IR 05000445/1986026
| ML20206E812 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/01/1987 |
| From: | Barnes I, Ellershaw L, Hale C, Spessard R, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20206E792 | List: |
| References | |
| 50-445-86-26, 50-446-86-22, NUDOCS 8704130746 | |
| Preceding documents: |
|
| Download: ML20206E812 (43) | |
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APPENDIX C COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-445/86-26 Permits: CPPR-126 50-446/86-22 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit Expiration Dates:
Unit 1: August 1, 1988 Unit 2: August 1, 1987 Applicant: Texas Utilities Electric Company Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES),
Units 1 & 2 Inspection At: Glen Rose, Texas Inspection Conducte September 1 through October 31, 1986 Inspectors: UO LI E. Ellershaw, Reactor Inspector, Region IV (Tate CPSES Group (paragraphs 2.b, 2.1, 3.c, 4.a-k, 5.c, and 6)
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C. J. Halg4 Reactor Inspector, Region IV Date CPSES Group (paragraphs 2.y, 3.a-b, 3.d-e, and 5.a)
9. C bMA P. C. Wagner, ReactorjInspector, Region IV Jlsi /67 Date CPSES Group (paragraphs 2.a-x, 2.z-al, and 5.a-b)
8704130746 870402 5 DR ADOCK 0500
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Consultants: EG&G - J. Dale (paragraphs 2.b, 4.j, 4.k and 5.c)
A. Maughan (paragraphs 2.a-x, 2.z-al, and 5.a)
W. Richins (paragraphs 2.b, 3.c, 4.a-c, and 5.a)
V. Wenczel (paragraph 5.a)
Parameter - J. Birmingham (paragraphs 2.y, 3.a-b, and 3.d-e)
K. Graham (paragraphs 2.b, 2.1, 4.e-f, 4.h-1, dnd 6)
D. Jew (paragraphs 2.1, 4.d, 4.g 5.a. and 6)
Reviewed By: .
rtd e 87 7 R. L. Spessard,'p/puty Director, Division -
Date of Inspection Programs, Office of Inspection and Enforcement Approved: W N/M7 1. Barnes, Chief, Region IV CPSES Group Date Inspection Summary Inspection Conducted September 1 through October 31, 1986 (Report 50-445/86-26; 50-446/86-22)
Areas Inspected: Nonroutine, unannounced inspection of applicant actions on previous inspection findings, Comanche Peak Response Team (CPRT) Issue-Specific Action Plans (ISAPs), and assessment of allegation Results: Within the three areas inspected, four violations (cable pulling ropes were left in Unit I conduits and cable trays, paragraph 2.h; a log documenting potentially nonconforming items was discarded without the items being dispositioned, paragraph 5.a; potentially nonconforming items being documented on request for inspection forms are not being effectively tracked or accounted improperlyfor, paragraph certified, 5.a; and4.k.)
paragraph Bahnson Service and five Company deviations t {an EvaluationBSC) welders w Research Corporation (ERC) inspector failed to write an out-of-scope memorandum documenting a potentially nonconforming condition, paragraph 2.h; ERC's craft training procedure review failed to identify the lack of a BSC personnel retraining requirement and thus did not recommend procedure improvement, paragraph 3.b; substantive changes to an ISAP were made and implemented prior to approval by the Senior Review Team, paragraph 3 b; ERC engineering failed to identify all the HVAC activities and attributes to be included in review and inspection checklists, paragraph 4.j; and ERC inspections in the HVAC area were based on documents different than those used for the inspection of record, paragraph 4.k) were identified.
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DETAILS Persons Contacted S. Ali, Engineering Assurance Systems Manager, Texas Utilities Generating Company (TUGCo) Nuclear Engineering (TNE)
J. Audas, Senior Licensing Engineer, TUGCo
- R. P. Baker, Regulatory Compliance Manager, TUGCo-
- J. L. Barker, Engineering Assurance Manager, TUGCo
- C. T. Brandt, Quality Engineering (QE) Supervisor, TUGCo
- T. Braudt, Senior Engineer, TUGCo
- R. E. Camp, Project Manager, Unit 1, TUGCo
- R. Deatherage, Director, Engineering Administration, TUGCo
. J. V. Everett, Project Manager, Impell Corporation
- P. E. Halstead, Site Quality Control (QC) Manager, TUGCo
- J. Krechting, Director of Engineering, TUGCo J. C. Kuykendall, Vice President, TUGCo
- D. McAfee, Manager, Quality Assurance (QA), TUGCo J. Ma11anda, Electrical Review Team Leader, CPRT S. Martinovich, Principal Engineer, Gibbs & Hill
- J. T. Merritt, Jr. , Assistant Project General Manager, TUGCo C. K. Moehlman, Project Mechanical Engineer, TUGCo
- L. D. Nace, Vice President, TUGCo E. Odar, Project Engineering Manager, EBASCO A. A. Patterson, Reinspection Engineering Supervisor, ERC F. L. Powers, Assistant Unit 1 Project Manager, TUGCo P. Passalugo, Equipment Qualification Engineer, Impell
- M. R. Steelman, CPRT, TUGCo P. Stevens, Electrical Engineer Manager, THE
- J. F. Streetar, Director, QA, TUGCo M. Strehlow, Conduit Engineering-Field Program Manager, EBASC0 T. G. Tyler, CPRT Program Director, TUGCo The NRC inspectors also interviewed other CPRT and applicant employees during this inspection perio * Denote:, personnel present at the October 9,1986, exit intervie ** Denotes personnel present at the November 12, 1986, exit intervie *** Denotes personnel present at both of the above exit interview . Applicant Actions on Previous Inspection Findings (Closed) Unresolved Item (445/8511-U-01): Unclear requirements in EC Quality Instructions (QIs). Tnis item dealt with the lack of clarity with respect to inspection requirements contained in two QI QI-008 contained unclear requirements with respect to channel separation, fire stops and seals, and certain attachment criteri QI-014 contained unclear instructions regarding inspection of cables that were not accessible for their full lengt The unclear requirements and instructions were suitably resolved with the issuance of Revision 2 of QI-008 on September 9, 1985, and Revision 1 of QI-014 on February 19, 1986, respectivel In addition, the NRC inspectors reviewed the 73 other QIs that had been issued as of September 30, 1976, for clarity of instructions and requirements. No other similar concerns were identified; therefore, this item is close However, it should be noted that an unresolved item (445/8622-U-15; 446/8620-U-06) pertaining to instructions not being provided in QI-070 for weld size inspection when the edge of tubing fittings had either been consumed by welding or subjected to grinding, has been identified in NRC Inspection Report 50-445/86-22; 50-446/86-2 (Closed) Deviation (445/8513-D-02): Verification package preparation. This item pertained to incomplete and incorrect preparation of verification packages by ERC population engineer In response to this deviation, the applicant proposed the following corrective actions: (1) retrain the population engineers in package preparation per Comanche Peak Project Procedure (CPP)-008 requirements, (2) review and revise as needed all QIs used for ISAPs VII.c and VII.b.3, (3) perform a reinspection of a sample of verification packages which were complete, (4) form an overview (surveillance) inspection group to perform independent inspections of a sample of completed inspection packages to assess past and future inspector performance, and (5) form an engineering assurance group to review completed verification packages and verify that they are properly prepared. The NRC inspector verified the above proposed corrective actions have been implemented by a review of:
(1) Corrective Action Report (CAR)-016, (2) appropriate procedures, (3) overview inspection log books and a sample of inspection packages, and (4) organization record (Closed) Open Item (445/8513-0-24): Loose conduit fittings. Further NRC inspector review of the loose conduit fittings discovered by ERC inspection of Verification Package I-E-CDUT-044 showed that nonconformance report (NCR) E85-101342 had been dispositioned to tighten the connection The NRC inspector verified that this work had been accomplishe d. (Closed) Open Item (445/8513-0-26): Missing plug and loose. retaining scre Further NRC inspector review of the out-of-scope conditions found by ERC inspection of Verification Package I-E-CDUT-027 showed NCR E85-101439 had been dispositioned and closed. The disposition stated that the plug was properly installed (it was difficult to see without close inspection) and that the retaining screw was stripped and needed to be replaced. The NRC inspector verified.the existence of the plug and that the screw had been replaced.
e. (Closed) Open Item (445/8513-0-33): ERC identified missing identification tag Further review by the NRC inspector of this item found that the NCR number in NRC Inspection Report 50-445/8601; 50-446/8601, Appendix E, was incorrectly stated as E85-1001289 when it should have been E85-101289. NCR E85-101289 has been dispositioned to require new identification tags to be fabricated and installed on the electrical conductor seal assemblies (ECSAs). NRC inspection verified that the NCR rework had been completed.
f. (Closed) Open Item (445/8513-0-35): ERC identified missing conduit identification (ID) digi Further review by the NRC inspector of this item revealed that, in addition to NCR E85-101289 which was written for this item, NCR E85-101440 was also writte Both of these NCRs had been dispositioned to require ID correction and were closed. The NRC inspector performed a reinspection and verified that the conduit ID had been corrected.
g. (Closed) Open Item (445/8513-0-36): ERC identified illegible conduit markings. Further NRC inspector review of this item revealed that NCR E85-101442 had been dispositioned and closed. The NRC inspector performed a reinspection and verified that the NCR required rework had been completed.
h. (Closed) Open Item (445/8513-0-37): Flexible conduit fittings and Valve 1-8875 This ERC identified item pertained to: (1) the flexible conduits at penetration 1E66 did not have protective sleeve inserts installed; (2) conduit C12018896 contained a nylon pull rope; and (3) a loose electrical attachment for Valve 1-8875A. Further review by the NRC revealed that TUGCo reinspected the flexible conduits and found the sleeves to be installed. On this basis, item (1) above is closed. The loose electrical attachment was found by NRC reinspection to be properly installed; therefore, item (3) is closed. The rope in the conduit was identified by both the ERC inspector and the NRC inspector witnessing this reinspection as an out-of scope deficiency. Follow-up by the NRC inspector found that the ERC inspector had failed to document this out-of-scope deficiency as required by Procedure CPP-020. Item (2) is closed; however, the failure by ERC to document this deficiency is a deviation (445/8626-0-01).
Further review and inspection by the NRC inspector during this report period found that conduit C12018896 still contained the pull rop .
In addition, during a tour of the 832' level of the auxiliary building on September 11, 1986, the NRC inspector observed a pull rope in safety-related Train A, cable tray T130ACG57. This cable tray had the thermolag covering removed for hanger inspections. The TUGCo post construction inspection Procedure QI-QP-11.3-40 required the inspector to verify that all cable pulling aids had been removed from the raceway. For both of these raceways, a post construction inspection had been performed. The failure of the project inspectors to identify that the ropes had not been removed is a violation (445/8626-V-02).
The applicant issued NCR E86-103883 for the rope in the conduit on September 4,1986, and NCR E86-103981 for the rope in the cable tray on September 12, 1986.
i. (0 pen) Violation (445/8513-V-01): Incomplete and missing conduit ids. This item pertained to through-the wall conduit sleeves (TWS)
and through-the-floor conduit sleeves (TFS) which were marked with incorrect identification numbers or had no identification markings applie In response to this violation, the applicant proposed the following corrective actions: (1) correct the identification marking for the sleeves identified in the Notice of Violation (N0V) as having incorrect or incomplete identification; (2) perform walkdowns of all power and nonpower TWS and TFS; (3) perform a review and comparison between the requirements in Specification ES-100, Drawing 2323-El-1701, design change authorization (DCA)-21,464, and installation and inspection procedures for TWS and TFS; (4) train personnel to procedure and drawing requirements; and (5) perform surveillance inspections to assess effectiveness of trainin The NRC inspector performed a reinspection for action (1) and verified the sleeve identifications had been correcte The NRC inspector review verified that ES-100 and Drawing 2323-El-1701 have been revised to reflect DCA-21,464 and that the training records indicated that involved personnel have been trained to the revised procedures; therefore, actions (3) and (4) are complete. This item remains open pending the applicants completion of actions (2)
and (5).
j. (Closed) Deviation (445/8514-D-02): Document & tion review of attribute This item pertained to the lack of inaccessible or nonrecreatable attributes in document review procedures as required by ISAP VII.c. In response to this deviation, the applicant proposed the following corrective actions: (1) revise ISAP VII.c to state that document reviews will only be used for nonrecreatable attributes where 60 occurrences of the attribute were not accessible from the population as a whole, and (2) inspect additional samples from the population for those attributes which were inaccessible in preceding inspections. These additional samples were selected until 60 samples of each attribute had been inspected. The NRC inspector reviewed the
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ERC files and verified that ISAP VII.c had been revised and that additional. samples were inspected for the inaccessible attribute k. (Closed) Deviation (445/8514-D-03): Inspector failed to follow procedur This item pertained to an ERC inspector who failed to follow the. instructions in document review Procedure QI-009. In response to this deviation, the applicant proposed to retrain the inspector in the requirements of Procedure QI-009 and reinspect 25%
of the inspector's completed packages to evaluate his performanc The NRC inspector reviewed the ERC training records and verification packages and verified the proposed actions have been implemente . (Closed) Deviation (445/8514-D-04): Inspectors failed to follow procedure This item pertained to reinspections for instrumentation supports (INSP), large bore pipe supports (LBSR) and instrumentation (ININ) where the ERC inspectors failed to follow procedure instructions. In response to this deviation, the applicant proposed the following corrective actions: (1) reinspect 25% of the INSP and LBSR packages completed by the two identified ERC inspectors and evaluate the results of these reinspections; (2) revise QI-012 to allow inspectors to indicate inaccessible bends; (3) hold a general training session for inspectors on spring nut inspections; and (4) revise and reissue all ININ verification packages for reinspection. The NRC inspector verified that the above actions had been implemented through a review of a sample of ERC verification package inspection reports (irs), procedures, and training record As a result of the reinspection performed for action (1), use of one inspector was discontinued and 100% of the inspections performed by that inspector were reinspected. _The other ERC inspector was retrained in the applicable procedure requirements, m. (0 pen) Open Item (445/8514-0-07): Comparison of NRC and ERC results from document reviews for cable Further review was performed for five ERC cable document review packages with the following findings:
R-E-CABL-004: NCR E85-102052 had been dispositioned and close The NRC inspector reviewed the NCR and verified it had been properly dispositioned. This document review package is ccmplete and close R-E-CABL-011: A comparison of ERC document review results with the NRC results was completed with no adverse finding R-E-CABL-026: The two deviation reports (ors) identified with this package have been invalidate The NRC inspector reviewed the DRs and verified that they had been properly dispositione R-E-CABL-028: The DR identified with this package was invalidate The NRC inspector reviewed the DR and verified it had been properly dispositione l
8 R-E-CABL-035: One of the two DRs written for this package was invalidated, the other was validate NCR E86-101208 was written for the valid DR. The NRC inspector reviewed the invalid DR and verified it had been properly dispositione This item will remain open pending NRC review of the disposition of the NCR for Verification Package R-E-CABL-03 (Closed) Open Item (445/8514-0-08): Cable tray splice plates. This item pertained to ERC and NRC identified conditions of unused holes next to splice plate bolts in tray T13GDCX60 and loose splice plate nuts in tray T13GDCS5 Further NRC inspector review and reinspection verified that the rework for these two cable trays has been complete o. (Closed) Open Item (445/8514-0-10): Document reviews for conduit Comparison of NRC review results to the ERC review results for six conduit document review packages was completed. Comparison of ERC results for Review Packages R-E-CDUT-027, R-E-COUT-044, and R-E-CDUT-050, with the NRC results was completed with no deviations or violations being identifie Review Packages R-E-CDUT-035, R-E-CDUT-065, and R-E-CDUT-066, which did not originally reference Procedure QI-QP-11.3-4, were re-reviewed by ERC using the revised QI-009 procedure. The NRC review of these packages was completed with no deviations or violations identifie p. (0 pen) Open Item (445/8514-0-13): Instrument tubing slope and location. This item pertained to the ERC identification of tubing for pressure instrument 1-PIS-4251 not meeting the slope requirements and the instrument not being located as shown on Drawing 2323-M1-261 NCRs 186-100058 (slope requirements) and 186-100699 (location requirements) have been written for these deficiencies. This item remains open pending disposition of the NCR q. (0 pen) Open Item (445/8514-0-14): ERC identified tubing line with reverse slope. Further review by the NRC inspector of the reverse slope of the tubing for pressure instrument 1-PT-4520 revealed that NCR 186-102023 had been writte This item remains open pending disposition of the NC r. (Closed) Open Item (445/8514-0-17): ERC identified damaged condui Further review by the NRC inspector revealed that NCR E85-101596 had been written, dispositioned and closed for the damaged conduit. The disposition called for the conduit to be replaced. The NRC inspector performed a reinspection and verified that the conduit had been replace s. (Closed) Unresolved Item (445/8514-U-16): Cable damage due to cable grip This item pertained to potential electrical cable damage resulting from installation practices used for cable support grip __
The NRC inspector reviewed the responses by the cable manufacturers to the TUGCo request for evaluation of the CPSES installation practices for cable grips, letters numbered VBR-19,469 and VBR-19,470, and verified that the installation practices used by TUGCo are in agreement with the recommended installation instructions of the cable manufacturer t. (Closed) Unresolved Item (445/8514-U-18): Incomplete document review. This item pertained to construction operation travelers that were not reviewed by ERC as part of Verification Package R-E-CDUT-064. Further review by the NRC inspector found that this verification package was revised by ERC to include these construction travelers. An NRC inspector comparison of the revised results to the NRC results was completed with no violations or deviations being identifie u. (0 pen) Violation (445/8514-V-04): Inspector not certified. This item pertained to an applicant inspector who performed inspections while not certified to the involved procedur In response-to this violation, the applicant proposed the following corrective actions:
(1) issue NCR E85-101639 for this violation; (2) review 800 inspection reports completed by 163 QC inspectors that were issued in the last 6 months; and (3) issue a weekly QC inspector certification list to supervisor The NRC inspector reviewed the applicant review reports from action (2). The applicant found no other instances of an inspector. signing an inspection report while not certified. The NRC inspector also reviewed the weekly certification list and verified that a sample of the inspectors were certified. This item remains open pending disposition and closure of the NCR for action (1),
v. (Closed) Deviation (445/8516-D-17): Incorrect cable routing. This item pertained to an ERC inspector who failed to identify that a cable routing did not agree with the cable and raceway schedule. In response to this deviation, the applicant proposed the following corrective actions: (1) discuss the deviation thoroughly with the inspector; (2) have the overview inspection group perform a historical review of inspections for this attribute by the inspector; and (3) write a OR for this deficiency. The NRC inspector reviewed the ERC records and verified that: (1) the training records indicate that the deviation was discussed with the inspector; (2) overview inspections had been performed; and (3) a DR for this deficiency had been issue w. (Closed) Deviation (445/8516-0-18): Incomplete cable tray configuration. This item pertained to an ERC inspector who failed to identify a missing nut and locking device on a cable tray splice plate. In response to this deviation, the applicant proposed the following corrective actions: (1) discuss deviation thoroughly with the inspector; and (2) write a DR and revise the verification package for this deficiency. The NRC inspector verified that: (1) the
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deviation was discussed with the inspector; (2) DR I-E-CATY-077-DR02 had been written; and (3) Verification. Package I-E-CATY-077 had been revised. Implementation of the overview inspection program was i verified, as discussed in paragraph 2.b above.
3 (0 pen) Deviation (445/8516-D-30): Improper instrumentation
inspections. This item pertained to incorrect instrumentation inspections by various ERC inspectors and the lack of procedure
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clarit In response to this deviation, the applicant proposed the following corrective actions: (1) reinspect the various items
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, identified and revise the verification packages by writing required DRs and out-of-scope observation memos; (2) revise instrumentation
] inspection Procedure QI-012; (3) perform a 100% reinspection of ININ packages after QI-012 had been revised; and (4) prior to fuel load of Unit 1, TUGCo will perform a reinspection of all system valve tags.
- The NRC inspector review of the ERC inspection records for the ININ population and QI-012 verified that the above actions have been implemented and completed except for item (4). This item remains
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, open pending completion of the valve tag reinspectio ! (Closed) Open Item (445/8516-0-19): ERC Special Evaluation Team
! actions regarding TUGCo inspector who had failed test. A review of the certification of the TUGCo QC inspector who failed the examination for QI-QP-11.3-29, but was certified to all QI-QP-11.3
! procedures, has been completed by ERC. NRC inspector review of the l' ERC report on this inspector indicated that: (1) this inspector performed no QI-QP-11.3-29 inspections after taking the test; (2) the error in certification was discovered by TUGCo and the inspector's
certifications were revised to exclude authorization to perform QI-QP-11.3-29 inspections; and (3) this inspector's performance will be evaluated in the ISAP I.d.1, Phase III, program.
- (Closed) Open Items (445/8516-0-21 through 445/8516-0-29): Document reviews. Comparison of the results of NRC documentation reviews to
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the results of the ERC reviews for the following nine electrical
- equipment verification packages has been completed.
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Open Item Verification Equipment l
- Package i'
445/8516-0-21 R-E-EEIN-003 ECSA-1-HV-4725-1, 2, & 3 445/8516-0-22 R-E-EEIN-012 ECSA-1-HV-4172-1, j 2, & 3
- 445/8516-0-23 R-E-EEIN-024 IE66 445/8516-0-24 R-E-EEIN-029 ECSA-1-85128 445/8516-0-25 R-E-EEIN-039 ECSA-1 ,iV-5561 l
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445/8516-0-26 R-E-EEIN-042 ECSA-1-8511B 445/8516-0-27 R-E-EEIN-045 1E15 445/8516-0-28 R-E-EEIN-052 ECSA-1-HV-4169 445/8516-0-29 R-E-EEIN-059 CP1-ECDPEC12 No violations or deviations were identified.
aa. (Closed) Deviation (445/8518-D-14): Inspector failed to follow procedur This item pertained to a reinspection for instrumentation not being performed in accordance with instructions. In response to this deviation, the applicant proposed the following corrective actions: (1) write a DR and an out-of-scope observation memorandum for the deficiencies identified by NRC inspectors, (2) revise the verification package, and (3) perform a 100% reinspection of instrumentation packages. The NRC inspector verified that: (1) a DR and memorandum had been written, (2) the verification package had been revised, and (3) a 100% reinspection of the instrumentation packages had been completed.
ab. (Closed) Unresolved Item (445/8518-U-13): Instrumentation procedur This item pertained to potential tubing damage and loose gland nuts not being addressed in ERC Procedure 01-012. Further review by the NRC inspector revealed that the ERC procedure was based on the TUGCo and the Brown and Root (B&R) instrumentation installation procedure The above two items were not included in these installation procedures, but were included in the TUGCo pressure testing and post construction procedures. The ERC procedure, therefore, adequately included all of the steps needed for instrumentation tubing installation, ac. (0 pen) Violation (445/8518-V-01): Incorrect conduit lengths per drawin This item pertained to two conduits for solenoid valves associated with valves 1-HV-4631A and 1-HV-4631B that are longer than Drawing 2323-El-1701 requirements. In response to this violation, the applicant proposed the following corrective actions: (1) issue NCR E86-102718 for valves 1-HV-4631A and 1-HV-4631B; (2) perform plant walkdowns to identify any deviations from the requirements of Drawing 2323-El-1701, Detail 18, as part of CAR-63; (3) revise Procedure QI-QP-11.3-28 to include instructions for Drawing 2323-E-1701, Detail 18, requirements; and (4) train QC inspectors to the revised procedure. The NRC inspector has verified, through a review of QI-QP-11.3-28 and training records, that actions (3)
and (4) have been implemented and are complete. This item remains open pending completion of applicant actions required by (1)
and (2) above.
ad. (0 pen) Violation (445/8518-V-11): This item pertained to incorrect and missing identification markings on the thermal lag installed on
cable trays and conduits. In response to this violation, the applicant proposed the following corrective actions: (1) issue NCRs for the items identified in the NOV; (2) reinspect and rework as required all thermal lag installed in Unit 1; and (3) train craft personnel to the requirements of Procedure CP-CPM-10.3 prior to thermal lag installation. The NRC inspector verified that NCRs E86-103146, E86-103147, E86-103148, and E86-103149 have been issued for action (1). This item remains open pending completion of applicant action ae. (0 pen) Violation (445/8518-V-15): Failure to perform engineering walkdow This item pertained to a failure by applicant engineering organizations to perform a walkdown of instrumentation tubing installations as required by DCA-13,023. In response to this violation, the applicant proposed the following corrective actions:
(1) revise DCA-13,023 to prohibit instrument tubing contact with galvanized surfaces, and (2) perform a walkdown of instrument tubing to identify any nonconforming conditions to the revised DCA-13,02 The NRC inspector verified that the DCA had been revised and issued, and that an engineering walkdown will be performed as part of the work for Significant Deficiency Analysis Report (SDAR)-8616. This item remains open pending completion of the walkdow af. (Closed) Open Item (445/8601-0-15): Comparison of ERC and NRC inspection results. This item pertained to the comparison of the NRC inspection results with ERC inspection results for Verification Package I-E-CDUT-11 The NRC inspector comparison of the results has been completed with no violations or deviations being identifie ag. (0 pen) Open Item (445/8603-0-07): Lack of tubing color coding identified by ERC during an NRC witnessed reinspection. This item pertained to tubing which did not have the required longitudinal color coding. Further review by the NRC inspector revealed that DR I-E-ININ-30R-DR01 and NCR 186-101787 have been written for this ite This item remains open pending disposition of the NC ah. (Closed) Open Item (445/8603-0-08): Flange material traceability identified by ERC during an NRC witnessed reinspection. This item pertained to lack of information included in the verification package to verify flange material identification and traceability. Further review by the NRC inspector revealed that the flange was shipped by the vendor as part of the instrument for which traceability is available.
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al. (0 pen) Open Item (445/8603-0-09): Lack of required air gap identified by ERC during an NRC witnessed reinspection. This item l pertained to four air gaps around the tubing which were less than i required. Further review by the NRC inspector revealed that DR I-E-ININ-030R-DR02 and NCR 186-101787 have been written for this item. This item remains open pending disposition of the NCR.
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aj. (Closed) Open Item (445/8603-0-10): Flange material traceability problem identified by ERC during an NRC witnessed reinspection. This item pertained to lack of information included in the verification package to verify flange material identification and traceabilit Further review by the NRC inspector revealed that the flange was shipped by the vendor as part of the instrument and that identification and traceability are available through the vendo ak. (0 pen) Open Item (445/8603-0-11): Lack of required air gap identified by ERC during an NRC witnessed reinspection. This item pertained to an air gap around the instrument tubing which was less than required. Further review by the NRC inspector revealed that DR I-E-ININ-034R-0R02 and NCR 186-101786 have been written for this item. This item remains open pending disposition of the NC al. (0 pen) Open Item (445/8603-0-12): Lack of required air gap identified by ERC during an NRC witnessed reinspection. This item pertained to two air gaps around instrument tubing which were less than required. Further review by the NRC inspector revealed that DR I-E-ININ-046R-DR01 and NCR 186-101745 have been written for this item. This item remains open pending disposition of the NCR.
3. CPRT ISAPs (Excluding ISAP VII.c) Guidelines for Administration of QC Inspector Tests (ISAP I.d.2)
During this report period, ISAP activities identified by NRC Reference 01.d.02.04 were inspected as follows:
Qualifications of Personnel (NRC Reference 01.d.02.04)
The NRC inspector reported the qualifications of the Special Evaluation Team in NRC Inspection Report 50-445/86-01; 50-446/86-0 ERC has utilized additional personnel for implementation of this ISAP. The qualifications of the additional personnel performing evaluations were inspected and were found to meet the requirements of the CPRT Program Plan and the specific requirements in Section 4.3 of this ISA This inspection was accomplished by review of the resumes and the objectivity questionnaires on file in the ERC personnel file No violations or deviations were identified during this inspectio Since the results report for this action plan has been issued and no additional personnel will be assigned, NRC inspection of this reference area is complet ._ - .-_- -- - - . - - . .-- . .- -
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l 14 i
i- Craft Personnel Training (ISAP I.d.3) [
During this report period, ISAP activities identified by NRC Reference 01.d.03.01 and the ISAP results report were inspected as
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follows:
I i Procedural Review (NRC Reference 01.d.03.01)
i
- In order to assess the current BAR and BSC craft training programs, i ERC reviewed procedures
- QCI-CPSES-013. Revision 4. " Indoctrination and Training of Personnel (BSC)"; and CP-CPM-2.2, Revision 4 j " Training of Personnel in Procedural Rcquirements (B&R)."
d The NRC inspector determined that the ERC reviews of these procedures '
- did not meet the intent of ISAP paragraph 4.1.2 in that the ERC
- review failed to identify a deficiency in the BSC training procedure.
i The NRC inspector evaluated the training procedures of B&R and BSC ;
- against the requirements of ANSI N45.2, 1971, and the guidelines on .
{ training given by Section D of the Gray Book, " Guidance on Quality !
'
- Assurance During Design and Procurement Phase of Nuclear Power Plants." The NRC inspector determined that the BSC training program i (as documented in Procedure QCI-CPSES-013, Revision 4) did not ,
provide, as necessary, the suitable maintenance of craft proficiency '
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as the craft fabrication / installation instructions were ciange ,
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- ERC's failure to comply with the requirements of ISAP paragraph 4. +
j isadeviation(445/8626-D-03;446/8622-D-01). ;
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No violations or deviations were noted for the B&R proc? dure review.
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ISAP I.d.3 Results Report f -During this report period, the CFRT issued the I.d.3 results repor ;
i i The NRC inspector determined, during review of the results report and i i the working files, that ERC had deviated from its Procedure CPP-024, l l " Issue Specific Action Plan Revisions" by implementing substantive I changes to the action plan prior to obtaining Senior Review Team .
l approval. For example, the Special Evaluation Team's effort was '
i transferred to the QA/QC Review Team and the issue coordinator was j changed (445/8626-D-04;446/8622-D-02). l
] Maintenance of Air Gap Between Concrete Structures (ISAP II.c) j
!
The following activities for ISAP II.c were reviewed by the NRC j j inspector during this report period:
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! Removal of Debris or Rotofoam (NRC Reference 02.c.02.00)
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During activities to break up and remove debris from the seismic air gap, parent concrete broke free from the safeguard Unit 2 wall i adjacent to the Unit 2 reactor building near 862' elevation. The i
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, e piece of dislodged concrete is approximately 6' in length, 1.5' in i width, and 4". deep. The damaged and dislodged concrete was
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discovered during inspection of the gap using,a remote video camera l following gap cleaning nearby. This condition was not apparent in L video recordings taken prior to the gap cleaning activities. The
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dislodged concrete was removed and the damaged safeguard Unit 2 wall is being assessed. NCR C-86-202323 dated September 19, 1986, l addressed this condition.
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The NRC inspector was notified of the damaged wall by project l personnel approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.after the discovery and examined the i dislodged concrete visually using remote video equipment. The NRC ,
inspector also examined video tapes taken prior to the gap cleaning l activities as well. as the dislodged concrete after renoval from the :
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gap. The NRC inspector will review the disposition of this NCR in a ;
l subsequentinspectionreportperiod(446/8622-0-03). l l NRC inspections' were not performed on other activities during this report period,
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o No violations or deviations were identified.
l Nonconformance and Corre..tive Action Systems (ISAP VII.a.2) i
)
During this report period NRC inspections were conducted for the ;
activities identified by NRC Reference 07.a.02.1 Review Implementation of 10 CFR 50.55(e) Reporting -
(NRC Reference 07.a.02.11)
ToassesstheERCreviewofTUGCo10CFRPart50.55(e) reporting,the NRC inspector evaluated the ERC checklists used for the review and i inspected a sample of the completed ERC reviews. The checklists were determined to properly reflect the requirements found in TUGCo .
. ProceduresCP-QP-16.1,NEOCS-1,andin10CFRPart50.55(e).
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ERC reviewed 61 TUGCo SDARs for compliance with these procedures and regulatory requirements. The NRC inspector inspected six of these SDARs to verify whether ERC had properly implemented its review. The 1 SDARs inspected were: CP-79-08. CP-80-10, CP-82-07 CP-83-03, i CP-84-08, and CP-86-0 The NRC inspection of these SDARs was performed utilizing the ERC t'
checklists. The results of the NRC inspections were then compared to ;
the ERC results. No differences from the ERC results were noted for the checklist attribute l
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_ _ _ _ _ _ _ _ . -_ _ _ . _ _ _ _ _ _ _ _ _ _ - _ _ _________ ___________________ _-_ . _ -- _ _ _
Based on the checklists reflecting the procedural and regulatory requirements and the results of the NRC inspection agreeing with the results of the ERC inspection, this item has been properly implemente During NRC review of the above SDARs, the NRC inspector reviewed documentation (not required to be reviewed in the ERC effort on SDARs) which identified that six installed Hilti Kwik bolts had been modified in an unauthorized manner. The length designator stamped on the end of five of these bolts had been modified such that the indicated lengths of these bolts were longer than the actual length The specific conditions of the bolts were: Five bolts with a length designator of 7" were actually 51" long; one bolt with a length designation of 7" was actually 11" long. These unauthorized modifications were found during a Hilti bolt reinspection program which was a part of SDAR CP-80-10. SDAR-CP-80-10 addressed modifications to Hilti Kwik bolts in which the length and the holding ability of the bolts were changed by craft cutting off the mandrel portion of a Hilti Kwik bolt and grinding a new mandrel on the shortened stud, or craft cutting off the bottom mandrel of a double-mandrelled Super Hilti Kwik bolt and installing the resultant shorter bol The Hilti bolt with modified length designations were not reported as part of SDAR CP-80-10. Documentation concerning whether these Hilti bolts were properly evaluated and whether the safety implications of the nonconformances (modifications to the length designators) were determined, could not be provided for NRC evaluation during this report period. This is an unresolved item (445/8626-U-05; 446/8622-U-04). Fuel Pool Liner Documentation (ISAP VII.a.8)
During this report period, the activities identified by NRC Reference 07.a.08.01, and the qualifications of ISAP personnel were inspected as follow Identify Inspection and Test Requirements from Document Reviews (NRC Reference 07.a 08.01)
The NRC inspector inspected the notes from the ERC review of documents related to fuel pool liner erection and inspectio These notes showed that ERC personnel had reviewed the engineering specification, the construction procedure, the nondestructive examination (NDE) procedures, applicable weld processes, and the inspection procedure. From their review ERC generated a data sheet listing the applicable inspection and test requirement To assess the implementation of the ERC document review, the NRC inspector compared ERC data sheets to the above fuel pool liner documentation and to ten completed construction travelers for the fuel pool line The NRC inspector found that the data sheet listed requirements for
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i l the areas of welding, inspection, NDE Nelson studs, and records.
l Items that required verification by ERC on the data sheet were the welders identification, the weld procedure used, weld filler material used, the QC inspectors identification QC hold / witness points, required civil data, and NDE procedures used. Other information such I as inspection report numbers, weld repair process sheets, NDE requests NDE reports, and NCR numbers were verified if applicabl The NRC inspector determined by reviewing the data sheet and comparing against the specifications and procedures that the inspection and test requirements were identified by ERC properly.
I No violations or deviations were identified.
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No further NRC inspection is planned for this reference are Qualification of Personnel The qualifications of personnel for this ISAP were first reported in NRC Inspection Report 50-445/86-01; 50-446/86-01. The qualifications of additional and replacement personnel were verified by the NRC inspector to meet the CPRT Program requirements. This was accomplished by review of the resumes and statements of objectivity maintained in the ERC personnel file. This action plan is nearly complete. No violations or deviations were identified and no further NRC inspection of this reference area is planne . ISAP VI Documentation Review of Cement Grout Status of CPRT Activity Documentation review of cement grout placements is complete with 121 packages reviewed. A total of 125 valid deviations have been identified and evaluated for safety significance. No safety-significant deviations were identifie Status of NRC Inspection Activity ,
The NRC inspector performed documentation reviews of the following five cement grout packages:
Verification Cement Grout Unit Package P_lacement R-S-GRTC-010 IRC-4591 1 R-S-GRTC-027 IRC-4870 1 R-S-GRTC-054 IR2-35005 2 R-S-GRTC-078 IRC-5542 Common R-S-GRTC-083 IRC-1324 1 No violations or deviations were identifie b. Documentation Review of Epoxy Grout Status of CPRT Activity Documentation review of epoxy grout placements is complete with 90 packages reviewed. Thirty-two valid deviations have been identified and evaluated for safety significance. No safety-significant deviatiori, were identifie Status of NRC Inspection Activity The NRC inspector performed documentation reviews of the following five epoxy grout packages:
Verification Epoxy Grout Unit Package Placement R-S-GRTE-003 IRC-7333 Comon R-S-GRTE-011 IRC-7149 Comon R-S-GRTE-029 IRC-6322 1 R-S-GRTE-043 IRC-8683 Comon R-S-GRTE-067 IRC-3983 Coman No violations or deviations were identified, c. Reinspection of Concrete Placement Status of CPRT Activity Reinspection and documentation review of concrete placement packages is complete. Forty-three valid deviations for reinspection and 100 valid deviation, for documentation review have been issued. A total
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of 133 deviations have been evaluated for safety significanc No safety-significant deviations have been identified to dat Status of NRC Inspection Activity
! The NRC inspector performed documentation reviews of the following five concrete placement packages:
Verification Concrete Placenent Unit Package l R-S-CONC-015 IRCN-CPC-002-4790-040 Comon R-5-CONC-023 IRCN-CPC-002 M852-082 Comon R-S-CONC-040 IRCN-CPC-105-6831-014 I l R-S-CONC-087 IRCN-CPC-101-5805-026 1 R-S-CONC-103 IRCN-CPC-002-6873-003 Comon No violations or deviations were identifie _ -. _-_ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ - - _ - - _ ___ - _
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I
, d. _!_nstrument Pipe / Tube Supports
_
j Status of CPRT Activity
ERC has completed all reinspections of instrument pipe / tube supports
from the planned random and engineered sample of 129. Five hundred ,
and three valid DRs have been identified and issued. The sample size :
- was increated from a previously reported figure of 111. The purpose
<
for tha increase was to ensure that the proper number of each
- attribute had been reinspecte :
- ERC has completed all documentation reviews of instrument pipe / tube supports from the sample size of 111. Sixty-six valid DRs have been
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identified and issued.
Status of NRC Inspection Activity l
} (1) To date, the NRC inspector has witnessed four reinspection I performed eight hardware inspections and conducted five i documentation review (2) The following hardware inspection was perfor1ned by the NRC l inspector during this inspection period:
Verification Instrument Tag System * Unit j Package l I-INSP-012 1-FT-4558 CC 1
- CC - Component Cooling Water System j No violations or deviations were identifie j (3) The following five documentation reviews were performed by the j NRC inspector during this inspection period: j l
! Verification Instrument Tag System * Unit l j Package j R-S-INSP-010 1-PT-4775-1 CT 1 !
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R-S-INSP-012 1-FT-4558 CC 1 !
R-S-INSP-033 1-LT-462 RC 1 !
R-5-INSP-107 1-PT-2326-C MS 1
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- R-S-INSP-126 1-PT-2328-A MS 1 l
- i i * CT - Contairment Spray System ;
{ CC - Component Cooling Water System l RC - Reactor Coolant System
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j
- MS - Main Steam System
l No violations or deviations were identified.
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e. Large Bare Supports - Rigid Status of CPRT Activity ERC has completed 134 reinspections and 89 documentation reviews of the planned random and engineered sample of large bore supports -
rigid. One hundred sixty-nine valid deviations have been issued by ER Status of NRC Inspection Activity (1) To date, the NRC inspector has witnessed five reinspections and performed six hardware inspection (2) The NRC inspector performed the following five documentation reviews in this period:
Verification Pipe Support System * Unit .
Package R-S-LBSR-005 CT-1-054-429-C42R CT 1 R-S-LBSR-011 DD-1-012-709-A33R DD 1 R-S-LBSR-020 SI-1-106-014-C52R SI 1 R-S-LBSR-021 SW-1-173-710-Y33R SW 1 R-S-LBSR-064 CC-1-134-704-E63R CC 1
- CT - Containment Spray DD - Demineralized and Reactor Makeup Water SI - Safety Injection SW - Service Water CC - Component Cooling No violations or deviations were identified.
f. Large Bore Supports - Nonrigid Status of CPRT Activity ERC has completed 92 reinspections and 82 documentation reviews of ,
the planned randem and engineered sample of large bore supports -
nonrigid. Two hundred fourteen valid deviations have been issued by ER Status of NRC Inspection Activity (1) To date, the NRC inspector has Witnessed six reinspections and performed five hardware inspection (2) The NRC inspector performed the following five documentation reviews in this inspection period:
l L
l
i Verification Pipe Support System * Unit Package R-S-LBSN-008 CC-1-008-026-A335 CC 1 R-S-LBSN-015 RC-1-164-003-C81K RC 1 R-S-LBSN-020 CS-1-001-039-C42K CS 1 R-S-LBSN-034 MS-1-074-004-CE2K MS 1 R-S-LBSN-061 CC-1-323-724-A43K CC 1
- CC - Component Cooling RC - Reactor Coolant CS - Chemical and Volume Control MS - Main Steam No violations or deviations were identified, g. Pipe Whip Restraints l
Status of CPRT Activity ERC has completed all reinspections of pipe whip restraints from the planned random and engineered sample of 143. Two hundred and seventy-seven valid DRs have been identified and issued. The sample size was increased from a previously reaorted figure of 110. The purpose of the increase was to ensure t1at the proper number of each attribute had been reinspecte ERCcompletedalldocumentreviewsofpipewhiprestrair$t: from the sample size of 13 Fifty-seven valid DRs have been identified and issue Status of NRC Inspection Activity (1) To date, the NRC inspector has witnessed five reinspections, performed six hardware inspections, and conducted five documentation reviews. The following four hardware inspections were performed by the NRC inspector during this inspection period:
Verification Support Identification System * Unit Package I-S-PWRE-062 CS-1-087-912-A47W CS 1 I-S-PWRE-521 FW-2-017-904-C57W FW 2 1-5-PWRE-527 FW-2-019-911-C57W FW 2 1-S-PWRE-541 FW-2-020-907-C47W FW 2
- CS - Chemical Volun,e and Control System FW - Steam Generator Feedwater System No violations or deviations were identifie .
(2) The following five document reviews were perforwed by the NRC inspector during this inspection period:
Verification Support Identification System * Unit Package R-S-PWRE-057 FW-1-018-906-C67W FW 1 R-S-PWRE-062 CS-1-087-912-A47W CS 1 R-S-PWRE-521 FW-2-017-904-C57W FW 2 R-S-PWRE-527 FW-2-019-911-C57W FW 2 R-S-PWRE-541 FW-2-020-907-C47W FW 2
- FW - Steam Generator Feedwater System CS - Chemical Volume and Control System No violations or deviations were identified.
h. Tubing Welds / Materials Status of CPRT Activity ERC has completed all reinspections and documentation reviews of tubing welds / materials from the planned random and engineered sample of 100 and 98, respectively. Twenty valid deviations have been issued by ER Status of NRC Inspection Activity (1) To date, the NRC inspector has witnessed three reinspections and performed four hardware inspection (2) The NRC inspector performed the following five documentation reviews in this inspection period:
Verification Drawing System * Unit Package R-M-TUWM-002 FSI-1-500 MS 1 R-M-TUWM-008 FSI-1-601-01 RC 1 R-M-TUWM-024 FSI-00043-17 NI 1 R-M-TUWM-034 FSI-00043-56 NI 1 R-M-TUWM-036 FSI-00043-54 NI 1
- MS - Main Steam RC - Reactor Coolant NI - Nuclear Instrumentation No violations or deviations were identifie l l
1. Mechanical Equipment Installation Status of CPRT Activity ERC has completed all 170 reinspections and 84 documentation reviews of the planned random and engineered sample of mechanical equipment installations. Two hundred and twenty-one valid deviations have been issued by ER Status of NRC Inspection Activity (1) To date, the NRC inspector has performed six hardware inspection (2) The NRC inspector performed the following five documentation reviews in this inspection period:
Verification Equipment Tag System * Unit Package R-M-MEIN-009 CP1-AFAPMD-01 AF 1 R-M-MEIN-019 CPI-CCAHHX-02 CC 1 R-M-MEIN-035 CP1-CHCICE-06 CH 1 R-M-MEIN-107 TBX-CSAPPD-01 CS 1 R-M-MEIN-263 CP1-VAAUSE-11 VA 1
- CC - Component Cooling CH - Ventilated Chilled Water CS - Chemical and Volume Control VA - Heating, Ventilation, and Air Conditioning No violations or deviations were identifie j. Reinspection of HVAC Ducts and Plenums Status of CPRT Activity ERC has completed all 110 reinspections of HVAC ducts and plenues in the random and engineered samples. A total of 176 valid deviations were identified by ER Status of NRC Inspection Activity The NRC inspector previously witnessed eight ERC reinspections and performed hardware inspections and documentation reviews on the following three verification packages during this report period:
Verification Duct Unit Package
! I-M-DUPL-045 EMD-1-8 Common I-M-DUPL-046 RMD-1-37 Common I-M-DUPL-051 EMD-1-6 Common
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Paragraph 4.3.3 of ISAP VII.c. states, in part. "For each population, attributes which have safety significance will be determined . . . .
Justification for not including attributes in the reinspection or I documentation review checklists which have been identified as l nonsafety-significant will be documented and retained as records in the ISAP file. For each safety-significant attribute identified, detailed instructions for the verification of the attribute, including definitive accept / reject criteria, will be established . . . ."
During review of BSC's HVAC duct and plenum procedures, the NRC inspector noted certain work activities and attributes which were not identified by ERC engineering during development of the QIs (QI-039
- and -040) associated with the reinspection and documentation review l of HVAC ducts and plenums and their applicable inspection and documentation review checklists. Work activities and attributes not addressed consisted of such items as:
l (1) Welded nuts on the interior of seismic volume extractors.
l (2) S and J crimps used for attaching various accessories such as grills, registers, and associated sealant materia The failure to identify these activities / attributes precluded determination of safety significance and the failure to provide justification for not including nonsafety-significant attributes in the applicable reinspection or documentation review checklists is a deviation (445/8626-D-06). No violations or deviations were i identified with respect to performance of the inspections and l documentation review k. HVAC Duct Supports Status of CPRT Activi ERC has completed all 183 reinspections of the HVAC Duct Support random and engineered sample. A total of 371 valid deviations were identified by ER Status of NRC Inspection Activity (1) The NRC inspector has previously witnessed seven ERC reinspections and separately inspected six verification package _
(2) The NRC inspector performed inspections and documentation reviews on the following six verification packages during this report period:
Verification Drawing Unit Location *
Package I-S-HVDS-003 CB-830-IN-1X 1 CB I-S-HVDS-023 CB-830-IN-1R 1 CB I-S-HVDS-046 CB-830-IN-1AL. 1 CB I-S-HVDS-117 CB-830-IN-1AQ 1 CB I-S-HVDS-118 CB-830-IN-C5 1 CB I-S-HVDS-060 SG-790-IH-28 1 SG
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- CB - Control building-SG - Safeguard building The following information was inadvertently omitted from NRC Inspection Report 50-445/8607; 50-446/8605. BSC provided ERC with a population list which was to have contained all final QC inspected and accepted Unit 2 HVAC duct supports. A population list was also presented to the NRC inspector for use in selecting inspection samples. Subsequent to selecting 15 supports for inspection, the NRC inspector requested BSC to provide the inspection records for those supports. BSC informed the NRC inspector that these supports had not been final QC inspected and they should not have been listed. This raised a question with respect to the validity of the list presented to ERC.
Follow-up of this information, in conjunction with the six inspections and documentation review activity, revealed the following conditions. Section 2.0 in Revision 1 of QI-035 and QI-036 requires that reinspection and documentation review be performed on only those duct supports which have been installed and final QC accepted by BSC.
Section 5.0 in QI-036 requires the initiation of a DR for any applicable HVAC duct / support attribute identified as not having been inspected by BSC.
In deviation from the above, the following conditions were identified:
(1) The documentation review verification packages issued to ERC inspectors for Unit I and common HVAC duct supports contained BSC detail drawings which were supposed to represent the installed and final QC accepted supports, and the applicable BSC inspection reports.
(2) The NRC inspector identified that the BSC inspection reports were dated as many as five years prior to the initial issue of the detail drawing (3) There was no evidence of inspections performed by BSC QC to verify the duct support configuration to the detail drawin (4) It was further determined that BSC QC used typical drawings for their . inspections. These drawings can be dissimilar to the detail drawings provided to ERC. As a result, the ability of ERC to identify attributes not inspected by BSC was affected; thus initiation of all required DRs was precluded (445/8626-D-07).
During review of BSC inspection records, the NRC inspector recorded the names of eight BSC welders in order to examine their performance qualification records. Review of BSC's procedures applicable to welders' qualifications (DFP-TUSI-001, Revision 8, and DFP-TUSI-003, Revision 7) identified that all welders performing work on duct supports and seismic support systems shall be qualified in accordance with Section IX of the ASME Cod Paragraph QW-301.2 in Section IX of the 1977, 1980, and 1983 editions of the ASME Code states, in part, "Each manufacturer or contractor shall qualify each welder or welding operator for each welding process to be used in production welding . . . ." QW-301.4 states, in part, "Information regarding the essential variables and the test results obtained by each welder . . . shall be recorded on a Record of Performance Qualification Tests."
The NRC inspector identified a violation with respect to position limitations and qualified material thickness ranges, in that BSC's welder performance qualification records dated May 1979 June 1981, and March 1983, certified their welders as being qualified in more positions and material thickness ranges than allowed by the reported number of test results (445/8626-V-08; 446/8622-V-05).
5. Assessment of Allegations A-50: Civil Engineering Concern Related to Safety Related Electrical Systems An alleger expressed several concerns to the NRC involving site activities and observations in the civil / structural area relative to safety-related electrical systems. The following paragraphs characterize these allegations and provide the NRC's assessments and conclusion (1) It was alleged that several cases existed at Comanche Peak in which a common hanger or support was used for redundant trains of safety-related electrical systems, while the Final Safety Analysis Report (FSAR) requires that such trains be kept separate. It was also alleged that another individual had
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identified the use of common hangers or supports for redundant
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safety-related Trains A and B to the Comanche Peak Safeteam as a
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.s 27-concern, but no response was given to the individual regarding the resolution of the concern. The general location where
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comon hangers or supports were used was identified as being in
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the northeast corner of the control roo In assessing the described concerns, the NRC inspector:
(1) determined FSAR comitments regarding the support and separation of redundant Class IE (safety-related) electrical systems; (2) verified TUGCo's method of supporting and separating Trafns A and B to conform to FSAR comitments; and (3) examined hos the common hanger or support concern reported to the Safeteam was resolved.
- Sections 3.10B.3, 7.0, and 8.0 of the FSAR prescribe the requirements for the independence of redundant Class IE system TUGCo has comitted to using seismic Category I hangers or supports for Trains A and B.- The FSAR does not prohibit Trains A and B from being installed on a comon hanger or
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support, provided train sepcration criteria are not violate There hangers and support's were designed such that if the
. safe-shutdown earthqucke occurs, electrical power,
' instrumentation, and control wiring in the cable trays will
. remain functional for Trains; A and B. These hangers and supports are attached to walls and floors of seismically designed buildings. Section 8.0 of the FSAR requires that Class 1E cables be routed in such a manner that any single failure in one tran?'does not cause a failure in another train. Preserystion of the independence of redundant electrical circuits is accomplished by raceway separation criteria. For example, in the cable spreading area and control room, a minimum separation of one foot horizontal and three feet vertical is required to be maintained between redundant raceways (cable trays and conduits).
Separation of redundant cable trays was inspected by the NRC inspector in the control room and cable spreading area for compliance to FSAR separation requirements. In examining the control room's northeast corner (identified by the alleger) for comon supports of Trains A and B, the NRC inspector found that no redundant trains in cable trays or conduits were installed in that area of the control room. Train A and B cables were found to be routed below the control room in the cable spread area prior to entering the control room. 'In the cable spread area, Train A and B cable trays were found to be supported on a comon support; however, tray separation was in accordance with prescribed requirement A common support location area for Train A and B cable trays was selected to verify that required seismic analysis had been performed. The location for Train A was spread room location K1 (elevation 814' 8"), and Train B was location P1
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(elevation 818' 2"). NRC review of the K1 and P1 support beam documentation, including calculations, confirmed that seismic analyses were performed as required and met design requirement '
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The NRC inspector reviewed the Safeteam's assessment of.the concern that Train A and B conduits having a common support could result in a compromise of safe plant shutdown capabilit Based on the review of the FSAR, site procedures, examination of installed hardware, and interviews with site personnel, the Safeteam determined that common support for Trains A and B was permissible; however, the Safeteam was unable to report its findings to the concerned individual, who chose to remain anonymou ,
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In sumary, the portion of the allegation that redundant safety-related electrical systems (Trains A and B) were supported by comon hangers or supports was substantiated; however, trains were kept separate and a violation of FSAR requirements did not occur. Review of FSAR comitments disclosed common support of redundant trains is permissible provided train separation is such that any single failure in one train does not cause a failure in another train. Based on NRC field inspections of cable tray separation and the verification of comon support
, seismic analysis, it was determined that the sampled redundant train installations conformed to FSAR comitment The issue that the Safeteam did not provide feed back to the individual who expressed a concern about comon support of Trains A and B was substantiated; however, the reason feedback was not given was that the individual chose to remain anonymou (2) It was alleged that safety-related cable trays were overloaded, and added fire wrap or thermolag contributed to further overloading. The cable spread room was identified as the location where this overloading was occurrin In assessing this allegation the NRC inspector: (1) determined the criteria used for cable tray weight loading; (2) evaluated l the method used by TUGCo to control tray weight; and
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(3) inspected the cable spread room for potential overloadin '
Table 3.9-1 of Gibbs & Hill (G&H) Specification 2323-ES-19,
- dated November 22, 1976, prescribes the design load2 for cable
, tray weight of 35 pounds (1bs.) per square foot (ft ).
!_ Section 8.3.3.1 by the FSAR establishes cable tray fill criteria to accomodate this design load as follows:
"
. . . generally limit the sumation of the cross-sectional areas of control and power cables to a maximum of 40 and 30 percent, respectively, of the usable cross-section [ area] ;
- of the tray. However, percentages may be exceeded provided
! the following conditions are satisfied:
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1) Cables do not extend above the side rails of the cable tray.
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2) For power cables - thermal rating of the cable is not exceeded.
3) Cable tray support design is adequate."
Based on interviews with site electrical and civil personnel, two types of overloading of cable trays have been considered:
(1)thethermalimpactofexceedingcabletraypercentfill;and (2) exceeding the design cable tray load considering the combined weights of the tray, cables, and fire barrier materia The FSAR 40% fill criteria limit for control cables was established using the National Electric Code fill requirements from Article 318-8(d), " Cable Tray." The FSAR 30% fill criteria limit on power cables was based on percent fill calculations performed by G& In determining the thermal-impact on percent tray fill for power cable such factors as ampacity, cable size, and ambient temperature were considered. TUGCo has committed t6 use Insulated Power Cable Engineers Association - National
>
Electric Manufactures Association standards publication,
! IPCEA P-54-440, "Ampacities, Cables in Open-Top Cable Trays" for determining heat generation rates for power cable and determining j necessary derating factors. Using IPCEA P-54-440, an acceptable percent tray fill, based on thermal consideration, was calculated to be 39.26%. The G8H 30% fill criteria limit for power cables was to provide additional margi ,
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Since the foregoing calculations for determining thermal loads were based on open cable trays, TUGCo performed tests to
!' ~ determine the additional thermal effect when fire barrier material (thermolag or fire blanket) was used to enclose the cable tra The NRC inspector reviewed these test reports and noted the
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following conditions: (1) thermolag testing was conducted using a dry film thickness of .500"; however, the thermolag installation Procedure CP-CPM-10.3, Revision 9, permits a film j thickness of .500" with a tolerance of
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permissible thickness of .750"; and (2)plus 50% fortesting qualification a maximum
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for both thermolag and the fire blanket material was performed at an ambient temperature of 40"C; however, the G&H cable derating calculations (G&H Procedure E-2323-VII, " Cable Sizing Calculations") were based on a 50 C ambient temperature. NRC l inspector's review of additional infonnation, some of which was not available until shortly after the end of this report period,
- disclosed
- (1) the fire protection rating of the thermolag was based on a minimum thickness of 0.500" and the cable derating calculations were based on a maximum thickness of 0.750", and
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(2) the acceptance criteria for electrical cable derating were-based on a maximum conductor temperature of 90 C regardless of the initial ambient temperature. Therefore, the NRC inspector found the thermal effects on electrical cable from the addition
'
of fire barrier material to be acceptable.-
Control of thermal and weight loads by percent cable tray fill is governed by a computerizad report developed by G8H, 2323-El-1700, " Electrical Raceway Schedule." This computer program performs several functions, including selecting the shortest path for cable routing between two points, and monitoring cable tray fill to assure fill does not exceed design criteria limits. Should tray fill approach maximum design
,
limits, the computer locks out the shortest path and selects the next available shortest route between two points. A pull card is generated then for the craftsmen to install the cable. The
, pull card contains beginning and ending points of the cable route, type of cable to be pulled, length of run, number of cables, drawing reference number, and other pertinent
- information to pull the cable. QC inspectors witness and
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inspect pull activity to verify work performed conforms to the applicable installation procedures and pull card requirement Procedure TNE-DC-10, Revisions 1 and 2, " Design Verification of Computer Programs," requires the design verification of computer programs which are originated, developed, modified and/or used !
> by TNE for computational purposes to determine the design, installation, performance, or operation of Class I or II, equipment, systems or structures at CPSES. The purpose of the design verification of Electrical Raceway Schedule Program (s)
,
was to demonstrate the validity of obtained results in conforming to established design criteria. The NRC inspector
- reviewed the computer program verification documentation that !
confirmed G&H had design verified the original program and
, subsequent modifications to the progra To determine if cable tray overfilling was occurring in the spread room as alleged, the NRC inspector reviewed a sample of 19 Train A and B cable tray segments. The location of these cable tray segments was between columns B and D and column lines 2.9 and 5, which included the area identified by the alleger. Inspection included the NRC inspector's physical examination of the tray fill, verifying the control being provided by the raceway schedule computer program, and reviewing the documented tray weight for compliance with the design basis
, of 35 lbs./ft2 The types of cables found in this area of the spread room were control and instrumentation and no fire barrier material was use .
.
, . _ . . . _ . . . . . . . . . _ , . - , . _ . _ , _ , , . . . - , - , . . , . . - - - _ . _ _ , _ _ _ _ _ , _ - . , . , ,,, . . _ _ , - , , . . . , , - - . . , . , ,_,-----,-_w..,. -.y --- . . . . - _ _ -
a
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(a) Overloading by Exceeding Percent Fill The 19 segments examined in the spread room were reviewed on the Electrical Raceway Schedule for compliance to the 40% area fill criteria. Several. segments were found to be greater than 40% (by 2% to 9%), but no cables were observed to be above the tray side rails, which is prohibited by FSAR requirements. Those segments exceeding 40% were found to be locked out by the computer for further cable routin An additional sample of documentation for approximately 740 Unit I control and instrumentation. cable tray segments were
.
reviewed to identify segments that exceeded the 40% fill i
criteria. Segments which were approaching 40% were noted with a warning message in the raceway schedule and segments
, exceeding 40% were locked out to prevent further use. From.
2 this additional ssmple, several tray segment fill limits were exceeded by 2% to 7%. In every case where the fill criteria was exceeded, additional analyses had been performed, either confirming the weight limit had not been
, exceeded, or the support system was modified to accommodate the additional weight loa A further documentation sample of approximately 700 Unit 1
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power cable tray segments was reviewed to identify segments that may exceed the 30% fill criteria. Only one instance of overfilling was identified which was 32%. The NRC inspector's physical examination of this tray segment disclosed the tray was not covered by fire barrier material. -Based on the calculated power cable fill limit (normal) of 39.26% and verifying the 35 lbs/ft2 was not violated, this instance of exceeding 30% fill did not
violate FSAR cable tray fill requirement (b) Overloading Cable Trays from Use of Thermolag
, The NRC inspector reviewed TNE Procedure CP-El-4.0-49, Revision 1, " Evaluation of Thermolag (TSI) Fire Barrier on Class 1 Electrical Raceways," which established methods for evaluation of the structural adequacy for the Class IE i electrical raceways (cable-trays and conduits) with the addition of fire barrier material. The evaluation
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considered the weight of cables plus the weight of the tray
.
with the thermolag, which collectively was not to exceed l the design load of 35 lbs/fte, The NRC inspector reviewed the evaluations of 149 cable
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trays with thermolag installed in the auxiliary, electrical control, and safeguards buildings. Of the 149 evaluations, 18 cable tray weights exceeded the design load limit of 35 lbs/fte and required additional analysis. The NRC l
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inspector reviewed in detail 9 of these 18 analyses and 6 were found to contain either errors or raise questions concerning the methodology used in performing the analyse Since TUGCo has retained two outside contractors (EBASCO and IMPELL) to perform a design verification of all Unit 1 Unit 2, and common cable tray supports, the NRC inspector
obtained and reviewed for adequacy the new analysis of one of the overloaded cable trays in question. TUGCo has a? designated these analyses as the analyses of record. The NRC inspector's evaluation found that these analyses are 4 based completely on the as-built configuration of the supports and trays. The NRC inspection of the analyses for
"
three of the supports, associated with one of these trays, did not identify any errors or questions in methodology.
i (c) Possible Overloading from the Use of Fire Blankets TUGCo has installed separation barrier and radiant energy shield material (thermal wrap) on Unit 1 cable raceways (cable trays and conduit). The original design
- verification of cable raceways did not consider the additional weight of thennal wrap on raceway supports in
,
design weight limit evaluations. Upon recognizing that thermal wrap had not been considered for overloading, TUGCo ve'rbally reported this issue to the NRC on August 27, 1985, as a potentially reportable item under the provisions of
. 10 CFR 50.55(e). The possible overloading by use of fire
'
blankets is being evaluated under the CPRT Program Plan, DSAP VIII, " Civil / Structural Discipline Specific Action Plan."
! In conclusion, the overloading of cable trays with respect to cable fill was not substantiated. The overloading of cable trays by the additional weight of fire barrier material did occur, but in every-case reviewed, the required reanalysis was
,
performed and support modifications were made if require In
! addition, TUGCo has initiated a reverification of design for all i Unit 1 Unit 2, and common electrical supports using, as a minimum, the actual cable tray fill and fire protection material
'
l weights (thermolag and fire blanket). The reverification of design, which will become the design and analysis of record, is
- _ being accomplished under the CPRT Civil / Structural Design l- Specific Action Plan (DSAP) VIII, Attachment 2, "CPSES Project l
Activities for Cable Tray Supports."
' (3) Procedure Control and Training
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The alleger was concerned that the field engineers' procedures l manuals were not being properly maintained. For example, j manuals were missing procedures or procedures were added without
,
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,. removal of the superseded procedure. According to the alleger, during February and March 1986, a problem with manual control was identified which resulted in manuals being recalled (removed from the manual holders). The alleger believed the lack of manual control was an indication of falsification of records because field engineers were required to sign a document
, attesting that the engineer had received, read, and understood the updated procedures and had removed the old procedure from the assigned manual. In addition, the alleger believed the official training given while at Comanche Peak was only
- superficia Based on information provided by the alleger and interviews with site personnel, the NRC inspector determined that the site procedures manual referred to by the alleger was the ThE Procedures Manual. The field engineers mentioned were TNE civil engineers from the Unit 1 Task Force engineering group which functioned from January 1984 through April 1986. The Unit 1 Task Force was dissolved in April-May 198 The NRC's approach to assessing this allegation was (a) determine how TNE controlled the procedures manuals issued to TNE personnel, and (b) evaluate TNE's personnel
. indoctrination / training program.
-
(a) THE Procedural Control Procedural control is governed by TNE Procedure TNE-AD-3,
" Preparation of Procedures and Instructions." For this assessment, Revision 7 was used to determine compliance to
, procedural requirements. Revision 7 was in effect from i
December 1985 through August 1986. The time period of the
! allegation was February and March 1986. THE-AD-3 required l that control of procedures was to be maintained by assigning a unique manual number to each control copy
- recipient. The use of a table of contents reflecting the current revision'of each procedure in the manual was an aid in assuring manuals were current. Each complete manual or single procedure issued for insertion into manuals was transmitted to controlled copy holders via a memorandu All issues were accompanied by a revised table of contents and each assigned manual holder was required to acknowledge this receipt by signing an acknowledgement form attached to the transmittal memorandum and returning the acknowledgement form to TNE files. If the acknowledgement form was not received within 30 days, the manual was subject to being decontrolled. TNE files maintained a list of controlled copy manual holders which varied from 320 to 350.
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No manuals were found to be decontrolled during January through April 1986 because of either failure to keep
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manuals current, or because TNE files had received late acknowledgement forms. During September 1986, two manuals were decontrolled by TNE files as.a result of manual holders not returning acknowledgements per TNE-AD-3
- requirements, well after the time period of this allegation.
i To determine if transmittal memorandums were signed and returned in accordance with TNE-AD-3, the returned acknowledgement forms were reviewed by the NRC inspector
, for the months of January, February, March, and April 1986.
! All civil engineering manual holder acknowledgements were found to have been returned within the prescribed time limit of 30 days, or when the 30 day limitation was exceeded, upon notification, the manual holder returned
- their acknowledgement forms.
.
On February 12-17, 1986, and March 3-11, 1986, TNE 2 conducted a self initiated internal surveillance of l- Procedure TNE-AD-3, Revision The purpose of the
); surveillance was to verify that controlled manuals contained the current table of contents, the _ proper procedures, and that the acknowledgement forms from the
- controlled manual holders had been submitted. Observations from this surveillance of 35 manuals were: (1) manuals were not being maintained current (5 and 6 revisions behind thecurrentissue);(2)deletedorsu were found to be in some manuals; (3)perseded procedures procedures were missing from some manuals; and (4) the return of acknowledgement forms exceeded the 30 day requirement in some case During the performance of the THE surveillance, actions were taken to correct the observed problems which included bringing the 35 manuals inspected into conformance with TNE-AD-3. A copy of the surveillance report (TNE-86-01)
was distributed to TNE managers recommending manual holders
- update manuals as new or revised procedures were receive On March 24-27, 1986, TUGCo Dallas QA performed a scheduled audit (TCP-86-10) of TNE's records and document control function. Part of the audit focused on THE procedural control. Eighteen TNE procedure manuals ,
were audited against the latest revision of the table of .
contents. The results of the audit were that 10 of the 18 manuals were not current with the table of content l Deficiencies observed included: (1) procedures missing, i (2)revisedproceduresnotinserted,and(3) deleted procedures not removed, r
i I
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l TNE's corrective action for this audit was to:-(1) update and verify the completeness of the controlled manuals listed as deficient in TCP-86-10; (2) review all remaining controlled manuals for completeness to the latest table of contents; and (3) issue a memorandum to all manual holders to remind them of their responsibility to maintain manuals to the latest table of contents and that manual completeness would be verified during future surveillance After bringing all manuals up-to-date TNE performed a
~ surveillance of a sample of 15 manuals on July 17 and 18,
, 1986. All manuals were found to conform to the a
requirements of TNE-AD-3 requirements. TUGCo's QA audit group, during a followup audit, verified TNE's corrective action was satisfactorily implemented and completed as j ,
scheduled. The audit finding was i:losed on July 21, 198 .
TNE transferred responsibility of manual distribution and maintenance to the site document control program (DCP-3,
"CPSES Document Control Program") effective October 13, 1986. The decision was based on site document control
, having a more effective mechanism to issue and maintain l procedure manuals than TNE. Under DCP-3, the Document
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Control Center (DDC) satellite personnel will physically insert in each controlled manual any updated or new TNE
. procedures and delete any old procedure With respect to recall of procedure manuals because of problems identified with manual control, the NRC inspector was unable to substantiate such an event. Based on site personnel interviews and the review of audits, surveillances, corrective actions, and TNE file records, no
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manuals were recalled for problems with manual control i- during the time frame of this allegation. The number of
!
manual holders was reduced from approximately 310 to 253 during April 1986. The cause for the reduction, according to TNE, was the elimination of the Unit 1 Task Force and the
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restriction by TNE management of manual holders to leads and higher supervision. The alleger may have viewed this
,
reduction in the number of manual holders in April 1986 as l a recall of manuals because of problems identified with TNE
- manuals during February and March 1986; however, this does
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not appear to be the cas The concern regarding the lack of THE procedure manual l-control was evidence that amounted to falsification i of records, was assessed. The. alleger stated that l- acknowledgement form TNE-AD-2.2 (from Procedure TNE-AD-2,
!- " Personnel Indoctrination and Training") signed by the manual holder attested to the removal of superseded or deleted procedures and that the manual holder had read and
,
understood the changes. The alleger assumed that if such l
l
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. was the case, any manuals found in noncompliance would amount to falsification of form TNE-AD-2.2 by the respective manual holde Form THE-AD-2.2 contained the following statement, "I acknowledge having received, read, and understood . . . the
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Procedures / Instructions transmitted per this Memo." This form then was signed, dated, and returned to THE file This fonn 'had no statement concerning the removal of the
- old procedure or the insertion of the new procedure.
- Accordingly, the' problems associated with manual control were not evidence of falsification of records with respect to signing the acknowledgement form, nor was there any other evidence that these forms were' falsifie (b)- TNE Training Program Regarding the concern that official training given to TNE i civil field engineering personnel was superficial. the NRC
'
, inspector reviewed TNE's personnel training / indoctrination program as described in Procedure TNE-AD-2, Revision Indoctrination / training consists'of a combination of required reading, classroom instruction, and as required L on-the-job training relative to experience in the practical implementation of established procedures. The standard reading list for all THE personnel included 10 CFR Part 50,
,
Appendix B; TUGCo/TUSI CPSES QA Plan; TNE Procedures
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Manual; and selected sections of the FSAR. On a case-by-case basis, each individual's supervisor specifies required reading in addition to the standard list.
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Completed initial indoctrination is documented on fonn TNE-AD-2.1, "TUGCo Nuclear Engineering Indoctrination
- Program." Deviation from the standard reading list is required to be justified and documente Fourteen civil field engineering personnel
' indoctrination / training files were reviewed. The NRC inspector found all initial indoctrination was completed
' and maintenance of proficiency in procedures was
' accomplished by completing reading assignments. Since TNE is an engineering organization, training is primarily accomplished via reading assignments. In reviewing
'
training sessions conducted during January, February, March, and April 1986 (not related to civil field
,
engineering), the NRC inspector noted that the following types of classroom training sessions were also given.
n Three were for procedural changes and two for specific i subject matter; i.e., containment analysis and power
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operated control valves. Outlines of subject matter
- presented and attendance records were documented in the
! files. Some sessions exceeded three hours in lengt ,
i
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~37
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Based on review of personnel indoctrination / training
-
records and classroom training files, the NRC inspector determined THE had established a training program that was .
more than superficial and in accordance with established '
procedure In conclusion, the allegation that controlled TNE procedures manuals were not properly maintained was substantiated. Both TNE internal surveillance personnel and TUGCo QA auditors identified problems with TNE manual control as alleged; however, corrective action was taken. Responsibility for procedure distribution and maintenance has been transferred to DCC who has a suitable mechanism to assure manual control. With respect to the allegations that: (1) manuals were recalled (withdrawn from manual holders) because of problems identified with manual control, (2) completion of the procedures receipt acknowledgement form when procedures were not inserted / deleted from the manuals was falsification of records, and (3) official training received by TNE personnel was superficial; these allegations were not substantiate (4) " Problem Log" Destroyed It was alleged that a " problem log" which was established to be used by field engineering to record safety-related concerns between July 1985 through mid-May 1986 was discarded before identified problems were evaluated for impact on hardwar The NRC's approach to assessing this allegation was to first determine if such a problem log existed. If such a log did exist, determine the function and purpose of the log and the types of problems that were recorded. Finally, if the log was determined to be destroyed, ascertain if problems were otherwise identified and suitably resolve From information provided by the alleger and interviews with three site personnel, the NRC inspector determined the area of concern was the Unit 1 Task Force, civil conduit walkdown field engineers. The function of the conduit field engineers was to create as-built isometric drawings (IS0s) of Unit 2 safety-related conduit systems installed in Unit I and common areas. The IS0s were drawn based on field verification of the as-built condition of installed conduit. These IS0s typically depicted conduit origin and destination. points, lengths and configurations,supportdetails(typesandlocation),and miscellaneous electrical fittings. The field verified conduits were of completed installations which had been accepted by QC in accordance with Procedure 2323-S-0910. " Conduit Routing and Support Package for Unit 1," for design and acceptance criteri The problem log did exist and was initiated by the field civil engineering supervisor to record any observations that were
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outside of the scope of the walkdown effort that could be potentially nonconforming conditions. The intention was to turn the log over to QC at the end of the walkdown activities, to determine if the identified out-of-scope observations were actually nonconforming conditions. If so, QC would report such conditions on an NCR for appropriate dispositionin Entries to the problem log would have covered the time interval of August 1985 through April 1986, as actual walkdowns occurred
. in August, September, and October 1985 and March through April 1986. In April 1986, the walkdown program by the Unit 1 Task Force was discontinued. This activity was started again under a new program conducted by EBASCO and described in the CPRT civil / structural design specific action plan DSAP VIII, Attachment 3 "CPSES Project for Conduit Supports." The current procedure governing conduit field verification (walkdowns) is TNE-FVM-CS-014. Revision 3. "As-built Field Verification Method
- Design Control of Electrical Conduit Raceways for Unit 2 Installation in Unit 1 and Common Areas, Class 1."
When EBASCO became responsible for the new design verification program for Unit 2 conduit, the old verification program was discarded, including the walkdown data and the created IS0 Apparently, in mid-May 1986, the " problem log" was discarded without having the identified concerns / problems evaluated for nonconforming conditions. To the best knowledge of the individual in charge of the log, the log contained about half of a page of entries, perhaps 10 to 15 concerns / problems. This individual also stated that those concerns / problems identified under the old program were the type of items that would be considered under the new program (TNE-FVM-CS-014). Two other individuals that had knowledge of this problem log were still on-site and were separately interviewed by the NRC inspecto Each individual's recollection was consistent with that of the individual in charge of the log. Discarding of the problem log bypassed the site nonconformance reporting mechanism. This action is in violation of Criterion XV of 10 CFR Part 50, Appendix B (446/8622-V-06).
1 Based on inspection of TNE-FVM-CS-014, Revision 3 (particularly paragraphs 2.2, 6, and 13.3), the NRC inspector determined the following concerning the current program. A process has been established to identify out-of-scope concerns / problems to be evaluated for potentially nonconforming conditions. These problems are required to be documented on a Request for Inspection (RFI) form. The original is kept in the RFI log book and c copy included in the applicable ISO work package. Based on interviews of EBASCO personnel, at the conclusion of the walkdown program copies of the RFI forms will be transmitted to THE Engineering Assurance for further evaluation and processin .-
.
.
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f No mechanism appears to be established that describes or controls the tracking and accountability of RFIs (126 to date)
to assure that identified items are evaluated and suitably
- dispositioned. The absence of such controls has been identified as a violation (446/8622-V-07).
In summary, the allegation that the problem log used by the Unit 1 Task Force civil field engineers to record out-of-scope concerns / problems was discarded before the items identified were evaluated or dispositioned was substantiated. A new Unit 2 and common conduit field verification program was established by TUGCo. Under the new program, all previous work (walkdowns and createdIS0s)wasdiscardedandtheworkstartedover. The new program provides for potentially nonconforming conditions to be identified, but lacks detail as to tracking identified conditions to assure appropriate evaluation and dispositioning. These conditions have been identified as a violatio A-013: Alleged Improper NCR Disposition A concern was raised that certain NCRs, related to Unit 2 electrical cable installations, were being improperly dispositioned; NCRs E85-201562, E86-200113, and E86-200195 were cited as examples. The NRC inspector reviewed these NCRs and other. germane documents, in 4-
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addition to performing physical inspections, in an effort to determine the adequacy of the dispositioning of these NCR i NCR E85-201562 A concern over nonconcentric' outer jacket insulation on electric cable from two cable reels was raised in this NCR on November 16, 1985. The original disposition indicated that the outer jacket is for protection of the cable during shipping, storage and installation; therefore, exact centering of the conductors was not required and the project could "use-as-is" this cabl This disposition was supported in a revision to the NCR (Revision 2, approved August 25,1986) which provided additional information. The revised disposition concluded that the nonconcentric outer jacket was acceptable based on: (1) evaluations conducted by the electrical cable manufacturer of representative samples of cable from the actual cable types at the CPSES, and (2) testing conducted by the cable manufacturer in 1979 on electrical cable with thin wall thickness of the outer jacket. The cable manufacturer's report (contained in
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Rockbestos Company letter VBR-19,608, dated June 10,1986) stated that an average jacket wall thickness of 50% of the specified thickness and spot minimums as low as 40% of the specified thickness
"will have no detrimental effect upon the ability of the cable jacket to perform its intended protective function."
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The NRC inspector also ieviewed the receiving inspection report file for both cable reels involved in this NCR. It was found that the specified minimum and average wall thickness were listed as 0.036" and 0.045" respectively for both reels and that the actual measurements were 0.039" and 0.049" for cable reel W-166-1, and 0.038" and 0.050" for cable reel W-266-1. The actual thickness was, therefore, greater than the specified minimums. Based on the aoove NRC_ inspector findings, this portion of the allegation was not substantiated. However, the NRC inspector noted that the original NCR disposition was not as complete as the Revision 2 disposition in explaining how the decision to "use-as-is" was detennine ,
NCR E86-200113 ,
A concern over the connection of the electrical wiring to a motor operated valve (MOV) was raised in this NCR dated January 15, 198 The concern addressed the bend radius of the electrical cable and the inability to inspect the cable for either color coding or possible insulation damage. The disposition indicated that the wiring conditions were acceptable and to "use-as-is" the installatio The basis for the above determination, as presented on the original disposition of the NCR dated January 27, 1986, and Revision 1 of the NCR dated February 12. 1986, was as follows: (1) the bend radius was measured as 0.797" in IR 2-0081174 on January 31, 1986 (this radius is greater than the minimum requirement); (2) the cable color code was verified by review of the original installation IR; and (3) no cable jacket damage was observed by QC inspection of the cable exposed inside the MOV connection box.
,
In order to verify the acceptability of the NCR's disposition, the
! NRC inspector had the M0V connection box opened and performed a physical inspection of the internal wiring. The NRC inspector noted
- that the outer jacket was removed back inside the flexible conduit for approximately 2", determined that the bend radius was acceptable for the 3, single, !6 conductors inside the MOV box and also
, determined that the conductor insulation exposed inside the MOV box i
was not damaged. The NRC inspector was also able to verify that the cable jacket was the correct orange color and that the conductor l insulation exposed inside the flexible conduit was not damaged by lifting up on the conductors while viewing down into the flexible condui Based on the above observations, the NRC inspector determined that this portion of the allegation was not substantiated. However, the NCR did not, by itself, contain a sufficient explanation for the NRC inspector to conclude that the "use-as-is" disposition was acceptable; visual inspection was required to reach this conclusion.
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NCR-E86-200195 A concern over cable slack being removed without QC present to monitor for possible cable damage was raised in this NCR on January 20, 1986. The disposition indicated that, since the raceway was properly prepared for cable installation, removal of slack would not damage the cable; therefore, "use-as-is."
The NRC inspector could not agree that the basis for the "use-as-is" disposition provided in the NCR was acceptable. Therefore, the NRC inspector physically checked the condition of the cables inside the junction boxes (JBs) and the cable tray mentioned in the NCR. The results of this inspection were: (1) JB 2C-4910, the electrical cables were found to be free of damage and to have adequate slack, and in addition, a cable support grip was installed in the vertical conduit that exits the bottom of the JB; (2) JB 2C-1920, the cables were found to be free of damage and to contain adequate slack; and (3) cable tray T230RCJ06, the cables were found to be free of damage and were properly coiled and protected while awaiting termination to the containment electrical penetration devic The NRC could not substantiate whether or not QC was present when the cable slack was removed. However, based on the above NRC inspector observations, even if this did occur, there was no adverse effect on the quality of the cable installatio Although the allegation was not substantiated, the NRC inspector noted that, in each of the above examples, additional information was required in order for him to conclude, by inspection and documentation review, that the NCR disposition was acceptable. The lack of a clear explanation on how the NCR disposition was determined could have contributed to the alleger's concer The NRC inspector discussed the concern of incomplete explanations for NCR dispositions with applicant QE personnel. The inspector was informed that TUGCo became aware that the NCR dispositions may not always be as explanatory as would be desirable and that steps were being taken to correct this situation. The first step included a redispositioning of selected NCRs in accordance with CAR-062, dated March 4, 1986. The NRC was informed by letter dated October 20, 1986, that the applicant had implemented a program to review
, additional NCRs. This review program encompasses a technical review of all previously closed NCRs with " void," " repair," or "use-as-is" dispositions and is planned to be completed by June 30, 1987. In addition, a new corporate procedure (NE0 3.05) is being finalized to provide more specific guidcnce on the processing of NCRs. The NRC inspector will evaluate the results of the above actions when they are implemented. This is an open item (445/8626-0-09; 446/8622-0-08).
!
l No violations or deviations were identified.
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c. 4-86-A-056: Alleged Improper Weld It was alleged that a foreman had directed a welder to make a weld on a cable tray support without removing existing paint. The support in question was reported to be located in the Unit 2 electrical room at elevation 852'. The weld was alleged to'have been made in approximately May 198 The cable tray supports are vendor supplied and are fabricated using ASTM A-36 structural steel and Type E7018 coated electrode Subsequent to fabrication, the supports are coated with a phenolic modified epox Normally, any welding performed on-site would be associated with the installation of the support. However, during TUGCo's inspection of Unit 2 cable tray supports which was initiated in approximately August 1985 and is about 65% complete, it was determined that, in some cases, additional members were required; e.g., bracin The addition of bracing was generally acccmplished by welding. Since the supports had already been coated, removal of the coating would be required prior to welding. If the coating had not been removed prior to welding, conditions which would normally be expected to occur, and which would be visible in the weld, are gross porosity, inclusions, and areas of nonfusio The NRC requested the alleger to assist in identifying the specific cable tray support. This request was denied. Thus, without having necessary specificity, the NRC inspector selected a sample of 35 cable tray supports based on the specified room (Unit 2 electrical room) and location (elevation 852'), and the fact that they exhibited welds made subsequent to installation. The NRC inspector performed a visual examination of the welds. The inspected welds were all deposited as a result of the identified need for added bracin These welds had not yet been coated; thus, were in the as deposited condition. The NRC inspector observed none of the conditions which would have been expected if welding over paint had occurre Further, it was observed that paint had been removed as bare metal was visible beyond the toe of each weld le There was no evidence of welds having been made over pain Therefore, this allegation was not substantiate . . . - -- - _ _ . . . ~ . - . - . . -
6. - Overview Inspection NRC inspectors have inspected, to date, a total of 45 overview
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verification packages. . The following six packages were inspected during this report period:
18-I-S-INSP-012 46-I-S-PWRE-541 2-I-S-PWRE-527 46-I-S-PWRE-521
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18-I-S-PWRE-521 14-R-S-LBSN-015 No violations or deviations were identifie . Exit Interview Exit interviews were conducted October 9 and November 12, 1986, with the applicant's representatives identified in paragraph 1 of this appendi During these interviews, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the finding .
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