ML20137G623
| ML20137G623 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/27/1985 |
| From: | Landers D TELEDYNE ENGINEERING SERVICES |
| To: | Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| References | |
| 6410-34, NUDOCS 8601210116 | |
| Download: ML20137G623 (17) | |
Text
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'RTELEDYNE I
ENGNEERING SERVCES 130 SECOND AVENUF WALTHAM. MASSACHUSE TTS 02254 1617) 890-3350 TWu (710) 3;I 7508 December 27, 1985 6410-34 Mr. Vince Noonan, Project Director Comanche Peak Project U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Mail Stop P-234 Washington, D. C.
20555
Dear Mr. Noonan:
Attached please find our preliminary Trip Report for our visit to the Comanche Peak Site for Audit of CPRT Action Plan Item Number VII.C on December 3-6, 1985.
If you have any questions please do not hesitate to contact me.
Very truly yours, TELEDYNE ENGINEERING SERVICES Donald F. Landers Executive Vice President DFL/lh Attachment (TripReportNo.2191) cc: L.Shao(USNRC)
J. Calvo (USNRC)
C. Tramell (USNRC)
C. Poslusny (USRNC) 6410 File (TES) 0
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1eTF1 PTY(NE ENGINEERING SERVICES TRIP REPORT NO. 2191 PROJECT 6410T VISIT OF JAMES A. FLAHERTY AND JAMES J. RIVARD TO COMANCHE PEAK FOR AUDIT OF CPRT ACTION PLAN ITEM NUMBER:
VII.C CONSTRUCTION REINSPECTION / DOCUMENTATION REVIEW PLAN December 3-6, 1985 The scope of this audit was an in-depth review of selected populations in tne mechanical and structural area of Item VII.C of the program plan.
This audit was performed at the Comanche Peak site and was a continuation of the audit of October 29-31, 1985.
Tne emphasis of the review was to ensure that all populations and work processes were homogeneous, that an auditable trail existed, and to assure that key attributes were defined.
The purpose of the audit did not include the implementation phase of the action plan.
TES met with other members of the NRC audit team, Tuesday, December 3, 1985.
Ed Tomlinson of the NRC was the audit leader.
The following is an overview of each population reviewed.
I.
MECHANICAL DISCIPLINE POPULATIONS A.
Mechanical Equipment Installation (MEIN)
I met with John Schauf. Mechanical Discipline Leader, and George Heffer, Project Leader, for MEIN.
ERC has revised the Work Process Defini-tion to include Brown & Root HVAC equipment installation.
However, the Population Items List and Population Description have not yet been revised to include Brown & Root.
QI-059, Procedure for Reinspection, has been issued.
QI-060, Procedure for Document Review, is out for review and com-ment, and has not yet been issued.
Thirteen (13) inspection packages have been sent to the inspection group.
However, no formal inspections have taken place to date.
The following inspection packages were reviewed:
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TM ENGNERNG SENCES l
Trip Report i
No. 2191.
l 1) 1-M-MEIN-014 19/TBX-TRAHMH-01 Heat Exchanger 2)
I-M-MEIN-034 CP2-MEATAR-04/D.G.
I Starting Air Receiver 3)
I-M-MEIN-035 52/ cpl-CHCICE-06 l
j Centrifugal Water Chiller
{
4)
I-M-MEIN-065 99-CP1-00ATDT-02 Fuel Oil Day Tank 5)
I-M-MEIN-046 66-TBX CSAPCH-01 Centrifugal Charging Pump 6)
I-M-MEIN-073 CP1-MEATAR-03 l
Diesel Generator Air Receiver 7)
I-M-MEIN-019 26/CP1-CCAHHX Heat Exchanger n reviewing the above packages, it was noted that the "eleva-tion" attribute was listed as - Not Applicable in several packages and that f
at times it was not discernable what type of anchor bolts were used.
In discussing this with George Heffer and John Schauf, it was noted that tolerances were not given on some of the original construction drawings.
ERC requested clarification from TUGC0 through a TIR (Technical Information Request).
The TIR indicated that this attribute was not safety significant for these items.
In determining the type of anchor bolt, ERC clarified the method for reviewing this item, f
The inspection packages for this population are well documented i
and an auditable trail exists for the development and issuance of the pack-ages.
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WTF1 MWNE ENGINEERING SERVCES Trip Report No. 2191.
B.
Piping Systems Bolted Joints / Material (P80M)
I reviewed the PB0M population with Joe DiMare.
I reviewed the revised Work Process Definition Procedure.
It was noted when reviewing inspe: tion packages that " Supplemental Inspection Instructions" (SII) were incluoed.
In reviewing the Project QA Procedure, specifically CPP-003, Revision 1, dated September 23, 1985, " Preparation of Verification Pack-ages", paragraph 5.5 describes the reason and justifiction for use.
SII's are allowed for clarifying, expanding, or adding information to a soecific sample.
The use of the S!! is consistent with the Project Procedures.
If SII's lead to generic clarification or revision to reinspection procedures, then all tne samples will be reviewed to determine the need for reinspec-tion.
Several of the attributes given in this population require both inspection and documentation review.
I-M will be cross-correlated with R-M for those specific attributes.
The following sample packages were reviewed:
1.
Documentation Verification Packages 022, Revision 0 R-M-PB0M-047 BRP-CS-1-SB-022B FL-1, Rev. 14 Chemical and Volume Control l
R-M-PB0M-048 BRP-SW-1-SB-003 FL-1, Rev. 14 Station Service Water R-M-PB0M-005 BRP-SW-1-SB-009 FL-11 l
R-M-PB0M-007 BRP-CC-X-AB-003A FL-1 Component Cooling Water l
R-M-PB0M-012 BRP-GH-X-AB-060 FL-1 Waste Processing Gas, Rev. 6 l
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WTm s:rh'NE ENGINEERING SERVCES l
Trio Report No. 2191.
2.
Reinspection Verification - Q1-021, Revision 0 l-M-PB0M-047 BRP-CS-1-SB-022B I-M-PB0M-042 BRP-SI-1-SB-012 FL-1 I-M-PB0M-043 BRP-SW-1-008 FL-1 I-M-PSOM-028 BRP-AF1-SB-003 FL-2 I-M-PB0M-013 BRP-SW-X-SI-002 FL-4 All packages reviewed contained the appropriate documentation, and an auditable trail existed.
C.
Field Fabricated Tanks (FFTA)
I reviewed this population with Malcolm Wright of ERC.
This population contains eight field-fabricated tanks constructed by Chicago Bridge and Iron.
All eight tanks will be reinspected.
Procedure QI-41, Rev. O, CN-001, dated September 24, 1985, and Procedure Ql-04, Rev. O, CN-001, dated October 30, 1985, were reviewed and contair.ed information for all attributes given in the Work Process Description.
Sample package I-M-FFTA-04, CPX-BRATRH-02, was reviewed for completeness.
It was noted that the package contained an S!! for base-material defect sizes.
This was generated in order that the procedure could be developed since this data had to be supplied by CBI.
Justification of data contained in S!! is given in TIR-017, which was supplied by TUGCO.
The package was complete, and an auditable train exists.
l 0.
Pipe-Welds and Material This population, which originally was two separate populations (large bore, small bore), is being reviewed by the statisticians for sam-pling correctness.
Since ERC is concentrating on sample selection, revised 1
QI's are not available at ths time.
All sample packages have been issued I
to tae inspection group.
Current thinking is to keep Q!'s for large bore and small bore.
ERC will then develop an umbrella QI that ties together the existing Q!'s.
No S!!'s have been written as of this date.
WMNE ENGNEERNG SERVIOEE Trip Report No. 2191.
l The following three inspection packages were reviewed:
I-M-LBWM-010 1-M-LBWM-016 I-M-LBWM-029 Tnese packages were complete, and an auditable trail existed relative to the original Ql.
E.
Instrument Tubing Welds / Material (ITidM) l This population has just been established.
Ql's and work pro-cess descriptions are not available at this time.
II.
STRUCTURAL DISCIPLINE 1
I met with Roger Brown Structural Discipline Leader.
The following populations were reviewed and are commented on below.
A.
HVAC Duct Supports (HVDS) l 1 met with Paul Mitkus who described the population and work processes.
The Work Process, Population Item List and QI-035, Reinspection Procedure, were reviewed.
Ql-035, Revision 0, dated October 10,1985,, with CN-002, dated November 4, 1935, was reviewed.
It was noted that CN-002 contained a revised checklist.
ERC will review all packages completed prior to this l
revision for compliance.
Where necessary, S!!'s will be issued.
The QI j
(Q!-036) for documentation review has not been issued.
It will be issued on approxinstely Occcmber 9, 1985.
The following reinspection packages were reviewed:
l-5 HVDS-099 SG-010-2H-40
W M NE ENGNEERING SERVIOES Trip Report f,0. 2191 I-5-HVDS-115 SG-810-2H-1AT I-S-HVDS-122 DG-310-2K-PS1 These packages were complete and provide an auditable trail.
B.
Cateaory I, Conduit Supports (C05P)
I met with Terry Veers of ERC.
Q1-053, Revision 0,
dated September 20, 1935, for Reinspection, was reviewed, and the checklist com-pared with sample pa:kages.
Tolerances for the attributes of this popula-tion were obtained from the Gibbs and Hill Specification 2323-ES-100, Revision 2, dated 0:tober 25,1980.
Paragraphs 2-36 and 4-19 of the G&H specification state t.1at supports shall be installed to detail drawings 2323-5-910 and 2323-FI-1705.
ERC's Q1-053, Reinspe: tion Procedure, con-tains this set of drawings for the reinspection.
inspection Package
!-S-COSP-059 was reviewed.
This was support mark number C04G21033-20.
Drawings 2323-5-0910, Sheets CA-5d, Revision 4. dated November 19, 1982, and Sheets CSD-14a,14b and 14c were listed in the attributes section for field verification.
The sample package was complete and an auditable trail l
existed.
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!!!. CIVIL / STRUCTURAL POPULATIONS A.
Concrete Placement J. J. Rivard met with Steve Popper, Civil / Structural Discipline Lead Engineer, and Fabian Kovensky, Concrete Placement Lead Engineer.
There were a number of items identified as open items during the previous l
audit of this population on November 29 and 30,1985.
These items were discussed with ECR and the following is an updated status:
1.
The concern was whether to establish cadwelds as a separate i
work process rather than as an attribute.
ERC reviewed the inspection procedure for the individual cadweld inspections i
in addition to the procedure used by the concreto l
TME ENGINEERING SEFNICES Trip Report l
No. 2191
-7 l
inspectors who signed off the concrete pour cards.
These i
l procedures required that each cadweld be tagged by the cadweld inspector to identify that the cadweld was accept-able and that the concrete pour inspector assured that each l
cadweld was properly tagged prior to the sign-off of the concrete pour card.
It is ERC's position that the cadwelds should remain as an attrioute of the Preplacement Popula-tion and not as a separate attribute.
The auditor agrees with this position as long as ERC provides proper doc-umentation.
i 2.
ERC was to consider establishing Richmond Inserts as a separate attribute rather than including these as part of the embedment attribute.
Revision 1 of the Concrete Reinspection Procedure Q!-043 issued November 5,
- 1985, added Richmond Inserts as an attribute.
However, Change Notice 001 to this procedure, issued November 22, 1985, deleted the attribute of Richmond Inserts.
The justifica-tion for not making Richmond Inserts an attribute was that since the GtH location drawings for Richmond Inserts allowed relocation of these inserts (without any tolerance) to prevent interference with robar or other embedmonts, it is meaningless to perform any location reinspection.
The l
auditor agrees with this position.
3.
ERC was to determine if embedded sleeves were used as anchors for piping passing through these sleeves, and, if this situation does exist, ERC would consider establishing a now attribute.
ERC has not yet evaluated this situation.
ltem No.
3, above, is the only item which the auditor feels still remains as an open-item.
ERC has revised the Work Process Definition.
This revision changed the minimum number of attributes required to less than 60 for three t
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TF WE ENGINEERING SERVCES Trip Report fio. 2191,
attributes.
The attributes are Waterstops in the Preplacement Work Process and Cored Holes and Patches in the Postplacement in the Work Process.
The justification for not reviewing a minimum of 60 of these three attributes is that a localized defect of any of these specific attributes will not constitute a concern related to the overall safety of the plant ERC has revised the Reinspection Procedure 01-043.
Revision 1, dated fiovember 5, 1995.
Section 5.3A, Surf ace Inspection of Walls, Curbs, Columns, Piers, Pedestals and Pads was revised to include a statement which recuires the icentification of foreign mateial in the pour which could potentially cause a void in the concrete, along with the addition of the Richmond Insert attribute.
A memorandum was issued on October 30, 1985, describing the reason for these changes, and a statement that all samples inspected prior to the issue date of the memorandum are not affected by these changes.
ERC was asked if there was any additional documentation assuring that the samples inspected prior to the issue of the memorandum were not affected by these changes.
ERC stated that there was no backup documentation and that the statement to address foreign material was added because the inspectors were noting this on the 1,1spection reports anyway.
The inspections were to identify voids; therefore, this addition was con-sidered a clarification, of the actual inspections.
Concrete Placement Reinspection package I-S-Cone-053, dated September 24, 1995, was reviewed, and it was noted that this reinspection was performed prior to the issue of the revision memorandum and that, in fact, foreign material was noted and a Deviation Report was written.
It was suggested to ERC that additional documentation should be considered either by identifying which reinspection packages noted foreign material and which packages definitely had no.ie, or by adding documentation to each package dated prior to the issue of the revision.
This should be a requirement for all populations.
The other item included in this revision was to add an attribute for cast in place of Richmond Inserts.
This attribute was later doloted by Change flotice 001, dated flovember 22, 1933 to Revision 1 of Q!-043.
See the discussion above.
Gibbs and 11111 Concrete Specifiction 2323 55-9, January 16, 1979, was reviewed to assure that the reinspection requirements in Q1043
YE NE ENGINEERING SERVIOES Trip Repart
..No. 2191 reflect the original construction tolerance and inspection requirements.
Q:-044, Procedure for 'Jocumentation Review, has not yet been issued.
Two reinspection packages were reviewed:
I-3-Conc-052 (see discussion above)
I-S-Conc-031 Included in these packages were the following:
4 Reins:ection Checklist Accessibility Walkdowns Appropriate Drawings Typical Details of Embedded Plates Deviation Reports This included infermation which appeared to provide the inspector with all appropriate information te perform the reinspections.
Package I-S-Cone-031 was for the treinspection of a pour with a Concrete Volume of 0.5 cubic yard and a surfNa area of 24 square feet.
ERC explained that this was to fill a blockout',in the original pour.
Approximstely 30 percent of their random sample includes similar blockouts.
Even though these are not significant structural pours, ERC has used these in their random sample to assure that the samp7e is not bias.
TbElr engineering sample (of 60) will not include any blockouts.
Sumary 1.
The Documentation Review Procedure QI-044 has not been issued.
2.
ERC is to datermine the status of embedded sleeves, which possibly could beijsed as anchors.
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SPTELEDYNE ENGINEERING SERVICES Tric Report No. 2191 ;
3.
ERC should provide acequate documentation to assure that all reinspections and document reviews completed prior to a revision to a procedure address the revised requirements of the revision. Inis comment is applicable to all populations.
B.
Structural Steel J. J. Rivard met with Steve Popper, Civil / Structural Discipline Lead Engineer, and Ed Baum, Structural Steel Lead Engineer.
There was one open issue as a result of the previous audit on flovember 29-31, 1985.
The concern was how the reinspection of grout would be addressed.
Two new grout populations were established.
The previous audit of this population was limited to a general overview.
This audit was of much greater detail.
The following documents were reviewed to see if homogeneity of the work process and attributes had been achieved, a.
ERC's Work Process Definitions for Structural Steel.
b.
ERC's Population Description for Structural Steel, Revi-sion 1, flovember 25, 1985.
c.
ERC's Population Items List for Structural
- Steel, September 25, 1985, d.
Procedure QI-045, Rev.
1, October 23, 1995, and Change flotice 001, October 23, 1985, Reinspection Procedure for Structural Steel, e.
ERC's Description Memorandum for Reinspection of Structural Steel:
1.
Rev. O, 9/15/S5 11.
Rev. 1, 10/8/85
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WTA prT/NE ENGINEERING SERVCES 7r,,g,p,rt No. 2191.
V iii. Change Notice to Rev. 1, 10/23/85 f.
Procedure QI-046, Rev. O, November 26, 1985, Documentation Review of Structural Steel.
g.
Gibos and Hill Structural Steel Specification 2323-55-168, Octooer 30, 1985.
h.
TUGC0 Instruction QI-QP-11.14-1, Inspection of Site Fab-rication and Installation of Structural and Miscellaneous Steel, Revision 21, cated June 18, 1985.
i.
TUGC0 Instruction QI-QP-11-0-15, Verification of Baseplates for Grouting, Revision 8, dated March 13, 1985.
j.
TUGC0 Instruction QI-QP-11.14-4, Control and Traceability for Site Fabricated Struct' ural / Miscellaneous Steel, Revi-sion 14, dated September 19, 1984 The Work Process Definitions for Structural Steel was reviewed and it was noted that there was some confusion as to the minimum number of s
samples to be reinspected.:
ERC explained that they had not intended to piample; a minimum of 60 of the attributes identified in the work process flowchart.
The reason was that these were actually subattributes, and ERC
. agreed to revise the flowchart to be more descriptive.
This was done before the end of the audit.
There has been a revision and a change notice to the revision of i;QI-045, Reinspection (see documents d and e, above).
ERC has addressed each reinspection package done prior to these revisions to assure that the reinspections addressed these revisions.
This was accompished in one case by issuing a memo stating which inspection packages were and which packages were not affected by the revision.
The second case was to issue an SI, s
o TME ENGINEERING SERVICES Trip Report No. 2191.
Supplemental Information, for each of the packages done prior to the the revision.
The Gibbs and Hill specifications and the TUGC0 instructions, documents g-j, noted above were reviewed, and the tolerances and the inspection procedures were compared with those included in the Reinspection 01-045 and Documentation Review QI-146 to assure that the reinspection requirements reflect the original construction requirements.
In reviewing TUGC0 Instruction QI-QP-ll.14-1, it was noted that the ERC has not addressed the Seismic Cables in the review.
ERC is to review this and determine whether these cables should be included in the Structural Steel Population.
Two reinspection packages were reviewed:
I-S-STEL-059 I-S-STEL-081 Included in these packages were the following:
Reinspection Checklist Accessibility Walkdown Appropriate Drawings Typical Details Deviation Reports There appeared to be adequate information for the inspector to perform the reinspections.
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WTri prh'NE ENGINEERING SERVIOES Trip Report No. 2191.
C.
Liners - Two Populations 1.
Containment Liner and Tank Stainless-Steel Liner 2.
Fuel Pool Liner Tnese two populations were reviewed together.
The details of these populations were discussed with Steve Popper and Neil Banerjee, Pop-ulation Lead Engineer.
Tne following documents were reviewed to determine if homogeneity of the work process and attributes has been achieved.
1.
Containment Liner and Tank Stainless-Steel Liner a.
ERC's Work Process Definitions b.
ERC's Population Item List, 8/14/85 c.
ERC's Population Description, 7/22/85 d.
ERC's QI-031, Reinspction, Rev. O, 8/22/85 e.
ERC's QI-032, Documentation Review, Rev. O, 10/18/85 f.
Gibbs and Hill Containment Steel Liner Specification 2323-SS-14, Rev. 4 2.
Fuel Pool Liner g.
ERC's Work Process h.
ERC's Population Items List, 9/27/85 1.
ERC's Population Description, 7/22/85 j.
ERC's QI-033, Reinspection, Rev. O, 10/2/85 k.
ERC's QI-033, Change Notice 001, 11/19/85 1.
G&H Stainless-Steel Liner Specification 2323-SS-18, Rev. 4, April 5, 1985 The tolerance and inspection instructions in the above ERC QI's were compared to the original G&H construction specifications to determine
SDE WE ENGNEERING SERVICES Trip Report No. 2191 -
if the ERC reinspection requirements adequately represent those of the original construction.
It was noted while reviewing 01-031 that the inspection instruc-tions to determine contour deviation, page 5, were not clear and that the inspector may not understand the requirements.
ERC agreed that, altnough the directions should be clearer, ERC felt that the inspections were being performed correctly.
The QI for the Documentation Review of the Fuel Pool Lines has not been issued.
Two reinspection packages wre reviewed, one from each popula-tion:
1-S-FDLR-35 Fuel Pool 1-S LINR-60 Containment-Each included all appropriate documentation.
D.
Fill and Backfill Placement J. J. Rivard dicussed the details of this population with Tom i
Boni, Population Lead Engineer, and reviewed the following documents.
a.
ERC's Work Process Definition b.
ERC's Population Description, 7/27/85 c.
ERC's Population Items List, 9/17/85 d.
ERC's QI-057, Documentation, Review of Fill and Backfill Placement, Rev. 3, 10/30/85
SPTA mfNE NEmmSEE 7r,, g,P,,,
No. 2191,
e.
Freese and Nicnols (F&R), FNSSI-1, Safe Shutdown Impound-ment Dam, Rev. 12, 6/3/77.
f.
F&R, QA Program, Rev. 2, 3/15/79 g.
G&H, Installation of Buried Pipe, Specification 2323-SS-8, Rev. 2, 8/7/85 h
TUGC0 Instruction QI-QP-0-9, Rev.
2, 9/1/84, Backfill Around Buried Pipe This population review consists only of a Documentation Review, and the work processes and attributes appear to be homogeneous.
The auditor had no comments with this population.
E.
Two New Grout Populations These are new populations and there was nothing to review.
IV.
GENERAL It was noted that the populations which contain Hilti bolts do not require that torque (as an attribute) be reinspected.
Torque tests will be performed under action plan VII.b.4.
However, samples from VII.C will be contained in the VII.b.4 population.
There is an item of concern not yet closed in the Concrete Placement Population concerning whether embedded sleeves were used as anchors.
o ERC should assure that all reinspections performed prior to any Inspection Revisions appropriately address the requirements of the revisions.
"RTFI m(NE ENGINEERING SERVICES Trip Report tio. 2191,
ERC should adcress the Seismic Cables in the Structural Steel Popula-tion by either including this item or justification for not including the Cables.
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James A. Flaherty 67 James J.Mivard JAF/JJR:jej 1 - Trip Report File 1 - W. J. Carey (TES) 1 - J. Q. Cragin (TES) 1 - D. F. Landers (TES)
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