;

identification of calibration procedures used; limitations on

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[ use; date of calibration and next required calibration date;

! and name of individual performing calibration. The NRC

inspector verified the calibration standards used and their

traceability to nationally recognized standards. In all cases

reviewed by the NRC inspector, the instrument used as a

calibration standard had an error rate several times less than

the instrument being calibrated, controlled calibration

procedures were available, and records indicated a well

established calibration schedule. TU Electric personnel are

currently assimilating Brown and Root's M&TE responsibilities

and equipment into their program. This influx of equipment is

being entered on TU Electric's computer aided tracking system

which records (through bar code identification) the

log-in/ log-out of all M&TE equipment; limitations on use; the

identification of all end user personnel; and present status

(i.e., lost, stolen, out of calibration, etc.).

The NRC inspector-reviewed 12 M&TE packages and associated

equipment'and found them to be an accurate representation of

the above requirements; however, the NRC inspector did have a

question concerning the apparent failure of TU Electric to

issue M&TE equipment to only qualified and authorized

personnel. TU Electric explained that only authorized QC

inspector personnel could sign off those items requiring M&TE

equipment usage and that this is controlled by the appropriate

QC procedures. The NRC inspector reviewed QC procedures and

concurs with-this explanation. No violations or deviations

were identified in this inspection.

14. Applicant Meetings (92700)

The NRC inspectors attended applicant meetings concerning site

activities and implementation of various site programs.

Meetings attended during this reporting period included the QA

Overview Committee meeting and an exit meeting for audit EFE

89-04.

Audit EFE 89-04 dealt with the incorporation of validated

design data into the applicant's programs for testing and

maintenance. The audit team presented the results of their

audit by first establishing the design basis documents which

contain the validated design data and second reviewing the

applicable implementing test or procedure to determine that the

design data or requirements were properly included. The audit

covered approximately 15 review sheets originally prepared by

Stone and Webster Engineering during their EFE activities. The

.NRC inspector determined that the information provided at the

exit indicated that the audit had been performed to an

appropriate depth and the audit conclusions were proper.

No violations or deviations were identified.

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115. Lopen' Items

open items are matters which have been' discussed with'the

applicant, which.will be reviewed 1further by the inspector,'and

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which involveLsome action on the part.of the.NRC or applicant

orEboth.. Two open items disclosed during the inspection are

discussed.in. paragraphs 9 and 12.

-16. Exit' Meeting (30703)

An exit meeting was. conducted June 6, 1989, with the

applicant's: representatives ~ identified in paragraph 1 of this

report. No written material was'provided'to:the. applicant by

the inspectors during this reporting. period. The applicant did

not identify as proprietary any of the materials provided to or

reviewed by the inspectors.during this. inspection. .'During this- l

meeting, the NRC inspectors. summarized the scope'and findings

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of the inspection.

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