ML20028F052
| ML20028F052 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/27/1983 |
| From: | Rothschild M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Cole R, Mccollom K, Mark Miller Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8301310069 | |
| Download: ML20028F052 (26) | |
Text
1 January 27, 1983 Marshall E. Miller, Esq., Chairman Dr. Kenneth A. McCollom Administrative Judge Administrative Judge Atomic Safety and Licensing Board Dean, Division of Engineering, U.S. Nuclear Requlatory Commission Architecture and Technology Washington, DC 20555 Stillwater, OK 74078 Dr. Richard Cole Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 In the Matter of Texas Utilities Generating Company, et al.
(Comanche Peak Steam Electric Station, UnTts r and 2)
Docket Nos. 50 445 and 50-446
Dear Administrative Judges:
In reviewing the record on Contention 5, the Staff has noted that although NRC Staff Exhibits 10,11 and 12 (relating to the rock overbreak) were marked for identification, they uere not moved and admitted into evidence. The record indicates that these exhibits have not been admitted due to a failure to move their admission rather than the objection of the other parties.
Staff Counsel has contacted the other parties and they have authorized Staff Counsel to represent that they do not object to the admission of the exhibits which were marked for identification as follows:
NRC Staff Exhibit 10 (letter from the NRC to the Applicants, dated April 22, 1975),*.r. 1275, NRC Staff Exhibit 11 (NRC Inspection Repcrt 75-06), Tr. 1277; NRC Staff Exhibit 12 (NRC Inspection Report 75-07), Tr.1277.
The Staff requests that such exhibits be received into evidence as NRC Staff Exhibits 10, 11 and 12.
In addition to providing copies to the service list, we are transmittino the appropriate number of copies to 0301310069 830127 PDR ADOCK 05000445 C
PDR f
i 2_
the NRC Docketing and Service Branch for inclusion in the record if the Board so directs.
j Sincerely, 1
Marjorie U. Rothschild Counsel for NRC Staff
Enclosures:
NRC Staff Exhibits 10, 11, and 12 cc w/encis: Service List DISTRIBUTION:
MURothschild GSMizuno SETurk SATreby MKarman SBurwell-316 Jtieoerman JMJrray ESchristen'oury ELD FF (2)
DMB-PDR/LPDR 0/C Chron J
bC07 0FC :0 ELD
-_-__:____ &____::0 ELD NAME :MRothschild :SATre y DATE :1/11/83
- 1/77/83 N
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- A."
- NRC Staff Exhibit D
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April 22, 1975
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Texas Utilities Generating Company Docket Nos. 50-545 3?
ft ATTN Mr. Perry G. Brittain 50-446 President
'k 7001 Bryan Tower I! 5 Dallas, Texas 75201 ka b
1 Gentlemen:
3 ;)
This refers to Mr. Caudle's lettsr of April 8, 1975, in reply to our
[,j 1stter dated Harch 6, 1975, and acknavledges our telephone conversation with Mr. Caudie on April 17, 1975.
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.,g With respect to the deficiency identified in IE Intpection Report No.
,k; 75-05,Section I, item A.3.a. this natter is still considered valid., This I\\
view is based ca the context of the Gibbs and 1H11, Inc. specification No. 2323-SS-6 and the Brown and Root, Inc. procedure CP-QCP-12. Based 1?
upon our telephone conversation with Mr. Caudle, it is our understanding
...l,'b-that your staff will initiate revisions to these two documents to obtain consistency with your current ad=fn4=trative controls for Class I structure' 'y'. [-
excavation.
M jh Regarding your Limited Work Authorisation, dated June 17, 1974, it is the view of this office that excavation activities for safety related structures,O:.
such as blasting, are within the meaning of all activities affecting safety,'I.'
related functions of those structure and pertinent requirements of.10 CPR 50...
j Appendix B, should apply.
(Referenca Regulatory Guide 1.29) Inviewof-j p 'k the variance in interpretation regarding excavation associated activities, -
such as blasting, this matter has be'en referred to the Office of Inspection,
i %N and Enforcement, Headquarters, for clarification and resolution..
Should you have any questions regarding the above, we will be pleased to h
discuss them with you.
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Sincerely,
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G. L. Madsen, Chief Raactor Construction and
.5, Operations Branch n
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yg so. JAIS NRC Staff ExMbit kI
- fezar Utilities Generatint Con:pany Dochet :.os. 50-445 f*M
/.11... lir. Ierry G. trittain 50-446 President 2N1 Lrya:: iowcr Lc11as, ' texas 75:..il Get.:1e:x.:
'fais refers to the inspection conducted by Messrs. K. C. Stewart and U. L. 1.utacul. of thi:, cffice on April F il, 1975, of activities cuenorized by ;;i;; Cur.struction Portit Isos. CFTP.126 and 127 for the Lo=sne.u. Iu;. facility. Units 1 and 2. and to the discussior. of the findin;;c i.elo cy the inspectors with Haasrs. h. U. Caudle,*d. C. Schmidt anc ot:4er ec:_.,ers cf your staff at the conclusion cf the inspection.
t.rwar c<.az ined during the. inspection and our findin;:s are discussed in ti.6 e.ucle.u inspectic:: report. Uitigin these areas, the inspection con-sistes of sclective examination of procedures and representativc.
recorcs, interviews with personnel, and observations by the inspector.
. uri:.t; the in:poccion 1: was found that certnir, activitics under your lice 2se ap; ear te oc :Lu nonco.:;diance with N pcudi). E'te 10 CTi. Su of the !.T.C Rerulatient,, Quality Assurance Criteria for ;.ucir.ar Power Ilantr.'.
- tie iteis of nouco=pliance and references to the pertinent require
- , ants are toentified in Sectior.1 of the susar. arf of the enclosed report.
Purnusnt to the provisions of Section 0.201 cf the ;.T.C'r "kules of Proctacu. : :r t.
'..itle 11:. Cnec of herr.1..c;.ulctic:.c.
Section Z.22 rquire.- yu tc sul:.it to this offics, it*i;. 3.- days of your receipt of this notice, a written statenent or explanation in reply including: (1) corrective steps which have beca taken by you, and the resulte achieved; (1) corrective steps which will be taken to avoid furtuur nonco=pliance; and (3) the date when full compliance vill bc l
achieved.
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Texas '.'tilities Cenerating Company MJ in accordance with Section 2.790 of the h2C's " Rules of Practice",
Part 1, Ziele 10. Coue of Federal.;4s;ulations, a copy of this letter aad the enclosed inspection report will be placed in the.<RC's Public Jocunent Koon.
If tse report contains any information that you believe to be propriatarf, it is nacessary that you sub=1t a written applic-2cioc to this office, within 2u Jays of the date of this letter, requestin:; that auch infot: ation he withheld from public disclosure.
.ha apslicacica cant include 2.~ull taccuut of cue reasona.;.y it is ci. Lined c..at tha iafor-acio2 ta proprietary.
ha appilcation.;nould be prepared so that any :roprietary information identified is contained an enclosure to the application, since the application without c w 4-enclosure vill also be placed in the Public eccument noon.
If ue do not hear frc:2 ycu in tais regard within the specified period, tne r.: port will be placsd in the ?'ablic Docu= ant " loon.
Lould jou havet 2ny questions concerning this inspection, se vill 'se pleas % to discuss c. c vich you.
Sincerely, Orismat Signea By Glen L linesen G. L. Hadsen, Chief,-
?.eactor Construction and Cperations 2 ranch r.nclosure:
IE Inspection.'eport *:os. 50-443/75-06 30-446/75-06 cc:
Texas Utilities Cenerating Company
.tTTN:
R. *!.
Caudie, Project ::anager 20J1 ;,rjan icwer
- allas, Texas 75201 bec
- v/0 enclosure
- 11. D. Thornburg, C:EQ (1)
C:HQ (1)
JR Central Files (1)
L: liq (4)
- ' SIC State of Te
- :as ":epartnant of Health
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U. S. NUCLEAR REGt1ATORY C05 FISSION OFFICE OF INSPECTION AND C.70RCE"NT REGION IV IE INSPECTION REPORT NOS.
50-445/75-06 DOCKET NOS. 50-445 50-446/75-06 50-446 APPLICANT:
Texas Utilities Generating Co=pany CATEGORY A2 2001 Bryan Tower Dallas, Texas 75201 FACILITY:
Comanche Peak Steam Electric Station Units 1 & 2 LOCATION:
Glen Rose, Texas TYPE OF LICDISEE:
TYPE OF INSPECTION:
Routine, Unannounced DATES OF INSPECTION: April 9-11, 1975 DATES OF PREVIOUS INSPECTION:
February 27-I8, 1975 p > >gm/D M/
Principal Inspector:__R.~C'. StehtGeT Reactor Inspector
'/Date Accompanying Inspector:
- ere: -
F W. G. Hubacek, Reacto M nspector Date 3
Other Accompanying Personnel: None Reviewed By:
O I
W. A. Crossman, Senior Reactor Inspector Date
SUMMARY
OF TINDINGS I.
Enforcement Action A.
Items of Noncompliance 1.
Violation None 2.
Infractions 75-06/A.2.a Organizational / Functional Alignment Contrary to 10 CTR 50, Appendix B, Criterion II, Construction Department personnel were performing QC inspection and acceptance activities which are not designated functions of that organization.
(DETAILS, paragraphs 3.a. 3.b and 3.j) 75-06/A.2.b QC Inspection Procedures Contrary to 10 CFR 50, Appendix B, Criterion V,
implementing BAR QC inspection procedures, or instructions, were not available that would verify conformance with the requirements prescribed in B&R CP-QC-14, " Concrete Inspection and Testing", dated
/
March 6, 1975.
(DITAILS, paragraph 3.b) t 3.
Deficiencies 75-06/A.3.a
' Batch' Plant'QC~ Inspection and Qualification Contrary to 10 CFR 50, Appendix 3, Criterion I",
QC inspection activities were conducted by individuals reporting to an organization who's functional authority is not independent of undue influence'and responsibilities for schedules and costs.
(DETAILS, paragraph 3.a. 3.j)
B.
Deviations None II.
Licensee Action on Previously Identified Enforce =ent Matters 75-05/A.3.a QA/QC Procedural Deficiency The licensee has responded by letter dated April 8, 1975, pursuant to the provisions of section 2.201, part 2, 10 CFR.
The response is currently under review.
This matter remains unresolved.
(continued)
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III.
New Unresolved Items 1.
Procedure Develooment and Control Established methods for the development and control of QA/QC Trocedures was not apparent.
(DETAILS, paragraph 3.c) 2.
NDE Procedures - Schedules and Titles A listing (Titles) and issue date schedule for the development of NDE QC inspection procedures was not available.
(DETAILS, paragraph 3.d) 3.
TUSI QA Site Surveillance Staff - Duties and Responsibilities The TUSI QA site organization, individual duties and responsibilities, need further clarification.
(DETAILS, paragraph 3.e) 4.
B&R OA/QC Site Organization - Duties and Responsibilities The B&R QA/QC site organization, individual duties and responsibilities, need further clarification.
(DETAILS, paragraph 3.f)
L 5.
B&R QA/QC Manuals - Revision Up-Date l
A B&R QA Manual, assigned to a member of the B&R field staff, was observed to be outdated.
(DETAILS, paragraph 3.g) 6.
Reinforcing Steel
' Test Discrepancy Contrary to BaR. Construction Procedure 35-1195-CCP-8, the QA Records indicate that reinforcing steel metallurgical tests were not conducted by an independent laboratory.
(DETAILS, paragraph 3.h) 7.
TUSI QA Site Surveillance - Followup Action The TUSI QA Plan does not appear to sufficiently describe requirements for timely followup action to correct deficiencies identified during site construction surveillance activities.
(DETAILS, paragraph 3.1)
IV.
Status of Previous 1v Reoorted Unresolved Items None V.
Design Changes None VI.
Unusual Occurrences None (continued)
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Other Significant Items None VIII.
Manneenent Interviev On Apr_1 11, at the conclusion of the inspection, a management =eeting was held with the folicwing licensee representatives in attendance:
Texas Utilities Services Inc. (TUSI)
R. W. Caudle, Project Manager i
A. H. Hickman, Project Engineer H. C. Schmidt, QA Manager C. H."Catchell, Resident Manager R. G. Tolson, QA Engineer Brown & Root, Inc. (B&R)
K. M. Broom, Manager - Power Services L. A. Ashley, Construction Manager H
C. Dodd, Project Manager W. E. Childress, Jr., Project Engineer P. L. Bussolini, Project QA Manager J. B. Loth, Project QA Coordinator D. L. Hansfori., QA/QC Engineer Cibbs & Hill (C&H)
J. J. Moorhead, Resident Engineer R. V. Fleck, QA Supervisor J. V. Hawkins, QA Specialist The inspection findings, as contained in the summary and details sections of this report, were discussed.
In addition, the QA/QC Procedural Deficiency (75-05/A.3.a), identified during the previous inspection, was reviewed and discussed.
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' DETAILS Persons Contacted Texas Utilities Services, Inc. (TUSI)
R. W. Caudle, Project Manager R. H. Hickman, Project Engineer H. C. Schmidt, QA Manager C. H. Catchell, Resident Manager R. G. Tolson," QA Engineer Brown & Root, Inc. (B&R)
K. M. Broom, Manager - Power Services L. A. Ashley, Construction Manager H. C. Dodd, Proj ect Manager '
W. E. Childress, Jr., Project Engineer P. L. Bussolini, Project QA Manager J. B. Loth, Project QA Coordinator D. L. Hansford, QA/QC Engineer B. G. Banks, Concrete Superintendent R. E. Morris, Batch Plant Superintendent Gibbs & Hill (C&H)
J. J. Moorhead, Resident Engineer R. V. Fleck, QA Supervisor J. V. Hawkins, QA Specialist Mason-Johnston & Associates (MJA)
- 3. V. Dreyer, Chief of Engineering, Geology H. C. Crowder, Field Geologist W. T. Cromaans, Resident Chief Technician R. W. Hunt B. Kinkade, Lead Level II Inspector l
R. Gutierrez, Level II Inspector J. J. Joseph, Level I Inspector Report of Subjects Inspected 1.
Scope of Inspection The inspection was limited to the review of site QA/QC grogram procedures and implementation as it applies to work activities regarding safety related I
structures in the initial construction phase.
The inspection included the review of QA/QC records and observation of the work in the areas of the l
l (continued) w_.
~6-rcccter building containment excavation and preparation for concrete placement, concrete batch plant qualification, and the safe shutdown inpoundnent dam (SSI Dam).
2.
Plant Progress The overall plant construction progress is reported as 1.0% complete.
Reactor building containment excavation to base mat elevation is essentially complete for units 1 and 2.
Excavation is continuing in the auxiliary building and fuel building areas.
The concrete batch plant units are operational; however, only the back-up unit (100 cu. yds /hr) has been qualified to Nationa1 Ready Ptix Concrete Association (NRMCA) requirements at this time.
Acceptable rock for tha SSI Dam fill has been located on site; however, surveys are continuing in an effort to find a source closer to the_SSI Dam in order to reduce haul distance and excessive handling.
Preparations are being made to start installation of a coffer dam, to divert creek water, at the SSI Dam site.
3.
QA/QC Procedure Review The inspector reviewed TUSI and B&R QC program procedures covering the areas of procurement; material certification; shipping, receipt and storage; and installation.
B&R procedures reviewed included:
ACP-3
" Material Receiving and Handling" CCP-10
" Concrete Batch Plant Operations" CCP-18
" Reinforcing Steel Activities" GCP-4
" Coordination of Field Procurement Activities" QCP-8
" Field Purchasing" QCP-10
" Material Receiving, Storage, Handling and Maintenance" QCP-14
" Concrete Inspection and Testing" QCP-15
" Reinforcing Steel Inspection and Testing" TUSI CPSES QA Plan review included:
Section 2.4
" Procurement Administration" Section 2.8
" Inspection and Surveillance" Section 3.1
" Material Receipt Surveillance" Section 3.2
" Storage and Handling Surveillance" Section 3.12
" Identification and Centrol of Material Parts and Components Surveillance" (continued) e t
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During the above review, the following were the IE inspection findings:
a.
Batch Plant QC Inspection and Qualification During the review of the B&R Procedure, CP-QCP-14. " Concrete Inspection and Testing", dated March 6, 1975, it was observed by the inspector that the concrete batch plant (back-up unit) had been certified in accordance with the NRMCA requirements February 20, 1975, and the " Certificate of Conformance for concrete Production Facility" was signed by a professional engineer, who is assigned to the construction project manager's staff.
In discussing this matter with the B&R QA Project Manager, the IE inspector was informed that the QC inspections and qualifications o( the concrete batch plants have been assigned to the construction project manager.
In addition, the concrete batch plant operations are performed by B&R personnel-under the supervision of a B&R superintendent and whose functional authotity is also directed by the construction project manager.
Neither the B&R QA/QC Program, nor the B&R Procedure, QCP-14, identify the implementation of the QC inspection activities, and functional authority, as currently being conducted.
Criterion II of 10 CFR 50, Appendix B, states in part, "... The applicant shall identify the structures, systems, and components to be covered by the Quality Assurance program and the major organiza-tions participating in the program, tonecher with the designated functions of these organizations." (Emphasis added)
In addition, Criterion I of 10 CTR 50, Appendix B, states in part, "Such persons and organizations performing quality assursace functions shall report to a management level such that this required authority and organiza-tional freedom, including sufficient indeoendence from cost and schedule when opposed to safety considerations, are provided".
(Emphasis addet)
This matter is identified by the IE inspector as an Item of Noncom-pliance with Appendix B to 10 CFR 50 of the NRC Regulations, Criteria I and II, as highlighted above.
(See item 3.j below) b.
QC Inspection Procedures During the review of B&R Procedure, CP-QCP-14. " Concrete Inspection and Testing", dated March 6, 1975, it was observed by the inspector that the procedure sets forth the QA requirements for the concrete placements for safety related project structures; however, neither implementing QC inspection procedures that would verify confor=ances to the stated QA requirements were provided, nor were the divisions of functional implementation by organizations identified (i.e., B&R inspection functions versus functions delegated to other inspection organizations).
This matter is identified by the IE inspector as an Itum of Noncom-pliance with Criteria II and V, Appendix B, 10 CFR 50, NRC Regulations.
(continued) 1 a.
- ~
j c.
Procedure Development and Control The B&R Quality Assurance / Control Manual does not contain a QA/QC Procedure that prescribes the methods for establishing format and control of QA/QC Procedures.
In discussing the subject with the B&R QA Project Manager, the IE inspector was informed by the QA Hanager that the QA/QC Procedura being utilized and which prescribes the above procedural controls is B&R QCP-5.
The document was originally included in the " Project Engineering, QA/QC Manual" and is currently being revised for inclusion in the site QA/QC Manual.
This item is considered unresolved and will be reviewed during a subsequent IE site inspection.
d.
NDE Procedures - Schedule and Titles During the inspector's review of procedures centained in the B&R Quality Assurance / Control Manual, the inspector observed that procedures which provide the implementation for QC inspection activities related to specific NDE requirements were not included in the QA/QC Manual.
The inspector was informed by the QA Project Manager that the specific NDE procedures are being developed; however, a listing and titles of these procedures are not available at this time.
This item is considered unresolved and will be reviewed during a subsequent II inspection.
TUSI QA Site Surveillance Staff - Duties and Responsibilities e.
During the inspector's review of the TUSI CPSES QA Plan, Section 1.0, Revision 2, dated April 1,1975, it was observed by the inspector that the specific duties and responsibilities for G&R-QA
.and TUSI-QA staff are not clear as to individual assignments; furthermore, Section 3.0 of the Manual refers to "The Site Quality Assurance Supervisor".
The newly revised Section 1.0 of the Manual does not identify this position.
During a subsequent discussion with the TUSI QA Manager, the inspector was informed that the matter appears to be an oversight and the specific sections will be reviewed for corrective measures.
This item is considered unresolved and will be reviewed by the IE inspector during a subsequent site inspection.
f.
3&R QA/QC Site Organization - Duties and Responsibilities The inspector observed that the B&R Procedures Manual does not clearly establish, and delineate in writing, the authority and duties of the site QA/QC supervisory staff performing activities within the QA/QC organization.
(continued)
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In discussing the matter with the B&R QA Project Manager, the inspector was informed that the B&R QA/QC site organization was in the final stages of formation.
The organization chart has been developed.
The authority and duties of the supervisory positions will be described and delineated in writing.
This item remains unresolved and will be reviewed during a subss uent site inspection.
g.
B&R QA/QC Manuals - Revision Update
.During the inspector's procedura review it was observed that Manual No. 41 did not contain Procedure CP-QCP-10.
In addition, it appeared that the index section was not updated to reflect the latest revisions.
The QA Project Manager informed the IE inspector that the matter would be discussed with the person to whom the manual was assigned in order to establish the reason for the out-dated condition of the manual.
This item remains unresolved and will be reviewed during the next IE inspection.
h.
Reinforcing Steel - Test Discrenancy Review of records for reinforcing steel revealed that tesiing of rebar supplied by the Bethlehem Steel Corporation (BSC) for CPSES was performed by the BSC Metallurgical Department.
This appears to be contrary to the requirement for independent tests stated in B&R Construction Procedure 35-1195-CCP-8, " Reinforcing Steel Activities", paragraph 4.4.1, which states in part, "B&R QC Department shall monitor the results of confirmatory tests which are performed by an independent laboratory (one per 50 tons of metal) to insure compliance with G&H Specification 2323-SS-10 prior to acceptance of the rebar."
"his matter remains r.nresolved and will be reviewed during a subsequent IE inspection.
1.
TUSI Site QA Construction Surveillance The inspector e.xamined reports of site QA surveillance required by Section 3.0 of the TUSI CPSES QA Plan.
Reports reviewed included:
C-001-75 " Receipt Inspection by B&R QC of Bulk Cemenc" performed January 31, 1975.
C-002-75 " Receiving of 3/4" QA Approved Bulk Aggregate" l
performed March 5. '975 (continued) p-
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t c'003-75 "Rebar Storage" performed March 14, 1975 C-004-75 "Rebar Storage" performed March 20, 1975 r
C-005-75 " Concrete Back-Up Batch Plant Certif'ication" performed April 9, 1975 C-006-75 "Shoterate Batching and Placing" performed April 11, 1975 A draf t memo to file, prepared by the B&R Project QA Manager, which addressed reports C-002-75,. C-003-75 and C-004-75 was reviewed by l
the inspector.
The surveillance appeared to have been conducted in accordance with established procedure, however, the guidance in the TUSI CPSES QA Plan does not appear to sufficiently define the mechanism for insuring timely follow-up action on identified nonconformances or deficiencies.
This item remains unresolved and will be reviewed during a subsequent IT. site inspection.
j QC Record Review The inspector examined QC records relating to receipt and storage of cement, aggregates, admixtures and reinforcing steel.
Review of QC records for concrete and admixtures revealed that personnel from the B&R Construction Department have been utilized
'p as Receiving QC Inspectors.
As a specific example, the Material Received Record for admixtures received March 17, 1975 was signed by an individual from the Construction Department.
This matter is considered to is in noncompliance with NRC Regulations, Criteria I and II, of 10 CFR 50, Appendix 3.
This matter has been brought to the attention of the licensee in conjunction with item 3.a above.
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NRC Staff Exhibit kk June 11,1975 Texas ttilities Generatig Cocpany boeket ::os. Sk445 gg A T:::
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Perry C.. hrittain 50-440 President 2001 brycr. Iower ballas, iexas 752C1 Gentie:sen:
This refers to the inspection conducted by Messrs'. h. C. Stewart and K. C. hubacch of this office on May 26-30, 1975, of activities authorized 1y ::1.C Construction Permit !;os. CPPTi-126 and 15 for the Co=anche Paal facility, Units 1 and 2, and to the discussion of the findings held by the inspectors with Mr. E. C. Sch=idt and other re bers of your st Tf at the conclusion of the inspection.
Area 6 2xacined during the inspectier and our findings are discussed in the enclosci inspection report. Within these arc c, the inspection consistec' of selective er.ar.ination of procedures at.d representative recorde.. interviews s-ith personnel, and observations by the inspectors.
Withir. the scope of the inspection, no itent of nonce =nliance were ider.tifin..:.
Uc have also exat.ined actions you have taken s-ith regard to previously identified enforcement matters and unresolved itens. The status of these iteme is identified in Sections II and IV of the succary of the enclosed rcport.
In accordance vit!. Sectic. 2.790 of the 2C's 'T.ulcr. of Practice,
Tart 2, 71tl 1~.
Code of Tcdcrr.1 Kerulatione, r. cepy of this letter and the enclosed inspectien report vill be placed in th< !7.C's Public Locument koor.
If the report contains any inforentio. that you believe to be proprietary, it is necessary that you subcit a written application to this office, within 20 days of the date of this letter, requesting that such information be vithheld free public disclosure. The applica-tion cust include e full statenent of the reasons why it is claist.cd n._
T4::as Utilities Generating Company that the infor=ation is proprietary. The application should be pre-pared so that any proprietary infor.ation identified is contained in an enclosure to the application, since the application without the If we do enclosure will also be placed in the Public Document Room.
not hear from you in this regard within the specified period, the report vill be placed in the Public Document 11oom.
Jhould you '.nw any questions concerning this inspection, we will be pleased to discuss then "ith you.
Sincerely, II[
J.
Af C. L. :tadsen, Chief,
'eactor Construction and Operations tranch
".nclosure:
It Inspection Report ::es. 53-445/75-07 30-446/75-C7 Texas Utilities Generating Co=pany cc:
..T"':1:
R.
- d. Caudle, Project :-tanager 2001 3ryan Tover Dallas, Ta.tss 75201 v/o enclosure bec: H. D. Thornburg, IE:HQ (1)
IE:HQ (1)
DR Central Files (1)
L:HQ (4)
- SIC State of Texas Department of Health 4
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U. S. NUCLEAR REGULATOR ** ColeiISSION OFFICE OF INSPECTION A!C ENTORCDfENT REGION IV IE Inspection Report No. 50-445/75-07 Docket No. 50-445 50-446/75-07 50-446 Applicant:
Texas Utilities Generating Co:pany Category A 2 2001 Bryan Tower Dallas, Texas 75201 Facility:
Comanche Peak Steam Electric Station Units 1 & 2 Lor.ation:
Glen Rose, Texas Type of Licensee:
W. PWR,1161 }{W(e)
Type of Inspection:
Routine, Unannounced Dates of Inspection: May 28-30, 1975 Dates of Previous Inspection: April 9-11, 1975 Principal Inspector:,S A_. W /_.[ w d 4 /// />h plR.C. Stewart, Reactor Inspector
'Date
~
Accompanying Inspector:M. DN/,. fY,l.b S/// [>S-
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W. G. Hubacek,'Reac:or Inspector Date Other Accompanying Personnel:
None Re.rieued py:
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[~n W. A. Crcssman, Senior Reactor Inspector Date 4
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SUt(ARY OF FDJINGS I.
Enforcement Action A.
Itens of' Noncompliance 1.
Violations
.None 2.
Infractions None 3.
Deficiencias None B.
Deviations None II.
Licensee Action on Previously Identified Enforcement Matters 75-05/A.3.a QA/QC Procedural Deficiency The licensee has initiated changes to the QA/QC Procedure, QP-QCP-14,
" Concrete Inspection and Testing", and the G&H Specification No. 2323-SS-6 to obtain consistency with the current administrative controls for the excavations of seismic Category I Structures; however, matters relative to QA/QC activities during' blasting for sais_ic Category I structures remain.
unresolved 1_/.
75-06/A.2.a Organizational / Functional Alignment The B&R Procedure, CP-QCP-14, " Concrete I:spection and Testing", was revised effective May 8, 1975.
The newly revised procedure identifies the division of functional implementation by organization and identifies the B&R QA/QC 1
surveillance requirements.
In addition, the B&R site QC organization bas been realigned and designated QC functions have been implemented.
These corrective actions are in accordance with the licensee's letter dated May 29, 1975.
This item is closed.
75-06/A.2.b QC Inspection Procedures l
The B&R Procedure, CP-QCP-14, " Concrete Isspection and Testing", has been revised to include implementing QC inspec-ion procedures and the inspection functions delegated to other organizations have been identified. These i
(continued) 1_/ Letter, G. L. Madsen to P. G. Brittain, dated 4/22/75.
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This ites is closed.
i 75-06/A.3.a Batch Plant QC Inspection and Qualification t
The B&R Procedure, CP-QCP-14. " Concrete Inspection and Testing" was revised effective May 8, 1975. The revised procedure contains the requirements l
for B&R site QA/QC personnel to conduct periodic surveillance activities associated with the batch plant certification requirements. The inspector reviewed the B&R QC surveillance records and had no further guestions. This item is considered resolved.
i III.
New Unresolved Items t
None i
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IV.
Status of Previously Reported Unresolved Items s
1.
Procedure Development and Control l
B&R has issued a procedure which covers the development and control of -
QA/QC procedures.
This item is considered resolved.
(DETAILS, paragraph 3) l 2.
NDE Procedures - Schedules and Titles l
B&R has provided a listing of titles and issue dates for NDE QC inspection 4
procedures.
This item is considered resolved.
(DETAILS, paragraph 4) 3.
TUSI QA Site Surveillance Staff - Duties and Responsibilities TUSI is currently revising their QA plan to include a more detailed description of the duties and responsibilities of the TUSI Site QA Surveillance Staff.
This item will remain open pending issuance of the revision and subsequent review by IE.
(DETAILS, paragraph 5)
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B&R.QA/QC Site Organization - Duties and Responsibilities l
B&R is developing a procedure which will cover their site QA organization.
This item will remain open pending issuance of.the procedure and review by IE during a subsequent inspection.
(DETAILS, paragraph 6) 5.
B&R QA/0C Manuals - Revision Update i
j Corrective action to update QA manuals has been completed.
This item
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is considered resolved.
(DETAILS, paragraph 7) l I
6.
Reinforcing Steel - Test Discrepanc7 I
B&R Construction Procedure 35-1195-CCP-18 has been revised to eliminate the test discrepancy.
This item is considered resolved.
(DETAILS, paragraph 8)
(continued) i i
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_Cibbs & Hill (C&H)
J. J. Moorhead, Resident Engineer R. V. Fleck, Site QA Supervisor J. V. Hawkins, Site QA Representative The inspection findings, as contained in -he Sunssary and Details Sections of the report, were discussed.
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TUSI QA Site Surve111snee - Followup Action TUSI is developing a revision to their QA plan which is to clarify the requirements for followup action. This item will remain open pending issuance of the revision and review by IE during a subsequent inspection.
i (DETAILS, paragraph 9) 8.
IE Bulletin S{.ntus 75-05 Hydraulic Shock and Sway suppressors The licensee response is due June 12, 1975.
9.
CDR-H00507F4 - Reactor Building Over-Excavation The licensee is continuing geological capping of the area. A finai report is to be submitted when corrective measures are finalized. This item remains unresolved.
V.
Design Changes None VI.
Unusual Occurrences a
None VII'.
Other Significant Items None
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VIII.
Management Interview On May 30, at the conclusion of the inspection, a meeting was held with tha following licensee representatives in attendance:
Texas Utilities Services, Inc. (TUSI)
C. H. Catchell, Resident Manager H. C. Schmidt, QA Manager P. M. Milam, Site QA Supervisor Brown & Rect, Inc. (BER) i L. A. Ashley, Construction Manager H. C. Dodd, Proj ect Manager C. E. Bonin, Assistant Project Manager P. L. Bussolini, Project QA Manager
- 3. L. Hansford, QC Engineer, Civil (continued) l
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-s-DETAILS Persons Contacted Texas Utilfties Service. Inc. (TUSI)
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C. H. Catchell, Resident Manager H. C. Schmidt, QA Manager P. M. Milam, Site QA Supervisor Brown & Root, Inc. (B&R)
L. A. Ashley, Cor.struction Manager H. C. Dodd, Project Manager C. E. Bonin, Assistant Project Manager P. L. Bussolini, Project QA Manager D. L. Hansford, QC Engineer (Civil)
B. C. Banis, Concrete Superintendent R. E. Morris, Batch Plant Superintendent Gibbs & Hill (G&H)
J. J. Moorhead, Resident Engineer R. V. Fleck, QA Supervisor J. V. Hawkins, Site QA Representative Mason-Johnston & Associates (MJA) i i
P. Henley, Vice President B. V. Dreyer, Chief of Engineering, Geology H. C. Crowder, Field Geologist W. T. Cromeans, Resident Chief Technician R. W. Hunt Co.
B. Kinkade, Lead Level II Inspector Teoort of Subjects Inspected 1.
Scope of Insoection The inspection was limited to the follow-up review of previously identified items of noncompliance and unresolved items relating to TUSI and B&R QA/QC program organization, procedures, and procedure implementation; the review of records, documents, and observation of work activities relating to reinforcing steal cadwelding; personnel qualification for installation and inspection for cadwelding; and observation of cadweld tensile testing conducted by R. W. Hunt Co.
inspection personnel.
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A review was also made of the' geological mapping of fractures in i
Category I excavation applicable to the over-excavation resulting from the initial blasting operations.
(TUSI CDR 1eeter, dated 2/4/75) 4 i
2.
Plant Progress i
The overall plant construction progress is reported as 1.0% complete.
The reactor building contsiumine excavation to base mat elevation is j
complete for units 1 and 2.
The base concrete " mud" mats were poured May 27 and 29, respectively.
The installation of reinforcing steel for the containment building concrete base sat foundation for unit 1 commenced May 29.
Excavation for the cooling watet discharge tunnels is reported as"60%
complete.
The temporary coffer dam (Panther Creek) is approximately 90% complete. Excavation of the SSI Dam core trench will not start l
until the coffer das is complete.
Previously Identified Unresolved Items 3.
Procedure Development and Control Quality Control Procedure CP-QCP-5, " Preparation and Control of Project i-QA/QC Procedures" has been prepared by the B&R Quality Assurance Depart-ment and issued April 11, 1975.
The procedure covers preparation, review, approval,' issuance and revision of B&R Comanche Peak QA/QC project procedures including format, typing, reproduction and distribu-j tion.. This' procedure has been. included in the Quality Assurance /
Control Procedure Manual issued for CPSES.
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This item is considered resolved.
4.
NDE Procedures - Schedules and Titles B&R interoffice memo TSQ-0131, dated May 6, 1975, subject " Comanche Peak QA Tasks" lists required QA/QC procedures and er.cablishes a schedule for their completion.' The inspector observed that draft NDE procedures were in the process of review hj s&R Site QA.
This itam is considered resolved.
5.
TUSI QA Jite Surveillance Staff - Duties and Resoonsibilities TUSI is develcping a revision of their QA Plan, Sections 1.0 "Organi-zation", and 3.0 " Site QA Construction Surveillance", which will address the duties and responsibilities of Site Quality Assurance Supervisor and the Site Quality Assurance Group.
The Site Quality Assurance Group will consist of TUSI QA personnel' assisted by C&H QA personnel.
(continued)
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1 This item will remain unresolved and will be reviewed during a subsequent IE inspection.
6.
B&R QA/0C Site Organization - Duties and Responsibilities B&R Site QA is in the process of developing procedure QA?-1.2,
" Site QA and QC Organization" which vill describe the authority
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and duties of personnel in the B&R Site QA organization. QAP-1.2 is expected to be completed and implamented by June 20, 1975.
.This item will remain unresolved and will be reviewed during a subsequent IE inspection.
7.
B&R OA/QC Manuals - Revision Update Manual No. 41 has been updated and new contains Procedure CP-QCP-10 and a current index. B&R now requiras that procedure revisions be sent to the site Document. Control Ce::er for distribution to insure timely updating of manuals. As folicvup on May'20, 1975, B&R QA conducted an audit of Quality Assurance /Contrcl Procedure Manu&ls assigned to the QA office.
This item is considered resolved.
8.
Reinforcing Steel - Test Discrepancy f
Procedure 35-1195-CCP-18 " Reinforcing Steel Activities" was revised April 16,-1975, to delete the require =ent for confirmatory testing by an independent laboratory. Bethlehe= Steel will continue to perfora the tests in accordanca with G&H Specification 2323-SS-10.
This item is considered resolved.
9.
TUSI Site QA Construction Surveillanca TUSI QA is developing a revision to Section 3.0, " Site QA Construction",
of their QA plan which appears to adaquately describe requirements for timely followup action to correct deficiencies identified during site construction surveillance activities.
This ites will remain unresolved pending issuance of the revision and review by IE during a subsequent inspection.
10.
Cadweld Rebar Splicing The inspector reviewed G&H Specification No. 2323-S5-11 "Cadweld Connee-tors for Reinforcing Steel; B&R Construction Procedure 35-1195-CCP-19,
" Reinforcing Steel Mechanical Splici:3 (Cadwelds)"; B&R Procedure CP-QCP-20, "Cadwald Inspection and Testing"; Erico Catalog RB10M-974, "Cadweld Rebar Splicing"; and Erico publication R35M-274, " Inspection i
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.s of the Cadweld Rebar Splice". The specification and procedures appeared to conform to requirements described in the Erico documents.
The inspector observed production splicing of horizontal #18 rebar.
The splicing was utilized as qualification for the rebar splicers and as training for QC inspectars.
Tensile tests of completed splices were observed to exceed minimum requirements.
No discrepancias were noted.
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