ML20136B641
| ML20136B641 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/10/1984 |
| From: | Bielfeldt L TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20136A539 | List:
|
| References | |
| FOIA-85-59 CP-QP-18.0, EI-005, EI-5, NUDOCS 8601020700 | |
| Download: ML20136B641 (31) | |
Text
,
w PRCCEDURE ISSUE RWISION PAGE NUMBER DATE TEXAS UT1UTIES GENERATING CO CPSES CP-QP-18.0 19 JUL 10 1983 1 of 13 PREPARED'BY:
d,1d /dk 7-/o.pd.
m, OATE INSPECTION REPORT uI
'/
j APPROVED BY:
W 7'/# Y g
DATE.
v
1.0 REFERENCES
1-A CP-QP-16.0, "Nonconformances" CONTROLLED COPY 1-B CP-QP-17.0, " Corrective Action" CONTROL No.?M "
2.0 sENERAt 2.1 PtRPOSE The purpose of this procedure is to establish a method of documenting field inspections performed by Qualf ty Control
~,
personnel.
~
2.2 TYPES OF INSPECTION 2.2.1 Monitor (OCI-M)
To assure that a specific operation is being perfomed in accordance with applicable requirements.
Conformance verification by monitoring is accomplished by physically observing a task being performed on a periodic or random 4
j ba si s.
The QC inspector moni toring an ope ration r:us t determine the extent of physical observation required during the performance of an operation based on variables associated with the operation.
The QC inspector must be notified prior to an operation being perfomed that has a "QCI-M" designation.
2.2.2 Verify (OCI-V)
To assure that a specific operation has been perfomed to meet applicable requirements. This type inspection does not require the QC inspector to physically obser.re an operation being perfomed, but allows the inspector to physically inspect an iten after perfomance of an' operation.
The QC inspector must be notified subsequent to performance of an operation with "QCI-V" designated 8601020700 851113 l
I r
TUGCC CA O
,.-.z_...
PROCEDURE ISSUE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
CPSES CP-Q P-18.0 19 JUL 101984 2 of 13 2.2.3 Witness (OCI-W)
To assure an operation is being perfanned in accordance with applicable requi rements.
Confo rmance verification by witnessing requires the inspector to physically observe the entire operation being performed.
The QC inspector must be notified prior to beginning the operation and shall be present during pe rformance of an operation with "Q CI-W" designated.
~
3.0 PROCEDURE 3.1 PREPARATION OF INSPECTION REPORT The Inspection Report shall be completed in black ink and be legible.
The Inspection Report (IR) shall completely and accurately describe the iten or activity observed and reference any other applicable documents. The attributes listed on the IR shall be pre-determined although additional conditions may be noted.
When any block of the IR is not applicable, N/A shall be marked in that block.
The Inspection Report must be signed by the QC Inspector in the appropriate spaces on the. report.
Initialing is.not acceptable except for corrections.-
Corrections shall be made by a single line drawn through incorrect entries, with the correct entries made legible and accompanied by' the initial s of the i
correcting individual and the date.
The following explanations refer to the various blocks on the Inspection Report (Figure 1).
An Inspection Report Supplemental Sheet (Figure 2) should be used when the IR does not provide adequate space for the at-tributes.
NOTE:
No changes, such as additions or deletions to a closed I.R., will be made by personnel other than the originator except as authorized by the Site QA Manager.
In cases where the originator is no longer enployed at CPS ES, the responsible supervisor can have appropriate changes made, with adequate justification.
Addi tional corrections shall be initialed and dated.
TUGCO CA
,, g 3 3
PROCEDURE ISSUE REVISION PAGE NUMBER DATE TED04S UT1LITIES GENERATING CO.
CPSES CP-Q P-18.0 19 JUL 10 884 3 of 13 Block l':
IR numbers shall follow an alphanumeric sequence, such as:
Example: MHS-2-0000001 a
a n
Report Number One i
Unit 2 (1 for Unit 1 & Common)
Discipline Code (for Unit 1 & Common only)
Discipline Codes:
BP -Base Plate l
C - Civil l
CT - Cable Tray Hanger Backfit Unit 2 Only DG - Diesel Generator E - Electrical EC - Electrical Cables ET - Electrical Terminations FP - Fire Protection (Thermolag
~ Inst'allation ).
I - Instrumentation M - Mechanical ME - Mechanical Electrical
^,
MH - Mechanical Hilti Bolts MHS-Class 5 Hangers MI - Mechanical Equipment
~MS - Structural Misc./ Steel PC - Protective Coating PCIT-Protective Coating Inspection Traveler (Unit 1)
PCR. Protective Coating Reinspection PCV-Post Construction Verification PS - Plant Surveillance PSI-Preservice Inspection Report PSS-Plant Surveillance ~ Separation SL - Steel Liners TC - Unit 2 Tray Clamp Reinspection TW - Tack Weld NOTE:
Protective Coatings Inspection Travelers are i
handled in accordance with QI-QP-11.4-28.
e f
4 gGco cA,.,
e
.-a PROCEDURE NUMBER REVISION ISSUE TEXAS UTILITIES GENERATING CO.
DATE PAGE CPSES CP-QP-18.0 39 JUL 101984 4 of 13 j
tains the IR Log and assigns the IR m
, u.. %.. n Report.
NOTE:
The Unit 2 PFG is responsible to coordinate the processing of inspection reports initiated by receiving inspection or other inspection groups outside the Unit i and Unit 2 organizationc.
An IR may be voided by the appropriate QC Supervisor.
The QC Supervisor shall state in the comments section of the IR l
the justification for voiding the IR.
The IR is marked VOID', the IR I.og is updated to show the IR voided, and l
i the IR is fo rwa rded to the PPRV or returned to the data package for later submittal to the Interim Vault as appropriate.
In the event that it becomes necessary ' to issue a new sequence of Inspection Report numbers, (for example, a new discipline code) the new code shall be issued by the Non-ASME QE Supervisor and inco rporated into the next revision of this procedure.
Blocks 2 & 3:
Record sufficient information to uniquely identify the item or activi ty obse rved.
Example:
Item Description Identi fica tion No.
Pressure Transmitter PT-458 Block 4:
Record the sys tem and/or structu re destgnation, including unit, buil ding,
eleva tion, roan number, and area code, as appropriatt., to specifically locate the iten.
Example:
System / Structure Designation SW EL. 832 Service Water Intake Structure Blocks 5 & 6:
Record the governing specification number and revision.
Q 3
TUGCC CA
PRCCEDURE ISSUC REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
CPSES M1 CP-QP-18. 0 19 5 of 13 l
Block 7:
Record the quali ty procedure and/or instruction and revision number.
Example:
Ref. QC Doc. & Rev. No.
QI-QP-11.8-5 Rev.10
~ Block 8:
Record the M&TE number (s) and the calibration due date of the calibrated instrument used to verify an inspeccion attribute.
Block 9:
Check the type of inspection performed.
Block 10:
Check the appropriate block and sign (do not initial) and date in the space provided when the inspection is complete and all items marked sat or unsat.
Block 11 & 12:
Prior to pehonning the inspection, list the attributes to be observed.
(An attribute is a
characteristic
.or property which can be appraised in tenns of whether it does or does not ex'ist.)
Indicate the acceptability of the attribute by checking either ' Sat' or
' Un s a t'.
NOTE:
The acceptabili ty of the attribute is to be noted regardless of elapsed time before correction of the i
'Unsat' condition, i
l Block 13:
Sign (do not initial) and date this block after satisfactory correction of the "UNSAT" attribute.
Do not use this i
block for " SAT" attributes.
Block 14:
Reference all applicable docurrentation such as drawing numbers, specifications, DCA'S, CMC'S, e tc. an'd revisions as applicable.
j I
Block 15:
Record any applicable NCR number.
l i
i I
I TUGCO CA
,, g 3
PROCEDURE ISSUE REvtSION PAGE NUMBER CATE.
TEXAS UTit tTIES GENERATING CO.
CPSES lJijl10 W 6 of 13 CP-Q P-18.0 19 Block'16:
Upon satisfactory completion of unsatis-factory attributes, or issuance of an NCR, or superseding IR, check the "IR CLOSED" block, sign and date the report. Put NA in this block if all the attributes are
" SAT".
If a DCA or CMC has been issued which makes the unsatisfactory condition acceptable, the DCA or CMC will'be noted in the comments section and the IR starked " SAT" and closed out.
Unsatisfactory Inspection Reports may be.
superseded by the issuance of another IR authorized by approved procedures /
~
instructions.
In these cases the unsatisfactory IR nisnber shall be referenced in the remarks section of the new or superseding IR and the original unsatisfactory - IR clossd wi th the following (or similar) statement in Block 14: "The UNSAT attributes of this IR have been added to IR #
and this IR is closed). The OC Inspector shall then close the IR by checking the IR closed block, signing and da ting Block 16.
3.2 INSPECTION REPORT PROCESSING 3.2.1 tit I and Common The QC Inspector perfonns the ' inspection, prepares the IR in accordance with Section 3.1, and forwards the IR to the IR Clerk for further processing.
The IR Clerk records the required infonnation from the IR into the IR Log.
If no unsatisfactory conditions are noted, the IR is then forwarded to the PPRV.
If unsatisfactory conditions are noted: the original Unsat IR is maintained by the IR Clerk and copies of the Unsat IR are forwarded to the craft for correction of the unsatisfactory condition.
TUGCO CA
,, g 3
l[
PROCEDURE ISSUE REV:SION PAGE NUMBER DATE TEXAS UTIUTIES GENERATING CO.
CPSES CP-QP-18.0 19 JUL 101984 7 of 13 t
When all unsatisfactory' conditions have been corrected and reinspected and accepted, or when an NCR or superseding IR has been prepared for the unsatisfactory condition (s) per approved procedures / instructions, the QC Inspector shall Black 16).
The closed IR shall then be forwarded to the' PPRV by the IR Clerk.
NOTE:
Deficiencies for itens which have been accepted by final inspection (unless an IRN has been issued) as delineated by Quali ty Ins tructions, or deficiencies for which a "use-as-is" or non standard repair disposition is reques ted, shall be documented in accordance with Reference 1-A.
Inspection Reports for Class 5 hangers and Class S hanger hiltis remain with the hanger package for transfer to the PPRV.
3.2.2 Unit 2 PFG Inspection Report Fonns are placed into the work package for the applicable component prior to the package being issued to the fiel d.
The IR ~ Fonn shall be numbered (Reference Section 3.1) and all applicable heading or identification infonnation filled in by the PFG.
A cover sheet (Figure 4), may be used when more than one inspection is required.
When a cover sheet is used, the various inspection reports attached to it are listed as pages under one IR numbe r.
Upon canpletion of each inspection report, the cover sheet.is signed as well as the IR or marked NA if the specific inspection was not required. When all required inspections are complete, the Lead or Level II Inspector in the appropriate discipline shall verify - the inspections are complete and all required signatures affixed to the inspection reports and the cover sheet. He/she shall then sign the cover sheet indicating the IR is closed. When the package is presented to QC for inspection, the QC inspector shall complete the fann based on inspection results.
The package shall then be returned to the PFG.
4 TUGCC OA
,3
~
- _ ~-
I-4 PROCEOURE PAGE E
E CP-Q P-18.0 79 g74 g 8 of 13 r
J NOTE:
In the event heading infonnation is not emplete and/cr requires further clarification, the inspector shall' add any requi red infonnation to the-IR.
In the event an IR is required to document an ins pection and one is not contained within the component package; the QC Inspector shall obtain a prenunbe red repo rt fram the PFG for placement in the data package.
When all unsatisfactory conditions have been corrected, and reinspected and accepted, or when an NCR or superseding IR has been prepared for the unsatisfactory condition (s) per approved procedures / instructions,
.the Discipline QC Inspector.shall close the original unsat IR (refer to Paragraph 3.1, Block 16), and the PFG IR coordinator shall close the IR log.
^
NOTE:
Deficiencies for itens shich have been accepted by final inspection as delineated by Quali ty Ins tructions, or deficiencies for which a
"use-as-is" or non standard repair disposition is
- required, shall be docunented in accordance with Reference 1-A.
3.3 INSPECTION REPORT LOGS IR Logs are maintained by the appropriate PFG.
1 The infonnation required on the Inspection Report Logs is self explanatory and obtained directly from the IR except as follows:
a.
If an NCR has been issued, record the NCR nunber in the Identification Section.
i b.
If an IR is superceded,'the new IR number is recorded i
in the Identification Section.
E TUGeo CA Form 86e. 3
i i.
ISSUE
~
PROCEDURE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
CPSES CP-QP-18.0 19 JUL I O 1964 9 of 13 I
3.4 CORRECTIVE ACTION TREND ANALYSIS f
the At the end of each quarter,,
will send a repo rt of ins pections pe rto nnea to tne QE Supervisor for trend analysis in accordance with Reference 1-B.
These reports shall include the number of Inspection Reports worked and the number of unsatisfactory reports for each type of report (MJi, E, ET, EC, etc.)
l l
l i
~
l I
i i
~~
s TUGCC CA
,, g 3
PROCEDURE ISSUE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
CPSES CP-QP-18.0 19 JUL 10 $84 10 of 13 FIGURE 1 C::MANCME Pr.,a STEAM Eu2C7RIC STA7ics INSPECTICN MEPCMT
(*
m assumanon esan m aca e.
u srus, ar=wc r.M a.w...r.a g
1..-w a tr. -
2... :x...
..e d.
C i= W, on C vg;ghg= Cr=arypg a r,w,,
- any, e sama.ra C mesense coeurso, au, as ucasts areas sarwacroar O===cm <=en. -o e irt= usrun====
usSPEC710N ATTRieuTES IIgarg ((w
=
=
i il I
I i il l
l l 1i i
i r!l 1
)
I' li l
i lI i
i i li i
l I il l
l I 11 I
i lii i
i ll l l
6 i ii I
I ii i
i li i
l ii l
I l II i
l i lI l
i l i i l
l l Il i
l iil l
I I il i
i i il i
l i i l l-l r m apeu, specs, rica
~ * " " "
) L M. C.a2C Q
- ** R l snessu=
,g l
,, g 3 TUGCO CA l
i 1
u.
~
PROCEDURE ISSUE REVISION PAGE NUMBER CATE TEXAS UTILITIES GENERATING CO.
CPSES CP-QP-18.0 19 Jul.10 1984 11 of 13 FIGlRE 2 CDMAmCHE PEAM STEAM ELECTRIC $TATION INSPECTION REPORT (Suh8tiMENTAL)
N#
.... "' F FT 1
- 10.
5F8 r0R n"
' 'E t ~ *-
ca ' *3 0c
'"E INSPE
- tor. *:TRieuTEs g
q smann i
^
(
f ROSAMS* (Epssa.pecs,gTcJ aELafia oca no g.n i siessaruse IR. CLOSCO Q
4' 8
OC meSPEC 7 04
'S g
TUGCQ CA p.,,,, % 3
~
4.
g
't
d PROCEDURE ISSUE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
CPSES CP.QP-18.0 19 Ji)L i 0 EB4 12 of 13 I
FIGlRE 3 PREFIX IR 40 IDENTIFICATION REPT DATE 3/U CL3E DaTE INSP ssammassasssss s sss s sssssssssss ssssss=s amassas s a sssam asa ssssass a sssss s s s s s s s s s s a e
e r
e e 2 0 0,24: e e
o e
e e
...s....
e.
- .. c o.....
e e
e.
e e
e e.
e e
e
- t.0 0 0,2 4 3 e
e e
e e
e e
e-e e.
e e
e t.0009244 e e
e e
e e-e e.
e-e e-e e.
e e
e e-e 1 0009245 e
^
- e-e-
e e-e e
a e.
e e
e e
e e-e e
e-e e
e e-e-1 0009246. e e
e-e e
e e-e-
e e
e-e e
e e-e-
e e.
e e
e e
e 1 0009247 e e
e e
e-e e
e e
e-e e
m e
e e
e e.1 0009248 e e
e.
e e
e.
e e
e
.e.
e,.
e-
. e.
e.
.e.-. e e
a 1 000924t e e
e-e a
e e
r.
e e
,, e e
_e e
e e
e e
e e
e e
e-1 0009250 e e
e e
e e
e-e-
e.
e e
e e-e-
e-e e
e e t.000925: e e.
e e
e e
- -.. e-e-
e n.
e e
e e-e e
e e 1 0009252 e e
e e
e e
e e
e e
e e
e
.............._...e..................
e-e e
e-e e
e e
e
- 1 0009253 e e
e e
e e-e e
e e
e-e e
e e
e 1 0009254 e e-e.
e e
e e
e e
e e
TUGCO CA Form No 3 p
p l
i i
i
^
PROCEDURE ISSUE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
CPSES CP-QP-18.0 19 jut 10 884 13 of 13 FIGURE 4
.- me
.v a m-FO m 1 of 8 i
.s UNIT II ;
5:cQ.."I;;<
. &: 54~6;.% -% >:*.% '
- *. :- aff --
NIS CAALE INSPECTION REPORT i
- 1. A. 7 <-
~
GMPONENTi
!.I. CONTENT 5 F0 md E 26A/01 QC OATE F0 m i E tiA/03 QC OATE Fa m i E 41/01 QC
/
DATE FORMd E 43/01 QC OAft FCRMf E 43/02 QC MM FORMi E 43/03 QC
. DATE FORMi 5 51A/0!
QC j
uit LEVEL 2 VEAIFICATION QC Daft TUGCO CA 3
9 n
,-,c,
+ -- + - - - - - -,-,,.--- - - ----
i s
y D 253 l
Annex 3 Conversation Record 1
Allegation Number AGG-3/
Time # 00 /M Date 7-7/-8 Type Visit Conference X Telephone j
Incoming 4 Outgoing Name of Person (s) Contacted I
or in Contact With You Organization Telephone Number G.A.P. Au.esen 'N *
~
1
SUBJECT:
Z pseue:ree To ewnter TNe w. esse To es44try Me t/te:Fic M47'eA& ot* Me-4&LefereM*
SUt9ARY: We. qs.Lesen storea wy pts a,,yesoy ;j
,,,, yy yyg gyjrem p<<a4ee r wmen ><e-sereseawoo.x Sraerue we Am.ainmaz (.rwn) in Txor mer se xor 4s.wss eccuerny Aneuese irre cure ~ r*
1 wrotot 4 Aeettt*A4A ITEM wit $ *N*4hresar 4t!!**'*0*
i Norrt 77tts Het etert arrnerwee to or meer op 4 "Tisirwo
- coNceek ?M4N 4M bersien " axe +us Neerree+ n+s ters suutexes to n Tistr*+ '**A
~
Name of Person 00cumenting Conversation Uburm f. AfAsiw/
~
Sfgnature dBNZ-
//p>M__
Date 9'-/-#'fe Name(s) of Other Persons Who Were Present Ouring Conversation koca mea W icrr a s ae
' Xrp Gg vo I have reviewed the sungnary of the conversation with the individual (s) named i
below and agree that it accurately represents the conversation.
t Signature of Person Providing Information NM Pj File: Allegation Work Package cc: Project Director Group Leader Additional pages may be attached as needed. Additional pages should be identified, signed, and dated.
I
-,,.,...--,-,n,--,
.--.,-._,v-.,.-.,__.,
lk Draft 4 - 8/6/84 Action Plan - Electrical 15/CP3 COMANCHE PEAK OPEN ISSUE ACTION PLAN l
Task: Allegation Group Electrical 15 - Electrical Procedures l
Ref. No.: AQE-23, AQE-32, AQE-39, AQE-44, AQE-46, and parts of AQE-6, AE-18, l
AE-20 and AQE-37.
Character 1:ation: Various allegations pertaining to:
l l
(a) Omission of procedure requirements.
(b) Reduction in the number of required inspections.
(c) Adequate basis for procedure revisions.
(d)
"Use-as-is" dispositions contrary to procedures.
(e) Paper flow problems exist involving rework.
(f) Use of bute splices contrary to procedure.
(g) Redundant train separation.
Initial Assessment of Significance: The adequacy of procedures to ensure the quality of construction tasks.
Source: Allegations:
Approach to Resolutions:
(a) Examine and review pertinent documentation (b) Conduct intervi is (c) Evaluate results (d) Report on results Related Open Issue Identification: None Status: Open Review Lead: Jose A. Calvo Support: None Estimated Resources:
6 man-days Estimated Completion: August 4, 1984 CLOSURE:
Reviewed by:
TRT Leader
~
D 265
i l
D bh 'd SL.
,6-E O_te htc.'c m b ve.,(
a i(
Q% 6 4
m v
L W' h w.c.g d
W kyrwt.,)
' u.,w.e_ b
\\k
\\ E% r.r.e e NQ f
N O
WM L4 n Q C - Q @ - 11,3 -2 k@
\\b m, bm 1 e.n-v i
3,0
- u. w h 1 or ts' l.
t m
J3 oddw.Nu k
Yb sw
? F'h,_ W. %
S ~ g e% >
---rw
- V~. s..,,,r
. ~...,
en o
o t a 1>-
,r-s w,,m g(M,k(.,
h 0
)V'#}
Y rM ) H tw ni
&J w,4 ~f A. 4 ~
Samol*(kg 3 #4 en
>s 3
a
~
bI2s5
9 s
an$"wn gNd" tnv.o\\c.bsoed o.
p.oies c.t < s
.peceAor=.3.
-9 Onech W< hilen$ cc b\\e3 ic<mo:. ben C.ubkTt-22,, A-ou,9 so43\\3, b\\ussud ukk ce,Ju.,\\.,
TO
- 2, t.<tnsode pat 76 + 17. A \\m% splic<.
is c.bn \\
'E kad h.ck yb. cable.
TC-2'3, A G teen
\\oi32%, T O*2, b<m pb % 77, gr e.~ a uk q ccbh.
O L R e\\cq b b g e R s c u W. 5-A -Gsun dG% 344 wWk cenAwd e,.
km sk69 T R E.,
4<m f. *2,\\S" u.g i w b\\e.
A G<<cc \\4G([S l, b\\=1c4ter\\ k cwbkM i
nm, wtn ek % 5 (. 6" u.p A c.abk) la-Gcun, di /A 62, Wch ri.ch\\c. uk sh pTRn
\\
4<ns9.\\\\*n,C.wt qMoc cab \\e)
Ne>cs-Q M \\ c w iuc. cxncu.d.3 b.hnc( TR4 adTRG E - occm<g in ps / wLib codmt, c.n 6k 4
A<<. co.bb c% cd ek 443
.\\
u-G 124462.,w4 cgun en Twm 7 <d
(-
c#[Y 3 --
AusON:.du\\t. & \\
(cdi
, toich,pecd vk'h. hum E-0.ug $49 3d / L d r w(b.
c n TROL / Sec\\
- "Y*
M,0,* 2 Guen 1113 3,c,,(u.>b.h c~d < d) en T ce_ I i. 2.- 6 9
e.Grun 2 c719s (yuc. Asc) a T t s', y Mdd M k ChchCcbh y %b M c.h W )
L
f
$~
o W
\\y I
I T' Another example of the violation of regulations at CP is in the practice of regularly using " butt splices" on both quality and non-cuality cables.
Butt splicing is used on a routine basis at bomanche Peak'where cables are not
~
1,o n g enough to reach their intended destinatiort.
(Butt Q-splicing is a means of physically attaching a new length of K
cable to an existing length of cable using a crimp to secure the attachment.)
The problem with butt splicing is that, if it is not properly done, the cables can separate Posing a Potential fire ha:ard.
This potential ha:ard is heightene'd by the fact that the majority of the butt N*
y&
9 e
C# J v\\
e O
4 6
9 e
O r
i j~
s i
o I
e
.e, AFFIOAv!T OF ga DO NOT DISCLOSL splices are in bundles Cf cables and the hazard extends
.beyon_d the cable that has been spliced to the cables that surround it.
It is my understanding that butt splicing is specifically prohibited by,the NRC.
I have confirmed this belief by contacting the NRC Region V Office.
In p a r t i c u *. a r, it is my understanding that Regulatory Guide.
1.75 specifies that cable' splices in ' raceways s'hould'be
~
Prohibited and further', that'if such sp'li,ces do exist, the 14 resulting design should be j u s't i f i e d by analysis and 6
submitted as part of the FSAR.
However, at Comanche Peak, r-0 (OCA 19264 nd several other DCA's allo'w butt splicing of g}
quality cables.
At Comanche Peak not only do the butt T
splic,es exist, but in some cases no notation is made on design drawings that the splices exist.
As a result, there may be no record of where butt' splices have been'made.
It is my belief that it will be necessary to reinspect all cables and conduits for butt splices since'no records s'r e kept of their existence,or location.,
s I am particularly concerned about the practice of butt sp1keing because of its potential for starting fires, and
~
because it is my experience that there are many fossil fuel 12 O
i AFFIDAVIT OF
$.N
':3T DISCLOSE o
O plants where butt splicing i s not allowed.
T l
I i
9 I
e I
9 s
6 8
O e
.. ~..
P r
N 3
V to\\4en,\\ co.9c 4<a3 9<ahco 'cc
<c.mds.
O,ke 3, H q.
o_pp< coa bu au. NoccouskM p{tec.elt es te -
5 g<cLo$
c.aW.-Wc $ s, p.u bec.
Chk E5- \\co]
kwb.9 Condu.d C - \\adt'%'65 orc q osecs. s c\\ce
\\c.ckhc 4<agT - \\sGtc. mo a.
.(6" u. phen) 4 Chc.ch occu<cu.3 d preich.ue g< TdAR cm1N0f j
%c,.a. t.,s W
9 C.- \\ 5% \\4 5 31 ye, un2e.r T-\\3G CC md 5
(.on\\g a upi4K<,nl Eo kcw H AaA aba 1" sepoken, csc catuJcAe t,-is e42 33 4 9 30.o:k c r-isor.tno(.c (2-Q 9
T-M $ c,oa 31
-P C- \\'A 6 A1191 o
4 4,Vs =0't &*A g>d)y *-
C#
O
4 e.
a.
,,m, enumwe+
me.
,o 25.
74:ndWe. (c9.idiern m be e\\<.Mmi p4-c_onbur.bg d
_I
- vepompm
[
e chec.k ecoubo, LIoApm.L u_340)
-> hiens ou %AS hs o# 4 O.
seyen e)>
s c, 3 4
YU5 Q,
1 l
s I
e
.--v
s My socond category of concer ns r ogar ds procedur os t hat I believe represent actual violations of specific g
i n s t a n c e's, represent substantia 3/ lh regulations and, in some
/
safety hazards.
I also believe the following examples f u r t. h e r indicate.the breakdown of the QA/QC program at F
l Comanche Peak.
As an example, I believe'that Cable Separation --
Specification 2323-ES-100, Rev.
2, is in violation of Regulatory Guide 1.75.
A portion of ES-100. Se: tion 4.11.3.2, provides, "(mlinimum separation between a conduit (safety related or non safety related) and a bottom or side S,
of a tray (solid' bottom or ladder) shall be one inch."
(JT This is not consistent with the minimum separations required by Regulatory' Guide 1.75, which provides that conduit separation should be at least five feet from the bottom of a tray and three feet from the side, except in the cable spreading room where it can be'two feet from t h,e side and three feet from the bottom.
I am particularly concerned about the above situation 10 1<A
)
ti (I
w 0,
Y. g
\\
g\\$
&t J:n f G
9 I
M Argiouvir os
-esmuse DO NOT L>iocLOSE I
since, if I am correct in my interpretation of the regulations, then the entire plant has been built using i
l errant specifications.
In order to correct this situation.
l it would be necessary to reinspect all cables and conduits at the plant to ensure proper separation.
I am not the
-f-only one who believes'that,ES-100 is in violation of J.
Re g u l a t o~r y (5u i d e 1.75., I am aware of one instance where a g
Id Design' Change Authoriration.'(DCA3 was writ. ten against ES-
.I
. 100 to change a portion of the procedure unrelated t o.' c a b l e separation.
The Gibson Hill employee who was a sl: e d to authori:e the change refused to sign off on the OCA b'ecause of the violation existing in ES-100.
e O
.I O
t
. ~... ~..
l$
/
CCMANCHE PEAK OpEN ISSUE ACTION plan Task:
M Ref. No.: AQW-15, AQW-16, AQW-17, AQW-18, AQW-19, AQW-27,
, AQE-AQB-2, AQ-38, AQ-39, AQ-50, AQO-7, AQO-14 Characterization:
Inadequate and/or improper certification of the qualifications of QC personnel.
Initial Assessment of Significance:
possibly indicative of a general breakdown in the QA program.
Source: Various Acoroach to Resolution:
1.
Review procedures, codes / standards, design requirements, NRC requirements, and licensee commitments for adequacy at time work was performed; were codes / standards, FSAR, contractor requirements, and other commitments met?
2.
Discuss adequacy of procedures with personnel involved.
Examine installation, as appropriate, that is associated with any inadequate procedures identified.
3.
Refer any examples of wrongdoing or significant deficiencies to TRT manager.
4.
Evaluate allegations for generic / safety implications.
5.
' Report on results of review / evaluation of allegations.-
Related Ooen Issues Review activities necessary to close or partially close related items, either based on inspection conducted above or reasonable additional inspection while the inspector is familiar with the areas.
D gj I
h 2s
c.
[u A;_.
u n v.
w ss
,, fa u cesr ev spo Q
~
66 pf% <..
9 m m. _
b Inspector Name: A-3 l
--l Date Interviewed:
["
General
Background:
}
O Interviewee Comments:
f m
Generally concerned with finding numerous problems during past construction inspection and procedure being changed to delete he inspection, e.g.,
loose terminations found in lighting.
Some NCR's are answered simply that the problem is not addressed in Specification ES-100.
l Recent NCR written because restraint cable (lighting) crimp gages were worn & therefore, inspection was inadequate.
This is still being evaluated.
Wires of two different gages were terminated at some lugs and many M terminations are loose.
Have more pressure ~not to write NCR's during turnover.
A es Found loose LB's (elbow term'ination fittings) @ East & South ends of Unit 1 Diesel Generators, wrote two NCR's, was accepted as is. 4 Found cables not trained (routed) in worbanlike manner in Unit 1 Cable Spread Room 9 junction boxes 1056 and 1059. NCR said OK because
/s cable radius was OK but did not admit workmanship problem.
~ Feels post. construction inspectors were transferred to Unit 2 as retaliation for finding problems.
Heard second hand that I R s (inspection' reports) were being written falsely (without reinspection) to clear IIRN's (discrep-ancy report) on cable trays. Heard frem lady in Paper Flow Group (PFG) and lady in vault. Said he would get back to NRC with more specifics.
Notes:
Some review of the lighting. termination issue and post check procedure was conducted by team member Ruff. The site inspector indicated he had told of most of these issues and QA was evaluating. I forwarded concern relative to 1058 & 1059 junction boxes to RIV: Martin and he indicated he inspected these boxes and sees no technical problem.
Resident Inspector:
Smith partic-ipated in most of.the interview and indicated he was aware of the D/G loose fittings and sees no technical problem. I evaluated reasons why 6 personnel including were transferred to Unit 2 and this move does not appear to be discriminatory.
e sw
.. ~...
(n but y 196 0 v
hu.I
-/981 3T acai.
na.
x, AuG 23~
AJCA-Du t1 e~t T.
y 3 yrA-
.fA T u siw a m w tv>p. /~ L w.
44 h ;t., s (
'i9 l (2) d%,
\\
re
'fm E uc/s ao h wt-e s s -i.',
c (12)
[hg <t u I
w
.l w y l,liel l
l s
n-m 2 L.
e./c,t s 2
.m ts
< c s e ~e t,
.o e
4 4
e i
O
- w.
I9 COMANCHE PEAK OPEN ISSUE ACTION PLAN Task: Electrical Category 16 - Inspection Reports, Inspection Item Removal Notice, and In-process Inspection.
Ref. No.: AQE-7, AQE-43 Characterization: Concern is that validity of irs and IRNs. Also, in-process inspections are not being performed.
Initial Assessment of Significance: irs may have been signed off without inspections being made or were falsely signed to close out IIRNs.
1 Source: Allegations Approach to Resolutions:
I (1) hview pertinent documentation (2) Interview paper flow group personnel responsible for irs and IRNs (3) Examine irs and IRNs (4) Intervise QC Electrical Inspector I
(5) Evaluate Results (6) Report on Results i
Related Open Issue Identification: None l
Status: Open Review Lead: Jose Calvo l
Support:
None Eseimated Resources: 4 man-days l
1 Estimated Completions: August 3, 1984 CLOSURE,:
'i l
Reviewed by:
TRT Leader
[
[
i t
i l
l N
l
.ma
j l
i-
. -. ~. -. -..........
f
~
e, FOLDER NO.
Y Draf t No.
Date l
COMANCHE PEAK ALLEGATION WORK PACKAGE l
@ tot gy SMQC Category.W - Inadequate Inspection And Certification Allegation Numbers:.E3, A0W-16, A0W-17, A0W-18, A0W-19. A0W-27, AQE-7, h
1 A08-2, AQ-38, AQ-39, AQ-50, AQO-7, AQ0 1 i
Statement of Allegation:
Inadequate or improper certification of the qualifications of QC personnel.
Reference Documents:
4 See source documents marked on attached pages from. allegation list.
4 h
Source of Allegation: Various Date Received: Various The above information prepared by R. G. Taylor 6/8/84 Name Date Group Leader Name Date Assigned Team Members Date Assigned I
Date Assigned i
Date Assigned Date Assigned O
t
,,,,,,m,-
' o 6
COMANCHE PEAK OPEN ISSUE ACTION PLAN Task:
gg('l AQW-15,AQW-16,AQW-17,AQW-18,AQW-19,AQW-27,Q,E-7,AQE-lh Ref. No.:
AQB-2 AQ-38, AQ-39, AQ-50, AQO-7, AQO-14 Characterization:
Inadequate and/or improper certification of the qualifications of QC personnel.
Initial Assessment of Significance: Possibly indicative of a general breakdown in the QA program.
Source: Various Aporoach to Resolution:
1.
Review procedures, codes / standards, design requirements, NRC requirements, and licensee commitments 'for adequacy at time work was performed; were codes / standards, FSAR, contractor requirements, and other commitments met?
2.
Discuss adequacy of procedures with personnel involved.
Examine installation, i
as appropriate, that is associated with any inadequate procedures identified.
3.
Refer any examples of' wrongdoing or significant deficiencies to TRT manager.
4.
Evaluate allegations for generic / safety implications.
5.
Report on results of review / evaluation of allegations.
Related Open Issues Review activities necessary to close or partially close related items, either based on~ inspection conducted above or reasonable additional inspection while the inspector is familiar with the areas.
'me y
f
'
- 2 I'd -
s.
Status:
Review Lead:
Supoort:
Estimated Resources:
Estimated Comoletion:
CLOSURE:
Reviewed by:
~
I e
i
h
/+ dL E - 4 U. 5. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV
'l Investigation No. 50-445/81-04 7
[i 50-446/81-04 Docket Nos. 50-445; 50-446 t
Licensee:
Texas Utilities Generating Company Facility:
Comanche Peak, Units 1 and 2 Investigation at:
GlenRose,Somervelk, County, Texas Investigation conducted:
February 25-27 a d March 9-13, 1981 Investigators:
v:
et -2. i-% (
D. D. Oriskill, Investigator Date Investigation and Enforcement Staff Y/f s
9-2-f/-
R.'
K. Herr, Investigator
.Date Investigation and Enforcement Staff In pectors:
/
[/////
L. E. Marti Reactor Inspector Y Date Projects ction No. 3
.,~~----
R. G. Taylor, Resident Reactor Inspector Date rejects Section No. 3 h
f J
Reviewed by:
I. Y V h U
II J. NE. Gagl \\ arco, Director Date*
Investigation and Enforcement Staff J, -
Nd f-, o/-/.cc h -
Approved by:
G.
L. Madsen, Chief
/
Reactor Projects Section
,!! L
-v~hfrt0$&5--~
]
l 2
Sum. mary Investigation on February 25-27 and March 9-13, 1981 (Report No. 50-445/81-04; 1
50-446/81-04)
Area Investicated:
Allegations were made that a Comanche Peak Steam Electric Station (CPSES) Brown and Root, Inc. (B&R), Quality Control (QC) supervisor repeatedly told electrical QC inspectors to violate inspection procedures; that a QC supervisor told electrical QC inspectors not to do required in process inspections; that electrical QC Department blueprints are not always of the current revision; that electrical QC management is " tight with the craft" due to their being sympathetic to production management aeeds; that some electrical QC inspectors are inadequately. qualified and have been helped to pass certifica-tion test; and that some electrical QC inspectors have " bought off" electrical terminations in nonconformance with drawings.
Another allegation was received stating that pipa hanger packages are being divided making final QA reviews inadequate. This investigation involved 154 investigator / inspector man-hours by two NRC investigators and two NRC inspectors.
Results:
Personal interview of the source and numerous interviews of electrical QC personnel disclosed no instances wherein the QC Supervisor allegedly instructed I
electrical QC inspectors to violate procedures or not to conduct required in-process inspections.
Interviews disclosed that the electrical QC Department blueprints are only rarely found not to be of the. current revision and no extended delay or nonconformances ' relating to blueprints, were identified.
Numerous interviews of electrical QC inspectors disclosed a unanimous opinion that they possess independence in conducting their dut'ies without pressures from either QC or production management:
In depth investigations of qualifica-tions of some electrical QC inspectors identified none who were unqualified for their position; however, examination of the certification tests.for one electrical QC inspector disclosed that the electrical Quality Engineer con-ducting the examination had deleted several incorrectly answered questions from the test, which resulted in a passing grade for the inspector vice a failing grade.
Numerous interviews identified no instances wherein electrical terminations were intentionally " bought off" in nonconformance with drawings.
Investigation disclosed that pipe hanger packages were formerly divided and filed separately; however, the packages have recently been combined eliminating the admitted inconvenience factor in their final QA review.
During this investigation it was identified and confirmed that a member of QC management was prohibiting QC inspectors from obtaining NCR numbers in order to insure that all NCRs were brought to him for approval prior to being issued.
L
~
3 INTRODUCTION Comanche Peak Steam Electric Station Units 1 and 2 are under construction in Somervell County, Texas near the town of Glen Rose, Texas.
Texas Utilities Generating Company (TUGCO) is the construction permit holder with Brown and Root Incorporated as the constructor and Gibbs and Hill Incorporated (G&H) as the Architect / Engineer.
REASON FOR INVESTIGATION On January 23, 1981, Individuals A and B were interviewed by a member of the NRC Region IV staff regarding their expressed concerns relating to alleged procedural violations in the B&R electrical QC Department at CPSES and relating to review of pipe hanger packages at CPSES.
SUMMARY
OF FACTS On January 23,-1981, Individuals A and B were interviewed by Mr. R. E. Hall, Chief, Systems and Technical Section, Enginee' ring Inspection Branch, Region IV, Nuclear Regulatory Commiss.en, at which time the following safety-related concerns were identified:
1.
A QC Supervisor has repeatedly told electrical QC inspectors to violate inspection procedures and once stated " don't worry about the flowers in the trees," which was interpreted to mean don't reject on looks alone.
2.
A QC Supervisor instructed electrical QC inspectors not to do in process inspections, but only to inspect completed work, which is contrary to procedures.
3.
Field copies of blueprints used by the electrical QC department for inspections are not always of the current revision.
4.
Electrical QC management is " tight with the craft" as a result of their being sympathetic to production,menagement.
5.
Some electrical QC personnel are~ inadequately qualified; were helped to pass certification tests and their experience requirements were " pencil whipped."
6.
Electrical terminations were being made and " bought off" by some electrical QC personnel, in nonconformance with drawings.
7.
Construction and inspection records relating to some pipe hangers are being separately maintained resulting in their final QA review being inadequate.
h a
4 1.
Persons Contacted Licensee Employees J. Hawkins, Project QA. Manager, TUGC0
- R. Tolson, Site QA Manager, TUGC0
- D. Chapman, QA Manager, TUGC0
- J. Ainsworth, QE Supervisor, TUGC0 Other Persons Contacted Individuals A thru X
- Denotes those attending exit interview.
2.
Investigation of. Allegations
. (.
Allegations No. 1 A-QC Supervisor has repeatedly told electrical QC inspectors to violate,
inspection procedures and once stated " don't worry about the flowers in the trees," which was interpreted to mean don't reject on looks alone.
Investigative Findings On February 24, 1981, Individual A was interviewe'd.
Individual A stated it was his opinion that an electrical QC Supervisor, Individual C, en-courages electrical QC inspectors to overlook certain safety-related aspects of their inspections.
Individual A recalled one occasion when Individual C made statements to the effect of " don't reject on looks alone" and " don't worry about the flowers in the trees," which Individual A stated he interpreted to mean the inspectors should not find fault with 'the work they were inspecting. Individual A was unable to provide any specific instances when Individual C explicitly told him or another electrical QC inspector to violate a specific procedure.
Interview of Electrical OC Insoectors Between February 25, 1981 and March 12, 1981, Individuals D thru K were individually interviewed concerning various aspects of their employment as B&R electrical QC inspectors.
Individual D recalled one instance wherein an electrical QC Supervisor, Individual C, stated "I know what the procedure calls for and I'm telling you to do it this way."
Individual D stated this comment was made when Indivudal C was being cuestioned concerning inspection of cable separations.
Individual D also added that electrical cable separation has. presented a long term problem and that about three months ago their requirement to document cable 1
separations, as suitable or otherwise, was deleted from.the electrical
5 QC inspection form and an alternate avenue of documenting unsuitable cable separations was initiated in order to avoid the submission of " unsatisfactory inspection reports" when cable separation were the only area of noncompliance.
Individual D was unable to identify any other occasions when he believed that Individual C had instructed or inferred that a CPSES procedure be violated.
When interviewed Individuals E, F, G, H, I and J, each stated that Individual C's comments regarding " flowers in the trees" and " don't reject on looks alone" were interpreted to mean the inspectors responsi-bility is to ensure the quality of the specific task conforms with procedures and that the individual inspectors should not impose his/her own subjective criteria, regarding appearance, on task they inspect.
Individual K stated he had not given consideration to the specific comments, made by Individual C, and did not know what.they meant.
None of the foregoing individuals supported a centention that the electrical QC inspectors were either directly or by inference directed to violate any procedure or limit the quality of their respective inspection duties.
Interview of Former Electrical OC Inspectors On March 9, 1981 and March 11, 1981, Individuals L and M, respectively, were individually interviewed. Both Indiviudals L and M stated that they interpreted Individual C's comment regarding " flowers in the trees" to mean that their-inspection responsibility was limited to the safety-related aspects and adequacy of the task being inspected.
Neither Individuals L or M racalled an instance wherein they were instructed to disregard compliance with CPSES procedures.
Interview of Electrical QC Suoervisors On March 12, 1981, Individuals C and N, both electrical QC supervisory personnel were individually interviewed.
Individual N stated Individual C's comments regarding " flowers in the trees" meant inspection should con-centrate on the safety-related functions of items being inspected and not nonsafety related aspects of the system or components which was not a part of the respective inspectors responsibility to inspect.
Individual N stated no comments made by Individual C should have been interpreted to nean a procedure should be violated.
When questioned concerning his alleged past statements " don't reject on looks alone" and " don't worry about the flowers in the trees," Individual C corrected the latter to " don't worry about the flowers and the trees."
He stated these comments were directed to some electrical QC inspectors who were frequently finding nonsafety related problems in areas of their inspections.
Individual C stated that he was not aware there had been any misinterpretation of his statements and said "perhaps I didn't choose my words carefully enough." He said he had meant, by these statements, that inspectors should not apply their personal standards to a condition in order to reject it, if, in fact, it meets the required specifications.
Individual C also stated he frequently made comments to inspectors O
t 6
i such as "you're not designing this place" when their criticism of an item took them outside the scope of their inspection responsibility.
Individual C stated he'never knowingly instructed anyone to violate a CPSES procedure../
Allegation No. 2
[
A QC Supervisor instructed an electrical QC inspector not to do in process inspections, but only to inspect completed-work, which is contrary to pro-cedures.
)
Investigative Findings On February 24, 1981, Individual A was interviewed and stated it was his 4
opinion that Individual C discouraged electrical QC inspectors from performing the procedurally. required in process inspections., Individual A i
stated that a rumor exists within the electrical QC Department that one QC inspector was fired for dcing "too many in process inspections" and other QC inspectors are now using that as an excuse for not doing in process
(
inspections.
Individual A could provide no information relating to specific instances wherein the Supervisors told inspectors not to do in process inspections.
Individual A further stated that Individual J was known to rarely cohduct in process inspections and had been heard to say "they take too long and they are boring." Individual A stated CPSES procedures i
require each inspector to conduct a minimum of 10 in process inspections
]
per day.
Individual A stated that Individual J had probably never con-ducted 10 in process inspections in a single day..
)
Interviews of Electrical QC Inspectors Between February 25, 1981 and March 12, 1981, Individuals D thru K were individually interviewed.
Individuals D, E, F, G, H, I and K each stated they regularly performed in process inspections du_ ring the course of their.
duties.
Individual J related that in process inspections are "too tima 1
j consuming and.they are boring." Individual J admitted avoiding in process inspections whenever possible, but stated in recent weeks everyone conducting-termination inspections has been getting to do a lot of in process work.
Individuals D thru K uniformly stated that they had never been instructed F
by Supervisors, not to conduct in process inspections nor had Supervisors ever discouraged their conducting in process inspections.
Individual G i
4 i
related that his understanding of CPSES procedures required'that the i
electrical QC Department conduct a total of'10 in process inspections per
. day; however, there was no requirement-for a specific inspector to conduct any required _ number of in process inspections.
-In'erviews of Former QC Inspectors t
On March 9,1981 and March 11, 1981, Individuals L and M respectively, were individually interviewed. -Both stated that when formerly employed i
in the electrical QC Department they each regularly. performed in process i
. - _ =
7 inspections and neither recalled having ever been discouraged from, or instructed not to do in process inspections.
Individual L explained that during 1980 the electrical QC Department had many more terminations inspectors than now employed, due to the larger quantity of terminations being done.
Individual L stated some of these inspectors did numerous in process inspections ~during each week day while other inspectors were
" lazy" and did very few, if any, in process inspections.
Individual L stated.that he believed this disparity in total individual productivity,
. as well as with in process inspections conducted, created some resentment towards several of the less motivated inspectors.
Individual M also related that some termination inspectors, whom he did not identify, were i
" lazy."
Interview of Electrical Craft Supervisor On March 10, 1981, Individual 0, an electrical craft supervisor, was inter-
[
viewed.
Individual 0 stated some termination QC inspectors had worked closely l
with the electrical termination department and had conducted numerous i
i in process inspections of work performed by his personnel.
He stated other QC inspectors were not particularly responsive to the needs of his personnel i
and that he had heard criticism regarding some QC inspectors who would, on t
many occasions, make excuses or refuse to conduct in process-inspections.
l i
Individual 0 stated he never heard nor had any indication that electrical
[
QC Supervisors had instructed their personnel not to conduct in process inspections.
l i
i Interviews of Brown and Root (B&R) Elect'ricians -
l On March 9,1981, Individuals P and Q were individually interviewed con-cerning their knowledge of in process electrical QC inspections.
Individual ~ P stated most electrical QC personnel ~are not reluctant to i
conduct in process inspections.
Individual P identified Individual J i
as having refused, on numerous occasions, to conduct in process inspections l
stating "it is boring."
Individua-1 Q also identified Individual J
[
as the only electrical QC inspector he knew who avoided or refused to conduct in process inspections.
Neither P or Q were aware of any facts l
which would. indicate electrical QC inspectors-had been instructed not to I
conduct in process inspections.
l Interviews of Electrical QC Supervisors On March 12, 1981, Individuals C and N were individually interviewed.
I Individual C stated that the electrical QC Department is required by i
procedure to conduct a total of 10 in process inspections each day.
Individual C stated the purpose of the in process inspection is to sample the work of various electrical deparment craftsman to ensure i
they are doing the work properly.
Individual C stated that during the past year the electrical QC Department bas far exceeded the required i
r-number of in process inspections daily.
Individual N also stated the l
(
i e
8 number of in process inspections conducted each day is more than adequate to determine that work is being done properly.
Both Individuals C and N stated they have never told inspectors not to conduct in process inspections nor have they ever discouraged the inspectors from conducting in process inspections.
Alleoation No. 3 Field copies of blueprints used by electrical QC departments for inspections are not always of the current revision.,
Investioative Findings On February 25, 1981, Individual A was interviewed.
Individual A stated that during the: course of the last year, on several occasions, blueprints obtained from the electrical QC Department, for use~during inspections, have not been of the current revision.
Individual A stated this problem never resulted in an inspection being done improperly.
Individual A was unable to identify any specific date or blueprint associated with this problem nor was Individual A able to identify any other inspectors who were aware of
.this problem.
Interview of Electrical QC Inspectors Between February 25, 1981 and March 12, 1981, Individuals D thru K were ~
individually interviewed.
Individuals E, F, H and J related they had never identified a blueprint, they 'were using for inspection purposes,-
as being out-of-date.
Individual D stated be had, on several occasions, identified blueprints as being out of-date; however, the problem was quickly resolved.
Individuals G, I, L and K indicated they had identified blueprints as being not of the current revision on several occasions and it had created no problem for them during the course.of their inspections, as the proper blueprint was readily accessible.
None of these inspectors indicated that a problem with blueprints leads to a QC inspection being improperly done.
Interview of Electrical QC Suoervisors t
On March, 12, 1981, Indivudals C and N were individually interviewed.
Individual C stated 'that during a short period in 1980 the electrical QC Department had received revised blueprints ~approximately one' day later than the electrical craft department due to hand delivery.
Individual C stated that upon notifying the B&R Document Control Center of this problem it was quickly resolved. _ Individual C stated he was aware of no problem, created for the QC inspectors by out-of-date blueprints, aside from the inconvenience of having to obtain a current revision.
Individual N stated that on rare occasions the electrical QC Department does not have the current revision of a particular blueprint.
He stated this problem is alway's resolved quickly and to his knowledge has never created an inspection problem.
Individual N additionally stated that an audit of
9 the electrical QC Department blueprints is conducted every three months and rarely is any problem ever identified.
Alleoation No. 4 Electrical QC management is " tight with the craft" as a result of their being sympathetic to production management.
Investigative Findings On February 24, 1981, Individual A was interviewed.
Individual A stated that it was his impression that Individual C is overly sympathetic to the needs of production management and that this may contribute to a compromise of Quality Control inspections at CPSES.
Individual A related, as an example of this, a frequently encountered 1980 problem relating to separation requirements for safety related cables going to the CPSES control room.
Individual A stated QC inspectors had been required to prepare two separate inspection reports regarding some cables on which the required separation had not been met.
Individual A stated that when QC inspections of cables were conducted and all aspects were found to be acceptable, with the exception of separation, two reports would have to be prepared.
One report would document the inspection acceptability of the cables and/or terminations and a separate report would be prepared documenting that the required separa-tion had not been met.
Individual A stated this was obviously being done to preclude the_ separation aspect being the basis for an unsatisfactory inspection report for the cable as a whole.
Individual A stated that he felt this policy was the result of an informal ag'reement between Individual C and production management.
Individual A was unable to cite any additional examples of Individual C being sympathetic to production management needs.
Individual A agreed that, insomuch as the unsatisfactory separation con-ditions were documented and must be addressed, no further safety-related problems are likely to occur.
Interview of Electrical OC Insoectors Between February 25, 1981 and March 12, 1981, Individuals 0 thru K were individually interviewed concerning their independence as QC inspectors and the possibility that quality may be compromised due to management being sympathetic to production needs or requests.
Individual 0 related that on several occasions he has overheard members of his Department, whose identities he was unable to recall, relate instances wherein Individual C had told them to ease off on some inspections to avoid conflict with the craf t.
Individual D stated he had no personal' knowledge of this having occurred.
Individual D stated he felt totally independent in conducting Quality Control inspections and believed he was. supported by QC management to the fullest extent in his decisions.
Individuals E thru K also stated they felt totally independent in' their Quality Control evaluations and believed they had the full support of other Supervisors with regard to decisions they made.
None of these Individuals recalled having ever personally been. asked to " ease off on inspections" 'nor did they believe that electrical QC Supervisors are sympathetic to the needs of production management when quality might be adversely affected.
l
+
j t
i 10 i
t Interviews of Electrical QC Suoervisors 4
j On March 12, 1981, Individuals C and N were individually interviewed.
Individual C stated his Supervisors allow him the independence and latitude E
to manage his Department as it should be.
Individual C stated he maintained a good relationship with Craft Supervisors however, his primary goal is to ensure that.the Quality Control objectives at CPSES are achieved.
Both Individuals C and N stated they were totally independent from craft pressures and that they had never been pressured by their own Supervisors i
or production management to compromise Quality Control standards.
j (Investigators Note:
While conducting the foregoing facets of this j
investigation a possible noncompliance with CPSES procedures was identified, l
relating to NCRs, within the electrical QC Department.
Investigative findings concerning this matter are contained in this report.)
l Allegation No. 5 2
Some electrical QC' personnel are inadequately qualified; were helped to j
past the Certification Tests and their experience requirements were i
" pencil whipped."
l r
Investigative Findings On February 24, 1981, Individual A was interviewed.
Individual A stated i
I that several persons working as QC inspectors in the area of electrical l
termination were not qualified for their positions when they began working I
as QC inspectors.
These persons were identified as' Individuals H, I and
~
J.
Individual A stated none of.them had prior electrical or construction i
experience, therefore the experience portion of their applications must i
have been " pencil whipped." (Falsified to document them as having a certain degree of experience.) Individual A related that Individual I i
i has worked hard and would probably now be qualified, due to the experience level achieved.
Individual A-related having heard that Individual J got b
hired as a QC inspector due to Individual's C being a close friend of j
Individual J's brother.
Individual A stated numerous other persons employed as electrical QC inspectors and als'o some electrical craftsman concurred i
in the aforementioned evaluations of Individuals H, I and J.
Interviews of Electrical QC Inspectors i
i Between February 25, 1981 and March 12, 1981, Individuals' 0, E, F, G and K were individually interviewed.
Individual D identified Individuals I and J as being only marginaly qualified for their duties as QC inspectors.
[
Individual D stated that Individuals-I and J seemed to make no effort L
i to improve their ability and due to their having apparently gained the favor of their Supervisors (Individuals C.and N) they can usually be i
l i
.n.+-.m r
---.---.---.-.-r
-r
,,-r.
.,.--,_%._m...-.....,._,-w_,nv
.,,_.~,--,-me,-
,-wr-.-mmee+,-s.-
-rwe.
11 found sitting in the office talking.
Individuals E and F stated they felt all persons working as electrical QC inspectors are qualified for their jobs.
Individual G stated Individual H was qualified and works hard.
Individual G related having never worked with Individuals I and J, but stated some inspectors, whom'he refused to identify, are " lazy."
Review of Former QC Inspectors On March 9, 1981 and March 11, 1981, Individuals L and M were individually interviewed.
Individual L stated that Individuals H and I were pretty good workers and are probably qualified in all phases of the inspections they perform.
Individual L stated Individual J, at best, was probably only marginaly qualified as a QC inspector and was a very poor performer.
Individual L stated that electrical QC Supervisors displayed an obvious favoritism towards Individuals H, I and J over other QC inspectors, which would probably' account for their doing less field work and spending more time around the office.
Individual M stated a belief that all QC inspectors are qualified, but stated some (not identified) are " lazy."
Interview of B&R Electricians On March 9,1981, Individal's P and Q, B&R electricians, were individually interviewed.
Individual P stated that Individual J was not adequately qualified as a QC inspector.
Individual P related that on occasions Individual J would ask questions about work being inspected which would indica,te a lack of knowledge regarding the field.
Individual P stated that Individuals H and I also do not appear adequately knowledgeable regarding electrical QC work.
Individual P also identified Individual R as probably not being qualified and performing poorly.
Individual Q stated Individual J may not be qualified as a QC inspector and related details regarding occasions when Individual J did not understand simple aspects of work to be inspected.
Individual Q related no knowledge regarding Individuals H and I being qualified as electrical QC inspectors.
Review of B&R OC Qualifications and Training Records i
On February 26, 1981 and March 12, 1981, CPSES requirements for QC inspectors qualifications and the training records for Individuals H, I,. J and R were reviewed.
It was determined that each met the required background qualifications and satisfactorily completed the required written and oral examinations and the required on-the-job training necessary for certi-fication as electrical QC inspectors.
It was noted that Individual J passed the certification exam for the inspection of electrical terminations wif.h a score of 84 percentile, subsequent to the disqualification of two incorrectly answered questions.
Examination of other electrical terminations certification exams taken by other persons during a similar time frame disclosed the same questions had not been disqualified.
It was determined that Individual J would not have passed this certification exam had these questions 'not been deleted l
from the exam.
12 Interview of B&R Quality Engineers On March 12, 1981, Individuals S and T, B&R electrical Quality Engineers (QE) were interviewed.
Each explained that a combination of on-the-job training and classroom training are required of individuals prior to taking a particular QA Certification Exam.
Individual 5 stated all certification exams are administered by a QE, subsequent to which an oral exam is administered.
Individual 5 stated that the QE, based on the results of the oral exam, has the right to adjust, upward or downward, the score of the written examination.
Individual S stated the certification can be denied solely on the results of the oral exam.
Individual 5 stated; however, that a person who displays a obvious understanding of the material required for certification, but has not scored above the 80% required on the exam, is usually required to take the examination again.
Individual 5 stated the QE who administered the written and oral exam to Individual J was no longer employed at CPSES; therefore no reason could be provided for the disqualification of questions on the written exam of~ Individual J.
Interviews of Individuals H, I and J 4
On March 11-12, 1981, Individuals H,II and J were each separ,ately interviewed by an NRC inspector (Electrical Specialist) and NRC investigator in an effort to determine their respective qualifications.
The interviews indicated that each possessed an adequate degree of familiarity with the inspection procedures and techniques to perform the termination inspection requirements.
Individuals H, I and J also indicated that they freely exercise the prerogative of asking their Supervisors for the answers to any questions that they encountered during the performance of inspections, -
both technical and 'dministrative.
These interviews determined that QC inspectors H, I ant J were each qualified to conduct the QC inspections in the area of electrical cable termination inspections or instructed by site procedures.
When specifically queried concerning the possiblity that Individual C had influenced Individual J's employment in the QC Department and influenced certification, Individual J related having no personal knowledge to support such allegations and stated no personal relationship existed with Individual C, aside froni a professional one.
Interview of Electrical QC Suoervisors On March 12, 1981, Individuals C and N individually were interviewed.
When questioned concerning the qualifications of Individuals H, I and J, as electrical QC inspectors, Individuals C and N each. stated they' believed those individuals to be qualified.
Both stated a belief that the training program for QC inspectors was sufficient, but each added that more' training would be desirable.
Individual C stated that as an adjunct to the initial 1
training program, new electrical QC inspectors are encouraged to. always ask questions-of either Supervisors or more experienced Electrical QC inspectors when.they had questions concerning an area they were inspecting.
Both 1
I I
~u---
13 Individuals C and N stated that over a period of time this process can develop good inspectors.
When specifically questioned concerning Individuals H, I and J, both Individuals C and N stated they believed the training and experience had mutually been responsible for the better qualifications of those persons.
When questioned concerning the alleged favoritism received by Individuals H, I and J, Individual C stated that the attention received by these individuals during their training was apparently misunderstood as being favoritism.
Individual C stated that Individuals H, I and J, due to their inexperinece,.had required more assistance of the Supervisors during recent months, which may have been misunderstood, by some, as fav'oritism or special attention.
- Lastly, Individual C stated he was a personal friend of Individual J's brother; however, this had in no way influenced Individual J's receiving a job within the electrical QC department.
Furthermore, Individual C stated that he had not been responsible for hiring Individual J nor had Individual J's brother been aware that Individual J was being transfered to the electrical QC Department.
Allegation No. 6 Electrical terminations were being made anc " bought off" by some electrical QC personnel, in nonconformance with drawings.
Investigative Findings On February 24, 1981, Individual A was interviewe.d.
Individual A stated he believed electrical terminations have been " bought off" (approved by inspectors) which are in nonconformance with drawings.
Individual A stated this situation is specifically attributable to some electrical QC inspectors being unqualified for their job, rather than any intentional wrongdoing.
Individual A provided two examples of nonconforming con-ditions which were approved by electrical QC inspectors (Individuals I and J).
Individual A was unable to provide any additional information pertinent to the identification of nonconformances which have been approved by electrical QC inspectors.
Inspection of Alleged Nonconforming Conditions On February 25, 1981, an inspection of the alleged nonconforming conditions, approved by Individual J, was conducted.
The inspection disclosed that no nonconformances existed in the alleged component, at this time.
On February 26, 1981, a review of the documentation relating to the allegedly nonconforming conditions approved by Individual I was conducted.
The review disclosed the work associated with this inspection required only a visual inspection after the work was completed.
The documentation for this work indicated that Individual I had visually observed and approved the work and additionally the work was also independently approved by one other electrical QC inspector at another time.
i 14 Interview of Electrical QC Inspectors 4
Between February 25, 1981 and March 12, 1981, Individuals 0 thru K were individually interviewed.
Individual D stated he believed that allegations made that electrical QC inspectors have " bought off" inspections would probably more aptly relate to the qualifications of an individual inspector i
and his/her ability to identify a particular nonconformance.
Individual D stated he has no knowledge of a nonconformance being knowingly approved by a electrical-QC inspector.
Individual D stated he had personally reinspected the task which had been visually inspected by Individual I (reported above),
and found the work to be in conformance with drawings.
Individuals E thru l
K related having no personal knowledge of nonconformances being approved by QC inspectors.
Individuals H and J each stated if they had approved i
a nonconforming condition in the past, it was done unintentionally, i
Individuals H and J stated that such an occurrence would be the result of their not understanding all aspects of the work they were inspecting.
None of the aforementioned inspectors recalled having ever been asked to approve a nonconforming condition.
Interview of Brown & Root Electricians On March 9, 1981, Individuals P and Q were individually interviewed regarding electrical QC inspections ' :ing " bought off" in an nonconforming condition by electrical QC inspector s.
Both Individuals P and Q comments regarding inspections being " bought off" related directly -to the qualifications of specific inspectors and the diligence with which.they conducted their
' inspections. Neither Individuals P or Q was aware of any nonconformance-being intentionally approved.
i Interview of Electrical QC Supervisors On March 12, 1981, Individuals C and N were individually interviewed.
Vnen questioned concerning electrical QC inspections being " bought off",
i Individual N related that occurrences of nonconforming conditions being approved by an electrical QC inspector would probably be the result of the 4
respective inspector's inexperience.
Individual N stated that during i
the summer and fall of 1980, when much electrical termination work was being done and when a number of terminations inspectors were new on the job, the likelihood of nonconforming conditions not being identified during an inspection was much greater than now.
Individual N stated he frequently, during that timeframe, reinspected work done by the less experienced ins'pectors and, on occassions, did identify mistakes they had overlooked.
Individual N stated that termination inspectors were encouraged to contact him when they had questions regarding a particular inspection, in order to preclude errors being made.
Individual'N stated he did not believe any intentional approval of a nonconforming item had ever occurred.
Individual C also stated if' errors were made during inspections and a nonconforming condition was approved, it'was due to the inexperience i
of the respective inspector.
Individual C stated that the less experienced inspectors were assigned less complex inspection task when they began in order for them to gradually acquaint themselves with the inspection process and avoid errors.
Furthermore, he stated that, as an adjunct i
l.
15 to the former training program, new inspectors'were instructed to "ask questions" of their supervisors when they did not understand the area they were inspecting.
Individual C stated this process made better inspectors and helped ensure that mistakes were not made during inspections.
A11ecation No. 7 Construction and inspection records relating to some pipe hangers are being separately maintained, resulting in their final QA review being inadequate.
Investigative Findings On February 23, 1981, Individual B was interviewed.
Individual B stated that prior to April 1,1980, procedures for the construction, installation and inspection of every pipe hanger was very rigorous and that each step in these processes was documented.
Individual B stated that on April 1,1980,. the procedures for most of this inspection and documenta-i tion were eliminated.
Individual B stated that a new procedure was implemented which required each safety class hanger have NDE and mechanical inspections performed following its installation.
Individual B stated that the problem exists with regard to hangers being fabricated prior to a April 1,1980, and which were completed subsequent to the initiation of the new inspection procedure.
Individual B stated that the hanger packages (containing all documents relating to the fabrication and inspection of each hanger)- in existence on Ap,ril 1,1980, were filed l-away and a new hanger package was started for every hanger which was not yet installed and QC approved.
Individual B pointed out-that the Documentation Review Group, now reviewing the fabrication and inspection history of each hanger, is only receiving the hanger packages containing documentation prepared after. April 1,1980.
Individual B stated that-this prevents a complete review being accomplished on hangers which were in the fabrication process on April 1,1980.
Individual B stated the Welding Engineering Department currently main-tains the old hanger packages for hangers which were being fabricated on April 1,-1980, and they refused to give the old packages to the Docu=entation Review Group without a written request from the QA Depart-ment.
Individual B stated this constitutes a violation of CPSES pro-l cedures, in that all documentation is no't being incorporated into a final review package.
Interview of Documentation Review Group Suoervisor On February 25, 1981, Individual U was interviewed regarding the review of hanger packages.
Individual U stated that since January 1980 numerous procedural changes have occurred relating to fabrication.and inspection of pipe hangers which has resulted in problems regarding a mutually agreeable consolidation of all records relating to the respective hanger packages.
Individual U stated that on September 1,1980, a major procedural change was implemented regarding the. documentation format for both construction l
and QC preparation of structural hanger packages.
Individual U stated
{
16 that subsequent to September 1,1980, he learned that hanger documentation packages were being divided into two separate packages by the Welding Engineering Department.
He stated this division involved separation of old documentation (prepared prior to September 1, 1980), into a packsge that would be maintained by the Welding Engineering Department and another package of documents prepared in accordance with the new procedural change (subsequent to September 1, 1980).
Individual U stated that subsequent to the installation and inspection of the hangers having two documentation packages, only the new package was being forwarded to the CPSES vault for final component review.
Individual U stated this separation of the packages did not always affect his final review and acceptability of a respective hanger.
He stated tha't when the old documentation was required to make a final determination of acceptability, his group was required to submit a written request, through his Supervisor, to the Supervisor of the Welding Engineering Department in order to obtain the old hanger package.
Individual U stated that on every occasien his Department's requests for the old hanger packages were approved.
Individual U stated that approximately one month ago (early February,1981),
. the Welding Engineering Department had agreed that upon notification that a new hanger package had been sent to the Documentation Review Group for review, they would send the old package to also be reviewed.
Individual,U stated that during the past week, acco_rding to information he had received, the Welding Engineering Department had sent several boxes of old hanger packages to the vault room for storage with the new hanger packages.
Individual U stated this would ensure availabilty of all documentation relating to hanger packages.
Individual U stated that the Welding Engineering Department had never refused to send a package for the reviews his group was conducting and no CPSES procedures or codes have been violated.
Lastly, he stated that had he ever been refused a hanger package, to complete his review, he would have refused to determine the acceptabilty of the respective hanger. "
Allegation No. 8 Electrical QC Supervisors require that nonconformance report (NCR) drafts be submitted to them and they are the only individuals within the electrical
.QC Department authorized to obtain an NCR number for the draft.
Investigation Findings On March 11-12, 1981, Individuals H, I, J, L and M were interviewed individually regarding matters associated with this allegation.
During the interview of Indivudal M, he commented that the electrical QC Department policy regarding NCRs, is that the inspector prepares the draft and gives it to either Individual C or Individual N (electrical QC Supervisors) who are the only persons authorized to obtain an NCR number for the draft.
Individual N recalled that during November 1980, Individual C had stated an NCR prepared by Individual M related only to the " cosmetic" aspect of the item inspected and had directed it be withdrawn, which it was.
Individual M stated this was the only occasion in which he ever had an NCR denied by a Supervisor.
Individual M did not recall any specific information regarding that NCR.
Interview of Individuals H, I, J and t disclosed they each were aware of the electrical QC Department policy designating
17 electrical QC Supervisors as the only persons, in that Department, authorized to obtain NCR numbers for NCR drafts.
None of these individuals recalled ever having been denied the right to submit an NCR.
Interview of NCR Coordinators On March 11, 1981, Individual V, a TUGC0 NCR Coordinator was interviewed regarding electrical QC Department policy relating to obtaining of NCR numbers.
Individual V stated that in about September 1980, Individual C had directed that only he and Individual N be allowed to obtain NCR numbers for the electrical QC Department.
Individual V stated that no electrical QC Department NCR, without Incividual C or Individual N's signature on it, had been processed, in accordance with this direction.
On March 12, 1981, Individual W, a B&R NCR Coordinator was interviewed.
Individual W stated that B&R NCR Coordinators office processes only civil and mechanical QC inspection department NCRs.
Individual W related having no association with the electrical QC Department or their NCRs.
Individual W stated that no agreements exist between the B&R NCR Coordinators office and civil or mechanical QC Supervisors.
Individual W stated however, that 99% of the NCRs issued from the B&R NCR Coordinators Office, to the civil a'nd mechanical QC Departments, are issued to Supervisors.
Interview of Electrical QC Supervisors On March 12, 1981, Individuals C and N were individually interviewed regarding their department policy relating to NCRs.
Individual N stated a policy exists in the electrical QC Department requiring electrical QC inspectors to provide an NCR draft to an electrical QC Supervisor (either Individual C or Individual N), for review and that the respective Supervisor is responsible for obtaining the NCR number from the NCR Coordinator.
Individual N stated that he had never " turned down a legitimate NCR; however, he stated that he had questioned the legitimacy of some and has required that a Field Deficiency Report (FDR) be prepared instead of an NCR on occasion." Individual N stated this problem happens only occasionally (two or three. times per month), and usually involves an inexperienced inspector.
Individual C, when interviewed, stated he was responsible for initiation of the policy requiring electrical QC inspectors to have their NCRs approved by a Supervisor because, during the early fall,1980, he learned some electrical QC inspectors were obtaining NCR numbers for their NCR drafts and never submitting the NCR.
Individual C stated he implemented the policy to assure accountability of NCR numbers and to ensure each NCR submitted, by his department adequately explained and identified the problem found.
Individual C stated he was not aware his policy contradicted TUGC0 (CPSES) Procedure No. CP-QP-16.0 (Revision 3),
dated July 9,1980.
Individual C stated he would rescind his policy and ensure compliance with the site procedure.
t
1.
18 r
Interview of QA Manaoer i
On March 13, 1981, Individual X was interviewed.
Individual X stated he
[
was unaware the site NCR. procedure was not being preperly followed by i
the electrical QC Department.
Individual X stated he believed this was an isolated situation and that corrective action would be immediately taken to properly implement the site NCR procedure.
Individual X, furthermore; stated "I will make it clear how this procedure is to be interpreted and imple-mented" to all QC Departments."
l I
t i
l 4
1 P
I i
l i
I
+
1 4
e v
v w
~
r
e w
DEPARTMENTAL CORRESPONDENCE DATE October 28_ 1991 A
LJEtt Texar titilit ies Services - Letter dated October 27, 1953 R.~B.
Roth OV_
J. Lieinnkv 1.
In addition to the individuals identified in the subject trip report, the vricer met with a number of the coating quality control inspectors.
These individuals were: 1amette Adamn Dave Ambrose Gary Corrigan Joe Deshanbo (sp?)
Margaret Lucke Evert Mouser Casandra Owen Note:
The writer unet other inspectors but cannot recall the individual names.
~
The writer discussed job status, project conditions, work activitics and other miscellaneous items with the above individuals. The writer has either employed or worked with the above listed individuals en one or more nuclear projects.
2.
As stated rcpcatedly by the writer, a thorough review / audit would be required to provide specifics on the six itelas listed by
'.N.
Chapmsc.
J However, the following explanation is provided for each item as listed by D. N. Chap::utn.
- A.
Material Storage - the writer observed that the costing material is mixed, and set on pick up pallets outside Containment.
None of the material had tage attached (status or six information), and there is no apparent control on how long mixed matcrial sits on the pallets.
~
i B.
Workmanship - at the time of the writer's visit the applicator qualification program was being administered by production pcraonnel with no inspection or monitoring of the* qualification proecss (befer during or af ter) by quality control.
This information was provided to the writer by Mark Wells of site engineering'and quali,ty control.
Vith regard to the quality of the work, the writer observed numerous arcas of in place work which by t.;,pearance was less than the qualit) of work put in place by Cannon on nuclear and non-nuclear projects
\\/
- l
. )n A,
D,2 bl
[ ; (,1
/
j
)
w oac 215 m
+,
7 9
-c
~
l To:
R.'b. Roth Re:
Texas Utilities Services Letter Dated 10/27/83 October 28, 1983 Page 2 i
Additionally, by engineering and/or productiothe writer was informed o individuals n that a low percentage of then m any Cood as p(ainters.34 out of 452 individuals) empl Compliance with ANSI Requirem oyed as painteys were no C.
the report all of the required data was notformat utilized on site.e However amined Also, ANS7 has included on indications were t hat,
there are forms to be completrequirements for applicator qualifi the inspection reports.
manuf acturers ' inst ructions, notcrial storage, tagging, andcation
'd),
neue a few.
D.
"Possibly" coating integrit Possible document deficienciesy see Item E and P on pag E.
P.
!! orale probicas - based on con see Item C above the writer concluded thatrersonnel, including those in f
were not satisfied with their jobsthe ins ~pection personnel on thn numbe n
e!. project To the writer's knowledge H. Williams are no longer,o. Deshanbo, E. Nou J
1 3.
As indicated in the subject n the project site as of October 31ser, C. Ow that
'prclininary assesseent btrip report, when the write 1983.
problems t
painter quelification and indoin areas of'satcrial stor y J. J. Lipinsky, that Comanche PradvikedR.To ctrination), not satisfage, wcrkmanship (qua ments and possiole co
- eal. has not my job or concern"ating integrity', he (R. Tolson)ying ANSR require-and of coating integrity (andThe itees indicated, with thereplied J' 'That 's opinior., with quality related that "Thet is not is debatable) deal, at possible exception to believe thatbia job or conrrn" patters and R. Tolsor., the QA Mid the writer least cerned with quality.R. Toleon was indicating th t hTherciore, the writer wol C. Brandt e (R. 1olson) was note incline a
4 advised them (C.and R. Tolson mentioned T. Mill con-
' Cannon employees (Erandt
{
er specifically when the writer and R. 1olson The writer vaa referring to iinspectors) were or)are that approximately nine former 5
on the project.
6.
~
See item 2B abc.ve.
ssues raised in Item 2 above 7
In the writer 's opinion at the meeting of July 28and apparently in the opinion of result
, 1983 of this a get together was(see page 2) this was the situationthose Inspectors and' foreman togeth planned based on follow-up centersatio. However, to bring the Quality Control A6 er.
this was later ns with the site personnel caneclied..
l l
To:
R. B. Roth ke:
1exas Utilities Services Oct ober 28, 1983 Letter dec ed 10/27/83 Page 3 8.
Apparently, the air cocpressors or air supply lines were not providing clean (water and oil free) air, and up to half the shift, approximately.
five hours, was utilized to make the air quality acceptabic.
~
Zimmer has probicos related to coatings as a result of placing more 9.
cephasis on production than they (Zimmer) did on quality.
It is the writer's opin3on that this appears to be a hang-up at Comanche Peak.
10.
The writer based this statement on conversations with inspection staff in what appeared to be poor instructions in the procedures (though the writer cannot recall specifics), coupled with the number of changes to the spceifications (most of which catered toward relieving requirements on areas or items where requirements could not.be satisfied.
The implications of the writer's statement is that somewhere down the road, another set of eyes may or may not concur with my assessnent.
11.
See Item 2 above.
i 12.
As a result of the meetings attended by the writer', the site management peopic (R. Tolson) declined the offer of Cannon to perform an in-depth sudit that would have either confirmed or-satisfied the concerns I raised.
13.
The writer based this on conversations with site inspection personnel and the apparently disinterested attitude of R. Tolson, when advised of potential coating quality problems.
14.
See Item 2F above.
15.
The writer is unable to recall the names of inspeerion personnel encoun i
while in the field.
HovcVer, two of the topics frequently discussed we the quality of work and where employment possibilities oey currently er.
l 16.
There is an honest internal disagreement in the manner in which ANSI re t
quirenents impact the cost of a project and the quality of the,vork.
l l
17.
Sec Item 12 above.
38.
The writer. based this observation on previous work experience, and l
suggests that the coating manufacturer be contacted to confirm same.
I
{
Hote:
Power grinding on~ isolated areas of one square foot or less abould not be a probica.
l 19.
- l. gain, the writer based thia observation on previous work experience and sugEcsts that the coating manufacturer be contacted.
However, old l'henolinc 9305 (one year or more, with veld fuse accumulation) may not
[
......n....
...,. w..u. a
.. <.<.,. :. r.....
To:
R. B. Roth
'he: Texas Utilities Services October 28, 1983 Letter dated 10/27/83 Page 4
- 19. - continued beadequa{elycleanedandprovidesufficient intercoat adhesion by solvent v2 pang.
20.
The writer's speciality is Quality Assurance / Quality Control, as.these terms deal with.cor, tings and the writer's of fer of an in-depth audit (in order to confirm or alley quality concerns) was repeated 13 rejceted.
Also~sce Itcas 3 and 12.
21.
Based on the writer's observations on site. and my past Nuclear site-experience, the work observed in place appears questionable with regard i
to quality.
(Again, an in-depth audit / review may resolve this issue.)
Also, any attempt by Cannon or any qualified professional applicat or to gsalvage "in place work", msy not be practical or realistic, certainly, isolated areas mey prove acceptable and perhaps complete rooms a6ay be okay.
However, realistically and from a cost /cifcctive viewpoint, "revork" is more logical considering production effort and the attendent documentation.
22, 4cc Iteni21 above.
Additionally, the retrofit program tasy well rc=olve the writer's concerr but I have not reviewed the adequacy or result, of the ret rofit program.
Realir.ing that the writer is not. familiar with the results of the retrof program. I cannot consent one way or the other on the acceptability of I retrofi t program.
23.
The writer distributed the trip report to R. B. koth and J. J. Norris, c or around August 8, 1983.
24.
The writer did discuss the subject matter in my trip report with T.. Nous Field Coatines Quality Control Supervisor, on. subsequent trips to the
. project site.
),
r
(
c l
- 0. *.
yQ) f.L k,2' g
ao(,h Lgpi),(y
{
Dat e d :
1
.)
.. a m.
.. m.. m... l..
- .v --.
.z., ?.
..n.....,...
k l
l 1
m.-.
y _..
7 7
IdP
- 4, UmgTED STATES t
NUCLEAR REGULATORY COMMISSION f.,
g
?
^A E
REGION IV k
$11 RYAN PLAZA oRIVL SUITE 1000
%, f,',, /
ARumatoN.TsxAs mott June 21, 1984 In Reply Refer to-Occket: 50-445 Texas Utilities Electric Cormany Attn:
M. D. Spence, President, TUGC0 Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Gentlemen:
This refers' to the special inspection of the Cable Spread Room during the period of March 13, 1984, through April 11, 1984, of activities authorized by NRC Construction Permit CPPR-126 for the Comanche Peak Facility, Unit 1, and to the discussion of our findings with you and other members of your staff at the conclusion of the inspection.
This inspection is the second in a series of planned construction completion room / area inspections. The primary purpose of this inspection was to evaluate actual as-built status of the Cable Spread Room as compared to the design and insoection documentation. This inspection covered some construction character-1stics, such as cable separation, workmanship, suoports, etc., which have been the subject of allegations to the NRC, but the inspection _ was not intended to achieve resolutien of specific allegations except for the specific concern noted in the report regarding cable tray side rails. Resolution of specific allegations may involve additional inspection in these areas, and may result in additional corrective actions.
Areas examined during the inspection included Electrical Raceway and Raceway Su::corts, Electrical Cable Routing and Terminations, Electrical Separation, HVAC, Fire Protection / Detection, and followup on unresolvec items from the soecial inspection of the Fuel Building. Within these areas, the inspection consisted of selective examination of procedures and repre-senta:1ve records, interviews and discussions with craft and OC personnel, and ocservations by the inspectors. The findings are occumented in the enciesed ins::ection report.
y' Within the scooe of the inspection, no violationsNr deviations')were
---._,.___..r._....
N identified. The secoe and results of this inspitctidrr%4 test 1it that the
~
utili:aticn of Building Manager codcaptMproviding approcriate controls for the tracking and satisfactory ccmoletion of the Uni: 1 Cable Sprea,d Roc..
r 9/@g l
8 YO 3;p
io Texas Utilities Electric 2-June 21, 1984 Canpany One new unresolved item pertaining to Fire Protection is identified in Paragraph 7 (8410-01).
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office by telepnene, within 10 days of the date of this letter, and submit written application to withhold infomation contained therein within 30 days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, Richard L. Bangart. Director Region IV Task Force Enc 1csure:
NRC Inspection Recort 50-445/84-10 cc w/ encl:
Texas Utilities Electric Ccmpany ATIN: H. C. Schmidt, Manager Nuclear Services Skyway Tower 400 North Olive Street Lock Box S1 Dallas, Texas 75201 Texas Utilities Electric Company AT7N:
B. R. Clerrents, Vice President, Nuclear Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 i
f,'-
t U. S. NUCLEAR REGULATORY CCMMISSICM REGION IV NRC Ins:ection Report: 50-445/84-10 Occket: 50-445 License Pemit: CPPR-126 Licensee: Texas Utilities Generating Company (TUGCO) s' Skyway Tower 400 North Olive Street Lock Box 81-Dallas, Texas 75201 Facility Name: Comanche Peak, Unit 1 Inspection At: Comanche Peak, Unit 1, Glen Rose, Texas Inscecticn Conducted: March 13 - April 11,1984 I
s Inspecters: Il77" M.e, w._~&-
5/3//W
/ Date fp L. E. l'artin, Reac ce Inspector, RIV Task Force
/,
(paragraphs 1, 2, 3, 4, 6, 7, 8, 9, 10, and 11)
A b $')" M s P
.: /.T//o
~
v
- C. R. Oberg, Reactor,, inspector, RIV Task Farce Cete (paragraphs 5 and 8) k 5
tbs S /~5/ f S4 s
C. E. Jonnson, Reagor Inspector, RIV Task Force Date
/
(paragrapn 5)
'f g
, 'i,i -
, wn,,
a M.-E. Mur3ny, Reac:Or Ins ector RIV Tasx Force ate (paragrach 7)
Aceroved:
., f** b i
/
.F 7//6y O. M. nunn1 cutt, Team Leacer, RIV Task Fer:e Ce te
'(
I.)
sf a
,, o lk U V ~
. g L
j
(
2 Insoection Suninary Inscaction Conducted: March 13 - April 11, 1984 (Recort 50-445/84-101 Areas Insoected: Special inspection of 'c.:.struction completion of Electrical Raceway and Raceway Supports, Electrical Cable Routing and Terminations Electrical Separation HVAC, Fire Protection / Detection in the Unit 1 Cable Spread Room, and followup on two unresolved items from the special inspection of the Fuel Building. The inspection involved 392 inspector-hours onsite by four NRC inspectors.
Results : No violations or deviations were identified; one new unresolved item was identified in the area of Fire Protection / Detection as discussed in paragraph 7 (8410-01).
e l
[
.o 3
DETAILS
- 1.
Persons Contacted Princioal Licensee Contacts
- M. D. Spence, President, TUGC0
- S. R. Clements. Vice President, Nuclear Operations, TUGC0
- L. F. Fikar. Exec. Vice President Engineering
-*J. B. George, Vice President, PGM CPSES
- J. T. Merritt, Site Project Manager
- M. McBay, Engineering Manager, TUGC0
- F. L. Powers, Building Manager I. Voglesang, Project Electrical Engineer
- 0. Snyder, Asst. Building Manager, UE&C B. C. Scott, QA Supervisor Other Contractor Contacts J. Fort, QC Inspector, B&R
'J. S. Leutwyler, QC Supervisor, B&R' J. DeVitro, QC Inspector, UE
- 0. Gray, QC Inspector, BAR J. Long, QC Inspector, B&R D. Holmgren, QC Inspector, B&R B. Bryson, Foreman, B&R S. Edwards, Project Manager, Bahnson D. O'Brien, Project Engineer, Bannson G. Dickerson, Project QA Manager, Bahnson The NRC inscectors also contacted other plant personnel including memcers of the construction, tecnnical, quality assurance, and administrative staffs.
'Cenotes those attending the exit interview.
2.
Insoection Obfective and Sccce The objective of this inspection was to evaluate the construction completion of the Unit 1 Cable Spread Room (Room 133). This objective was accomolished through examination of selected samoles of hardware, to insure that the hardware installation conforms with FSAR comitments and approved design documents as cetailed in the inscection packages.
w.
[
4 For eacn of the areas inspected, prepared inspection data sheets were utilized to define the inspection attributes, acceptance criteria, and results. These inspection dati sheets are included as an attachment to this report. Also included in the scope of this inspection were informal discussions with craft and QC personnel and subjective evaluations by the NRC inspectors of their job knowledge.
The areas selected for examination were:
. Electrical Raceway and Raceway Supports
. Cable Routing and Termination
. Electrical Separation
.HVAC Duct and Supports
. Fire Protection / Detection Also included in this inspection, but not part of the original sample plan was:
.Followuo on Unresolved Items from NRC Inspection Report 50-445/83-23 (Fuel Building)
This area is documented in paragraph 8 of this report.
3.
Status of Unit 1 Cable Scread Room The Unit 1 Cable Scread Room (Roan 133) was essentially complete at the time of this inspection. The major ongoing activities in the Cable Spread Roan were the installation of fire wrap materials and tray covers, termination cabinet modifications, and OC inspections associated with Insmected Item Removal Notices (IRNs), Design Change Authoritations (OCA),
and ocen Nonconformance Reports (NCR).
The following is a summary of the open items by discipline from Master Cata Base (MCB) System (Punch list) for Room 133:
Engineering 33 Paper Flow Grouc 63 Documentation 173 QC 58 Craft 714 1: art Ua 62 bisc 11 1,114 As from the aoove summary, the majority of the acen items were in.
the Craf t area. Cf the 714 craf t items 551 were reistec to electrical
(
5 separation items that had been identified, documented, and technically resolved, but the resolutions had not been implemented. The reason for the lack of imolementation was the licensee's decision not to install tray covers and fire wrap materials until after this inspection, in order to provide the NRC inspectors access to the cable raceways and supports. The installation of tray covers, fire wrao material, or other barriers will resolve the majority of these items.
'4 Electrical Raceway and Raceway Succorts The NRC inspector selected 80 sections of cable tray and 50 conduit runs for inspection. The specific raceway sections inspected are identified -on the Raceway Inspection Data Sheets in Attachment 1 to this report.
The following attributes were utilized during this portion of the inspection:
. Type and Size - This pertains to the type and size of conduit or cable tray including fittings, splices, pull boxes, covers, offsets, and fasteners.,
. Tray covers - installed as required or identified as an open item.
. Grounding - installed as reouired on all raceways. This ground-ing is primarily for personnel protection.
. Craftsmanship - all fasteners properly installed, raceways free of sharp edges and burrs, galvinox protection, raceways free of damage, overall integrity of raceways, and proper bending of conduit.
. Identification - raceway identification and train or channel identification at eacn end and at the proper intervals in between, as specified in IEEE 384.
. Supports - proper type and scacing of raceway suoports, material size and dimensions, welding, structural attachments, raceway attachments, location, bolt size and scacing.
. Separation (Wac :al/ electrical) - proper separation from pioina, ducting, etc. proper separation between voltage level, o.ie foot /
three feet separation between redundant trains, or barriers, and scoaration from possible noise sources for Nuclear Instrumentation System (NIS) cables.
6
. Documentation - review of installation and inspection records to ensure that these records document the as installed raceway and supports and agree with the current approved design information.
The NRC inspectors physically walked down and inspected 50 conduit runs, approximately 400 conduit supports, totaling approximately 2500 linear feet of conduit. The. inspectors utilized the current aooroved design infomation and the latest QC inspection report to determine the adequacy of installation and accuracy of documentation. The conduits inspected, including supports and fixtures, were properly installed and accurately documented with the exceptions of three inspection reports. The inspec-tion reports for conduit runs C14R11208, C13G14654, and CO2011932 had errors where the QC inspector had transposed numbers. These errors did not have technidal significance however, the licensee had the total conduit runs re-inspected and new inspection reports prepared.
-During this inspection the NRC inspector had-infomal discussions with craft, QC, engineering, and documentation personnel to determine job knowledge and overall familiarity with drawings, procedures and the day to day mechanics of their job. In every case the people were knowledgeable and professional.
The NRC insoectors physically walked down and inspected 80 cable tray sections,123 cable tray suppor*,.s, totaling approximately 1000 feet of cable tray. All of the cable trays and supports inspected were properly
- installed and the documentation was in order.
The discussions with QC personnel identified a concern of one of the 0; inspectors. This individual was concerned about certain cable tray modifications where the siderails on the cable tray had been extended.
~he individual was primarily concerned with the engineering justifica-tien for these modifications and whether the supports could handle the additional loads. The NRC inspector made an adjustment in the sample pattern to include areas of the tray that had been modified to extend the siderails.
The NRC inscector identified six areas where the siderails on the cable tray had been extenced. In every case the additions had been acercoriately docum2nted on accroved engineering drawings or design change autnorizations and nad accrocriate design review and document-ati on. The QC inspector will be advised on these inspection findings.
i l
b
(
7 The NRC inspector visually inspected all Class 1E cable trays that had been modified. All of the modifications in this area were accomplished by bolting a 6" piece of 16 gauge galvanized steel to.the existinn 4" siderail. Therefore, the original strength and stiffness of the tray was maintained. The design change reviews for these mcdifications included both electrical and the structural supports. One of the requirements of G&H specification ES-19 and DCA 6.814 is that the static tray load does not exceed 35 pounds per square foot (PSF).
The NRC inspector, after examining the cabl'e ' tray modifications, selected a section of cable tray at points T13GCCM10 and T13GCC111 at the intersection with T13GCCM97 to use as a prime example for cable tray fill. Point T13GCCM10 had 295 cables in it for a total static weight of 21.76 PSF. Point T13GCCM11 had 371 cables in it for a total static weight of 28.67 PSF. Point T13GCCM97 had 247 cables in it for a total static weight of 19.92 PSF. These static weights are within the design limit of 35 PSF. This particular tray section is shown in the pnotographs on the following page.
No violations or deviations were identified in this area of the inspection.
O J
,I f
N 1
a e
f f
l
!9 2 u :.,, I i'.::- A) y t
=
f
<M
}f r.-
=
b y
C. r gdi E
,a w.
1 i
M s
0 _~
,9 r,
s y l..
k
~
2 Q;
o NN ( N b'
e
'N
'4h
i 9
5.
Cable and Cable Seoaration a.
General This section of the report contains infomation regarding the inspection of cables and cable teminations in the Cable Spreading Room and the results of that inspection. Detailed cable identification is contained in the-data sheets of Attachment 1.
Eignty-six cables and 325 terminations were inspected. These cables either originated in or terminated in the Cable Spreading Room. The terminations were distributed among 26 cabinets and cable termination racks. The cables selected were inspected for specific attributes (described below). Criteria for acceptance were contained in FSAR, Section 8.3. IEEE 348 IEEE 420. Electrical Erection Specification 2323-ES-100, Revision 2 (and changes thereto), electrical QC inspection procedures, and specified G&H drawings, b.
Results of Inspection No discrepancies were identified during the inspection of the selected cables / cable - terminations. When apparent problems with acceptance criteria or attributes were identified, they were clarified through discussion with electrical QC inspectors and/or construction personnel. The resolution to an apparent problem was confirmed by appropriate documentation such as Design Change Authorization (DCA). Electrical QC personnel questioned were knowledgeable in their areas.. All documentation and records relevant to the cables selected were available through the record vault in a timely manner and were complete and identifiable to the cables, raceways and cabinets being inspected. Separation of redundant electrical and instrumentation trains was found to meet the acceptance criteria contained in IEEE 384-1974 (draft) and other governing specifications, procedures and drawings.
c.
Attributes predetermined attributes for inspection are identified on the Inspecticn Data Sheet. Tne following paragraphs give a detailed description.of these attributes:
. Cable Tyee Tne tyce of cable used was confirmed by comoarison of the cable to Caole Connection Sign-off Cards and Cable pull Cards. The numcer of conductors and color of cables were specifically verified as part of the inspection.
i l
L
,a e
4 10
. Cable Routing Cable routing verification was limited to ascertaining that the cables entered the appropiate conduit from the temination cabinet / distribution panel and into the correct cable tray as indicated on the Cab'e Pull Card. Additional tracing through the cable trays was not done.
. Separation (Electrical)
Separation criteria for Class IE circuits for CPSES is contained in IEEE 384-1974 (draft). Typical separation details for cables i
and raceways is ' contained in G&H drawing 2323-EI-1702-02. This drawing was based on the Electrical Erection Specification l
2323-ES-100, Section 4.11 " Separation Criteria". Additional criteria for MIS separation is contained on G&H drawing 2323 EI-0602-03. The criteria contained in the above doc:anents were used as basis for examining train separation. Cable termination racks and panels were also inspected for internal separation requirements.
.Craftmanshio Specific note was'made of correctness of craft functions such as appropriate and adequate use of cable
- ties, crimping of connections, correct and clear identification of the cables, bend radius of cables, surface condition of cable, etc.
. Color Codinc Safety related trains are indicated by the color of the outer jacket of the cable as indicated below:
"A" train - orange - 9 Associated "A" train - orange with white stripes "B"
train - green - G Associated "S" train - green with white stripes "C" train-Black - K - non-Q r
Instrument Channel I Red R Instrument Channel II White W Inst-ument Channel III Blue B Instrument Channel IV Yellow Y Cable trays and conduits are marked with unique identification numbers which include a train, or color code, designation. The use of color code assisted in the determination of acceptable secaration achievement. The cables were checked for consistent ano correct color (train) designation.
l 1
l
m
'll
.Teminati ons Inspection of cable teminations included these items to ensure
~
that the cables were consistent with the installation record.
Specifically:
. Cable numbering and marking at termination points.
.All cables teminated to' cable terminal racks and distribution panels in accordance with applicable.
design drawings, Cable Termination Cards and Cable and Raceway Schedule Pull Cards.
.All teminations of conductors were made to correct ter-minal blocks; conductor color and markings were verified.
.0ccumentation Documentation of the cables was reviewed to detemine if the QC inspection record was (a) clearly identified to' the cable involved, (b) legible, (c) corncted, when necessary, by the use of a single line drawn through incorrect entries, (d) completely filled out, dated and signed by authorized QC inspector.
Included in the inspection of related records.were (a) Cable Megger and Continuity Cards and (gin or destination (b; Cable Connection Sign Off Carcs for ori c) Cable Pull Cards. The specific drawing of the interconnection diagram for the indi-vidual termination rack distribution panels was used to check actual cable teminations. Changes to any drawings (0CA's) affecting the selected cables were also examined.
.10 violations or deviations were identified in this area.
i 5.
Heatine, Ventilation and Air' Conditioninc (HVAC)
The NRC,insoectors ins;:ected accroximately one-third of the HVAC duct and succorts. Twenty-four duct succorts and aporoximately 120 feet of duct in the Unit 1 Cable Sorted Roan were inspected in detail l
using FSAR Sectica 9.4 and the accroved design drawings to determine the as-built condition. Attachment 1 contains a detailed listing of succorts and duct inspectac.
The following attributes were utilized during this portion of this
,inspecti on.
Duct Sucoorts Duct Segments 1.
Location 1.
Orientation 2.
Jimensicnal Recuirements 2..
Si:e 3.
Member Si:e 3.
General Ccnfiguration 4.
Weld 1ng 3
.Asso:'.ted Hardware Location 1
I.
12 On six of the twenty-four duct supports the NRC inspectors identified dimensional discrepancies or incorrect member sizes. Similar problems had previously been identified in the CAT inspection report 50-445/83-18, and appropriate enforcement action was taken by Region IV. Corporate Consulting and Development Company, Ltd (CCL) had performed an evaluation of the most highly stressed supports in the Safeguard, Auxiliary, and Control Buildings. The results of this evaluation, documented in CCL report A-579-83, concluded that the duct and supports meet the functional design requirements. The NRC inspectors reviewed this evaluation to determine if the discrepancies identified above and the welding fell within the envelop of this evaluation. By observation the NRC inspectors were confident that the identified discrepancies were within the scope of the CCL evaluation. As a backup, the NRC inspectors asked the licensee to submit the supports for evaluation by CCL. A CCL letter to Bahnson Service Company (Bahnson) of March 25, 1984, documented the requested evaluation and clearly confimed, to the NRC inspectors, that the auct supports were more than adequate as they were installed.
The NRC inspectors also reviewed the Bahnson procedures pertaining to the fabrication, installation, and inspection of the seismic duct and hangers.
The CAT inspection report 50-445/83-18 had identified problems with the adequacy and detail of requirements of these procedures. As a result of the CAT inspections these procedures were revised.
The following is a list of the procedures reviewed:
OCI-CPSES-012, Rev 3. " Surveillance & Inspection of Ancher ' Bolt Installation" QCI-CPSES-014, Rev.1, " Seismic Duct Support Installation Inspection" QCI-CPSES-009, Rev. 2. " Welder Qualification Inspection Procedure" QCI-CPSES-Oll, Rev. 3 " Visual Inspection of Welds" These revised procecures are appropriate and contain sufficient detiil and acteDtance criteria.
No violations or deviations were identified in this area of the Cable coread Room inscectien.
1 l
7.
Fire protection / Detection i
The NRC inspector inspected essentially 100% of the Halen Fire Suppression, the Dry Pipe Pre-action Manual Water Sprinkler Systems, and Fire Detection System and 50% of Penetration Fire Stops in the Unit 1 Cable Scread Room. See Attachment I for additional details.
4 e
v~.-n
j 13 I
The NRC inspector used FSAR Section 9.5 and NRC Branch Technical Position 9.5.1, the Associated G&H Specifications, and the approved design drawings as the acceptance criteria.
FSAR Figure 9.5-39 for Unit 1 Cable Spread Room was not consistent with FSAR Sections 9.5.1.2.3 Item 10 and 9.5.1.3.1 Item 22. Figure 9.5-39 incorrectly states that the primary fire suppression in the Cable Spread Room is an automatic water system and that there are 24 Fire Detectors in the room. Evidently the licensee failed to upda*a i
the table when the.ather two sections of the FSAR were updated. Per the NRC letter of January 24, 1984, transmitting the Staff Supplemental l
Fire Protection Evaluation the staff recognized and approved the use of a Halon 1301 system as primary and a Dry Pipe Manual Water System as the Secondary Suppression System. The licensee is in the process of issuing a revision to the FSAR that will update table 9.5-39.
The NRC inspector found that the Halon and Water Sprinkler Systems and the Fire Detection System were appropriately installed and meet the requirements of the Branch Technical Position.
During the inspection of Penetration Fire Stoos and Fire Doors the NRC inspector identified two areas of concern. The first area concerns three wall penetrations that were not sealed. The NRC inspector inspected 378 wall penetrations and found six that had not been sealed. Three of tnese had been individually identified on Inspected Item Removal Notice i
I (IRN's), however, the other three were not identified. Wall penetrations l
1083, 1084, 1085 were not properly sealed at the time of this inspection.
These particular penetrations had been utili:ed for temporary cables l
and when the temporary cables were moved the penetrations were no.
sealed. The contractor for these seals, Bisco, has an open item, Final Inspection of All Seals in the Cable Spread Room. This inspection will be comolated prior to the testing of the Halon system.
l The second concern pertains to a breach of the frame on Fire Door E-29.
This door has a one inch conduit and a one-half inch instrument tubing through the frame of the door. These two penetrations have not been i
sealed, but were scheduled to be sealed. The concern pertains to the adequacy of the seal to ensure that the three hour ratino of r
tnis door is not jeopardized. Fire Door E-29 has been type tested and qualified by Southwest Research Institute and the penetration seals will need to be qualified or analy:ed to ensure that the three hour qualification is not nullified by the tubing or conduit.
This is an unresolved item pending installation of the three wall I
seals and the cualification/ certification and installation of the seals on door E-29 (8410-01).
r No violations or deviations were ioentified in this area of tne inscection.
i 1
b I
.._..-_,m
,,e
---.,..,,..__.c_..,
_. ~,., _,.,. -.,. -,,.
-.,_..,..y._
m-,.m-.-..
14 8.
Miscellaneous (Closed) Unresolved Item (8323-04) Conduit Raceway and Cable Tray Records CP-QP-15.2 "Startuo/ Turnover QA Activities," (Rev 3,4/16/81) established the general. methods for verification of records pertinent to safety-related structures, systems and camponents.
CP-QP-18.2 " Implementation of the Pemanent Plant Records Management Systems" (Rev 2,10/29/82) described the organization and procedures relating to the implementation of records requirements. This procedure also described the Records Management Manual which was composed of a series of procedures covering topics such as organization, the ARMS (Autanated Record Management System), the processing of ASME QA records, and the inclusion of permanent plant verification records in ARMS.
During the special inspection of the Fuel Building in May-June,1983, the adequacy of control of conduit raceway and cable tray records was questioned. In November of 1983 a comprehensive records verification program was established to define and control installation and verifi-
. cation of QA records. This program included a method for identifying infomation documentation via an required conduit and cable tray (EMS).
" Electrical Management System" All records are verified as complete by a verification group prior to transfer to the Pemanent Plant Records Vault (PPRV). A Paper Flow Group (PFG) has been established to resolve all doc:anent deficiencies.
Based on ene information contained in the above procedures and from discussion with personnel involved in the PPRV, this item is considered closed.
(Closed) Unresolved Item 8323-05 Control of Construction Punchlist.
The " Construction Punchlist" no longer exists at CPSES. All items are now inout into the Master Data Base (MDB). The MOS is a historical file that can output the total file or just open items. The M08 is an administrative tool utilized to monitor the status of ongoing activities.
Tne M08 does not replace or supersede Inscoction Reports, NCRs, or IRNs.
Tne controlling document for tne MCS, crior to turnover is tne "Acministrative Guidelines for the Building Management Organi:ation."
These guidelines provide the controls for item inout/ removal through tne MCB coordinator and the Pacer Flow Grouo coordinator. Procedure CP-SAP-3 is the controlling document for MOS at the time of turnover.
This item is considered closed.
r
.a 15 9.
Unresolved Items Unresolved items are matters about which more infonmation is required in order to ascertain whether the itens'are acceptable or not. There was one new unresolved item identified in paragraph 7 of this report.
(8410-01)
- 10. Summary The Unit 1 Cable Spread Room inspection identified no violations or deviations.~ The one unresolved item concerning the Penetration Fire Stops will be followed uo during a subsequent inspection. Based on 392 inspector-hours, and the sample size in each inspected area, and the results of the inspection, it is the concensus of the NRC inspectors on this team that the Building Manager conceot has provided sufficient controls of craft, OC and documentation for the comaletion of the Unit 1 Cable Scread Room.
- 11. Exit Interview Cn Acril 11, 1984, Mr. J. T. Collins and other members of the RIV staff, including the Resident Inspectors met with f?r. Spence, and members of his staff and others as denoted in paragraph 1 of this report. The NRC inspectors discussed the findings of this report. The licensee acknowledged the unresolved item discussed above.
h e
S
ATTACHMENT 1 INSPECTION DATA SHEETS FOR UNIT 1 CABLE SPREAD ROOF (RM - 133)
NRC I.R. 50-455/84-10 t
t 59 l R1 RACEWAY INSPECTION DATA SHEET ROC 14:
thm Sposan be [b JM)
DATE: 4 -t - 2 4 RACEWAY NUMSER/ TYPE (Tray, C:-da)
T13 r,cc m S cerreus of rnen 1i; T14r r DM Sne mus 4n ruan 43)'
TI%r,Cr yYi %e rrnn < 4 6 w =u 49,* T~1R C,rr W1 SverrM < d 9 rMon 13,*
T14r P nH Lexim1s 14 %o u 19,' TIR 42 l'e Q S ce scu s 2 8 ra o n 28)'
TIM en (3 ' Reerreu< f (o w o n 2/ 5 60 ' TidG PD S.) See-rears 01 rggg. ]q i
j ATTRIBUTES Type & Size Identification Documentation (Installation Tray Covers Fill Factor
& Inspection)
Grounding Supports Connections Craftsmanship Separation (Physical / Electrical)
ACCEPTANCE CRITERIA i
FSAR Section 8.3 R.G.
7.76 IEEE 384 Spect fication ES-1.co Es-79 Procedure o T-c A-o. 3 2d erop-ff,3.g; Q F GP-il.,5-4clG.Z-G P-II.,5 -Sc RESULTS:
Q u.
n e ru r a m>>n.
ren v ser, rmis (Rm A nn e.- er rurr> _v s
Ann %C A u+r3A 79n MnDGngf$
IW L r u m_A9 $ 9 9_r D C A R Ks e TE R V, susrm e s n su ner e p nma ne r ups u '$-Rin (12 3 < n coenzs) u3 c e =
non ru r soow~rtn me<v.a me >msnrs; Ave hw n rrrsw rpm av r uw - rma n mrs. n marxs,. -. n e, n so n-n ecun us.zrrus.
RESOLUTION:
M/4
/
INSP. RPT. NO:.
,8 4 -10 PAGE NO: Arr I-1 INSPECTOR: D1o erw OsE2G l
-__,,-.n.-
58.2 R1 RACEWAY INSPECTION DATA SHEET RCCH: _0 ano e Roerno Reem f Rm IM)
DATE:
4 R d.
RACEWAY NUMBER / TYPE (Tray, ~ d_it)
T 1*%C00 M Ree-romus 34 r>o o u 45, A 2 l M,* T24p (' DJ f werreus 3n, M, 32, f 4 4 Tuo n 49-Puv ra scarve n I S <: er-rrno n c una m_au 4 G nws reAv, war wn unr JUrs irm a n1 3An10t p C,1 E M_
ATTRIBUTES Tyoe & Size Identification Documentation (Installation Tray Covers Fill Factor
& Inspection)
-Grounding Supports Connections Craftsmanship Separation (Physical / Electrical)
ACCEPTANCE CRITERIA FSAR Section 8.3 R.G.
1.'75 IEEE 384 Specification _R-1MD. ES-79 Procedure _ ser crur. <;w as y RESULTS:
u3soe nn rns t e n vn t u ei r m t: A s ci mica ac -tray -
T4 A T Man sins Entr-rneco cre A rreds. S f s anrusirn rn r rn rLS MD2 9 312 C T'n A $ r2 C %ffhL1 Tr4 # r A2.C32 m>> r/ Als Dr$022$$10k}S 11*)? TA A b b f t f AP W To /2. -
l RESOLUTICN:
Al/4 INSP. RPT. NO:
84-10 PAGE NO: Ar7 I -2.
INSPECTOR: Ma p_ria CBJE.E.G l
~
l sn. 3 INSPECT:CN DATA CONTINUATION SHEET
!NSPECTICN ELEMENT
- 0 4 5<2 Spes an Aarn ( Em sa w
- 1. S n.evooes Mur'n - O T -M O-11. f o - 1, ni-n D -II. rn -2, DT-O P-II. lo-5 2, S t. nnppent e<vtf oc ru c s~,v t n e'3]Dn: ~'b p man vA LD c o c u vrr,2 c n T c resome_r THp
.s Ami r 7env Ann p< w inrfb sucee m :
2323-El-6712-or 232 %. _<- 9 /t.
P.M Fr, as ?w u 5 2M23-f1-o7/2-02 2 %p %-n-917 2n? n-W 1 -o77p -e4 2 993-5-921 232?- E1-n712-11 2 52 m - s-922 252R-E1-nytp.13 zum - E1 -1781 2323-Ei -07/2-IP_
.1_*2 9-F 1 -1702 2.323. F 4 ~8712 -14 2_%2 m-51 -1702-61 2523-F 4 -67/2-1.6" nm2%-F 4-17ap-op 2 52 E-E1 -e712-niS 2.329 17n3 2328-74-8719-o23 2328-21-1765 i
2.323-F1- 0715 2323-E 1.- 1413 2 32 R-P 2 - 67]S-61 23 2 7-E t - 12tn A sur.s s _s 2328-S - 901 PS E - 19n
.l 2322 902 PER-191 2323- $ - 903 F:5 E-214 23?R 91 S F5 E-IS9 spew _s INSP. RPT. NO: 2 9 -Fo PAGE: Mrrl-5 INSPECTOR:
M m in C i r. z G, 0
--.-w
'=v
-c='-*"
'~
Sv.1 gi RACEWAY INSPECTION DATA SHEET
(
RCCH:
fxms Sysrxn Ae lEm 133 )
DATE:
R-30.g4 i
)
RACEWAY NUMEER/ TYPE ( %, Conduit) 0/4A/12/7, M14M t f 2 /A, 0/4P1128 R, 214 2 99 209, 214 2 199 0 de, r/2G14231 e13Go 7M9, e /4 n 11214, 't* > 2,$ 14 4 k M A)4,0126 9 *42
.o e13 d> n %12 e/2 a ou?3 t'1Ar,n 5414 t"/2011544 2 GWA /S74f)/
/
s s
4
/
4
/
0)MP 141142 (12 M al. 4s 7, c1 *A A 14 7a 7 (sppen pgasti,, 8/4 g 0 7eSg ATTRIBUTES Type & Size Identification Documentation (Installation
- . C
- :: :
" ' " "= ; r
& Inspection)
Grounding Supports Connections Craftsmanship Separation (Physical / Electrical)
ACCEPTANCE CRITERIA FSAR Section 8.3 R.G.
/. 7S IEEE 384 Specification ES-JDO Procedure GI-op-//A ~23 CZ-Q P-//. S ~ ;
QZ-Q P-//, /4-1 RESULT 5:
Au_
f.sn sssnd njo n s:
-m A Manwy wspre rrn
& s A s w w r/n h j P A es r_s Asss ssMn'sa ss mnwg 2/>> N 3-9/o A>-i.assix<
san rez ssssasmssz ~xas
~12PMin,M w issyfA dv/ D D M / M As*f d P J_A C PJ A' nJsFM &2 11#D//M 13J 7M~ str MMLnjr.s de,p'rpp Ndf/PAf=f RE5C'.UTION :
M/4 t
INSP. RPT. NO:
84-/D PAGE NO: Ary _f-7' INSPECTOR: 3": u oe-o hye.rra O
9 l
l l
t Sd. 2 R1 RACEWAY INSPECTION DATA SHEET ROOM:
Anwrfppson Poam /Em 733)
DATE:
3-Jo-X4 RACEVAY NUMBER / TYPE ( M f, Conduit) 01261R54S 213 0$ 1M M 7, el T M 19/49, F/ A &lA 799 d/2d O603)
/
01362/2 T9, 013GD4/229, d)_9& D R A nR, 2/2ef2sj79 effdtif//ff f /2d d2/192 A Q 3A*//_EJM, YOY$ AL V4h, 8A2b OIVIT $lSA/9'f$f A03&oM 7D Pn A M</AT, A12415~2/9, 0/ 4 G I $ 793, A/Adf/6/2 l
ATTRIBUTES I
l Type & Size Identification Documentation (Installation T-3, E: : :
T
~ :t:r
& Inspection)
Grounding Supports Connections Craftsmanship Separation (Physical / Electrical)
ACCEPTANCE CRITERIA FSAR Section 8,3 R.G.
1.73 ICE 384 scecificat1on _kS-100 Procedure CI-QP-fl ~ :3, DT-cP-)),3 R Q
RESULTS:
d M f/4 P/) ACE / J 9 d /4/45W
- Z-Q P-//. /O-t
/
Ad2d>J922 MAA
/
/
/
wune"scrwnad //ss-m jijssss rassnsrw Am 177#DJ 7 J" m L 4 1 )*// W // W M AM TMAr JAds;#Prj~d ArAcAF
$ssi.S h m iss m m s2ss s As-m -rA's Arm Dabs /s/ Y Ad%:-//Mrs>r/A sA/ As>A sjsrsprb) Lwm, 9.ESCLUTION:
Al/4
/
i INSP. RPT. NO: 3 4-10 PAGE NO: #/rf-f INSPECTOR: osse Mlpwst
~ % usca i
(
l S n.3 R1 l
RACEWAY INSFECTION DATA SHEET
~
ROOM:
041sts d pp enry b m [9ml93}
DATE:
3-Mo-84 RACEWAY NUMSER/ TYPE (Tray, Conduit)
(12 $a 70 73, C O26119 A 2 C l3 G14 L 5 4, C l2 G I 9 tM t.
C l2 G 196 / 2, 012GO 79 0 7, el2 GI 3 3 R Q n12 G II 442, 012 M n L9 4 A, M O2GO'7468 -
-ATTRIBUTES Type & Size Identification Documentation (Installation Tray Covt-s Fill Factor
& Inspection)
Grounding Supports Connections Craftsmanship Separation (Physical / Electrical)
ACCEDTANCE CRITERIA FSAR Section 8.3 R.G.
1.74 IEEE 384 Specification 1:5. rad Procedure rJr.co.it 3.pA cr.co.f;,3.yo, QZ GP-)t.10 I RESULTS:
RESCLUTION:
M/)Q
/
IMSP. RPT. NO: R4-)O PAGE NO: #rrl-4 INSPECTOR: os,,4 Jcnuson mawa
)
R1 CABLES / CABLING INSPECTION DATA SHEET
- Roca: 01AGeA-
&^: --
Date:
Slo t - HlIe { t9 7V CABLE IDENTIFICATION:
.: M -J J m
/L.C M - L -- 4 d h a.tw w = w D
- - _ x a, J a & & w a ik,,.= L l
p s
g h h _---- w ATTRIBUTES ss s #-
Cable Type ColorCode(Train / Channel)(4,3,I,3.)
-Routing Terminations Separation (Physical / Electrical)
~'"
I....
Craftsmanship Documentation (
- xi.....'
Inspection)
ACCEPTANCE CRITERIA
~
FSAR, Section 8.3
- e-0;-S/-l'.*
IEEE 384, 420, 4iit-c::.o p-/t. 'l a6 Specifications E f -/#o Procedures c
.on.,, t -17 RESULTS:
2 6 fA W 3 ; 5 "Gvw * - 3 %2 YJa$12. A-
.A & n.Jw L A & M S '22 m J / - cL -L efK wk
%&m-*>
2 6 6. z at M'-- &.32 a e,4 RESCLUTION:
M. 4.
INSP. RPI. NO: 50 Wl'/?F/C PAGE NO: //7.f-/ INSPECTCR: d GC.0< C
(!
INSPECTION OATA CONTINUATION SHEET INSPECTION ELEMENT: Of]1).L. [# AL ALw l
- hM MA K* W _?g 40 l$
W d.-
& 1A.,_>>- 0 s-D,,-x= jak g M,* - 3 e:Q C c.bl.. 5
- 1L A ':!
~ 0. P X E C P A TC C I 2 0017 9'/ f
.S~
B 6 e.'s* 7 / 7
/2 3*c AA A60/r70 4 4
JV 7% #1 of0/r74/
4 4 / d e.r4 7V
$~
00 ?S8. Em! - d P / E r P2T*C0 2.-
3G /31117
-7 5 4./.7920 7 2
E c. 12.3 4 1(-
7
- 6. C- ! / 2
- 1 7 c"
E. c
/ 2 7 v r 3 5
EC- (3 9 2. I 7 3
i.1 ed EG-l15 4 3 *i
.T" 44 L_ *.'7K EG t L'1 C ty 5
6 G I 3 2 to 7 [
S~~
RC-i: 1Cf3 2
L C-CM 312 2
EG IC'l1IC 7
INSP. RPT. NO: foiWNV/o PAGE: #fff-f INSPECTOR:
- d. 8.8de G
l
Al g
INSPECTION DATA CONTINUATION SHEET
-INSPECTION ELEMENT:
[a.,4 de.
AdL pm.
4 b=22 All2 :Lk QJ. $kt a ch?5 c o 2 L
Ec:. sos-cv.~
l 3<A Ec 01147 YM
/
3 W;- 4%
e G. 2.o r S W I
fa.46 G- *--=% Aud C.P x E c? RT c. o t '
A G-o s CG 70 pG C/r1/4
- )
C' e 1 &=
A-C. O si' 7 3 C
~7 2/ MK A G off" 7YY
/>
E G. I 11 L 'l9
/%
(QA Qw A - fAS)
M_1L Phle.
C P i s c P t.T c o y G C t :1 Tf /
7 6d /3 f ff 3 4
1
.E 6 $ 131 f Y 5
6 E6I IL Lof L
3 W=' -fM E 6 / 3 9 f f's 1
S.#/0f77f f
i INSP. RPT. NO: 60-Wr/#WO PAGE: g n I-f INSPECTOR:
0 2 6b.
Q
^ QL w,+
jw & wA i L r'<- '%
M, $
h q W L W T ! Cs M l
i w- - +
,_,--,,.--3 g-n
-,-+-
a,--,-,,-w--
s t
- l g INSPECTION DATA CONTINUATION SHEET INSPECTION ELEMENT
0$s $w'dA $d ~ G P / EC P e rc O S~
EG 111.7.4 7
/ z,.
E C-I CY C' 3 2 3
5' e'Mr E. 6- / I 3 91 3 2.
wss~
5 G//3406 9
6 G / ? 4 37 9
/2
((P 4 Cr - m i M)
(Ws Nm' xL Na 1 - C P /Ed.P ATC 07 E O 107T 16
'h 66Il996L-9 Y GN' -
~
Em 1a 3 4Q0 5
- / "M EOI23 Sit Y
Anlb. TMs.Ch 2d - C.Pl 5CP2.Tc 0?
E G0!s~9 ??
S' E & C I f 2.\\ f
.?.
f* gg.//s E G/2.7 t, L /
5
/~/ &
-_h E G /234a7 S*
E G-h 9 io$
1'1. ([~P/NdcNacW G A2L L)
INSP. RPT. NO:d'O-WI[fV/O PAGE: frrf,#
INSPECTOR:
. O. [b[
O
r d'/
INSPECTION DATA CONTINUATION SHEET INSPECTICN ELEMENT:
[ add, ca.Z4E, b) h k
- di / ECf,tt. 7"C. / O Td121731 7
3cnM.
Eei1IT33 7
/*/$ =l-27%
E 6 / 4 0 V 05-f
/w Coupe e4 6c.:41 61./s.
L Ad - d P/ECPai~c //
G t:Ivr2 9 9 7
6 G-/1 l 9Y7 5
3.ist/h__-
E Gi3 ?S'9/
3.
9W
$ = W h kae
.5 0 /3?/W 3
.2&
2 8 /$/99/
R
,$" $ n s f_k Yb $#k4~
ku
- dP/ECP2.it' /t/
5 c:. to ~ 4 99 2.
S~M K G-! Lt9 9t/
[
7&nAhu INSPECTOR:
d M. 82ste INSP. RPT. NO:fd*Wl'//(//P. PAGE: #n/-//
V
.m_
m
.a.-..-
.=
.=.
4 El INSPECTION OATA CONTINUATION SHEET INSPECTION ELEMENT:
[# d d J u b E.e. [_^c-w g2P
'I n' W -),- /' p/ E C P 24. \\/ /G Ed 130596, C
3.c!? A 5 0 / v 4, 2.V 7 Q
/3 22_n-> - %,
Ed /Y437/
9
- h W
E e t 2 17 Y3~
9 A C 4.l $4 V
Edi4 0 29 4 2
( 7/Al GtWMic rca dM L&f E c.- t.1 v.,s 3 4
PW l
f* $?$0.ChkCR l8 Ed 13/c Ca
.2
/&
y 04 E+a% Pd d!!EcwcR
& & /3 /09/
A
/ Cedh 1
- Ll-Fr INSP. RPT. NO: O '"YVI f V/C PAGE: #771-/4 INSPECTOR: d
. [bs _
i l
I
[
e
- 1 g.
INSPECTION DATA CONTINUATION SHEET INSPECTION ELEMENT:
I
- AIE, N
AJA $M
- ~ A. -GPtECPRTC 20 E G IIEl es*
7 J' MA -
E G-/07//s S~
/2 M h~
E G-13 t'ic5
/1
( P/n coassacn eneisJ 56-139966
/2 (7/M CONNacrad. dn245)
'EG-/3?967 I.T
(?/d Cowwac ret 2.
d A-24.E) q.
b4b $=='=xbA ka.s.d - CP/ G CTR 7"C 2 '2 -
- -}
A 090/703 S~
3.
Q e ' D'- -
A C n os/43 2
4'W (MA S m a ge_ & /? J___ - d P/ RCP2 TC 2. 3
~~
A G 0/4.2 0/
Q d & 6 A G. /30 4G4
- 1 Y.L
- s%
E2P /J07 8A2 2. (TR~d) - CPI E CP RC2.2 V E G /u dos o A.
/'&
2 Yx INSP. RPT. NO: Co-Wa~/f9/o PAGE: /rrf-d INSPECTOR:
d $,[b-V l
\\
L
- 1 INSPECTION DATA CONTINUATION SHEET INSPECTION ELEMENT:
W2 suh//M, A*
$ $ & sT4. Ar-L 5P/Ect*/?rc Q.6 l
5eic4,645 2
/ de Als
- 1. E m'-_76 5$ i 3 8 G 3 2.
/ 2.
(Pm coaus crvA. cs2rss]
M $&& *- IEv4 - dP/ECP ALT *C 7
E G // 9.12 y 9
/ W1
.: t 9WK
~
._y.
'30 P p ut bl
_ Pn J // - C PIECPlt ca. 3 ~3 E C- /2T P'2. /
2
/ ah n Y&ir M, %ds hd - C.P/ ECf R Tc, 4/
E d II9ct r,4 Q
1 n A /1 E-C / / d 7f 7 1
6 E C / / 2 47f a
INSP.RPT.NO:(CVMTV/6 PAGE:/n1-/f' INSPECTOR: 6. O.Mu4 d V
e 4
t kl
~
G INSPECTION DATA CONTINUATION SHEET
{
>> /M b INSPECTION ELEMENT:
$)& $misL Paek - GPI ECPt.T~c Y2.
E &ll 914' 9 Y
C GotrrM
.t 8&Mr nG nir 717
.t I A WL _M_%
EGot7e;]
2-EGit/1/3 A
T ar
_=
- 5
~.
1 s
INSP. RPT. NO:ES-WMff/o PAGE: #rrl/S INSPECT 0P.:
- 8. M. M-g o
l t
- e w
w
.-s, y,-y w,w-yy,wy-y
-m.--g-,-----y-r e--.w---
,,-----<-.--,,--.-9-,-u+-.,w
6 R1 INSPECTION DATA CONTINUATION SHEET INSPECTION ELEMENT: bM bs_2h
-h d W
A/ A s_d."
C.P. Q P II. 3 I?- A. ?/NNT h*?1Ala$ A =m?4 M PN-II 3/6/ fV W ZE & bt M-CP -CG - II.1 - 2.3 11di C G-CP-il, 3 -2 6 I - -20 3h9//>C OdP WbW
?
i
- -(
.o _ -,MA Cr OP-!!. 3-27 P- = -3. 0 Mrlft/ ($== ZE W $ rS: WL S_.
6 - CP-II.5-2A b ~- I t
'll 7l? 4 QM G T - O P - li. T - 1 9. \\
k s t~ L)I1l TV VN- [O' A>' d ? "91= ?A e.
G N
O e
e e
INSP. RPT. NO:
- 4/d PAGE: #rr/-gINSPECTCR:
thw_
4 8
.~.
p i
El INSPECTION DATA CONTINUATION $HEET
- - - - - INSPECTION ELEMENT:
.[ h - > $fd W A L & A */AA Y._ i % K ).
n.
e a
h $ 1-u
_u- % /
C.
i I
l L
=.
i 0
.=-
i i
r l
INSP. RPT. NO: 80-W//F/a PAGE: A y/ W INSPECTOR:
d8S M NJ l
=
l h
HVAC INSPECTION DATA SHEET Room:
I.. U, ; Tc., C - :,,,,. 4 Q --.- -
DATE:
E 2.C--64 s..-.s -r L._
c,r A M..rb AREA (s) EXAMINED:
u vL /*
no nN
-r v
AT RIBUTES,'
E::uipment (Du::s, Camcers, Supports)
!=:ncr;='r '. :... A. (Separation & Craftsmanship) i Occumentation (Installation & Inspection)
ACCEPTANCE CRITERIA
- FSAR Sce.ru,, 9.9 R.G.
5:e'cifications G *- W Procecure RESULTS:
de e,
--, e l e r.
c,;,. ~, 1 a-A eh, ee Jer\\
wer.h C-er eie.<,n Eu L 4 ;-s e e, h.
a
). e w oedobd A b d
q
\\ 'l
- -v. -. \\1 s
L,.t e
_ e.,.
i e--
e-s a
b f d.. - 4.-
!.. h.,..,.- b e.
Id -
k se
.e - r-c i m.*
s ~.. A ec *m,
i d,-:k..Les el. _:. 4 t-e
. k e,
u7 _
J. --. e d e <-
aj e 1
M,. h e m -, k f-J I r. -
e C
'4.
t' \\/ /
+
RESat.u icN:., A 4,\\.
V t: L )
'm '\\
n 9...,
A...L
,, - L.
C u.. l
- u., b_
i 3r. s.-..t.-%-
i-_.g.
2
-0..- -- : - -e\\ e C ec e \\ s 2
C.,./'--- -. M s
- o. r M r,,,e d ',,,,.b'.
E --, d - -
1.
' l ek k.,.l...,,rc e
..\\L 4.
.., e -
1 -. - - )
s
- NS?. RFT. NC:
- 9-/4 PAGE NC: #rr //e7 INSPECTCR:
-~7u' am-v 8?hoXR/
e
-e m
m--
--e,
.-m
-4
--,-.----y,ww--g-yy3 -y m---gay 9-gw-gw--gm-g wm 9 9 --
e.
INS?ECTION CATA CONTINUATICN SHEET 4 b..m s
i
.Ns m--.0N
,:.,. NT:
c_, <
-a
. ~ -... -.. ~,
_.,..m_,
.,-._7 - 1.,..\\
._j:e..l..)
, l i s e e,. -.., ~., _
'7"o -.3..-.l g. k
. -,, %,. N
,. \\ \\. -
M,.
L,1 : -,. L,1
,A - m :-o,,
e.
)
.._._ \\
,a v,.
n t.,,. t
.tk L...,,
e,A.
.-E 1.
i
,-..,..: - A We A vec.,
u
=_
,ud h
.-:l:C.r:.~_;s ebvneA \\ e J-L.
- 4
-n.,--
.me-..
a
--.,, L,-
M et.
m,.
4 mo l
6.
, L-1
..., -,,i,s
& cl
\\
..A.. -.,, e -- m.-,..
g ef. _ -,. - _.
5
%.e
,,.l.
m,
..c.,,
..s 6
m.
i._...
ur,
1,. k1. m n,. L.
C e,-,,-.1, C,
<m.1 L : -,
N vi..... -. \\-
C. c e..
, 3 u,w (cc.L
- 4 - el e-
- .,%1.'.. s
? 4.\\.,:,,~., e. k. k. k \\.s.,) ~..
k <... s
- .2
,, L,i h :',ld.~.
d.., c,. f.. - A L.a,\\ : c.,,., ?.._,; l l : v.
, _,s v,
/
-.8
,s\\,2\\.
2
,\\ -,
b.,. m..
f 4 L c_ i
--C.
(~.
.\\.
. ', J.
m \\A d.,.,.
,.i.,.c,.
u.,,,
..v,. s
- s. m e., < c,. A t
,r-e 0,. - ob u._
iw.\\.. g.
e
.t n_
e-
-e e-
.. :. \\ h L r..
o e \\ >,\\
.L'\\. N
'. :. & w ~ AL
\\
c
-.... l....
_. '.dg e e r
.:: d r
s i
I i we
. e.... -,
.,,L. c s s a.\\e ed e_j T-sre c
., \\ r
- s
_s L
g il
- m
_a-,,4 2e
--s s' > e m - - - re-c.--
-- e.! I - u~
1
.)
I e
1 I
.'.d
'^
4bc C,'" L.
euc.!v N. -
_ e. -., t e
i 1
INSP. RPT. NO: /6/#
PAGE: 47f-/9 INSPECTOR:
Sws WMw 1
I i
j
~
v i
4 HVAC INSPECTICN DATA SHEET Room: OaLIs I'.... e, -_.,,,5 "Q.,,w DATE: _S.M - 6 A.
i AREA (s) EXAMINED:
av v,
e, A s. 1-
.c, _> m... L.
cmA N
O O_
- P
,9f_
- S-4, /. M O O s
a 1
ATTRIEUTES,'
Equipment (Ducts, Campers, Supports)
Instrumentation & Controls (Separation & Craftsmanship)
Occumentation (Installation & Inspection)
ACCEPTANCE CRITERIA
- FSAR Dwisar 9.'/
R.G.
5pectfications wie.es Pracecure i
rev RESULTS:
4vK G 4. n-,, _ E j el. c., --.n-c.k
?
C G-9.o7-1dA 3
rsv o ewt cew 1
. C ^ - 8 0'7 - t u A =
/ 8 - c o 7 t C.
C A-no 7-s u-t A rse o' rse t e en a C f6 - c c 7 - t M - t A A.
C, E - c.c 7 - (.
- I M - A t-C.m cio -< - tM-4C.3 t e= o en.w \\
v.aw e 0 8-ec 7 - u -i 4 - nv C. As - ac r - i e - 11,
. e D., - Go 1 - Co - 1 N - 1 t,,.
eav o esw 2.
rev i e r- -se, -, e - c_ s e s- - cc, -, y -, a C B-se7.i4-T:'A A em L re, t -
ens L CA-ee
-~-.o
- c. e _ %, - w - e c. t_ - t c, o c.-, _, o _ i cew o ce~ o cew a Cf5-onr
,w-c.G c rS - c-e 3 7 - i y - A rs em-e.sr r_
,c_ax
'cew a
'm o o'
6: c,w
- e. e- - i u -t x C 6 - G c T - i M - o S e B -cc,.y-<. - i u -E.
/
o een o c m - c.rwe - i w-i e r m -ecr-iN-si:
' 4-to FAGE NO: #rr f-s INSPECTCR:
3 -.uu wa INSP. RPT. NO:
2
>1ne.rso
INS?ECTION CATA CCNTINUATION SHEET INSFECTICN ELEMENT l
14 VAL Ave $
s,.nmenk -
d $ o skem GMO/s OLvr A
T&
L
- i. i ss AL..mk
& T :Ji-A7 a
D4 de e thb / t U Av c 3
s t. 7_ % 4 fi L.
a
- e bN ! b ti AV%
b d 4a E 7-1 1
1 INSP. RPT. NO:
8 4-70 PAGE: fyrf-// IN5?ECTCR:
L-,.o n{nena i
e i
t I
i
--r-w y
g g
-w-n--
--wew a-mee ry-e-7w--* - -
e-wr---F' e-a--'99-*
f =
rc va-MBr+w"w*Nw"W-
([76.J FIRE 2ROTECTICN INSPECTICN DATA SHEET RCCM:
Ca.<, g Spwo 4-C/~,
/
CATE:
74 V
AREA (s) EXAMINED:
/ !- s t o u A~, ie-t.-
$~~ / /x-c rrio ~'
C v.trE*1 ATTRIBUTES :(Preper Installation)
- .;...... r i ru 5. o -
~' e S-ec 'en G_iFe SuceressicQ...
___s c'r: Er'-dact
.. _.. _ _ _ _ _ _........,a s............u
_...uf ACCEPTANCE CRITERIA; W ^lA,t,,y F5A'R R.G..
$.7'f.9 f Scecification 2 T 2 3 - M f-IF&
' =.
.% A='f*/4-12 A-RE5 ULT 5:
T"f g fx.,nr a
,e
- , u 74 ps_s_syy,o,
.s v;rs y 5 9 st-YAn* ! 'f" l
( M L 1.
$o 's e AAFJ
-A.
O O oLar
!1 Ab-s n
.I k A.5'&f L
!.J.s. c. o n.
/ 7o /
1.
, r., n x,,,_
r,,.,w a, r.,+
i l
p C re. n i2 w av i.% - r s. n r > a O n r e e r2 A v i w ia css ar.t
~
1 sA ~
L o s"-- o c.
DC r.'S r"cm i1
/rr oisoao o"
0,, e e.
E. V r 1 f 5*' --S C-6 S/ 7 f Y'-o ~7 A'r/72P-V/4
/
C 9-! 7 r r' ~ *1
~
A-m.1 i rrse uxn
,7v 4-se '~~s a t Y/_ _4 l*
I' r n C 9 A.* w c.-7~so ~,o
~3 'yr r~fm f.
e v.1-7"E m
&41 4 *.*
- L o e 4.-rs o A #
- rs T-7n rr.r r
A-s,<
fros.s.rms a 74 r f'x~-c-r~rs--
A~o d.cs.e t~ e m + ~ a., & c is c rn mo.,~ -
A b[/ b / IY.
6.' f'
/*# ee.9 a f p.,*= / Psd L 4.88 A. f O g Sr 4 sm-sc 0.
IN53 RPT. NO.
- $/S PAGE NO.
INSPECTOR: 7 v/v,by/
4 y%..
o r.-_, -
9p-
--we--..---
'te--w
- awt'TwsvN
- -*me e-
- ""W"'N"N-"**'***C-
" "-"-"^-
i I
c p,yg,.,5 FIRE PROTECTIcN INS 7ECTICN OATA SHEET RCCM: C s.st _c
$~/se s, u w e b as,
v f or r /
DATE:
Sk.c / y AREA (s) EXAMINED:
Px v-p/pr
/c s - es c 7 / o,v
./ i. :f4 m a 4. /
/
.J A. rcA.'
f ss ! ~x. t. r, c.
S v r r-w A URIBUTES,'(Pro:er Installation) 2e et st':- : h;n
.~.. ~... n i ; r 6 ire Su: cross 1@
fr: C it'a;r-C,;..x : n i s G..... '....wa s inspew.s )
ACCE TANCE CRI G IA;
- 9. r d 9 [ /' 4 F5XR kyp m
/'-
l, Nf R.G.
7 7 S /vf f-W 5pecifica ica 1
RESULT 5:
l$ww
/
. i n-.e f as /An strio -
ir
/,4.
- nip 40 W r 'r"7h
'7~~L.**
O.e. Y /s /8 s/A:.c -A e.r>c u.
mis-m s-c v e -<n-ras.r u ;c <. c n 7.yj7-1 9L
. r-L a.
r vi es -,
M f
M
$" V <* WM
/$
s " $?~.e.LL d'a M ~ C & t") CA -C O TL L
.*% st C.-
/ sm.- 5 /C e r~.* 4 p i re a rr e />
i%
sG-T j
- d. t/ L4' S 4 MA-r t ****;
- /-
=rA fC" L-r C 4nf FC rt,. s.
/ 4 c.7~
i 7"T.-A *~
T2 s t 9.,, r r~ss-w
//
/4,'. 4 fc.r rt.
- v~
r2 4 9 e A ! / 4~t9 s os.--
4"~A. C f~~$Af /Z.
+f se.s -
A a rr==*,s.fsc s
~~ r - / / f G
< /At Iss - te.< C st-S 't / 1'~b"'s 1 A- ~ r">
o
- s. J s>
~
/ <*- F e A-M $.O
'7"LA. '1"-
'i~ $.,. e f rf d f,,.,.4 ee at M c,.7J.rs7 ry "T"2 g=
,,~-; g r-f-j~/>17.
x :c y i $~/ o s.
~NSP. RPT. NC.
96/4 PAGE NO.
13S?ECTCR: 2 W
4 d
i
f.3.. ' '.
c'ff6 8 FIRE PROTECTICN INSPECTICN DATA SHEET RCCM:
C4.st c k<.sso ~c s,-.
- tJ~ w /
OATE:
Jktb es AREA (s) EXAMINED:
/:
, 4 e-De er e en v AT RIBUTES,'(Proper Installation)
' : : -- - * -- ' -- S t - s C:f re Detectf U3
--- ;;;w m..
.......e
____*9.
4..
t s.....-.-_-
f.,,.,+4eni ACCEPTANCE CRITERIA,'
- 33g e_--n R.G.
.s f 9. )~- l Scecifica:1on I 7 2 "T - E S / >g famoeeewre RESULT 5:
Pes c o e r-s e ri eu r5 d'x-r - i o e o 11 !
! *~.1 1 /> - > > ~
na eL 94-rt e va n1 m
i -> rz L-t.s a s* cA-4~.1 ** ir r ni,
/214. e p,c.
2.3 2.7 - E /- La11
- f f e,< C lY
__ /
2-fS.
Tl.24E' D L 7"5 c.N st J
,H-r *.*f'Ch ov e,e o e r
- 1. s~ c we., e,
7>
u o c.
w u.o n - - n ms, A._
A # as. p 2"E A.L Ana. **9 m
=r* l o.".:*_
ALn rW =r.s.-d's&
J.L-s2 d o a.-*
$"=t l/4 Ar ?/ r o ~'
T '-r / 7"4s,=*t.
"Y~~$ *ar 0,,* C.
f r6.o
,,-1 IS' M
0 S :~f c T'~o oe T
~
4'L 4.
os c-
/ A S r!C e rest.
f f 4.-a 74 0 2J ns r-x eers ?
, < r a, s. r co x r-r n.,c
> a,c.,r.e o e, en/7, r ;
,.&-M 0
/J C r C./J. 7'J.
RL sm-d C.
,,s.r 9 4 eJ-":r-n.
st e 7 g p 7' p
/>-
c.
C fi os== f 4 4*
' tE'.4 /ssd* 14 +M T o *#4
'YT.- ss. r 74 6 1""21.4 Ld.
J**
Y f&
f$h INSP. RPT. NO.
/%/a PAGE NO.
INS.:ECTCR:M' YMdy o a r,,,, s, n e.,. m.
7z.a u, e s~, a i~ e~ '- i=-c ge,4us
,ir 9.~ c r1.c
,s.coisn-n Per'c-<-m r I
d [of kf[ *
- E*,-'88.dM CeP.# FI'd M e. C aI.$ -Y N
,,.-- ru m
psu r, si.s nuo sa a ogss j
& f*
/f-$ Vs f/.? W =
y e
. f 'ff'f FIRE PROTECTICN INSPECTICN CATA SHEET Oj p U RCCM:
[A.dL e fpH20s
- s. A's om - L/~, r- / -Ese Me.tDATE:
9 AY AREA (s) EXAMINED:
l'E.n E y a y/c M i~o,r t f.~.1/ J G 1L /
c,~ w o -
I'> f &
d Hv4 c.
D., e e s 1 n c 7x..s r i> ~.r 1-L < m
- ! re e-. ' s a.o 7 ida rfn 4,e i cs. -
Mrst o om
/
ATTR IBUTE5,'( P ro p e r In sta l l a t i on )
b: tien F F' e C ect':M r.____..__
s..............
ACCE37ANCE CRITERIA.*
F5A'R W N/A R.G. '
O.7-#
- /. 3/
d'^ "
5cecifica:1en vs. t 717-Mf-Jff Precadure RE5Ul.T5:
C.uc c e o~owsr-PI pg wp
/.J VA c. p.,ae r ps erey,o n.s
!rr~rie rs eu
?i ee o O vs 4 E / - c. e) 7 - / y 7 L 22 /, ::,,,..,.7f r
F c -r0 7 hs73
~
m ecrr i m.e 2 no & & - ro ?- 1J u A-s,. ees s
~w 7
I90
~
ax r o <>
s#e.~ r7 u no ~1 r ~r see e aco e sa 7-f/ X
- A
- 7 4 h a r /).c.
7~R, r
~,
i,.S t e AT. r_ f a
/ e
(_ e.., o E>
dillummusaitr' 7 - L a.
it..a. n n
- c., s. e s o a ss.],
fr e,, w ut so~* **r*
s e m.-u rr ons ca.= s ~ o wr r s n., e o :
m"*'=*"*"~:
/3 J' 7 / Dr't r ol'D c.sr I c o r 2.
n rD J~2
"4 f.
=, c <, n c
- o. o
~<
, ~,,., ~,. ~
n-~
~.,,,c,,,~
p* pr~GerJT"
? z.+c c 7 5 o~-
r*4rt fr~.c
.no-J.
TLM C J'd.~~2*, M.r r D ~::-
~
~ t.e. <
psv~o
- n. a r-rsm,3 a n.o u.-u
~.,
in,s -
- r u.C t)? 7. Io?9
/ :) YJ~.
rtere at 2 i n. c *
.oe-e; w,.,
4771-25 INi?. RP7. NC.
fi/HD
??GE NC.
! J.-.r IN3PECTCR: /Wf /*
x s,.e,-
n.
+/e n I
I l
l
[
k-INSPECT!CN DATA CONTINUATICN SHEET
\\
~
INSPECT:CN EL_ MENT:
P o a. iz.
P u.o,e.p a o ~o-o <
se,, s,,r s s isas
- 4 c.4 i
n 1
Ad e# Ano /S YvA2 3=a-4 st. af A "r.lP 7"
/dP 8.-eb-f'"/ /*'# 4 *#
- db"'"
rA
- 7 s 5*c a con n.,
-c1 7~r t -r w se.,<..e e n,e an.
S r -t J JJ se ~ x e-r re Pu oo o at 3 1se s ssce7rD, TL.,.# ' W
/O 4 w s# s4*d so-D4.
- 2. 1 2 7
.A / ) J ~s) *r'
- = - 2. s 2 - 2 0 A-
. t - 2 o ff f -2 )
C -2 z
- -o L
.s 3
s
- " 5 y $
$ f $ 0 s8 Y ShO $
$ O %.
f*L **
r AdL /
rsx toe 42 *2 m eer up 7")#
VA_ 4 m et. o 0 6*%
Yk f
$*= d4* Y~/e.
A t, L 1'"L f
3 0 a st Il s
9 o n
W$
$1 #$n -N O
/
O 80d d
?
h9O &
n ew 2
9 A -A*
i f*
A.-
s* s / /t st-
'i'y A A s M*s V A
o rl.rs,_
r f A
? A /f C d r,3^ G or s f~~
- J f"~sel-i-
s.
A.,
3,*sa.,J,s.D L rif-C-* 4*/
AA 9 a,- A== 0 YJ d Y 7"AA s e or.
rsnE=
7~4.f*
l r
.2^.o.e r ?'"
"'I~LA*
t o C / a.1 es-a--ss 1 b yi$2e 72 4 r-i A-A* V
- a S / / o C A-r/a m
=)** nr 4-
-
- i a 49 s:~ f,t f s
i OP J A-AA.-O k L J 'f"1 S / n ~- d'.
M A 7"~
D. 4. C u *'> ?
- $ $ $ A, * $ lA f W Y$8 s4$-**'** $
JL=n".'.,** A }*f$O
$Y ll 1am /' a s-s r f CJ 7~4. r
? i 7"s s t-oA r~Le
? c:o t, o
s RC /* M sn-< **d c T2 ^.- u an-1
~~o e. O
.0' y er f g fs,e _.es.,4;, :,g.
T* A: t e c JA.-1 d's
- 1~),
- L
-7~
R d.
.Cs s..o-e Am o s.
e,;.a.
i
-A
}
c > de r Psn.s r ss s- -7.ns-->
Y w -- a r -
>. r sa-o E
- NsP. APT. No:
u /d PAGE:,
PE m R:
M $ % - [.,.
i
,r a cu..e s. mise.--
~-
r--~ - n
.?-
i.
/%
- f. of-C,.
p,,.st's.c r2 A-A o.,!~*>t #
- 7~ f' s'A-sf /)
s's D < ~
l t.f I'3*O
_/'""L 6 W a!) tom' J J'S **f f l# MS " ! *'
f o. **
s s
.; - ofin / f*fs' 7 l
w
~-
w
- ~-
r
{
-u f~-e"7 {W 10/19/84 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-445 TEXAS UTILITIES ELECTRIC
)
50-446 COMPANY, et al.
Docket Nos. 50-445/2 (Coma'nche Peak Steam Electric 50/446/2 Station, Units I and 2)
)
AFFIDAVIT OF VINCENT S. N0ONAN I, Viricent S. Noonan, being duly sworn, do depose and state-as follows:
1.
I am responsible for direction of the NRC Staff's (" Staff's")
Project Task Force for CPSES in accordance with attached Memorandum dated October 17, 1984 from William J. Dircks, Executive Director for Operations.
My affidavit addresses the Board's request for a status report and sch'edule for completing pending Staff action on hearing issues which are currently controlling the proceeding. My affidavit is based upon information provided to me by the Comanche Peak project staff and the former Comanche Peak Project Director.
2.
The TRT was established to undertake a comprehensive review of many particularized issues relating to the adequacy of design and con-struction of CPSES. These issues encompass matters identified in the hearing as well as matters identified in allegations which were not i
qa m #r 3)f29,\\
v
\\
i
-2 raised in the CPSES licensing hearings. The TRT's review and findings '
~
may bear directly on currently unresolved matters raised in the hearing, such as QA procedures in document control.
In other areas the TRT effort in the cour.se of addr'essing a broader issue may bear upon relatively narrow issues raised in the hearing. For example, the maximum surface roughness issue, raised in the hearing may itself be a relatively narrow issue but it is encompassed in the TRT consideration of the croader, more generic concern about the adequacy of protective coatings at CPSES. In still other areas, the TRT findings may bear on issues having some rele-vance to the overall programmatic QA issue in contention. The TRT is conducting a comprehensive evaluation of the Applicants' management of their QA and QC program.
In all these areas, the TRT proposes to assess these factors in terms of their safety significance at CPSES as actually constructed. Thus, the TRT review will provide the Staff with a compre-hensive appreciation and assessment of safety matters at CPSES.
Because of the many individual issues being addressed by the TRT, and because of the relevance of these individual issues to the broader issue of the overall adequacy of the Applicants' QA/QC program at CPSES, the Staff believes that an attempt to close out individual issues before the Staff have completed its review and developed its overall position can only result in an incomplete and possibly mistaken understanding of the actual situation at CPSES and a confused hearing record.
In my view the most productive method of resolving the overall hearing issues is to permit the Staff to conclude its TRT effort, develop its overall position 9
u
_y
... =..
on the basis of its review, and then present that overall position to the' Board at an appropriate time.
Until the Staff is able to concludes its effort and develope an overall assessment of CPSES, it will not be able to effectively assist the Board in developing a comprehensive and coherent record and assessing
.the significrace of the macy individual matters raised in this proceeding, from the standpoints of facility safety and applicable regulatory require-ments. Therefore, the Staff believes that the Board should await the completion of the TRT review before undertaking. additional hearings.
The TRT expects to complete its identification of problem areas by the end of November 1984. Assuming a month for Applicants' responses to the TRT findings, the Staff should be able to evaluate the Appli-cants' responses and developed its position on the issues in contro-versv, including the overall programmatic QA issue encompassed in Contention 5, in late January 1985. That should enable the Board and parties to develop a schedule for promptly hearing these matters and the Board reaching its decision on the basis of.a comprehensive and ccherent hearing record.
3.
The Staff has responded to CASE's Discovery Motion on October 16, 1984 by production of a portion of the regs::ted documents. The Staff expects to produce the remaining documents requested by CASE on October 24, 1984. Further, the Staff has advised the other parties that the authors of the EG&G Report will'be available in Bethesda, Maryland for a " Briefing Session" on November 8-9, 1984.
4.
The Staff efforts on TDI diesel generators to date have been directed primarily at the technical questions involving the adequac'y of l
l L.
l.
TDI diesel generators. To assist'it in its review and evaluation of the adequacy of TDI diesel generators, the Staff retained Pacific Northwest Laboratories ("PNL") to review the Applicants' site-specific program for ensuring adequacy of the TDI diesel generators at CPSES. The Staff has completed its review of PNL's Report on Applicants' Program, and has issued a preliminary Supplemental Safety Evaluation Report ("SSER") on this subject. Copies of the preliminary SSER and the PNL Report were
~
transmitted to the Board and parties on October 1, 1984.
The Staff is currently evaluating the adequacy of the Applicants' Vendor QA program. The Staff has also asked Applicants a set of questions regarding QA/QC with regard to TDI diesel generators and is currently beginning an inquiry into the adequacy of Applicants' Vender QA program as applied to TDI diesel generators. The Staff expects to complete its inquiry on Applicants' Vendor QA program and its implementation with regard to TDI diesel generators by the end of November 1984.
5.
The Staff currently projects to respond to the Board's " Memo-randum (Concerns About Startup Quality Assurance) (October 1, 1984).by the middle of December 1984. The Staff intends to respond to " Applicants' Supplement to Motion for Authorization Pursuant to 10 CFR i 50.57(c)"
(September 13,1984) by November 2, 1984.
6.
The Staff is currently reviewing the Applicants' September 24, 1984 partial response to a set of Staff questions raised during the tech-
. nical meetings held on August 8, 9, and 23, 1984. The Staff is awaiting the Applicants' remaining responses to the Staff's questions. The Staff expects to be able to complete one summary disposition motion (ASW/ASME Codes Provisions on Weld Design) by early November 1984. The Staff expects G
g v.
to file its responses on damping factors for OBE/SSE loading conditions, section property values, effects of gaps on seismic response, safety factors..use of generic stiffnesses, and friction forces due te small thermal movements by the end of November 1983. The Staff expects to file its responses to Applicants' summary disposition motions on U-bolts, Richmond inserts, stability of certain pipe support designs, the upper later restraint, wall-to-wall and floor to ceiling supports, force distri-butions in axial restraints, and local displacements and stresses by the end of December 1984.
The remaining summary disposition motion on the overall pipe and pipe support design QA and design control process cannot be completed until the Staff has finished its evaluation of the previously men-tiened summary disposition motions, and also reviewed the findings of the TRT in the design QA/QC area. Accordingly,'the Staff projects that its response on this subject will be able to be filed by mid January 1985.
7.
Applicants have filed motions for summary disposition on the maximum surface roughness issue (June 25,1984) and on Westinghouse com-ponent coatings (September 4, 1984). The TRT is current,1y completing its review of the protective coatings area, and the Staff expects to'be in a position to respond to Applicants' summary disposition motions on protec-tive coatings by mid January 1985.
The above statements are true and correct to the best of my knowledge and belief.
/>
e
/
///,
A W
/pticefit. Npchi Subscribed and sworn to before me this 19th day of October, 1984
/
7/
- /, *f X/ sl-)
Mi;/ bcu ai otary PublTt!
(
My Conr.issier expires: d.IJG((;
3 il )
$9
l i
VINCENT 5. N0ONAN I
Project Director for Comanche Peak Division of Licensing Oftl:e of Nuclear Reactor Regulation and Chief Equipment Qualification Branch Division of Engineering Office of Nuclear Reactor Regulation Vincent S. Noonan is Chief. Equipment Qualification Branch, Division of Engineering. Mr. Noonan joined the AEC in 1974 as a Senior Mechanical Engineer, Division of Systems Safety. He served as both Section Leader and Chief of the Engineering Branch in the Division of Operating Reactors. He later served as Assistant Director, Materials and Qualifications Engineering in the Division of Engineering. Between April 1981 and October 1982 he was with EDS Nuclear. Inc., as Division Manager of the Engineering Analysis Division.
From 1959 to 1974 Mr. Noonan was a Structural Dynamic Group Engineer with the McDonnell Douglas Corporation in St.-Louis, Missouri.
He holds the Bachelor of Science degree in Aeronautical Engineering from St. Louis University and the Master of Science degree in Engineering fram the University of Missouri-Rolla.
d 4
F
-,vy
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SArETY AND LICENSING BOARD In the Matter of TEXAS UT!tITIES ELECTRIC Docket Nos. 50-445 COMPANY, g g.
)
50-446
)
(Comanche Peak Steam Electric
)
Docket Nos. 50-445/2 Station, Units 1 and 2)
)
50-446/2 CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF REPORT TO THE LICENSING BOARD ON STATUS AND SCHEDULE FOR ADDRESSING HEARING ISSUES" together with the Affidavit of Vincent S. Noonan in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or deposit the Nuclear Regulatory Comission's internal mail system (*), or by express mail or overnight delivery (**), or by hand delivery (***), this 19th day of October, 1984:
Peter B. Bloch, Esq., Chairman ***
Mrs. Juanita Ellis Administ ative Judge President CASE.
Atomic Safety and Licensing Board 1426 South Polk Street U.S. Nuclear Regulatory Comission Dallas, TX 75224 Washington, DC 20555 Renea Hicks, Esq.
Herbert Grossman, Alternate Chairman ***
Assistant Attorney General
' Administrative Judge
' Environmental Protection Division Atomic Safety and Licensing Board P. O. Box 12548, Capital Station U.S. Nuclear Regulatory Comission Austin, TX 78711 Washington, DC 20555 Nicholas S. Reynolds, Esq.**
Dr. Walter H. Jordan =*
Administrative Judge William A. Horin, Esq.
Bishop, Liberman, Cook, 881 W. Outer Drive Purcell & Reynolds Oak Ridge, TN 37830 1200 17th Street, N.W.
Dr. Kenneth A. McCollom **
Administrative Judge Mr. James E. Cumins Dean, Division of Engineering, Resident Inspector / Comanche Peak Architecture and Technology Steam Electric Station Oklahoma State University c/o U.S. Nuclear Regulatory Comission Stillwater, OK 74078 P.O. Box 38 Glen Rose, TX 76043 i
Robert D. Martin Billie Pirner Garde William L. Brown Citizens Clinic Director U.S. Nuclear Regulatory Commission Government Accountability Project 611 Ryan Plaza Drive, Suite 1000 1901 Que Street, N.W.
Arlington, TX 76011 Washington, DC 20009 Mr. Michael D. Spence, President Robert A. Wooldridge.
Texas Utilities Electric Company Worsham, Forsythe, Sampels & Wooldridge Skyway Tower 2001 Bryan Tower, Suite 2500 400 North Olive Street, L.B. 81 Dallas, TX 75201 Dallas, TX 75201 Ellen Ginsberg, Esq.*
Lanny Alan Sinkin Atomic Safety and Licensing Board 114 W. 7th, Suite 220 U.S. Nuclear Regulatory Commission Austin, TX 78701 Washington, DC 20555 Atomic Safety and Licensing Board Atomic Safety and Licensing Appeal Panel
- Board Panel
- U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comnission Washington, DC 20555 Washington, DC 20555 Docketing and Service
- Anthony Z. Roisman, Esq.**
Office of the Secretary Trial Lawyers for Public Justice U.S. Nuclear Regulatory Commission 2000 P Street, N.W. Suite 611 Washington, DC 20555 Washington, DC 20036 sn
/((.
0Y
. O%
Geary 5. Nfzuno i
Counsel for NRC Staff t
-