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NOV 6 1984 MEMORANDUM FOR:
Larry Shao
. Jose Calvo Herbert Livermore Conrad McCracken Phillip Matthews Richard Bangart Richard Keimig FROM:
Vincent S. Noonan Project Director for Comanche Peak
SUBJECT:
CONSULTANT SERVICES FOR SSER COORDINATION As the TRT effort progresses, individual SSER sections are being prepared by reviewers and reviewed by group leaders and the TRT management. In order that the overall SSER organizations and conclusions are systematically consistent -
we have retained the services of two consultants to assist the TRT management in coordinating and reviewing the SSERs. These consultants and their assigned areas are:
Charles Hofmayer Civil / Structural, 3
(Brookhaven National Laboratory; Electrical / Instrumentation, formerly with the NRC/NRR)
Test Programs Bernard Saffell Mechanical / Piping, Miscellaneous (Battelle Columbus Laboratory) i We are seeking a third consultant to assist in reviewing and coordinating the SSERs in the QA/QC and coatings areas.
The consultants will review the current versions of the SSER sections in their assigned areas and provide coments. These coments will be forwarded to the appropriate group leaders for consideration / incorporation. The revised SSERs j
will then be ready for management review (Noonan/Gagliardo).
R.C. Tang of my staff (x28986) has been assigned to work with the consultants in coordinating and preparing the final SSER.
i The consultants' telephone numbers will be made available to you once they are officially on board.- Chet Poslusny (x27066) will continue to coordinate the t Miscellaneous and Coatings areas.yping of SSERs in Test Programs, Electrical,
'If you disagree with some of the I
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fg o an Project irector for cc:
J. Gagliardo C. Hofmayer B. Saffell R.C. Tang C. Poslusny R. Wessman A. Vietti S. Burwell J. Youngblood W. Oliu C. Brown
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NOTE TO: Darrell G. Eisenhut, Director FROM:
Vincent S. Noonan, Project Director
SUBJECT:
FORMATION OF PANEL TO FORMULATE AN NRC POSITION CONTENTION #5 (ADHERENCE TO QA/QC REQUIREM
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1 Since our meeting on the above subject, I have taken steps to put together a special panel of experts to deal with Hearing Contention #5 which addresses the adherence to quality assurance and quality control at Comanche Peak.
view this panel as a group of experts who will develop a position andI l
i recommendations that will be made to the Director, Division of Licensing.
l This panel would also be required to testify in front of the her ring board i
I have met with J. Scinto, S. Treby and T. Ippolito and have discussed the i
formation of this panel in some detail.
that the panel will be composed of a working group and a policy group The working group will address identified issues on management, intimidation, and quality assurance construction and will develop recon / quality control for dcsign and It will be comprised of the following indiviouals:nendations with p implications.
Heishman (IE), Al Herdt (Region II) and Jim Liberman (EL Jim of the panel would provide input.would be the OI representative from Brooks Griffin T. Ippolito will serve as an advisor to the working panel.
(I have not provided for a Division of Licensing i
representative on the panel as I feel that this is not necessary but I would like your thoughts on this aspect.)
Ed Case recommended to me that Jim i
Liberwan should be a member of this direction of obtaining his services. panel so I have actively moved in the i
Will issue NRC positions in those areas requiring such a complement a decision on the license for the plant.
t The group will be comprised of Hayes ano an:huditional member may be identified if required.D i
All members above have been contacted and are prepared to serve on the i
1 panel.
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NOV 6 1964 I wou$d expect the working panel to complete its work by Dece
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prepared to meet with the policy panel during the week of December i
I am settin
- 10. 1984 activities.g up a meeting with this panel on November 14 to start the I need your input and reconnendations as soon as possible.
, Project Director nc e Pe Te ical Review Team cc:
E. Case R. Vollmer
- 8. Hayes T. Ippolito -
J. Scinto S. Treby l
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NOV 6 1984 MEMORANDUM FOR: Darrell G. Eisenhut, Director Division of Licensing FROM:
Vincent S. Noonan, Project Director Comanche Peak Technical Review Team
SUBJECT:
COMANCHE PEAK PROJECT STATUS Three weeks have pas' sed since I assumed responsibility for directing the regulatory activities relating to Comanche Peak. This memo sumarizes recent major accomplishments, the status of significant issues, major activities being planned, and potential problem areas. A detailed schedule update of all Comanche Peak Action Items is being provided separately.
I.
Recent Accomplishments Reorganized the assignments of individuals associated with the-project and added several individuals to the staff. The attached chart (Enclosure 1) sumarizes the organization and assignments.
One additiontl' staff member is still being sought to help with SSER effort.
Met with Applicants on October 19, 23, 1984 to discuss Applicants' Program Plan for Civil. Electrical and Test Program issues. Staff coments on plan are being prepared.
Requested that ASLB postpone additional hearings until TRT effort complete.
(Status report of 10/19/84 and Motion for Postponement of Hearing of 10/23/84.) ASLB plans to hold hearings on 0. B. Cannon (Lipinsky Report) on 11/19 and Fuel Pool Liner Weld Travelers on 11/26.
Filed Staff Response to TUEC 50.57(c) Motion on November 2,1984 Met with Regional Administrator and senior Region IV staff, toured facility and met with resident inspection staff (10/25-26/84).
Met with J.'Ellis (CASE) on 10/25/84 and 8. Garde (GAP) on 11/1/84.
Additional meetings planned with J. Ellis on 11/7/84 (allegations feedback) and B. Garde on.11/8/84 (identify potential allegations).
II. Status of Significant' Issues Alleger feedback effort for Civil / Electrical and Test Program areas is about one half complete. Various difficulties in locating individuals, individuals failing to show up for appointments, etc. sumarizes alleger feedback effort.
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NOV 6 1984 Civ41/ Electrical / Test Program SSER development being affected by allegations feedback effort and discovery of omissions in several writeups. Issue date.is expected to be 11/20/84.
Coatings and paint debris evaluation awaiting applicant response and then still require short turnaround of NRR staff evaluation.
Results cf staff position on coatings and integration of TRT effort dependent on this review, scheduled for completion 11/15/84 Staff review of Cygna Reports are back in progress, with completion expected in late December. Phase 4 review expected after Cygna makes additional submittal.
Developing ASLB " Panel" to respond to QA and intimidation issues.
Mechanical, Coatings and QA SSER development going slower than anticipated. Significant rewriting and editing effort is necessary.
Region IV inspection effort appears to be caught up with facility completion.
Region about to issue first inspection status letter pursuant to IE MC 94300.
III. Major Activities Planned Meetings with many of available allegers in Mechanical, Coatings, and QA areas during week of 11/12/84.
QA issues briefing to DL management on 11/20/84.
Meet with Applicants to present initial TRT findings in Coatings and Miscellaneous areas on 11/21/84.
Meet with Applicants to present initial TRT findings in Mechanical and QA areas on 12/6/84.
Continue efforts to meet with allegers, provide feedback and conduct reassessment, and update SSERs as required cased on results of feedback interviews.
IV. Potential Problem Areas Magnitude of staff effort to complete technical reviews, allegations l
closeout, and support hearings is greater than anticipated.
Most individuals associated with Comanche Peak.have been and continue to work overtime.
Alleger feedback interv'iews are revealing gaps in portions of some SSER writeups. Additional TRT effort will be needed. The amount of this effort is unknown, but could be significant.
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NOV 6 1984 Locating allegers, conducting face-to-face interviews, etc. involve trips to various parts of U.S., consume a significant amount of time, and require extensive coordinetton.
Staff review of IE Motions for Summary Disposition (Walsh/Doyle) is scheduled for completion in December, but may be impacted by resource limitations.
Eight 01 investigations are in progress. The impact of this effort is still unknown. A major OI report, dealing with document control center issues, has not been issued.
Typing and secretarial support remains a challenge, and will continue to be so as we get closer to completing the SSER.
I will be available to discuss this memorandum at your convenience.
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gram Director nche Pe chn cal Review Team Division o Licensing cc:
J. Scinto E. Case R. Martin, RIV T. Novak B. Hayes, OI l
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.o COMANCHE PEAK PROJECT V. Noonan T. Ippolito Director ' - - - ~~ ~
Advisor Dep ties C. Posiusny J. Gagliardo, R4 Admin.
4 OI----- R. Wessman NRR (1/2 time)
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Tech. Editors Secretarles
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6 W. 011u K. Brown
_... _ A.Stang(PT)
P. Fischetti (PT)
(LicensingBranchNo.1
- 8. J. Youngblood)
S. Burwell,
A. Vietti J.4Stefano J. Zudans D. Terao R.C. Tang
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-PM Assist.
(1/2 time)
C. Haughney
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-TRT SSERS Prog.
-Interface
'0 ELD / Hearings
-SSER #6
-A11eger Feed-
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-50.57(c) back Program Reviewers
-FOIA Actions
-Reinspection Program
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-Civil
-Misc.
-Elec.
- Test Group Leaders
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SSER C I
i R. Bangart R. Keinig J. Calvo L. Shao C. McCracken H. Livermore
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Test Prog.
Elec.
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-s ALLEGER FEEDBACK EFFORT Electrical Civil Test Total Allegations 53 56 19 A11egers to Contact 13 11 3
"Near" Site 6
5 2
Away from Site (or unknown) 7 6
1 A11egers* Contacted:
9 6
2 Personal Interview 1
O Teleohone Interview 3
Failed to Keep Appt.
3 Didn't want Interview 1
1 Telephone Interview Scheduled Personal Interview Scheduled 4
2 2
A11egers Not Located 3
4 A11egers Not Contacted yet 1
1 1
A11egers Requiring Followup 2
A11egers Requiring No Followup 1
- Includes 4 individuals from "T-Shirt" event.
l NOTE: Some allegers common to more than one area.
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TEXAS UTILITIES GENERATING COMPANY TXX-4367 MKYWAY TOWER. 400 NORTH OLIVE MTREET. L.B. et
- DALLAN. TEXAh TSSOS MtCMatL 0 SPENCE November 21, 1984 m
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NNS$G Mr. Darre11 G. Eisenhut
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Director, Division of Licensing U.S. Nuclear Regulatory Ccmission h
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Washington, D.C.
20555
Dear Mr. Eisenhut:
On October 8,1984, Texas Utilities Electric Company (1UEC) submitted our response to the NRC-Technical Review Team initial transmittal of potential open items. Our response consisted of two principal elements, the Comanche Peak Response Team (CPRT) Program Plan and issue-specific Action Plans.
Subsequent to our meetings of October 19 and 23, during which TUEC-had the benefit of NRC Staff feedback and coments on our October 8 submittal, we have substantially revised our Program Plan. Enclosed with this letter is Revision 1 to the Progra Plan.
The revisions focus on enhancing three aspects of the plan. First, we have added two members to the Senior Review Team (SRT) fra outside RJEC. We have also replaced all the Issue Team Imaders with experts fr a outside TUEC. Our objective in filling these key, decision-making positions by experienced, nuclear industry experts is to eliminate any questions regarding the credibility and objectivity of the program by providing fre,h perspective.
Second, the Program Plan has been revised to include more specificity regarding the detemination of root causes and potential generic implications.
The manner in which such detenunations shall be incorporated in the scope and content of Issue-Specific Action Plans has been clarified.
Third, the Propi.m Plan now contains guidance with respect to relevant information raised by or presented to the Comanche Peak Atomic Safety and Licensing Board in the scope and content of the specific Action Plans.
We are currently revising Appendix A of the Program Plan (i.e., the issue specific Action Plans) to address the NRC staff ccanents provided to us at the recent meetings. The Issue-Specific Action Plans will be resubmitted under separate cover after our newly-assigned Review Team Leaders have incorporated any appropriate revisicas.
Sincerely, Aacg chael D. Spence MDS/sk 7
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o TEXAS UTILITIES GENERATING COMPANY TXX-4367 MKYWAY TE8WER
- 400 NORTH OLIVE MTREET. L.B. sal
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"'c "'.'d *,,U"'c8 November 21, 1984 Mr. Darrell G. Eisenhut Director, Division of Licensing U.S. Nuclear Regulatory Comission Washington, D.C.
20555
Dear Mr. Eisenhut:
On October 8,1984, Texas Utilities Electric Company (TUEC) submitted our response to the NRC-Technical Review Team initial transmittal of potential open items. Our response consisted of two principal elements, the Comanche Peak-Response Team (CPRT) Program P1.an and issue-specific Action Plans.
Subsequent to our meetings of October 19 and 23, during which 'IUEC had the benefit of NRC Staff feedback and ccanents on our October 8 submittal, we have substantially revised our Program Plan. Enclosed with this letter is Revision 1 to the Program Plan..
t The revisions focus on enhancing three aspects of the plan. First, we have added two members to the Senior Review Team (SRT) from outside TUEC. We have also replaced all the Issue Team Leaders with experts from outside TUEC. Our objective in filling these key, decision-making positions by experienced, nuclear industry experts is to eliminate any questions regarding the credibility and objectivity of the program by providing fresh perspective.
Second, the Program Plan has been revised to include more specificity regarding the.detennination of root causes and potential generic implications.
The manner in which such detennnations shall be incorporated in the scope and content of Issue-Specific Action Plans has been clarified.
Third, the Pro p Plan now contains guidance with respect to relevant information raised by or presented to the Comanche Peak Atomic Safety and Licensing Board in the scope and content of the specific Action Plans.
We are currently revising Append 2.x A of the Program Plan (i.e., the issue specific Action Plans) to address the NRC staff coments provided to us at the recent meetings. The Issue-Specific Action Plans will be resubmitted under separate cover after our newly-assigned Review Team Leaders have incorporated any appropriate revisions.
Sincerely, 9411260 53 841121
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> chael D. Spence NDS/sk A DIVislON OF TEXA9 t'TILITIES ELECTRIC COMPANY
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COMANCHE PEAK STEAM ELECTRIC STATION UNITS I AND 2 3 ROGRAM PLAN AND ISSUE-S'3ECIFIC ACTION 3LANS REVISION I NOVEMBER 19,1984 l
TEXAS UTILITIES GENERATING COMPANY g(I A DIVISION OF TEX AS UTILITIES ELECTRIC COMPANY SSllS
COMANCHE PEAK STEAM ELECTRIC STATION a
UNITS 1 AND 2 PROGRAM PLAN AND ISSUE-SPECIFIC ACTION PLANS REVISION 1 NOVEMBER 19, 1984 TEXAS UTILITIES GENERATING COMPANY A DIVISION OF TEXAS UTILITIES ELECTRIC COMPANY
Revision:
1 TABLE OF CONTENTS I.
INTRODUCTION II.
PROGRAM PLAN OBJECTIVES III.
PROGRAM PLAN PRINCIPLES IV.
PROGRAM ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES V.
PROGRAM PROCESS VI.
PROGRAM OUTPUTS VII.
PROGRAM QUALITY ASSURANCE VIII.
PROGRAM RECO3DS II.
SCHEDULE ATTACHMENT 1: CPRT ORGANIZATION CHART ATTACHMENT 2: ACTION PLAN FORMAT ATTACHMENT 3: A GION PLAN RESULTS REPORT FORMAT ATTACHMENT 6:
SUMMARY
OF PROGRAM PROCESS APPENDIX A:
ISSUE - SPECIFIC ACTION PLANS 4
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1 Page 1 of 17 Comanche Peak Steam Electric Station Comanche Peak Response Team Program Plan I.
INTRODUCTION The Nuclear Regulatory Commission (NRC) established a Technical Review Team (TRT) to review certain aspects of the Comanche Peak Steam Electric Station'(CPSES). The purpose of the TRT is to evaluate certain technical issues and allegations of improper construction practices at CPSES. In July 1984, the TRT began onsite activities as part of its review plan using a team divided into five groups:
electrical / instrumentation, civil / mechanical, QA/QC, protective coatings, and test programs.
On September 18, 1984, a public meeting was held in the NRC's offices in Bethesda, Maryland, at which NRC management and the TRT presented Texas Utilities Electric Company (TUEC) with a request for additional information. This request was based on the,results of the TRT efforts to date in the electrical /
instrumentation, civil, and testing program areas. The TRT stated that they required additional information in order to make a determination of the safety significance of certain concerns.
The TRT request for information was documented in an attachment to an NRC letter dated September 18, 1984. The request was divided into three primary areas and several sub-areas, each representing a subject of concern to the TRT.
TUEC developed a Program Plan and individual Action Plans for each of the issues identified in the September 18, 1984, i
letter..The Program Plan and the Issue-Specific Action Plans were submitted to the NRC by letter dated October 8, 1984.
Subsequently, public meetings were held at the NRC's Bethesda, Maryland, offices on October 19 and 23 at which TUEC made verbal presentations of the Program Plan and the Action Plans, obtained verbal NRC comments and provided clarifications by answering questions.
As a result of the meetings with the NRC, TUEC has revised the i
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Program Plan and is in the process of revising the Issue-Specific Action Plans. These revisions reflect-consideration of the NRC's comments and observations, clarifications needed to respond to questions that were raised, and experience gained during the initial stages of implementation of the original version of the Program Plan and the Action Plans.
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Revision:
1 Page 2 of 17 The overall' Program Plan, as revised, is presented below. The revised Issue-Specific Action Plans will be provided in a i
future revision to Appendix A.
Similar Issue-Specific Action Plans will be developed to respond to any additional TRT issues identified to TUEC in the future.
II.
PROGRAM Pl.AN OBJECTIVES TUEC continues to be committed to the safe, reliable, and efficient design, construction, and operation of CPSES and will cooperate fully with the NRC and its TRT to resolve the identified issues. The Program Plan described in this document is intended to establish a framework for responding to the TRT's requests for additional information and to assist in dispositioning the associated issues. Where necessary, corrective action will be taken. Appropriate action will also be taken to preclude similar deficiencies from occurring in the future. Therefore, th_e objectives of the Program Plan are to:
w Evaluate and respond to the issues raised by the TRT Identify the root cause and evaluate the generic implications of identified deficiencies l
Evaluate the collective. significance of identified deficiencies g
Define necessary corrective actions for identified deficiencies Define steps necessary to preclude similar occurrences in I
the future III.
PROGRAM PLAN PRINCIPLES To ensure that the Program Plan objectives are met, the program was developed using the following principles:
l A.
Thorouah Reviews The NRC's September 18, 1984, letter and its attachment identified specific reonests for additional information and provided specific examples of potential deficiencies.
It is recognized that the specific examples identifie'd by the NRC-TRT may be representative of an underlying concern. -Accordingly, each of these issues will be thoroughly evaluated, even if a preliminary assessment of the specific examples indicates that they have no safety significance.
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Revision:
1 Page 3 of 17 The NRC-TRT used sampling techniques in the performance of its reviews. In some cases it will be appropriate to expand the size of the sample to explo;s the issues identified by the NRC-TRT more thoroughly. This will enable TUEC to obtain a more complete understanding of root causes, potential generic implications, and safety significance of any identified deficiencies and.to achieve a higher degree of confidence in the Program Plan results.
Some of the issues identified by the NRC-TRT are directly 4
related to similar questions currently before the Comanche Peak Atomic Safety and Licensing dearing Board (ASLB). For those instances where TUEC is aware of additional information that has been p esented to the Board (or matters raised directly by '.he Board) and that is directly relevant to an issue.iden:ified by the NRC-TRT, the Issue-Specific Action Plans will appropriately include consideration of such information.
i B.
Root Cause Determinations Root causes will be determined for each issue identified by the NRC-TRT and for all valid deficiencies identified by the NRC-TRT or by TUEC. Such determinations will enable TUEC to identify potential generic implications, to establish appropriate expanded scopes of review, and to define appropriate. corrective actions.
In some cases, preliminary determinarians of root causes can be made during the development of the Issue-Specific Action Plans and, where appropriate, reflected in an expanded scope of review in an Issue-Specific Action Plan. However, in most cases, the root causes of potential or actual deficiencies cannot be immediately determined. The Issue-Specific Action Plans are being developed to include tasks that are intended to identify l
root causes of identified deficiencies. These tasks are oriented both at specific testing of initial root cause hypothesis as well as more general exploratory efforts that will lead to new root'cause hypothesis. The Action Plans will provide a description of the iterative actions and alternatives used to identify root causes.
It is recognized that the determinations of root causes may result in a need for changes to the Issue-Specific Action Plans. The Action Plans will be structured to eliminate the need for unnecessary revisions. TUEC will strive to identify the root causes conclusively as soon as possible for each Issue-Specific Action' Plan.
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1 Page 4 of 17 C.
Generie Implications Evaluations At such time as the root causes of identified deficicacies have been determined, an evaluation will be performed to identify any associated potential generic implications. Such evaluations will enable TUEC to determine whether the deficiencies represent isolated occurrences, non-isolated or generic weaknesses within a particular area, or generic weaknesses that are programmatic in nature.
The results of such evaluations, in conjunction with an assessment of the safety-significance of the deficiencies and weaknesses, will enable TUEC to define appropriate expanded scopes of review and to identify appropriate corrective actions.
D.
Safety Significance Evaluations The safety-significance of identified deficiencies, both specific and generic / programmatic. will be evaluated to facilitate the definition of the scope of appropriate expanded reviews and the definition of appropriate corrective action.
E.
Collective Significance Evaluation The Collective Significance Evaluation will fscus on the integrated impact of the identified deficiencias, both specific and generic / programmatic, on the CPsES project.
This evaluation will be based primarily on the information developed through the root cause determinations, generic implications evaluations, and safety significance evaluations. It will include a determination as to whether the existence of multiple, apparently isolated and relatively minor deficiencies indicates a common shortcoming in the ?rograms and procedures applicable'to the CPET.3 ;;oject. It will also identify " lessons learned" as they apply to future activities at CPSES Units 1 and 2.
F.
Corrective Actions Appropriate corrective actions will be defined and implemented to resolve all specific deficiencies identified by the NRC-TRT and by TUEC during the course i
of this review and evaluation program.
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1 Page 5 of 17 In addition to corrective actions designed to resolve specific deficiencies, actions will be identified to prevent the future occurrence of similar deficiencies at CPSES Units 1 and 2.
Such actions will be developed using the results of the evaluations of root causes, generic implications, and collective significance.
Accordingly, the focus of these corrective actions will be to resolve actual or potential weaknesses that are generic or programmatic in nature.
G.
Objectivity The Program Plan submitted to the NRC staff by TUEC on October 8, 1984, included a number of features that were intended to provide assurance regarding the objectivity of the Program. Nonetheless, during subsequent public meetings with the NRC staff, it became apparent that it would be necessary to incorporate additional features to further ensure the objectivity and credibility of the Program. Accordingly, additional programmatic features have been implemented to ensure that the Program is conducted in such a==nnar that its objectivity and credibility will be beyond question.
As described in Section IV, the CPRT Program Organization.
includes a substantial number of participants in key decision-making positions who are affiliated with organizations external to TUEC. Three of the six members of the Senior Review Team and all five Review Team Leaders are experienced nuclear-industry consultants who have not bden previously involved with the CPSES activities that they will now be reviewing.. The Review Team Leaders, subject to Senior Review Team review and approval, have the authority and responsibility to establish the scope and content of the Issue-Specific Action Plans and to determine how and by whom the Issue-Specific Action Plans will be implemented. The members of the SRT and the Review Team Leaders have
-access to all plant areas, documentation, calculations, files, and personnel as they deem necessary to meet the Program Objectives.
The Senior Review Team has established the following guidelines with respect to the objectivity in implementation of the Action Plans:
Analyses and calculations either will be performed by an organization not previously responsible for the technical subject area for the CPSES project cg; an engineering design verification of the analysis / calculation will be performed by a third party organization.
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Revision:
1 Page 6 of 17 Inspections either will be performed by qualified inspectors not previously affiliated with the CPSES project and not currently affiliated with TUEC or its principal contractors for the CPSES project eg; the inspections will be performed by qualified inspectors who were not personally involved in the inspection activities in question and an inspection validation program will be conducted on a sampling j
basis by third-party inspection personnel.
Selection of personnel for inspection activities will be mutually agreed upon by the responsible Review Team Leader and the Review Team Leader for i
the QA/QC area.
l Records reviews and evaluations either will be performed by third-party personnel or,by CPSES project personnel with a third-party validation on a sampling basis.
Testing and NDE activities (other than preoperational testing) will be conducted and test results will be certified by third-party personnel.
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H.
Personnel Qualifications / Training Issue-Specific Action Plan implementation activities (such as analyses, inspections, records reviews, and testing) will be performed by personnel selected by the i
Review Team Leaders on the basis of technical competence and subject to the objectivity guidelines noted above.
l (For Action Plan a*.tivities performed prior to the
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adoption of Revisias 1 of the Program Plan, each Review j
Team Leader will determine the acceptability of that work
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relative to the additional objectivity and other requirements contained in Revision 1.)
Whera applicable, such personnel vill also receive training on the procedures to be utilized and will be qualified / certified in accordance with the existing CPSES QA Program i
provisions.-
I.
Sampling Issue-Specific Action Plan implementation activities may include the use of sampling techniques. The bases for using sampling and the sampling method will be documented in each Issue-Specific Action Plan when sampling is used.
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Revision:
1 Page 7 of 17 In general the following guidelines will apply:
Samples will be randomly selected from populatio ts or subpopulations of concern (e.g. of concern to safety) for the purpose of identifying the existence
-and/or the extent of potential deficiencies.
MIL-STD 105D, or other appropriate procedures, will be used to determine sample size. Sampling programs will be designed to include a limiting quality of 5 percent with an acceptance probability of 0.05 (i.e.
at least 95% of the population is in conformance with the acceptance criteria at the 95% confidence level).
Acceptance / rejection criteria will be explicitly defined.
Mr. John Reed of Jack Benjamin & Associates will be used as a third-party engineering statistics consultant to provide an objective evaluation of the adequacy of the 1
design of each sampling program and to ensure consistency in the interpretation of results.
J.
Records and Quality Assurance The Program Plan requires that the activities performed in accordance with each Action Plan be documented appropriately along with the results of the Action Plan.
The resulting records will be maintained in auditable 1
form.
Action Plan activities that otherwise would be subject to the CPSES QA program shall be performed in accordance with the applicable portions of that program.
Utilizing the general principles presented above, revised Issue-Specific Action Plans are being developed for each issue identified in the September 18, 1984, letter with consideration given to comments received at the October 18 and 23 meetings. These revised Action Plat 1 will be provided as a revision to Appendix A cf this document. Similar Issue-Specific Action Plans will be developed to respond to TRT questions in the aschanical, QA/QC, and protective coatings areas when they are-identified-to TUEC.
Revision:
1 Page 8 of 17 IV.
PROGRAM ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES A,
Introduccion The organization established by TUEC to develop and implement this Program Plan has been designated as the Comanche Peak Response Team (CPRT). A chart depicting the organizational structure and principal members of the CPRT is presented as Attachment 1.
The personnel assigaments to this project reflect the importance that TUEC has attributed to its successful conduct and completion.
B.
Team Members -- Roles and Responsibilities 1.
Senior Review Team A Senior Review Team, consisting of senior TUCCO line managers and senior nuclear-industry consultants, has been established with overall responsibility for the development, implementation, and management of the CPRT Program.
The Senior Review Team (SRT) for the CPRT Program consists of the following members:
Mr. Lou F. Fikar, Executive Vice-President, Engineering, TUGCO Mr. Billy R. Clements, Vice-President, Nuclear Operations, TUGC0 l
Mr. John W. Beck, Manager, Nuclear Licensing, TUGC0 Mr. John C. Guibert, Consultant; Manager, Nuclear Safety & Licensing, TERA Corporation l
Mr. Anthony R. Buhl, Consultant; President, Energx Corporation Mr. John L. French, Consultant; Vice-President, Delian Corporation The specific responsibilities of the Senior Review Team include the following:
Development of the CPRT Program Plan, and any subsequent revisions thereof f
Establishment of CPRT Program standards for personnel qualifications and objectivity i
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1 Page 9 of 17 Assignment of CPRT Program Review Team Leaders Review and approval of Issue-Specific Action Plans, and any subsequent revisions thereof Ensuring that necessary resources are provided to support the successful implementation of the CPRT Program Ensuring that " root cause" and " generic tuplications" evaluations are conducted as soon as possible for each issue identified by the TRT Review and approval of " root cause"
' determinations and " generic implications" assessments, including evaluations of the e
adequacy of the Action Plans to address these matters Monitoring the status of the implementation of the Issue-Specific Action Plans Review and approval of the Issue-Specific Action Plan Results Reports Review and approval of the Collective Significance Evaluation Report Advising the President of TUGC0 regarding the adequacy and status of the implementation of the CPRT Program Mr. Fikar is chairman of the SRT. The SRT chairman has assigned additional responsibilities to certain SRT members.
Mr. Beck will serve as the principal interface with the NRC staff's TRT Program Director for CPRT/TRT matters.
Mr. Guibert will be responsible for the development of the Collective Significance Evaluation Report.
2.
Senior Review Team Support Group In order to assist the SRT in the execution of its responsibilities, an SRT Support Group has-been established. The functions of the SRT Support Group fall within the two general categories of project coordination and project administration and include the following specific activities:
Assisting the Review Team Leaders in obtaining access to CPSES project personnel, project
-documentation, and project physical spaces
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Providing necessary on-site clerical and administrative support to the SRT and to the Review Teat Leaders Maintaining the CPRT Project Central File Developing programmatic procedures and guidelines at the request and for the approval of the SRT Assisting the SRT in monitoring the implementation schedules for the Issue-Specific Action Plans Other support functions as assigned by the SRT 3.
Review Team Leaders Review Team Leaders have been assigned to develop and manage the implementation of the Issue-Specific Action Plans within each of the six general areas evaluated by the NRC's TRT. Each of the Review Team Leaders is a member of an organiz; tion external to TUEC.
Review Team Leaders were selected by the Senior Review Team using the following criteria:
Knowledge and experience in quality assurance, nuclear safety, and the review area subject matter, as appropriate.
Managerial competence based on experience in managing rachnical projects and reviews Integrity of both the individuals and the
_ organizations with which they are affiliated based upon their reputation and standing within the nuclear industry Objectivity of both the individuals and the organizations with which they are affiliated based upon their demonstrated capability and reputation for providing objective, dispassionate technical judgements on the basis of technical merit.
Objectivity of both the individuals and the organizations with which they are affiliated based upon the lack of previous involvement in the CPSES project' activities in question G
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1 Page 11 of 17 The specific Review Team Leader assignments are as follows:
Mr. Howard A. Levin; Manager, Engineering, TERA Corporation; Review Team Leader for the Civil, Structural, and Mechanical Areas Mr. John L. Hansel; Director, Energy & Environmental Science Division, Evaluation Research Corporation; Review Team Leader for the Quality Assurance / Quality Control Area Mr. Martin B. Jones, Jr.; Private Consultant; Review Team Leader for the Electrical /Insttumentation Area Mr. E._P. Stroupe; Director, Technical Services Division Technology for Energy Corporation; Review Team Leader for the Protective Coatings Area Mr. Monte J. Wise; President, Wise & Associates; Review Team Leader for the Testing Programs Area The specific responsibilities of the Review Team Leaders include the following:
I Serving as the principal interface with the NRC-TRT Leaders in their respective areas for the purpose of ensuring that additional clarifying information is obtained (where necessary), for obtaining feedback.
on the adequacy of. Action Plans within their area, and for ensuring that responses to NRC questions regarding implementation.of Actio'n Plans within their area are provided Development of the Issue-Specific Action Plans within their area, and any sr.bsequent revisions thereof, using the format and content guidelines set forth in Attachment 2 Ensuring that personnel implementing the Action Plans (including personnel performing validations or design verifications described in Section III.G.
above) within their area meet CPRT Program standards for personnel qualifications and objectivity i
. Assignment of Issue Coordinators Identifying and obtaining necessary resources to implement the Action Plans within their area Ensuring that tha' Action-Plans within their area are being implemented appropriately Providing periodic status reports to the Senior Review Team on the implementation of the l
Issue-Specific Action Plans within their area i
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1 Page 12 of 17 Determining " root causes" and " generic implications" of identified deficiencies within their area; ensuring that these determinations are adequately addressed in the asscciated Action Plans cg; ensu-ing that the Action Plans are appropriately revised Identifying and defining corrective actions for any identified deficiencies within their area Identifying and defining necessary actions to preclude occurrence of similar deficiencies in the future Developing Issue-Specific Action Plan Results Reports, using the format and content guidelines set forth in Attachment 3 Maintaining a Project Working File for each Action Plan within their area Transferring Project Working Files to the Project Central File at such time that each Action Plan is completed (i.e., Action Plan Results Report reviewed and approved by the Senior Review Team) 4.
Issue Coordinators In order to assist the Review Team Leaders in implementing the Issue-Specific Action Plans within their area, they have been authorized to assign Issue Coordinators for each of their specific Action Plans. Review Team Leaders also have the option of assigning themselves as Issue Coordi2 tor for some or all of the Action Plans within their area.
The criteria for selection of Issue Coordinators is essentially the same as that for selection of Review Team Leaders. In cases where an Issue Coordinator has had some degree of previous involvement in the CPSES project activities in question, specific provisions will be established in the Action Plan to ensure that the objectivity guidelines of Section III.C are met.
Issue Coordinators are responsible for assisting the Review Team Leaders in Issue-Specific activities as directed by the Review Team Leaders.
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1 Page 13 of 17 V.
PROGRAM PROCESS 4
j The overall process for the development and implementation of this Program Plan and its associated individual Action Plans
'I was presented, to a large extent, in the preceeding sections.
A summary of the key elements of the overall program process is presented in Attachment 4.
Additional information related to the process for developing Issue-Specific Action Plans is presented in Attachment 2.
While each Action Plan is unique, the programmatic guidelines set forth in Attachment 2 and the Action Plan review and approval process ensure that each Action Plan is developed and implemented in a manner that meets the Program Plan Objectives and the Program Plan Principles. Each Action Plan includes a description, where appliegble, of the following:
scope and methodology identification of procedures and checklists participating personnel gualifications of perticipating personnel 1
training of participating personnel l
sampling plan l
relevant standards applicable acceptance criteria, and applicable decision criteria.
Additional information related to'the process for developing Issue-Specific Action Plan Results Reports is presented in l
The programmatic guidelines set forth in i and the Results Report review and approval l
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process ensure that the following subjects are adequately j
addressed where appropriate during the implementation of the j
1 Action Plan:
)
identification of root causes of identified deficiencies, i
I an evaluation of the safety significance of any identified deficiencies, a determination regarding potential generic implications
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and a description of how they were addressed, l
identification of necessary corrective actions to resolve identified deficiencies, identification of necessary action to preclude recurrence i.
in the future.
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To the maximum extent possible, the scope of the Issue-Specific Action Plans will be based on a preliminary assessment of the root cause and potential generic implications of the identified deficiencies. Action Plans will be sufficiently broad to identify and' assess root causes, generic implications, and safety significance. Accordingly, sost of the Issue-Specific Action Plans will utilize iterative or phased implementation approaches that include an initial phase which is exploratory in nature. Conclusive determinations of root causes and potential gena.ric implications will be made as soon as possible. Determinations with respect to the safety significance of identified or potential deficiencies will also be reached. The adequacy of the scope of the associated Issue-Specific Action Plans will be reassessed in light of these determinations. If an Action Plan is determined not to'ba sufficiently broad to meet program requirements, it will be appropriately revised and new Action Plans may be developed (if appropriate) to ensure that the potential generic implications of identified deficiencies are properly investigated and addreased.
VI.
PROGRAM OUTPUTS The principal outputs of the CPRT Program will be the Action Plan Results Reports. The format and content to be utilized i
in the development of these Reports is presented in Attachment 3.
Specific conclusions will be reached regarding root cause, l
safety significance, and generic Laplications. Necessary i
corrective actions will be identified to resolve deficiencies, including any corrective actions necessary to preclude recurrence of stailar deficiencies in the future.
An additional report documenting the results of the Collective Significance Evaluation will be developed. This report will, in large measure, be based upon an integrated assessment of the Action. Plan Results Reports.. The principal focus of this evaluation will be to identify additional programmatic
" lessons learned" which should be reflected in future
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project-related activities - for both Comanche Peak Unit i and Comanche Peak Unit 2.
At the conclusion of the CPRT Program, a Final Report summarizing the results and conclusions of the Program will be submitted to the NRC. Interim status reports or briefings will be provided to the NRC staff as requested.
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1 Page 15'of 17 VII.
PROGRAM QUALITY ASSURANCE Activities associated with the implementation of individual Action Plans will be conducted within the framework of the existing CPSES QA Program. Existing procedures, revised or supplemented as necessary to address special requirements, will be used to perform reasses'sment activities, reinspection activities, and rework activities performed by engineering, construction, and QA/QC personnel.
VIII.
PROGRAM RECORDS In order to ensure that an auditable record of the CPRT Program is available, the documentation described below will be developed and maintained.
A.
Project Central File The Project Central File will be maintained by the SRT Support Group. At the completion of the CPRT Program, it will contain all project documentation, including the Project Working Files maintained by the Review Team Leaders during the conduct of the Program. During the conduct of the Program, the' Project Central File will contain the following material:
A copy of the Program Plan subnitted to the NRC and any subsequent revisions thereof A copy of the individual Action Plans submitted to the-NRC and any subsequent revisions thereof A copy of the individual Action Plan Results Reports l
A copy of the individual Action Plan Working File for all Action Plans which have been completed (i.e., Action Plan Results Reports reviewed and approved by the Senior Review Team).
B.
Project Working Files Project Working Files will be maintained by the Review Team Leaders for each Action Plan under their cognizance until such time as the Action Plan has been completed.
At taat-time, the Project Working File for the completed Action Plan will be transferred to the Project Central File. The specific material contained in each Project Working File will vary, depending upon the nature of the associated Action Plan; where applicable, it will contain, at a minimum, the following material:
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1 Page 16 of 17 Copies of letters, memoranda or reports documenting the results of analysis performed as part of the Action Plan, including any associated documentatior.
related to the evaluation of such results.
Copies of letters, memoranda, or reports documenting the results of testing performed as part of the Action Plan, including any associated documentation related to the evaluation of such results.-
Copies of procedures or checklists used in the performance of testing.
Copies of letters, memorarda, reports, dravic5s or other means of_ documenting the results of inspections performed as parc of the Action Plan, including any associated docuaentation related to the eyaluation of such results.
Copies of procedures or checklists utilized in the
< s performance of inspections.
l Copies of letters, memoranda, or reports documenting the results of record reviews performed as part of the Action Plan, including any associated documentation related to the evaluation of such L
results.
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. Copies of procedures or checklists utilized in the 1
performance of record reviews.
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i A record of personnel qualifications and a record of f
training for personnel participating in the t
implementation of the Action Plan.
- s II.
SCHEDULE i
At the present time, it is impractical to accurately estimate the achedule for completion of the entire CPRT Program. This
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is primarily due to evo elements of uncertainty:
'Several of the Action Plans utilize a phased approach for resolution, consequently the full scope of the necessary review effort cannot be det0rmined ur.til' preliminary results become available; and The TWT questions in the areas of mechanical, QA/QC, and yrotective coatings have not yet been provided to TUIC,
' consequently the' nature of the Action Plan activities necessary to respond to these questions (and their associated schedule) cannot be determined until a later
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1 Page 17 of 17 The Action Plans presented in Appendix A address, to the extent practicable at the present time, the current status and projected schediles for completion of selected elements of the individual Action Plans and, in a few cases, the schedule fot completion of the entire Action Plan. As additional information becomes available regarding projected completion schedules for individual Action Plans and for the entire CPRT Program, it will be provided to the NRC staff.
TUEC is committed to a thordigh and complete review of the safety-related issues _ identified by the TRT. A satisfactory resolution of these issues which potentially affect the safe operation of the Comanche Peak Units takes precedence over schedule concerns.
As the implementation of the CPRT Program proceeds and after the additional TRT questions have been received and additional
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Action Plans have been developed to address them, TUEC intends to perform an evaluation to determine, at that time, whether a safety basis exists to support authorization for fuel loading and precritical testing at Comanche Peak Unit 1 prior to the completion of the entire CPRT Program. TUEC will inform the NRC staff of the results of this evaluation.
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COMANCllE PEAK RESPONSE TEAM (C P RT) i TUGCO PRESIDENT M. SPENCE l
SENIOR REVIEW TEAM L. F. FlK AR B.R.CLEMENTS J.W. B ECK J.L. FRENCH J.C. GulBERT A. R. B U HL 4
SRT SUPPORT GROUP F
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7 ELECTRIC AL /
ClVIL / MECK PROTECTIVE COATING QA/OC TESTING PROGRAMS INSTR. LEADER LEADER LEADER LEADER LE ADER M.S. JONES N. A. LEVIN E. P. STROUPE J. L. H A N S EL M. J. WIS E I
ATTACHMENT I REVISION I
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1 Page 1 of 3 ATTACHMENT 2 ACTION PLAN FORMAT ITEM NUMBER (Short Title) 1.
Description of Issue Identified by NRC
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-Verbatim statement of the TRT issue as stated in the enclosure to the NRC issue transmitted letter 1
-Develop a separate Action Plan for each numbered TRT item 2.
Action Identified by NRC
-Verbatim statement of NRC - directed action as stated in the I
enclosure to the NRC issue transmitted letter
===3.
Background===
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-Relevant information which clarifies the issue definition i
-Relevant information to provide additional perspective and understanding of the issue (including consideration of relevant information before the ASLB)
-An explanation (where applicable) of why TUEC has decided to pursue the approach described under Section 4.0 below, where alternative approaches were available i
-If possible, a statement regarding the preliminary l
determination of root cause and potential ~ generic implications i
of identified deficiencies l
4.
TUEC Action Plan 1
-Scope and Methodology
-Describe approach.(phased, if applicable) l
-tasks to be performed without conditions l
-tasks to be performed under certain conditions (e.g.,
"If we-find "x", then we will take the following additional action...")
-tasks to be performed as part of an expanded review I
(where applicable and where this has.already been determined) i
-describe how potential generic-implications are being l
-considered.(where applicable and where this has already-been determined) l k
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-Procedure (s) to be used
-reference existing procedures
-describe any new or revised procedures
-Participant's Roles and Responsibilities
-which organizations are involved
-scope for ecch organization
-identify lead. individual
-Qualifications of Po sonnel
-state qualifications of personnel implementing the Action Plan
-reference these qualifications to. existing requirements
-discuss training of personnel which will be conducted
-Sampling Plan
-if performing a 100% review, state that a 100%
review is being done
-if sampling is used, provide information relevant to the sampling plan, and provida justification for 3
the sample size
-Describe any other features of the sampling plan (e.g. random sampling of the universe, random sampling of each discipline, etc.)
-Provide the definition of a "rej ect"
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-Standards / Acceptance Criteria
-describe the standards (e.g., FSAR, IEEE, Reg.
l Guides, etc.) against which you are performing the review
-Decision Criteria
-describe the criteria to be used for going rA 11e next phase of a phased-approach review or for expanding the sample size for~a review using i
sampling techniques t
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-Describe the criteria for closing out this item (this is related to the standards / acceptance criteria and the criteria for subsequent phases) 5.
Schedule / Status Describe schedule and current status, to the extent possible. Reference the schedule to the phases ~where appropriate. If a schedule for a phase cannot be provided until additional information is obtained, state that a schedule will be developed at the completion of the previous phase.
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1 Page 1 of 2 ATTACHMENT 3 ACTION Pl.AN RESULTS REPORT FORMAT ITEM NUMBER (Short Title)
-1.
Description of Issue Identified by NRC (same as Action Plan) 2.
Action Identified by NRC (same as Action Plan)
===3.
Background===
(same as Action Plan) 4.
TUEC' Action Plan
-Scope and Methodology
-Same as Action Plan except:
-where conditional phases were implemented, reword the conditional statement so that it is clear that the phase had been implemented
-where a cenditional phase was determined not to be necessary, state that it was not needed and provide a reference to a subsequent part of-the report which justifies the decision not to Laplorant the conditional phase
-describe'any other substantive changes to the Action Plan and why the changes were necessary 5.
Discussion of Results
-Comparison of results against standards / acceptance l
criteria
-Comparisen of results against decision criteria
-Discussion of corrective actions for any identified deficiencies (e.g., any reinspections, rework, reanalysis, etc.)
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1 Page 2 of 2 6.
Conclusions j
-Identification of root cause of any deficiencies i
-Evaluation of safety significance of identified deficiencies
-Evaluation of generic implications
-where applicable, describe expanded scope of review to address them
-demonstrate linkage to the root cause
-where applicable, describe basis for conclusion that no generic implications exist 7.
Ongoing Activities
-Describe any activities still.in progress
-State whether these on-going activities have safety significance
-State schedule for completing activities. State whether the work must be completed by fuel load, initial criticality, or power above 5%.
8.
Action to Preclude Occurrence in the Future
-Training, Procedural changes, etc.
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SUMMARY
OF PROGRAM PROCESS 1.
Receipt of NRC-TRT request for additional infor=ation.
2.
Preltninary review of issue by Senior Review Team and appropriate Review Team Leader.
3.
Review Team Leader obtain additional, clarifying information from NRC-TRT to ensure full understanding of the concern (if necessary).
4.
Review Team Leader make a preliminary determination of root cause and potential generic implications of identified deficiencies (if possible) 5.
Review Team Leader develop Action Plan to resolve concern using guidance provided in Attachment 2.
6.
Action Plan approved by Senior Review Team.
7.
Review Team Leader implement Action Plan.*
8.
Review Team Leader make a conclusive determination of root cause and potential generic implications of identified deficiencies.
9.
Review Team Leader obtain concurrence of Senior _ Review Team in root cause definition and potential generic implications assessment. ~
10.
Review Team Leader develop revised Action Plan to reflect the~ conclusive determination of root cause and potential generic implications (if applicable).
11.
Revised Action Plan approved by Senior Review Team (if applicable).
12.
Review Team Leader implement Revised ~ Action Plan (if applicable).*
13.
Review Team Leader define necessary corrective action for identified deficiencies (if applicable).
14.
Review Team Leader define necessary corrective action to prevent recurrence of similar deficiencias in the future (if applicable).
15.
Review Team Leader develop Action Plan Results Report using guidance provided in Attachment 3.
16.
Action Plan Results Report approved by Senior Review Team.
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1 Page-2 of 2 17.
SRT assess Action Plan Results Report as part of Collective Significance Evaluation.
18.
SRT define necessary corrective actions stemming from the Collective Significance Evaluation 19.
Submit Final Report to NRC, including implementation schedule for necessary corrective actions.
20.
TUEC implemant necessary corrective action.
- Action Plans and revised Action Plans will be submitted to the NRC staff for review and comment at the time they have been approved by the SRT; however, implementation of Action Plans will not be delayed pending receipt of NRC staff comments. Any necessary changes to Action Plans resulting from NRC review and comments will be incorporated expeditiously.
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I APPENDIX A ISSUE-SPECIFIC ACTION PLANS (Revision 1 to be submitted under separate cover)
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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- E WASHINGTON, D. C. 20655
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January 8, 1985 Docket Nos. 50-445/446 Mr. M. D. Spence, President Texas Utilities Generating Company 400 North Olive Street Lock Box 81 Dallas, Texas 75201
Dear Mr. Spence:
Subject:
Comanche Peak. Review On July 9,1984, the Comanche Peak Technical Review Team (TRT) began an intensive onsite effort to complete a portion of the reviews necessary for the NRC staff to reach its decision regarding the licensing of Comanche Peak Unit 1.
The onsite effort covered a number of areas, including the review of allegations of improper construction practices at the facility.
On September 18, 1984, the NRC met with you and other Texas Utilities Electric Company representatives to provide you with a request for additional infor-mation in the electrical and instrumentation, civil and structural, and test program areas having potential safety implications. On November 29, 1984, we reported to you on the status of our technical review in the protective coatings area and requested additional information in the mechanical, and miscellaneous areas. TRT reviews of construction QA/QC allegations and technical issues have progressed to the point where we can now provide you with the status of our efforts in the construction QA/QC area and a request for a program plan specifically addressing our concerns. Further background infomation regarding these allegations and technical issues will be published in Supplements to the Comancl.e Peak Safety Evaluation Report (SSER),
which will document the TRT's detailed ass'essment of the significance of all issues examined.
The TRT effort constitutes one element in the process of the agency's review of the Comanche Peak license application. The QA review group on the TRT was comprised of about 20 individuals having a total of over 300 years experience in r.uclear engineering, QA, and related fields. This group spent several months at the Comanche Peak site examining the construction QA program in depth.
The TRT findings are provided in the enclosure'to this letter. We have not proposed specific TUEC corrective actions as we have in previcus reports from 3
the TRT. We request that you evaluate the TRT findings and consider the-implications of these findings on construction quality at Comanche Peak. We request that you submit to the NRC, in writing, a program and schedule for completing a detailed and thorough assessment.of the QA issues presented in the enclosure to this letter.
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I Your programmatic plan and the plans for its implementation will be reviewed and evaluated by the staff before NRC considers the issuance of an operating license for Comanche Peak Unit 1.
The TRT considers the construction QA/QC findings to be generic to both Units 1 and 2 and your program plan and schedule-should address both units. This program plan shall: (1) address the root cause i
4 of each finding and its generic implications on safety-related systems, programs, or areas, (2) address the. collective significance of these t
deficiencies, and (3) propose an action plan from TUEC that will. ensure that such problems do not occur in the future. Your actions should consider the use l
of management personnel with a fresh perspective to evaluate the TRT's findings and implement your corrective actions. Finally, you should consider the use of.
an independent consultant to provide oversight to your program.
l The findings of TRT with respect to QA/QC allegations, along with the TRT's assessments of your response to this letter, will be provided to the Senior Management Panel on~ Contention 5 established by the Executive Director on December 24, 1984. The Senior Management Panel will determine an overall NRC staff position on Contention 5 based on an integrated review of a number of sources of information concerning QA/QC at Comanche Peak in addition to the 3
TRT findings, including infonnation from the CAT team, the SRT team, 01, Region IV and the Hearing Board.
j The TRT's overall evaluation of the technical issues and allegations is nearing completion. As we finalize information received in conversations with allegers, and further assess the implications of our findings we will inform you of additional concerns, as they arise. In the mean time, your examination i
of the potential safety implications of the TRT findings should include, but l
not be limited to the areas or' activities selected by the TRT.
e In order to fully discuss these concerns with you we are scheduling a meeting
]
4 for January 17, 1985 which will be held in our office in Bethesda, Maryland.
This meeting will provide an opportunity to ask questions regarding these concerns prior to formulating your program plan. Additional meetings will be held at NRC request as your program plan is formulated.
j This request. is submitted to you in keeping with the NRC practice of promptly notifying applicants of outstanding information needs that could potentially j
affect the safe operation os their plant. Future requests for information of j
this nature will be made, if necessary, as TRT technical reviews continue.
l Sincerely, bn varre gis
. DTrector Division of Licensing 4
l Office of Nuclear Reactor Regulation
Enclosure:
As stated.
cc w/ enclosure:
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See next page l
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COMANCHE PEAK Mr. M. D. Spence Presiiient Texas Utilities Generating Company 400 N. Olive St., L.B. 81 Dallas, Texas 75201 c.::
Nicholas S. Reynolds, Esq.
Mr. James E. Cumins Bishop, Libeman, Cook, Resident Inspector / Comanche Peak Purcell & Reynolds Nuclear Power Station 1200 Seventeenth Street, N. W.
c/o U. S. Nuclear Regulatory Washington, D. C. 20036 Comission P. O. Box 38 Robert A. Wooldridge, Esq.
Glen Rose, i'exas 76043 Worsham, Forsythe, Sampels &
Wooldridge Mr. Robert D. Martin 2001 Bryan Tow,er, Suite 2500 U. S. NRC, Region IV Dallas, Texas 75201-611 Ryan Plaza Drive Suite 1000 Mr. Homer C. Schmidt Arlington, Texas 76011 Manager - Nuclear Services Texas Utilities Generating Company Mr. Lanny Alan Sinkin Skyway Tower 114 W. 7th, Suite 220 400 North Olive Street Austin, Texas' 78701 L. B. 81 Dallas, Texas 75201 B. R. Clements Vice President Nuclear Mr. H. R. Rock Texas Utilities Generating Company Gibbs and Hill, Inc.
Skyway Tower 393 Seventh Avenue 400 North Olive Street New York, New York 10001 L. B 81
. Dallas, Texas 75201 Mr. A. T. Parker Westinghouse Electric Corporation William A. Burchette. Esq.
P. O. Box 355 1200 New Hampshire Avenue, N. W.
Pittsburgh, Pennsylvania 15230 Suite 420 Washington, D. C.
20036 Renea Hicks, Esq.
Assistant ~ Attorney General Ms. Sillie Pirner Garde Environmental Protection Division Citizens Clinic Directer P. O. Box 12548, Capitol Station Government Accountability Project Austin, Texas 78711 1901 Que Street, N. W.
Washington, D. C.
20009 Mrs. Juanita Ellis, President Citizens Association for Sound David R. Pigott, Esq.
Energy Orrick, Herrington & Sutcliffe 1426 South Polk 600 Montgomery Street Dallas, Teras 75224 San Francisco, California 94111 Ms. Nancy H. Williams Anthony Z. Roisman, Esq.
CYGNA Trial Lawyers for Public Justice 101 California Street 2000 P. Street, N. W.
San Francisco, California 94111 Suite 611 Washington, D. C. 20036
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COMANCHE PEAK
' cc:
Mr. Dennis Kelley-Resident Inspector - Comanche Peak clo U. 5. NRC P. O. Box 1029 Granbury, Texas - 76048 Mr. John W. Beck Manager - Licensing Texas Utilities Electric Company Skyway Tower 400 N. Olive Street L. B. 81
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Dallas, Texas 75201 Mr. Jack Redding Licensing Texas Utilities Generating Company 4901 Fairmont Avenue Bethesda, Maryland 20014
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i Enclosure Technical Review Team Findings Resulting From Quality Assurance / Quality Control Allegations In evaluating the QA/QC program at CPSES, the Technical Review Team (TRT) com-pleted the following:
(1) interviewed Texas Utilities Electric Company (TUEC) and Brown & Root (B&R) personnel and allegers, (2) reviewed quality assurance records, selected affidavits, transcripts and depositions, and NRC Regional and i
j Office of Investigations reports, and (3) physically inspected hardware to evaluate the safety significance of quality assurance / quality control (QA/QC) allegations at Comanche Peak Steam Electric Station (CPSES).
1 QUALITY ASSURANCE PROGRAM The TRT found that a'lthough the TUEC QA program documentation met NRC require-ments, the weaknesses of its implementation in several areas demonstrate that TUEC lacked the commitment to aggressively implement an effective QA/QC program in several areas:
A.
TUEC failed to periodically assess the overall effectiveness of the site QA progree in that there have been no regular reviews of program adequacy by senior management.
Further, TUEC did not assess the effectiveness of its QC inspection program.
B.
During the peak site construction period of 1981-2, TUEC employed only four auditors, all of whom had questionable qualifications in technical disciplines. Although charged with overview of all site construction and associated vendors, these Dallas based auditors provided only limited QA surveillance of construction activities.
l C.
Repetitive NCRs were issued that identified the need to retrain con-struction personnel in the requirements and contents of QA procedures.
One corrective action request (CAR) dealir.g with inadequate construc-tion training and records remained open for one year. The identical problem was identified in a subsequent CAR, which still nad not been closed at the time of the TRT's onsite review.
D.
The TRT found many examples of incomplete and inadequate workmanship and ineffective QC inspection in TUEC's evaluation of the as-built program.
(See Section 4 for a detailed discussion.)
p E.
Some craft workers newly assigned as QC inspectors were in a position to inspect their own work and records.
Site management did r.ot view this lack of separation between production and inspection roles as a potential cenflict-of-interest.
^
F.
There were potential weaknesses in the TUEC 10 CFR 50.55(e) deficiency-l reporting system. Applicable procedures did not identify what types l
l f D 2-1 y s\\
t
of deficiencies constituted significant breakdowns in the QA program,
{
nor how they should be evaluated for reportability to the NRC.
Evalu-i ation guidelines for reporting hardware deficiencies lacked clarity and definitive instructions and the threshold for reporting deficien-cies was too high. Specific past and present cons *.ruction deficien-cies that were not reported by TUEC are listed in St tions 4, 5 and 11 of this enclosure.
i G.
The TUEC exit interview system for departing employees appeared to be neither well structured nor effective, as evidenced by the lack of employee confidence, limited implementation, failure to document explanations and rationale, and failure to complete corrective actions and to determine root causes.
H.
The B&R corrective action system was generally ineffective and was bypassed by the B&R QA Manager, as exemplified in the following instances:
1.
There were no definitive instructions to describe the types of problems that required corrective action. Minimal procedural instructions resulted in corrective action decisions frequertly being left to the judgement of the QA Manager.
2.
Since June 1983,.B&R had issued no Corrective Action Requests 1
(CARS), and was substituting menos and letters of concern for this function. This shortcut had become a regular method of operation and appeared to bypass the CAR system.
i I.
The TUEC corrective action system was poorly structured and ineffec-tive in that:
1.
Controlling procedures were brief and general.
I 2.
There was no translation of FSAR requirements on trending and no details on how trend analyses were to be accomplished.
t 3.
Quarterly reports were not issued in a timely manner.
4.
The method of categorizing 1)roblems by building did not assure meaningful trend analysis.
4 5.
A 1984 CAR report identified three items requiring action; how-ever, none had been taken.
i 6.
CAR 029 was used as a vehicle for a specific disposition rather than for generic action, as intended by the CAR system.
.i l
2 QUALITY CONTROL INSPECTION i
The TRT evaluated the CPSES QC program to determine if it was functionally
[
effective and if'the QC system and organization effectively ensured consistent
~
quality of design, procedures, processes and product at the plant. The results of this review showed the following problems.
'I i
2-2 i
l A.
Based on the TRT review of about 200 fuel pool travelers, TUEC was unable to maintain an effective and controlled QC program for fuel-i pool liner fabrication, installation, and inspection. Typical fuel pool traveler irregularities were:
1.
There was apparently a routine practice during construction of the fuel pool that allowed craft personnel to complete a portion of.the inspection report forms prior to the actual inspection.
Craft personnel entered the word " SAT," dated the entry, and-left blank only the space for the QC inspector's signature.
It appeared that the craft personnel were judging the inspection
. results prior to inspections.
2.
The date accompanying the ' signature for visual examination of an inside weld was changed to a date that appeared to precede the examination.
3.
Entries by the same inspector for two different inspections did not appear to match in that one entry appeared to be written by another person.
4.
The procedure number for a dye penetrant inspection was changed
'by an inspector different from the one who conducted the inspection.
5.
The date for a dye penetrant inspection was changed by an inspector other than the one who performed the inspection.
/
4 6.
Fuel pool travelers were found with missing QC signoffs for t
fitup and cleaniness. No proof could be found that some of the required weld fitup and cleanliness inspections were ever performed.
7.
The TRT review disclosed the following irregularities with traveler entries in addition to those listed above:
(a) Data changes after the fact (b) Signoffs for functions out of sequence (c) Corrections after the fact (d) Changcs to first party inspector date signoffs (e) Missing signatures B.
There were examples of limited corrective action including vendor-supplied pipe whip restraints that had received inadequate source inspections. Twelva NCRs were issued ineilving weld defects on these restraints. TUEC corrective action inclucid paint removal from only a sample of the welds and 21 restraints ware selected for. reanalysis; however, the TRT'found no basis or criteria for paint removal or how
.the worst case restraints were identified.
The reviews of allegations in the Civil and Structural, Coatings, Electrical, Test Programs, and Piping and Mechanical areas also indicate QC insnection g
deficiencies, as provided in our letters of Stjtimber 18, and November 29, 1984.
1 2-3 i
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i i
3 T-SHIRT INCIDENT The T shirt incident has previously been explored in many forums, including hearings before the Atomic Safety and Licensing Board. The TRT has examined this matter, but will not now describe all of the associated issues.
Impor-tantly, however, the TRT believes that TUEC m..iagement failed to adequately investigate the incident to determine its root cause, but reacted as though the QC inspectors involved were guilty of disruptive behavior.
Of particular concern to the TRT is the strong perception that TUEC QA management may have acquiesced to pressures and complaints from construction personnel and may have failed to adequately support their QC workforce.
4~
INSPECTIONS OF AS-BUILT PIPE AND ELECTRICAL RACEWAY SUPPORTS The TRT conducted a series of inspections encompassing as-built safety-related pipe support and electrical raceway support installations. These inspections were of completed systems or components that had been previously inspected and accepted by TUEC QC,as meeting the respective construction and installation requirements.
A.
Pipe Support Inspections Tables 1 and 2 are indicative of the scope of the TRT-pipe support as-built inspection effort. Of the 42 pipe supports inspected, 37 were randomly selected, while 5 originated from an alleger's list. Forty-six deficien-cies were identified in the supports inspected. Following are examples of the deficiencies identified and the applicable criteria. TUEC's final QC inspections of this sample ranged from December 1982 to October 1984.
l 1.
Component Support Welds:
'(a) Applicable criteria ASME Section III, NF Subsection and subarticles NF-4424 and NF-5360 set forth rules for examining welds.
(
B&R QI-QAP-11.1-28 Revision 25. Paragraph 3.5.5.1 delineates l
criteria for the examination of welds, including inspection parameters for acceptable weld sizes.
The TRT found supports exhibiting welds that did not appear to be in accordance with the above-referenced codes and procedures.
i (b) Examples.of deficient welds (1) Support No. AF-1-001-001-533R. Discrepancias included porosity; insufficient weld leg; incomplete welds and insufficient fill. This support was removed, scrapped, and completely rebuilt subsequent to the TRT inspection.
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Table 1 Pipe supports in unit 1 Supports' Inspected by TRT As-Built group
- 42 Class 1 supports inspected 4
i Class 2 supports inspected 14 Class 3 supports inspected 24 Hangers with problems
- 26 Total problems identified 46 Procedure adequacy problems 5
Hardware-related problems 16 As-built drawing related problems 8
Component identification problems 2
Weld-related problems 10 QC record problems 1
Material identification problems 4
Welds inspected without paint by TRT 305 Welds inspected with paint by TRT 89 Total welds-inspected by TRT 394 Welds needing weld repair 10
% of welds inspected 2.5%
Supports needing welding repair 6
% of supports inspected 14%
No. of Supports Bldg System Inspected Containment Safety Injection (SI) 1 Containment Reactor Coolant (RC) 6 Containment-Residual Heat Removal (RHR) 2 Fuel Handling Component Cooling (CC) 11 Safeguards Residual Heat Removal (RHR) 1 Safeguards Containment Spray (CT) 8 Safeguards Domineralized Water (DD) 1 Safeguards Auxiliary Feedwater (AF) 8 i
Auxiliary Chemical Volume & Control (CS) 1 Safeguards Main Steam (MS) 2 Safeguards Chilled Water (CH) 1 "All 42 pipe supports inspected by tne TRT had been previously accepted by site QC.
4 i
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1 Table 2 Pipe supports in unit 1*
Problem Category Hanger No.
No. of Problems Type e
- 1. No locking device for threaded fasteners RC-1-901-702-C82S 2
Hardware problem '
CS-1-085-003-A42K l
- 2. Min, edge distance (on base plate) violated CC-X-039-006-F43R 1
Hardware prob.
- 3. Baseplate hole-location dimansions out of tolerance CC-X-039-007-F43R 4
As-Built prob.
I i
CC-1-126-010-F33R I
CC-1-126-011-F33R I
I CC-1-126-012-F33R l
- 4. Spherical bearing / washer gap excessive CC-1-126-015-F43R 4
Hardware prob.
RC-1-052-016-C41K RC-1-052-020-C41K MS-1-416-001-533R l
S. Spherical bearing contamination SI-1-090-006-C41K 2
Hardware prob.
g MS-1-416-002-533R i
- 6. Snubber adapter plate-insufficient thread engagement MS-1-416-002-533R 3
Proced. prob.
i SI-1-090-006-C41K m
l ln CT-1-013-012-532K
- 7. Insufficient threaded eng'et, threaded rod RC-1-901-702-C82S 1
Hardware prob.
(sight holes)
- 8. Snubber / Strut load pin locking device broken or AF-1-001-014-533R 1
Hardware prob.
l missing I
- 9. Load side of pipe clamp halves not parallel
. AF-1-001-001-S33R 2
Proced. prob.
i AF-1-001-014-S33R
- 10. Pipe clearances w/ support out of tolerance CC-1-126-013-F33R 2
Hardware prob.
AF-1-001-702-533R
- 11. Pipe clamp locknut loose AF-1-03S-011-533R 1
Hardware prob.
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- All 42 pipe supports inspected by TRT had been previously accepted by site QC.
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1 m
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1 Tablo 2 (Continued) Pipe supports in unit 10 Problem Category Hanger No.
No. of Problems M
- 12. Snubber / Sway strut misalignment CC-1-126-014-F43R 2
Hardware problem -
j RC-1-052-020-C41R
- 13. Snubber cold set dimension does not match drawing CS-1-085-003-A42k 1
As-Built prob.
i
- 14. Snubber orientation does not match drawing CT-1-005-004-522K 2
As-Built prob.
4 CT-1-013-010-522K
- 15. Component type /model no. installed does'not match SI-1-090-006-C41K 2
Compon. ID prob, drawing RC-1-052-020-C41R f
- 16. No identification for support materials, parts, and CT-1-013-014-532R 4
Mati. identific.
components CC-1-126-012-F33R prob.
i CC-X-039-005-F43R l
AF-1-035-011-S33R 17.
BRP column line dimension does not match.8RHl.
Support not affected 1
As-Built prob.
1 Dimenslota
{
- 18. Weld porosity excessive AF-1-001-001-533R 1
Weld-related prob.
- 19. Weld undercut excessive AF-1-001-702-533R 1
Weld-related prob.
- 20. Weld length undersized AF-1-001-001-333R 1
Weld-relat'ed prob.
1 j
- 21. Weld leg or effective throat undarsized AF-1-001-001-533R 3
Weld-related prob.
i RH-1-006-012-C42R i
CC-X-039-007-F43R
- 22. Weld called out on drawing does not exist in fiele CC-1-126-013-F33R 1
Weld-related prob.
- 23. Welds added in field are not reflected on drawing AF-1-001-702-S33R 1
Weld-related prob.
numerous welds
- 24. Excessive-grinding resulting in min. thickness AF-1-037-002-533R 2
Weld-related prob.
violations (weld clean-up)
CT-1-013-014-S32R
. 25. No QC Buy-off on weld data card CC-1-126-013-F33R
_1 QC record problem 1
46 Total problems 1
identified by TRT
- All -42 pipe supports inspected by TRT had been previously accepted by site QC.
i l
(2) Support No. AF-1-001-702-533R.
Exhibited extraneous welding that was not documented on the as-built drawing. One of the required welds was undercut beyond the limits of acceptance (this weld was subsequently repaired).
(3) Support No. CC-1-126-013-F33R.
Support drawing required a 1/4" fillet weld to connect item 5 to item 6.
This weld was omitted in the field.
(4) Support No. CC-X-039-007-F43R. A required'5/16" all-around fillet weld had an approximstely 1/16" undersize weld leg for the length across the top flat of the tube steel.
(5) Support No. RH-1-006-012-C42R. An all-around 1/4" fillet weld connecting item 5 to item 7 was undersized by 1/32" to 1/16" across the top.
(6). Support No. AF-1-037-002-S33R..This support exhibited a
'1/16" to 3/32" reduction in plate thickness and weld size due to excessive grinding of the weld at the base plate.
Base material thickness of the support plate was reduced beyond the limits of acceptance in three locations.
(7) Support No. CT-1-013-014-S32R.
Excessive overgrinding of welds resulted in notching of the sway strut rear brackets.
This condition was repaired subsequent to the TRT inspection.
2.
Lockina Device for Threaded Fasteners:
.(a) Applicable criteria Subarticle NF-4725 states in part that all threaded fasteners, except high-strength bolts, shall be provided with locking devices to prevent loosening during service.
ASME Sect. III, Div.1 Interpretation No. III-1-83-49R provides that the user should satisfy himself that any other device than those described in NF-4725 is capable of acting as a locking device under all service conditions.
Brown & Root Procedure QI-QAP-11.1-28, Attachment 2, Operation 7, l
Inspection Attribute h., requires that all exposed threads be free of extraneous material.
CPSES/FSAR, Paragraph 17.1.2 states that the design verification i
procedure assure that drawings, specifications, procedures, and l
instructions meet stipulations of related codes and standards, i
10 CFR 50.55(e)(1) directs that the holder of the construction permit shall notify the NRC regarding each deficiency found in design and construction which, if not corrected, could adversely affset the safety of operations at any time throughout the expected lifetime of the plant.
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t There appeared to be a difference in locking devices on threaded fasteners for similar pipe support hardware made by two separate vendors. Whereas l
in some cases Nuclear Power Service Incorporated (NPSI) specified only one nut and no locking device, ITT-Grinnell required two nuts in those same applications. If the design of NPSI models indeed should be found to need the locknuts or their equivalent, there could be hundreds of pipe supports 1
installed without adequate locking devices.
4 The TRT found examples in Unit I where deficiencies existed so that TUEC was in potential violation of the codes, procedures, guidelines, l
and commitments concerning locking devices for threaded fasteners.
In spite of the requirements pursuant to 10 CFR 50.55(e)(1), TUEC did not report to the NRC the omission of thread-locking devices in the Unit I nuclear safety systems and did not httempt corrective action until May 1984, when TUEC tested previously applied paint for thread-lock capability. That test was inconclusive, since it did not estab-lish that the paint, an epoxy process, would reliably perform as an effective locking device under all service conditions and throughout the expected l'ifetime of the plant.
Further, TUEC could not. identify to the TRT which paint was the subject of testing.
TUEC had a potentially inadequate quality assurance specification j
No. 2323-AS-31, which did not cover inspection of painted threaded fas-l teners. The paint was applied to ASME code-controlled, NF hardware per specification 2323-AS-30 (non-Q) which required no inspection. This issue 3
]
appears to be generic for Unit 1.
The TRT notes that TUEC did not initiate an NCR identifying the widespread i
problem of missing locknuts; only a Request for Information was generated, I
which TUEC could net locate for the TRT. An NCR, required by procedure, would have brought the problem and its ramifications to management atten-tion and would have provided a vehicle for controlled, organized, and l
l approved engineering disposition.
(b) Examples of deficient locking devices.
I Pipe support RC-1-901-702-C825 had a load bolt at a beam attach-ment which did not exhibit an approved locking device.
(The bolt i
i material type was SA-307 grade A.) Additionally, pipe support CS-1-085-003-A42K had no approved locking device on the "special j
clamp" bolts, even though the design drawing for this clamp showed each bolt with a nut and a locknut.
i 3.
' Minimum Edoe Distance for Bolts:
e (a) Applicable criteria-i QI-QAP 11.1-28 Revision 19. Paragraph 6.1 required that bolt i
i
' holes in structural. members shall not be closer than 1-1/2 times the bolt diameter from the edge of the member to the center of the bolt hole.
2 r
2-9 l
i l
i ASME Sect. III Div. 1, Subsection NA, Appendix XVII Table XVII-2462-1(b)-1, gives specifically allowed minimum edge dis-
~
tances for bolt holes (reamed, punched or drilled) at sheared or rolled edges of plates, shapes, or bars.
i (b) Example of minimum edge distance violation The baseplate for pipe support CC-X-039-006-F43R, located in the component cooling system, Room 249A, Fuel Handling Building, violated minimum edge distance criteria for bolt holes-4.
Base Plate Hole-Location Dimensions:
(a) Applicable criterion QI-QAP-11.1-28, Revision 19, Attachment 4, Paragraph 2, under
' fabrication tolerances, limits a " hole centerline location to 11/4" or as shown on the design drawing."
~
(b) Examples of hole-location dimension problems The TRT found the horizontal member of Support CC-1-126-010-F33R i
was 3 inches lower at its centerline relative to the upper bolt-hole centerline than shown on the vendor-certified drawing. The as-built drawing had not been revised to reflect the actual installed condition in the plant. This support was located in j
the component cooling system, Room 247A, in the' Fuel. Handling Building. Other supports with similar hole-location violations found in the inspections were:
CC-X-039-007-F43R, CC-1-126-011-F33R, and CC-1-126-012-F33R.
5.
Spherical Bearina Gap:
(a) App 1'icable criterion Brown & Root Procedure, QI-QAP 11.1-28, Revision 25 paragraph 3.7.3.1 states that "a sufficient number of spacers shall be used to prevent the spherical bearings from becoming dislodged," and "in no case shall the resulting gap be more than the thickness of one vendor-supplied spacer."
(b) Examples of spherical bearing gap deficiencies An excessive free gap existed between spherical bearing and washers on the sway strut assembly of support CC-1-126-015-F43R.
Other supports with similar bearing gap anomalies found in TRT's inspections were: RC-1-052-016-C41X, RC-I-052-020-C41K, and 3
MS-1-416-001-533R. The frequency of this type of procedure vio-1 lation in the TRT's limited inspection suggests that this problem is generic for Unit 1.
M i
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l 6.
Spherical Bearina Co'ntamination:
(a) Applicable criterion l
QI-QAP-11.1-28 Revision 22, Paraaraph 6.3.1 Note 2 states in part that " bearing internal and external surfaces shall be free of rust and foreign material, and bearing shall move freely within the housing."
4 (b) Examples of spherical bearing contamination Thr TRT found paint contamination in the bearings of both snubber 1
asremblies on component support SI-1-090-006-C41K that severely obstructed the bearing cavities and limited their movement. This Class 1 component support is located in the Containment Building of the Unit 1 safety injection system. A similar condition exists on support MS-1-416-002-533R.
7.
Snubber Adapter Plate Boltina - Lack of Full Thread Enaagement:
1 (a) Applicable criteria QI-0AP-11.1-28, Revision 22, Paracraph 6.1, states that "all bolts, studs, or threaded rods shall have full thread engagement in the nut."
i ASME Sect. III Div. 1. Subsection NF, Subarticle NF 4711 states that "the threads of all bolts or studs shall be engaged for the i
full length of thread in the nut."
i QI-0AP-11.1-28. Revision 25, Attachment 29 permits less than full thread engagement in threaded plates.
This allowance for less than full thread engagement is a potential violation of the ASME Code Sect. III, NF-4711; no code case was invoked to set aside this procedure. The requirement of NF-4711 that "the l
threads of all bolts or studs shall be engaged for the full length of thread in the nut" also implies that there be a full i
length of a threaded hole in plates, shapes, or bars where the l
required threaded hole length is the same as the bolt diameter.
Further, there is no evidence ~ that partial thread engagement at the snubber adapter plate connection has been given consideration in the design procedures for linear-type supports, nor does it appear that sufficient design margins have been introduced to l
allow for less than full-threaded connection. The TRT did not check "as-built" analyses to determine whether any such varia-tions fmm the design norm had been considered in the "as-built" stress calculations.
What is in question is whether any calculations had been made to address this particular thread engagement condition for each size snubber being used in the plant..
h t
2-11 h
I
(b) Examples of lack of full thread engagement Snubber (shock arrester) adapter plate bolt threads were insufff-
. ciently engaged in all four threaded holes of component support MS-1-416-002-533R. The worst condition was 0.095" short, or more than 25% less than full thread engagement.
Similar lack of #ull thread engagement deficiencies was found on NF supports SI-1-090-006-C41K and CT-1-013-012-S32K.
8.
Threaded Rod Thread Engagement:
(a) Applicable criterion QI-QAP-11.1-28, Revision 21, Paragraph 6.3.2.a. directs that "QC shall verify thread engagement if site [ sight] holes are present in the strut body."
(b) Example of rod thread engagement deficiency Sight holes were present in the strut body to verify threaded rod engagement. The rod was not visible through the sight hole for support RC-1-901-702-C825.
9.
Snubber / Sway Strut Load Pin L'ocking Device:
(a) Applicable criterion QI-QAP-11.1-28, Revision 22, Paracraph 6.3.1.1.b states that "the size of the cotter pins, when used, should be the maximum size the hole will accommodate and shall be fully opened."
(b) Example of locking device deficiency i
Sway strut No. AF-1-001-014-S33R had a broken cotter pin.
I 10.
Load Side of Pipe Clamp Halves Not Parallel:
(a) Applicable criterion QI-QAP-11.1-28, Rev. 25, Sec. 3.7.3.1 states that " pipe clamp halves, in relation to attaching eyerod end, shall be parallel."
(b) Examples of. halves not parallel i
Clamp halves for pipe supports AF-1-001-001-S33R and i
AF-1-001-014-533R were not parallel.
11.
Pipe Clearances Outside of Allowable Tolerance:
(a) Applicablecritefion QI-QAP-11.1-28, Revision 19, Attachment 4, item 3.b states "where the design shows 0" on one side and 1/16" on the other, 0" must be maintained while 1/16" i 1/32" is required on the other side."
2-12
(b) Examples of pipe clearance violations Pipe support CC-1-126-013-F33R exhibited no clearance on top or bottom, while the hanger drawing called out'0" on the bottom and 1/16" on top. A-similar problem existed for pipe support AF-1-001-702-S33R.
12.
Pipe Clamp Locknut Loose:
(a) Applicable criterion QI-QAP-11.1-28 Revision 21, Sect. 6.1 states' that "unless other-wise shown or, the drawing, fasteners will be tightened securely."
(b) Example of loose locknut A pipe clamp locknut for pipe support AF-1-035-011-S33R was found loose (less than finger-tight).
- 13. Snubber / Sway Strut Misalignment:
(a) Applicable criterion QI-QAP-11.1-28, Revision 18, Sect. 6.3.1.d states that " maximum sway strut misalignment shall not exceed 5* for ITT-Grine11 and NPSI from the centerline of the sway strut."
(b) Examples of misalignment Pipe support CC-1-126-014-F43R exhibited angularity that exceeded this requirement. A similar problem existed with pipe support RC-1-052-020-C41R.
(a) Applicable criterion QI-QAP-11.1-28, Revision 24, Sec. 3.8.3.5.b states that "devia-tion of more than i 1/8" from the specified cold setting (AC
[
dimension shown on the design drawing) is not permitted, unless authorized by a design change."
l (b) Example of incorrect AC dimension i
Pipe support CS-1-085-003-A42K deviated by approximateTy~1" from the cold set dimension shown on the design drawing.
- 15. Support Configuration Did Not Match Orawing:
(a) Applicable criterion QI-Q P-11.1-28, Revision 24, Attachment 2, Operation 3 lists the
[
following inspection attribute:
" support configuration complies with the design drawing."
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(b) Examples of configuration problems Pipe support snubber CT-1-005-004-522K was installed end-to-end opposite from the orientation shown on the drawing. A similar problem existed with pipe support CT-1-013-010-S22K, where dimen-sional discrepancies existed on the support drawing that detailed the orientation of the snubber.
l l
- 16. Component Type /Model No. Installed Did Not Match Drawing:
l (a) Applicable criterion QI-QAP-11.1-28, Revision 24, Sect. 3.2.1.1 states that " vendor-supplied NPT stamped component supports shall bear marking (i.e.,
name plate) traceable to the design drawing."
(b) Examples of component identification problems.
Mode'l numbers of installed snubbers for pipe support 4
SI-1-090-006-C41K did not match the model number on the design drawing. A similar problem existed with pipe support i
RC-1-052-020-C41R.
(a) Applicable criterion QI-QAP-11.1-28. Rev. 25, Paragraph 3.5.3 Welder and Weldina
. Material Verification states that "The QCI shall verify that the welder is qualified to make the weld utilizing the welder quali-fication matrix (attachment 16, typical), that the use of the I
WPS (Attachment 17, typical), and the type of filler material listed on the WFML [ weld filler material log] are the same as l
those listed on-the weld data card (WDC), and the welder's j
symbol has been recorded on the WFML."
l (b) Example of deficient weld data card Support number CC-1-126-013-F33R had some welds performed with no QC inspector initials or signature on the corresponding blocks of
-the weld data card for that support inspection package.
i 18.
Identification of Natorials and Parts:
(a) Applicable criteria 10 CFR 50 Appendix B, Criterion VIII states that " measures shall assure that identification of the item is maintained by heat I
number, part number, serial number or other appropriate means either on item or on records traceable to the ites, as required throughout fabrication, erection, installation and use of the ites."
~
2-14
QI-QAP-11.1-28, Revision 19, Sect. 3.1.2 states that "at installation inspection, the QC inspector shall verify the hanger number, the material type, grade and heat number... using the information provided on the Material Identification Log."
(b) Examples of material identification deficiencies A replacement part (sway strut eyerod) for pipe support' CT-1-013-014-532R had no apparent material identification either on the hardware or in the documentatir 26.~. ge for the support.
The Material Identification Log (MIL:
d not list any identi-fication traceable to the origin of.ne replacement part. A similar problem existed with pipe supports CC-1-126-012-F33R, CC-X-039-005-F43R, and AF-1-035-011-533R.
B.
Deficiencies with High Rate of Occurrence The following pipe support inspections by the TRT were in addition to those already listed in the previous examples. Results of these ancillary inspections are summarized in Table 3.
The TRT identified six specific deficient items which need further evalua-tion to assess their generic implications. The TRT concern is that these items may have a high rate of occurrence throughout plant safety-related systems. The specific " frequently occurring" items and relevant inspec-tion criteria were as follows:
(1) Strut and snubber load pin spherical bearing clearance with washers was excessive (Ref. QI-QAP-11.1-28, Sec. 3.7.3.1 Rev. 25).
(2) Strut and snubber load pin locking devices (cotter pins or snap lock rings) were damaged or missing (Ref. QI-QAP-11.1-28 Rev. 25, which did not specifically address load pin locking devices).
(3) Pipe clamp halves on load side were not parallel-(Ref. QI-QAP-11.1-28, Sec. 3.7.3.1 Rev. 25).
(4) Bolts threaded into tapped holes of snubber adapter plates had less than full thread engagement (a " frequently occurring" deficiency; see related discussions on pipe supports, example 7 " Snubber Adapter Plate Bolting - Lack of Full Thread Engagement" within Part A of this section on as-built inspection).
(5) "Hilti Kwik" bolts (concrete expansion anchors) as installed did not meet'ainimum effective embedment criteria (Ref QI-QP-11.2-1, Sec. 3.5.1 Rev. 16).
(6) Locking devices for threaded fasteners were missing or of a non-approved type (see ites 2 " Locking devices for threaded fasteners" on pipe support deficiencies within Part A of this section on as-built
' inspection).
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Table 3 Summary of additional TRT inspections Area: Room 77N, El 810'-6" Unit 1, Safeguards Bldg No. of Supports No. of Supports Deficiency Inspected Deficient
% Deficient Item 1.
Excessive 92 5
5.4%
Spherical Bearing Clearance Item 2.
Load Pin Locking 92 14 15.2%
Device Missing Item 3.
Pipe Clamp Halves 40 9
22.5%
Not Parallel Item 4.
Snubber Adapter 19
- 13 to be Plate Bolts With determined Less Than Full Thread Engagement Area: Cable Spread Room 133. El 807'-0" Unit 1, Auxiliary Bldg Deficiency Bolts Inspected NL'aber Deficient
% Deficient t
Item 5.
Hilti Kwik Bolt 24 3
12.5%
Does Not Meet Minimum Embedment**
- Bolts had less than full thread engagement.
- Taking into account the " allowed" slippage of the bolt for a distance of one nut thickness due to torquing (Ref. " Installation of 'Hilti' Drilled-In Bolts" 35-1195-CEI-2D, Rev. 3, Para. 3.1.4.1) and the minimum specified embedment, the above Hilti bolts violated the " effective" embedment requirements.
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The TRT undertook additional hardware inspections to ascertain the regu-larity with which these specific items may exist. All accessible pipe supports in Room 77N, at tne 810-foot, 6-inch elevation of the Unit 1 Safeguards ~ Building, were inspected for " frequently occurring" def t-ciencies 1, 2, 3 and 4 listed above.
To assess the level of occurrence of
" frequently occurring" deficiency 5, electrical support 'Hilti' baseplates located in the Cable Spread Room 133, at the 807-foot elevation of the Unit 1 Auxiliary Building, were inspected. For details on " frequently occurring" deficiency 6, see item A.2, " Locking Device for Threaded Fas-teners," of the pipe support deficiencies, described above.
C.
Electrical Raceway Support Inspections The TRT inspected electrical conduit supports and cable tray hangers to the requirements of QI-QP-11.10-1, Inspection of Seismic Electrical Support and Restraint Systems; QI-QP-11.21-1, Requirements of Visual Weld Inspection; and other applicable instructions for conduit support and cable tray. hanger inspections. All electrical raceway supports included in TRT inspections had been previously QC accepted. Table 4 summarizes the results of the TRT inspections not previously provided 1
as part of our letter of September 18, 1984.
The TRT found the following discrepancies during its inspection of j
selected electrical. conduit supports and cable tray hangers in Unit 1:
1.
Undersize Welds:
(a) Applicable criterion DCA 3464. Rev. 23, page 3 of 32, note 3 states -in part that
" welding requirements as shown on various details should be read as the minimum requirement."
(b) Examples of undersize welds Three of four welds on conduit support C120-21-194-3 (cable spread room) were undersized. The required weld size was 1/4" at all weld joints, while the measured weld size was i-7/32" to 5/32" for the full lengths of three out of the four welds.
Similarly, cable tray hanger CTH 5824 (Containment Building) had 12 undersize welds. The all-around welds on the six horizontal beams should be 1/4" in size, according to details Li and L2 on Orawing FSE-00159, sheet 5824,1 of 2.
The measured size of these welds was 3/16" to 5/32" at each connection. Also, support IN-SP-7b exhibited undersize welds measuring 7/32" to 5/32" instead of the required 1/4".
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Table 4 Summary of electrical raceway support inspection by the TRT - unit 1 Support welds inspected 59 Supports inspected 5*
Supports with problems 3 (60%)
Types of problems Hardware-related, other than welding 6
Unauthorized configuration change 1
Weld-related types of problems (categories) 2 Welds requiring rework 41 Welds made in field but not recorded on drawing 80**
Beam stiffeners added but not recorded on drawing
~40 Building / Area Supports Cable Spread Room CTH 12646 C 130-21-250-3 C 120-21-194-3 Auxiliary Building CTH 6742 Containment CTH 5824
- All electrical supports inspected by the TRT had been previously inspected and accepted by QC.
- Full visual inspection was not performed by the TRT on these extra welds.
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Misplaced Welds:
1 (a) Applicable criterion QI-QP-11.10-1, Revision 29, Paragraph 3.5.2, Assembly Inspection, includes the requirement to inspect a support for configuration.
Paragraph 3.6.2 of the same procedure requires that support welds receive visual inspection and that nonconforming welds be reported.
(b) Examples of misplaced welds During inspection of Hanger CTH-6742, the TRT found that two structural welds were made in the wrong direction. The 3/16" shop welds which join MK-10 and MK-11 were made hori-zonta11y instead of vertically, as shown on drawing FSE-00159, sheet 6742. QC Inspection Report ME-I-0024909,
, dated February 16, 1984, accepted-all inspectable attributes as satisfactory prior to the TRT inspection.
3.
Unauthorized Configuration Chances:
(a) Applicable criterion QI-QP-11.10-1, Inspection of Seismic Electrical Support and
. Restraint Sy-tems, paragraph 3.5.2 includes the requirement for inspection of a support for configuration compliance.
(b) Examples of configuration change The TRT found that cable tray hanger CTH 5824 (Containment Building) had been fabricated to include 40 more stiffeners and 80 more welds than required or shown on drawing FSE-00159, sheet 5824, 2 of 2, Detail Ls.
Inspection Report ME-1-0006155 verified final QC inspection and acceptance on January 3 1984.
Further, cable tray hanger CTH-6742 (Auxiliary Building),
Clip, MK-12, should be 6" x 6" x 3/4" angle stock in accord-ance with FSE-00159, sheet 6742. The actual flange thick-ness of MK-12 was 3/8".
4.
Hilti Anchor Bolt Installation Deficiencies:
(a) Applicable criterion QI-QP-11'.2-1 Concrete Anchor Bolt Installation, provided requirements for proper installation and inspection of Hilti anchor bolts.
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(b) Examples of Hilti bolt deficiencies CTH-6742 (Auxiliary Building) anchor bolt torque was not verified (paragraph 3.5 of the procedure). Hilti bolts were not marked in accordance with attachment 1 of the procedure, nor was the length of these bolts verifiable (paragraph 3.2).
CTH-5824 (Containment Building) base plate bolt holes had violated minimum edge distance-edge distance cannot be less than 1 7/8" (Attachment 2 of the procedure). Actual dis-tance was 1 5/8" to 1 3/8" from the nearest plate edge.
This condition affected five of the eight Hilti anchor bolt holes in the base plates for this hanger.
One Hilti bolt was skewed to more than 15 degrees. Maximum allowable skew was 6 degrees without corrective bevel washers (paragraph 3.1.2).
t
'The Hilti bolt torque on this hanger CTH 6741 (Auxiliary Building) was not documented as being verified by QC (paragraph 3.5).
5.
Undersize Nuts:
There was inconsistency in the application of nuts for SA-325 bolts in that both standard and heavy hex nuts were used. No stipulation was found which would permit the use of standard (non-heavy) hex nuts. This condition is a potential violation of the Material Specification ASTM A325 (ASTM, Part 4-1974) paragraph 1.5, which provides that " heavy hex structural bolts and heavy hex nuts shall be furnished unless other dimensional requirements are stipulated...." B&R Drawing No. FSE-000159, sheet 5824, 2 of 2, required the use of ASTM A325 bolts for cable tray hanger number CTH-5824.
O.
Summary of Pipe Support and Electrical Raceway Support Inspections The as-built verification effort conducted by the TRT provides evi-dance of faulty construction by craft personnel, installed hardware that does not match as-built drawings, and ineffective QA and QC inspections. Despite the small size of the TRT's sample, there appears to be a large number of deficiencies. The potential also exists that these deficiencies are not represented correctly in the final stress analysis.
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5 DOCUMENT CONTROL The TRT evaluated the CPSES document control system to determine if it was effective and if it ensured consistent quality of documents and records.
The results of this review showed the following problems.
1 A.
The TRT found that there was a potential for document control center (DCC) field distribution centers (satellites) to issue deficient document packages, to craft personnel. Typical problems identified were: packages were not thoroughly examined; procedures and guidelines were not specific or were not followed; and documents controlling operation of the centers existed in the form of guidelines and charts rather than as controlled procedures.
B.
The TRT found that many problems indicative of inadequate drawing control existed at CPSES from September 1981 to April 1984. These problems had been identified prior tg the TRT's evaluation by both TUEC and NRC Region IV audits and reviews.
Prior to placing the satellites in operation (a phased effort between February and August 1983), DCC distributed drawings, component modifica-tion cards (CMCs), and design change authorizations (DCAs) to file custo-dians, welding engineering, the pipe fabrication shop, QC, and the hanger task force. Document control through this system proved to be ineffective.
In an attempt to correct identified problems, DCC satellites were created to distribute drawings to field personnel, rather than use the file custo-dians. However, between August 1983 and April 1984, recurring problems with document control were identified.
Examples of the types of document
- . control problems that existed between August 1983 and April 1984 were as
- follows:
1.
Drawings released to the field were not current.
2.
Drawing and specification changes were not current.
3.
Design documentation packages were* incomplete.
4.
DCC did not provide the satellites with up-to-date drawings, CMCs, DCAs and document revisions.
5.
Drawings hanging from an open rack, which had no checkout control, were available to craft and QC personnel.
6.
Design change logs were inaccurate.
7.
Design documents were not always properly accounted for in DCC.
8.
Current and superseded copies of design documents were filed together.
9.
Satellite distribution lists were inaccurate.
- 10. There were discrepancies between drawings contained irr the I
satellites and those in DCC.
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- 11. Some drawings were missing from the satellite files.
- 12. Telephone requests for design documents resulted in the issuance of documents that bypassed the controlled distribution system.
In April 1984, top management took a direct interest in recurring
'l document control problems.. Their efforts appear to have been successful.
For instance, in April 1984 satellites 306 and 307 had error rates of 30%
and 10%, respectively; but by July 1984, these error rates had fallen to less than 1% for both satellites. The TRT has found that TUEC document 1
control after July 1984 was adequate; however, the effects of document l
control inadequacies prior to July 1984 have yet to be fully analyzed by TUEC.
t C.
Deficiency reporting procedure CP-EP-16.3 appeared to relate only to craft t
and engineering personnel and was not directed to noncraft and nonengineer-ing personnel who may have had knowledge of reportable items.
Procedure CP-EP-16.3 indicated that the applicable manager was responsible for dea.u-
)
eenting and reporting Deficiency and Disposition Reports (DDRs); but there
'were no checks or balances to ensure that a manager or a designated substi-tute would process a DDR.
j D.
TUEC did not consider the CYGNA audit findings regarding the DCC as appropriate for formal reporting to the NRC pursuant to 10 CFR 50.55(e),
i as required by procedure CP-EP-16.3, " Control of Reportable Deficiencies."
I i
E.
The TRT found that the DCC issued a controlled copy stamp to the QC depart-i ment to expedite the flow of hanger packages to the Authorized Nuclear l
Inspector. Methods for this kind of issuance and control of such stamps i
were not described in TUEC's procedures, i
6 TRAINING / QUALIFICATION 1
The TRT identified numerous weaknesses during its review of the ASME and non-I
)
ASME training, certification, and qualification of QC and DCC personnel. TUEC's i
training and certification program lacked the programmatic controls to ensure i
that the requirements in 10 CFR 50, Appendix 8 were achieved and maintained.
I The items identified by the TRT include those listed below, in addition to the items previously provided in our letter of September 18, 1984.
i t
A.
Twenty percent of the training records reviewed contained no verifica-tion of education or work experience.
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8.
The results of Level I certification tests were used for some Level II certifications rather than the results of a Level II test.
i C.
Mter failing a certification test, a candidate could take the j
identical test again.
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D.
Certifications were not always signed or dated.
E.
White-out was used on certification tests.
F.
Seven inspectors had questionable qualifications.
G.
There was no limit or control on the number of times an examina-tion could be retaken.
H.
No guidelines were provided for the use of waivers for on-the-job training.
I.
In some cases recertification was accomplished by a simple "yes" from a supervisor.
J.
There was no formal orientation training for DCC personnel prior-to August 1983.
K.
The responsibility for administration of the non-ASME training program was not clearly assigned to a single individual or group.
L.
Non-ASME personnel capabilities were loosely defined by levels (I,II,III).
M.
There were numerous additional problems in non-ASME certification testing, such as: no requirement for additional training between a failed test and the retest; no time limitation between a failed test and a retest; two different scoring methods to grade a test and a retest; no guidelines on how a test question should be disqualified; no program for periodically establishing new tests except when procedures changed; and no details on how the administration of tests should be monitored.
N.
The exemption provision in ANSI N45.2.6, which allowed substitution of previous experience or demonstrated capability, was the normal method for qualifying inspection personnel rather than the exceptional method.
7 VALVE INSTALLATION The TRT found that installation of certain tutt-welded valves in thre'e systems required removal of the valve bonnets and internals prior to welding to protect temperature-sensitive parts. The three systems involved were the spent fuel cooling and cleaning system, the boron recycle system, and the chemical and volt.se control system. This installation process was poorly controlled in that disassembled parts were piled in uncontrolled areas, resulting in lost, damaged, or interchanged parts. This practice created the potential for inter-changing valve bonnets and internal parts having different pressure and temper-ature ratings, t
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8 ONSITE FABRICATION The TRT findings regarding onsite fabrication shop activities indicated that:
i A.
The scrap and salvage pile la the fabrication (fab) shop laydown yard was not identified and did not have restricted access.
r B.
Material requisitions prepared in the fab shop ditt not comply.with the applicable procedure.
C.
The fab shop foremen were not familiar with procedures that controlled i
the work under their responsibility.
i D.
Fabrication and installation procedures did not include information to ensure that B&R-fabricated threads conformed to oesign specifications I
or to an applicable standard.
E.
Indeterminate bulk materials that accumulated as a result of site cleanup operations were singled with controlled safety and nonsafety material in the fab shop laydown yard.
F.
Site surveillance of material storage was not documented.
i G.
Work in the fab shop was performed in response to menos and sketches instead of hanger packages, travelers, and controlled drawings.
9 HOUSEKEEPING AND SYSTEM CLEANLINESS i
TRT inspections at CPSES indicated that the facility was well maintained, i
However, two issues were identified that indicate housekeeping and system cleanliness deficiencies.
i A.
The TRT reviewed the August 6,1984, draft of flusn procedure FP-55-08.
The purpose of this procedure was to verify the cleanliness of Unit 1 reactor coolant loops, including the reactor vessel, by means of hand-wiping, visual inspection, and swipe testing. Tests to determine surface chloride and fluoride contamination were performed by TUEC systems test engineers ard Westinghouse representatives. The TRT notes, however, that FP-55-08 required only two swipe tests of the reactor vessel--one on the side and one on the bottoa. This limited number of swipe tests may not provide adequate assurance that the vessel had been properly cleaned.
B.
In rooms 67, 72, and 74 of the Unit 2 Safeguards 8uilding, the TRT observed that not all snubbers were wrapped with protective covering i
when welding was being done in close proximity to them. This practice was a violation of B&R procedure CP-CPM-14.1, which required protec-tion of installed equiprent during welding. This condition was i
immediately corrected when the TRT reported it to TUEC QA management, and an inspection was performed by TUEC to correct similar conditions in other areas as well.
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10 NONCONFORMANCE REPORTS (NCRs)
There were several weaknesses in the NCR and deficiency identification reporting systems. The TRT found that:
A.
The TUEC procedure for preparation and processing of NCRs did not contain explicit instructions for handling voided NCRs.
B.
NCRs were used as a tracking document to record removal of a part.from equipment on a permanent equipment transfer r4ther than for reporting a nonconforming condition; such usage of the NCR was not defined in procedures.
C.
There was an inconsistency between paragraphs 2.1 and 3.2.1 in pro-cedure CP-QP-16.0.
Paragraph 2.1 required all site employees to report nonconformances to their supervisor or to the site QA super-visor, while paragraph 3.2.1 required persons other than QA or QC personnel. to submit a draft NCR to the Paper Flow Group.
D.
The NCR form had no fom number or revision date to indicate that the form was being adequately controlled.
E.
There were two versions of the TUEC NCR form, one with and one with-out a space for the Authorized Nuclear Inspection (ANI) review.
F.
The NCR form had no space to identify the cause of the nonconformance and the steps taken to prevent its recurrence.
G.
The NCR form had no provision for quality assurance review.
H.
The TRT found approximately 40 different forms (other than NCRs) for recording deficiencies. Many of these forms and reports were not considered in trending nonconforming conditions.
11 MATERIALS The as-built review effort by the TRT included a material traceability check on 33 of the same pipe supports that the TRT had field inspected. The material traceability was adequate for those 33 pipe supports, with the. exception of four material identification discrepancies, as noted in section 4 on as built inspections.
Ir. another case, TUEC failed to maintain material traceability for safety-related material and numerous hardware components. This QA breakdown was identified in an ASME Code survey in October 1981 yet was not reported to the NRC~in accordance with the requirements of 10 CFR 50.55(e).
2-25
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