IR 05000445/1987011
| ML20238D793 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/02/1987 |
| From: | Barnes I, Ellershaw L, Hale C, Will Smith, Wagner P NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20238D763 | List: |
| References | |
| 50-445-87-11, 50-446-87-09, 50-446-87-9, NUDOCS 8709110398 | |
| Download: ML20238D793 (45) | |
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APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report:
50-445/87-11 Permits: CPPE-126 50-446/87-09 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit Expiration Dates:
Unit 1: August 1, 1988 Unit 2: Extension request submitted.
Applicant:
TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES),
l Units 1 & 2 Inspection At:
Comanche Peak site, Glen Rose, Texas Inspection Conducted:
June 5 through July 7, 1987 Inspectors: b/
AsAa A f-J"N LV E. Ellershaw, Reactor Inspector Date (paragraphs 2.a-c, 3.a, 3.c-f, 3.1, 4.a-c, and 6)
S/dW
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C. J. Kale, Reactor Inspector Date
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(pafagraphs 2.e, 2.g, 3g-h, and 4.d-g)
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}t Y 9/2l17 W.
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Smith, Reactor Inspector Date (paragraphs 2.d and 3.b)
@ C. b_bo h 9/2/87 l
P.
C. Wagner, Rehotor Inspector Date (paragraphs 2.f, 3.j-1, and 5)
Consultants:
EG&G - J. Dale (paragraph 2.c)
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A. Maughan (paragraph 2.f)
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W. Richins (paragraphs 4.a and 4.b)
V. Wenczel (paragraph 2.g)
i Parameter - J. Birmingham (paragraph 4.d-g)
K. Graham (paragraphs 2.a-b, 4.c, and 6)
D. Jew (paragraphs 3.a, 3.c-f, and 3.1)
Reviewed by:
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Barnes, Senior Project Inspector Date l
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Inspection Summary:
Inspection Conducted: June 5 through July 7, 1987 (Report 50-445/87-11; 50-446/87-09)
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Areas Inspected: Nonroutine, unannounced inspection of applicant I
actions on previous inspection findings, follow-up on items of
noncompliance /. deviations, pipe support and restraint systems, l
general plant areas (tours), and Comanche Peak Response Team (CPRT)
j issue-specific action plans (ISAPs);
i.e.,
II.c, II.d, V.a,
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VII.a.1, VII.e.2, VII.a.7, and VII.a.9.
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Results:
Within the five areas inspected, one violation I
(unauthorized electrical connection metheds), paragraph 2.f was identified.
The questionable disposition of certain nonconf6rmance
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reports (NCRs) was identified as an unresolved item in i
paragraph 2.e.
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-DETAILS
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Persons Contacted i
J. Arros, Discipline Coordinator, TERA
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L. Barker, EA Manager, TU Electric.
- M.LBlevins, Manager, Technical Support, TU Electric G. Braun, Deputy Site Manager, TERA G. T. Bunt, Supervisor, ASME Paper. Flow Group (PFG),
TU Electric
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- W.
G. Counsil, Executive Vice President,-TU Electric
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- R. D. Delano, Licensing Engineer,'TU Electric
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- D.
Deviney, Operations Quality Assurance (QA): Manager, TU Electric'
J. Gallagher, Training l Coordinator, TU Electric, l
P. E. Halstead, Quality Control-(QC) Manager,-TU Electric I
J. L. Hansel, QA/QC Review 1 Team Leader,-ERC-B. Haynes, Comanche Peak Engineering (CPE) Electrical /I&C,
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TU Electric
- T.
Heatherly, Regulatory Compliance Engineer, TU Electric
- G.
D. Karpyar, CPRT, TU Electric M. G. Kennedy, Training Coordinator, TU-Electric i
P. A. Leyendecker, Surveillance Supervisor,'TU. Electric
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- G.
M. McGrath, TS/ SSP Manager, Startup, TU Electric I
- L.
D. Nace, Engineering & Construction Vice' President,.
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TU Electric I
- D.
Noss, QA Issue Interface Coordinator, TU. Electric G. Purdy,. Site QA Manager, Brown & Root (B&R)
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- J. Redding, Executive Assistant, TU Electric
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M. Reynerson,. Construction Director, TU Electric i
- J.
C. Smith, Operations Staff, TU Electric
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B. Stevens, Manager, Electrical Engineering, TU Electric
- J.
F. Streeter, QA Director, TU Electric
- C.
L. Terry, Executive Assistant, TU Electric-
- D. Woodlan, Nuclear Licensing Supervisor, TU Electric The NRC inspectors also interviewed other applicant employees
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during this inspection period.
- Denotes personnel present at the July 7, 1987, exit interview.
i 2.
Applicant Actions on Previous Inspection Findings (92701)
a.
'(Closed) Open Item (445/8513-O-45):
During an NRC witnessed inspection of Verification Package I-S-LBSN-037, ERC identified the following conditions as subject to evaluation as potential deviations: (1) clamp bolts did not have locking devices, and (2) paint was
identified on spherical bearings.
The NRC inspector verified that a: deviation report (DR) was written fcr
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each deviating condition.
The DRs were subsequently documented on NCR M-23284N.
The NCR was dispositioned
"I-S-LBSN-037-DR-1 and 2 are not nonconforming.
conditions". for the following reasons: (1) paint is an acceptable locking device (reference NCR M-23216N R-1)
and was verified to exist on threaded connections of the i
subject support, and (2) paint on the spherical bearings
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does not impair free gimbaling of the snubber which is the acceptance criteria defined by QI-QAP-11.1-28, Revision 34.
With respect to paint as an acceptable locking method, the NRC inspector identified that a previous NRC inspection report, EA 86-09, Violation B, Part 6, identified a failure to comply with the requirements of paragraph NF-4725 of ASME,Section III.
The applicant's response to the violation dated August 4, 1986, admitted to the violation and committed to the mechanical locking of threaded fasteners.
l The B&R site QA Manager was contacted in order to clarify the conflict between applicant's response to the violation and the NCR evaluation of clamp bolts not having locking devices.
Although the technical justification for NCR M-23216N was previously approved by TU Electric Project Engineering, the subsequent issuance of design change authorization (DCA)-31900, Revision 1, required reinspection to' verify
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compliance with the ASME identified locking methods.
The conflict between tne NCRs and the DCA was documented by the QC group with DR C-87-2692.
The action to correct
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the deficiency identified that correctivo action report l
(CAR)-66X had been issued for locking cevices and that the Hardware Validation Program (HVP) required reinspection to assure that all supports exhibit the correct locking device.
Furthermore, the NCR log book was annotated with the DR number next to each NCR number i
for future reference.
The NRC inspector verified that HVP procedures require inspection for the correct locking device and that the NCR log book had been annotated, b.
(Closed) Open Item (445/8513-0-47):
During an NRC witnessed inspection of Verification Package I-S-LBSR-029, ERC identified the following conditions as subject to evaluation as potential deviations:
(1) missing locking devices, and (2) dimensional discrepancies.
The NRC inspector verified that a DR was written for each deviating condition.
The DRs were-subsequently documented on NCR M-23135N.
The NCR was dispositioned "I-S-LBSR-029 DR 1&2 are not nonconforming conditions" for the following reasons: (1) paint is an
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acceptable locking device (reference NCR M-23216N R-1)
and was verified to exist on threaded connections of the subject support, and (2) dimensional discrepancies identified were not a valid deviation.
The note on the drawing stating all dimensions plus or minus 1/4" is.
i applicable for base plates only; not the location of
piping (which was the identified dimensionally discrepant condition).
With respect to the acceptability of paint:as a locking device, see paragraph 2.a, above.
The NRC inspector concurs that the TU Electric disposition of the identified dimensional discrepancies was correct.
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(Closed) Unresolved Item (445/8516-U-55):
The NRC
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inspector observed three Hilti Kwik Bolts (HKBs) that had
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been installed through an embed plate.
Further review by
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the NRC inspector identified DCA 9091 which authorized the installation of the three HKBs and the cutting of rebar to facilitate the in_stallation.
The adequacy of j
the engineering basis for the DCA was considered an I
unresolved item.
Technical justification for cutting three rebar and installing three HKBs through an embed plate was identified in TU Electric office memorandum NE-8765, DCA
9091, and Engineering Calculation SSB-118C, Set'4.
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documents contained the following information:
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The rebar cut at the 2 1/2" depth was authorized by
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DCA-9091.
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The rebar cut at the 5 1/2" depth is a template bar and requires no authorization for cutting.
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The rebar cut at the 7" depth is the end of the tail of a bent bar.
The cutting of such bars are generically approved by DCA-243 and no further authorization is required.
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Drilling through the 8" embedded wall plate was
authorized by DCA-9091 and supported by Engineering Calculation SSB-118C, Set 4.
The NRC inspector reviewed Revision 2 of DCA-9091, Revision 1 of NCR-M-80-161, Revision 3 of NCR 80-00173, Drawing 2323-S1-0628/13, Section 33.33 of Engineering Calculation SSB-118C, Set 4, and TU Electric office memorandum NE-8765, and concurred with the engineering evaluation of this unresolved ite.
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d.
(Closed) Unresolved Item (445/8518-U-07):
Actions taken by the CPRT to resolve ISAP III.d screening checklists found with missing entries.
During an ISAP III.d implementation inspection, the NRC inspector identified 12 sample items for preoperational tests that did not have completely filled-in screening checklists.
It was unclear to the NRC inspector whether the absence of the information had any bearing on sampling results.
Subsequently, the Review Team Leader (RTL) demonstrated to the inspector that the reviewer had taken some shortcuts to arrive at the same conclusion he would have arrived at had he gone through the mechanics of filling in all of the blanks.
While reviewing all 12 samples, the NRC inspector was shown that the information was either unnecessary in the particular situation or was redundant.
In three cases the records-had been revised to provide the information for the sake of clarity, but in those cases the results were still unaltered.
This issue was resolved to the inspector's satisfaction, on the basis that there was sufficient information in each sample file to permit the blank entries., and no purpose would be served by filling in the blanks at this time.
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(Closed) Open Item (446/8602-0-07):
This item concerned the disposition of NCR E86-200637, which required the Inspection Surveillance Group to identify all'
nonconforming conditions that were documented on three-part memos and listed on the' Inspection Process Control (IPC) Discrepancy Tracking Log, then issue i
specific NCRs where required.
The three-part memos in question were generated during IPC inspections of specific QC inspection attributes.
If an apparent nonconforming condition was noted, but was i
outside the scope of the specific inspection attributes, the IPC inspector would document the item on a three-part memo and forward the memo to Quality Engineering (QE) for consideration and action as necessary.
As those three-part memos were issued, they were entered and tracked on the IPC Discrepancy Tracking Log.
When the IPC group was replaced by the Inspection Surveillance i
Group, this log contained entries of 45 three-part memos.
The Inspection Surveillance Group documented the disposition of NCR E86-200637 in an office memorandum,-
QQS-013, dated September 26, 1986.
This memo described
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the actions taken for 49 issues; four additional items
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were identified during the disposition of this NCR.
l The Inspection Surveillance Group' located 39 of the i
45 three-part memos listed on'the IPC tracking log.
Each
of these documented concerns were dispositioned by the j
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issuance of an NCR or a justification of why the item was acceptable.
In the six cases where the three-part memo could not be located, the Inspection Surveillance Group repeated the IPC inspection which had generated the-three-part memo or inspected the area for the deficiency i
described in the tracking log for that item.
The total j
Inspection Surveillance Group effort resulted in the l
issuance of 28 new NCRs.
i The NRC inspector reviewed the actions taken by the Inspection Surveillance Group on all 49 items and found-the inspection of each item was appropriate and the action taken was correct.
The 28 new NCRs have all been dispositioned and the NRC inspector reviewed the
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disposition of each.
To assure proper disposition of i
16 of the NCRs, it was necessary to review the total i
documentation packages that were obtained from the PFG or l
the Interim Records Vault.
In all but tuo instances, the j
NCR dispositions appeared proper.
The two NCRs in question were invalidated by the responding group; however, a review of the document packages in the PFG indicated the NCR may have been valid and programmatic or personnel actions (i.e., training) should have been taken.
Since both of these NCRs appear to have been dispositioned incorrectly, the NRC inspector selected 10 other invalidated NCRs outside the review area of this open item.
One of these NCRs also appeared to have been dispositioned incorrectly.
Since further inspection is necessary before the NRC inspector can determine if procedures have been violated, this matter will be considered unresolved (445/8711-U-01; 446/8709-U-01).
The action on NCR E86-200637 has been completed.
Except for the unresolved item described above, which is a potential problem unrelated to the initial NCR.
The actions taken have been verified'by NRC inspection as being appropriate.
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f.
(closed) Unresolved Item (445/8622-U-08; 446/8620-U-05):
i The acceptability of various NRC inspection findings on
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the safcty-related water chillers (CP1/2-CHCICE-05/06) to meet the requirements of the CPSES electrical erection specification requirements.
The NRC inspector performed a follow-up inspection and reviewed the applicable specifications for these four chiller units.
The results of this inspection / review and a review of information provided by the applicant related to this unresolved item follows:
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CP1-CHCICE-05/06 & CP2-CHCICE-05/06 (1)
Bolts on the compressor discharge flange that were not installed as shown on Drawing 376-09121E have been analyzed and found acceptable as documented by Impell letter IMT-0240 to T. Brandt, QE from J. V. Everett dated August 8, 1986..
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(2)
The use of slide-on, tab type wire connectors on some of the devices inside the control panel was found acceptable based'on the seismic qualification tests for the chiller units.
This test, as documented in York Report No. CPSES-5., indicated that these connectors wero qualified.for the installed service.
(3)
The practice of splicing two conductors inside the barrel of a crimp connector was found to=be
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acceptable based upon this configuration being installed on the unit used for the seismic qualification tests for the chiller units.
This test is documented in York Report No. CPSES-5.
(4)
The use of cap type, inline splice connectors to j
terminate instruments and limit switches and the use of a wire nut to terminate one lead of the CP2-CHCICE-06 auxiliary oil pump motor were evaluated.
The NRC inspector noted that Specification 2323-MS-80B required all vendor wiring to be brought to terminal blocks and that splicing of wiring or the use of common wire nuts was
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forbidden.
The failure to meet these specification requirements is a violation (445/8711-V-02; 446/8709-V-02).
(5)
Follow-up by the NRC inspector of the wires.with short bend radii and the oil leak out of fitting i
OPG, found that the applicant had reinspected the chiller units and written NCRs E86-103034 and
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E86-250266.
In addition, the applicant has initiated a bend radius inspection of these units by instructions approved on May 5, 1987, to supplement the ISAP VII.a.9 inspections.
cpl-CHCICE-05 (6)
Follow-up by the NRC inspector of peeling paint on the underside of the compressor found that the applicant had reinspected the unit and written NCR E86-103034.
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(7)
Follow-up by the NRC inspector of the flexible
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conduit for switch PRV, which.had the outer jacket l
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during their earlier ISAP VII.a.9 inspection, had identified this condition and written DR I-M-VII.a. 9-050-42.
This unresolved item is closed.
Follow-up actions will be tracked and documented under the violation.
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(Closed) Open Item (445/8702-0-04; 446/8702-0-04):
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Development and implementation of a formal procedure had
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not been accomplished by the CPRT statistical advisor j
that specifies statistical review methodology and establishes a tracking system to assure required actions
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identified during statistical reviews were completed in a
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tLmely manner.
The NRC inspector verified that the statistical advisor
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developed and implemented a. procedure for.CSAP sample
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selection reviews on March 11, 1987.
The procedure provided instructions for performing initial and final
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statistical reviews; use of acceptance criteria in reviews; methodology used in reporting review results; a tracking system to identify and monitor actions required (open items) to assure satisfactory resolution was achieved; and a documentation mechanism to furnish evidence of statistical review and closure of open items..
To verify procedural implementation, the NRC inspected
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t the results of 12 of the 18 statistical reviews completed
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since March 1987.- Logs were maintained to track ~open
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items identified during-those reviews to assure closure in a timely manner.
In addition to instructions for activities internal to the Statistical Review Group, the procedure provided documented control of interactions j
with the Results Report and Working File Review Committee (RRRC).
Of the 12 completed reviews the NRC inspected,
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6 had interactions with the RRRC.
These interactions were reviewed and found to comply to procedural
requirements.
Based on inspecting 12 statistical review documentation files and 6 RRRC documentation files, the NRC inspectors determined that the statistical review procedure was being implemented as written.
It was noted by the NRC inspector at the beginning of this inspection j
that the procedure had not been formally issued.
Prior i
to completion of the NRC inspection activities, the procedure, " Instructions for Sampling Reviews," dated June 25, 1987, was formally issued and distributed to the four users via interoffice memo CPRT-943 dated June 25, 1987.
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Based on verifying procedural implementation and formal
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issue of the statistical review procedures, this item is l
closed.
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Follow-up on Items of Noncompliance / Deviations (92702)
a.
(Closed) Deviation (445/8518-D-04):
The ERC population I
engineer incorrectly indicated "N/A" for a checklist
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attribute which was applicable for Verification Package j
I-M-SBCO-022.
As a result, attribute 1.1, dealing with i
dimensionally locating bolted flanges in accordance with I
the piping isometric, was not reinspected by ERC.
During I
a subsequent NRC inspection of this package, it was l
observed that this attribute was applicable as evidenced
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by the presence of four bolted flanges.
j The committed corrective action consisted of reinspecting this package for inspection checklist attribute 1.i.
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review of Revision 1 of the ERC inspection checklist dated February 6, 1986, confirmed that attribute 1.1 had been reinspected and accepted.
Additionally, it should be noted that the ERC inspection findings on attribute 1.1 were consistent with those of the NRC inspection.
The committed actions to prevent recurrence' involved several steps, which were verified by the NRC inspector.
These included discussions with the population engineers and instructions to ERC inspectors.
Also the ERC EA Group, which performs the final ERC documentation review, is required to verify that all "N/A" entrics on inspection checklists are justified with an explanation and that there is adequate documentation to support the explanation.
The NRC inspector reviewed a total of 20 Small Bore Piping Configuration (SBCO) and Large Bore Piping Configuration (LBCO) inspection checklists involving the same population engineer whera "N/A" was marked for attribute 1.1 (location of bctited flanges).
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cases, review of the applicable piping isometrics l
revealed no bolted flanges within the scope of the ERC l
inspection; therefore, the "N/A" had been correctly
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inserted.
It was also confirmed by the NRC inspector that ERC memorandum QA/QC-RT-2007 instructed ERC inspectors to bring to the attention of the population engineer any discrepancies of this type encountered during their reinspection.
The NRC inspector reviewed the specific EA documentation review criteria for the SBCO population.
Criterion 11 on
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the generic checklist required EA to verify that justification for the "N/A" was included.
Conversations with the lead EA reviewers for the SBCO and LBCO populations verified that this criterion required comparing the isometric drawing to the ERC reinspection checklist to assure that the "N/A" is applicable.
Implementation of this criterion with respect to the LBCO and SBCO populations would be adequate to detect any other improper "N/As" inserted by the population engineer.
The NRC inspector also reviewed ERC memorandum QA/QC-RT-4483 dated November 19, 1986, and revised May 4,
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1987, titled, " Attribute Count Matrix for Small Bore Piping Configuration Population (SBCO)."
This memorandum tabulated the attribute count for the entire SBCO population.
Review of this memorandum revealed that the'
attribute count associated with the location of bolted flanges was in excess of 60 and omission of this attribute from Verification Package I-M-SBCO-022 would not have affected the sample conclusions.
b.
(Closed) Deviation (445/8518-D-05):
Failure to document, disposition, and track discrepancies found during the CPRT review of drawing changes and their potential effect on related preoperational tests (pts) sampled in accordance with ISAP III.d.
The NRC inspector noted during an inspection of the above review documentation that System Test Engineers (STEs)
had failed to change the revision number of drawings
referenced in updated pts, and therefore the referenced drawing list did not properly indicate which drawing revisions were in effect during the conduct of the test.
The CPRT was aware of this but appeared to have failed to document the discrepancy as committed in Section D of Appendix E to the CPRT Program Plan, Revision 2.
The applicant explained that in each case the STE'had updated
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the body of the PT appropriately, but had failed to l
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update the revision numbers in the reference list, which j
would make subsequent reviews easier but had ne technical-or safety significance.
The objective of the ISAP was to find evidence that startup recognized the need for a change.
This objective was met, and thus no discrepancy was noted by the CPRT.
The applicant's formal response was documented by TUEC letter TKX-4848 dated July 9, 1986, and was accepted by NRC letter dated November 17, 1986.
The NRC inspector discussed some advantages of j
properly updating the revision numbers on the reference i
list with TU Electric Startup Management personnel at l
that time, and during the present inspection period noted I
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that Startup Administration Procedure CP SAP-7, " Format and Content of Test Instructions /Precedures," had been revised to require a prerequisite signoff in all pts that the test procedure drawings have been-reviewed and revisions updated to reflect the current as-built status of the plant and are reflected in the procedure.
This prectice was not proceduralized in the past, which explained why some STEs were updating the revision
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The revision to CP-SAP-7
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Implementation will be evaluated during future routine preoperational testing inspections.
c.
(Closed) Deviation (445/8518-D-22):
The ERC inspector documented "N/A" for attribute 4.5 for supports 023A and 023C for Verification' Package 1-S-INSP-023.
This attribute dealt with verifying that the serrated grooves i
of the Unistrut nut align with the channel clamping
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ridge.
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Investigation by ERC revealed that Verification Package I-S-INSP-023 contained several inspection checklists, one for the stand and one for each support.
For this package, which was one of the first INSP (i.e..,
Instrument Pipe / Tube Supports) packages to be inspected, all spring nuts were inspected and accepted under the checklist for the stand.
Therefore, all the supports i
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The committed corrective action included correcting Verification Package I-S-INSP-023 on January 6, 1986, to reflect acceptance of the spring nut attribute on a "per support" basis and a leview to identify other packages for which spring nuts had not been accepted on a "per support" basis.
The committed action to prevent recurrence involved training provided to all discipline inspectors.
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l The NRC inspector confirmed that the checklists were i
revised for Verification Package I-S-INSP-023 on January 6, 1986, to reflect spring nuts acceptance on a i
"por support" basis.
This was also the code for Verification Package I-S-INSP-048.
Additionally, the NRC inspector reviewed 10 other INSP packages involving 5 different ERC inspectors to assure that no other packages had been erroneously documented with respect to attribute 4.5.
No other instances were identified.
d.
(Closed) Deviation (445/8518-D-26):
In Verification-Package I-M-SBCO-022, bill of material item No. 17, (a socket welded coupling) was delineated en the piping isometric with distinct linear dimensions.
The coupling i
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by the ERC inspector denoting that all linear dimensions were verified.
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Prior to the initial ERC reinspection, a three-part memorandum dated September 5, 1985, was issued by engineering stating that coupling locations for samples in the SBCO population need not be measured.
The committed corrective actions included revising QI-026,
Revision 1, to include checking the location of socket j
welded couplings.
All previously inspected verification i
packages were reinspected to criteria of QI-026, Revision 2.
Upon review of the supplemental inspection checklist for Verification Package I-M-SBCO-022, the NRC inspector verified that ERC had reinspected to the criteria of Revision 2 to QI-026 on May.1, 1986.
Subsequent field inspection by the NRC inspector confirmed that the locations of the couplings were within tolerance to those specified on the piping isometric.
Further review of I
five SBCO packages, in which the piping isometric.
contained socket welded couplings, revealed.that ERC had documented reinspection of the locations of the couplings per the criteria of Revision 2 to QI-026.
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(Closed) Deviation (445/8601-D-17):
This deviation. dealt with f ailure on the part of the ERC inspector to docuinent I
an unacceptable clearance between the inspected line and an adjacent line for Verification Package I-M-LBCO-038.
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The committed corrective action included reinspection of the line for clearances.
The committed action to prevent recurrence included undocumented informational training between the lead ERC mechanical inspector and the inspector of record.
NRC review of the verification package confirmed that the line was reinspected for clearances and that DR I-M-LBCO-038-DR-1 was issued to document the pipe clearance condition.
Additionally, the NRC inspector concurs with the disposition of NCR M25226N as a means of resolving this issue.
Subsequent field inspection i
verified that the insulation has been notched and that i
minimum clearance requirements are now met.
Upon review of the ERC Overview Inspection Group (OI) program files, it was determined by the NRC inspector that this j
inspector's error rate was below the average for j
mechanical inspectors and that no other discrepancies of this type (pipe clearance) were encountered by OI.
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(Closed) Deviation (445/8601-D-18):
This deviation dealt with the population engineer incorrectly' inserting "N/A" for attribute 1.e on the checklist-for Verification Package I-M-LBCO-038.
As a result, attribute 1.e which deals with branch connection locations was not inspected.
This particular condition was determined to be an isolated incident.
The NRC inspector reviewed a total of 52 verification packages from both the LBCO and SBCO samples in which this particular population engineer was involved.
There were no other' instances identified in which the population engineer had erroneously entered N/A on the checklist.
The committed actions to prevent recurrence consisted of'
instructing the population engineer to take added precautions and informing the ERC inspectors to either correct such discrepant conditions or bring it to the population engineer's attention for resolution.
In addition, ERC has scheduled and performed surveillance of CPRT activities in accordance with ERC-QA-15, " Performance of Project Surveillance," which includes verification of work activities by population engineers.
The NRC inspector verified that a portion of ERC QA Surveillance II 85-20 specifically dealt with the work activities of the population engineer involved in this deviation.
I g.
(Closed) Violation (445/8601-V-12; 446/8601-V-03):
Item 3: Potentially nonconforming items identified by the IPC group were documented on three-part memos instead of the required NCRs.
By the end of December 1985, the violating practice was stopped when the IPC Group was dissolved and replaced
with the Inspection Surveillance group.
An NCR was written (E86-200637) requiring review of all three-part memos and NCRs written, if required.
This effort began l
on February 28, 1986, and was completed on October 3, 1986.
The processing of NCR E86-200637 was inspected by the NRC and the results are documented in paragraph 2.c.
of this report.
i The Inspection Surveillance Group, which. replaced the IPC
Group, began functioning'with new procedures in March 1986.
The NRC inspected this group's procedures and their implementation with results documented in NRC Inspection Report 50-445/86-03; 50-446/86-02.
The Inspection Surveillance Group's activities were i
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i controlled by Procedure CP-QP-19.13, " Inspection Gurveillances," which required that NCRs be originated to
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document all unacceptable conditions.
Subsequent to the above NRC inspection, a reorganization has occurred.and the Inspection Surveillance Group now reports to the site QA manager.
Because of this reorganization, the controlling procedure was renumbered to DQP-SG-4, but-remains basically the' sam 2 procedure.
"
l The above actions together with those described in paragraph 2.e above closes this item.-
h.
(Closed) Violation (446/8602-V-06):
QC inspectors were completing inspection report attributes with " SAT" when i
the proper entry should have been "NA" and QC management j
had not taken prompt corrective action.
TU Electric stated in their response to this violation, and the NRC inspector verified, that nonconforming hardware conditions were not involved, but only documentation inconsistencies.
Corrective action has
'
been completed in the form of procedure revicion and training.
The NRC inspector verified tnat the applicable portion of Procedure CP-QP-18.0, " Inspection Report," was revised (Revision 24) and issued June 3, 1986.
Formal classroom
training for all QA/QC personnel was conducted covering
!
the changes made in CP-QP-18.0, Revision 24.
)
An interview with the instructor that conducted this training and a review of the documented lesson plan for the training verified that, among other changes, the proper use of " SAT" and "NA" in inspection reports was emphasized.
The NRC inspector reviewed the attendance lists for the above training, together with personnel accountability lists maintained by the training coordinator, and verified that all applicable Q.T/QC personnel had attended one of the 17 training sessions conducted, concerning this procedure revisicne To assess the effectiveness of the procedu'e revision and r
a the training, the NRC inspector reviewed the results of l
surveillance conducted of QC inspector activity for the period from June 1986 (training conducted) to May,1987.
,
The surveillance group identified two occurrences where
" SAT" was used instead of
"NA", both occurrences being attributed to the same QC inspector.
NCR M-86-202263 and I
construction deficiency rcport (CDR) 87-04452 were, issued j
by the surveillance group documenting these nirors.
Both of these reports have been dispositioned, correcting the j
documentation.
The inspector making these errors is hc
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longer onsite.
As further preventive action, the
' inspection procedure used in the instance of both deficiencies was revised to provide further clarity.
The NRC inspector verified this action by reviewing the revised procedure.
Since the r'esults of all surveillance group inspections are computerized,'the NRC inspector obtained the number
of inspection attributes inspected by the surveillance group of QC.inspectichs completed after June.4, 1986 (the day after training was completed) through June 11, 1987.
,
The total number of attributes inspected was 15,284.
j Since only two recurrences of the " SAT" vs "NA" problems
!
were identified, it appeared the preventive action taken was effective.
l i.
(Open) Deviation ( 4 45/8607-D-10) :
This deviation dealt with OI Package 13-1-M-LBCO-148 not identifying unsatisfactory decisiens made by the initial ERC i
inspector.
The unsati factory decisions' consisted of acceptance of three pipe to pipe clearances which were subsequently identified by the NRC inspector as being in I
I violation of Section 5.2.6.2 of QI-025, Revision 3.
ERC confirmed that inspector error was the cause of the
deviation.
The committed corrective actions consisted of reinspection, correction of the appropriate ERC reinspection and OI checklists, and the issuance of a DR.
The committed actions to prevent recurrence included
documented discussion with the ERC inspectors of record j
and all OI inspectors.
j The NRC inspector confirmed that documented discussions with the ERC inspectors of record and all OI inspectors relative to this finding occurred on July 10 and' June 10, l
1986, respectively.
Further review revealed that i
appropriate changes to the ERC reinspection and OI l
checklists had occurred and that DR I-M-LBCO-148-DR03 was J
initiated and resulted in the-issuance of NCR M-25340N on i
August 22, 1986, which address these clearance problems.
i Further NRC inspection revealed that this NCR was closed I
and reissued as NCR CM-87-5721 as a result of a'new NCR'
system.
The new NCR was sent to engineering on April 27,
1987 for dispositioning The deviation remains open i
pending completion of the NCR disposition.
l
j.
(Closed) Violation (446/8611-V-05):
Incorrect electrical I
junction box identification.
The applicant's January 16,
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1987, response to this violation stated that NCRs E86-201921, M86-201905 and M86-201939 had been written to
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correct the discrepant conditions and that the
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responsible personnel had been retrained.
The NRC l
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17 inspector verified that the above NCRs had been j
dispositioned and closed and that the completed work had i
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been inspected by QC personnel as documented on inspection reports (irs).
The inspector also noted training records documented that training on the appropriate procedures had.been administered.
In addition, the NRC inspector physically verified that the cited identification roblems had been corrected, k.
(closed) violation (446/8611-V-06):
Incorrect conduit identification.
In addition to the germane actions identified for violation 446/8611-V-05, above, the applicant also wrote NCR M86-201938 to correct this conduit identification problem.
The NRC inspector verified that the NCR and its associated IR were acceptably completed and physically verified that the identification markings had,been corrected.
l l
1.
(Closed) Violation (445/8614-V-03; 446/8611-V-10):
Lack of procedural controls for drilling holes in cable trays.
The applicant revised the January 16, 1987, response to
this violation by letter dated May 29, 1987.
The revised response more accurately presented the actions taken by the applicant to resolve this NRC concern.
These actions i
l were the revision of the craft installation and the QC inspection procedures to:
(1) ensure care is exercised during the drilling of holes in solid bottom cable trays t
to facilitate the installation of any fittings or cable retention devices and, (2) when installation is completed, ensure that the cables are checked for
possa.ble damage.
The NRC inspector reviewed the revised procedures and found tha concern had been acceptably addressed.
l 4.
CPRT ISNPs_[ Excluding VII.c)
i a.
Maintenance of Air Gap Between Concrete Structures (ISAP
,II.c) (46053)
The following activities for ISAP II.c were reviewed by.
I the NRC inspector during this report period.
Documentation of Final As-Built Cond2cion (NRC Reference 02.c.04.00)
The NRC inspector witnessed the following QC inspections of the final as-built condition of seismic gaps subsequent to debris removal and/or width modifications.
Inspection of gap width and condition was performed per QI-QP-11.0-16.
Inspection of concrete surfaces within the gaps was performed per QI-QP-ll.0-5.
These
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l inspections were documented on the following construction operation travelers.
Traveler CE86-1637-8403 This inspection involved a single wall gap between the
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safeguard building and the reactor building for Unit 1.
The minimum gap width allowed was 2 3/4" for the floor slab at 852'6" elevation and walls up to i
l 886'6" elevation.
Above elevation 886'6", the minimum gap width allowed was 2 7/8".
A wall along the 5-S line above 873'
4" required no seal by design and the minimum gap width allowed was l'3/4".
Minimum gap widths are specified on DCA 21829, Revision 6.
The minimum gap width observed complied with the above allowable values.
The. gap width, gap condition, and concrete surfaces were satisfactory and met the requirements of QI-QP-11.0-16 and QI-QP-11.0-5.
Traveler CE67-1728-8903 This inspection involved a single wall gap between the safeguard building and the reactor building for Unit 1 similar to and just south of the inspection for Traveler CE86-1637-8903 described above.
The minimum gap width
!
allowed was 2 3/4" for the floor slab at-852' 6"
{
elevation and walls up to 886'
6" elevation.
Above i
elevation 886'
6",
the minimum gap width allowed was 2 7/8".
A wall along the 7-S line above 873" 4" requires q
no seal by design and the minimum gap width allowed was l 3/4".
Minimum gap widths are specified on DCA 21829, Revision 6.
The minimum gap width observed complied with the above allowable values.
The gap width, gap condition, and concrete surfaces were satisfactory and met the requirements of QI-QP-11.0-16 and QI-QP-11.0-5.
No violations or deviations were identified.
NkC inspections will continue during subsequent report periods.
NRC inspections were not performed for other reference items during this report period.
b.
Seismic Design of Control Room Ceiling Elements (ISAP II.d) (48053, 48055)
The following activities for ISAP II.d were reviewed by the NRC inspector during this report period.
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Design of New Control Room Ceiling Structure and
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Components to be Reviewed (NRC Reference 02.d.01.00)
I CPRT reviewed design drawings, calculations, and computer analyses pertaining to the new control room ceiling structure steel frame for compliance with acceptance criteria.
Thic review was documented in Engineering-i Evaluation, Control Room Ceiling Design, Revision.0, File No. II.d.4b.1, dated January 28, 1987.
This document included a general description of the new design'and the evaluation process, a list of acceptance criteria with sources, communications of questions between CPRT and the
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applicant, and conclusions.
CPRT concluded that the new design meets FSAR commitments and acceptance criteria and that resolutions of discrepancies and questions previously identified by CPRT have been incorporated into the current design.
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The NRC inspector previously reviewed (NRC Inspection Report 50-445/86-01; 50-446/86-01) six of the nine calculations reviewed by CPRT for content, accuracy of numerical calculations, and for comparison with design commitments in the FSAR.
The NRC inspector evaluated the-CPRT review of these calculations during this report period and concurred with the conclusions reached by CPRT based on this review.
No violations or deviations were identified'and no
further NRC inspection is planned-for this reference
{
item.
.
NRC inspections were not performed on other reference
items during this report period.
c.
Inspection for Certain Types of Skewed Welds in NF Supports (ISAP V.a) (57050)
Select Random Sample for Inspection (NRC Reference
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05.a.03.00)
The process of generating a random sample from a population for ISAp V.a was previously verified and documented by NRC Inspection Report 50-445/87-02; 50-446/87-02.
This activity is complete.
Develop Sampling Plan in Accordance with Appendix D (NRC'
Reference 05.a.03.01)
The NRC inspector performed a review of the ISAP V.a working files.
The Type 2 skewed weld population was developed from a review of the Hanger Information
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Tracking System (HITS) computer printout.
A review of all pipe support drawings listed on the HITS printout was performed by TU Electric Project Engineering to identify the supports which contained Type 2 skewed welds and had been inspected and accepted by QC inspection.
There were 359 valid Type 2 skewed weld population items identified from the 13,476 pipe supports.
The NRC inspector reviewed the project engineering screening process and found no errors in the determination of." valid" and
" invalid" population items.
NRC inspection of this activity is complete.
No violations or deviations were-identified.
Perform Sampling Evaluation to Determine if Procedural Ambiguities Resulted in Undersize Welds (NRC Reference 05.a.03.02)
The NRC inspector verified that 60 B&R fabricated supports which contain Type 2 skewed weld joint geometry were inspected by ERC inspectors.
Any support where more than 50% of the weld length was inaccessible for measurement was excluded as a valid sample.
NRC inspectors witnessed ERC inspectors performing reinspection to the requirements of ERC Quality Instruction QI-006, and performed inspections to evaluate the adequacy of ERC inspections.
Refer to NRC Inspection Report 50-445/85-13; 50-446/85-09.
No violations or deviations were identified.
This activity is complete.
Perform Analysis to Determine if Welds Meet ASME Code Allowable Stress Levels for Those Found not to Meet
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Design Requirements (NRC Reference 05.a.03.03)
Twelve of the 60 B&R fabricated supports were identified by ERC inspectors to exhibit undersize welds for a portion of the total weld length.
These undersize welds f
were documented on NCRs and evaluated by TU Electric Project Engineering to determine if the actual weld' size would satisfy ASME design requirements.
The NRC inspector verified by review of the NCR dispositions that all welds were determined to be acceptable to use-as-is and that the applicable design drawing weld size was revised.
No violations or deviations were identified and this activity is complete.
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Determine Whether Sample is to be Expanded (NRC Reference 05.a.03.04)
The NRC inspector verified by review of documentation that undersize welding identified during implementation-I of ISAP V.a was properly documented and evaluated for safety significance.
The applicant issued NCRs,for each'
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undersize weld which was identified by ERC inspectors.
The disposition of each NCR was verified to be use-as-is.
No physical rework was required because the as-built weld'
sizes were greater than the minimum required by ASME design.
Population sample expansion is not required due to the fact that no safety significant deficiencies were.
identified.
No violations or deviations were identified-and this activity is complete.
Assess Root Cause and Generic Implications (NRC Reference 05.a.05.01)
The NRC inspector verified that all undersize welds were documented on NCRs and evaluated to use-as-is.
In all cases the actual weld sizes exceeded ASME minimum allowable stress levels.
Therefore, the deviations were not safety significant.
The third party performed a trend analysis and determined that the group of undersize welds were an average of 30%
larger than required by design and that an adverse trend did not exist.
Since no design deficiencies or adverse trends were identified, the CPRT Program Plan did not require an assessment of root cause and generic implications.
No violations or deviations were identified and sens activity is complete.
Identify any Physical Modifications and Procedural Changes Required (NRC Reference 05.a.05.,02)
Evaluations performed by the applicant and the third party determined that no physical changes were required.
The inspection procedure, QI-QAP-ll.1-28, has been revised and now contains acceptance criteria and techniques for the measurement of Type 2 skewed welds.
The NRC inspector verified that the inspection procedure contained appropriate instructions and considers this activity complete.
No violations or deviations were identified.
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d.
Material Traceability (ISAP VII.a.1) (35061)
During this report period, NRC Reference 07.a.01.03 was l
reviewed as follows:
j
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Evaluate Actions Relative to 1981 ASME Survey (NRC Reference 07.a.01.03)
The NRC Technical Review Team (TRT) reported in SSER 11 that TU Electric had failed to maintain material traceability for safety-related material and numerous i
hardware components.
This failure had been previously j
identified during an ASME Code survey in October 1981.
]
ISAP VII.a.1 committed to evaluate the TRT finding regarding the failure to maintain material traceability I
as identified in the October 1981 ASME Code. survey.
The
]
ISAP committed to evaluate in sufficient depth to l
determine the root cause and generic implications of the l
original ASME Code finding and whether the.TU Electric corrective actions in response to the ASME Code survey were appropriate.
The CPRT reviewed the results of the October 1981 ASME
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Code survey and determined that two of the findings i
pertained to material control / traceability:
(1)
Plate material identified in the fabrication shop had not been receipt inspected nor had the material been identified (heat number) as required by the B&R purchase order.
B&R had divided the material hnd
,
I transferred the material identification incorrectly.
B&R practice, at that time, did not include QC verification of the transfer of material identification.
(2)
Component supports were procured as Code stamped items.
The component supports were supplied to B&R i
with only the Code Data' Report.
Due to design changes, many of these supports could not be used as originally intended.
B&R instituted a support salvage program to reuse the materials.
B&R cut the component supperts, removed the welds, and used the material to fabricate other component supports; however, B&R did not have the Certificates of Compliance for the material.
!
The B&R corrective actions for Item 1. included issuance of NCR M-2971, receipt inspection of the material in question, identification of the remaining material not yet issued, replacement of the material with the incorrect heat number, and revision of the QA Manual and
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appliccrie procedures to require QC verification prior to
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separation of a bundle or cutting of material.
j The B&R corrective actions for Item 2 included issuance l
of NCR M-3131 to control the hanger salvage program, requesting the certificates of Compliance or Material Test Reports for the material being salvaged, and review by B&R of the documentation to assure acceptability of~
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the documentation.
!
Based upon review of the NCRs issued to correct the noted
'
deficiencies and the correspondence between the ASME and B&R, the CPRT concluded that the corrective actions taken j
by B&R were acceptable.
This conclusion was consistent I
with the results of an ASME re-survey conducted in 1982 and a subsequent ASME survey conducted in October 1984.
The CPRT, based upon the documentation available, determined that the most likely root cause for the occurrence of thece deficiencies was insufficient detail in the B&R QA Manual, i.e.,
a definitive requirement for QC verification of the transfer of ID markings on bulk material prior to separation of a bundle or cutting of material.
The CPRT also determined, since the QA Manual lacked sufficient detail in procedures controlling material traceability verification, a generic implication existed and other implementing procedures may also lack sufficient detail.
The B&R procedures applicable to material traceability were revised by B&R and were found acceptable by the ASME during subsequent surveys.
The NRC reviewed the October 1981 ASME Code survey findings, the subsequent correspondence between B&R and ASME, the NCRs issued to address the ASME findings, and the revised procedures pertaining to material traceability.
Based upon this review, the NRC found that the CPRT had: correctly identified those findings in the October 1981 survey that pertained to material traceability; correctly identified the root cause for the material identification deficiencies to have been a lack of detail in the B&R QA Manual to require QC verification of transfer of material identity prior to separation.from the bundle or cutting of the material; properly evaluated the generic implications of those deficiencies and their root cause; and properly evaluated the B&R corrective actions pursuant to the October 1981 ASME Code survey.
No violations or deviations were noted during this inspection and no further review of this NRC reference item is planned.
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e.
Nonconformance and Corrective Action System (ISAP VII.a.2) (35061)
The following activities for ISAP VII.a.2 were reviewed by the NRC during.this report period:
Review of Samples of Nonconformance Processing During the TRT inspection of site nonconformances, the TRT found that nonconforming conditions were documented on NCRs and many "other forms."
In SSER 11, the TRT noted that the use of so many "other forms" was confusing and may have led to a lack of proper control of.the nonconforming condition.
Therefore, the CPRT Program Plan included in its ISAP VII.a.2 a review of site
,
procedures for "other forms" and an inspection of'the implementation of "other forms" used to control l
nonconforming conditions.
l To determine the "other forms" used to control nonconforming conditions, the CPRT reviewed current and historical site procedures.
The CPRT found that many forms were used to provide information about the l
nonconforming condition and its repair; e.g., NCRs, field l
deficiency reports, irs, weld data cards, multiple weld data cards, repair process sheets (RPSs), inspected item removal notices (IIRNs), and nondestructive examination l
(NDE) reports.
This resulted in the CPRT performing a
'
review of NCRs and the "other forms".
The CPRT review of NCR implementation has been inspected and reported by the NRC in Inspection Report 50-445/86-01; 50-446/86-01.
NRC inspection of the "other forms" reviewed by the CPRT follows under the headings of field deficiency reports, weld data cards, multiple weld data cards, and nonconforming conditions documented on irs.
5 additionally, a review of current methods for documenting nonconformances was performed by CPRT and inspected by the NRC and is reported in a subsequent paragraph of this report.
Field Deficiency Reports (FDRs)
The NRC inspected the identification of the FDR population and the selection of FDR samples performed by CPRT.
During this inspection, the NRC found that not all FDRs had been included in the original sample.
The issue coordinator explained that initially a population of l
2,004 FDRs had been identified from the FDR log book and l
that a sample of 60 FDRs was selected.
Subsequent to the completion of the review, CPRT learned of an additional 2,357 FDRs that were not included in the original sample i
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selection.
CPRT concluded by examining the FDRs that review of a sample of these FDRs would not provide information to change their conclusion that the FDRs were improperly used to document nonconformances.
NRC review I
of the sample selection from the initial population found the sample to comply with the requirements of Appendix D of the CPRT Program Plan.
A review by the NRC of the additional FDRs found them to be similar to the initial FDRs.
NRC review of the ISAP VII.a.2 Results Report i
found it to address recommendations for all FDRs.
l l
NRC inspection of six FDRs from the CPRT sample, plus zul additional 14 FDRs cutside of the CPRT sample found that i
in addition to rework or scrap dispositions, the FDRs
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documented conditions that appear to require engineering evaluation; e.g.,
kinks found in cable, Hilti bolts found
,
improperly stamped for length identification, cable
pulled without using all pull points, and desiccant I
failed to be maintained as required.
As a result of its review, CPRT issued Programraatic Deviation Report.(PDR) QA/QC PDR-64 for improper use of FDRs to document deficiencies requiring engineering analysis.
No violations or deviations were noted during inspection of the CPRT review of FDRs.
NRC inspection of the processing of all PDRs will be a subject. included in a future inspection report.
Weld Data Cards (WDCs) and Multiple Weld Data Cards (MWDCs)
The CPRT had identified by its review of procedures that nonconforming conditions on pipe welds and pipe support welds were documented on WDCs and MWDCs.
Since ISAP VII.c had previously identified populations for pipe welds and support welds, these populations were used for the random sample selection of WDCs and MWDCs.
The NRC reviewed the population description, the population printout, the sample selection description, and the final
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sample list for both samples.
The NRC review found the selection of sample items to be in accordance with the CPRT Program Plan for random sample selection.
To implement the review of MWDCs and WDCs the CPRT
]
prepared a checklist.
The NRC reviewed this checklist
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and found that it contained criteria as follows:
(1)
Was the nonconforming condition identified and documented in accordance with procedures?
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(2)
Was the deficiency "reworkable"?
(Note: The definition of reworkable included repairs performed in accordance with existing engineering approved procedures.)
j (3)
was the inspection reviewed and approved by appropriate personnel?
(4)
Were the reworked items inspected and tested to original requirements or acceptable alternates?
(5)
Were the disposition and closecut of the deficiency reviewed by appropriate personnel?
(6)
Was the nonconformance included in the trend program?
(7)
Was the nonconformance reviewed for deportability?
l The NRC found by comparing the checklist to the NRC l
Standard Review Plan (SRP) that the checklist was a proper basis for the CPRT evaluation.
To verify the CPRT review, the NRC inspector ' selected six support weld packages and six pipe weld packages from the CPRT sample and inspected them to the criteria of the CPRT checklist.
Support weld packages inspected by the NRC were:
J DD-1-012-067-S33A CS-X-AB-020-006-3 CC-1-RB-068-003-3 CC-1-110-007-A435 FW-1-019-001-S62R AF-1-100-018-S33R Pipe weld packages inspected by the NRC were:
CP-1-RB-22-FW-2
RH-1-SB-13-FW-6A i
CH-1-SB-001-8-0-2 i
CC-2-AB-012-FW-9 CC-2-RB-083-1-WE-1-1
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CT-2-SB-00-5-FW-1 As a result of its revinw, the CPRT issued DRs for j
potential hardware deficiencies and PDR QA/QC PDR-59 for the absence of adequate procedural controls in the use of
"other forms" for documenting, processing and dispositioning nonconformances.
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No additional NRC violations or deviations were found during inspection of the CPRT review of MWDCs and WDCs.
Nonconforming Conditions Recorded ~on Inspection Reports The NRC inspection of the CPRT review of TU Electric irs found that CPRT had reviewed documentation packages; such as, electrical cable installation, electrical conduit supports, instrumentation tubing and related supports, for irs with at least one attribute marked "unsat".
(Since the irs, RPSs, and IIRNs in the pipe and support packages were reviewed during the CPRT reviews of WDCs aad MWDCs, they were not included in this CPRT review of
"unsat" irs.)
This review yielded over 60 irs with unsatisfactory attributes.
The NRC reviewed six of the
,
irs selected by CPRT and an additional six irs not l
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selected by CPRT.
The NRC review was performed to the l
l same criteria used in the CPRT review; i.e., was the l
!
l unacceptable condition adequately described, resolved,
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and checked to verify that it met the design requirements
'
after rework.
irs reviewed by the NRC were:
i IR-E-43149 IR-FP-1-44468 IR-E-6891 IR-FP-1-42709 IR-E-6878 IR-FP-1-44517 IR-E-6880 IR-FP-1-49291
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IR-E-1-37126 IR-E-101196 i
,
l IR-E-FP-1-49391 IR-I-5683
)
The results of the NRC review found in c the unacceptable conditions were adequately described and reinspected to the design criteria after rework was performed.
The review could not fully determine if the rework was adequately performed because a description of the rework activity was not included on the IR.
Since the results of the CPRT review were similar to the results of WDCs and MWDCs evaluation, they were consolidated and included l
in the QA/QC PDR-59 discussed earlier in this report.
J No additional violations or deviations were found during inspection of the CPRT review of deficiencies documented on irs.
No further NRC inspections of the CPRT review of j
nonconformances documented on "other forms" is planned;
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however, additional NRC inspections of "other" ways of documenting nonconforming conditions are planned.
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Review of Current Methods of Documenting Nonconformances -
ISAP VII.a.2, Revision 1, required that a review,
,
including a procedural search, be conducted to identify l
the historical methods used by the CPSES site for j
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,
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identifying and documenting nonconformances.
The CPRT performed this review-in late 1985.
The NRC inspected and reported on this activity in NRC Inspection Report 50-445/86-01; 50-446/86-01.
Due in part to deficiencies found in historical procedures governing the use of
"other forms" to document nonconforming conditions, the
CPRT performed a review of the current procedures and j
their implementation.
The results of this review is q
presented in the ISAP VII.a.2 Results Report (RR).
A discussion of the NRC inspection of this CPRT review activity follows.
!
The NRC inspector found that the CPRT had prepared a l
checklist of eight essential criteria to be considered i
~
for its review of current procedures for "other forms" of docp.menting nonconforming conditions.
(1)
The nonconforming item is properly identified.
(2)
The nonconforming condition is properly described.
I i
(3)
The disposition is identified as use-as-is, rework, repair, or scrap.
(4)
The NCR contains signature approval by appropriate level of personnel.
1 (5)
Reworked, repaired, and replacement items are inspected and tested in accordance with original requirements or acceptable alternatives.
,
(6)
An independent review is conducted of the nonconformance, including disposition and closecut by appropriately qualified personnel.
(7)
The nonconformance is included in the trend analysis process and reviewed for corrective action.
,
(8)
The nonconformance is reviewed to determine J
necessity for conducting further evaluation for
'
[
10 CFR 50.55(e) deportability.
.
This. checklist was used to review 124 current B&R and
TU Electric procedurer.
The NitC inspector compa. red the criteria of the checklist to the guidance in the SRP found the checklist addressed the essential elements of the SRP.
To evaluate the implementation of the checklist, the NRC inspector, reviewed 25 procedures selected from the CPRT l
list of procedure s, utilizing the CPRT checklist.
l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
A
__
_ _ - - _ _ _ _ _ _ _ _ - _ __ _ _.
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Examples of the procedures inspected by the NRC inspector are:
TU Electric Procedures Procedure Title Revision CP-QP-8.0 Receiving Inspection
QI-QP-8.0-2 Receiving Inspection
Instruction QI-QP-8.0-4 Receiving Bagged Cement
QI-QP-8.0-5 Receiving Commercial Grout
CP-QP-11.0 Civil Inspection Activities
1 QI-QP-11.0-1 Cadweld Inspection
Activities QI-QP-11.0-2 Reinforcing Steel,
I Miscellaneous Steel, and Embedded Item Placement Inspection QI-QP-11.0-3 Concrete or Mortar
Placement Inspection B&R Procedures CP-QAP-4.1 Design Control
CP-QAP-5.1 QA Review of Procurement
Documents
,
l l
CP-QAP-8.1 Receiving Inspection
CP-QAP-9.1 Permanent Equipment
Transfers i
CP-QAP-11.1 Fabrication and
i Installation Inspection
of Components, Components i
Supports, and Piping l
QP-QAP11.1-28 Fabrication and
i Installation Inspection of Safety Class Component Supports
l I
_ _ _ _ _ _.
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f
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i
]R CP-QAP-13.1 Control of. Measuring 4-and Test Equipment To evaluate the results of the CPRT review of how current i
'
procedures are implemented, the NRC selected and inspected:the'following traveler packages'(includes irs, NCRs, WDCs, and RPSs previously reviewed. by.ERC.-
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l Piping Packages FW-2-RB-025-SWF-1 DO-2-DG-042-FW-36
,
l MS-2-RB-026-ITT-2 CC-2-RB-093-1Q3 l
MS-2-RB-020-FW5 CC-2-RB-098-203 CC-2-RB-077-4Q3 CC-2-RB-087-3Q3 CC-2-RB-081-7Q3 SI-2-SB-001-W-13
,
Cable Tray Hangers Packages j
d CTH-11222 CTH-11227 j
CTH-10582 CTH-11458 j
CTH-10674 CTH-11410
The NRC review found that the traveler packages documented nonconforming conditions for the time frame of i
July through August 1986.
The NRC verified that for each i
,
package the nonconforming condition was properly identified on an IR or NCR.
The dispositions were reviewed by the NRC to determine if the' corrective actions specified were proper to. address the.
nonconformance and that the dispositions were approved by.
the appropriate organization; i.e.,-engineering and/or
!
J QA.
The documents by which repair or rework of'the nonconforming condition was accomplished were reviewed to determine if they were conducted in_accordance with the
,
controlling procedures.
This inspection verified that
'
l the item or condition was inspected to the current requirements, l
The results of the NRC and-the CPRT inspections agreed, i
that is, the procedures do not provide sufficient
guidance or detail for all the criteria of the_ checklist.
The CPRT has recorded this conclusion on QA/QC PDR-59,
~
which is'to be addressed by TU Electric.
j No additional violations or deviations were identified
during NRC inspection of the CPRT procedure review.
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f.
Housekeeping and System Cleanliness (ISAP VII.a.7)
(35743)
During this report period, the following ISAP activities
!
were reviewed:
i f
Review the Results of ISAP II.c and VI.a. (NRC Reference I
07.a.07.01)
{
i ISAP VII.a.7 required the issue coordinator to review the
'
results of ISAPs II.c and VI.a for adverse trends relative to housekeeping and system cleanliness.
These l
two ISAPs concerned debris found in critical spaces.
The issue coordinator stated this review was accomplished by a review of the preliminary results of those two ISAPs,
especially those sections describing how the debris came l
to be in the critical spaces and why it remained undetected.
The issue coordinator concluded from his l
review that there were no deviations relative to the i
housekeeping program noted in the ISAP results.
I To verify the issue coordinator's conclusien and to assure that the final published results of ISAP II.c and VI.a remained the same, the NRC inspector reviewed the l
issued results reports (RRs).
The RR for ISAP II.c, i
concerning debris found in seismic gaps, was issued as
'
l Revision 1 on December 17, 1986.
In Section 5.3, the RR i
'
l presented the as-found condition of the gaps.
The types of debris found included elastic joint filler material, Bisco fire sealant and damming material, concrete, wood scraps, rebar tailings, and dirt.
In Section 5.12, the l
l RR presented an assessment of the root causes and generic J
l implications.
The RR concluded that, "The root cause for I
the presence of debris in the seismic gap is inadequate
!
construction and QC procedures for the in-process protection and post pour inspection of the seismic l
gaps.
Had these steps been included in the
...
,
l inspection procedures, it is likely that significant debris intrusion would have been prevented or detected."
This indicated that improper identification by l
engineering, construction, and QC of the importance in l
maintaining the gap, and the lack of procedures to require maintenance of the gap was the root cause rather than a failure of the housekeeping / surveillance program to detect the debris in the gap and cause it to be removed.
I l
The RR for ISAP VI.a, Revision 1, was issued March 25,
'
1987, concerning debris in critical spaces such as the gap between the reactor pressure vessel reflective insulation and the biological shield wall.
In Section 5.8, the RR presented an assessment of the root f
l L
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'
causas and generic implications.
The root cause for the debris being present in the critical space could not be identified to one organization or requirement.
As to the root cause for the debris remaining undetected, the QA/QC Review Team made the following observations:
"1.
The historical housekeeping and housekeeping surveillance programs were typical of normal industry practice.
"2.
Housekeeping and housekeeping surveillance procedures did not address the cleanliness of critical spaces, and
"3.
Design specifications did not identify the critical nature of these spaces or define requirements for cleanliness and protection.
" Based on the above, the QA/QC Review Team postulated that the root cause was the failure of design and specifications to adequately define cleanliness requirements for critical spaces (documented with DIR E-0268)."
Based on the published results of ISAP II.c and VI.a, the NRC found the review and conclusions by the ISAP VII.a.7 issue coordinator to be proper.
No violations or deviations were noted during inspection of this activity and no further NRC inspection of this reference activity is planned.
Analysis of All Data (NRC Reference 07.a.07.06)
The NRC inspector interviewed the ISAP VII.a.7 issue coordinator concerning the methods used to perform the analysis required in paragraph 4.2.1.6 of this ISAP.
The issue coordinator stated that data considered in the analysis were from: other housekeeping related ISAPs, such as, II.c and VI.a; the project procedures governing housekeeping and surveillance activities; flush and swipe procedures; the surveillance report on housekeeping activities; and the CPRT conducted surveillance of plant areas.
The issue coordinator compared this data to the requirements found in Criterion XIII of 10 CFR Part 50, Appendix B, and paragraphs 17.1.13 and 17.1.15 of the CPSES FSAR.
The results of this analysis were issued in Sections 5.1 through 5.6 of the ISAP VII.a.7 RR.
The NRC inspector reviewed the ISAP working files and the data used by the CPRT in their analysis.
The CPRT collection of this data had previously been inspected by the NRC and reported in previous inspection reports under NRC
- - _ - _ - _ - _
.
,
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'
References 07.a.07.02,
.03,
.04, and.05 (see NRC
,
Inspection Reports 50-445/86-01, 50-446/86-01;
'
50-445/86-07, 50-446/86-05; and 50-445/87-11, 50-446/87-09).
The NRC inspector reviewed the results of CPRT's evaluation of ISAPs II.c and VI.a during this reporting period as reported under NRC Reference 07.a.07.01 above.
CPRT concluded from their evaluation that the current CPSES program for housekeeping activities, including surveillance, was in compliance with 10 CFR Part 50, Appendix B, and the commitments in the CPSES FSAR.
During this evaluation, CPRT found two program weaknesses.
B&R and TU Electric procedures for surveillance of housekeeping and storage contained minor inadequacies; such as, not identifying those areas to be surveyed in the procedures.
CPRT also determined that the current CPSES program for system cleanliness does not adequately define acceptance criteria.
The failure to
'
adequately define acceptance criteria was documented by CPRT in PDR No. QA/QC PDR-49.
Based upon review of the same data and specifically the procedures governing surveillance of housekeeping and storage activities, the site construction procedures detailing the requirements
'
for storage, housekeeping, and system cleanliness and flush plans / traveler, including their controlling J
procedures, the NRC found the CPRT conclusions to be proper.
No violations or deviations were noted during inspection of this NRC reference item and no further inspection of this reference activity is planned.
g.
Receipt and Storage of Purchased Material and Equipment (ISAP VII.a.9) (35065)
During this report period, the following activities were inspected.
Develop Reinspection Checklists for Material and Equipment Selected (NRC Reference 07.a.09.02) and Perform Field Inspection of Selected Material and Equipment (NRC Reference 07.a.09.03)
The purchased material and equipment samples selected for reinspection under this action plan were chosen by CPRT to represent a cross section of purchased items and to reflect the criteria listed in paragraph 4.1.2 of this ISAP.
NRC inspection of the CPRT sample selection of purchased material and equipment for compliance with the ISAP i
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.
'
requirements is ongoing and will be reported under NRC Reference 07.a.09.01.
To. verify the adequacy of the CPRT inspection of the selected purchased material and equipment for compliance with procurement specifications, a 10% sample of the verification packages prepared by the i
d CPRT for inspection of these items.was chosen by the NRC inspector.
The NRC sample for inspection was chosen based on previously identified-concerns with certain vendor supplied materials and included a cross section of material type; e.g.,
electrical, mechanical', and civil / structural.
To inspect this cross section of procured items, a team of five NRC inspectors with background experience in the areas'of electrical, instrumentation and control (I&C), mechanical, j
civil / structural, welding, and QA/QC was ucilized.
These
NRC inspections were' structured to duplicate the j
inspections already performed by CPRT-inspectors.
j a
l Verification packages inspected by the NRC during this f
j report period are listed below followed by the results of j
l the NRC inspections.
Item or Material Verification package Discipline Area Aggregate D-C-VII.a.9-099 Civil Structural Weld filler D-W-VII.a.9-084 Welding material
?
Control Valve I-M-VII.A.9.027 Mechanical
!
Cable I-M-VII.a.9-108 Electrical i
I Level indicating I-M-VII.a.9-032 I&C j
switch.
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l Verification Package D-C-VII.a.9-099
]
j This CPRT verification package was prepared for a documentation review of coarse and fine, high density aggregate procured under purchase order (P.O.)
i 35-1195-13501 and received under Receipt Inspection l
Reports (RIRs) 03562, 03570, 03576, 07849, 03568, 03575, l
06996, and 07851.
Requirements were defined in Gibbs &
Hill (G&H) Specification 2323-55-9, Revision 4,
" Concrete."
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. _ - _ _
.
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The NRC reviewed Specification 2323-55-9 and the CPRT checklist and found that the CPRT had properly included verification of the following items:
(1)
The aggregates are certified to conform to ASTM C637-75.
(2)
The material conforms to minimum specific gravity and maximum absorption values as specified in the G&H specification.
(3)
A Los Angeles Abrasion Test Report was submitted for coarse aggregate.
(4)
The fineness modules listed is in accordance with values specified in the G&H specification.
(5)
The gradation of the aggregates conforms to values listed in the G&H specification.
The NRC inspector reviewed RIRs for the checklist attributes and found that the CPRT had properly verified and documented all attributes including deficiencies.
CPRT issued DRs DC-VII.a.9-099-DR1 for failure to reference ASTM C637-75 and DC-VII.a.9-099-DR2 for failure to record the percent absorption in 6 RIRs for 17 of 24 rail cars of aggregate.
No violations or deviations were identified in this area of inspection.
Verification Package D-W-VII.a.9-084 This CPRT verification package was prepared for a review of the documentation required to support the quality of weld filler material procured under P.O. 35-1195-18590 and received under RIRs 7442, 13333, 20024, and 20956.
The P.O.
required the vendor to comply with specification WE-080, " Procurement Specification for Corrosion Resisting Chromium and Chromium-Nickel Steel Welding Rods and Bare Electrodes," Revision 10.
The NRC inspector reviewed specification WE-080 and the CPRT checklist and found that CPRT had properly included procurement requirements such as:
(1)
Electrode classification compliance with WE-080.
(2)
Certified Test Report (CTR) supplied for each heat number of material.
(3)
Delta ferrite content in compliance with WE-080.
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(4)
Chemical composition properties identified and in
.
compliance with WE-080.
(5)
CTR complete and accurate.
The NRC reviewed the four wcld filler material RIRs using the same checklist criteria and review techniques used by
,
CPRT and found that the CPRT results and the NRC results I
were the same.
No violations or deviations were identified during inspection of this verification package.
Verification Package I-M-VII.a.9-027
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This CPRT verification package was prepared for a documentation review and ficld inspection of a control valve, 1-HV-4178, purchased on P.O. CP-0600 and received on RIR 12917.
The procurement requirements were defined in G&H Specification 2323-MS-600, " Nuclear Safety Class Power Operated Control Valves," Revision 3.
The NRC reviewed the G&H specification and the CPRT checklist.
The NRC found that the CPRT had properly included inspection attributes from the specification such as:
(1)
Inclusion of documentation required by the specification; i.e.,
certified material test reports (CMTRs), hydrostatic test reports, NDE test reports, records of heat treatment, and ASME Code
]
certification.
'
i (2)
Verification that the chemicals and physicals listed i
on the CMTR for valve assembly parts, actuator l
assembly, valve operator springs, pneumatic tubing,
'
and diaphragm motor case were as specified in ASME Section II.
(3)
Verification that external physical dimensions of the valve body and operator were in accordance with the drawing.
i (4)
Verification of information on dath plates and nameplates.
(5)
Verification that attachments such as solenoid l
valves, limit switches, filter / regulator, and pressure gages were the type and size required.
(6)
Verification that electrical connections were the size and type required.
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l
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' 3 7..
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(7)
Verification that welded connections were of an I
acceptable weld quality.
I (8)
Verification that a record of performance testing by.
the vendor was supplied and that valve performance
as recorded on the test was acceptable.
The NRC inspector also reviewed those attributes
!
~
' determined by CPRT to be inaccessible and, based on field
'1 inspection, concurred that without dismantling of the i
valve they would be inaccessible..
l The NRC results from the'RIR review and the field inspection will be compared with the CPRT.results-when
.their effort on this verification package.is completed.
The NRC assessment:will be based on this comparison and documented in a future inspection report.
Verification Package D-E-VII.a.9-108'
]
This CPRT' verification package was prepared for documentation review of' cable types'W-047, W-052, W-151, W-751, and W-851.
Cable type W-151 was found to be in storage and accessible and therefore was also field inspected.
Since cable type W-151 was both a
documentation review and a. field inspection the NRC I
inspector chose cable type W-151 for review.
Cable type
,
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W-151 was procured under P.O. CPO465.2.C and received under RIR 08161.
The procurement requirements were l
defined in G&H Specification 2323-ES-13.B.1,." Low Voltage
]
Power, Control, Lighting and Grounding Cable," dated j
September 22, 1975.
The NRC' inspector reviewed the G&H i
specification and the CPRT checklist-and'found that CPRT had properly included in the checklist inspection attributes such as:
(1)
Information on cable reel, cable jacket, and
,
information tag was per the G&H specification e..g.,
l reel number, voltage, cable tray, and number and l
l size of conductors.
(2)
Cable jacket and conductors were. free of manufacturing defects and complied with the G&H-specification for color markings, and concentricity.
(3)
Cable physical characteristics and makeup were in compliance with the G&H specification'and
,
manufacturer's drawing.
'
(4)
Documents required by the. specification were supplied e.g. CTRs for dielectric, insulati-on resistance, and conductor resistance; physical ~ test
!
l I
l
. _ - _. - _ _ _. _ _ _ - _ _ - _ _ - _ _ _ _ - _ - _ - _. _ _ _ _ - _ _. - _ _ _ _ _ _ _ _ _ _.
.
.
report; certificate of compliance; and environmental qualification report.
'
The NRC inspector reviewed the documentation'in RIR 08161 and also inspected a 3-foot sample of cable for all physical characteristics of the CPRT checklists.
i The NRC results from the RIR review.and the field q
inspection will be compared with the CPRT results when their effort on this verification packages is completed.
The NRC assessment will be based on this comparison and i
documented in a future inspection report.
]
Verification Package I-M-VII.a.9-032 This CPRT verification package was prepared for a
'
documentation review and field inspection of a level indicating switch, 2-LIS-4754, purchased under P.O.
CP-0616 and received under RIR 21734..The procurement requirements were defined in G&H Specification 2323-MS-616, " Differential Pressure-Indicating Switches,"
Revision 1.
The NRC inspector reviewed the G&H specification, the CPRT checklist, and memorandum QA/QC-RT-4184.
This memorandum detailed the attributes
from the specification included in the checklist and the
'
justification for not including others.
The NRC found that CPRT had properly. included verification of such attributes as:
(1)
Correct information on data / nameplates.
(2)
External dimensions within tolerances as indicated on manufacturer's drawing.
(3)
Switch components and material in accordance with the G&H specification.
(4)
Proper documentati6n supplied as required by the G&H specification; i.e.,
certificate of compliance, hydrostatic test report, environmental qualification report, and seismic qualification report.
The NRC reviewed RIR 21734 for the checklist attributes
that were to be accomplished by document review and performed a field inspection of level indicating switch 2-LIS-4754 fbr those attributes verifiable in the field, The NRC found that the CPRT had properly verified and documented all inspection attributes including deficiencies.
The CPRT issued valid DRs I-M-VII.a.9-032 DR1, DRS, and DR6.
The valid DRs documented.the
.following deficiencies: dial indicators did not identify that increments were in inches, hydrostatic test duration
not specified, and instrument repeatability was not stated.
The NRC inspector also reviewed six DRs that were invalidated and found that suitable justifications for invalidating the DRs was provided in all cases.
No violations or deviations were noted for the ISAP VII.a.9 reinspection / document review activities.
NRC inapection of additional ISAP VII.a.9 verification
packages and the other ISAP VII.a.9 activities is planned-and will be reported in a future inspection report.
5.
Plant Tours (25401B, 51063, 52053)
The NRC inspector made frequent tours of the facility and observed such items as housekeeping, equipment protection and in process work activities.
The following observations were brought to the attention of the applicant:
a.
On June 16, 1987, the NRC inspector observed red jacketed j
conductors running from each of the control room chlorine
detector transmitters (X-AIS-5880-A and B) and recorders (X-AR-5880-A and B) in the air handling room in the auxiliary building, elevation 852'.
These four conductors appeared to be spliced together with another
{
conductor which was then routed from the area along the
'
outside of conduit C14K17465.
While the NRC inspector assumed that these conductors were part of a temporary modification, there was no evidence that this was the case (i.e., tagging or color coding as required by j
procedure); therefore, he requested clarification from j
the applicant.
The NRC inspector was informed by applicant QA personnel
,
on June 24, 1987, that these conductors were a permanent i
installation which was authorized by DCA 19862 Revision 2.
Review of the DCA disclosed no information i
concerning the exposed, unlabeled conductors in question.
The NRC inspector then rechecked the installation but was unable to discern any additional identification information.
Since the control room chlorine detection system was required by NUREG-0737, Item III.D.3.4, applicant personnel were recontracted and asked to provide more information on this installation.
On July 6, 1987, applicant personnel provided the NRC inspector a copy of Startup Work Authorization (SWA) 23454 dated October 9,
,
1984.
This SWA presented the installation of j
instrumentation ground leads on the subject instruments.
I In addition, facility drawings El-1703 (Note 17) and El-1703-01 (Table 2) were provided and found to contain
!
authorization for this type of grounding installation.
<
j
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a k
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b.
The WRC inspector also observed that the electrical leads l
to the steam generator main feedwater return valve j
1FCV-540, which is located out doors, remained l
disconnected and exposed to the elements.
The two I
safety-related Train A conductors were removed from l
conduit Cl3014209 where the valve flexible conduit had H
been disconnected from the rigid conduit.
The inspector, who had earlier assumed that this was work in progress, recognized that this condition had existed for some time and questioned applicant personnel on the status of this activity.
On June 24, 1987, the NRC inspector was informed that this condition was the result of work in process which
,
'
was authorized by Work Order (WO) C85-0003405.
A review of the WO package disclosed that it had been initiated to determine the status of environmental seal splices in the l
electrical cables -connected to a number of pieces of
!
equipment, including 1FCV-540.
The WO directed the j
determination of the connecting conductors for inspection i
I in accordance with NCR E05-100630S.
The WO package also contained a number of NCRs which were written during those inspections for conduits which exceeded the maximum i
'
allowable length and for broken Weidmuller terminal blocks.
The problems with the installation in question were documented in NCR E86-100222S, Revision 2, dated l
August 8, 1986.
The NCR reported that: 1) the conduit,
!
including the flexible portion, exceed the allowable 270
degrees of bends between pull points; 2) the installed
!
cable (E0118235A) was saturated with water; 3) the
!
conduit and junction box (JB1S-10120) had water and rust l
internally; and 4) the heat shrink cable splices in the j
conduit were more than the allowable 15 feet from the JB.
>
The disposition for this NCR called for rework, including the installation of an intermediate pullpoint, cleaning, and the installation of a new cable.
When the NRC inspector toured the area of 1FCV-540 on
June 24, 1987, he observed a work in process tag dated j
June 19, 1987, attached to the disconnected leads.
i c.
The NRC inspector requested information on what appeared I
to be the connector for the electrical (security) door latch to Room 69 in the Unit 2 safeguards building, l
elevation 790'.
This room houses the residual heat removal (RHR) and containment spray heat exchangers.
The i
connector pigtails were attached to the field cable with i
I the AMP preinsulated environmental sealed (PIES) splices I
l that were the subject of ISAPs I.a.2 and I.a.3.
Since the use of the PIES splices outside of control cabinets i
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F
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i
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i
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k had been the subject of previous discussions, the NRC inspector requested verification that their use in this
.{
application was acceptable.
Based on the information-
]
provided and the review of the applicable craft and QC
inspection procedures and the RR for ISAP I.a.3, the NRC inspector continued to be unsure of the allowable installation locations.
The NRC inspector requested clarification of allowable installation locations for the AMP PIES splices at the exit interview discussed at the end of this leport.
Applicant personnel agreed to provide the requested clarification.
No violations or deviations were ideutified.
6.
Pipe Support and Restraint Systems (50090)
a.
Status of Applicant's Work Activities i
During the public meeting held on October 2 and 3, 1985, in Granbury, Texas, the NRC Staff raised questions about.
the TU Electric program and the organizations involved in addressing the requirements of NRC IE Bulletin 79-14,
" Seismic Analysis for As-Built Safety-Related Piping Systems."
TU Electric commissioned a task group to
!
conduct an overall assessment of relevant activities associated with piping and pipe supp6rts at CPSES,
-
Unit 1.
The purpose of this assessment was to determine whether the existing programs are effective to ensure the adequacy and completeness of the as-built documents used in the stress requalification program being performed by Stone & Webster Engineering Corporation (SWEC).
Based upon an evaluation of several review programs, construction deficiencies have been identified involving completed pipe support installations.
In order to assess the full extent of these conditions, an extensive reinspection program is required.
The scope of this issue includes all Unit 1 and Common safety class piping and supports.
~
TU Electric has contracted SWEC to imple. ment the TU Electric Corrective Action Program which includes performance of a stress.requalification program for the safety-related piping and pipe supports at CPSES.
SWEC recommendations suggest that TU Electric develop two types of programs to organize any generic corrective action which deals with verification of specific attributes.
A hardware validation program (HVP) will address items such as loose, missing, damaged, or misaligned hardware.
A supplemental verification program (SVP) will address other items such as penetration seal
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requirements, tie-back supports, and insulation thickness.
The distinction between the two is that the HVP is geared towards tightening, replacing, or reworking the hardware so that there is no change to the as-built drawings, while.the'SVP.is geared towards documenting changes to the current requirements that could affect the stress requalification program.
The two programs will directly refer to the NCR and CAR procedures to ensure
!
that all TU Electric corrective action is appropriately addressed.
Currently, physical inspections of large and small bore pipe. supports are in process as part of the HVP.
This program is intended to assure that pipe supports meet the established design, fabrication, installation and regulatory criteria.- Rework, as required for acceptance, will be documented for each support.
Approximately 19,261 supports are involved in the Unit 1 and Common area program.
Unit 2 inspections will be performed as part of the normal final inspections required for support certification.
b.
Status of NRC Inspection Hardware attributes required to be verified by the HVP have been incorporated into Procedure CP-QAP-12.1,
" Quality Control Procedure for Mechanical Component
. Installation Verification."
For pipe support designs which are required to be modified, the applicable QC
.
procedure for inspection is QI-QAP-11.1-28, " Fabrication and Installation Inspection of Safety Class Component Supports."
During this inspection period, NRC inspectors performed documentation reviews and hardware inspections to
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determine whether the TU Electric work control system was functioning properly and whether the installation of safety-related pipe supports and restraints were in compliance with NRC requirements, applicant commitments, and applicable codes.
Individual checklists for documentation of inspection results were contained in a work package which was prepared for each component support.. The NRC inspectors j
performed a documentation review and field inspection of
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the associated hardware to determine whether the applicant was adequately preparing, reviewing, and
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maintaining a system of quality records.
The following work packages were inspected during this report period:
- _ _ _ _ _ _.
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l Support Drawing No.
Pipe Isometric-No'.
H-CS-1-AB-236-002-2 R/1 CS-1-AB-236
~
CS-1-319-003-S53R R/CP-1 CS-1-SB-016A'
i H-CH-1-SB-023A-011-3 R/1 CH-1-SB-023A i
CS-1-074-705-A42R n/3 CH-1-AB-005 CC-1-030-003-S33R R/CP-1 CC-1-SB-004-H-FW-1-SB-035-004-2 R/1 FW-1-SB-035 i
AF-1-097-003-S33K.R/0 AF-1-SB-021
.
l BR-X-057-712-A33R R/2 BR-X-AB-089 CC-1-040-014-E33R R/3 CC-1-EC-002 CC-X-078-010-A75D R/6 CC-X-AB-32-
CS-1-074-045-S42R R/2 CS-1-SB+051B j
i No violations or deviations were' identified.
i
Future NRC inspections will be performed ~to determine whether as-built design and construction drawings, and specifications correctly reflect the actual physical'
configuration of the plant.
These inspections will be i
performed subsequent to the issuance of vendor certified-I drawings (final as-built drawings) for each component i
support design and completion-of' activities in response to NRC IE Bulletin 79-14.
7.
Offsite Inspection Activity i
Office of Special Projects Headquarters staff visited SWEC on j
June 4 and 5, 1987, for the purpose of planning inspections of.
the Comanche Peak Design Basis Consolidation Program (DBCP),
!
specifically the mechanical, civil / structural, electrical, and
!
instrumentation / controls portions being performed'by the SWEC/ CAP organization.
SWEC is validating (and, where appropriate, replacing) 100% of the G&H safety-related
calculations, drawings, and specifications.
Validation
consists of reviewing the design documents to determine I
whether they adequately implement design. requirements compiled in Design Basis Documents.
,
The staff also reviewed the SWEC Engineering Functional Evaluation (EFE) program as it pertains tc the above SWEC/ CAP i
e effert.
TU. Electric stated that it plans to submit to the NRC a program plan for EFE third-party overview inspections.
For
'the above disciplines, EFE Will conduct a vertical slice
!
review focusing on the containment spray system..
!
8.
Unresolved Items
'
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
One unresolved item j
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,,
disclosed during this inspection is discussed in paragraph 2.e.
9.
Exit Interview (30703)
An exit interview was conducted July 7, 1987, with.the applicant's representatives identified in paragrapn 1 of this report.
During this interview, the NRC inspectors summarized the scope and findings of the inspection.
The applicant acknowledged the findings.
Mr. Warnick then indicated that significant progress had been made to resolve three concerns described in Inspection Report 50-445/87-09; 50-446/87-07, paragraph 7.
Resolution of the timeliness of the applicant's l
determination of deportability under 10 CFR 50.55(e) is in progress as documented in Inspection Report 50-445/87-08.
The applicant has identified the need to improve controls over system cleanliness and has initiated that action, as documented in Inspection Report 50-445/87-10; 50-446/87-08.
The applicant's NCR re-review program has been explained and this satisfactorily alleviated the NRC concern regarding whether NCRs dispositioned " invalidated," " rework," or " scrap" were included in the re-review.
In the exit, the NRC resident staff also discussed the following potential concerns:
(1) The NRC inspection of the j
nonconformance reporting system including documentation and
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dispositions is continuing; (2) The NRC inspection of the l
hundreds of NRC open items is progressing slowly.
The utility must complete its work before the NRC can inspect for closeout.
Based on the applicant's schedule, this process will have to proceed at a faster pace to avoid a log jam prior to the applicant's projected date for readiness to receive a license; (3) The timeliness / completeness of information j
provided to the NEC during inspections or in applicant responses to notices of violations and deviations appeared to be a problem.
Although the NRC inspectors try to obtain all'
applicable information during an inspection, there have been instances recently where new information was provided in the responses.
In addition, some responses have not been factually correct.
The examples discussed were two responses cited in Inspection Report 50-445/8706; Inspection Report 50-446/8705.
Mr. Counsil asked that he be informed of any additional examples of the applicants lack of timeliness or completeness which might be identified by the NRC.
Mr. Warnick agreed to keep him informed.
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