IR 05000445/1986022
| ML20245A119 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/10/1987 |
| From: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20238B208 | List:
|
| References | |
| FOIA-87-428 NUDOCS 8702180081 | |
| Download: ML20245A119 (62) | |
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"" 1 ' I Docket Nos. 50-445 and 50 4',6 FEMORANDUM FOR:
Eric H. Johnson, Director Division of Reactor Safety and Projects Region IV
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FROM:
R. Lee Spessard, Deputy Director Division of Inspection Programs Office of Inspection and Enforcement SUBJECT:
INSPECTION REPORT REVIEW ASSISTANCE - COMANCHE PEAK
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This will confirm the completion of our review of Inspection Report 50-445/86-22; 50-446/86-20 4, 6crordance with J. M. Taylor's memorandum to R. D. Martin dated
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June 26, 1965.
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l As a part of our re i ew process, we' provided copies of the report to NRR i
(Trammell) and OGC (r.izuno) for comment.
Both NRR and 0GC had several comments; these have been coordinated and resolved through discussions with I. Barnes.
Our concurrence in the report was provided on February 10, 1987, as noted on the enclosed report.
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R. Lee Spessard, Deputy Director Division of Inspection Programs Office of Inspection an8 Enforcement
Enclosure:
Inspection Report
REGION IV==
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NRC' Inspection Report:
50-445/86-22
Permits:
CPPR-126
50-446/86-20
CPPR-127
Dockets:
50-445
Category:
A2
50-446
Licensee:
Texas Utilities Electric Company
Construction Permit:
Expiration Dates:
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Unit 1: August 1, 1988
Unit 2: August 1, 1987
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Applicant: Texas Utilities Electric Company
Skyway Tower
400 North Olive Street
Lock Box 81
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Dallas, Texas 75201
Facility Name:
Comanche Peak Steam Electric Station (CPSES),
Units I & 2.
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Inspection At:
Glen Rose, Texas
Inspection Conducted: July 1 through August 31, 1986
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Inspectors:
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L. E. Ellershaw, Reactor Inspector, Region IV
Date
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CPSES Group
(paragraphs 2.n, 2.v-z, 2.0, 4 b-c, 4.f-h,
6.1, 7, 8, and 9)
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C J. Hale, Reactor Inspector, Region IV
Date
C6;ES Group
(paragraphs 2.a 2.m
2.0, 4.b-c, 4.f-h,
6.a, 7, 8, and 9)
P. C. Wagner, Reactor Inspector, Region IV
Date
CPSES Group
(paragraphs z.b.-1, 2.p-u, 4.1, 5.1, and 6.b)
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Consultants:
EG&G - J. Dale (paragraphs 2.z, 3, 4.j, and 5.j)
A. Maughan (paragraphs 2.b-1, 2.p-u, and 5.a)
W. Richins (paragraphs 2.n, 2.v-y, 4.d 5.e)
V. Wenczel (paragraphs 8 and 9)
Parameter - J. Birmingham (pardgraphs 4.b-c, 4.f-h, and 7)
K. Graham (paragraphs 4.3, L.c-d, 5.f, 5.1 and 5.b)
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D. Jew (paragraphs 4.1, and 5. g-h)
Reviewed by:
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R. L. Spessard, Seputy Director, Division of
Date
Inspection Programs, Office of Inspection
and Enforcement
Approved:
1. Barnes, Chief, Region IV CPSES Group
Date
Inspection Summary
Inspection Conducted:
July 1 through August 31, 1986 (Report 50-445/86-22;
50-446/86-20)
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Areas Inspected:
Nonroutine, unannounced inspection of applicant actions on
previous inspection findings; employee protection posting; assessment of
allegations; Comanche Peak Response Team (CPRT) issue-specific action
plans (0 SAPS); CPRT central and working files; ERC overview inspection program;
dnd procurement, receiving, and storage.
Results:
Within the seven areas inspected, four violations (stainless steel
and carbon steel were stored in outside areas with improper protective end
coverings, paragraph 6.1; records of heat treatment were not available for disc
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inserts and spares for main steam safety valves, nor was it apparent that
proper source and receipt inspections were performed, paragraph 4.6;
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nonconformance reports (NCRs) dea'..ng with installed valve bonnets were
incorrectly dispositioned, paragraph 4.1; and a correct assessment was not
provided regarding adequacy of design with respect to. square groove welds in
HVAC duct supports, paragraph 2.z) and six deviations (objectivity forms and
evaluations had not been completed for certain members of the CPRT staff,
paragraph 2.a; and Evaluation Research Corporation (ERC) documentation package
review failed to identify four inspectors ano two welders involved in the
package being reviewed, paragraph 4.h; ERC overview inspection failed to
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identify deviating conditions and unsatisfactory decisions made by the initial
ERC inspector, paragraph 4.j and 5.g; ERC identified eight deviations on a pump
but did not tag the pump, paragraph 5.c; diaphragm valves were purchased to an
earlier version of the ASME Code than that consnitted in the Final Safety
Arialysis Report (FSAR), paragraph 4.1; and ERC engineering did not identify all
sdfety signifiCant attributes on the inspection checklist for mechanical
equipment inst 611ation, paragraph 5.c) were identified.
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DETAILS
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1.
Persons Contacted
- J. W. Audas, Senior Licensing Engineer, Texas Utilities
Generating Company, (TUCCo)
- J.,L. Barker, Engineering Assurance Manager TUGCo
L. B. Barker, Executive Assistant TUGCo
- R. T. Bentley, Technical Assistant, CPRT
- C. T. Brandt, Quality Engineering Supervisor, TUGCo
- R. E. Camp, Project General Manager, Unit 1. TUGCo
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- W. G. Counsil, Executive Vice President, TUGCo
B. DuBois, Quality Assurance (QA) Manager, TERA
P. E. Halstead, Site Quality Control (QC) Manager, TUGCo
M. Keathley, Lead Electrical QC Inspector, ERC
- J. Krechting, Director of Engineering, TUGCo
- J. Mallanda, Electrical Review Team Leader, CPRT
- J. T. Merritt, Jr., Director of Construction, TUGCo
C. K. Moehlman, Project Mechanical Engineer, TUGCo
- J. T. Merritt, Jr., Director of Construction, TUGCo
C. K. Moehlman, Project Mechanical Engineer, TUGCo
- L. D. Nace, Vice President, TUGCo
0. Nevins, Training Coordinator. TERA
A. A. Patterson, Reinspection Engineering Supervisor, ERC
- F. L. Powers, Assistant Unit 1 Project Manager, TUGCo
P. Pussalugo, Equipment Qualification Engineer, TUGCo
F. Schafer, Systems Engineering Manager, TERA
B. Shair, Lead Electrical Engineer, ERC
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P. Stevens, Electrical Engineer, TUGCo
- J. F. Streeter, Director of QA, TUGCo
T. G. Tyler, CPRT Program Director, TUGCo
R. F. Wright, Manager, Warehouse and Material Control, TUGCo
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The NRC inspectors also interviewed other CPRT and applicant employees
during this inspection period.
- Denotes persunnel present at the August 7, 1986, exit interview.
- Denotes personnel present at the September 5, 1986, exit
interview.
- Denotes personnel present at both of the above exit interviews.
2.
Applicant Action on Previous Inspection Findings
a.
(Closeri) Deviation (445/8511-D-02):
An issue coordinator that had
been previously involved with CPSES activities had not been
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identified to the NRC, nor had the CPRT provided justification
regarding his objectivity as required by Section VII of the CPRT
Program Plan.
Revision 3 to the CPRT Program Plan deleted the commitment from
Section VII to identify.and provide justification to the NRC when
third party personnel were found to have had prior CPSES involvement.
By letter to the NRC dated April 1,1986, (Counsil to Johnson), it
was further committed that all CPRT personnel would complete
objectivity questionnaires (Attachment 7 of the CPRT Program Plan).
When completed questionnaires identified prior CPSES involvement or
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association of an individual, further evaluation was required by the
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Senior Review Team (SRT) for Review Team Leaders (RTLs) and by the
RTL for their assigned personnel.
In such cases evaluation forms
were to be completed documenting the basis of the SRT or RTL
conclusions concerning the objectivity of such an individual. These
objective and evaluation forms were to be completed by the end of
April 1986.
The NRC inspector verified the implementation of these revised
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commitments by:
(1) a review of a sample of the ERC and TERA files
on objectivity of personnel (the TERA records were in Bethesda,
Maryland, and QA branch personnel from the Office of Inspection and
Enforcement conducted this review); (2) review of all the objectivity
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records of the testing and electrical personnel; and (3) review of a
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objectivity questionnaires and their evaluations by the appropriate
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authority were found to be in compliance with the revised commitments
with the following exceptions.
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The technical support staff (two individuals) of the CPRT Program
Director had not completed objectivity questionnaires nor had the
personnel on the records review committee. The CPRT Program _ Director
did not believe the revised commitment applied to these individuals;
however, the commitment states that these documents had been
completed for the SRT, RTL, and support staff.
Further, a commitment
was made to document an evaluation of the objectivity forms for all
CPRT personnel by April 1986; however, such an evaluation was not
made for the CPRT Program Director and the TERA RTL evaluation was
not completed until July 17, 1986. These findings represent ~a.
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deviation from commitment (445/8622-D-01; 446/8620-D-01).
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b.
(Closed)OpenItem(445/8511-0-01):
Incorrect electrical pull box
location.
Further NRC review established that the ERC determir.6 tion
of incorrect box location was based on a drawing which was for
guidance only and did not contain mandatory location requirements.
The NRC inspector verified that the box had been properly installed
and met all of the required quality procedure checklist items.
Further NRC review fo @und that NRC Inspection R
(Closed) Open Item (445/8511-0-09): i
cable trap edges and cable
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jacket damage.
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50-445/86-01; 50-446/86-01 hud incorrectly associated NCR ES5-100831
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with this open item. The correct NCR (i.e., E85-100844) was found to
h6ve been dis ositioned and closed.
The disposition stated that
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since the s op edges were not inside the cable tray but were on the
troy's lip, a ove the cable jacket, the conditions were acceptable.
The NRC inspector performed a reinspection of the cable tray and
found that the NCR had been properly dispositioned.
d.
(Closed) Open Item (445/8511-0-11:
Loose splice plate bolt.
Further
NRC review found NCR E85-100988 had been dispositioned and closed.
The disposition stated that the nut was jammed and could neither be
tightened or removed.
The condition was determined to be acceptable
since Design Change Authorization (DCA) 3883, Revision 2, requires
only six bolts per -plate and there are eight bolts in this plate.
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The NRC inspector performed a reinspection of the splice plate for
this NCR and found that the NCR had been properly dispositioned.
e.
(Closec) Open Item (445/8511-0-21): Missing fire seals. The
findings that fire stop sealing material was not present in the
conduit stubs which entered a control room panel was evaluated during
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a review of the ERC deviation report (DR). A review of the
dpplicable project requirements by the NRC inspector showed that the
seal material can be installed in either end of the conduit and an
inspection revealed that it was installed in the opposite end of
these conduits.
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f.
(Closed) Open Item (445/8511-0-22):
Improper electrical separation.
The condition of conduit C13016035 ending just under tray T030CCQ64
instead of ending 10" above the tray was identified during a
witnessed ERC inspection.
Further review by the NRC showed that
Drawing 2323-El-1702, Note Sc, allowed this type of installation
provided 2" of slack was maintained.
Reinspection by the NRC of the
installation found it to be acceptable,
g.
(Closed) Open Item (445/8511-0-23):
Group of cables bearing on
single cable,
Further review by the NRC found NCR E85-101047X had
been dispositioned and closed.
The disposition stated that the
indentation of the cable outer jacket was minor and would not affect
conductor performance.
The NRC inspector performed a reinspection of
the cable and found that the NCR had been properly dispositioned.
h.
(0 pen) Open Item (445/8511-0-24):
Lack of cable slack. This item
pertained to a lack of the required 2" of cable slack at the cable
tray (T130SC65) to conduit (C13015570) transition for cable E010C091.
Further review by the NRC showed NCR E85-101211SX had been written
for this deficiency.
This item remeins open pending disposition of
the hCR.
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(0 pen) Open Item (445/8511-0-31):
Cable with cut outer jacket. This
item pertained to a two conductor cable with a cut outer jacket which
was located at the floor penetration for motor control center (MCC)
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Further review by the NRC showed NCR E85-101048X had been
written for this finding. This item remains open pending disposition
of the NCR.
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(0 pen)OpenItem(445/8511-0-32):
Incorrect tray to conduit
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separation. This item pertained to less than the required 1" of
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separation between a cable tray (T030 SCC 68) and a lighting conduit.
Further review by the NRC shoed NCR E85-1001805 had been written for
this finding. This item remains open pending disposition of the NCR.
k.
(Closed)OpenItem(445/8511-0-38): This item perteined to the lack
of CPRT quality instructions governing ISAP I.1.5 activities.
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Further review by the NRC of the required tasks, redispositioning of. -
NCRs and obtaining a vendor analysis report, showed that the
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activities were already governed by acceptable existing site
procedures.
1.
(Closed) Violation (445/8511-V-01):
Inspector failed to write NCR.
During an NRC witnessed reinsperb on, a TUGCo QC inspector failed tot
document nonconforming conditions and process an NCR in a prompt
manner relative to out-of-scope ERC inspection findings. The
inspector involved was retrained to Procedure CP-QP-16-0,
"Nonconformances," on September 16. 1985.
For the nonconforming
conditions identified, TUGCo has issued NCR E85-100993X.
In addition
to the above actions, ERC Procedure CPP-020 "Out-of-Scope
Observations," Revision 0, was issued on August 23, 1985, to provide
a procedure to third party inspectors to follow in documenting
out-of-space observations.
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(Closed) Open Item (445/8511-0-37):
Prior to the development of the
design adequacy procedures (DAPs), TERA personnel used informal work
instructions to control their activities.
The DAPs manual was issued in October 1985. This manual is fully
developed, presently containing 23 procedures.
NRC inspectors from
the QA branch in the Office of Inspection and Enforcement have
inspected the adequacy and implementation of these procedures at
TERA's office in Bethesda, Maryland, and Berkeley, California.
The
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results of these inspections are documented in NRC Inspection Reports
50-445/86-17; 50-446/86-14 and 50-445/86-19; 50-446/86-16.
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NRC personnel involved in these inspections observed that very little
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work was performed by TERA prior to March 1986 that would have
required these procedures being in place. Therefore, the DAP manual
was issued before substantive TERA work was conducted.
n.
(Closed) Deviation (446/8513-D-11): This deviation addressed field
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reinspection of a containment liner packages that included weld seams
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between materials of unequal thickness. Change Notice 001 to QI-031,
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Revision 2, provided guidelines for measuring reinforcement of welds
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using a contour gauge for weld seams between materials of unequal
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thickness. Approximately 38 containment liner packages were
reinspected. Two new DRs were issued, ten were superseded, and six
"
were invalidated. The NRC inspector inspected containment liner
Verifiu. tion Package I-S-LINR-061 using Change Notice 001 to QI-031,
Revision 2, and found the weld reinforcement to be acceptable. A
sample of the results of the' additional reinspection by ERC for weld
reinforcement was reviewed by the NRC inspector. The committed
corrective actions were found to by the NRC inspector to have been
correctly implemented.
o.
(Closed)'Open Item (445/8513-0-01): TERA identified a potentially
reportable condition on August 27, 1985. This open item was to track
its disposition.
Discrepancy / Issue Resolution Report (DIR) D-0004 was initiated by
TERA on August 27, 1985, concerning the evaluation of an air gap
deviation using methodology in apparent conflict with FSAR
commitments. On Vuly 26, 1985, a significant deficiency analysis
report was issued (CP85-27) and the NRC was notified that the matter
was.potentially reportable under paragraph 50.55(e) of 10 CFR Part 50.
On December 17, 1985, this item was determined to be
reporteble and e report was submitted to the NRC. This matter is
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included in the CPRT's assessment under ISAP II.c, which the NRC is
monitoring on a continuing basis. Accordingly, this item is closed,
p.
(Clesed) Open Item (445/8513-0-25):
Conduit separation and loose
fittings. This item pertained to two loose conduit couplings'and
separation between two conduits being less than the required 1".
These conaitions were identified during a witnessed ERC inspectier,
and were' additionally addressed in NRC Inspection Report
50-445/86-01; 50-446/86-01. NRC review during this report period
found that NCR E85-101496SX had been dispositioned and closed. The
disposition of the NCR required the couplings to be tightened and the
conduits reworked to meet the 1" requirement. The NRC performed an
inspection of the conduits and found the reworked condition
acceptable,
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(Closed) Open Item (445/8513-0-28):
Incorrect tray node
identification. This item pertained to a trey section identification
tag not located as shown on Drawing 2323-El-0500-15.
Further NRC
review of Drawing 23E3-El-0500-16 found that note 1 is used only to
identify the location of the tray segment, not its identification.
Review of TUGCo Instruction QI-QP-11.3-24, " Class IE Cable Tray
Raceway Inspections," by the NRC inspector found that the tray
identification tag was properly installed.
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(0 pen) Open Item (45/8513-0-38): Misaligned torque indicators.
This item pertaint:0 to anti-torque.
Indicators on flexible hose
connections wicch were misaligned.
Further NRC review found that
DR-I-E-ININ-005-DR01 and NCR 175-101251SX had been written for this
condition. This item remains open pending disposition of the NCR.
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(0 pen)OpenItem-(445/8513-0-39):
L % lighting switch box. This
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item pertained to a lighting circu t. switch box which was loose.
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Further NRC review found that NCR E86-101053X had been written for.
this condition. This item remains open pending disposition of the
NCR.
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(0 pen) Open Item (445/8514-0-03): Cable routing and conduit
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identification. The conditions of incorrect routing for cable
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EG113538 end two through-wall conduit. sleeves with the same
identification number were noted during a witnessed ERC inspection.
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Review of ERC Verification Package I-E-CABL-078 by the NRC inspector
showed that DR I-E-CAB-078-DR01 and NCR E85-101382SX had been written
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for these conditions. This item remains open pending disposition of
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the NCR.
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(Closed) Open Item (445/8514-)-11):
Incomplete procedure. The
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condition that an ERC procedure (Q0-009) did not reference the
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specific procedures for plant Class IE lighting conduits was resolved
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by the initiation of e new population for lighting circuits.
The new
population covered all aspects of the plant lighting circuits,
including the conduits, and resulted in the removal of lig~nting
circuits from the other populations;
i.e., conduit, cables,
equipment. Therefore, the new population eliminated the need to
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incorporate lighting conduit procedures in the conduit inspection
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procedures.
v.
(Closed) Deviation (445/8516-D-41):
This deviation
addressed:
(1) an inconsistency regarding measurement of liner
contour between ERC QI-031, Revision 0, for containment liner
reinspection and Gibbs & Hill (G&Fi) Containment Liner
Specification 2323-55-14, Revision 4; and (2) a failure to provide
comprehensive instructions far reinspection of containment liner
contour using a 10' straight edge.
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The committed corrective action involved the revision of the
applicable paragraphs in QI-031.
ERC conducted a review of each QI
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for clarity and discussed changes to QI-031 with the ERC inspectors.
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QI-031 was revised and Revisior. I was issued on January 15, 1986. A
review of inspection packages completed prior to this date was
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reviewed by the NRC inspector.
The committed corrective actions have
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been made to determine if any package was inappropriately marked
"N/A" for Attribute A.1.b.
In addition, ERC determined that previous
inspections using the 10' straight edge (Attribute 1.1.d) were
correctly performed.
The NRC inspector reviewed the changes made to Q0-031 to assure
consistency with G&H Specification 2323-SS-14 and that adequate
instructions were provin d for the measurement of containment liner
contour. The NRC inspector also discussed with the ERC population
engineer and inspectnrs, the methods used for inspection of these
ettributes prior to January 15, 1986.
The NRC inspector reviewed an
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additional ten containment liner reinspection packages and determined
that the original ERC reinspection conformed to Attributes A.1.b. and
A.I.d of QI-031, Revision 1.
The committed corrective actions were
verified to have been implemented.
(Closed) Deviation (445/8516-D-42): This deviation addressed field
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reinspection of containment liner packages by ERC that were not
performed in accordance with approved instructions.
The ERC
inspector entered "N/A" for not applicable and " dome only" in the
remarks column for Attribute A.1.a on the checklists for three
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containment liner packages.
These verification packages involved the
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cylindrical liner and Attribute A.1.a did, in fact, apply.
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The committed corrective actions involved the revision of ERC QI-031
and a review of reinspection packages.
In addition to the 3 noted
verification packages,14 other packages initially reinspected by the
same ERC inspector were identified as having "N/A" and " dome only"
entered for Attribute A.1.a.
These packages were reinspected for
Attribute A.1.a and two new DRs were issued regarding liner contour.
The NRC inspector has reviewed the corrections made to QI-031, the
results, of the ERC reinspection of Verification
Packages I-S-LINR-08, I-S-LINR-12, and I-S-LINR-61, and three of the
additional packages reinspected by ERC for Attribute A.I.a.
The
committed corrective actions have been verified by the NRC to have
been implemented.
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(Closed) Deviation (445/8516-D-47): This deviation addressed the
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completeness and accuracy of an ERC checklist for a concrete
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placement reinspection. Attribute 3.1 of the completed checklist for
Verification Package I-2-CONC-015 was neither accepted nor rejected;
i.e., not signed off, and actual reinspection for this attribute
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could not be. verified. The checklist was approved and signed by both
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the lead inspector and the lead discipline engineer.
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The committed corrective actions were the' reinspection of this
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verification package for Attribute 3. A. and ERC management meetings
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with all ERC inspectors and leads to emphasize the importance of
providing complete and accurdte information. The overview inspection
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program has also been implemented to reinspect a sample of each
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inspector's work.
The NRC inspector reviewed ERC's reinspection of
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Verification Package I-S-CONC-015 and established from record review
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that training meetings were held with ERC inspectors and leads. A
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review of the overview inspection program is ongoing.
The committed
corrective actions have been implemented.
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(Closed) Devi6 tion (445/8516-D-48):
[ Note:
This deviation was
incorrectly identified as 445/8516-D-47 in the Notice of Deviation,
NRC Inspection Report 50-445/85-16; 50-446/85-13. Appendix D of that
report correctly identified the deviation as 445/8516-D-48]. This
deviation addressed field reinspection of a concrete placement
packege by ERC that was not performed in accordtnce with approved
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instructions.
The ERC inspector entered "N/A" for not applicable and
" coated" in the remarks column for Attribute 3.A'on the checklist for
Verification Package I-S-CONC-057. A subsequent NRC inspector,
however, identified that the surface was not coated.
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The committed corrective actions involved discussions with the
inspector and a historical review of the inspector's activity by the
ERC overview inspection program.
No additional errors were
identified. The ERC inspector stated that reinspection was made on a
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blockout immediately adjacent to theLdesignated blockout. The NRC
inspector has reinspected Verification Package I-S-CONC-057, verified
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ERC's reinspection of the correct blockout, and reviewed the results
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of the ERC overview inspection program. The committed corrective
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actions have been implemented.
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(Closed)' Unresolved Item (446/8602-U-12):
It was not apparent that
inspection of square groove weld penetration conditions had been
considered in the Corporate Consulting & Development Company, Ltd.
(CCL) reanalysis of HVAC supports.
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Further review of this item identified Memorandum No. BSC-2156, which
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references Section 6.2 of Revision 8 to Bahnson Service Company (BSC)
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Procedure DFP-TUSI-003 and states, "The following shall-be considered
a part of the subject procedure:
All groove welds on the seismic
duct hanger detail drawings shall be shown as square groove welds.
Unless otherwise stated the weld shall be considered partial
No size will be shown.
Per the attached test results a
penetration of not less than 1/8" (0.125") is achieved. These tests
results with coupons are retained in DCC."
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This 1/8" penetration has been used in CCL's reanalysis of HVAC
supports in Unit 2.
However, the available documentation for the
original test program did not assure that the test results were fully
representative of minimum penetration conditions that could occur
during field welding; i.e., the position dsed to weld the samples was
not recorded and etching was performed on weld sample ends rather
than on sections cut from samples.
Further, the tests coupons were
not retained in the Document Control Center (DCC) and could not be
,
located.
L
(
Additional welded samples were prepared and sections macroetched,
with the NRC inspector witnessing the activities.
The samples were
welded with a 3/32" electrode in the vertical position using BSC
Welding Procedure Specification BSC-20. Macroetching of sections
revealed a maximum partial penetration of 0.047", which is 0.078"
less than the claimed penetration used for reanalysis.
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3.
Employee Protection Posting
The unresolved item has been closed and replaced by a violation, as a
result of the failure to provide an appropriate test basis for assumptions
used in the design analysis (446/8620-V-02).
Paragraph (e) in 10 CFR Part 50.7, " Employee Protection," requires the
applicant to post Form NRC-3 " Notice of Employees" on its premises.
Posting must be at locations sufficient to permit employees to observe a
copy on the way to or from their place of work.
As a result of recent relocations and modifications to entrances and
exits, the NRC inspector performed an inspection to determined if TUGCo
was in compliance with the above requirements. The inspection revealed
l
that TUGCo was in compliance in that Form NRC-3 had been conspicuously
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posted at all entrances and exits to the job site, and at various
locations within Units I and 2.
No violations or deviations were identified.
Action Request (MAR) 85-0757 as implemented by Operation Traveler
EE85-11348-2203.
No violations or. deviations were identified.
4.
CPRT ISAPs (Excluding ISAP VII.c)
a.
Butt Splice Qualification ISAP I.a.3
'
The NRC inspector participated, with representatives of NRR and the
applicant, in an inspection of selected Unit 1 panels known to
contain the AMP splices thet are the subject of this ISAP.
The
panels (i.e., control room relay panel CR-03, cable spreading room
termination cabinets TC 41 and TC 42, and auxiliary building MCC
CEB 4-1) were inspected to familiarize the NRR representative with
the type of installations and configurations in which the splices are
installed.
During this inspection, the NRC inspector noted wrappings of
electrical tape on a conductor in control room panel CP1-ECPRCR-03.
l
The green conductor of cable E0112530 was subsequently identified as
having had its insulation repaired and inspected by Maintenance
Action request (MAR) 85-0757 as implemented by Operation Traveler
EE85-11348-2203.
No violations or deviations were identifiad.
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b.
QC Inspector Qualifications (ISAP I.d.1)
During this report period, the activities identified by NRC Reference
No 01.d.01.04 were inspected as follows:
Phase III Sample Selection and Reinspection (NRC Reference No.,
-01.d.01.04
The NRC inspector reviewed four reinspection matrices approved by the
ERC Discipline Level III inspector. These matrices were used to
evaluate the performance of those inspectors placed into Phase'III
due to documentation difficulties with their. qualifications.
The
reinspection matrices were for TUGCo Instructions QI-QP-11.2-1,
.
.
Revision 16, " Installation of Drilled-in Hilt! Bolts"; QO-QP-11.14-8,
Revisions 1 and 2, " Verification of Installation of Richmond Insert
Bolts"; QI-QP-11.0-15. The NRC inspector verified that the
reinspection matrices identified the inspection procedures and
designated the inspection attributes as recreatable/nonrecreatable
and subjective / objective as defined in ERC QI-005, " Evaluation of-
Inspector Performance."
The NRC. inspector witnessed the ERC Phase III reinspection of TUGCo
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Inspection Reports (irs) 2-0010162 and 2-0020136.- Subsequent NRC
review of the completed ERC reinspection matrices for these two irs
found them to be complete and to properly reflect the actual field
conditions.
No violations or deviations were noted during this inspection.
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c.
Craft Personnel Training ISAP I.d.3)
During this report period, the ISAP activities identified by NRC
Reference Nos 01.d.03.02, 01.d.03.03, 01.d.03.04, 01.d.03.05,
01.d.03.06, and 01.d.03.07 were inspected as follows:
,
Interview Personnel (NRC Reference No 01.d.03.02)
The NRC inspector reviewed the documentation from the interviews of
site personnel conducted by ERC.
Thirty-seven interview of personnel
were conducted, with the selection of personnel interviewed ranging
from general superintendents to craft journeymen and helpers
The NRC inspection was performed to determine if' the attributes
listed in Section 4.1.2 of the ISAP were included. Since no
established list of questions was utilized.in the ERC interviews, the
NRC inspector reviewed the interviews to assure that each attribute
was included.
It was found that the interviews in total did address
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each attribute, although not every attribute was applicable or
addressed in each interview; e.g., attributes applicable to
management were only addressed in the management interviews.
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From review of interviews, the NRC inspector determined that specific
areas of NRC Technical Review Team (TRT) concern, such as knowledge
of criteria used for lifting of heavy. loads and installation of
electrical supports were addressed in interviews of the
representative craft personnel.
Separate NRC interviews of personnel are planned to be conducted
during a subsequent inspection.
No violations or deviations were noted.
Observe Training and Field Activities (NRC Reference No. 01.d.03.03
.
The NRC inspector reviewed the records of ERC's observations of
training and field activities.
These records showed that one class
each of mock up training, classroom training, and procedural training
were observed. The lesson plan for each class was reviewed by the
NRC inspector. The ERC observations were.found by the NRC inspector
,
to be in agreement with the lesson plans..The records'of field
'
activities observed showed that 11 field activities were observed
which included inst 611ation of Hilti bolts and pipe hanger rework in
the mechanical discipline, cable termination and pulling in the-
electrical discipline and installation of a duct and a duct hanger
for HVAC. The field observations lists were noted by the NRC
inspector to attributes that would be found in the applicable
procedures, but did not give either a direct reference to the
procedure in most cases, or provide specific evidence of craft
compliance with these attributes.
The ERC observers were determined
by the NRC inspector from file review to have previously reviewed the
craft procedures to familiarize themselves with the craft activities.
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to be observed. The NRC inspector verified that the listed
procedures were applicable to the field activities observed.
Additional assessment of the adequacy of field activity observations
will be made during a subsequent NRC inspection.
,
No violations or deviations were identified during this inspection.
Recommendations for Improvement and Evaluation of Changes (NRC
Reference Nos. 01.d.03.04 and 01.d.03.05)
~
The NRC inspector verified performance of the following ERC
activities by inspection of documents in the working files for this
ISAp.
.
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ERC addressed through implementation of this ISAp the specific TRT
.
concerns for conduit supports, lifting of heavy loads, and the
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general concern of craft training.
ERC found by interviews of
electrical personnel and observation of a conduit support
installation that craft were aware of necessary documents of
installation, but did not always recall the formal name of the
documents.
ERC found by review of the training procedure, interviews
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of rigging personnel, using records, and a field observation that
training related to lifting of heavy loads was adequate. ERC also
found as e result of interviews, procedure review, and field
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observations that the training programs of Brown & Root (B&R) and BSC
craft personnel were adequate and therefore recommendations for
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improvement or evaluation of changes were not applicable.
The NRC inspection inspected the current training procedure of B&R
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and found that it met the requirements of ANSI N45.2, 1971, and the
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guidelines on training given by Section D of the Gray Book, " Guidance
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on Quality Assurance During Design and Procurement Phase of Nuclear
Power Plants." The NRC inspector verified a portion of the training
records listed in the ERC working files by reviewing the signed
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attendance sheets in the TUGCo training files. The NRC inspector
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inspected the lesson plans for the training classes that were
monitored by ERC and found that the lesson plans support the ERC
observations of mockup, classroom, and procedural training adequacy.
!
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The ERC review of Corrective Action Requests (CARS) was related to
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craft training inspected by the NRC inspector.
A sample of the CARS reviewed by ERC was inspected in detail.
These
CARS were found by the NRC inspector to support ERC's determination
that most craft training related CARS pertained to documentation,
administrative, and clerical deficiencies rather than craft training
program or implementation deficiencies.
NRC inspection of the BSC
training program will be reported in a subsequent inspection report.
No violations or deviations were identified.
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Qualification of Personnel (NRC Reference No. 01.d.03.06)
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The NRC inspector verified the qualification of personnel associated
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with the evaluation of this ISAP.
The resumes and objectivity
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questionnaires from the personnel files were reviewed and found to
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meet the requirements of the CPRT Program, Plan.
No violations or deviations were noted during this inspection.
No
further NRC inspection is planned for this reference area.
Root Cause Determined from VII.c Results (NRC Reference
ho. 01.d.03.07
The results report for ISAP I.d.3 was approved by the SRT on
August 27, 1986,
ho program deviations or deficiencies were
identified by ERC; therefore, root cause and generic implication
analyses were determined by ERC to be not applicable.
NRC evaluation
of this determination will be reported when inspection of I.d.3
activities is completed.
Craft training may be determined to be the
root cause of construction deficiencies or adverse trends found
during implementation of other ISAPs, including VII.c.
If this
occurs, the Collective Evaluation Group is responsible for evaluation
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of that determination. NRC inspection of the Collective Evaluation
Group activities for this ISAP reference area (01.d.03.07) will be
'
reported when the collective evaluation is completed.
No violations or deviations were noted during this inspection.
'
d.
Maintenance of Air Gap Between Concrete Structures (ISAP II.c)
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The following activities for ISAP II.c were reviewed by the NRC
inspector during this report period:
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Reinspect and Assess As-Built Condition (NRC Reference No. 02.c.01.00
The NRC inspector reviewed Unit 1 and Unit 2 work in progress on
single wall, secondary wall, and basemat gap initial clean out and
inspection.
These activities are complete for single wall gaps.
The
initial clean out of foam to allow for gap inspection has started for
secondary wall gaps with approximately 70% of the work complete. The
initial clean out of foam and inspection of the as-built condition
has also started for gaps associated with the basemat.
Initial clean out and inspection of double wall gaps is essentially
complete with the exception of several areas at or near the basemat
that are not accessible through existing access points. Two
blockouts, approximately 6' x
5', have been cut through the auxiliary
building walls to provide access to the gaps between the auxiliary
dnd safeguards buildings for both Units 1 and 2 at the 790' level.
Five additional blockouts are planned.
No violations or deviations were identified.
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Removal of Debris or Rotofoam (NRC Reference No. 02.c.02.00
The NRC inspector witnessed ongoing cleaning and repair activities of
air gaps between structures in Units 1 and 2 during this report
period. These activities included use of,a high pressure water jet
system, concrete removal from single walled gaps, grinding of
concrete in secondary wall gaps to increase the gap dimensions, and
removal of debris through the blockouts discussed above.
NRC inspections were not performed on other activities during this
report period.
l
No violations or deviatiuns were identified.
e.
Plug Weld ISAP V.d)
The following activities for ISAP V.d were reviewed by the NRC
inspector during this report period:
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Determine Effects of Plug Welds on Quality of Supports (NRC Reference
No. 05.d.09.03
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A concern relative to the effect of plug weld on the quality of
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supports is the influence on weld properties of the slag removal
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method used during welding. To address this concern, a program was
established by the CPRT in which 3/4" diameter plug welds were made
in 3/8" think predrilled plates.
Three welders were randomly
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selected from a list of all welders qualified to make plug welds.
Each welder was provided with eight test plates and instructed to
make plug welds and remove slag with a chipping hammer and wire brush
on the first four test plates, and a grinding tool on the remaining
four test plates.
Each of the 24 test plates was radiographer per
AWS 01.1.
Three test plates were selected from each slag removal
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process used by each welder (i.e.,18 plates) and tensile test
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coupons were prepared and tested per ASTM E8.
The two remaining coupons prepared by each of the the three welders
!
were sectioned, polished, and acid etched for macroscopic testing.
The NRC inspector will review all test results and associated
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documentation during a subsequent report period.
No other activities in this ISAP were inspected during this report
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period.
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No violations or deviations were identified.
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f.
Periodic Review of the QA Program (ISAP VII.a.5)
'
During this report period, the ISAP activities identified by NRC
Reference Nos. 07.1.05.01 and 07.1.05.02 were inspected as follows:
Develop Criteria for Review of the QA Program (NRC Reference
No. 07.a.05.01
,
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ERC considered information obtained from INP0 and guidance from the
USNRC Standard Review Plan in developing the review criteria to
assess the current management review of the QA program.
The review
criteria specified that a policy statement of management objectives
for the QA program be published and that specific details be
developed to assure program management's review of progress in meeting
those objectives.
In addition, the review criteria required
management review of:
current QA status reports, including any
deficiencies from all departments; trend' analysis reports; audit
reports; notices and bulletins from externa.1 sources; construction
progress reports; and other typical sources.
The ERC review criteria
further specified that the methods should be detailed by which
management would:
respond to reported information, track deficiencies
and assure that followup and closecut is performed, and provide for an
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annual review of management's actions in meeting the published
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objectives. The NRC inspector verified that the applicable elements
of the USNRC Standard Review Plan were incorporated in the ERC review
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criteria.
The NRC inspector determined that the ERC, review criteria
would provide an adequate basis to perform an evaluation of management
review of the QA program required in paragraph 4.1.2.4 of the ISAP.
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ERC's development of review criteria is coniplete. No violations or
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deviations were identified and no further NRC inspection is planned
for this reference area.
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Evaluation of the prrent QA Program Review Versus the Developed
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Criteria (NRC Refers nce No. 07.a.05.02
The NRC inspector reviewed the ERC issue coordinator's evaluation of
the current QA program review.
The ERC evaluation reviewed Policy
Statement No.2, Revision 0, issued by the Executive Vice President
for Nuclear Engineering and Operations (NEO). This policy statement
details the QA program objectives and defines the responsibilities of
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the Director of QA and the organizational vice presidents. The
policy specifies that the vice presidents shal'1 meet periodically to
assess the status and adequacy of the QA program and at least=
annually provide a written assessment of the QA program to the
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Executive Vice President, NE0. The Executive Vice President, NE0, is
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responsible to assure that an annual independent assessment of the
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TUGCo QA program is performed.
NE0 Procedure 2.20, Revision 1,
" Senior Management QA Overview Program," details the methods by which
the objectives of the policy statement are to be implemented.
The
issue coordinator reviewed NE0 2.20, Revision 1, and attended the
first two meetings of the Senior Management Quali);y Assurance
Overview Committee.
The notes and recommendations of the issue
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coordinator and the minutes of the overview committee meetings were
,
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reviewed by the NRC inspector.
The results of this review showed
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that the issue coordinator had evaluated the meetings against the
objectives of Policy Statement No. 2 and the ERC developed criteria.
NRC's review of these notes and Revision 1 of NEO 2.20 showed that
recounendations of the issue coordinator.had been incorporated.
No violations or deviations were identified and no further NRC
inspection is planned for this reference area.
g.
Receipt and Storage of Purchased Material and Equipment (ISAP VII.a.9
Receipt Inspection Report (RIR) 13686 was inspected by the NRC as a
sample of the implementation of ISAP VII.a.9.
During this
inspection, a disc insert for main steam safety valve CP2-2MS-021 and
two spare disc inserts were found not to have required records of
heat treatment available in the documentation package.
The NRC
inspector noted that implenientation if ISAP VII.a.9, Revision 0,
would not have identified the deficiency.
For this and other
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reasons, ISAP VII.a.9 is undergoing revision. The failure to have
heat treatment records for the indicated disc inserts is a violation
(445/8622-V-02;446/8620-V-03).
h.
Onsite Fabrication ISAP VII.b.1
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During this report period, the ISAP' activities' identified by NRC
Reference Nos. 07.b.01.01 and 07.b.01.03 were inspected as follows:
)
Review and Evaluate Procedures for Onsite Fabrication (NRC Reference
]
No. 07.b.01.01)
The NRC inspected the review performed by ERC of material storage,
)
fabrication, and inspection procedures applicable to both ASME and
non-ASME onsite fabrication. The ERC review listed the attributes
i
necessary for control of material traceability, _ fabrication
processes, and item inspection for acceptability. The ERC review
then identified where the attributes existed in the historical and
the current procedures.
NRC inspection of the attributes found them
to reflect the requirements of 10 CFR Part 50, Appendix B,
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Criteria VIII and XIII; ANSI N45.2; and the Comanche Peak FSAR.
The
.
NRC inspector selected several of the attributes for inspection and
verified that the attributes were included in the procedures for the
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tir.es specified (historical and current) by the ERC review.
{
No violations or deviations were noted in this area and no further
NRC inspection is planned for the reference item.
Review Fabrication Packages (NRC Reference No. 07.b.01.03)
The ERC sample selection and review of ASME-related fabrication
packages were inspected by the NRC inspector.
ERC reviews of
non-ASME packages are near completion and will be inspected and
reported when complete. The 73 ASME-related package reviews were
inspected for overall completeness and adherence to the guidelines of
the ISAP and the review checklists. The following nine ERC package
reviews were selected for inspection in detail:
CC-1-195-015-C42R
SI-1-101-011-C41R
RH-1-063-010-522R
SI-1-031-033-732K
PS-2-RB-011-003-2
SW-1-102-066-543R
These package reviews were compared to the hanger packages and other
applicable documents to determine their completeness and accuracy.
NRC inspection showed that eight of the nine package reviews were
complete and accurate for all review criteria, such as welder or
inspector qualifications, all required inspections complete, required
documentation complete and legible, documentation consistent and in
proper sequence, and traceability requirements met. One package was
noted to have failed to record four inspectors and two welders.
This
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deficiency was corrected at the time of discovery and all reviews
performed by the responsible document reviewer were repeated.
NRC
inspection of the repeated reviews found them to be satisfactory.
This deficiency has been identified as a deviation (445/8622-0-03;
446/8620-D-04).
No other violetiuns or deviations were noted.
i.
ValveDisa"1bly(ISAPVII.b.2)
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Review Cons t etion and QC Procedures to Determine if They Provide
Adequate Controls of Materials During Disassembly / Reassembly (NRC
ReferenceNo.07.b.02.03)
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NRC Inspection Report 50-445/86-07; 50-446/86-05 documented by
Deviation 445/8607-D-26 the failure of CPRT to identify that B&R did
not have an implementing procedure in existence for a portion of 1983
to control the disassembly / reassembly of valves. The CPRT
investigated to determine the reason (s) for not having a procedure in
effect for the five month time span anc what effect it had on the
valve disassembly / reassembly process.
The CPRT's response is
documented in a memorandum dated May 23, 1986, from Counsil tu
Noonan.
Based on review of the above memorandum, the NRC inspector concurs
with the CPRT finding that with the appropriate portions of QA
Procedure QI-QAP-11-1.26, Revisions 9 thru 12, still in effect, and
the use of an operation traveler similar in format and content to
those utilized prior to the procedural omission, adequate control of
valve disassembly / reassembly existed during this time frame. This
activity is complete.
No violations or deviations were identified.
Perform an Analysis to Determine the Safety Consequences of
Improperly Assembled Valves (NRC Reference No. 07.b.02.03
y
An analysis was performed by CPRT to determine the safety
consequences and f ailure modes of improperly assembled generic
valves.
Generic valves ore those which required disassembly of all
valves of that type and included ITT Grinnell diaphragm valves and
Borg-Warner check valves.
All possible combinations of reassembling generic valve bodies and
bonnets of the same size and type were evaluated in this analysis.
CPRT concluded that improper reassembly could possibly result in a
loss of valve function for Borg-Warner check valves.
For ITT
Grinnell diaphragm valves, it was determined that improper reassembly
would result in ASME Code violations, but not a loss of valve
function.
The NRC inspector reviewed this analysis for v61idity and
completeness, factoring into the review ASME Code requirements and
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information received from the' valve vendors.
However, a satisfactory
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response is required with respect to a previously identified
unresolved item: 445/8607-U-28 before a final. evaluation of this
ISAP element can be made.
This unresolved item deals with the lack-
of consideration in the results report, after stating there was a
potential for switching ASME and non-ASME' bonnets, of the
significance of differences in QA requirements for non-ASME and ASME
Code bonnets.
No violations or deviations were identified.
Additional NRC Findings
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As a result of DRs identifying the lack of traceability between the
installed bonnet and the vendor supplied NPV-1 form for Valve Tag
Nos. 1-7046 and XSF-179, NCRs were issued by B&R.
NCRs.M-23175N,
Revision 1, and M-23178N were initiated on February 25, 1986, and
were dispositioned and closed out by TUGCo on July 15, 1986.
To-
assess the applicant's review of these nonconformances, the NRC
inspector reviewed the NCR dispositions.
The dispositions stated that documentation, except'for hydrostatic
testing, was received from the vendor-indicating that the bonnet
material met all applicable requirements of ASME Section II and
Section III, ND-2000. The dispositions, hcwever, stated that an
acceptable bonnet hydrostatic test was performed-during the
system / subsystem hydrostatic test, as allowed by-the ASME: Code.
In
order to reconcile the fact that the valve bonnet heat numbers did
not correspond with those specified on the vendor's Nuclear
Valves / Heat Code Identification, the dispositions' stated that the
)
bonnets shall be considered as replacement parts and documented as
such on an NIS-2 form, which is an Owner's Report for Repair and
Replacement.
i
As a result of this review, the NRC inspeotor identified the
following:
(1) The disposition was incorrect with respect to an acceptable
bonnet hydrostatic test being performed during the system /
subsystem hydrostatic test. When a' diaphragm valve is
'
hydrostatic tested as a complete assembly, the diaphragm
isolates the bonnet from any hydrostatic pressures, Therefore,
there is still no evidence of the required hydrostatic test
having been properly performed.
This incorrect disposition of
the NCRs is a violation (445/8622-V-04).
(2) The NRC questions the validity of utilizing an~NIS-2 form to
document as-installed components. This matter is-an unresolved
item pending the applicant providing the NRC with adequate bases
for using the NIS-2 forms (445/8622-U-05).
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(3) Table 3.2-1 in Section 3 of Amendment 56 to the CPSES FSAR-
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requires that Class 2 and 3 valves shall meet the requirements
I
of the 1974 Edition of Section III of the ASME Code,
Westinghouse P0 546-CCA-1919000-XN, which deals with Class 2 and
f
3 valves, specifies, however, the applicable Code requirement to
)
be Section III, 1971 Edition, Summer 1972 Addenda, Receipt of
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valves in accordance with this criteria is evidenced by the
NPV-1 form for Valve Tag No. 1-7046 which states, "The material,
design, construction, and workmanship complies with ASME Code,
~
Section III, Class 3,1971 Edition, Summer 1972 Addenda." The
failure to comply with FSAR commitments is a deviation
(445/8622-D-06),
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Pipe Support Inspections (ISAP VII.b.3)
(1) Status of CPRT Activity
The reinspection being performed under ISAP VII.b.3 deal with
pipe supports located in Room 77N and the 42 pipe supports
previously inspected by the RTR. All other pipe support
populations and their samples are being reinspected under
ISAP-VII.c.
Room 77N Pipe Supports
i
Reinspection of the 178 pipe supports identified as being
i
nonconforming by TRT has been completed.
Of the 252 deviations
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identified, 248 have been evaluated to date, with 99 determined
to be valid.
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TRT Issues - 42 Pipe Supports
Of the 42 pipe supports identified by TRT as being nonconform-
.
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ing, 40 have been reinspected. Of the 103 deviations
identified, 99 have beer, evaluated to date, with 67 determined
to be valid.
(2) Status of NRC Inspection Activity
Room 77N Pipe Supports
To date, nine NRC inspectors of ERC verification packages have
_
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been performed with the following one being performed during
this report period:
Verification
Support No.
System *
Unit
Package No.
I-S-PS7N-146
SI-1-001-015-542R
SI - Safety Injection Systen
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While performing this inspection, the following conditions were
identified.
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!
The initial ERC inspector inspected and signed off Attribute 3
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on the inspection checklist regarding spherical bearing gap and
I
noted.that a gap of 1/32 existed.
Subsequently, the Overview
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signed Inspector (01) performed the required overview inspection
!
and signed off Attribute 3 on the inspection checklist and noted
that a resultant gap of 0" existed.
During the NRC inspection,
I
however, it was observed that an excessive amount of paint
precluded the ability to measure the resultant gap,'in that
paint filled the gap and masked the bearing assembly. The
acceptance of this attribute by both the ERC inspector and the
>
01, and the failure of the 01 to identify an unsatisfactory ).
decision by the ERC inspector, is a aeviation (445/8622-D-07
l
As a result of this deviation being identified, ERC determined
,
that reinspection of six verification packages which had
previously been inspected by the ERC inspector would be
performed. The reinspected packages are as follows:
I-S-LBSN-048
I-S-LBSR-009
I-S-SBPS-033
I-S-PS7N-001
I-S-PS7N-136
I-S-PS7N-145
The reinspection, which were witnessed by the NRC inspector,
resulted in the identification of out-of-scope observations
pertaining to paint on the spherical bearings for packages
I-S-PS7N-001, I-S-PS7N-135, and I-S-PS7N-145.
Disposition of these out-of-scope observations is an open item
(445/8622-0-08)
TRT Issues - 42 Pipe Supports
There were no NRC inspections perfonded in this area during this
report period.
No NRC inspections were performed in other ISAP VII.b.3
activities.
5.
ISAP VII.c
a.
Electrical Equipment
,
Status of CPRT Activity
ERC has completed 98 reinspection and 98 documentation review
packages of sampled electrical equipment as of August 31, 1986.
- - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _
!
"
"
-24-
,
Status of NRC Inspection Activity
,
The status of NRC inspection activity remains unchanged for the ERC
population sample from the previous inspection report; i.e., the NRC
inspectors have witnessed 14 ERC reinspection, performed separate
reviews of 15 documentation packages, and performed 6 separate
reinspection of sampled electrical equipment. The NRC inspectors
i
I
did, however,. perform the following inspection during this report
period.of electrical equipment which was not included in the ERC
population sample:
(1) The NRC inspectors performed an inspection of the four
safety-related refrigeration. units to verify proper
installation. The. inspections included observations that:
.
,
(a) components were properly installed and identified as
indicated on the latest design documents, (b) supports and
,
attachments were properly mounted and secured, (c) protective
j
'
coatings were as specified, (d) electrical separation and
independence were maintained, and (e) provisions related to
environmental qualification of the components were maintained.
The following refrigeration units cool the safety chilled water
system (SCW)-which provides cooling water to various engineered
safety features (ESF) components' room coolers:
Equipment No.
S_ystem
Unit
CP1-CHCICE-05
CP1-CHCICE-06
i
CP2-CHCICE-05
,
CP2-CHCICE-06
I
~
During the above inspections, the following conditions, which
appeared to deviate from CPSES electrical erection specification
requirements, were identified.
CP1-05
(a) Bolts on the compressor discharge flange were not installed
<
as shown on Drawing 376-09121E;
(b)
Paint on the underside of the compressor was peeling;
(c) Some of the devices inside the control panel had wires
terminated using slide-on, tab type connectors;
(d) A number of wires inside the control panel had a short bend
radius;
(e) A number of connectors had two conductors crimped inside
one connector's barrel;
,
i
_________m______
_ _ ___ _ _ _ _ _ _ _ _ _ _. _. _ _ _ _ _ -. _ - _
,
!
'
,
"
-25-
.
(f)
Fitting No. OPG, inside the control panel, was leaking oil
<
onto relay SG and its associated wiring, which had resulted
in damage to the insulation of one of the wires;
(g) The flexible conduit for switch PRV had the outer jacket
split and falling off; and
(h) Cap type, inline splice connectors were used to terminate
instruments and limit switches.
CP1-06
)
This unit had the same conditions as identified in (a), (c),
<
(d), (c), (f) and (h) above for CPI-05, and.
)
(a) Some splices used to terminate instruments and limit
switches were made using Thomas and Betts (T&B) RC-6
j
'
connectors, which are usually only used for lighting
circuits; and
(b) A cap type, inline splice was installed on a wire in the
control panel.
CP2-05
i
This unit had the same conditions as identified in (a), (c),
(d), (e), (f), and (h) for CP1-05.
CP2-06
.
This unit had the same conditions as identified in (a), (c),
(d), (e), (f), and (h) for CP1-05 and one of the auxiliary oil
pump motor leads was also terminated using a wire nut.
The above findings are an unresolved' item pending the completion
of an NRC review of the applicable requirements for these pieces
of equipment (445/8622-U-09; 446/8620-U-05).
(2)
In addition to the above inspection efforts, the NRC inspector
noted, during a tour of the Unit I cable spreading room, feeder
cable splices and a cable jacket repair inside distribution
snel CPX-ECDPEC-02.
The cover had been removed from this
panel, as well as another panel, to facilitate some plant
modifications;thecableinquestion(EG205704) was, however,
unaffected by those modifications.
The NRC inspector noted that the outer jacket of one of the two
conductors of cable EG205704 had been repaired by wrappings of
electrical tape and that both conductors had been reduced in
size from AWG 4/0 to AWG #2 through the use of reduction
splices. A review of the applicable records showed:
,.
~...
.
. -
y
,
I
.:
.
-26-
(a) The damage to the cable jacket had been. reported in NCR
I
E84-01095, was repaired and the-results recorded in
IR E-1-0036473.
(b) The reduction splices we're installed in accordance wi.th.
construction operation traveler EE83-3520-2-02CT.. The
reduction consisted of installing a terminal lug of the
proper size on'each of the conductors and then bolting the
.,
lugs of one-of the 4/0 and one of the #2.together. These
i
connections were then covered with heat shrinkable tubing.
insulation.
The conductor size reduction was necessary for connection-
-
to the circuit breaker in the panel.
Since the circuit-
breaker was rated for 100 amperes, and a review of the'
applicable plant drawing (2323-El-1701) showed the smaller
'
(#2 AWG) conductor was rated for-116 amperes,. sufficient
current carrying capability was maintained by the
reduction.
No violations or deviations were identified.
b.
Documentation Review of NIS Cable Terminations
Status of CPRT Acti<, g
ERC completed the review 1 the 60 sampled nuclear instrumentation
system (NIS) cable termination verification packages prior to
August 31, 1986.
Because the attributes effecting these connectors
are not inspectable without completely reworking the c~onnectors, no
physical inspections were required.
ERC is continuing the evaluation
of the deviations which were noted during the documentation reviews;
Status of NRC Inspection Activity
,
(1) Procedures Review
The NRC inspector initiated the review of this population during
,
this report period. A review of the procedure which was
<
utilized by ERC (QI-074, Revision 0, dated March 10, 1986,
i
" Documentation Review of NIS Cable Terminations /R-E-NIST").
showed that it required checking five attributes. The ERC
reviewer was required to verify that:
(a) all attributes on the
IR for the connector were indicated to be satisfactory, (b) all-
IR attributes for insulation and resist 6nce measuring were
satisfactory, (c) all IR attributes for the coupling of the
connector were satisfactory, (d) all IR attributes for soldered
connections were satisfactory, and (e) the QC inspector who
verified the above four connection attributes was certified to
the applicable procedure. The NRC inspector also reviewed the
latest revision of the QC installation inspection procedure for
_
_--_-___- _
-
-
!
^
-27-
j
.
NIS connectors, QI-QP-11.3-43, Revision 20. dated February 18,
1986, " Verify Testing and Installation of NIS Triaxial Cable
!
Connectors."
(2) CPRT Records Review
Ten of the completed ERC verification packages were selected at
random and reviewed by the NRC inspector. A total of nine DRs
were noted to have been written by the ERC inspectors for
findings made during their documentation reviews of these ten
packages.
Each package consisted of one NIS connector. Of the
nine DRs, four were written because the heat shrink tubing (H5T)
had not been installed over the completed connection. A
'
!
subsequent review of the applicable requirements by ERC showed
that HST need only be applied to those NIS connectors at the
l
containment penetrations and at the detector wells.
Since all
!
of the connectors in question were equipment connections, HST
!
was not required. One DR was written because the test date was
l
not included in the package; however, the data sheet was
!
subsequently located. Another DR was written because the "0"
l
ring seal between connector halves had not been installed;
!
'
however, the connector in question was, a spare connector which
was coyered with HST and not mated with another connector half.
A seventh DR was written because a procedure step for insulaticn
and resistance measurements had been marked "N/A"; however,
since the connector was not a penetration connection, these
measurements were not required.
The remaining two DRs were
!
written because other steps in the procedure had been marked
!
"NA."
Further review determined that the steps marked "hA" were
not required for the particular application.
ERC, therefore,
determined that all of the nine DRs were invalid.
The NRC inspector questioned the appropriateness of some of the
above determinations with CPRT personnel and the applicant
personnel responsible for the prepar4 tion and implementation of
'
the QC procedure. The inspector was informed that all
connectors located inside the containment were covered with HST;
i
l
the invalidated DRs on this subject were for connectors located
I
outside the containment.
In addition, the entire length of the
j
cable run, excluding active devices, was subjected to an
insulation and resistance measurement test after final
I
installation.
The NRC inspector found no reason to disagree
with the above determinations.
!
l
.
!
!
I
!
_
_ _ _ _ _ _
-_
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-28-
,
(3) TUCCo Documentation Review
The NRC inspector performed reviews of TUGCo documentation for
the following four verification packages for Unit 1 NIS cables:
Verification
Cable No.
Package No.
R-E-NIST-002
EW-140610
R-E-NIST-003
EY-140308
R-E-NIST-004
ER-140490Z
R-E-NIST-008
EW-140601
i
The results of the NRC inspector's review, which included
-
verification of the QC inspector's certification, were
j
compared to the ERC review findings with no differences
being identified.
!
I
No violations or deviations were identified.
l
c.
Mechanical Equipment Installation
Status of CPRT Activity
ERC has completed 168 reinspection of mechanical equipment
installation items from a total random and engineered sample size of
171.
Two hundred and fifteen valid DRs were issued as a result of
l
the above reinspection.
ERC has completed all documentation reviews of the total sample of 84
documentation review packages.
Two valid DRs have been issued.
Slatus of NRC Inspection Activity
To date, nine inspections have been completed of sample items
previously inspected by ERC. The NRC inspector performed the
following inspections during this report period:
Verification
Equipment Tag No.
System
Unit
Package No.
I-M-MEIN-107
TBX-CSAPPD-01
Connon (1)
1-M-MEIN-019
CP1-CCAHHX-02
I-M-MEIN-263
CP1-VAAUSE-11
CS - Chemical and Volume Control;
CC - Component Cooling Water-
l
VA - Containment Ventilation
l
The NRC inspector identified that ERC engineering during their review
l
of historical data pertaining to Verification Package I-M-MEIN-017,
_ _ _ _ _ _ - _ _ _ _ _
.
-29-
'
'
i
faileo to provide ERC inspectors with accept / reject criteria for the
following work activities described by construction operation
travelers (C0Ts):
(1) COT NE78-101-4901 identified the use of Richmond inserts for
equipment anchoring.
No inspection instruction were provided to
verify adequacy of stud bolt thread engagement.
(2) C0T ME83-1532-4900 identified torquing requirements for Cylinder
Head Cover No.9.
No inspection instructions were provided to
verify satisfactory performance of the torquing operation.
(3)
COT ME78-101-4901 identified a requirement to install the oil
cooler and its associated piping.
No inspection instructions
i
were provided to verify satisfactory performance of the work
activities required for installation.
Subsequent to the NRC inspection, ERC engineering issued inspection
instructions to resolve (2) and (3) above. The failure to include
the preceding work activities in the scope of the reinspection effort
is a deviation (445/8622-D-10).
As a result of the additional inspection activities performed by ERC
inspection personnel with respect to (2) and (3) above, eight
deviations pertaining to nonconforming torque and coupling / alignment
specifications were identified.
However, NRC subsequent inspection
revealeo that the equipment was not tagged to identify the
nonconforming conditions as required by ERC Procedure CPP-010. This
failure to tag)the nonconforming equipment is a deviation
(445/8622-D-11.
.
d.
Pipe Welds / Materials
{
Status of CPRT Activity
l
The Pipe Welds / Material (PIWM) population,was created by combining
j
two previous populations referred to as Large Bore Pipe
l
Welds / Material and Small Bore Piping and Instrument Tubing / Piping
Welds / Material.
In addition, tubing welds were excluded and placed
.
in their own population, and mechanical equipment pressure boundary
j
welds were added as PIWM welds.
The PIWM population was then
i
categorized into two subsets: Large Bore Pipe Welds / Material (LBWM)
subset and Small Bore Pipe Welds / Material (SBWM) subset.
This
.
categorization has been done for the purpose of utilizing the
!
existing inspection QIs and corresponding verification packages.
ERC has completed all of the planned random and engineered sample of
!
180 reinspection packages and the 182 documentation review packages.
Of the five valid DRs which were issued, four have been evaluated, to
date, and determined to be nonsafety significant.
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____ _.. _ _
l
- _ _ _ - _ _ _ _ _ _ _ _ - _ _
_ __.
.
-30-
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.
' Status of NRC Inspection Activity
(1) To date, the NRC inspector has witnessed 15 ERC reinspection
and performed 6 separate inspections of ERC verification
packages. The following three inspections were performed during
this report period:
Verification
Drawing No.
Weld No.
System *
Unit
Package No.
I-M-SBWM-029
BRP-MS-2-RB-044
WE-15
MS
l
I-M-LBWM-054
BRP-BR-2-SB-014
WE-7
BR
I-M-LBWM-038
BRP-MS-2-SB-056
FW-3A
MS
MS - Main Steam; BR - Boron Recycling
No violations or deviations were identified.
(2) The NRC inspector performed a documentation review of the following
four ERC population samples:
i
Verification
Drawing No.
System * Unit
Package No.
No.
.
R-M-PIWM-174
BRP-BR-2-014
WE-7
BR
R-M-PIWM-046
BRP-MS-2-RB-044
WE-15
MS
R-M-PIWM-110
BRP-MS-2-SB-056
FW-3A
MS
R-M-PIWM-2004 TNE-12-2107-04-B-01-1Q2 FW-14
"
BR - Boron Recycling; MS - Main Steam; CS'- Chemical and Volume
Control
No violations or deviations were identified.
e.
Equipment Supports
Status of CPRT Activity
j
ERC reinspection of equipment supports is complete with 70 support
packages reinspected and 128 DRs issued.
Eighty-nine DRs have been
determined to be valid. Documentation review is also complete with
225 DRs issued.
No safety significant deviations have been
identified.
Status of NRC Inspection Activity
(1) Two ERC equipment support inspections were witnessed by the NRC
,
inspector during March 1986.
The discussion of the following
_ _ _ _ - _ - _ _ _ - _ _ - _ _ _ _ _ _ - _ _ - _ - _
- _.
. _ _.
<
=
'
-31-
.
witnessed inspections was inadvertently left out of NRC
Inspection Report 50-445/86-03; 50-446/86-02:
Verification
Equipment No.
Building *
Unit
,
Package No.
I-S-EQSP-002
CP2-EPBCED-03
Connon
I-S-EQSP-010
CP2-ECDPED-01
CR
Common
AB - Auxiliary Building, CR - Control Room
During the above reinspection, ERC identified the following
conditions to the NRC inspector as subject to evaluation as
.
potential deviations:
I-S-EQSP-002: A channel was incorrectly located by 1/4" and a
weld length was undersized for 1 3/4".
I-S-EQSP-010: The support location was not in accordance with
the installation drawing.
The gap between the panel and the
concrete wall exceeded the allowable of 1/2".
In addition, a
Hilti bolt spacing violdtion was identified.
Dispositions of the above findings are open items (445/8622-0-12
and 445/8622 0-13).
(2) The following seven equipment supports were separately
reinspected during this report period:
Verification
Equipment No.
Building *
Unit
Package No.
I-S-EQSP-008
CP1-VAFNAV-32
I-S-EQSP-023
CP2-ELDPEC-04
I-S-EQSP-027
CP2-VAFNAV-27
1-S-EQSP-038
ILCS5691A
I-S-EQSP-045
ILCS5803
I-S-EOSP-049
CPX-EPTRET-04
CR
Common
I-S-EQSP-052
CP2-ELDPEC-14
CR
Conrnon
DG - Diesel Generator, AB - Auxiliary Building,
CR - Control Room
The above seven equipment supports had been previously inspected
by the ERC 01.
The initial ERC reinspection of Verification
Package I-S-EQSP-023 was evaluated as unacceptable by the
ERC 01.
The initial ERC inspector rejected Attribute 6F(i)
because nuts and washt'rs were not installed on two Hilti bolts.
Note 10 of DCA 3273 states, "If Hilti violations occur between
existing Hilti Kwik bolts ono new added Hiltis, remove nut
permanently from existing Hilti Kwik bolts." Note 5 of DCA
.
~
- _ _ _ _ _ _ _
..
.
-32-
.
20659 states that the Hilti bolts inside the panel.are not
necessa ry. The 01 determined that a DR saould not have been
. issued. Upon evaluation of this finding by the overview
supervisor, a decision was made to accept the initial ERC
inspector's DR, since the identity of the new verses existing
Hilti bolts could not be determined. Thus, Note 5 of DCA.20659
was not opplied.
The initial ERC reinspection of VeHfication
Package I-S-EQSP-052 was evaluated as unacceptable by the
ERC 01. Two additional DRs were issued. Attribute 3,
configuration, was rejected by the ERC OI.
The_ bottom of the
panel was 5/8" from the wall whereas DCA 14811 allowed 1/2"-
maximum. Attribute 6F(ii), anchor bolt nut engagement and
bearing, was alsu rejected by the ERC 01. One Hilti bolt was
installed without a required washer.
ERC Overview inspection results agreed with the initial ERC
reinpsections for the remaining five packages listed above.
No violations or deviations were identified.
f.
Fuel Poor Liner
Stetus of CPRT Activity
ERC has completed 62 reinspection of the fuel poor liner from a
population sample size of 62. ' Ten valid DRs were issued as a result
of the above reinspection.
ERC has completed 100 documentation reviews from a total sample size
of 100.
Forty-four valid DRs have been issued as a result of the
above documentation reviews.
Status of NRC Inspection Activity
,
(1) The NRC inspector witnessed the following ERC inspection during
December 1905, the discussion of which was inadvertently omitted
from NRC Inspection Report 50-445/85-18; 50-446/85-15:
Verification
Unit
Package No.
I.Do.
I-S-FPLR-163
1161
No deviating conditions were identified during this inspection.
-_
_ _ _ _ _ _ _ _ - _ - _
-
.
33-
-
.
(2) To date, the NRC inspector has performed the following
inspections of ERC inspected ~ packages:
Verification
Unit
Tackage No.
I.F~"~Ro.
I-S-FPLR-004
969
I-S-FPLR-111
1748
I-S-FPLR-029
1052
Common (1)
I-S-FPLR-072
1049
I-S-FPLR-058
1015
Common'(1)
No violations or deviations were identified.
g.
Small Bore Piping Configuration
Status of CPRT Activity
ERC has completed all reinspection of small bore piping
configurations from the planned random and engineered sample of 99.
Seventy-nine' valid DRs have been identified and issued.
Status of NRC Inspection Activity
(1) To date, the NRC inspector has witnessed seven ERC reinspection
and performed seven separate inspection of ERC. inspected
packages, of which the following three separate inspections
occurred during this report period:
Verification
Drawing No.
System *
Unit
Package No.
1-M-SBC0-023
BRP-GH-X-AB-068
GH
Conmon
I-M-SBC0-097
BRP-RC-1-RB-039
RC
1-M-SBC0-121
BRP-RH-1-SB-011,
RH
GH - Gaseous Waste Processing System;
RC - Reactor. Coolant System; RH - Residual
Heat Removal System
(2) With respect to Verification Package I-M-SBC0-121, the.01
identified that in the northwest corner of Room No. 67, the
inspected line and the floor grating angle iron did not meet the
separation criteria of Section 5.2 of QI-026. The deviation was
not identified by the original ERC inspector.
Disposition of
the above item is an open item (445/8622-0-14).
(3) During the inspection of Verification Package I-M-SBC0-121, the
NRC inspector identified two instances where the separation
criteria of paragraph 5.2.6.2 in 01-026 was violated.
QI-026
requires that for pipes operating at 200 degrees Fahrenheit or
- - _ - _ - _ _ _
___
- _ _
_ - _ _ _ _.-__
.
I
-34-
i
i
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l
greater, a minimum of 1", including insulation, shall be
maintained between the pipe and nc.n,ers. Attribute 1.f
(separation) of the ERC reinspection checklist for this
verification package was accepted by the ERC inspector. lThe.
subsequent overview inspection failed to identify the. deviating
q
conditions; thus resulting in a failure to identify
i
unsatisfactory. decisions made by the ERC inspector. These
failures constitute a deviation (445/8622-D-15).
,
i
These conditions existed between a vertical run of pipe (5' 7
1/2" west of wall D-S and 3' 4" south of wall 5-S at elevation
789'6") and and structural tubing of pipe support
,
RH-1-025-004-S22R, and at elevation 791' 2" with the snubber
rear bracket of Pipe Support No. RH-2-013-008-S32K.
-
h.
Large Bore Piping Configuration
l
l
Status of CPRT Activity
I
ERC has completed all reinfections of large bore piping.
configurations from the planned random and engineered sample of.98.
Sixty-three valid DRs have been identified and issued.
I
Status of NRC Inspection Activity
To date, the NRC inspection has witnessed seven ERC reinspection and
l
performed seven separate inspections of ERC inspected packages, of
'
which the following separate inspections occurred during this report -
period:
~
Verification
Drawing No.
System *
Unit
,
Package No.
I
l
l
I-M-LBC0-087
BRP-CT-1-RB-020
I-M-LBC0-025
CRP-CC-1-RB-057
,
CT - Containment Spray; CC - Component Cooling Water
l
No violations or deviations were identified.
1.
Reinspection of Tubing Welds / Materials
Status of CPRT Activity
ERC has completed all reinspection of tubing welds / materials from
the total random and engineered sample of 99.- Seventeen valid DRs
were issued as a result of the above reinspection.
i
l
ERC has also completed all documentation reviews from the sample of
98 packages.
Fourteen valid DRs have been generated as a result of
l
the above documentation review.
,
L______________._____
_
i
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.
-35-
.
Status of NRC Inspection Activity
Review of this population identified that documentation of NRC
inspection activity had been deferred pending attempted resolution of
i
questions concerning the adequacy of instruction to inspectors in
>
0!-070, Revision 1.
The questions, which 'are somewhat judgmental in
nature, are described in paragraph (3) below.
(1) The NRC inspector has, to date, witnessed the following three
inspections:
j
,
Verification
Drawing No.
System *
Unit
Package No.
I-M-TUWM-024
FSI-0043-17
NI
I-M-TUWM-034
FSI-00043-56
NI
J
I-M-TUWM-036
FSI-00043-54
NI
i
NI - Nuclear Instrumentation
>
I
During these inspections, no deviating conditions were
identified by the ERC inspector.
No violations or deviations
were identified by the NRC inspector.
.
(2) The NRC inspector has, to date, performed the following four
separate inspections of ERC inspected packages:
Verification
Drawing No.
System *
Uni t
Package No.
,
]
..
I-M-TUWM-002
FSI-1-500
MS
I-M-TUWM-008
FSI-1-601-01
RC
I-M-TUWM-016
FSI-1-601-01
RC
I-M-TUWM-025
FSI-1-528
RC
MS - Main Stream; RC - Reactor 8colant
No violations or deviations were identified.
(3) The NRC inspector questioned ERC engineering concerning the
odequacy of QI-070, Revision 1, relative to instructions not
being provided for weld size inspection when the edge of tubing
fittings had either been consumed by welding.or subjected to
grinding. An additional related question was asked concerning
the QI not requiring verification of socket weld fitting sizes.
In the NRC inspector's judgement, fitting size verification
would have permitted more accurate assessment of weld size when
the edge of the fitting was not identifiable.
In attempting o
suitably resolve these questions, TUGCo Quality Engineering was
contracted relative to original inspection criteria used for
weld acceptance. TUGCo Quality Engineering issued NCRs
!
- __-_-_----_
.
-36-
.
M-86-103363 (for Unit 1) and M-86-201978 (for Unit 2) to obtain
suitable resolution of these questions. This subject is
considered unresolved pending disposition of the NCRs and the
NRC review (445/8622-U-16; 446/8620-U-06).
J.
Category I Conduit Supports
Status of CPRT Activity
Reinspection of Category I Conduit supports is complete with 161
support pack 6ges reinspected. A total of 80 valid deviations were
identified. Documentation review is also complete with 160 packages
reviewed. A total of 186 valid deviations were identified.
Status of NRC Inspection Activity
The NRC inspector has, to date, performed the following eight
separate inspections of ERC inspected packages, all of which occurred
during this report period:
Verification
Support No.
Unit
Package No.
I-S-COSP-071
I-S-COSP 073
C140-06419-01
I-S-COSP!046
C03G09956-04
I-S-COSP-003
EAB9-5
I-S-COSP-017
ESB2-21
I-S-COSP-024
ESB8-6
1
1-S-COSP-042
-
I-S-COSP-009
C146-20047-01
No violations or deviations were identified,
k.
Inspection of Nonpressure Boundary Welds for a Supplementary
Evaluation of Visual Weldino Inspection T6thniques
StatusofCPRTActivity
All inspection activity is complete.
Status of NRC Inspection Activity
(1) All inspection activity is comp'ete.
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(2) The NRC inspector witnessed the.following inspection during
March 1986 which was documented in NRC Inspection
Report 50-445/86-03; 50-446/86-02:
Verification
Equi 3 ment
System *
Unit
Package No.
Tag
Vo.
I-S-NPBW-004
FW-1-017-908-C77W
4 - Steam Generator Feedwater System
An open item was identified during the inspection; however, its
discussion was inadverte.ntly left out of the NRC inspection
-
report. The following is a discussion of that open item.
During the second phase inspection (after removal of coating),
,
the NRC inspector identified what appeared to be an unacceptable
weld surface condition; i.e., not suitable for nondestructive
-1
examination (NDE). This open item was resolved by the
J
performance of a magnetic particle examination (MT) of the' weld
by a Brown & Root (B&R) Level III NDE examiner on June 30, 1986,
)
using NDE Procedure'QI-QAP 10.2-2, Revision 4.
The result of
j
the MT was documented on MT Report No. 22583, and showed that
the weld surface condition was suitable for NDE.
No rejectable
indications were observed.
No violations or deviations were identified.
)
6.
Assessment of Allegations
,
a.
AQ-148 (4-05-A-15), AQ-155, and AQ-157 (4-85-A-30):
It was alleged
that the construction start-up/ turnover surveillance (CSTS) group
performed a QA surveill6nce of the warehouse and bulk material
storage (laydown) areas and found deficiencies.
The QC group had
performed a similar surveillance in the sdme areas, yet the QC
surveillance did not detect or record any deficiencies (AQ-148 and
i
Althou
AQ-157).
shop (fab shop) gh the QC group had reported the iron fabrication
had satisfactorily implemented corrective action for
previously identified deficiencies, CSTS surveillance found that the
'
same type deficiencies continued.
Also, the QC surveillance of the
feb shop did not detect or record the continuing deficiencies
(AQ-155).
These three allegations were assessed in common since they concern
departures from procedural requirements pertaining to surveillance
of the segregation, protection, and storage of bulk materials.
The NRC inspector reviewed the CSTS QA Surv
' nce Report 85-002
dated January 14, 1985, for the fab shop a'
d that the report
"
identified several deficiencies regarding i
'al storage and one
'
"
deficiency that QC surveillance required by,
cedures were not
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documented. The CSTS record package contained documentation of
'
satisfactory corrective action that was implemented by CAR 039 dated
January 16, 1985, which addressed surveillance not being documented.
The NRC inspector reviewed CSTS QA surveillance reports through
.
April 1985.
These reports identified deficiencies in the warehouse
areas that related to maintenance records for stored in place items;
however, no deficiencies similar to those previously identified in
the fab shop were noted. The CSTS record packages contained
documentation of the satisfactory implementation of corrective action
of the maintenance record deficiencies noted. A walkdown ir.spection
by the NRC inspector did not identify any continuing deficiencies or
a
deficiencies similar to previous findings in the fab shop.
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All allegers referred to a QC surveillance of the warehouse area
which did not identify any deficiencies; however, a CSTS QA
surveillarme of the same area conducted one day later uncapped pipe
and deteriorated tape on pipe ends. The NRC inspector found that a
QC surveillance report of bulk material storage outside Warehouse C
was performed on April 30, 1985.
On the following d6y, May 1, 1985,
j
the CSTS QA surveillance group performed a random (unscheduled, not
utilizing a prepared QA checklist) surveillance of the same area.
The random surveillance resulted in the issuance of surveillance
deficiency reports concerning pipe end caps missing or damaged. The
deficient items were corrected and the deficiency reports closed.
'
The NRC inspector considered further the differences in the results
of the April 30 survey, which was satisfactory, and the May 1 survey
which identified the deficiencies.
Based on interviews with
personnel involved and review of documentation, it was determined
that the April 30 survey was a visual only inspection of the stored
condition of the items in the laydown yard. The May 1 survey was 6
hands on inspection of protective coverings which identified
deficiencies that would not necessarily be identified during a visual
only inspection.
This difference in inspection technique could
6ccount for the different survey results. #
'
In discussions with the manager, Warehouse and Material Control, the
NRC inspector found that warehouse and receiving QC personnel conduct
weekly and monthly surveillance of all storage areas. While the
requirement for these surveillance are not clearly documented in
procedures, the surveillance results are documented for each area
inspected, a result of implementation of CAR-039.
In addition,
periodic surveys and audits are conducted by personnel from the CSTS
group and the Dallas-based QA audit group. The NRC inspector
reviewed the results of the following surveillance and audits of the
pipe laydown area outside Warehouse C.
,
(2) Monthly surveillance are conducted in 14 areas by receiving QC
personnel. The January through June surveillance reports were
reviewed.
The February report identified seven items not stored
_ _ _ - _ _ _ - _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _
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properly in areas outside Warehouse C, which were subsequently
corrected. All other reports found conditions satisfactory in this
)
same area.
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(3) CSTS Report No.86-170, conducted the end of March 1986, was
reviewed. This survey of warehousing included the pipe laydown areas
j
outside Warehouse C.
Checklist item #4, based on CP-CPM-8.1,
!
Revision 3, was to verify piping and components were capped and
protected. This item was documented as satisfactory.
I
(4) The Dallas QA group conducted an audit (TCP-86-08) of the warehousing
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at the site, including the laydown areas outside Warehouse'C..during
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the weeks of March 3-17, 1986.
No unsatisfactory conditions were
i
noted in the audit report concerning outside pipe storage,
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The NRC inspector discussed the above findings with both the CSTS
surveillance inspector and the Dallas QA auditor. Each confirmed
that the outside pipe storage areas were in compliance with
i
requirements during their inspections.
This is potentially accurate
since the monthly surveillance conducted February 28, 1986, had
l
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identified seven nonconforming items which had been corrected.
Further, no audits or surveillance since the end of February had
identified nonconforming conditions in the outside pipe storage
areas.
On July 10, 1986, accompained by the manager, Warehouse and Material
.
l
Control, the NRC inspector conducted an inspection of outside storage
at Warehouse C, including pipe storage.
Four pieces of stainless
steel pipe were found with damapeo or deteriorated end covers, which
is a violation of Procedure MCP 10. Revision 9, " Storage and Storage
Maintenance of Mechanical and Electrical Equipment." The manager,
Warehouse and Material Control, initiated immediate corrective
action.
The NRC inspector found several pieces of carbon steel pipe
with end crps in place. When asked why, the manager Warehouse and
Material Control, stated that when carbon + steel pipe is received with
end caps in place they were not required to remove them. This also
is contrary to MCP-10 which states, in part, " Carbon steel piping
'
material or structural tubing shall not be capped."
These conditions are considered a violation (445/8622-V-17;
446/8620-V-07).
/.
Based on the assessment of these allegations, the NRC inspector /
substantiated that the weekly and perhaps the monthly surveHTances
~'
were not completely effective in identifying storace dy M ciencies nor
in preventing ident<ified deficiencies fromtreceivinD The NRC
findings above and those identified in paragraph.7.c of this report
I
are indicative that the alleged ineffectiveness'of the surveillance
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continues to exist.
The NRC findings concerning material storage
outside was the only example of receiving deficiencies that was
_ _ _ _ _ _ _ _ _ _ - _ _
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identified that is indicative of ineffective preventive measures
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while several examples of effective preventive measures, such as
{
CAR-039 were noted.
!
b.
4-86-A-026:
Improper Drilling on Cable Trays
i
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An allegation was made to the NRC inspectors that craft personnel had
drilled holes through solid bottom cable trays while electrical
cables were installed.
The holes were drilled so that cable ties
could be installed in the bottom of the tray to hold the electrical
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cables in proper separation positions, The concern was that the
j
drilling through the tray could cause damaage to the electrical
{
cable (s).
.
An NRC inspector identified a similar concern in NRC Inspection
!
Report 50-445/86-14; 50-446/86-11, in that holes were being drilled
through cable trays (paragraph 10.d).
The failure of the applicant
to control the drilling of holes through cable trays containing
,
electrical cables was determined to be o violation of Criterion V of
Appendix B to 10 CFR Part 50 (445/8614-V-03; 446/8611-V-10).
.
,
Therefore, this allegation has been substantiated and the NRC will
follow the corrective actions proposed by the applicant in response
to the above violation.
'
7.
Procurement, Receiving, and Storage
Durir.g this report period, an inspection of TUGCo procurement, receiving,
l
and onsite storage activities was made by the NRC inspector.
The
j
activities of subcontractors that perform safety-related procurement were
{
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also inspected.
Review of safety-related contracts revealed that BSC is
!
the only subcontractor currently performing onsite safety-related
procurement.
l
a.
TUGCo Onsite Procurement
o
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Onsite procurement is the responsibility of TUGCo as committed in the
FSAR and the TUGCo/TUSI QA Manual.
Details of organization ore in
TUGCo Procedure CP-SP-1, Revision 0.
A review of the site
procurement procedures found that they include the requirements of
ANSI N45.2.13 (1986).
l
To verify TUGCo implementation of onsite procurement requirements,
the NRC inspector selected ten safety-related P0s issued in the last
i
!
6 months for inspection. The P0sselected were:
(1) CPF-12901-S,
(2) CPF-12913-S, (3) CPF-12971-S, (4) CPF-13022-S, (5) CPF-13114-S,
(6) CPF-13141-S, (7) CPF-13172-S, (8( CPF-13210-S, (9) CPF-13257-5,
(10) CPF-13313-5.
For all of the P0s, the purchasing documents
specified and imposed the applicable technical requirements; i.e.,
codes 6nd standards.
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The NRC inspector verified chat the PCs were placed-with suppliers
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from the approved suppliers list or that the items were purchased
j
commercial grand and the required engineering evaluations performed.
The adequacy of the vendor surveillance program was previously
'
inspected and reported in NRC Inspection Report 50-445/86-03;.
50-446/86-02. As a further review, ten vendors were selected and a
verification made that a current audit or evaluation had been
performed. Two of these audits were reviewed in depth.
.
'j
Audit TBBC-3/T of BBC Brown Boveri Inc., was performed by Gilbert
j
Commonwealth for TUGCo, an approved supplier for conducting these
audits. Nuclear Supplier Quality Assurance System Evaluation
i
Checklist developed by the Coordinating Agency for Supplier
]
Evaluation. Audit TWH-34 of Westinghouse Nuclear Components Division
l
was performed by the TUGCo Dallas audit group utilizing their own
prepared checklist. Both vendors QA programs were evaluated as
'
acceptable.
No violations or deviations'were found in this area of the
inspection.
b.
TUGCo Receipt Inspection
The system for conducting receipt inspection was examined for
procedural compliance.
Procedures utilized were-
CP-QP-8-0, Revision 5, " Receiving Inspection"
i
.
CP-QP-8-0-2, Revision 1, " Receiving Inspection Instruction"
i
.
CP-QP-2-1, Revision 21, " Training of Inspection Personnel"
.
QI-QAP-2.1-5, Revision 9, " Training and Certification of
.
'
Mechanical Inspection Personnel."
The qualifications of six receipt inspectors were inspected and found
to be proper with appropriate supporting documentation in the
qualification file.
,
I
The area used for receipt inspection provided controlled access, a
clean and protectet inspection area, a hold area for nonconforming
material, calibrated measuring equipment in current calibration, and
j
an area with controlled temperature and humidity available for
'
receipt inspection of environmentally sensitive material.
Eleven RIRs and supplemental data were inspected to determine if the
requirements of the receiving procedures and purchasing
specification were met. The R0Rs selected were #27448, #26274,
- 27699, #27737, #27738, #27698, #27650. #27672, #27857, #27735, and
'
- 27734. The receiving requirements were met for all of these RIRs
and no violations or deviations were identified.
)
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c.
TUGCo Storage
The site storage and laydown areas were inspected for compliance to.
B&R Procedure MCP-10, Revision 9,." Storage and Storage Maintenance of.
Mechanical and Electrical Equipment." Areas inspected were
Warehouse's A and B, Welders Qualification Training Center (WQTC), the-
Pipe Fabrication Shop, Millwrights Shop, and the pipe, steel, and
'
electrical laydown areas. Also, items " stored inplace" inside Unit 2
reactor building were inspected.
The following areas of.
noncompliance were noted:.two level transmitters " stored inplace"
were not protected from overhead grinding activity; electrical cable
in cable trays in Unit 2 were not properly protected from nearby
welding activity; stainless steel tubing with the ends not capped or
capped with tape in degraded condition was found outside in the area
-
behind the WQTC and the layout area north of Warehouse C.
Violations
<
for the unprotected level transmitters and electrical cable was
'
reported in NRC Inspection Report 50-445/86-15; 50-446/6G-12. The
improperly capped tubing was identified as violation of
a
445/8622-V-17; 446/8620-V-07 in this report during the assessment of
-
an allegation.
'
The NRC inspector reviewed Procedures CP-QAP-14-1, Revision 6,
j
" Inspection of Storage and Maintenance of Permanent' Plant Equi
I
CP-QP-19.0, Revision 4," Construction, Start-up/ Turnover (CST)pment";
)
Surveillance"; and MCP-10. These procedures describe storage levels
]
anc' inspection requirements for storage.and maintenance. The-
prc;edures meet the requirement of ANSI-N45.2.2, Sections 2.7 and
6.1.2 for storage levels, and Section 6.4.1, for inspection
requirements.
No other violations or deviations were noted in this area of
inspection.
d.
Subcontractor Onsite Safety-Related Procurement Activity
To determine the procurement, receipt, and storage requirements for
BSC, the NRC inspector reviewed the terms of the BSC contract with
TUGCo.
The contract imposed the requirements of 10 CFR Part 50,
Appendix B; ANSI N45.2, 1971; and ASME,Section III, 1977.
The
!
following BSC procedures for procurement, receipt, and storage of
safety-related materials were reviewed to determine if they
incorporated these requirennents:
Procedure
Ti tle
QFP-4.003-CP1
Procurement of Material and Service from
General Contractor'/0wner
QFP-4.002-CP1
Procurement of Welding and Brazing Material
_ - _ _ _ - _ _ _
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Procedure
. Title
QFP-4.001-CP1
Procurement Document Control for Nuclear
Projects
QFP-7.002-CPI
Receiving and Storage
QFP-8.001-CP1
Identification and Control of Materials,
)
Parts, and Components
y
<
QCI-CPSES-004
Receiving Inspection and Identification
~ Procedure
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These procedures were found to adequately incorporate-the above
standards and requirements for procurement, receipt, and storage
activities.
j
BSC P0s 1769, 1776, and 1864 and BSC RIRs 511 and 517 were compared
with the criteria of the procurement and receipt inspection
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procedures. They were found to have been developed and processed in
accordance with these procedures.
The NRC. inspected the inside and outside storage areas as well as the
l
weld road room and oven area.
These areas were found to be in
compliance with the storage procedures and suitable for the type of
material stored.
Inspection of recent surveillance reports for these
,
areas found that surveillance were being performed to the specified
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frequency and that the area surveillance forms were completed
j
including notation of deficiencies,
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The approved vendors list was reviewed to determine if a current
audit or evaluation had been performed for each vendor. This review
four.d all vendors listed to be in compliance or to have been rernoved
from the approved vendors list.
The qualifications and certification files of all receipt inspectors
were reviewed.
These were found to be in accordance with the
requirements of ANS0-N45.2 and the BSC procedure for inspector
qualification.
No violations or deviations were identified during this area of
inspection.
'
S.
CPRT Central and Working Files
The purpose of this inspection was to verify that the CPRT central and
working files have been established, maintained, and controlled in
.
accordance with the requirements of. Policy and Guideline (PAG) PAG-02,
l
Revisions 0 and 1. " Policy on Assembly of CPRT Program Central and Working
Files,: and PAG-11, Revision 0, " Policy for Controlling Access to the CPRT
'
File and Closed Working Files."
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PAG-02 describes:
(a) documents to be included in the CPRT central files;
(b) accountability mechanisms; (c) specific requirements for content
organization, and format of ISAP working files; and (d) the criteria used
by the results report and working file review committee (RRRC) in their
]
review of completed working files and results reports for compliance to
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ISAP requirements.
PAG-11 describes the measures used to control access
to CPRT files.
PAG-02 and PAG-11 are implementing documents for CPRT
Program Plan,.Section III.J. "CPRT. Program Records," and Appendix G,
a
Attachment 4, " Verification of Issue-Specific Action Plan Working' Files."
]
It should be noted that FAG-02, Revision 0, and PAG-11. Revision 0, were
!
!
not issued until May 12, 1986, and July 30, 1986, respectively.
Work
accomplished prior to issuance of PAG-02 and PAG-11 was inspected for
.I
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compliance using the requirements in the CPRT Program Plan,Section III.J.
and Appendix G, Attachment 4.
a.
Organization of Central Files
The description of the central file contents and file index.is
provided in ' PAG-02, paragraph 2 and Attachment 6.6.
To verify
implementation of the PAG-02 requirements, the file index and file
contents log of each file was examined for compliance with
requirements.
In cases where files were too large for 100%
inspection, sampling was used to verify file content.
For example,
j
of the ten closed ISAP working files, seven were 100% inspected and
a
three were sampled.
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Tne results of this inspection verified that file indexes, content
logs, and file contents were consistent with requirements. The only
l
exception was the CPRT Program Director's personnel file which did
not contain the required objectivity questionnaire / evaluation
documentation. This matter has been identified as a deviation in
paragraph 2.a of this appendix.
l
b.
Control of Documentation / Files
Accountability of a file is accomplished by matching documentation
r
listed on the content file log against those documents in the file.
Procedurally, documents or document packages contained in the file
are required to be identified with the file number and the content
log sequential number. PAG-02, Revision 1, requires working file
documents or the contents of documentation packages to be
sequentially page-numbered. This allows for accountability and/or
recompiling should pages be mixed after or during reproduction, file
transmittal, or other use. The central file is in the process of
,
numbering pages of working files processed prior to PAG-02,
'
Revision 1.
With the exception of working files, the pages of
documents, such as action plans, results reports, CPRT program plan,
etc., were always numbered.
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PAG-11 requires controlled access to the file cabinets containing the
files.
Files are locked when not in use.
With the exception of the
working files, files may be removed from the central file mom by
using check out cards to account for the documents.
The NRC inspected checkout cards, access methods to file cabinsts,
the practice used to review working files in the central file room,
and documentation accountability..The practices used were found to
conform to PAG-02 and PAG-11 requirements.
c.
Verification of ISAP Working Files
l
Appendix G, Attachment 4 of the CPRT Program Plan describes the
'
requirements, responsibility, and criteria for the review and
verification of working file by the RRRC. This review occurs after
the ISAP has been completed and prior to the results report (RR)
being submitted to the SRT for review and approval. The purpose of
this review / verification is to determine:
(1) the contents of the
working file is complete and organized to be consistent with the-
requirements of the CPRT Program Plan, and-(2) the work reported and
"
conclusions reached in the RR are supported by information contained
l
in the working files.
Prior to May 22, 1986, che RRRC performed review activities using
checklists individually developed from Appendix G, Attachment 4.
The
l
checklists listed criteria to be used in verifying consistency
)
between the ISAP, working files, and.RR.
Results of the
review / verification were documented on the checklist with actions
required. After actions required were completed by the responsible
issue coordinator, the RRRC conclusions resulting' form the review and
i
verification were documented in a working file verification report.
'
The verification report was.then submitted with the RR to the SRT for
their review. Of the seven working files reviewed using Appendix G
l
checklist,sixwerefoundinthebackupffle,buttherewasno
commitment to retain the checklist.
In each case, the working file
verification report was in the file to document the performance of
the RRRC review and the conclusions reached.
Retention of the
working file verification report is a requirement.
The three. working files processed by the RRRC using PAG-02,
Revision 0, were found to~ comply to stated requirements of PAG-02 and
Appendix G.
Found in the backup files were detailed checklists
listing criteria to perform reviews, actions required, identification
closure of actions required, and the completed RRRC report submitted
j
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tu the SRT.
t
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The NRC inspector witnessed a portion of in-process review of I.d.3
',
by the RRRC and found it to comply with PAG-02, Revision 1,
requirements. A checklist was used to document review results and
actions required.
.
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In summary, the NRC inspector determined that the CPRT hao established
measures to develop and maintain the CPRT central files.
Procedures
governing the central file activities have been suitab'ly implemented with
one observed exception concerning the objectivity questionnaire missing
from the CPRT Program Director's personnel file noted above. Other files
appear to contain the required documentation. Accountability and access
to files were controlled per procedural requirement.
With respect to the results report and working files review performed by
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the RRRC, their reviews were found to conform to the applicable
j
requirements and guidelines.
The inspected documentation confirmed the
{
performance of reviews and that conclusions reached were reported to the
i
/
SRT as required.
_
Based upon a review of central files and supporting documentation, for
RRRC activities, it appears that PAG-02, Revision 0 and 1, and PAG-11,
Revision 0, have been adequately implemented.
.
9.
ERC Overview Inspection Program
i
The purpose of this inspection was to verify that the ERC overview
}
inspection program, as delineated in ERC-QA-28, Revision 3, " Performance
of Overview Inspections," was being implemented in accordance with
requirements. According to ERC personnel, the objectives of the overview
inspection program are:
(a) to measure the effectiveness of ERC
{
activities, and (b) g third party reinspection / documentation review
inspectors performin
to determine the adequacy of QIs in directing
inspection activities. To achieve these reinspection / documentation review
activities, and (b) to determine the adequacy of QIs in directing
,
inspection activities.
To achieve these objectives, the Ols duplicate the
j
initial reinspection or documentation review, then by comparing these
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results with the initial reinspection / documentation review identify any
inconsistencies.
Inconsistencies are then evaluated for validity and
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resolution including required actions to prevent recurrence.
'
The NRC inspector developed a checklist detailing requirements identified
in ERC-QA-28, Revision 3,
nd compared a sample of overview inspection
verification packages (VPs) against the checklist to determine if the VPs
'
were developed and processed in accordance with ERC-QA-28 requirements.
Of the ten certified Ols, seven had performed the majority of the overview
inspections,
The sample of overview VPs was selected to contain at least
one or more packages from each of the seven most active Ols.
It was noted
that, in some cases, more than one OI participated in a single overview
inspection.
This inspection was structured to evaluate the following
topics:
sample selection, determination of accessibility, preparation of
overview VPs, completion of overview checklists, comparison of results
with the initial reinspection, completion of overview inspection report
and verification and followup of actions required.
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a.
Sample Selection
VPs documenting the results of initial reinspection / documentation
reviews were randomly selected for overview inspection.
Based on the
type of reinspection activity, the sampling technique is described in
ERC 0A-28 for the selection of VPs for overview inspection. The NRC
sample selected for inspection was 16 out of a total of 51 ERC
j
inspectors.
The number of inspectors sampled were by discipline:
q
six-piping; five-mechanical, three-electrical, and two-civil. The
i
NRC review of this sample included:
the overview inspection program
selection methods and use of random tables, calculations, and
selection results. Based on documentation reviewed, the sample
,
selection used in the overview inspection program conformed to
procedural requirements,
b.
Determination of Accessibility
The OI required to confirm that any necessary equipment / services to
perform overview inspections are in place and that the sample is
accessible. This practice was found to be documented.
If the
equipment / services was not available or the sample inaccessible, such
j
was documented in the sample selection log and another accessible
'
sample chosen in accordance with procedures.
c.
Preparation of Overview VPs
)
The overview VP is prepared by ERC and duplicates the initial VP used
by the ERC inspector.
Upon receipt, the 01 supervisor is responsible
to verify that the overview VP is complete and accurate prior to
assignment to an 01.
Based on the NRC inspector's review of 17
overview VPs, it was determined that the 01 supervisor had verified
the completeness and accuracy of VPs. The contents of this packages
were found to agree with the contents from which lists all the
documents that comprise the overview VP; e.g., inspection drawings,
supplemental inspection instructions, and inspection checklist.
d.
Completion of Checklists and VP Contents Form
In the review of overview inspection checklists, it was found thi.t
some checklists were not processed in accordance with ERC-QA-28
requirements. Noted errors were:
corrections not initialed and
dated; absence of required entries; no justification or explant. tion
for "N/A" (not applicable) entries; supplemental checklist not signed
by OI; and added documents to the VP were not entered on the VP
contents form. These type errors were also identified by ERC during
audit ERC-86-03, June 16-20, 1986.
Corrective action responding to
these findings was the conduct of an independent review of historical
VPs.
A detailed checklist was developed to identify errors in
checklists and content forms.
ERC was in the process of conducting
this historical review of VPs during the NRC inspection.
The NRC
inspector examined 12 historical review results.
VP checklist and
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content form errors that were identified were being corrected.
processed after completion of this corrective action would be subject
to independent reviews to assure completion errors are being
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identified and corrected.
Comparison cf Overview Inspection Results vs Initial Reinspection
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e.
Results
Procedurally, a comparison is required to be made between the
overview inspection packages and the initial reinspection / document
review package to identify inconsistencies. Those inconsistencies
t
confirmed as being valid are reported in the overview inspection
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report for required action.
During the NRC's comparison of the
packages, it was found that not all inconsistencies were identified
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by the 01.
Examples of inconsistencies were:
inspection checklists
reflect disagreement between ERC inspectors and Ols, but the overview
,
inspection report did not identify the disagreement; the ERC
'
inspector or 01 accepted an attribute and the other inspector would
enter N/A; and items not inspected by overview were inspected by the
initial ERC inspectors. These types of inconsistencies were also
identified in audit ERC-86-03.
Corrective action taken was to also
address these type errors in the historical review of overview VPs.
During 'the NRC's inspection of the 12 historical reviews, it was
found that the inconsistency errors were being addressed and when
indicated, inspector retraining was conducted.
f.
Overview Inspection Reports
Seventeen overview inspection reports were examined. The results
from overview inspections were found to t,e documented on the reports
j
per procedural requirements.
Information in overview inspection
reports included:
accept / reject criteria; the observed deviating
condition; and action required with a completion schedule. Typical
corrective action included:
inspector retraining, reinspection of
identified inconsistency, revising'Ols or the combination thereof.
The overview inspeciton reports were reviewed and approved by the 01
supervisor and transmitted by memo to the responsible ERC personnel
for action.
g.
Followup and Verification of Actions Required
ERC-QA-28 delineates steps for the verification of actions required.
Of the 17 Vs reviewed, 11 contdined overview inspection reports
requiring actions to correct identified inconsistencies.
One
overview inspection report contained on error in that the required
corrective action had not been ven fied. This type error was to be
addressed in the historical review being performed by overview
personnel as a result of a finding in audit ERC-86-03. To assure the
historic 61 review was effective und would identify this type of
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error, the NRC witnessed the historical review of the overview
inspection report. The error was identified during the historical'
d
review.
To date, 104 overview inspection reports required corrective action.
Seventy-nine related to findings against reinspection inspectors
(inspector effectiveness), and 25 related to ERC engineering
(inadequacy of QQIs).
Inspector deficiencies identified in overview
inspection reports.are trended for corrective action tc prevent.
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recurrence. When engineering deficiencies are identified, the
appropriate QI-is revised as necessary, and previously completed' work
per the affected QI is essessed for impact.
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As of July 28, 1986, 46 open overview inspection reports requiring-
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corrective action were from 8 to.175 days past the scheduled closure
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date.. Audit ERC-86-03 identified the overdue reports as untimely
corrective action.
In response to this audit finding, ERC
established a tracking system to monitor the status of overview
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inspection reports and their progress.
10.
Exit Interview
Exit interviews were conducted on August 7, 1986, and September 5, 1986,
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with the applicant's representatives identified in paragraph 1-of this
6ppendix.
During these interviews, the NRC inspectors summarized the
scope and findings of the inspection. The applicant acknowledged the
findings.
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