IA-86-272, Discusses 851113-14 Audit of Comanche Peak Response Team Const Evaluation Program in Area Re Piping & Pipe Supports. Three Unresolved Items Listed
Text
N dP DEC 11 We Docket Nos.: 50-445/50-446 P.EMGRAhDUM FOR: Larry C. Shao, Manager Comanche Peak Project FRON: David Terao, Mechanical Engineer Comanche Peak Project
SUBJECT:
AUDIT
SUMMARY
OF CPRT CONSTRUCT 10h EVALUATION PROGRAM (PIP 1hG/PIPESUPPORTS)
~
On November 13-14, 1985, the staff and its consultant from Teledyne Engineering Services (TES) perfomed an audit of the CPRT Construction Evaluation Program in the area related to piping and pipe supports.
This portion of the program is currently being conducted by ERC as part of the overall QA/QC program to verify the adequacy and quality of construction of CPSES. The purpose of the staff audit was to gain an understanding of the sample population of piping and pipe supports reinspected by ERC. This acquired knowledge of the ERC population sample would enable the staff to assess the adequacy of the as-built documentation provided by TU6CO to Stone & Webster Engineering Corpora-tion (SWEC) for the requalification of piping systems. A list of the personnel interviewed is attached to this memorandum.
- Scope of hRC Stcff Audit l
l The staff reviewed approximately 10 each of the reinspection packages l for the following populations:
(1) Large Bore Piping Configuration t (2) Small Bore Piping Configuration I (3) Large Bore Pipe Supports (Rigid)
(4 (S) Large i Small Bore Bore PipePipe Supports Supports (Non-Rigid)
For each of the reinspection packages, the staff reviewed the checklist
! attributes reinspected by ERC and the types of deviations identified by ERC as noted in the Deviation Report (CR). -.
8610090229 PDR GARDE 86-272 FOIA 861003 PDR
~ b/
emes > . . . . . " " . . . "- - . " * " * " + " * * " " " " * " * " "
- DATWh "" * * **
- ForiFRM1AL RECORD COPY
4 L. Shao g W,
In addition, the staff discussed with ERC the process used to evaluate the safety significance of identified deviations. When a deviation is identified it is documented in a Deviation Report (DR). The DR is transmitted to the ERC Safety Significt.nce Evaluation Group (SSEG) and to TUGCO. The SSEG perfonns an evaluation on the deviation to ~ determine the need for population expansion. TUGC0 incorporates the devittion into its NCR system for trending and to evaluate the need for'siodifica-tions and reportability per 10 CFR 50.55(e).
NRC Staff Findings As a result of our review of the checklist attributes and deviation reports, the staff identified three unresolved items.
Piping Clearances in Grouted Penetrations The large bore and small bore piping configuration populations include a checklist attribute for piping clearances. The clearances reinspected by ERC were associated with the gap between the piping and adjacent components and structures. However, the treatment of grouted floor
_. and wall penetrations through which the piping traversed was not specific-ally addressed in the reinspection procedures. Because the piping isometric drawings (BRPs) do not inoicate where grouted penetrations exists, it is not clear whether an improparly grouted penetration would have been identified by ERC in their reinspection of clearances. This matter is considered to be an unresolved item.
Disposition of NCRs Using GhH Stress Analyses In reviewing the DRs for large bore pipe supports, the staff noted that several deviations were closed because the deviation had been previously resolved by an NCR disposition. However, the NCR disposition was based on previous Gibbs & Hill (G&H) piping stress analysis results.
The staff raised a. concern regarding 'the appropriateness of resolving ,
deviations by using previous NCRs which relied on G&H stress analyses for its disposition since the SWEC piping reanalysis can potentially result in piping responses with significantly different loads and displace-ments. This matter is considered to be an unresolved item.
Determination of " Safety-Significant" Items The staff discussed the determination of " safety-significant" items related to piping and supports which would cause a need for sample pcpulation expansion. The ERC Safety Significance Evaluation Group '
(SSEG) detemines whether an identified deviation is safety-significant.
The mewing of the phrase " safety-significant" by ERC is not directly associated with the ccnditions described in 10 CFR 50.55(e), but rather is only intended to denote a need for expansion of the sample population related to the construction evaluation program. For certain itdes (e.g., pipe supports), the detemination of safety-significant ts based
- "'C'> ............ ............. ............. ........ -
~-
- *c > ............ ............. ..... ......- ......... - .- .-
-w.m peu ouo ND COPY
-e L. Shao D0$
, SEC 11 on tha abilitj of the itea to perform its safety function. For exa.mple, if a pipe support cannot perfom its intendcd safety function (i.e.,
support or restrain a component), irrespective of whether the supported companent or system can function, then the deviation would be considered saf et.y-significant and a population expansion would be required. However, for cther components (e.g., piping configuration), the detemirjation of safety-significant is based on the ability of the system to perfom its intended function. Thus, it appears that the definition of " safety-significant" varies wich the population being evaluated. The NRC staff will continue to review the ideaning of " safety-significant" as it per-tuins to the various population items in order to f ully understand its significance for the different populations.
David Terao, Mechanical Engineer Comanche Peak Project
Enclosure:
- List of Meeting Attendees cc: w/ attachment V. Ndonan, NRR C. Trtm all DL J. Calvo, DE T. Westerman, RIV S. Hou, TRT G. Mizuno. ELD P. Chen, ETEC D. Landt.rs, TES R. Hockway. TES D. Terao, TRT A. Vietti-Cook, NRR l
l DISTRIBUTION:
RMinogue GpMtto
.4Terao TRT RD TRT SUBJ -,
MISC 9 - audit summary memo
^*
l i
-,,.-> . . . .mn.m . c..... ............. .............. ............. ............. ............
- > ....DTerso:c r .s . ............. .............. ......... ... ..... ... .. -
-> . . . . m.ses ...... . .;............. ............. ............. ............. .. .........
9C ,GRM 31811480) NRCM 0240
-t ATTACHMENT Personnel Interviewed - [-
=L November 13, 1985 Company -
Joe DiMare ERC John Schauf ERC R. S. Tate ERC M. Iannucci ERC November 14, 1985 Lou Fendo ERC John Warrington ERC Jim Adam ERC NRC Staff R. Kookway TES/NRC Consultant T. Westerman (part-time) RIV D. Terao NRR e ,*
9 4
-5
Y2/
/ 6 - P'le y
p W%h UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION P p BEFORE THE ATOMIC SAFETY AND LICENSING BOARD h[
In the Matter of
)
Docket Nos. 50 45
-446 LQ T-TEXAS UTILITIES ELECTRIC
) (3) 7 COMPANY, e_tt al .
) 'q )
(Comanche Peak Steam Electric )
) f Station, Units 1 and 2) d
~
g[ #
NRC STAFF COMMENTS ON STATISTICAL INFERENCE MEMORANDUM 'f '
I. Introduction i
On November 11, 1985 the Licensing Boards 1/ ssued their
" Memorandum (Statistical Inferences from CPRT Sampling)" (" Memorandum").
Therein, the Board expressed certain propositions and concerns about the ongoing reinspection effort by the Ap911 cants' Comanche Peak Response Team ("CPRT"). The Board's concerns are in the area of statistical sampling by the CPRT, and particularly how the sampling studies are designed. The Board has acknowledged that the CPRT results are not yet in evidence, but raised its concerns now to avoid delay at a later stage in the case. Memorandum at 1. The Board invited the comments of the Memorandum at 4-5.
parties on the points made in the Memorandum.
1/ On December 24, 1985, the two dockets in this proceeding were f -
unified before the initial Licensing Board, hence, hereinafter, reference will be to the " Board".
l l
l) f / +
'll'O Q Obyt _ _ _ _ _ _ _ _ . .-- _
fh
l
- I i
II. Staff Coments The main area of concern for the Board is the manner in which the CPRT structures its samples for reinspection. 2/ While not specifically stated in the Memorandum, it appears that the genesis of the Board's concerns is Appendix D-to Applicants' " Comanche Peak Response Team Pro- ,
~
gram Plan and Issue-Specific Action Plans," revision 2, dated June 28, 1985 (" Program Plan"). Appendix D is entitled "CPRT Sampling Approach, Applications, and Guidance," and contains information pertaining to the Applicants' sampling plans.
The Staff is currently reviewing the CPRT Program Plan, and will present its evaluation of the Plan (and its implementatien) in a supple-mental safety evaluation report (SSER). It is the intention of the Staff to evaluate and report on the Applicants' sampling procedures as_well as the neerns raised by the Board h, stratification of samples) in the SSER.
The Staff believes that, by presenting the Board with its evalua-tion of the sampling program when the Staff has completed its review, the Board will receive a more accurate picture of the sampling program.
In its Memorandum, the Board also invited the comments of the Memo-parties on "the possible need for an exemption for Appendix B."
rendum at 4-5. The Board's concern was that if the " level of safety contemplated by Appendix B" could not be assured by the Applicants' _ _
~ sampling process. "the plant would appear to fail to meet Appendix B
)
2/ The Appifcants have stated that the CPRT will perform "a sample reinspection of essentially the entirety of the safety significant hardware in the plant." Applicants' Current Management Views and Management Plan for Resolution of All Issues, June 28, 1985, p. 23.
i
f requirements and to require the granting of an exemption from Appendix B pursuant to 10 C.F.R. 2.758." M.at4.
Appendix B to 10 C.F.R. Part 50, Ouality Assurance Criteria for Nuclear Power Plants, was first proposed and noticed in the Federal Register on April 17, 19.69 as a proposed amendment to 10 C.F.R. Part 50.
34 Fed. Reg. 6599. According to the notice, the criteria proposed were to assist applicants (1) to comply with 10 C.F.R. 50.34(a)(7), which requires a description of the quality assurance program in the preli-minary safety analysis report (PSAR) and (2) in the development of controls to assure safety operation to be included in the final safety analysis report (FSAR) as required by 10 C.F.R. 50.34(b)(6)(if). M.
at 6600. The criteria were also to be "used for guidance" in evaluating quality assurance programs in use by holders of construction permits and operating licenses. Id. Appendix B became effective July 27, 1970, with minor changes. 35 Fed. Reg. 10498, June 27, 1970.
From the initial notice in the Federal Register to the present, the Introduction to Appendix 8 has defined " quality assurance" as "all those planned and systematic actions necessary to provide adequate confidence that a structure, system or component will perform satisfactorily in service." (Emphasissupplied). More recently, in amending Criterion I of Appendix 8 it was stated that:
The intent of the quality assurance criteria provided in Appendix B to 10 C.F.R. Part 50 is to require that all activities affecting the safety-related functions of nuclear facility structures, systems, and components be accomplished in a systematic and controlled manner so that there is a high degree of assurance that these activities are performed correctly. 40 Fed. Reg. 32100 (January 20,1985).
e For an applicant to provide the " adequate confidence" that the safety-related functions of a plant will perform satisfactorily in l
service, a quality assurance program complying with the requirements of . _ . . .
. . - - l Appendixhtheeighteencriteria)mustbedemonstrated. But, in .
deciding what constitutes compliance with' Appendix B, the Appeal Board has stated:
In any project even remotely approaching in magnitude and complexity the erection of a nuclear -
power plant, there inevitably will_bg_some con- .
struction. defects e _ tied to_ quality assurance _ lapses.
1t would therefore be totally unreasonable to hinge tdTrant.ortfCHRC-Sperar.ing-license upon a demonstration of_ error-free construction. Nor is such Tresult mandated by either the Atomic Energy Act of 1954, as amended, or the Comission's implementing regulations. What they require is f I
Isimply a finding of reasonable ossurance that, as buTit, the f_acility can and.,wil' he marated without endangerino the nuh14e Mth =ad safety.l (
{
42 V.~S.T. n zl33ld), 2232(a); 10 C.F.R.
I50.57(a)(3)(1).
Union Electric Company (Callaway Plant, Unit 1) ALAB-740, 18 NRC 343, 346(1983). "Thus," the Appeal Board continued, "in examining claims of quality assurance deficiencies, one must look to the implication of those deffciencies in terms of safe plant operation." Id. Where, as here, deficiencies in a quality assurance program are raised in a licensing proceeding, a licensing board must consider (1) "whether all ascertained _
construction errors have been cured"_and (2) even if so, if there rernins a question "whether there has been a breakdown . . . . . . . . . . -
in quality assurance
~'
procedures of sufficient dimensions to raise legitimate doubt as to the
! overall_ integrjty of the_ facility and its safety-related structures and Id. In examining these issues, it is appropriat2 to look comgo y ts."
X tothetotalityofanapplicanfeffortstoassurethatthedesignand
(
l .
construction of the facility satisfy the requirements of Appendix B; in See Diablo Canyon, this case including the activities of the CPRT.
ALAB-763, ur sup_ra, 19 NRC at 576, 577-578 (1984). Subsequent cases have endorsed the Callaway concept, 3/ and it has been acknowledged by the Boardsinthisproceeding.$!
As noted above, the Board has expressed concern about assuring "the There is, however, no level of safety contemrlsted by Appendix 8."
precise, quantitative measure by which to gauge whether an applicant has provided " adequate confidence" for a given quality assurance program.
Normally, an effectively functioning quality assurance pro-gram ensures that the design of a nuclear power plant is in conformance with the design criteria and connitments set forth in an applicant's PSAR . . . and FSAR . . . .
Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, X
In Diablo Canyon, the Units 1 and 2), ALAB-763, 19 NRC 571, 576 (1984).
Appeal Board was faced with evidence that the design quality assurance program was " faulty" and " failed to comply with 10 C.F.R. Part 50, i
Appendix 8." Diablo Canyon, ALAB-763, supra, 19 NRC at 576. Neverthe-less, the Appeal Board recognized that an operating license could be authorized if it could otherwisWemonstrated that the f_acility'5__
l l
6 l
l I
3/
- See, e.g. Pacific Gas and Electric Company (Diablo Cany Louisiana Power and Light Company (W(aterford Steam Electric Sta Unit 3), ALAB-812, 22 NRC 5, 14-15 1985).
"The project is too large to be perfect." Memorandum at 4.
4/
1
r l
designwascorrect.Id.El Referring to independent design verification . . - . .
activities,.similar to the CPRT in this proceeding, b the Appeal Board ,
l stated that these activities "if properly conceived and carried out, are tosubstitutefor,andsuhplement,theapplicant'sapparentlyfaulty I
de s i gn qual i ty_a s_su s r.g nce ,p rogram .
M . And there, as here, it was recognized that a substantial amount of the verification effort was .
predicated on a sampling of appropriate structures, systems and components, rather than on a 100% review. Such sampling process, the Appeal Board observed, must be sufficient to pemit a determination of ._
"adeounte confidence." Id. at 587. As relevant to the Licensing Boards' -
- _____.m inquiry, the Appeal Board, in Diablo Canyon, stated:
This qualitative standard is not numerically quantifiable into expressions of probability of errors or error rates . .
. . Thus, the ultimate determination regarding th of the pianes aesign renipu..quautative.Judgm.e. ent and we adequacy must~tsrh to th'e virlfi~ cation work that was performed to
~
MceFtain 9fiitherglFsTppfJuid quality are sufficient to
~
provids'the requisite. assurance of design adequacy.
5/ The Appeal Board noted that:
the Connission mandated the IDVP to provide after the fact assurance that the Diablo Canyon design confor-med to the various design criteria and nevertheless could receive an_operatinglicense.everLthee@ th~
~
applicaMtTapfrintly'fiilledja. comply with. the Connislsion's quality assurance regulations.
Diablo Canyon, Order at 5. August 16,1983(unpublished).
6/ The Independent Design Verification Program (IDVP) implemented for
~
Diablo Canyon focused almost exclusively on design activities and examined construction activities on a rather limited basis, unlike the CPRT being implemented with respect to ComancheJoak ashich has significanhyy g.g rected i di to Foth design and construction.
i i
l
l l
Id. at 587-588, footnotes omitted. E Moreover, in rejecting the intervenors'. claim that a demonstration of compliance with each and every licensing criterion and comitment, irrespective of safety significance, was required and, thus, that it was unacceptable that there may exist i certain undetected deficiencies, the Appeal Board concluded that The central issue with respect to the proper design of . . .
. . faMITtyQtne_contonnante UffthrdesigrCto the any~f@_,7, sTgEi fd[ substantive sa_fety requirements and licensing 7/ As in this proceeding, the use of a statistically-based sampling program was of concern. In this regard, the Appeal Board opined:
. . . we note our skepticism that a statistically valid design verification program, as thorough as the applicant's verification efforts, could have been developed and implemented. No such program has ever been developed for a nuclear power plant. . . . Although theoretically possible, implementation presents formidable obstacles such as identifying and~ stratifying- ~
the many thousaids of desiri Acisiviis th~arwent into the facility so that they may be randomly sampled. . . .
It must be borne in mind that the subject under investigation is the design adequacy of a complex facility consisting of a multitude of engineered systems, each with its own function and each with some potential for interacting in various ways with the other plant systems. Each " design element" or design decision for a particular system involves input from previous determinations for that system and for interacting systems. We are not persuaded that random sampling of
[]
such elements is necessarily the most effective means
[l'4 ,{ L ~
for addressing design adequacy. Rathme e enhorent [
s_ampling scheme devised in view nf a tyt+am's_
characteristics, its function. and its interaction with other systems appears to us to be a more ace ntahlea methodforascertainingtheadequacyofthedesignof__3(
nucleFA pielt.
Diablo Canyon, ALAB-763, supra, n.71. Although the foregoing reservations were noted in the enntavt av e W ing pennram directed toward design activities._it nonetheless provides a perspective on sampling programs addressing construction as well.
r 9 criteria. To conclude otherwise would ignore reality and substitute " perfection" for the regulatory standards of
" adequate confidence" and " reasonable assurance."
Id., n.68.
Based on the above discussion, and as applied to the instant proceeding, the Staff would consider it too speculative to attempt to forecast the circumstances under which the Applicants might petition for a waiver or exception to Appendix B pursuant to 10 C.F.R. I 2.758 8/,
Rather, in the context of the foregoing, it is appropriate to evaluate the adequacy of the CPRT and related project efforts in terms of their scope and quality in providing the " adequate confidence" and " reasonable ,
assurance" required by the Commission's regulations as interpreted by NRC .'
caselaw.
l s
8/ For this pleading, the Staff has not addressed the implications of the " sole ground" for an exception or waiver, i.e., the special circumstances such that the regulation would not serve the purposes for which it was adopted. See 10 C.F.R. I 2.758(b).
~ ~
OBattelle Columbus Division I f 1:: ~]
BERNARD F. SAFFELL, JR. 424 5294 ,
/Z 5 G)
AJ 6 /)4
~ & a y '
YY' 2% n~LL
- e M
s i.i,.
i -
s-I .$,
a.
> :) . W
'. r u '*
f f ; , _t e
1.
Title:
NRC Audits of Comanche Peak Response Team Construction Reinspection / Documentation Review Program (ISAP VII.C)
- 2. NRC Staff and Consultants:
J. A. Calvo, NRC (Chairman) E. Tomlinson, NRC J. A. Nevshemal, Westec J. Flaherty, Teledyne B. F. Saffell, Battelle R. Philleo, Consulting Engineer R. Masterson, EAS J. Rivard, Teledyne
- 3. Persons Contacted: ,
J. L. Hansel, ERC J. M. Schauf, ERC T. Bori, ERC J. T. Christensen, ERC G. Hefter, ERC E. Baum, ERC D. Boulton, ERC A. Burke, ERC N. Banerjee, ERC J. Brand, ERC H. Bossung, ERC R. Brown, ERC A. Patterson, ERC J. Brown, ERC J.Tablerio/,ERC J. DiMare, ERC R. Tate, ERC J. Greer, ERC M. Iannuci, ERC F. Korensky, ERC J. Warrington, ERC
- 4. CPRT Construction Reinspection /Documantation Review Program Audits of the Comanche Peak Response Team (CPRT) Construction Reinspection / Documentation Review Program, subsequently referred to as the Construction Adequacy Review' Program, were conducted on October 16 and 17, 1985, at the Comanche Peak Steam Electric Station site. All disciplines--mechanical, civil, and electrical--were audited by teams composed of NRC staff and consultants. Through these audits, the NRC l reviewed the basis for establishment of the groupings within each I
discipline and the work process populations associated with each j discipline and utilized by the CPRT for assessment of construction adequacy. The primary purpose of this audit was to determine the degree of homogeneity within each work process from an engineering perspective.
Detail audit of work process attributes will be accomplished in subsequent audits.
The construction adequacy review program is being performed within the purview of the Comanche Peak Response Team with ERC, Inc. re:ponsible I
l i
. - - .- -~ -
2 for performing the review. The presentation made by Mr. John Hansel of
- ERC,-Inc., at a public meeting held on October 3 and 4, 1985, in Grandbury,' Texas, provided the basis for the staff's initial audit of the
- CPRT Construction Adequacy Program.
Work processes are being identified for construction of safety related systems, components, and supports. Each work process will be 4 evaluated by a random sample drawn from the associated population of systems, components, or supports related to that work process. Further, sample items reviewed are drawn from Unit 1. Unit 2, and common areas, and must be construction complete and quality approved. Each work process sample is expanded to include an engineering sample. The ,
, engineering sample assures that a number of safe shutdown system items
- equivalent to the number of items addressed by the random sample are also reviewed for adequacy of construction.
Subsequent sections describe two NRC audits of this process.
- 5. Mechanical Discipline The mechanical discipline is divided into nine populations which
- are: >
(a) HVAC ducts and plenums (b) HVAC equipment installation 2 -
(c) Field fabricated tanks (d) Mechanical equipment installation (e) Large bore piping configuration (f) Small bore piping configuration 4 (g) Pipe-welds / material (h) Piping system bolted joints / material.
, Each of these populations was discussed with ERC personnel by NRC staff and consultants participating in the audit. The canstruction adequacy review for the mechanical discipline is approximately 15 percent complete at the time of the initial audit. Completion is scheduled for the end of
- February, 1986. Only field construction work processes are addressed by the scope of this activity; vendor fabrication is not within the scope of
- the Construction Adequacy Program. For each of the mechanical areas, ERC i
'o- y-_ . -,,9~,,,-.-,~.,-%,--,,..-<w-. w e, -- - - - + ,-,,-,,.------,-.----,---.-----,-y.-,,,,-e,,,,,y,-.--y---re-.--,---ww---c.,,--vw-r.,w+ - , , , - - - , - , ,
e g
. 3 had prepared a "Popnlation Description" addressing the contents of each category, its boundary, and any specific interfaces germane to the population. In addition to the Population Descriptions, a flow chart describing the work processes and associated attributes for each sample population was provided and discussed with ERC's Population Engineers.
ERC indicated that these attributes provide the basis for the checklists which are being developed for re-inspection of mechanical systems and components.
ERC reported that the construction adequacy review is being performed in accordance with their own quality assurance program which is -
co@ atible with the CPRT's quality assurance program. ERC's implementation of the construction reinspection / documentation review program is being audited by both CPRT and ERC quality assurance personnel.
Specific coments on each population within the mechanical discipline are provided in the subsequent paragraphs. ,_
- a. HVAC Ducts and Plenumo This audit was initiated during the October 17 and 18, 1985, site visit. The HVAC Duct and Plenum population encompasses 6800 items. Fabrication, installation and welding are the, three work processes associated with construction of HVAC ducts and plenums. Bahnson Service Company was th'e only subcontractor to Brown &
Root for all HVAC duct and plequm fabrication and installation.
j Reasonable homogeneity is demonstrated because fabrication and installation of this equipment are each characterized by a single craft--
f sheet metal workers for fabrication, welders for installation, and a single subcontractor. Installation and fabrication procedures are based on Gibbs & Hill Specification MS-85. The attributes associated with each f
work process were reviewed and appeared to be complete. This audit was continued during October 29-31, 1985, by a further review of the i following ERC procedures:
$,Y*' ff$aY.eb"he. serif Ned C,Jr; Popu'1ation Items List l g p. QI-OSS, " Reinspection of HVAC Equipment".
l.
w
4 This population has been modified based on a concern raised during the October 16 audit.- The work process for Equipment Setting by 7 -
f Brown & Root has been deleted and will be combined with the mechanical equipment installation population since the same B&R procedures and installation specifications were used.
b.
HVAC Equipment. As with the HVAC Ducts and Plenums, this audTt Yh was initiated on the October 17 and 18 visit and continued during the Oper29-31,1985, visit. This population contains 604 items of
-passN equipment in the safety-related HVAC system whereas the HVAC M/ w equipment population contains only. tems. This equipment was either installed by Brown & Root or Bahnson and this was the basis for subdividing this category. The work processes associated with HVAC equipment installation are the setting of the equipment and then connecting it to the plenum and ductwork. Further, the attributes of each work process are the same, regardless of the installer. .The attributes associated with the work processes were reviewed and appeared appropriate for the process.
The following ERC procedures were reviewed during the continuation of this audit:
- a. Work Process Definitions
-b A Pdpuidu N f yt Population Items List g g C g QI-039, " Reinspection of HVAC-Bucts =d Dlaums".
QI-039 has been issued and is very detailed. It contains much of the original documents and sketches required during the construction ase. The document review procedure has not been completed yet.
- c. Field Fabricated Tanks. This particular activity was discussed in a qualitative manner. ERC informed the audit team that eight field fabricated tanks exist and that all would be reinspected. This was not pursued further as population homogeneity was not an issue because of the 100 percent reinspection.
I I
l I
p b
- 5 y TO V o }z w '
- d. Mechanical Equipment Installation.vMechanical-tqtripment7udit-
.of-October 47-and-16r 1985r-population encompasrer336 items, The governing construction document is the Gibbs & Hill Mechanical Erection '
Specification 2323-MS-101. The implementation of this is accomplished by Brown & Root Specification titled " General Installation of Mechanical Equipment", CP-1. The governing quality assurance procedure is Brown &
Root QI/QAP11.1-39 titled " Mechanical Equipment Installation Inspection".
Qualitative results of the sampling conducted so far indicates that 20 to 25 percent of trie sample drawn is from Unit 2. The remainder of the sample is from Unit 1 and common areas. The work processes associated -
with mechanical equipment installation are setting, anchoring, welding and, for rotating equipment only, alignment. The attributes of each work process were discussed in depth. ERC personnel indicated that if a particular attribute of the work processes was not addressed when the sampling activity was completed, assessment would be made as to whether or not the sample needed to be expanded to include that attribute. If a _
decision was made not to specifically address that attribute, the basis for this decision would be provided in the report addressing the construction adequacy evaluation of, in this instance, mechanical equipment. Work process homogeneity is evaluated by checking to make sure that the same organizations are involved, procedures have remained nominally constant, and that the welder inspector qualification standards have remained the same. Sampling is performed at the work process level.
Since evaluation of equipment is made at the work process level, each sample will be expanded such that sixty evaluations will be made for each work process. This means that more than the minimum number of equipment items (60) are addressed during completion of the sampling process.
This particular category was pursued further in that an installation procedure for a heat exchanger and a pump (rotating equipment) was l reviewed to evaluate the compatibility of the attributes associated with work processes with the installation requirements contained in the )
procedure. Compatibility did appear to exist between the work process I
attributes and installation procedures for both cases. In one case, the installation procedure for heat exchanger CP1-CCAHHX-01 was reviewed to see if this specific installation procedure was compatible with the u p. -- - - - - ---
6 attributes of the work processes for mechanical equipment installation.
The procedure for installing an auxilliary feed water pump, cpl-AFAP-MD-01 was reviewed to evaluate its compatibility with the alignment work '
pr6 cess attributes.
Audit of October 29-31, 1985 The following documents were review 2d as part of the continuing audit of the Mechanical Equipment Installation (MEIN) population:
(1) Work Process Definition for MEIN. -
(2) Population Description. ,
(3) Population Item List.
(4) QI-059, Revision 0, Draft Procedure Quality Instruction for Issue Specific Action Plan (ISAP) VII.C., " Reinspection of Mechanical Equipment Installation").
l (5) Original Mechanical Erection Specification 2323-MS-101, __
l Revision 4, 6/28/84, Gibbs & Hill, Inc., Specification.
(6) Brown & Root Specification MCP-1, 8/1/84, Revision 4, " General Installation of Mechanical Equipment".
(7) Brown & Root QI-QAP-11-1-39, Revision 4, 6/11/84, " Mechanical Equipment Installation Inspection Procedure".
(8) Brown & Root, CCP-24, Revision'4, 6/26/80, " Rigging".
(9) Brown & Root, " Grouting Base Plates, Bearing Plates and Equipment Bases", CCP-16, Revision 4, 2/8/84.
(10) Brown & Root, " Installation of Hilti Drilled-In Bolts", CEI-20, Revision 9, 12/16/83.
There are currently three work processes being reviewed. The welding work process has been deleted from the MEIN population and, as of October 28, 1985, has been put in the appropriate pipe weld work process.
ERC is also reviewing the deletion of grout from the attribute list and is establishing a new population that specifically addresses grout. This change is due primarily to the way documentation was established.
The ERC reinspection procedures and original construction specifications and procedures were reviewed and compared for homogeneity of work processes and choice of generic attributes. The writer feels
- 7
.that all attributes listed are appropriate and cover the original construction sequence.
S N g e r xt:tter packages from the sampled population were reviewed for completion of documentation and comparison to general i specifications and attribute list.
The six deoumente M ee. packages reviewed were:
(1) Service Water Pump, P.O. CP-010-001 Rotating equipment installed per Hayward Tyler manual. Manual gave specific tolerances on parallel alignment between motor half coupling and collar. .
(2) Pressurizer, P.O. -0001-18 All dimensions for installation are per Westinghouse drawings.
(3) Safety Injection Pump, TBX-SIAPSI-01 and 02 Specified tolerances on rim-to-rim and face-to-face coupling alignment. A requirement was also given on vibration i
tolerance. In a discussion with ERC, ERC stated that this _
~
! attribute may be added to attribute list as a documentation check.
(4) Centrifugal Charging Pump, TBX-CSAPCH-01 and CP-0001-024 for Unit 1 Installation is per manufacturer's manual. This pump is part
.of the Chemical and Vo.lume Control System and was fabricated by Pacific Pumps.
(5) Motor-Driven Auxiliary Feedwater Pumps, P.O. CP-007-001 Alignment is per manufacturer's specifications. Criteria given for checking anchor bolts, level and alignment and grouting.
(6) Excess Letdown Heat Exchanges Criteria given for backing off of foundation bolts to allow for
! thermal growth. Requirement given by Westinghouse.
The work processes and their attributes are considered to be
! appropriate to the installation of mechanical equipment. The above six mechanical component document packages were well documented and the appropriate attributes listed on the ERC checklist. The review of the MEIN population will be completed po resolution of two open items. A l concernfektdingtheattributeof torquing as it applies to
! equipment anchor bolts. The " tightness" attribute may address the need 4
. 8 to distinguish " hand tightening" from those instances requiring a specified torque limit. This issue will be further investigated in future audits. Second, ERC is reviewing the need for a vibration '
attribute. This will be addressed in the next audit.
e./f. Large Bore Piping Configuration /Small Bore Piping Configuration. The large and small bore piping configuration construction adequacy reviews are addressed using 3000 Brown & Root isometric drawings. The scope of this activity is intended to assess the work process of piping installation through evaluation of attributes such -
as location, size, and orientation of piping and pipe components. The Brown & Root isometric drawings provide the basis for sampling both large and small bore piping. Large bore piping includes that piping which is 2-1/2 inches and larger in diameter; small bore piping is that piping less than 2-1/2 inches in diameter. If an isometric drawing containing both large and small bore piping were to be drawn as part of a. sample, it __
would be used in both the large and the small bore work process review.
The installation work process and its attributes are the same for both large and small bore piping. The piping considered in this review includes all ASME code piping. ERC r'eported that all piping of large and small bore is installed to one procedure and by one craft--pipe fitters.
Some attributes such as piping valves would obviously be included in any sample 19F drawn for either large or small bore piping. There are other attributes such as expansion joints, screw joints, and strainers which because k are very few in the system, might not be included in any selected sample. ERC reported that following the sampling process, a review to assess the adequacy of the sample for adequate representation of attributes would be made. However, a specific component, because it was not included in a sample, would not necessarily be examined only for that reason.
The number of attributes corresponding to the installation of large jj However, the number of .tisem bore piping appeared accurate and complete.
I seems to precluW er M tion of-them all through the random and engineered sampling process. If ERC suggests that it is not imperative that all such as screwed joints, strainers, and expansion joints be
- 9 .
evaluated from a configuration viewpoint, their report should justify this type of conclusion. It appears that the sample should include'some k number of components which are not extensively used in piping to provide '
confidence that these components are installed correctly. Their sampling process appears to address the key items such as piping orientation, N valve location and orientation, and bends.. p
- g. Pipe-Welds and Material Audit of October 17 and 18, 1985 -
sN As with large and small bore pipe configuration, the welding of %'
large and small bore pipe are considered as one grouping. Separate ,f samples, however, are utilized to address each. More than 66,000 welds x s are required to connect safety-related large and small bore piping. '
work processes associated with welding of either large or small bore are _,
N prewelding, welding, post-welding. As with the other categories within .
the mechanical discipline, the population description was reviewed and appeared complete. The process of construction adequacy review is about kk
( '
40 percent complete. The initial review has been completed; samples have been drawn and preparation of reinspection pr.ocedures is in process. '
Approximately 65 percent of the sample drawn is either Unit 1 or comon.
The remainder is Unit 2. ERC personnel were not sure if any Class 1 e welds were included in the sampling. It was indicated that Brown & Root h performed all field welding. ERC further reported that the weld inspection processes are the same regardless of the ASME code class. The
- categories of large and small bore pipe welds were not separated to N
! distinguish between the welding of stainless steel pipe opposed to carbon ,r ,
f steelpipe.JERCindicatedthatthewelderswerequalifiedtoweldboth) stainlesssteelandcarbonsteelpipingandhencetherewasnoneedtoM f
separatethis.[Attheexit,theauditteamexpressedconcernregarding N the lumping of stainless steel welds with carbon steel welds. ERC agreed \
to review the sample to determine the number of stainless and carbon j
steel welds. Welds addressed by this study include only field welds.
l l
i L--..__.~,_
.__._._,,...,___._m.. . _ . , _ , _ . , _ , . , . . _ _ _ , _ _ , . . . . . _ , _ _ . . , _ . , _ _ , . _ , , _ _ _ _ . __
10 Welds of the penetration sleeve to flange were included within this category. There are 282 such welds in this category. None were included in the random or engineering sampling, however, the large and small bore '
samples were supplemented to include one mechanical and one electrical penetration weld.
Welds work processes and attributes appeared complete but conclusions regarding population homogeneity cannot be reached until review of implementation procedures and welder qualifications is completed. Further, as previously noted, concern exists for the consideration of stainless and carbon steel welds as part of the same -
population.
Audit of October 28-30, 1985 The piping welding area was addressed in the staff's second audit of the CPRT's Construction Reinspection / Document Review Program to verify , , ,
(1) the basis for establishment of each population; (2) population boundaries; (3) population exclusions; (4) population interfaces; (5) population list. source and basis; (6) work process and basis; (7) attributes associated with work process; and (8) source of attributes.
Based upon the fact that both large bore and small bore pipe welds were fabricated to the same procedure and by the same craft, ERC decided to lump the populations.together. The staff reviewed the (LBWM and SBWM) population basis, description memorandum, population description, populations item list and work process definition. ERC indicated that only one work process was chosen, Welding. Apparently, regardless of the possible differences in the welds (configuration, material type, or process) each work process involves: (1) comon erection specification requirements; (2) comon installation procedure requirements; (3) comon craft labor performing the same basic types of operations; (4) comon inspection procedure; and (5) a comon inspection organization. l Since basically one two welding methods were used at CPSES, Gas )
Tungsten ARC Welding (GTAW) and Shielded Metal ARC Welding (SMAW), ERC j has committed to two random samples of 60 welds for each welding method.
The staff expressed a concern for the lack of separation of carbon steel I l
. _ , _, . _ _ , _ . . .__ _. . . _ _ _ -_ . . ~ _ , - - . . . _ _ . . - _ _ _
. 11 and stainless steel welding. ERC pointed out'that welder qualification is in compliance with B&R Specification WES-031 which qualifies a welder to both carbon and stainless steel welding. The staff reviewed WES-031 and '
B&R procedure CP-CPM-6.90, " Welding and Related Processes", and found very few areas where the procedures or specifications differed with regard to carbon and stainless steel welding. Differences were associated with the two welding methods GTAW and SMAW. ERC said that of the 120 samples already established, approximately 50 percent were stainless steel welds.
In addition, an engineered sample of 60 welds for each method was picked to account for safe shutdown systems. In both cases, GTAW and SMAW, the .
original sample of 60 and the engineered sample overlapped. This necessitated increasing the original sample to achieve the engineered sample of 60 welds. In all, a total number of approximately 180 samples will be inspected.
Under the work process identified as " Welding", 24 attributes were identified, 18 of which are common to both welding methods and to all welds. The remaining 6 attributes will be inspected as the sample dictates. Additional samples for these 6 attributes will be chosen as deemed necessary, or a justification for not increasing the sample will be given at that time.
- h. Piping System Bolted Joints Audit of October 17 and 18, 1985 Two work processes comprise the piping system bolted joint category.
They are installation preparation and final bolt fitup. There are 7000 bolted joints at the Comanche Peak Power Station. The work processes and their attributes appear to adequately represent the bolting of piping joints. The procedure which governs this is CP-CPM-6.9E Rev. 8. A flow chart and population description had been prepared to provide the basis for the sampling of bolted joints. The staff's audit did not yet pursue this to the depth required to draw a firm conclusion regarding the homogeneous nature of the work process populations.
12 Audit of October 29-31, 1985 The following ERC procedures were reviewed during the continuation
~
of this audit:
(a) Work Process Definitions (b) Population Description (c) Population Items List (d) QI-021, Revision 1, " Reinspection of Piping System Bolted Joint Material.
During the October 18 audit, the NRC audit team raised a concern on ,
torque being an attribute and not a work process. The concern was relative to equipment specifications requiring a specific torque value on certain types of flanges and the reinspection attribute not containing sufficient samples. In the discussion with ERC, it was noted that there are approximately 7000 items in the piping system bolted joint population.
Of the approximately 7000 items, 6700 are in line-piping connections which were installed in accordance with Brown & Root Procedure CP-CPM 6.9E. Section 3.12 of the B&R procedure did not require a specific torque value to be used. The governing requirement was that the joint "shall be tightened sufficiently to prevent leakage during pressure testing". Since ISAP VII.C is addressing QC-accepted items _, only reinspection per the original specification is required. The only flanges which may have required specific torque values would therefore be in the Mechanical Equipment Population. ERC has reviewed the MEIN population and has only found approximately six flanges which required specific values. Therefore, the issue raised during the October 16 audit is not an issue for Piping System Bolted Joints.
It was also noted that the Population Description and Population Item Lists will be revised to delete instrument flanges. These will now j be included in the electrical area.
1 e
, 13
- 6. Electrical Discipline W
4 9% O I
- _ - _ _ . , _ _ . - . . .- . . . . . . - . . - . , _ . - . , . , _ . - , _ - _ _ . _ - . ~ . , _ . _ . - - - - .- _ - _ _ _ - .-.-__
. 14
- 7. Civil / Structural Discipline The civil structural discipline is divided into 15 populations which are: -
(a) Concrete Placement (b) Structural Steel (c) Liners (d) Fuel Pool Liner (e) Fill and Backfill Placement (f) Grout-Cement (g) Grout-Epoxy .
(h) Large Bore Pipe Supports - Rigid (1) Large Bore Pipe Supports - Non-rigid (j) Small Bore Pipe Supports (k) Large Bore Pipe Whip Restraints (1) Instrument Pipe / Tube Supports (m) Category 1 Conduit Supports (n) HVAC Duct Supports (o) Equipment Supports.
Most of these areas were discussed with ERC personnel by the NRC staff and consultants participating in the first two audits. Some areas have been reviewed in depth while others have been treated in a cursory manner and will be examined further in future audits. Populations (k) through h have not been reviewed as of this time because they had recently been formulated and the work processes and work process attributes were still being developed.
- a. Concrete Placement. The concrete placement population was reviewed in a cursory manner during the initial audit and in depth during the second. During this time the following documents were reviewed to determine if homogeneity of the work processes and attributes had been achieved.
(a) ERC's Work Process Definitions for Concrete Placement Population.
(b) ERC's Population Description for Concrete Placement, 8/5/85.
ERC's Population Description for Concrete Placement, 8 Q)
0 ..
e 15 (d) ERC's Population Items List for Concrete Placement, 9/5/85.
(e) Procedure QI-043, Revision 0, 9/16/85, Procedure, Quality Instructions for Issue-Specific Action Plan No. VII.C., *
- " Reinspection of Concrete Placement".
(f) Gibbs and Hill Specification 2323-SS-9, 1/16/79, " Concrete".
(g) Gibbs and Hill Specification 2323-55-30, 2/10/84, " Structural Embeddments".
(h) Brown & Root Construction Procedure 35-1195-CCP-11. " Concrete Placement", Rev. O.
The concrete placement population is presently subdivided into three .
work processes, each work process having various numbers of attributes.
l Some of the attributes are to be reviewed by means of a field
{ reinspection; others can only be reviewed by means of a document review; and some will be reviewed utilizing both field reinspection and documentation review. The field reinspection was in progress at the time of this audit and the documentation review had not yet begun. No _ _
, reinspection packages were reviewed.
. A few concerns evolved from this audit; however, the reinspection of concrete placement's work processes and attribJtes does achieve an appropriate level of homogeneity. These concerns were discussed with ERC I
and were left as open items. The following is a list of open-items which ERC should address: -
(a) It may be more appropriate to establish cadwelds as a work process rather than as an attribute. ERC.is to review the j
cadweld inspection procedure and the concrete pour card sign-i off requirements to determine whether cadwelds should be a 3
separate work process.
(b) ERC to consider establishing Richmond Inserts as a separate o attribute instead of including it with the embeddment attribute.
(c) ERC to determine if the condition exists where embedded pipe sleeves are used to anchor the piping system. If this l'
situation does exist, the embedded sleeves should be a separate attribute.
1 wn-., . .a n. , --- - - - ---.,-..,-n-.-, c -._n-.,,- , , - - , ,,-.-ev_m,m,,w.
g,,n,. n..n,-,m,- -r.,-. ,---,,,m~~- ,.,y - ,..,~.y,--r. e
l l
16 l
l
- b. Structural Steel. Cursory review of this area was done during l
~
- the second audit to determine if the concept of choosing work processes and attributes would achieve acceptable homogeneity. A limited review of' thit following documents was performed.
i (a) Procedure QI-045, Rev. 1, 10/23/85, and Change Notice 001, 10/23/85, Quality Instructions for Specific Action Plan VII.C, Reinspection Procedures for Structural Steel.
(b) ERC's Description Memorandum for Reinspection of Structural Steel:
- 1. Rev. O, 9/15/85 .
ii. Rev. 1, 10/8/85 .
iii. Change Notice to Rev. 1,10/23/85.
(c) Gibbs and Hill Specification 2323-5S 168, " Structural Steel",
5/12/75.
(d) TUGC0 Instruction QI-QP-11.0-15, " Verification of Baseplates for Grouting", Rev. 8, 3/13/85. -
After performing this general overview of the structural-steel reinspection activity, it is felt that the work processes and attributes identified generally will achieve acceptable homogeneity. However, a more detailed audit of the reinspection procedures will be required to make more detailed coments.
! c. Liners. The containment liner population includes horizontal, vertical, and penetration welds. The work processes were reviewed and ERC was informed that consideration should be given to including a plumbness requirement as a work process. Also, it was suggested that ERC l
consider revising the tolerance when a 6-inch template is substituted for
- a 10-inch template.
- This area will be reviewed in subsequent audits.
1 l d. Fuel Pool Liners. The first audit addressed only the formation of the populations. All welds covered by travelers will form this
! population. This area will be reviewed in subsequent audits.
i
. - ~ . . . . , _ _ _ . _ _ . . _ _ - . _ . _ _ , . _ _ _ _ _ _ . _ _ . , _ _ _ _ _ . _ _ . _ , _ _ _ . . . _
o,. ,
17 i
- e. Fill and Backfill Placement. The initial audit addressed the population formation and the work processes within the population.
Testing is a work process within this population and not within concrete.
- Coiisiderationshouldbegiventotheneedforconsistency. If testing is retained as a work process, the population description should be modified-to reflect this as a separate work process.
l f./g. Grout-Cement / Grout-Epoxy. These are new populations which have not yet been reviewed.
1 I
- h./1./j. Large Bore Pipe Supports--Rigid (LBSR)/ Nonrigid (LBSN)/Small Eore Pipe Supports (SBPS). All of the noted pipe support populations were addressed in the audit of October 29-31, 1985. These populations were formulated in order to assure a proper sampling of rigid f and non-rigid pipe supports. This is important, since the majority of i
" standard catalog supports" are in the non-rigid category. The small _ _
) bore sampling was not divided, because the number of non-rigid small bore supports is very small and also because the type of support is not readily obvious from the support number (as in the case for LB supports).
ERC intends to sample 60 supports from each of the three groups (LBSR, i
LBSN, and SBPS).. The SBPS population was made up of four work processes;
{ fabrication, installation, welding, and' inspection. The ERC management seemed to be confused as to whether inspection should be a work process or an attribute. The two LB populations did not show inspection as a
- work process. After much discussion, the individual in charge of the I
SBPS group indicated that rework to a support very often occurred during the inspection phase as a result of an UNSAT Inspection Report (IR).
Since this work was per, formed under the umbrella of inspection in order to close out the IR, this was a separate work process. The individuals
! in charge of the LB group appeared hesitant to accept this but eventually j they did. However, at the exit interview, ERC upper management balked at l this agreement and said that they would like to investigate this area further. They indicated that if they made any changes they would contact '
the staff (the staff agrees with inspection being a separate work j
process).
J sw-,-. -,-,.e, ,- r_.~_..,,-...,,--.,,,,,,-~y,
18 The staff reviewed the various documents (description memorandum, i
population description and basis, population items list, work process justification, attribute description and basis, and QI-019-020, 027 '
thPough 030). An auditable trail existed such that all work processes i and accompanying attributes could be verified. The staff noted that h under pipe supports welding two attributes were omitted (cleanliness and h -
base metal defects). ERC pointed out that cleanliness was unattainable l
- both from an inspection standpoint (prewelding attribute), and from the point of view of document review (cleanliness was not a hold point on the Multiple Weld Data Card (MWDC)). ERC also said that they did not include .
I base metal defects for supports as an attribute, since it was difficult N to see defects through the paint. The staff pointed out that Y
requirements for identifying base metal defects existed in ASME s
x Subsection NF-4000 and B&R Procedure QI-QAP-11.1-28. ERC stated that
[
during the reinspection of the sample supports, base metal defects were looked for in each case and noted as an."out of scope" observation for N inclusion in the normal deviation system. The staff would not accept this, and asked ERC to reconsider this approacn. After some discussion, ERC committed to put base metal defects into the attribute list and to
. treat all instances as part of the cdnstruction adequacy.
- k. Large Bore Pipe Whip Restraints. An overview of the pipe whip restraint population was provided by ERC. This population consists of moment restraints, pipe whip restraints and restraint support structures listed in Section 3.6 of FSAR. Due to the original construction, two populations may be established, one for the restraint and one for the support structure. Nine systems have postulated line breaks. Some restraints are listed by Gibbs and Hill and other restraints are listed by Site Damage Group. At this time ERC is still reviewing the work process and is establishing which groups were responsible for installation.
These populations were formed after the initial audit and have not yet been reviewed.
19
- 1. Instrument Pipe / Tube Supports,
- m. Category / Conduit Supports. '
- n. HVAC Duct Supports. l
- o. Equipment Supports.
h6 4
T I
ai 3
1 l
}
Lawrence Livermore Natk>nal Laboratory
- j. e. r.
bcr7'S / f $ u l~ 7N!/
~
skrPenrene-
/Sc'7=em r-rw e:- rf7(,
no rrttr Ver
~
December 13, 1985
/L////d'F NSSP-NV-
& * h hrf fZt*7?d>t 7 !.C
/NO / F fw 8 ds <W~ 'r O '#
Mr. E. B. Tomlinson, M/S P-932 /7,/f:ft,f F arac N e rty Nuclear Regulatory Commission - cf g ,2>co<( -
U. 5. /t-u /> h / Cove -2 fr-r_ c_
7920 Norfolk Avenue 777z/4 e a C- u , r r ~ c. rice:
Bethesda, MD 20814 p em.r o up
.c cm nerrt C#P.
1985 (Draft).
SUBJECT:
Inspection Report for CPSES for October Dear Mr. Tom 1inson Enclosed please find the subject report.
Yours truly, Paul M. A. Chan (702) 295-2411 (Comm) 4 (8)7575-2411 l-I-
I PMC/B-1 Enclosures
[
White, LLNL
,.- cc: Robert L.
s e e
t N' Universrty ot CaMomsa Lawrence Lovermore NatronalLaboratory *
}
- b P.O. Bon 45
)
(
uomorv Nevede sgo23
o U. S. NUCLEAR REGULATORY COMMISSION BETHESDA, MARYLAND IW s' ' T CPPR-126
% 445,6 9yn tc meuInspection Report: [0_ff ((__[__
s Construction Permit: CPPR-126 6 ______________
Dockets: 50-445 50-446 (TUEC)
Appl 3 cant:
Texas Utilities Electric Cor,.pany Skyway Tower 400 North Olive Street Lock Box B1 75201 Dallas, Texas (CPSES),
Facility Name: Cnmanche Peak Steam Electric Station Units 1 and 2 Inspection Att Glen Rose, Texa y c 1 Auo lo if- t~l and 28'-31, I
1995 v o'*$i, FF T
p October bL-49, ,
~
Inspection Conducted: g, r $r A6/te' b.
w
..st*'
~~
at
~ ~~
hp#
Ins ector :
~
5~~CI~ arino [67p~u(~Mk~.IA d~~~~~~~
~
/ DM
,,c Pc E % vsect ourtt. u n t' S V$ 7 61s - PO m Pb %o4 *Trvcy'
. Auc -
_____..:-,_ w
_- _ & _^-._-_-___ Date -
e
- _m_nson E. B. Tomli
, L4n o c11 5"'" b'"' (f ,T.
- ~_n e-
'FM I M [t Eth-N' Chan
~- t "{' lV i.M.
o M. I Consultants:*'TES LLNL -- P. J. A. Flaherty,
' J. J. Rivard k _
EAS - R. Masterson
( M'8 ' J Nevshemal sBattelle - B. F. Saffell Philleo sConsulting Engineer - R.
t O@ __________ bh* __________
?? h -___________'_' M Date
'.~ 5 Reviewed By: f.C. bN %-_ _f_Svt rems /Dern m-,Aroount t r e %p
,- iA a inc t _
- w --p cader, Elec an Comanche Peak Project P
r e
! 4fI'rtus n D'l
- ______________ ___-_-____- Date Tu . i c u; d 27^L._ Shao'
_ _ _ _ _ _ __ _[j_A u s%<.% andC1'/i h EA/4tAjon=n/W
.I errup Lc:d;; , "rch.
,l Comanche Peak Project i pas, vo ev: N. GAlG,l.or&D ym .. m ra s.
- P O
2
__________ ~_______________ Date Approved By: _______ ____1. A . C A s w; Ti A as *tev*
wr Neer so - Pr-eses t Projec.t_tianasc+ --Cansachz @wP "ce.P 5 y : n. w > / 6 P m A-ri %
G w c' n> ?.n e PMeer r pn
~~~~.._
- . . . . ' oM'Mp 1 ro r/cm-i leauestigo Swesety t-i o er 25._end_;?0:211_12DD_.16en9Ct#__
7 ___1 10seestige_c90 ducted _9stz M-t@t_21: %
onroutim , e - m n4 nunced-Nac-euotts-e+ the,Speci41c Ac 6tses_10mnectedt E.lectri en i ~~
g' k{omanche nstruction.ReiPeak -Re3 ponse tiechani cal,- and -Struct e4ERC)-
-Team--+CFH14- al % ssue-and-Instrumentstion -& Contro1 tor-hours-onsite-by-1i( [ -fh-scrp4 a nes. -Audrt of -EvaluatiomResearchr-Corpor_ation--
,pcogress, -The~inspectTon-irivolved- -_-- inspec two-NRC -i n sp ect or s an d~el'gid' ion sul t a6EW.
Within the areas inspected, no deviations or violations Eggyltg1 [vmy, ,,u were identified. ou 3 iW lllIC g k b'7C v1w4 2e-rentsee t/
co d ec#rt ui a c. Cm s oe st1~
NosJl2duTIOI',[itus!ou*Jee~r> c f 7E C ) # A r c.sta s f-D 7 Prnt A rto u t
yr w (cpie r) z c s e,e Joan<<~<cw A4 rie v rn r i w c r <uo 2%uri m u/.Doeana 2 Pc-A &xrep}.
yo" & ~ w n ,o , " e n n m .r c wo u.c <r Gsrrex< rrn- 'e m rnaeae ,
i
,o no ir>werunk r p'i ,~ s ra<i m eu rw< aa, u s-cir>< we m , ci w c. :- - ::f
. /s*-e 79 s/ / 7~/ ed e Qw,:n ,-
C u N f r /t u e r-t o J 1
,; grp,s J rr w A ^r*
's S
's J $
l f
8 ef
)
7'M '\,
%m-f r v en i 7 t
p rJ
)
. 9+ ms 5 acn.c.,u q
- 1~f Y L P I s.,p C L u O f P Lv V e?M 3
~ * . . --- --. __ _
~
DEIGILS E*d N 2._EeCanon_Gnetacted VB. Shair. ERC Of '0" Lead Electrical Engineer 6. FM wo y ERC herMcu Qosto essue R- Eac+ ; n o , ED W 7peng -,E"gt;,
mng r eview isor NQ,pm gFA.. A. Patterson, ERCg[bD'Mf)eput Team Leader g R ,r m#* v J R..
- 5 ,$. Chri stensen,ERC Support Engineer Merham,
'i . Kulaga, ERC OA/DC Discipline Engineer h lse ow v J. L. Hansel.
ERC & A/& c (true 6-.s D. Boulton, ERC J. Brand, ERC J. D1 Mare, ERC M. Iannuci, ERC p J.
M. Schauf, ERC G. Hefter, ERC A. Burke, ERC H. Bossung. ERC J. brown, ERC R. Tate, ERC F. Korensky, ERC T. Bori, ERC E. Baum. ERC ERC N. Bancrace,
, R. Brown, ERC J. Tablerion, ERC I.,
J. Greer, ERC J. Warrington, ERC
- v }). b A $/ D07t. ; (?P.C ;
T*'G o w W '"
a V, il venw , Etic CSWet)GTtc. Lena e s .an. , dz Afdllt c -
v W< 6+*'m a 3ast Tu c& v , J u c.a PM :t r a evr & . . .
-1, J , hetc. ,
I I
I s
1
4 2._GEBI_ggomitgetigo_Betonenstigolpecumentattgo_geview_ECnetas The object of the program is to verify the adequacy of the construction, and to gain additional insight of the quality of the plant. The program consists of establishing a comprehensive method of reinspection and verification independent of the applicant's authority. 7g49 gy,c ))
Audits of the Comanche Peak Response Team (CPRT) Construction Reinspection / Documentation Review Program, subsequently referred to as the Construction Adequacy Review P ogram, were conducted gBld (~ on Oc tober=M z 1-%Ano 2o41, IVtqp at the Comanche Peak
~
Steam Electric Station site. All disciplines -- mechanical, civil / structural, electrical and instrumentation & control p t 7d by teams composed of NRC staff and consultants.
were at Througt the NRC reviewed the basis f or establishment gggpits,y wit.hin of the
- Q;'
- e such discipline and the wo*4 processes populat ~. .moc. lated wi+.h each discipline and (J l ' a d b- the CPRT fe; >Lce.r.iment of (.cnstruction adequacy . erc=pr% mar-rWW -
~
omogeneity within fof t}is ~sudi tNac~to determi ne the" degree-'~of he ,a,udi,t r ;
even work procpss/fr,6m ad e9gineering perspectiye.j}focesses attempted to, establish ff homogeneity /df 3he work p j
.pdch v attributes had be9th aghievidjf or t s'electe rk lpeeeec&gi lktion htc y '
tb_g.cdiscip1ine/aryas.fDEEmil tabdi tuof wo%popu -
"f
_will be completed TW subsequent audits.
The construction adequacy review program is being performed within the purview of the Comanche Peak Response Team with ERC, Inc. reponsible for performing the review. The presentation made by Mr. John Hansel of ERC, Inc., at a public meeting held on October 3 and 4, 1985, in Grandbury, Texac, provided the basis for A/ the staf f's initial audit of the CPRT Construction Adequacy Program. t safety Work processes are being identified for construction of
/f components, and supports. Each work process will j' related systems, be evaluated by a random sample drawn from the associated population of systems, components, or supports related to that
/
work process. Further, sampleand items reviewed must are drawn be construction from Unit complete and
' 2, and common areas, jlg glg})y 2;;. _ d Each work process s mple is expanded to include anengineer64hsa.mple. The engineer sample assures that a number of safe shutdown system items equivalent to the number of items addressed by the random sample are also reviewed f or adequacy of construction.
Subsequent sections describe the NRC audits of this process.
e O
5
- g. gasser *~ss 3._Elggtcigel_ged_10gttymE01E1190d d Witpe+wsNTo*~GS 6 Bras
- win s^
,1 Aw.yMae i s The electrical and ins g 4 g ss subdivided into f i ve popule -a.en. grou (a) Instrumentation Equipment (b) Cable Tray (c) Electrical Equipment (d) Conduit
.' (e) Ceble
),
i s a In each group, the attributes f or reinspection were established.
d This provided the basis f or a unif orm approach to verificati
%[E'
$ without leaving out M The Construction Adequacy Program Review for the electrical d
\
populations is only addressing construction complete items is fabrication annot onl y includes construction activities. Vendor Program. For each of d - the Construction Adequacy y'h within the scope of ERC provfcTe'd a "FopulatitnT UEIscr*iption"
~ areas, the , boundaries,
~tWe~TecirTc al f which addressed the contents of each population, j h[e and any specific interfaces germane to the population.- In addition i
$3 t
g My to the " Population Descriptionsj"p ERC also provided a [1pw1char items
'E describing the work processes associated _ w2tb_.the. mechanica,
~~~T61s
~
~
f1ow chart contained attributes Kf wLheach~
t groupincL ERC indicated these attributes associated %itJi each work process.the checklists which are being are providing the basis for developed for re-inspection of electrical systems and components.
i ERC reported that the construction adequacy review is beingquality assu ,'
performed in accordance with their ouwnnos 14 4 y n aci tr mn t-n_pr.cgra.
e p #g which It Comp?tible with the the Cractruc4-i-on Adequacy Rev ew .Er_ooram .
3 p( .pytf- EftC's-ifnplemeni..ai.1 cii c fMemg audited - by-both-CPRT-end-ERG--qu
<3 rif'ij/ end-personnel.
The selection of the
, (a)_lDEICUGE0$9ti90 Eggigegottand the attributes themselves wer attributes, homogeneity and comprehensiveness. k ll.
The instrumentation equipment population is divided into two wor i
processes, and the attributes f or each process are as f ollows:
Installation attributes
- 1. Tubing / Piping and ComponentTubing Size & Marking, l Material Identification, System Bends, and Routing, Slope, Air Gap, Separation, Flex Hose Installation. Identification,
.g
- 11. Instrument Installation Location, Installation, attributes:
Separation, and Damage.
o h
~
6 The NRC staff and consultants discussedThe each work process auditors re-and attribute with the ERC personnel. and viewed how each work process and attribute was derived, behind ERC's consideration with respect reviewed the rational to the adequacy of the work processs and attributes.
item list was made listing An instrumentation equipment population Unit 2, and common areas.
all 1024 population items in Unit 1, These items were all safety related, and they were listed with their respective instrument tag numbers and flow diagram numbers.
Thic constituted the total population from which A random numberinstrumentation was generated for equipment camples were selected.
in the list, and a random sample of sixty each population item items was selected f or re-inspection and analysis. ThisNone sampleof the
$bOIS r / contains items only from Unit 1 and the common areas. construction A4%r ru items from Unit 2 were included as Unit 2 was under Eighteen S'g[ph[yhw and the Unit 2 items were not released from construction.
sixty items were related to sixty safe safe
- of this initial sample of rnd/
,ser/ gapW shutdown.
In order to establish the second sample of a further forty-two items were selected.
- d /" shutdown related items, selection of rdv' pnpg This method of sample selection resulted in a total eMg 102 items out of whicg si g g 39fye,re related to safe shutdown.
The samples self cted4 wer,e re-inspected as per ERC procedure No.01-012, Rev. O, dated 08/09/85, " Reinspection of Instrumentation Equipment".
From the documentation evalua+. ion and discussions with ERC personnel it apperars that the methodology for establishing homogeneity within the instrumentation equipment population is sound.
The auditors reviewed the f ollowing documents:
- 1. Gibbs b Hill Specification 2323-ES-100,i"dated Electrical October 15, 1980.
Erection Specification," Rev. 2,
- 2. TUGCO Instruction QI-OP-11.8-5, Rev. 15, " Inspection of Instrument Tubing Fabrication, Installation and Instrument Installation."
- 3. Gibbs & Hill Specification 2323-MS-625, " Instrument Tubing & Fittings," Rev. 3, March 19, 1980.
- 4. Brown & Root Procedure ICP-4, Rev.8, dated March 29, 1985
" Instrument and Tubing Installation and Inspection."
- 5. ERC Instruction D1-012, Rev. O, August 9,
, 1985, "Re-inspection of Instrumentation Equipment."
l :,
bl
- 6. ERC Instruction 01-013, Rev. 4, Sept. 25, 1985, " Quality i
5 Instruction for Issue Specific Action Plan ISAP-VII.c."
4, J
7
- 7. ERC document OA/DC-RT-341, " Population Description for Instrumentation Equipment," dated August 7, 1985.
- 8. ERC document DA/DC-RT-340, " Population items list for Instrumentation Equipment," dated August 7, 1985.
- 9. ERC document, " Definition of Work Process for Instrumentation Equipment Population Group," with work process flow diagram.
- 10. ERC document, " Instrumentation Equipment Population Item List."
- 11. "A Million Random Digits," by the Rand Corporation.
(b) Cabl e_Ttay This population has one work process: cable tray installation. The work process is supported by the following attributes: Identification and color code, No damage, Configuration (Tray size, Routing, Attachemnts, Welding, Rung spacing, and Bolting), Clearance, Fire stops, and; Separation criteria. One of these attributes, welding, has twelve contributing sub-attributes.
There are 5311 sections of cable tray in the population.
Brown and Root's Electrical Group is responsible f or the supervision of cable tray installations, with it's craftsmen performing the actual installation. The installation was performed employing: Gibbs and Hill specifications and procedures, Brown and Root procedures, and TUGCO Quality Instructions.
During the audit the work process and attributes were dis-cussed and evaluated, with respect to tne above documentation,
~
to determine how each was derived and approved by ERC. The auditors also reviewed the method used in the sample selection process where a sample of sixty safe shutdown items was l
selected to achieve a reasonably homogeneous population.
From the documentation evaluation and discussions with ERC personnel, it appears that the methodology for establishing homogeneity within the cable tray population is sound.
(C) EltEICiEgl_EguigGEDI The electrical equipment population is made up of two work processes with several supporting attributes. The two work processes are electrical equipment installation, and field assembly and field modifications. The population includes b
electrical equipment of various sizes and unique configurations such as electrical penetrations. Documentation used in the installation of this equipment are Gibbs and Hill procedures
O and specifications, Brown and Root installation procedures, and TUGCO quality instruction procedures. Brown and Root's Electrical Group is responsible f or the supervision of electric-cal equipment installation and Brown and Root's electricians perform the actual equipment installation.
x The above work processes, attributes, and documentation were discussed with ERC during the audit. It appears that the electrical equipment installation was perf ormed toasthe above specification and procedures in the same manner the other electrical populations. The sampling process is the same as for the previously described electrical populations.
1 From the discussions with ERC personnel, it appears that the methodology for establishing homogeneity within the electrical equipment population is sound.
(d) Gonduit This population has three wor k processes with the ;f ollowing supporting attributes:
- i. Selection attributes: Size / Material ii. Preparation attributes: Conduit / Fabrication. Cutting, De-burring, and Repair iii. Installation attributes: Identification, Origin /
Destination, Fittings, Bends, Pull points, Flexible conduit, Interface (tray), Clearance, Fire stops and seals, and Separation.
The work processes apply to both rigid and flex conduit.
The conduit was installed to Brown and Root specification and procedures. The above work processes, attributes, andIt documentation were discussed with ERC during the audit.
appears that the conduit population installation was performed to the Brown and Root specification and procedures in the same manner as the other electrical populations, Also, the sampling process is the same as for.
' the other electrical population. From the discussions with ERC personnel and the documentation reviews it appears that
).
the methodology for establishing homogeneity within the
[
conduit population is sound.
k O
e 9
O 9
~
(e) Cab _].e This population has three work processes with the f ollowing supporting attributes:
1.
Prepull attributes: Si=e, Type, Color, Defects, and Raceway.
- 12. Pull attributes: Lubricant, Routing, Bend radius, Spacing, Slack, Pull tension, Separation, Damage, and Repair.
Identification, Testing,
"# ii. Terminate attributes:
Insulation, Conductors, Terminals, Hardware,
"' # Landings, Heat Shrink, and Secure.
- ~}f 7 tnt ou wn - sizes.
fyrv u-s1 These three work processes encompasses cables of all documents were retiewed and 4,.ff During the audit several
/
- include Gibbs and Hill procedures;and g.g ,ge- evaluated, which Brown and Root procedures, ERC The quality Brown and d M gfftN!).specifscations,and 2nstructions, TUGCO quality instructions.
LM*7 Root construction management organization has beencable installa
/,(W8 # #_ responsible for all the beginning of construction work.
fit 7ff/
pr Each work process and attribute was discussed and evaluated, to determine how with respee? to the above documentation, Also
" p -r fv'd
- each was derived and considered adequate by ERC. d e#M :r- F- [M , shutdown samples were selected to achieve a reasonablyFrom th 7
,rf f homogeneous population. it ap' pears that the f and discussions with ERC personnel,
~ Il ef8 methodology for establishing homogeneity within the cable N e gf population is sound. -y v -. c trv' y r /.s A= --- = M v J ,o
- O
}fgflr/(h L...;
1 Naserieer>t ~ wur, inwmv rv zw .c Tw/> r a swwp q rf w w ie ?~eekn m-maau m w ev r r>,./
f pd **j w n
.r/ cemn- wks -
we c
}y &=Oop y M Ww my 7v+y is r> w m #
h /.
/ ~u on s n.c ~ r c, ~ w n ~/, <-
/A,sc/y,PJp'yr ma- < .c c--, ,
<~ ~ ~n -
s q,,+,p,zy, . am p , n
.; P oca " w -r> rrt ot-e <- is .w es.m sru c wo V' / p\pQ /t-f s'v e OcO /Cc'~.
l 1
a ah
[
10 4._t_1echggigal_Qu cie heg he N A Y f e v 4 g4ym a.ar are rvf 4 /W Su 5 D'v ' * **
The mechanical d4-scipM+me_.a.s[~h into nine population ( 44Le-t P Sl whrun- ar m s (a) HVAC ducts and plenums (b) HVAC equipment installation (c) Field fabricated tanks (d) Mechanical equipment installation (e) Large bore piping configuration
- (f) Small bore piping configuration (g) Pipe-welds / material (h) Piping system bolted joints / material .
Each of these populations was discussed with ERC personnel by NRC staff and consultants participating in the a dig 3,Theb v a) construction adequacy review for the mechanical -apl+ne is approximately 15 percent complete at the time of the initial, audit. Completion is scheduled for the end of February, 1986.
Only field construction work processes are addressed by the scope of this activity; vendor fabrication is not within the scope of the Construction Adequacy Program. For each of the mechanical' areas, ERC had prepared a " Population Description" addressing the contents of each category, i ts boundary, and any specific interfaces germane to the population. In addition to the Population Descriptions, a flow chart describing the work -
processes and associated attributes for each sample population was provided and discussed with ERC's Population Engineers. ERC l
indicated that these attributes provide the basis f or the checklists which are being developed f or re-inspection of mechanical systems and components.
ERC reported that the construction adequacy review is being i performed in accordance with their own quality assurance j program.rhich i= -r patible with the CFoT"= n"ali+v m s = ' r a n c e____
oroce.am M RU s i mpl ementati oTT Di the-c-enst uc ti on --rei nspecti on/-
.dru ument ation-i n a vn progr.m . . beii.g adited sby- both CPRT and ERC ouality-assurance-personnel,-- - --- ._
f Specific comments on each population within the mechanical discipline are provided in the subsequent paragraphs.
(
Hy@C_Qygig_ gad _Elgnymgz This population contains all l (a) passive equipment in the safety-related HVAC system whereas the HVAC equipment population contains only active items. The HVAC Duct and Plenum population encompasses 6800 items. Fabrication, installation and welding are the three work processes associated with construction of HVAC ducts and plenums. Bahnson Service Company was the only subcontractor to Brown & Root for all HVAC duct and plenum f abrication and installation.
Reasonable homogeneity is demonstrated because fabrication and installation of this equipment are each characterized by a 1
- /
W<#
r rp';r"'J.
11 e & ;p e-c qI f,2 & (
b If Pf f(J j!
workers f or f ayrication, welders f or (i M single craft -- sheet metal Iristallation and ~ af t[d r' J
instM h t~.idri,~5nd a' single subcontractor. Specification (Y ( ,
fMS-85.
abricat-ion procedures are based on Gibbs & HillTheoM attribu reviewed and appeared to be complete. p 6 were reviewed: f fgt gr
- 1. Work Process Definitions b <
- 2. Population Items List rWr.h V
- 3. Population Description [f l $ /
03-039, " Reinspection of HVAC Ducts & Plenums"
- 5. ci p It contains much 01-039 has been issued and is very detailed. documents and f sketc of the original The document review procedure has not been {
[
construction phase.
completed yet.
on a The HVAC Ducts and Plenums population has been modified based concern raised during the h 6 The work process be f orSett g[
pgg Equipment equipment install ati onA popul ati on gt d
combined with the mechanical tj since the same Brown & Root procedures and installation g specifications were used. 0 ,'/
z This population contains 604 (b) WAC_Egui gment _ Inst all at i gnin the safety-related HVAC system items of passive equipment tive items.
whereas the HVAC equipment population contains only acinstalled pie by Brow This equipment was either The work this was the basis for subdividing this category.i nstal l at i on ar e t_h,le,, g er %'
ru processes setting of associated with HVAC equipmenttheeach work process equipment are t'heand
. thenp, T "f con rt'/
Quctwork. t-urther, the attrioutes the installer. ofThe attributes associated with the f sam f regardless ofthe work processes were reviewed and appeared appropria g.A process.
The following ERC procedures were reviewed during the audit: ed
- 1. Work Process Definitions IW
' g-
- 2. Population Items List Tb 7W ~ r -
- 3. Population Description #m
/ w%rv r
- 4. QI-023, " Reinspection of HVAC Equipment." /#
This population has been modified based on a concern pft" during the audit. be conbined with the MEIN
- & Root has been deleted and will installation procedures and 77M e population since the same Brown & Root specifications were used. yne -
U
/H.ff?tt-e $llL'Y
& Jt'C' '-
' ef' 77 ft? .f ye W /
5W W Sgn
/1 A/ / d t? MW
~ * *** h e h rA e+t. ( HU_ C.
s 12 (c) Elgld_Eghticettd_Ignhgz This particular activity was discussed in a qualitative manner. ERC informed the audit would be team that eight field fabricated tanks exist and that all reinspected. This was not pursued further as population homogeneity was not an issue because of the 100 percent reinspection.
(d) Mechanical _Eguigmggt_Instelletigaz The mechanicalThe equipment installation population encompasses 336 items.
q,verning construction document is theThe Gibbs & Hill Mechanical implementation of this is Erection Specification 2323-MS-101. " General accomplished by Brown & Root Specification titled Installation of Mechanical Equipment", MCP-1. The governing quality assurance procedure is Brown & Root DI/QAP 11.1-39 titled
" Mechanical the Equipment Installation Inspection". Qualitative results of sampling conducted so far indicates that 20 to 25 percent of the sample drawn is from Unit The 2. The remainder of the work processes sample is from Unit 1 and common areas.
associated with mechanical equipment installation are setting, #,I anchoring, welding and, for rotating equipment only, alignment. P**
The attributes of each work process were discussed in depth. -ERC-v3^'
the work [
personnel indicated that if a particular attribute of F"
.I6 N processes was not addressed when the sampling activity ~
M'wascom
- suunple. yede{to ne dEKKifded_to inclyd}~thaLaftrib'utie." If a the %
~
,y decision was made not to specifically address that attribute, basis for this decision would be provided in in theinstance, this report addressing pg w erg r
the construction adequacy evaluation of, Work process homogeneity is evaluated fpe by M+* mechanical equipment. rv
(-
checking to make sure that the same organinti_ons_areand that the tweldet /W#
involved, ir Sampling bgf -ed' procedures
~ have remained nomina 11v cotutant,W '41 cation standards 7have inspecte is performed at the work process level. Since evaluation of fp/>.
,c each sample will be 0 be made for eachequipment work fy
$ja-equipment is made at the work process level, expanded such that sixty evaluations willThis means that more than n pus-the f,m
/ process. are addressed during completion of the sampling ,7f ga items (60) 4p d process.This particular category was pursued further in that an (rotating g, e
Mp,,9 sta11ation procedure for a heat exchanger and a pumpwas reviewed the e t' sairi t
- equipment) llation *
' pg ' attributes associated with work processes with the instaCompatibility did appear #
M equirements contained in the procedure."to exist between the vwor procedures for both cases. In one case, r/V
' g l or heat exchanger CP1-CCAHHX-01 was reviewed to see if.this /W3'/'
' gM p fd ' specific installation procedure was compatible with the attributes The p-
- f of the work processes f or mechanical equipment installation. 77)
M /'
y' [ qvt procedure f or installing an auxiliary f eed water pump,CP3-AFAP N f
alignment work process attributes. ge ,
Mg g
[
ij
'Y [ ,R f O4 SNkkicY h &e$)hhW%'?
/
5C
l 13 I i
.The f ollowing documents were reviewed as part of the continuing audit of the Mechanical Equipment Installation (MEIN) populati.pn
- 1. Work Process Definition for MEIN
- 2. Population Description
- 3. Population Item List 01-059, Revi sion 0, Draft Procedure Quality Instruction for Issue Specific Action Plan (ISAP) VII.C., " Reinspection of 4.
Mechanical Equipment Installation"
- 5. Original Gibbs & Hill Mechanical Erection Specification 2323-MS-101, Revision 4, dated 6/28/84.
- 6. Brown & Root Specification MCP-1, B/1/84, Revision 4, " General Installation of Mechanical Equipment"
- 7. Brown & Root DI-DAP-11-1-39, Revision 4, 6/11/80, " Mechanical Equipment Installation Inspection Procedure" Brown & Root, CCP-24 ,
Revision 4, 6/26/80, " Rigging" 8.
- 9. Brown & Root, " Grouting Base Plates, Bearing Plates and Equipment Bases", CCP-16, Revision 4, 2/8/84.-
- 10. Brown & Root, " Installation of Hilti Drilled-In Bolts",
CEI-20, Revision 9, 12/16/83.
The There are currently three work processes being reviewed.
welding work process has been deleted f rom the MEIN population and, as of October ERC 28, 1985, is hasreviewing also been putthe in the appropriate deletion of pipe grout weld work process.
from the attribute list and is establishing This change aisnew due population primarily to that the specifically addresses grout.
way documentation was established.
5 The ERC reinspection procedures and original construction specifications and procedures were reviewed and compared for i
' homogeneity of work processes and choice of generic attributes.
The auditors feel that all attributes listed are appropriate and d cover.the original construction sequence.
Five documentation packages from the sampled population were
}! reviewed for completion of documentation and comparison to general f
C specifications and attribute list.
The six documentation packages reviewed were:
(
O 1 _ESCYiEg_Wgtgt_Eumgz_EzQz_CP Q19:9913 Rotating Manual gaveequipment specific h installed per Hayward Tyler manual.
y tolerances on parallel alignment between motor half coupling i'
and collar.
o' .,
14 2._EteS5MCiERCz_EzOz_:9991:18z per Westinghouse drawings.
All dimensions f or installation are SleEsing1_and_gaz Specified A 3._ Safety _Infestigo_Eyegz_Ip1: tolerances on rim-to-rimInand face-to-face coupl a discussion requirement with ERC, was also given on vibration tolerance.ERC stated that this a list as a documentation check.
4._GEOttiiU9al_Gbetgigg_Eyest_ID1 GSOECB:91_and_GE:Q991:Q2d_igt is per manufacturer's manual. This pump is Unit _1 Installation part of the Chemical and Volume Control System and was fabricated by Pacific Pumps.
5._M919t:Dtiven_8uniligty_Eegdwatet_Eu225 t_Ez9t_GE 992:991z Criteria given Alignment is per manufacturer's specifications.
for checking anchor bolts, level and alignment and grouting.
Criteria given for backing off 6._Encess_Letdgwg_ Heat _Enchaggest of f oundation bolts to allow for thermal growth. Requirement given by Westinghouse.
The work processes and their attributes are considered equipment. The to be above appropriate to the installation of mechanical six mechanical component document packages were well documented and the appropri ate attributes listed on the ERC checklist. The be completed upon resolution of review of the MEIN population willA concern regarding the attribute of both torquing two open items. The " tightness" attribute as it applies to equipment anchor bolts. " hand tightening" from those may address the need to distinguish ~
instances requiring a specified torque limit. This issue will be further investigated in future audits. Second, ERC is reviewing i
the need for a vibration attribute.
(e/f) 68t99_ Bete _EiDiOQ C90ii9ytatign/Segll_@gte_Eiging The large and small bore piping configuration E90fi99C8ti90sconstruction adequacy reviews are addressed using 3000 Brown &
Root isometric drawings.
The scope of this activity is intended to assess the work process of piping installation through evaluation of attributes such as location, size, and orientation of piping and pipe components. The Brown & Root isometric drawings provide the basis for sampling both large and small bore piping. Large bore piping includes that piping which is 2-1/2 inches and larger in diameter; small bore piping is that piping less than 2-1/2 o
inches in diameter. If an isometric drawing containing both large a sample, it e
and small bore piping were to be drawn as partbore of work process would be used in both the large and the small review.
The installation work process and its attributes are the same for both large and small bore piping. The piping considered
'l ' in this review includes all ASME code piping. ERC reported that q
all piping of large and small bore is installed to one procedure 1
i d
i, 15 Some attributes such as piping and bywould valves one crafts the pipe obviously fitters. in any sample drawn for either be included large or_small bore piping. There are other attributes such as and strainers which because they expansion joints, screw joints, might not be included in any selected are very few in the system, a review sample. ERC reported that following the sampling process, to assess the adequacy of the sample for adequate representation of attributes would be made. However, a specific component, because it was not included in a sample, would not necessarily be examined only for that reason.
The number of attributes corresponding to theHowever, installation the of large bore piping appeared accurate and complete. through number of them seems to preclude evaluation If of them all ERC suggests that FAdMf/"
the random and engineered sampling process. 7gpar it is not imperative that all such as screwed joints, strainers; gvf ' T' ' ~
and expansion joints be evaluated f rom a configurationItviewpoint, appears ' ' ' [ O(
the2r report _should justify this_ type of conclusion.
components which are t' hat the sample shouldininclude piping some number of to provide confidence that these not extensively used Their sampling process appears components are installed correctly. valve to address the key items such as piping orientation, location and orientation, and bends.
(0) EiEe:Wglds_and_detecialt As with large and small bore pipe configuration, the welding of large and small bore pipe are Separate samples, however, are considered as one grouping.More than 66,000 welds are required to utilized to address each.
connect safety-related large and small bore piping. The work large or small bore processes associated with post-wel welding, welding di of ng eitherAs
. with the other are pre-welding, the population categories within the mechanical discipline, description was reviewed and appeared complete.
percent,The processThe of construction adequacy review is about 40 complete.
4 initial review has been completed; samples have been drawn and f preparation of reinspection procedures is in process.the sample drawn1 is oreither Unit Approximately 65 percent of ERC personnel were not sure if common. The remainder is Unit 2. It was indicated any Class 1 welds were included in the sampling.
I that Brown & Root performed all field welding. ERC f urther reported that the weld inspection processes are the samelarge The categories of and
- l. regardless small of the ASME code class. bore pipe welds were not separated to di the welding of stainless steel pipe opposed to carbon steel pipe.
K ERC indicated that the welders were qualified to weld both stainless steel and carbon At the steel piping exit and hence interview, there team the audit was no l-I need to separate this. stainless steel welds r, expressed concern regarding the lumping ofERC agreed to review the sample to jy with carbon steel welds. welds. Welds b determine the number of stainless and carbon steel addressed by this study include only field welds.
- i
'] <
ii d
16 Welds of the penetration sleeve to flange were included within this category. There are 282 such welds in this category.
None were included in the random or engineering sampling, however, [An??
the large and small bore samples were supplemented to include one mechanical and one electrical penetration weld. gggt Welds work processes and._attcibutes_ appear.ed, complete but gw r-u ey Pc sf M conclusions reUriding population . homogeneity.. cannot tae reached k rec 5 until review of implementation procedures and welder (dili fi cati ons i s' c'ompl'eted. Further, as previously noted, concern
~~~
entsts for the consideration'of stainless and carbon steel welds as part of the same population.
The piping welding area was audited and verified f or the following: (1) the basis for establishment of each population; (2) population boundaries; (3) population exclusions; (4) population interfaces; (5) population list source and basis; (6) work process and (S) and basis; (7) attributes associated with work process; source of attributes.
Based upon the fact _that bnth laroe bore and small bore pipe
~s i i-We.l ds perelf ab^r_ica_ted _to _the samego.gedure and bEttl 1s me craf t_, ~
ER_C_ decided ,to, lump t_he_p.oqulations togetheh The staff reviewed the Large Bore Welding Materials (LBWM) and the Small Bore Welding Materials (SBWM) population basis, description memorandum, population description, populations item list and work process definition. ERC indicated that only one work process was chosen, Welding. Apparently, regardless of the possible differences in the welds (con f i gur ati on, material type, or process) each work (2) process involves: (1) common erection specification requirements; common installation procedure requirements; (3) common craft labor operations; (4) common performing the same basic andtypes(5) ofa common inspection organization.
inspection procedure; The auditors noted that ERC has revised the welding population and work processes The as a resultcombines revised population of concerns raised and )$k large-bore during the audit. ~
D * 'he all-bore piping weld, since the same weld-pr'ocedure M,-
cations were used. Within the welding process, two welding
~
metFiods wers'used: -sas-Tenigs' ten Arc Welding (GTAW) and Shielded
~
Metal Arc Welding (SMAW). Both methods were utilized for carbon g r #"j f' ir/
y,v(/
E
[
r and stainless steel welding and were performed by the_same worksixtyfl[gp force. Therefore each welding method will have a minimum of p ,s
- randomly selected samples. This revision of the Pipe f'j/ ' h Wel ds/Materi al Population Group (PIWM) resulted in a more AF#yfJ" homogeneous approach to the PIWM reinspection.
ERC pointed out that welder qualification is in compliance , f
, with Brown & Root Specification WES-031 which qualifies a6 we "o
to both corbon and stainless steel welding. The staff reviewed
" Welding and WES-031 and Brown & Root procedure CP-CPM-6.9D, ef(f Fj Related Processes", and found very few areas where the procedures F or specifications differed with regard to carbon and stainless (f steel welding. Differences were associated with the two welding g methods GTAW and SMAW.
ERC stated that of the 120 samples already welds. O d' established, approximately fifty percent were stainless steel i
yter aetr nFev ce 0:0 er.
temocerter ry Irwf E
e t% g e,).<
_N lb irc i d t' A N tNa rttcw rtNff gds g T St1/.S ,
er 1 ', !)Wr i
~Mcv%) wyn .f,9,,q', e u
- l -n+ tS
4 17 In addition, an engineered sample of sixty welds for each method was picked to account for safe shutdown systems. In both cases, 2
GTAW and.SMAW, the original sample of sixty welds and the This necessitated increasing the engineered sample overlapped.
original sample to achieve the engineered sample of sixty welds.
In all, a total number of approximately 180 samples will be inspected.
Under the work process identified as " Welding", 24 attributes were identified, out of which 18 of the attributes are common to both welding methods and to all welds. The remaining 6 attributes will be inspected as the sample dictates. Additional samples for f ett these 6 attributes will be chosen as deemed necessary, or a FC justification for not increasing the sample will be gi,ven at that_ owe
~
time. Ub#
The auditor also reviewed the original Brown & Root specification. It was noted that the original specification required noting of cleanliness and listing of any base-metal defects. The attributes listed on the PIWM checklist did not include these two elements. ERC was asked to review and comment.
(h) Pigigg_gygtgm_@gitgd_JgiDt sz Two work processes comprise They are installation the piping system bolted joint category.There are 7000 bolted joints at preparation and final bolt fitup. The work processes and the Comanche Peak Steam Electric Station.
their attributes appear to adequately represent the bolting of piping joints. The procedure which governs thi s i s CP-CPM-6.9E, Revision 8. A flow chart and population description had been prepared to provide the basis f or the sampling of bolted joints.
The staff's audit did not yet pursue this to the depth required to draw a firm conclusion regarding the homogeneous nature of the work process populations.
The following ERC procedures were reviewed during the audit.
- 1. Work Process Definitions
- 2. Population Description
- 3. Population Items List
, 4.01-021, Revision 1, " Reinspection of Piping System Bolted Joint Materi al . "
The NRC auditors raised the concern on torque being an
- attribute and not a work process. The concern was relative to equipment specifications requiring a specific torque value on certain types of flanges and the reinspection attribute not containing sufficient samples. In the discussion with ERC, it was noted that there are approximately 7000 items in the piping6700 system are bolted joint population. Of the approximately 7000 items,
- in line-piping connections which were installed in accordance with Brown & Root Procedure CP-CPM-6.9E. Section 3.12 of the Brown &
g e
Root procedure did not require a specific torque value to be used.
Y, f.
18 "shall be tightened The governing requirement was that the Since jointleakage during pressure testing".
sufficiently to prevent ISAP VII.C is addressing QC-accepted items, only reinspection per the original specification is required. The only flanges which may have required specific torque values would therefore be in the Mechanical Equipment Population. ERC has reviewedflanges the MEIN which population and has only f oundTherefore, approximately sixthe issue raised during the required specific values.
audit is not an issue for the Piping System Bolted Joints population.It was also noted that the Population Description and Population Item Lists will be revised to delete instrument area.
flanges. These will now be included in the electrical e
t I
.i
19 5._Givt1LSituttutgl_Disgiglingdiscipline is divided into 15 populations The c'ivil/ structural which are:
(a) Concrete Placement (b) Structural Steel (c) Liners (d) Fuel Pool Liner (e) Fill And Backfill Placement (f) Grout-Cement (g) Grout-Epoxy (h) Large Bore Pipe Supports - Rigid (i) Large Bore Pipe Supports - Non-rigid (j ) Small Bore Pipe Supports (k) Large Bore Pipe Whip Restraints (1) Instrument Pipe / Tube Supports (m) Category 1 Conduit Supports (n) HVAC Duct Supports (o) Equipment Supports by the Most of these and areas were discussed with ERC personnel consultants participating in the audit. Some NRC staff areas have been reviewed in depth while beothers havefurther examined been in treated in a cursory manner and will future audits. Populations (k) through (1) have not been reviewed as of this time because they had recently been formulated and the work processes and work process attributes were still being developed.
(a) ggggtgtg_Elacgmggtz The auditors reviewed the homogeneity of the work following documents to determine if processes and attributes had been achieved.
- 1. ERC's Work Process Definitions f or Concrete Placement Population.
8/5/85.
2.
ERC's Population Description for Concrete Placement, y 3. ERC's Population Items List for Concrete Placement, 9/5/85.
Ff
['. Revision 0, 9/16/85, Procedure, Quality J. 4. Procedure 01-043, Issue-Specific Action Plan No. VII.C.,
yi Instructions f or
" Reinspection of Concrete Placement".
g 1/16/79, " Concrete".
- 5. Gibbs & Hill Specification 2323-SS-9, kh 2/10/84, " Structural r 6. Gibbs & Hill Specification 2323-SS-30, M'
Embedments".
(
J1 35-1195-CCP-11,
- 7. Brown & Root Construction Procedure JJj " Concrete Placement", Rev. O.
1 I$
L1
I O, '
i
- 20
' The concrete placement population each work processis presently havingsubdivided various into three work processes,Some of the attributes are to be reviewed numbers of attributes. others can only be reviewed by by means of a field reinspection;and some will be reviewed utilizing means of a document review; The field both field reinspection and documentation review.
reinspection was in progress at the timeNoofreinspection this audit and the packages documentation review had not yet begun.
were reviewed. however, the A few concerns evolved from this audit; concrete placement's work process reinspection of does achieve an appropriate level of homogeneity. These concerns i
were discussed with ERC and were lef t as open items. The f ollowing is a list of open-items:
~ ~
- 1. It may be more appropriate to establish cadwelds as a worknRC is to review the proc,ess rather than as an attriEEte.
inspection procedure and the concrete pour card sign-off requirements to determine whether cadwelds should be a separate work process.
ERC is to consider - establishing Richmond Inserts as a , separate attribute instead of including it with the embedment attribute.
2.
3.
ERC is to determine if the condition exists whereIf embedded pipe this situation sleeves does exist, are used to anchor the piping system.the embedded sleeves sho (b) @ttugtucal_Steglz Cursory thereview concept of this area was of choosing done work during the audit to determine if A processes and attributes would achieve acceptable homogeneity.
limited review of the following documents was performed.
1, 10/23/85, and Change Notice 001,
- 1. Procedure QI-045, Rev. Instructions for Specific Action Plan VII.C.,
10/23/85, Quality
" Reinspection Procedures for Structural Steel".
Structural
- 2. ERC's Description Memorandum for Reinspection ofdated 10/8/85; O, dated 9/15/85; (ii) Rev. 1, Steel: (i ) Rev. 1, 10/23/85.
(iii) Change Notice to Rev.
" Structural steel",
2
- 3. Gibbs & Hill Specification 2323-SS-16B, 5/12/75.
" Verification of Baseplates .
- 4. TUGCO Instruction QI-QP-11.0-15, f or Grouting", Rev. 8, 3/13/85.
the structural After performing this general overview ofit is f elt that the work processes f steel reinspection activity, achieve acceptable
- 5.j e, and attributes identified generally willa more detailed audit of the reinspection homogeneity. However, 1
,; procedures will be required to make more detailed comments.
L
. ~.
21 (c) Liggtsz The containment liner population includes horizontal, vertical, and penetration welds. The work processes were reviewed and ERC was informed that consideration should be given to including a plumbness requirement as a work process.
Also, it was suggested that ERC consider revising the tolerance when a 6-inch template is substituted for a 10-inch template.
This area will be reviewed in aubsequent audits.
(d) Eggl_Pgg1_Liggtgz The first audit addressed only the welds covered by travelers will formation of the populations. All form this population. This area will be reviewed in subsequent audits.
(e) Eill_ggd_@gchfill_Elecemggtz The initial audit addressed the population f ormation and the work processes within the and Testing is a work process within this population population. Consideration should be given to the need for not within concrete.
consistency. If testing is retained as a work process, the population description should be modified to reflect this as a separate work process.
These are new populations (f/9) @C991Cgmentl@tgyt:Eggtyz which have not yet been reviewed.
i (h/i/j) Latge_@gte_Eiog_@ugggttg_ _ Rigid _fL@@RlLNggt All of the noted pipe gid IL@@N14@ mall _@gtg_Eige_Sygggtig_fgBE@lz in the audit. These populations rigid and support populations were addressedwere formulated in order to assure a non-rigid pipe supports. This is important, The
" standard catalog supports" are in the non-rigid category.because the number of small bore sampling bore was not divided, supports is very small and also because the(as non-rigid small is not readily obvious from the support number in the case for LB supports). ERC intends to sample 60 supports type of support The SBPS from each of the three groups (LBSR, LBSN, and SBPS). fabrication, de up of four work processes:
The ERC management seemed installation, welding, and inspection.
I ]fe'"* topopulation was ma inspection should be a work process I
~
benconfused as attributp.to whetherThe two LB populations did not show inspection as 7,/ F a work process. After much discussion, the individual in charge of
, ,4AD the SBPS group indicated that rework to a support very often an UNSAT
.s
, 5 occurred during the(IR). inspection phase as a result ofSince this work was perf this was a PIggf *I umbrella InspectionofReportinspection in order to close out the IR, The individuals in charge of the LB However,group i
TDTb separate work process.
\%' appeared hesitant to accept this but eventually they did.ERC upper m at the exit interview,
,l y agreement and said that they would like to investigate this area l
i 0
. ~.
9 22 They indicated that if they made any changes they would contact the staff (the staff agrees with inspection being a further.
separate. work process).
The staff reviewed the various documents population (descriptionitems memorandum, population description and basis, attribute description and basis, list, work process justification, and 01-019-020, 027 through 030). An auditable trail existed such that all work processes and accompanying attributes could be verified. The staff noted that under pipe supports welding two ERC attributes were omitted (cleanliness and base metal defects).
pointed out that cleanliness was unattainable both from anand from the point inspection standpoint (prewelding attribute),
(cleanliness was not a hold point on of view of document review (MWDC)). ERC also said that they did the Multiple Weld Data Carddefects for supports as an attribute, since not include base metal it was difficult to see defects through the paint. The staff defects pointed out that requirements for identifying base metal exi sted in ASME ERC Subsection statedNF-4000 AND the that during Brown & Root Procedure reinspection of the DI-DAP-11.1-28.
sample supports, base metal defects were looked for in each case and noted as an "out of scope" observation for inclusion in the normal deviation system. The staff would not accept this,, and After some discussion, ERC asked ERC to reconsider this approach. defects into the attribute list and to committed to put base metal treat all instances as part of the construction adequacy.
the pipe (k) Latgg_Egtg_Eigg_ Whig _Bggttgiatgz An overview of This population whip restraint population was provided by ERC. moment restraints, pipe wh consists of Due to the support _ structures listed in Section 3.6 of FSAR.two populations one for may be esta original construction, the restraint and one f orSomethe support structure.
restraints are Ninebysystems listed Gibbs &have Hill postulated line breaks. At this time and other restraints are listed by Site Damage Group. reviewing the wo ERC is still E groups were responsible for installation.
r: .
(1//m//n//o) Insttyment_Einallukt_EuanettsllGetteetylG90duit These Euanettalld28G_ Duct _EunnettallEggigegat_Sygggtigzpopulati been reviewed.
y Yl
<t i
I $