IR 05000445/1989016

Insp Repts 50-445/89-16 & 50-446/89-16 on 890308-0404.No Violations or Deviations Noted.Major Areas Inspected:Actions on Previous Insp Findings,Followup on Violations,Svc Water Corrective Actions & Mgt Meetings

ML20245C543
Person / Time
Site:	Comanche Peak
Issue date:	04/14/1989
From:	Livermore H, Phillips H Office of Nuclear Reactor Regulation
To:
Shared Package
ML20245C539	List: IR 05000445/1989016 ML20245C538
References
50-445-89-16, 50-446-89-16, NUDOCS 8904270206
Download: ML20245C543 (7)

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l U. S. NUCLEAR REGULATORY COMMISSION l- ,

. < OFFICE OF NUCLEAR REACTOR REGULATION NRC Inspection Report: 50-445/89-16 Permits: CPPR-126 50-446/89-16 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit

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Expiration Dates:

Unit 1: August 1, 1991 Unit 2: August 1, 1992

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Applicant: TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility N.u.:- Comanche Peak Steam Electric Station (CPSES),

Units 1 & 2 Inspection At: Comanche Peak Site, Glen Rose, Texas-Inspection Conducted: March 8 through April 4, 1989 Inspector: ( . 6 )# 9'- / V- 3'9

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H. S. Phillips, Senior Resident Inspector Date Construction Reviewed by: / fM.44 dL6 @ // -6 9 '

H. H. Livermore, Lead Senior Inspector Date 990427[h PDR

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Inspection Summary:

Inspection' Conducted March 8 through April'4, 1989-(Report 50-445/89-16; 50-446/89-16)

Areas Inspected: Unannounced, resident safety inspection included (1) applicant's actions on. previous inspection' findings, (2) follow-up on-violations, (3) service water corrective action, and_(4) management meeting Results: Within the areas inspected, no violations or deviations were. identified. With respect to corrective action on the Service Water System (SWS) QA concerns are identified in paragraph )

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. 3 DETAILS I Persons Contacted

• R. W. Ackley, Jr., Director, CECO

• L. Barker, Manager, Engineering Assurance, TU Electric

• D..P. Barry, Senior Manager, Engineering, Stone and Webster Engineering Corporation (SWEC)

• Beck, Vice President, Nuclear Engineering, TU Electric

• M. Blevins, Manager, Technical Support, TU Electric

• H. Bruner, Senior Vice President, TU Electric

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

• T. Conly, APE-Licensing, SWEC

• G. Creamer, Instrumentation & Control (I&C) Engineering Manager, TU Electric

• G. Davis, Nuclear Operations Inspection Report Item Coordinator, TU Electric

• C. Finneran, Jr., Manager, Civil Engineering, TU Electric

• A. Fonseca, Deputy Director, CECO

• G. Guldemond, Manager of Site Licensing, TU Electric

• L. Heatherly, Licensing Compliance Engineer, TU Electric

• C. Hicks, Licensing Compliance Manager, TU Electric

• B. Hogg, Engineering Manager, TU Electric

• Husain, Director, Reactor Engineering, TU Electric

• D. Karpyak, Nuclear Engineering, TU Electric

• J. Kelley, Manager, Plant Operations, TU Electric

• W. Lowe, Director of Engineering, TU Electric

• M. McAfee, Manager, QA, TU Electric

• G. McBee, NRC Interface, TU Electric

• W. Muffett, Manager of Engineering, TU Electric

• F. Ottney, Program Manager, CASE

• D. Redding, Executive Assistant, TU Electric

• M. Reynerson, Director of Construction, TU Electric

• J. Riggs, Plant Evaluation Manager, Operations, TU Electric

• H. Saunders, EA Evaluations Manager, TU Electric

• B. Scott, Vice President, Nuclear Operations, TU Electric

• E. Scott, Manager, Startup, TU Electric

• C. Smith, Plant Operations Staff, TU Electric

• R. Steelman, Licensing, TU Electric

• B. Stevens, Manager, Electrical Engineering, TU Electric

• F. Streeter, Director, QA, TU Electric

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

• G. Tyler, Director of Projects, TU Electric

• D. Walker, Manager of Nuclear Licensing, TU Electric

• G. Withrow, EA Systems Manager, TU Electric

• R. Woodlan, Docket Licensing Manager, TU Electric

• E. Wren, Assistant Director QA for Administration, TU Electric

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l The NRC inspector also interviewed other applicant employees l during this inspection period.

• Denotes personnel present at the April 4, 1989, exit meetin . Applicant Action on Previous Inspection Findings (92701)

i (Closed) Open Item (445/8847-0-03): Engineering responsibility for quality assurance (QA) requirements questioned. The NRC concern was that engineering may erroneously classify safety-related procurement. On March 15, 1989, the NRC inspector met with TU Electric's licensing personnel. They presented additional information and answered questions in regards to this issu Specifically, after procurement problems were found TU Electric began auditing commercial and nonnuclear procurement to verify that engineering correctly classified nonnuclear versus safety-related procurement for items and services. They estimated that they audited less than 10% of the requisitions and contracts specifically in the area where QA has no in-line review function. The applicant found only minor problems during the audits. This item is close (Closed) Open Item (445/8901-0-01): Offsite contractors, vendors, and suppliers will not always accept 10 CFR Part 50, Appendix B, QA program and 10 CFR Part 21 defect reporting requirements. On March 15, 1989, the NRC inspector met with TU Electric. TU Electric presented information and answered questions on this matter. They stated that the vendors could not always fulfill all of the Appendix B or defect reporting requirements, but TU Electric had developed alternative methods to purchase systems, components, parts, and services needed for safety-related applications and for continued plant operatio Such alternative methods may include destructively testing and inspecting a portion of parts procured. TU Electric has developed programmatic controls to enable them to procure needed items. This item is close . Follow-up on Violations / Deviations (92702) (Open) Violation (445/8847-V-01a): Failure to establish QA and technical requirements in procurement documents for coating remova (open) Violation (445/8847-V-Olb): Failure to establish adequate controls for the coating removal proces )

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, (Open) Violation (445/8847-V-01c): Failure to provide .

adequate QA/QC procedures for the coating removal i proces (Open) Violation (445/8847-V-01d): Failure to take i corrective action relative to coating problems and coating remova Note: The above violations are reviewed and discussed in paragraph 4 belo . Evaluation of Corrective Action Concerning Service Water System Piping (92702, 49063, 49065, 35065)

The NRC inspector reviewed TU Electric's response (TXX-89070 dated February 8, 1989) to NRC Notice of Violation (NOV)

50-445/88-47; 50-446/88-42 dated January 9, 1988. The NRC inspection report (50-445/88-47; 50-446/88-42) which supports the NOV was issued on September 2, 1988. The Enforcement l

Conference was conducted on November 9, 1988, in Rockville, Marylan The inspector selected one area of the response (paragraph 2, Corrective Steps Taken and Results Achieved on page 3 of the attachment to the response) to perform a field follow-up inspection. This part of the response stated that TU Electric followed-up to determine if other Code V procurement had experienced problems similar to the removal of coating from the SWS piping. For Code V procurement, the TU Electric QA program must substitute for the vendor's inability or refusal to provide a 10 CFR Part 50, Appendix B, QA program or 10 CFR part 21 defect reporting system. The results of the TU Electric review of Code V procurement were documented in internal memorandum NE-22156 dated September 30, 198 The NRC inspector found that six procurement (Contract i Nos. CPF-14220-S, CPF-13597-S, CPF-13593, 661-74054, l

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661-74340, and 661-74038) for vendor services were for work activities on emergency diesel generators, jacket water heat exchanger, component cooling water (CCW), steam generators, j and vacuum pump seal water systems. The referenced l TU Electric memorandum identified QA program deficiencies such j as failure to identify QA requirements, provide adequate i verification plans, clearly define organizational interfaces, j and require that defects Le reported. These deficiencies l were very similar to the service water system proculE3ent deficiencies. However, the TU Electric memo concluded that the quality involvement was better than service water and activities were properly controlled and conducted. The NRC inspector questioned why these negative findings (which directly related to pending NRC enforcement matters and appeared to be generic) were not thoroughly identified and I

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discussed during the public meeting at the site on September 13, 1988, and at the Enforcement Conference referenced above. The applicant representative had no answe The NRC inspector performed a field inspection to determine if the procurement J,cuments contained sufficient technical requirements and (A verification plans. The inspector concluded that the procurement packages / documents did not include comprehensive and adequate technical requirements or QA verification plans for the six procurement. The contracts for the subject services did not explicitly address the requirement for the vendor to identify and disposition nonconforming conditions. In these cases, TU Electric must substitute and implement the 10 CFR Part 50, Appendix B, or 10 CFR Part 21 reporting requirements for the vendor. The vendor must be made aware in the requisition and contract that work must be performed under these requirements as implemented by the TU Electric QA progra The NRC inspector reviewed records in the construction and QA record center vaults to determine if work activities for the referenced contracts were properly controlled and conducte The available records reviewed showed that the criteria of Appendix B to 10 CFR Part 50 had not been fully implemente The interfaces, responsibilities, and duties of TU Electric, contractor, and vendor organizations were not clearly described and defined with respect to QA and technical program.1/ activitie As a result of this review the NRC inspector provided 16 questions about the implementation of criteria of 10 CFR Part 50, Appendix B, and 10 CFR Part 21 reporting requirements for each of the contracts. The applicant was still working on the questions at the end of the inspection perio The NRC inspection of SWS corrective action is not complete, and will continue during the next inspection period. The violations concerning the subject NOV referenced in paragraph 3 will remain ope . Management Meetings (30702)

on March 17, 1989, R. F. Warnick met with W. G. Counsil, J. Cahill, A. B. Scott, and H. D. Bruner to discuss current management topics. Major subjects discussed were as follows:

(1) The recent clarification of the CASE /TUE/NRC Joint Stipulation in regards to meetings open to the publi (2) The NRC's desire to review the list of preoperational tests that will not be repeated by TU Electri ,-. _ . - _ _ _ - _ _ _ _ _ _ _ _ _ _

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(3) The NRC tracking of TU Electric's status of preparedness

for licensin (4) The items Mr. Warnick considers to be big issues that require resolution and/or closure (Unit 1 cold hydro / CASE dispute, closure 6f the large number of items remaining open, closure of SSW coating removal issues, and welding fit-ups).  ;

(5) TUE/NRC interfac . Exit Meeting (30703) 1 An exit meeting was conducted April 4, 1989, with the applicant's representatives identified in paragraph 1 of this report. No written material was provided to the applicant by the inspector during this' reporting period. The applicant did not identify as proprietary any of the materials provided to or reviewed by'the inspectors during this inspection. During this meeting, the NRC inspectors summarized the scope and findings of the inspectio 'l i

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