ML20005E715
| ML20005E715 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/05/1990 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-90001, NUDOCS 9001100172 | |
| Download: ML20005E715 (14) | |
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Log # TXX-90001 File # 10010
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Ref. # 10CFR50.57 L
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1 7t# ELECTRIC January 5, 1990 OrEa?$aNr U. S. Nuclear Regulatory Commission Attn:' Document' Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION'(CPSES)
DOCKET NO. 50-445 RESPONSE TO NRC INSPECTION REPORT 50-445/89-200 COMANCHE PEAK'0PERATIONAL READINESS ASSESSMENT TEAM INSPECTION REF:. Letter November 16, 1989 from Dennis M. Crutchfield d
of the NRC to W. J. Cahill, Jr.
Gentlemen:
x The referenced letter identified several actions to be taken before your Operational Readiness Assessment Team inspection could be completed.
~ Enclosure I to this letter provides the current status of these actions.
. Enclosure 2 identifies the current status of other activities to support issuance'of an operating license for CPSES Unit 1.
CPSES Unit I is substantially complete in accordance with the License
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. Application and the FSAR (as amended). The Operations Preparation period was entered'on December 27, 1989 to assure that operational phase programs are p
functional prior to fuel load and provide assurance that the actions L
prescribed in the referenced letter have been successfully completed.
In addition, TU Electric's internal Operational Readiness Team has completed its assessment and has concluded that CPSES Unit 1 is ready for fuel load and operation up to 5% rated power, with minor exceptions (as described in the Enclosures to this letter), to be completed by January 22, 1990. Systems required for fuel load are functional and will be declared OPERABLE by y
January 22, 1990. Accordingly, TU Electric has concluded that CPSES Unit 1 will be ready for the NRC's Operational Readiness Assessment Team to return on (d8 i
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- TXX-90001 January 5, 1990 Page 2 of 2 January 22, 1990 to complete the team's inspection. - TU Electric requests that an Operating License authorizing fuel load and operation up to 5% of rated
- power be issued subsequent to your confirmation of TU Electric's operational
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readiness.
Sincerely, William J. Cahill, Jr.
JDS/vid Enclosures Mr.-R. D. Martin, Region IV c
Resident Inspectors, CPSES (3) b I
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_ to TXX-90001 January 5, 1990
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Page 1 of_4-4 Status of Actions to be Taken Prior to Completion 'of the Operational Readiness Assessment Team Inspection Activities Action:
j Evaluate and resolve the specific concerns identified by the inspection team and listed in Enclosure 1 (of the NRC letter of November 16,1989).
In addition, perform a broad-based assessment of the adequacy and implementation of all of your programs to identify and resolve any similar deficiencies.
Status:
The Executive Vice President, Nuclear Engineering and Operations created an internal Operational Readiness Team (ORT) to assist in evaluating the ability of Comanche Peak personnel, programs, and procedures to support safe operation.
The ORT consists of nuclear professionals with significant experience in the management, operation, maintenance, and support of commercial nuclear power plants.
The ORT conducted its evaluation primarily by observing the implementation of ths programs and procedures needed to operate a nuclear power plant. One input to the ORT effort was the results of a Quality Assurance Department (QA) Operational Quality Assessment Team (0QAT) effort and the CPSES response to these results. ORT also monitored the implementation of the corrective actions taken as a result of the NRC's Operational Readiness Assessment Team visit to verify resolution of each issue raised by the NRC team.
This included both the concerns listed in Enclosure 1 of the November 16, 1989 letter, and verbally identified items during the inspection.
Observations and concerns from the ORT were provided to TV Electric Management for action.
Implementation of TU Electric actions are being monitored by the ORT.
TU Electric has addressed the concerns listed in Enclosure 1 of the November 16, 1989 letter and those verbally identified during the inspection and has completed (or will complete by January 22,1990) actions required for fuel load and operation up to 5% rated power, except where constrained by plant conditions or material availability.
Information relative to the resolution of the NRC concerns and of the l
ORT's findings will be available for review by the Operational Readiness Assessment Team.
Action:
Review previous commercial experience levels of your mid-level managers and licensed operating staff, and take steps to:
a.
Reduce the maintenance backlog and ensure that all systems are functional for power operations.
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i Enclosure I to TXX-90001
. January 5, 1990 i
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Page 2 of 4_
Evaluate augmentation of the management staff with experienced-
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personnel, c.
Focus attention on plant-labeling adequacy by examining the status of the present plant labeling and evaluating the need for immediate corrective actions, and by commiting to implementing labeling upgrades before the completion of the first refueling outage.
Status:
Item a.
The maintenance backlog has been reduced to an acceptable level. The items that must be completed in order to load fuel and to operate Unit I up to 5% rated power have been completed or will be completed by January 22, 1990, except.for items constrained by plant condit.ons or material availability. The remaining items in the maintenance backlog have been evaluated for impact on fuel load and operation up to 5% rated power.
The evaluations performed demonstrate that these items will not affect the safe reliable operation of Unit 1.
These work items will not provide undue burden on the operations staff or constrain the startup schedule. The justification for these items will be available for NRC review.
Plant systems required for fuel load and operation up to 5%
rated power will be functional for power operation by January 22, 1990, except as constrained by plant conditions or material availability.
Item b.
As part of the overall assessment of its readiness to operate CPSES Unit.
1, TU Electric reviewed the experience levels of personnel in key operating organizations. Organizations included in this review were Operations, Technical Support, Maintenance, Radiation Protection and Plant Evaluation. This review demonstrated that the experience level in each of these organizations meets or exceeds CPSES commitments to l
industry standards. However, in order to provide additional assurance of a safe and smooth initial startup, TU Electric has taken a number of steps to increase the immediate availability of additional personnel with commercial nuclear operating experience. Specifically, experienced p
advisors have been assigned to the Vice-President of Nuclear L
Operations, the Plant Manager, and the Managers of Operations, Technical Support, Maintenance, Radiation Protection, Instrumentation and Control, and Chemistry.
In addition, duty managers (TV Electric personnel) have been assigned to each operating shift.
The duty managers either have previous commercial nuclear experience or will be assisted by one of the previously mentioned advisors. Collectively, the 13 duty managers and advisors possess 116 years of commercial nuclear experience.
Six have been previously licensed on a commercial Westinghouse pressurized water reactor, including one who is a former nuclear plant manager.
In addition to managerial advisors and duty managers, individuals with l
previous licensed commercial nuclear operating experience and control l
room experience will be assigned to provide 24-hour per day coverage in the control room to support the shift supervisor. Three such individuals have been assigned and TV Electric is actively pursuing a fourth individual.
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R Enclosure"I to TXX-90001-January 5,-1990 7
Page 3 of 4-l Overall, TV Electric believes that the commercial nuclear _ experience' which exists in its operatir.g-organizations, as augmented, provides additional. assurance that Comanche Peak will achieve a safe and smooth initial-startup.
Item c.
e TU Electric has initiated an aggressive program for-improving the-labeling of CPSES Unit I areas and equipment. Approximately 120,000 s
labels will be placed in the plant as part of this program. The labels j
are being produced and installed in accordance.with a priority
- established by the Nuclear Operations organization.
Door labels and labels that identify major equipment in rooms and areas are the first priority; followed by valves, instrumentation, and flow arrows.
Labeling in the containment building is being performed early in the schedule to maximize the number of labels installed before access to this area is limited.
o This labeling program will be fully implemented before the completion of the first refueling outage.
Action:
The remainder of the ORAT inspection will be performed after you have:
a.
Demonstrated that all systems can function by the successful performance of all technical specifications surveillance tests that are required for t
5' percent power operations--to the extent they can be performed before L.
fuel load.
b.
Decided that the facility is operationally ready for low power operation, including completion of the items above, and advised the NRC that the facility is ready for the team to return and confirm your-operational readiness assessment.
Status:
Item a.
CPSES Unit I and common systems, rooms and areas have been turned over from Construction and Startup to Operations. The Station operating procedures required for control of work, for system operability, for meeting Technical Specification requirements and for maintenance have been implemented.
By January 22, 1990, surveillances on systems required for Modes 6 through 2 will be completed at least once except where constrained by plant conditions.
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Enclosure:
1-to TXX-90001 January 5, 1990 iv.
'Page 4 of.4
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Item b.
As of. this date, the. design and construction of Unit I are substantially complete in accordance with the Final Safety Analysis Report (FSAR) with technically justified minor exceptions. TU Electric entered into an Operations Preparation period on December 27, 1989. The Operations Preparation period completes a comprehensive program to-assure an orderly and controlled transition from construction oriented conditions-to the operational esivironment needed for fuel load and low power operation. TU Electric has concluded that CPSES Unit,1 will. be ready for the NRC's Operational Readiness Assessment Team to return on January 22, 1990 to complete-the team's inspection.
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! January 5, 1990-Page 1 of.6 j
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' Additional Information Sunoortina Readiness for Fuel load i
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A.
Ogprational Readiness.
- i In'mid-1988, a' structured operational readiness program was initiated i
/K within Nuclear Operations. A procedure was developed and utilized to guide a disciplined self-evaluation of the state of operational
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readiness by each of the organizational units within Nucl_ ear Operations.
Nuclear Operations identified capabilities required-to support the successful licensing, startup and operation of CPSES Unit 1, assessed existing capabilities, and_ defined actions to establish or enhance capabilities that were not fully in place. These assessments included consideration of staffing, qualifications, programs, procedures and facilities, as required-to meet operational objectives.
In late 1988, a similar structured program was initiated for the Nuclear Engineering and Operations-(NE0) organizational units outside of Nuclear Operations with functions necessary to support the licensing, start-up, and operation of Unit 1.
Each such organization also performed a self assessment of'its capabilities and status, and developed action items, as needed.
1 In February 1989, NE0 operational readiness developmental activities were brought under the direction of the Vice President, Nuclear Engineering. Action plans were refined and completed.
In addition, the focus of the programs shifted to achieving successful implementation of action items that addressed processes and procedures involving interfaces between multiple organizations. Task teams were established to support the development of such processes and procedures and to arrange.for and conduct structured walk-throughs (table-top exercises) for selected activities to assure the smooth flow of work across interfaces. The efforts of the task teams on interfaces have been completed. Operability drills are currently being conducted simulating actual operating conditions and exercising both personnel and programs, including interdepartmental interfaces.
The operational readiness program calls for the issuance of a summary statement by the manager of each organizational unit within Nuclear Operations prior to each major milestone during the startup of Unit 1 attesting to the readiness of the organizational units for that milestone.
Readiness statements for operation up to 5% rated power either have been issued or will be issued by January 22, 1990, except to the extent the manager's statement is dependent upon an activity that will take place after fuel load.
In addition, the manager of support organizations outside of Nuclear Operations has issued a statement attesting to the readiness of his unit to support startup and operation of CPSES Unit 1.
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Enclosure'2 to TXX-90001J January 5, 1990 Page 2 of 6-B.
- Doerational-Quality Assessment Team TU Electric's Quality Assurance Department established an Operational Quality Assessment Team (0QAT) to provide reasonable assurance that the programs to support CPSES operations have been implemented as required by applicable. regulations and procedures.
The 0QAT con::isted of approximately 40 personnel, including operationally experienced personnel, and assistance from other utilities. -The team reviewed a broad-spectrum of areas required for plant operations for program adequacy and implementation. NRC inspection modules, INPO good practices, previous NRC areas of concern, industry guidelines, and other applicable information were considered in development of the assessment plan for each area.
Items which require action prior-to fuel-load and o)eration up to-5% rated power have been identified by 0QAT and have eitier been completed or are scheduled for completion prior to January 22, 1990. Those items for which remedial actions have been scheduled beyond fuel load have been reviewed and determined to have no adverse effect on plant-operations.
C.
Preooerational/Prestart Testina i
Preoperational/prestart tests have been substantially completed in accordance with the FSAR (as amended) or will be completed by January 22, 1990. TU Electric has determined that limited testing will be required after fuel' load. This testing has previously been described to the NRC. in letter logged TXX-89824, dated December 6,1989.
Technical evaluations have been performed demonstrating that the affected activities can be delayed without impact on the safe and reliable operation of Unit I during the low power phase of the plant startup program. Appropriate measures are in place.to assure that the activities are planned and scheduled in conformance with the needs of startup and power ascension of Unit I and that performance of the act.ivities will not adversely affect safe startup and operations.
D.
Plant Procedures l
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Procedures required for fuel load and power operation up to 5% rated l
power will be issued by January 22, 1990.
E.
Exemotions The FSAR documents conformance of Unit 1 to the NRC rules and regulations set forth in 10CFR50, including Appendix A (General Design Criteria). Attachment A to this Enclosure lists the exemptions which have been requested in prior correspondence.
F.
Licensed Personnel l
The current number of licensed operators exceeds that required to fulfill the shift complement levels of the CPSES Technical Specifications for Unit 1.
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Endlosure[2. to 'TXX-90001 '
, January 5,-.1990
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G.
Nuclear Reactor Reaulation (NRR) Licensina Issues TU Electric has. maintained communications with the NRR Licensing Project Manager. to ~ assure expeditious and satisfactory resolution of licensing.
. issues.
Licensing issues are captured in:the CPSES Safety Evaluation i
Report and its supplements. The most recent-supplement, number 21, identifies ten (10) Outstanding Issues, eight (8) Confirmatory Issues and eight (8) potential License Conditions applicable to Unit 1.
The Outstanding and Confirmatory Issues applicable to Unit I are closed, except for the three (3) items listed in Attachment B to this Enclosure.
TU Electric expects that these three-(3) items will be resolved, but that additional work may be required beyond fuel load. TU Electric expects that only the three (3) potential License Conditions = listed in Attachment B to this Enclosure will remain at fuel load.
In addition to-the Safety Evaluation Report and its Supplements, the NRC staff occasionally requests additional information via letters addressed to TU Electric. TV Electric has responded to such letters received to date.
On occasion, the NRC staff requests specific action or information via
-Generic Letters. Generic Letters received to date have been resolved,
.except for Generic Letters 88-17, 88-20, 89-10 and 89-13, which are discussed in Attachment B to this Enclosure.
The NRR licensing issues that remain open will not impact fuel load or operation up to 5% rated power.
H.
Desian and Construction Assurance Reviews.
l CPSES has undergone a series of extensive reviews beyond the normal Quality Assurance Program to assure'that CPSES design and construction l
o conform to applicable requirements. The current status of each of the major reviews for Unit 1 is as follows:
'1.
Corrective Action Program (CAP)
The CAP was a broadly based program which had the purpose of demonstrating the compliance of systems structures components and their associated design documentation with FSAR and licensing commitments. The three major components of the Corrective Action Program are Design Validation, Post Construction Hardware Validation Program (PCHVP), and Final Reconciliation.
Design Validation was completed in January,1988 and the results were reported in 11 Project Status Reports (PSRs).
The PCHVP consisted of field verification of hardware and technical dispositions of identified issues.
PCHVP work is complete.
Final Reconciliation is also complete.
- Enclosure 2 to TXX-90001 I
z.I January 5, 1990
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- QA Technical Audit Program (TAP)
- TAP-has completed the required technical audits and six (6) c findings related to Unit 1 remain open.
These findings will either be closed prior to January 22, 1990 or evaluated and
~ determined to have no impact on operations.
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'3.
Engineering Functional Evaluation (EFE)
The Engineering Functional Evaluation (EFE) is comprised of four modules for the purpose of assessing (1). design completion I
. activities; (2) design data utilizing in testing; (3) design data l
utilization in maintenance and operations;-and (4) operating plant L
design control. Module 1 is. complete.
Modules 2 and 3 are I
complete with the exception of closure of one (1) open item and i
records completion, both of which will-be completed prior to.
January 22,1990. -Module 4 is complete with the exception of the implementation evaluation portion which will be completed after fuel load as described to the NRC in letter logged TXX-89768 dated l
October 19,.1989, and the completion of records which will be p
accomplished following the implementation evaluation.
4.
CYGNA Over a period of approximately six (6) years, CYGNA conducted an
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-Independent Assessment Program that consisted of a comprehensive and detailed independent review of design programs and design adequacy of CPSES.- It included assessment of the design control systems of TU Electric and its principal contractors, verification of implementation of selected elements of the design control i
systems, assessment of the design adequacy of selected critical safety-related systems, and verification of selected as-built L
configurations.
In its " Independent Assessment Final Report" (TR-L 84056-01,4/11/89), Cygna concluded that all of its findings and identified issues have been or are being satisfactorily resolved under TU Electric's various corrective action programs; that-current design programs included appropriate. measures and controls and conform to pertinent regulatory requirements; and that the CPSES design meets applicable requirements and license commitments and conforms to accepted industry standards if current programs are properly implemented.
5.
Comanche Peak Response Team (CPRT)
CPRT was charged with the mission of advising TU Electric management whether there is reasonable assurance that all design and construction defects that would have prevented the facility from being capable of operating in conformance with NRC Regulations have been detected and appropriate corrective actions for such defects have been defined. The CPRT conducted an extensive four year third party investigation and identified a number of findings in the design, construction, and quality program areas. Corrective actions that addressed these findings, the underlying root causes and associated generic implications were recommended to the Project. The Project committed to
[ Enclosure 2toTXX-9000).
- January 5,-1990-Page 5 of 6-r
' implement corrective actions that were acceptable to the CPRT.
CPRT summarized investigative and overview activities in the Collective Evaluation Report issued December 21, 1987 and the Collective Significance Re> ort issued February 26, 1988. With the
. successful completion of tie overview effort,.the Senior Review Team of the CPRT has determined that'the CPRT mission'has been accomplished, the reasonable assurance goal has been achieved and CPRT Program Plan objectives have been met.
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-Inspection. Bulletin and Reportable Items TU Electric maintains formal systems for the tracking and resolution of NRC inspection items, 10CFR50.55(e) items, 10 CFR Part 21 items, and NRC Bulletins..TU Electric actions for those items required for fuel load and operation up to 5% rated power are substantially complete. These actions will be completed consistent with the fuel load and power ascension schedule and commitments to the NRC.
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Technical Soecifications CPSES Technical Specifications for Unit I have received substantial internal review. The NRC Staff issued Final Draft Technical Specifications for Unit I with its letter of March 17, 1989.
In letters dated April 17, and May 15, 1989, TV Electric provided corrections to these Technical Specifications and certified that, with these corrections,- they accurately reflect the as-built plant (as it will be upon completion of design modifications in progress).and the FSAR.
In subsequent correspondence, TU Electric has kept the NRC Staff informed of changes to the Technical Specifications.
K.
Emeraency Preparedness The NRC reviewed the CPSES onsite emergency plan in its appraisal of t
l June 5-9, 1989. TU Electric actions required prior to fuel load p
resulting from this review will be completed by January 22, 1990. A schedule has been provided per letter logged TXX-89716, October 2,1989, L
for the remaining actions required as a result of this review.
l On July 23, 1985, the Federal Emergency Management Agency (FEMA) approved, pursuant to 44 CFR 350, the Radiological Emergency Plan submitted by the State of Texas.
A successful full participation emergency exercise for onsite and offsite organizations was held at CPSES on July 25-26, 1989, in accordance with 10CFR50, Appendix E.IV.F.
In addition, a drill to complete demonstration of on-site accountability / evacuation was successfully conducted on October 27, 1989.
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_ January 5, 1990
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Security The NRC has reviewed and accepted the CPSES Physical Security Plan, 'the I
CPSES Safeguards Contingency Plan and the CPSES Security Training and Qualification Plan.
Its approval is expected to be published in Supplement 22 of the Safety Evaluation Report.
Security lockdown has been achieved. TU Electric has also addressed the action items J
~ esulting-from NRC inspections ~and invited the NRC back to CPSES'to r
review the actions taken by TV Electric on January 8,1990.
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Insurance To satisfy NRC license requirements for Unit 1 of CPSES,.TV Electric has arranged for or received commitments from appropriate insurance carriers to provide 1) financial protection as required by 10CFR140.11(a)(4) in the form of the nuclear energy liability insurance policy set forth in 10CFR140.91, Appendix A and the secondary financial protection policy set forth in 10CFR140.109, Appendix I, 2) on-site property damage insurance required by 10CFR50.54(w) in the form of nuclear property _
insurance policies in the maximum amounts of' insurance currently available from American Nuclear Insurers / Mutual Atomic Energy Liability.
Underwriters, jointly, and Nuclear Electric-Insurance Limited and 3) evidence of guarantee of payment of deferred premiums 'under 10CFR140.21.
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Attachment A to Enclosure-2 of TXX-90001 January 5, 1990 Page 1 of 1 REQUESTED EXEMPTIONS SUBJECT REFERENCE REGULATION LETTER Dalf Criticality 10CFR70.24 TXX-89438 June 30, 1989
- Monitoring Requirements Decommissioning Funding 10CFR50.33(k)
TXX-89508 July 28, 1989 Plan 10CFR50.75 Airlock Leak Testing
_ 10CFR50 Appendix J TXX-4618 January 20, 1986 T
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Attachment B to Enclosure 2 of TXX-90001 i
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Page 1 of 1 l
NRR LICENSING ISSUES OUTSTANDING ISSUES STATUS-Control Room design.
Several minor. Human Engineering j
(Section 22, I.D.1)
Deficiencies may remain open at fuel load.
SPDS As a result of an NRR audit, TU Electric (Section22,I.D.2) has agreed to include additional radiological information on the SPDS at the first refueling outage, i
CONFIRMATORY ISSUES STATUS ISI Program Appraisal by the NRC staff of the ISI (Sections'5.2.4.1 and program is required prior to the first 6.6.1) refueling outage POTENTIAL LICENSE CONDITIONS STATUS Control of Mineral Exploration This is expected to remain a license (SER Sections 2.1.2, 2.2 and 2.3) condition.
Fire Protection Program Required by NRC staff
.-(Section 9.5.1)
Security Program Required by NRC staff (Section13.6)
GENERIC LETTERS STATUS (88-17) Reduced inventory Several committed actions extend beyond RHR Performance Indicators fuel load and will be completed on a scheduled agreed upon with the NRC staff.
i (88-20) Individual Plant TU Electric is responding to this Generic Examination Letter in a manner consistent with NRC l
established criteria and schedules.
(89-10) Safety Related TU Electric is committed to respond on a Motor Operated Valve schedule consistent with the requirements Testing of the generic letter.
(89-13) Service Water TV Electric is committed to respond on a System Problems schedule consistent with the requirements of the generic letter.
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