ML20148D073
| ML20148D073 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/18/1988 |
| From: | Wooldridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5401 OL, NUDOCS 8801250319 | |
| Download: ML20148D073 (207) | |
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fjoJJED cppREsrennt.tc WORSHAM, FORSYTHE, SAMPELS & W 6 RIDGE THIRTY TWO HUNOREO. 2001 BRY AN TOWER DALLAS. TEXAS 75201
'88 JAN 22 P2 '43 TELEPHONE (2W) 979 3000 '
".C E T OLeR,0GE .,
"W,",J;'Z' OFFlCE Gi 3ECfifIAP
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NEIL O ANDERSON SPENCER C RELYE.A MARA R WASEM fMRiS R MfLTENBERGER 00CKElmG A UvK.f.
RONALD M MANSON ROBERT R CLivER hhh(K OF COUNSEL J C AN BOP
- ANNAN CfMOY JACASON BRUNER JOS IRION WORSMAM TRAvis E VANDERPOOL JOE A DAVIS CARL A FORSVTHE JUD(TH K JOHNSON f RfC H PETERSON RiCMARD L ADAMS WALTER w WHITE DAVID C LONERGAN L. SCOTY AUSTfN JOHN w McPEY NOLOS TELECOPtER (2w) a800061 SLARE L BECdMAM TMOM AS F ULLARO w STERNEN COCMERMAM ROBERT M wise TRACY COM95 FLAN'GAN TaMOTHY A MACK January 18,1988 Peter B. Bloch, Esquire Dr. Kenneth A. McCollom Chairman Administrative Judge Atomic Safety and Licensing Board 1107 West Knapp U.S. Nuclear Regulatory Commission Stillwater, Oklahoma 74075 Washington, D.C. 20555 Dr. Walter H. Jordan Elizabeth B. Johnson c/o Carib Terrace Motel Oak Ridge National Laboratory 522 N. Ocean Boulevard P. O. Box X, Building 3500 Pompano Beach, Florida 33062 Oak Ridge, Tennessee 37830 Re: Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Units 1 & 2); Docket Nos. 50-445 and 50-446 - Ob
Dear Administrative Judges:
TU Electric has this date delivered to the Nuclear Regulatory Commissio'1 the following SRT approved Results Reports:
IS AP I.d.1 QC Inspector Qualifications ISAP VII.b.3 Pipe Support inspections These reports should be placed in sequence behind the tab "QA/QC" in the results reports binders previously transmitted. Also enclosed is a revised Table of Contents reflecting the issuance of these reports. As with all previous Results Reports issued to date, this materialis not being offered into evidence at this time but provided for information only.
Respect fly submitte ,
12 g y es g O '
Robert A. Wooldridge RAW /klw Enclosures cc: Service List yY 3
- Log 5 TXX-88101
== CPRT-1096
.9 File.# 10068
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. nlELECTRIC.
w mim c. comma January 18, 1988 ci, nan, ru, er,,s,,,,
U. S. Nuclear Regulatory Commission
.Atin: Document Control Desk Washington, D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 CPRT RESULTS REPORTS Gentlemen:
We transmit herewith the following SRT approved Results Reports:
ISAP I.d.1 - QC Inspector Qualifications ISAP VII,b.3 - Pipe Support inspections These reports should be placed in sequence behind the tab "QA/QC". A new binder is being provided for expansion (Volume IV). Also enclosed is a revised Table of Contents reflecting the issuance of these reports.
The files which contain supporting documentation for these Reports will be available for public inspection at the following locations:
I.d.1 QC Inspector Qualifications - Dallas or CPSES
- VII,b.3 Pipe Support Inspections - CPSES Only Anyone wi';hing to inspect these files should contact Ms. Debra Anderson at (214) 812-4379.
l Very truly yours,
\/
l W. G. Counsil TLS/mlh Enclosures c - Mr. R. D. Martin, Region IV Resident inspectors, CPSFS (3)
M Nonk Olne Street LB 81 skilas. Te ses H.'01
T V January 15, 1988 TABLE OF CONTENTS COLLECTIVE SIGNIFICANCE REPORT Later -
COLLECTIVE EVALUATION REPORT Issued -
RESULTS REPORTS Electrical 4
I.a.1 Heat-Shrinkable Cable Insulation Sleeves -
Revision 1
- I.a.2 Inspection Reports on Butt-Splices, Revision 1 ,
I.a.3 Butt-Splice Qualification - Revision 1 I.a.4 Agreement Between Drawings and Field Terminations
- Revision 2 I.a.5 NCR's on Vendor Installed Amp Terminal Lugs !
- Revision 1 O I,b.1 Flexible Conduit to Flexible Conduit Separation r
- Revision 1 I,b.2 Flexible Conduit to Cable Separation - Revision 1 I b.3 Conduit to Cable Tray Separation - Revision 1 I.b.4 Barrier Removal - Revision 1 fivil/ Structural I.c Train C Conduit and Supports - Revision 1 II.a Reinforcing Steel in the Reactor Cavity -
Revision 1 II.b Concrete Compression Strength - Revision 1 II.c Maintenance of Air Gap Between Concrete Structures
- Revision 1 II.d Seismic Design of Control Room Ceiling Elements -
Revision 1 ;
() II.e Rebar in the Fuel Handling Building - Revision 1 -
i
e-Y Testina
() 111.4.1 Hot Functional Testing - Revision 1 III.a.2 JTG Approval of Test Data - Revision 0 III.a.3 Technical Specification for Deferred Tests
- Revision 0 5
III.a.4 Traceability of Test Equipment Revisior. O III.a.5 Preoperational Test Review and Approval of Results, Revision 1 III.b Conduct of the CILRT .levision 0 III.c Prerequisite Testing - Revision 1 III.d Preoperational Testing - Revision 1 Mechanical V.a Inspection for Certain Types of Skewed Welds in NF Supports - Revision 1 with Errata V,b Improper Shortening of Anchor Bolts in Steam Generator 'Jpper L-teral Supports - Revision 0 V.c Design Consideration for Piping Systems Between Seismic Category I and Non-Seismic Category I Buildings - Revision 1 V.d Plug Welds - Revision 1 l V.e Installation of Main Steam Pipes - Revision 1 VI.a Gap between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall, Revision 1 l
VI,b Polar Crcne Shimming - Revision 1 l
l O
l l
/
OA/0C
(
(3 ,/ I.d.1 QC Inspector Qualifications I.d.2 Guidelines for Administration of QC Inspector Test
- Revision 1 I.d.3 Craft Personnel Training - Revision 1 VII.a.1 Material Traceability - Revision 1 VII.a.2 Nonconformance and Corrective Action System -
Revision 1 VII a.3 Document Control - Revision 1 VII.a.4 Audit Program and Auditor Qualification -
Revision 1 VII.a.5 Periodic Review of QA Program - Revision 1 VII.a.6 Exit Interviews - Revision 1 VII.a.7 Housekeeping and System Cleanliness - Revision 1-VII.a.8 Fuel Pool Liner Documentation - Revision 1
() VII.b.1 VII.b.2 Onsita Fabrication - Revision 1 Valve Disassembly - Revision 1 VII,b.3 Pipe Support Inspections VII,b.4 Hilti Anchor Bolt Installation - Revision 1 l VII.c Construction Reinspection / Documentation Review Plan l
I l DSAPs l VIII Civil / Structural - Train A & B Conduit and Supports
- Revision 1 VIII Civil / Structural - Cable Trays and Supports -
Revision 1 i
IX Piping and Supports Discipline Specific Action Plan
- Revision 1 I
l
ar O .
COMANCHE PEAK RESPONSE TEAM RISULTS REPORT ISAP I.d.1 Titlet QC Inspector Qualifications REVISION 1 O
b V' = - C 0[ t-IssueAoordinator[ V
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s ds/?7 Da(e #
Team Leader - '
Date 12/ U hl
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^'2 t J '-!- /% fh1 Jop. Beck,ChairmanCPRT-SRT Date l
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Revision: 1 Page 1 of 138 RESUI.TS REPORT ISAP I.d.1 QC Inspector Qualifications
1.0 DESCRIPTION
Page J 110) OF ISSUE IDENTIFIED BY NRC (NULEG.0797, . 7 Supple files, and requirements for personnel testing, o and racertification. ,
QA/QC personnel. The TRT also intseviewed selected electrical !
s l
The TRT found a lack of supportive documentation regarding personnel procedures and regulatory requirements.qualificacicna in the documentation for assuring that the requirements for electrical RCA inspection recortification were being met. Specific examples are:
One case of Equivalency no documentation of a high school diploma or General Diploma.
One case of1no documentation experience. to waive the remaining 2 months of the required year vision examinscion administered byspecialist. a professiona A makeup test using colored pencils was administered by a QC supervisor, was passed, and then a waiver was given.
Two cases where the experience requirements to become a Level I technician were only marginally met.
One case of no documentation in the training and certification files substantiating that the perton met the experience requirement,"
2.0 ACTION IDElffIFIED BY NRC (NUREC 0797, Supplement No. 7, Page J.l "Accordingly TUIC shall review all the Electrical QC inspector training, qualification, certification and re-certification files against the project requirements and provide the information in such a form that each requirement is clearly shown to have been met by each inspector.
If an inspector is found to not aset the training, 1 qualification, certification or re certification requirements, TUIC shall then review the recorda o datermine the adequacy of in:pections made by the unqualified individuals and pr: ovide a statement of the impact of the deficiencies.noted on the safety of the project " .
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RevisLon: 1
. RESUI.TS REPORT Pess 2 of 138 ISAF I.d.1 ,
(Cont'd) 3.0 BACXGROUND Prior to 1978, Brown & Root, as constructor, maintained a QC inspector certification programas part o covering both ASMR and non A$eM site inspection accivities. TU in 1978, when TU Electric assumed responsibility for program. l and maintained their own separate QC inspector certifica to support the ASME QA program.
Since its inception in May 1978, the TU Electrie QC inspector certification program had been based on certifying personnel in a given inspection function / activity as delineated in a specific instruction rather than a general certification of an individual in a discipline.
of some other members of the nuclear industry.The TU Electric ap The more common approach in the certifications fornuclear industry is to issue general discipline ins;4ctors. -
If properly implemented, the TU Electric approach was conservative in that it required additional in which general discipline certifications However, are issued. training and because of the increased number of certificttions and attendant certification requirements, the TU Electric approach was more difficult to administer than the alternate approach. Both approaches are acceptable if effectively implemented.
Since 1978, the Brown & Root QC inspector certification program , which certifies personnel by discipline rather than inspection functioncertification Electric / activity, has been significantly less complex than the TU program.
certification, and qualification of inspection personnel wereIn 1978, r4quireme Assurance Personnel Training Manual". contained in the Brown & Root Qu Although this manual contained requirements for the certification of a wide range of inspection disciplines, since May 1978 the manual was used only to certify nochanical inspection personnel and nondestructive examination (NDE) personnel in the areas of visual examination (VT), radiographic examination (R"), ultrasonic examination (UT), magnetic particle examination (MT), liquid penetrant examination (PT), and leak detection (LT) .
The mechanical inspection certification under this manual was generally based on ANSI N45.2.6, "Qualifications of Inspection Plants Examination and Testing Personnel for Nuclear Power
" guidelines.
The NDE certifications addressed the requirements of the Amerison Sociaty' for Nondestructive Testing's "Recommended Practice for Psrsonnel Qualification and Certification' ,
O'
Rovision: 1 Pago 3 of 138 ISAP I.d.1 (Cont'd) '
3.0 BACIGROUND (Cont'd)
SNT TC 1A, as modified by ASMR Code requirements.
. the Brown & Root ' Quality Amaurance Personnel Training Manual" wasIn F replaced by the following three procedures:
CP-QAP 2.1, "Personnel Training and Qualification",
QI-QAP 2.1 1, "Nondestructive Examination Personnel Certification *,
- i QI-QAP-2.1 5, "Training and certification of Mechanical Inspection Personnel".
- On January 30, 1981, and Brown & Root to the requirements of Regulatory Guide 1.58 Revision 1 "Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel".
'this Regulatory Guide invokes. !
Guide) and SNT TC 1A as1978 modified (as modified by by thetheASNI RegulatoryCode.the r' A detailed description of the TU Electric QC inspector certification precedures is contained in the Results Report for ISAP 1.d.2, "Guidelines for Administration of QC Inspector Test". ,
The NRC TRT concerns, described above in Sections 1.0 and 2.0, focused on TU Ilectric electrical QC inspectors. In addition to the electrical QC inspectors, a decision was nada to evaluate all TU Electric and Brown & Root QC inspectors employed onsite as of March 1985, as a rt of the ISAP I d.1 evaluation.
on the following considerations: This decision was based ByreviewingallTUdiectricslectricalQCinspectors, including those inspectors who had left the jobaite prior to March 1985, a significant amount of information r*Sarding the adequacy of the overall historical Comanche Peak QC inspector certification program would be developed.
4 Review of all current QC inspectors would determine if the current TU Iloctric and Brown & Root QC inspector certification programs were adequately implemented or, if required, would enable appropriate corrective action to be identified.
Subsequent to this decision. ISAP VII.c, "Construction Reinspection / Documentation. Review Plan," came into existence. Because documentation review is an 'important component of the VII.c evaluation and because the majority of the documentation evaluated is QC i
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Revision: 1 RISUI.TS RIPCRT ISAP 1.d.1 (Cont'd) 3.0 BACKCROUND (Ctnt'd) inspectionwere inspectors documentation, reviewed. certifications of the associated QC Inspectors whose certifications were identified as @ lionabis or inadsquate were documented on Deviation Reports. Thesu N 'istien Reports were reviewed by QA/QC Review Team personnel who participated in che implementation of ISAP I.d.1, and the inspectors received a I.d.1 type evaluation that included Phase III reinspections as requirrt.
- A '.ater decisien Jas made to condu:t a I.d.1 type evaluation of inspectors identified during the ISAP VII.c documentation review process, wt.ethsr or ret their certifierciwns were identified as questionable. This decision was made because of procedural inadequacies identified during implementation of ISAP 1.d.2 /
and the substantial number of inspectors who were identified as requiring scope Phase of ISAP III ow luation during !aplssentation of the original I.d.1.
9e specific valid Deviation Reports for QC inspector certification problems and the results of the I.d.1 type evaluations identified during this process were considered in the final conclusions on the overall adequacy of the CPSES QC inspector certification program addree ed in this ISAP. In addition, pessible s 5
impact of thess deviations and avaluations on was ilentified. '4e liAP VII.c resdte Some inspectors identified during implemen.;ation ei ISAP VII.a.8, O "Fuel Pool Lirer Documentation," ISAP VII.b.1, "% site Furication,"
and ISAP VII,b.3, "Pipe Support Inspections,' were P.co referred to the QA/QC Review Teen I.uol group for I.d.1 cype evaluatior .. As a result of ISAPs VII.c, VII.a 8, VII b.1, and VII b.3, an Aitional 268 TU tiectric, Brown & toot, have received I.d.1 cype evaluations, in addition to tho 319and other site subcontr inspectors evaluated in accordance with the original scope of ISAP I.d.1.
As a result of the evaluation of the additional inspection personnel associated with ISAPe othat the 1.d.1 listed above, a decision was made to increase the sc9pa of ISAP I.d.1 tc include these additional evaluations in the final conclusion on the overall adequacy of the CPSES site QC inspector certification program. The cocel number of TU Electric, Brown & Root, and other subcontractor QC inspot :o. s who have roteived I d.1 type evaluations comprises almost 70% of s.11 QC I inspectors who have been utilized Grough March 1985 dunns construction at Comanche Peak.
It should be noted that t d . inspectors identified during the ISAP VII.c documentation reviews formed a large euh.n.t of the inspectors
{
whose work was recreatable and was reinspected during ISAP VII.c reinspections, i
Revision: 1 Pogs 5 of 138 ISAP 'i.d.1
- O (Cont'd) 3.0 RACKCROUND (Cont'd)
- The evaluat;on asthcdology specified in Section 4 of this Results
- Report was established and implemented well in advance af the issuance of Revisions 2 and 3 oi' the CFRT Program Plan, including the assisciated Appendix E, 'CPAT Procedurs for the Resolution of Discrepancies Identified by the CFRT". Aprendix E deff.nes the classification implementationand resolution of discrepancies identified duri.1g the of ISAPs.
Because of the advanced stage of implementation of ISAP I.d.1 when Appendix E came into effect, no attempt was made requirements by the QA/QC of Appendix Review Team to backfit all the detailed E. However, the intent of the latest requirements addressed of the by this CFRTReport.
Results Program Plan and Appendix E are adequately Although discrepascies in individual inspector certification files were not documented as construction deviations Inspector certificati?n Evaluation Summaries (ICES), shown in Attachment 1, vera cor11sted and are equivalent to construction Deviation Reports. Se discrepancies noteJ or the ICS were evaluated evaluations (Phase in III)
Phasem.rcIT r4 a determination made whechar further required. If an inspector failed ?hase III evaluation, a root cause/ generic implication analysis was required (as it would have been fer a construction deficiency) and the possible impact on the safety fonction of the associated hardware was evaluated.
O evaluated. ISAF 1.d.1 results were reviewed and trends identified and Potential hardware implications were also considered for those inspectors whose Phase III evaluation results were indecersivate.
Section 5.7 of this The resultsReport.
Results of this review for trends are described in Hudware discrepancies identified during Phase III reinspections were separately documented as required by the TU Iloctric/ Brown & Root nonconformance system. All of there hardware discrepancies were evaluated to determina if any were reportable to the IRC by TU Iloctric in accordance with the requirements of 10CFRSO.55(e). 1 4.0 CFET ACTION FIAN This Action Plan was originally developed to address specific NRC TRT concerns regarding TU Electric electrical QC inspector qur.lifications.
As described above in section 3.0, the decisian was made to include the I d.1-type overall scope ofoveluations 1SAF I.d.1. made in conjunction with other ISAPs in ths and complements ISAP I.d.2. This Action Plan is closely related to Evaluations of the additional inspectors associated wEch ISA.'s VII.c VII.a.4 s VII.b.1, and VII.b.3 also provided a significant amount of information that was useful for evaluating the effectiveneak of the overall CPSES QC inspector certification program.
Data free the evaluations associated with O
Revisten: 1 Pego 6 of 138 M5U1.T3 REPORT ISM I.d.1 (Cont'd)
- 4.0 CFRT ACTION FIAN (Cont'd) these scope. ISMS was included with the results of the original ISM I .d. 1 This information, along with the ISM I d.2 results, was utilized to reach an o rerall conclusion on the adequacy of the IV Electric. Brown & Root, and subcontractor QC inspector certification programs.
Section 4.1 describes the scope and methodology utilized for the ,
original scope of ISM I.d.1, that included evaluation of all TU Electric historical slectrical QC inspectors and all current TU Electric and Brown & Root QC inspectors.
Section 4.2 describes the scope and methodology utilized for evaluatir.g inspectors associated with ISAPs VII.c, VII.a.8, VII.b.1, and VII,b.3.
4.1 Scope and Methodology. orisinal LSAP !.d.1 The original objectives of this action plan were to address the specific TRT concerns regarding the electrical QC inspector qualifications and to provide input into the overall assessment of the adequacy of quality control inspection. In order to meet these objectives, all current TU Electric and Brown & Root QC inspectors and TU Electric historical electrical QC inspectors were selected for evaluation from the population of current and historical QC inspectors.
The methodology for accomplishing the major objectives of this evaluation was as follove:
Phase I. Training, qualification, certification and racertification files for all TU Electric electrical QC inspetors, for all current Brown
& Root QC inspectors and for the remaining currenu TU Electric QC inspectors were reviewed against Project requirements.
Phase II. If inspectors' qualifications were found to be questionable or unverified in Phase I they were further evaluated to determine whether a basis existed to resolve the concerna utilizing availaole or obtainable documentation.
Phase III Finally, a portion of work completed by those l
inspectors whose qualifications could not be verified in Phase II was reinspected.
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I Revisten: 1 !
Pcgo 7 of US ISAP 1.d.1 !
(Cont'd) 4.0 CFRT ACTI0tt PLAN (Cont'd)
, Concurrent with the implementation of this portion of this ISAP .
TU Electric conducted a review of their QC inspector qualification improvements,recards system and identified and implemented
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4.1.1 Phase I Evaluation of Inspector Qualification Documentation '
\
The objective of Phase I was to perfora a review of the ;
available documentation of the qualifications of l inspectors and 3. aSainst the criteria contained in Attachments 2 The results of this review were docussneed to demonstrate, qualifications. where possible, the adequacy of inspector The review was conducted in two parts.
TV tiectric QC Inspector Review The review of TU Electric QC inspector i qualification docsments was initially conducted i
by the TU Iloctric Audit Group (TAG). The TAG initiated this review in late 1964 and completed l their work in January 1985. This TAG effort was i subsequently redone by the QA/QC Review Team to seet expanded requirements of the CFET Program that were established subsequent to this work.
This initial TAG review does not form a basis for any results or conclusions contained in Jhis Results Report.
The QA/QC Review Team review was based on the criteria contained in the matrix shown in Atemehment 2.
Brown & Root OC Insoector Review i
The QA/QC Review Team conducted a review of the l procetures for certifying / qualifying Brown &
Root QC inspectors to identify project l
{ reqairements and, for the current Brown & Root procedures, to assure coepliance with applicable standards and codes. The QA/QC Review Team also reviewed the certification records of current Brown & Root QC inspectors to verify compliance
, with these procedures and the criteria I
established in .the attached matrix (Attachment
- 3) . *. ..
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Rtvisten: 1 RESULTS REPORT Pcs 8 of 138 ISAF I.d.1 (Cont'd) 4.0 CFRT ACTI0tt PLAN (Cont'd)
For inepector certification dicumentation reviews, a i specific inspector.certification summary was generated for each The certification summary provides a listing of the individual's initial and discrepant certifications and any concerns /discrepancias noted regarding the individual's specific classroom training, on the job training and examinations in addition to education and experience.
Inspectors whose qualification documentation was lacking in one or more aspects listed on the certification summary were identified for further review during Phase II.
4.1.2 Phase II Further Evaluation The objective of Phase 11 was to evaluate qualifications that could not be verified in Phase I and, based on these results, determine whether further evaluation of the inspector's capabilities was required during Phase III.
A Special Evaluation Team ($ET), comprised of external consultants who had no responsibility for administering the CPSES Inspector Training / Certification Program and whose qualifications are described in paragraph 4.4 of this plan, evaluated the Phase I reviews conducted by the QA/QC Review Team to validate the reviews.
SET evaluated questionable 111 Electric QC and trown 4 Root QC inspector records for acceptability using the criteria established in Attachments 2 and 3. h se evaluations included consideration of the specific circumstances as applicable in the following areas:
l Experience of the inspector Education of the inspector Formal training at CPf".S l On the job training that damonstrates practical proficiency Examinations that demonstrate knowledge of procedpres O
Revisten: 1 Pego 9 of 138 RESULTS REPORT ISAF I.d.1 '
(Cont'd)
O 4.0 CPRT ACTION PLAN (Cont'd)
Other valid certifications in related areas Other considerations deemed appropriate by SET.
These consid2 rations were documented by SET.
For TU Ilectric QC inspector certifications prior to January 1981, the following additional criteria, listed in descending order of importance, were also used by the SET to evaluate inspector qualifications:
TU Iloctric procedure CF QP 2,1, P.evision 0 through Ravision 6, and the associated "daughter instructions" (QI-QPs). These "daughter instructions
- define specific inspection functions and capabilities, requirements for documenting training activities and requirassets for qualification of inspection personnel.
SET judgment based on ANSI N45.2 and ANSI N45.2.6 that have been industry consensus /
practice since 1973.
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Consideration of the TU Iloctric method utilized to limit certifications to specific inspection procedures containing detailed instructions /
steps, rather than attempting to certify personnel in a specific discipikw, such as "electrical", to perform any and a'l electrical inspections.
Related experience, if it had a direct relationship to the inspections for which certified. (e.g. , barwim on, power plant construction or QC inspection activities equivalent to activities for which certified.)
x For Brown & Root QC inspector certifications prior to January 1981, the Brown & Root ' Quality Assurance Personnel Training Manual" and judgment be. sed on ANSI N45.2 and ANSI N45.2.6, that have been industry consensus / practice since 1973, were used to evaluate inspector qualifications.
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Revision: 1 Pago 10 of 138 MSULTS MPoetT ISAF !.d.1 (Cont'd) 4.0 CFRT ACTION FIAN (Cont'd)
. Certification s m ry sheets, typical of Attachment 1,
, were prepared performed for each inspector to reflect the evaluation by Str.
TU Electric was requested to provide additional basis. information or verifications on a case by case RTL and the Issue Coordinator were responsible forThe QA/Q performing a review of all additional information obtained by TU Electric to update certification records. Copies of these records are retained in the ISAP I.d.1 working file.
Based on the results of this evaluation, the RTL or the Deputy RTL, in conjunction with the Issue coordinator, was responsible for accepting the qualifications without further action, or, for those inspectors whose qualifications to Project requirements could not be demonstrated, evaluation.
placing them into Phase III for further -
4.1.3 Phase III . Rainspection The objective of Phase III was to evaluate a sample of work completed by each of those inspectors whose qualifications could not be verified in Phase II. The purpose of this evaluation was to determine the following:
Whether the inspectors were able to conduct inspections properly despite weaknesses or inadequacies in their qualification documentation.
Whether additional evaluations were required of the impact on the safety function of hardware inspected by personnel failing Phase III
- evaluation or whose capabilities to satisfactorily conduct inspections were indeterminate or inconclusive.
Rainspections were conducted of the initial work for those inspectors whose qualifications were not accepted in Phase I or Phase II.
Ltvaluations that focus on the initial inspections of individuals were chosen because it is reasonable to conclude that added experience will increase an inspector's. capability.- As time progresses they become more familiar w'ith their assigned tasks, and the chance of G
Revisitn: 1 Pcg3 11 of 138 ISAP 1.d.1 (Cont'd)
- 4.0 CFRT ACTION PLM (Cont'd) error decreases. Therefore, the l'; ens to be reinspected
. were drawn, where possible, from an inspectors initial i
work conducted in the first 90 days after issuance of the applicable questionable certification.
A similar three. phase evaluation process, including the Phase III reinspections described below, has been utilized at another nuclear facility as an effective method to determine if an inspector was capable of performing the required inspections.
Population he population to be sampled included the identified applicable inspections performed by each of those {
inspectors placed into Phase III. -
Seasle Selection Process I Lists of inspections and inspection records were reviewed to identify work / inspections that each inspector performed during the first 90 days following the issuance of the O discrepant certification, his engineered selection of items, rather than a randos selec': ion from the whole population, is conservative because of the increased likelihood of inspection errors occurring while the inspector was relatively new to the work.
A review of the records of each itos chosen for reinspection determined if subsequent work had been perf9 rand that would disturb or change the condition of the ites since the initial inspection. A determination was also made as to whether the itse was still accessible, the inspection was recreatable and if the itse had been reinspected by others after the initial inspection.
Inspections for which the ites had been disturbed, changed, reinspected, or were inaccessible and inspections 4 that were not recreatable were removed from the sample.
Theas are definitions follows: of "inaccessible" and "not recreatable" 6
a.
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R violen: 1 Pcgo 12 of US ISAF 1.d.1 (Cone'd) 4.0 CFRT ACTION FIAN (Cont'd)
- "Inaccessible" is defined to mean a condition where extensive dismantling would be required to
~
sain access for direct reinspection, such as in the case of piping, reic. forcing steel or conduit that is sabedded in concrete.
"Not recreatable" is defined to mean a condition where a process or event cannot be recreat.ed, such as pull force during cable pulling, interpass weld temperature or receiving inspection.
Each inspection conducted during the first 90 days was reinspected. In the event that this first sample was too saali (less than 50 items) to make s judgment on an inspector's qualifications, selection continued in sequential order until the sample reached 50 icons or included all of the identifiable recreatable work accomplished by that inspector.
Reinsoection of Hardware Each ites in the sample was reinspected using W Electric or Brown & Root inspectors, who were presently certified to conduct the required inspections (verified by tha QA/QC Review Team) and not personally involved in the original inspection activities in question, vien a 100% overview by independent third party QA/QC Review Team inspectors. The name TU Electric or Brown & Root inspection procedures utilized on the initial inspection were used for the reinspection.
Care was taken to assure that the ites was reinspected to the same criteria as that used for the initial inspection. Prior to conducting the reinspections, the objective / subjective designation of each inspection attribute was determined. Discrepancies identified during the reinspection were processed in accordance procedures. with W Electric / Brown & Root nonconformance The results of the reinspection were compared to the original inspection results in accordance with the following:
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Itsvision: 1 icgo 13 of 138 13AF I.d.1 (Cont'd) '
O 4.0 CFRT ACTION FIAN (Cont'd)
. For objective type attributes there sust be a
, 95% or greater agreement race between the results of the original inspection and the results of the reinspection. This figure (956) was chosen based on e,he fact that objective attributes are repeatable and are not subject to interpretation nor require judgment. For example, asasurement of physical dimensions to verify compliance with dimensional tolerances is an objective attribute.
Tor subjective type attributes there must be a 904 or greater a5reesr,at race between the results of the origiani inspection and the results of the reinspostion. h is figure (904) was chosen based on the fact that subjoetive attributes require interpretation, and the ~
specific item being inspected may be viewed differently by various inspectors. For example, determining if a weld is smooth enough so that any existing surface irregularities will not i interfere with it terpretation of a radiograph O that is to be taken of that veld is a subjective attribute.
ne results of the reinspection were compared to the original inspection to determine if this agreement rate was equal to or g. eater than the
, requirement of 95% for objective attributes and
! 90% for subjective attributes. If the inspector l failed to meet this rate, the sample was i
-required to be expanded to include the next 90 days of work. The same criteria for a minimum sample size of 50 was applied.
The sees process of reinspection was repeated andday ll0 theperiod.
cumulative results calculated for a If the inspector failed (i.e.
less than 954 agreement of cumulative results for objective type attributes and/or less than
! 90% a3reement of cumulative results for subjective type attributes), a 1004 reinspection of all the inspector's work was required to be O
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Rsvistan: 1 Pego 14 of 138 RESUI.TS REPORT j ISAF'!.d.1 (Cont'd) 4.0 CFRT ACTION FIAN (Cont'd) conducted, unless otherwise recommended by the QA/QC Review Team based on the results of root cause/ generic implication analyses or other relevant information.
The Issua Coordinator, in conjunction with the QA/QC Deputy RTL, evaluated the results of the Phase IU reinspections. In cases where the required number of inspections was obtained within time frames reasonably close to the initial discrepant certification, inspectors were datermined to the reinspection be acceptable or failed, depending on results. In cases where the required number of inspections was not obtained or where inspections occurred in time frames substantially after the initial certification, inspectors were determined to have failed, to be of indeterminate acceptability, or to be substantially positive if there was a substantial amount of positive information retarding their capabilities.
Root cause/ generic implication analyses were conducted for inspectors failing Phase III and QA/QC program deviations and deficiencies that occurred were identified and referred to IV Electric for correction.
4.1.4 Qualification Records System Review In addition to the review of records for individual inspectors TU Electric took action to identify improvements to their qualification records systes and procedures, the objective of this review was to establish a qualification records systes that collects qualification data in a clear and concise form that is easily retrievable.
4.2 Scone and Methodolory for Evaluations Associated With Related
.Uhlt ISAFs VII.c. VII.a.4, VII,b.1, and VII.b.3 included requirements forQC' by the inspectors.
review and evaluation of documentation that was prepared As a check on the validity of this documentation, the certifications of the QC inspectors who prepared the documentation were reviewed for adequacy. All inspectors who were identified during these documentation reviews were subjected to a I,.d.1 type evaluation.
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Revietsn: 1 Pess 15 of 138 ISAP I d.1 (Cont'd) '
4.0 CFET ACTION PLAN (Cont'd)
The methodology for conducting the evaluations associated with related ISAPs was as follows:
For ISAPs VII.c. VII.b.1, and VII,b.3, documentation review checklists contained attributes to verify that QC inspectors associated with the documentation being reviewed had valid certifications.
the certifications appeared discrepant,In those cases where and forwarded to the ISAP 1.4.1 Issue Coordinator whereDRs were they were processed as follows:
- 1) )
ISAP I.d.1 personnel reviewed the DRs and, as appropriate, validated or invalidated the Das.
2) 1.d.1 type evaluations were performed on these inspectors, whether or not the associated Das were valid or invalid. Where valid DRs asisted, the specifics of the certification deviations were addressed in the I.d.1. type evaluations.
Tor ISAP VII.a.8, the ISAP Issus Coordinator transmitted a i
I list of all QC inspectors identified during implementation of the ISAP to the ISAP I.d.1 Issue Ccordinator. A I.d.1. type evaluation was performed on all these inspectors.
Por ISAPs VII.c and VII.b.3, QC inspectors associated with dicumentation reviews for whom no des retarding 4
! cattification had been written were identified free im'ormal documentation Inspection Group. A similarmaintained by the QA/QC Review Team type list of inspectors associated with ISAP VII.b.1 for whom no dss had been written was provided to the ISAP I.d.1 Issue Coordinator by the ISAP VII.b.1 Issue Coordinator. A 1.d.1. type evaluation inspectors. was performed on all these additional The ISAP 1.d.1 Issua Coordinator provided the results of the I.d.1. type evaluations, including the status of related DRa, to the applicable Issue Coordinators.
- Results of the additional I.d.1. type evaluations associated vitih related ISAPs were included with the results of the evaluations associated with the Sori inal ISq1.d.1 scope'. The combined results were utilized to
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0 Revision: 1 Pegs 16 of 138 ISAF I d.1 ^
(Cont'd) 4.0 CFRT ACTION FIAN (Cont'd) reach a conclusion on the overall adequacy of the TU Electric and Brown & Root QC inspector certification programs.
The I d.1 type evaluations were ronducted using the same three phase methodology described in Section 4.1 and as detailed in the following sections:
4.2.1 Phase I - Evaluation of Inspector Certification Documentation The Phase I evaluattorJ of QC inspectors associated with related ISAFs were conducted by the QA/QC Review Team under the direction of the ISAP I.d.1 Issue Coordinator utilising the same review criteria specified in Section 4.1.1. In addition to QC inspectors free TU Electric sad trown & Roet, QC inspectors free Chicago Bridge & Iron (CSI), Sahnson, Mason Johnston, R. W. Hunt, and Freese &
Nichels were evaluated. Except for CBI, criteria contained in Attachment 2 were utilized for the review.
In the case of CSI, criteria contained in Attachment 3 were utilised for the review.
A specific certification sunnary was generated for each I
inspector. Each summary provided a listing of the individual's initial and discrepant certific.acions. The summary also identified any concerns / discrepancies noted
! regarding the individual's specific classroom training, on the. job training, examinations, and education and experience.
Concerns related to DRs were also referenced and described in the summaries.
l Inspectors whose qualification documentation was lacking in one or more aspects listed on the certification summary were identified for further review during Phase II. Ihe certification summaries for these Phase II inspectors were also transmitted to the TV Electric Quality Training Supervisor for further action and resolution of the outstanding concerns.
4.2.2 Phase II Further tvaluation The objectives.,opd methodology for conducting Phase II evaluations of inspectors associated with related ISAPs was the same as described in Section 4.1.2 with the following exceptions:
h
Rov ts Ls:n: 1 usut.Ts upoat Fes3 U of US ISAP I.d.1 (Cont'd) 4.0 CPST ACTION FIAN (Cont'd)
- 1 N Phase 11 evaluation was conducted by the ISAP 1.d.1 Deputy RTL. Issue Coordinator and the QA/QC The SET did not participate in any evaluations of inspectors associated with related ISAPs.
The Phase II evaluation was conducted utilizing the TV Electric response, including any additional information, to the concerns noted in the certification summaries. Evaluation criteria were the same as noted in Section 4.1.2.
In the case of subcontractor QC inspectors, applicable requirements of the subcontracters' QA/QC programs and inspector certification proce C es and requireaants were also considered in the Phase II evaluation process. ,
Based on the results of the Phase 11 evaluations, the Issus Coordinator and the Deputy RTL accepted the qualifications without further action, or, for those inspectors whose qualifications to Project requirements O could t,ot be demonstrated, placed them into Phase III for further eveluation.
4.2.3 Phase III Reinspection h Phase III reinspections of inspectors' work associated with related described ISAFs were ir. Section 4.1.3. conducted in the same manner as 4.3 Participants holes and Responsibilities 4.3.1 special Evaluation Team (SIT) 4.3.1.1 Evaluated the QA/QC Review Team Phase I reviews for the original ISAP I.d.1 scope of work.
4.3.1.2 Conducted evaluations of inspectors where
' qualification documentation was inadequate or not available during Phase 11 for the original ISAF I.d.1 scope of work.
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Revision: 1 RESULTS REPORT Pass 18 of 138 ISAF I.d.1 (Cont'd) 4.0 CFET ACTION FIAN (Cont'd) 4.3.1.3 Forsonnel Mr. J. V. Sutton Mr. M. L. Curland 4.3.2 TU Electric QA 4.3.2.1 Providad additional information or verifications on a case by. case basis during Phase II evaluations.
4.3.2.2 Identified recreatable inspections for those inspectors placed into Phase III.
4.3.2.3 Provided qualified inspectors to conduct thase III reinspections.
4.3.2.4 Identified improvements to the IV Electric QC inspector proceduras, qualification records systen and 4.3.2.5 Forsonnel Mr. F. E. Halstead Quality Control Manager, Site Kr. A. M. Contino Quality Training i Supervisor 4.3.3 QA/QC Review Team 4.3.3.1 Reviewed Brown & Root and TU Electric QC inspector qualification documents in Phase I for the original ISAF I.d.1 scope of work and for l inspectors associated with related ISAFs.
4.3.3.2 Reviewed Phase II evaluation results and determined whether individual inspectors were acceptable or required further evaluation in Phase work.
III for the original ISAP I.d.1 scope of
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i R vistan: 1 Pcgs 19 et 138 RESULTS REPORT ISAP 1.d.1 ,
(Cont'd) )
4.0 CFRT ACTION pun (Cont'd) 4.3.3.3 l Conducted Phase 11 evaluations for inspectors
,'. associated with related ISAPs and determined whether they were acceptable or required further i evaluation in Phase III.
4.3.3.4 !
i Condu.:ted Root Phase100% overview of Rf Electric /Stown &
III reinspections. l 4.3.3.5 Reviewed current Brown & Root procedures and i instructions for qualifying and certifying QC inspectors to verify compliance with FSAR requirements and reviewed the results of the TU Electric action to upgrade the QC inspector qualification records system and procedure.
4.3.3.6 Reviewed accomplishedresults of Phase III evaluations and' the following:
Identified and classified trends.
- Conducted root cause/ generic Laplication analysis.
Identified QA/QC program deviations.
Identified additional evaluations required to determine and resolve the potential impact on the safety of hardware inspected by personnel whose capabilities were indeterminate or inconclusive after Phase III evaluation.
4.3.3.7 Fersonnel Mr. J. L. Hansel QA/QC Review Team Leader Mr. J. D. Christensen QA/QC Deputy Review Team Lander Mr . J . E. Young Issue Coordinator i
, _ - - _ _ ~ _ _ _ _ . .- _
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R;vician: 1 P St 20 et 138 ISAP 1.d.1 *
(Cont'd) 4.O CFRT ACTION FIAN (Cont'd) 4.4 Qualifications of Personnel 4.4.1 QA/QC Review Team inspectors were certified to the requirements cuide 1.58. of ANSI N45.2.6 and Re5ulatory 4.4.2 TU Electric and Brown & Root QC inspectors who conducted the Phase III reinspections were certified at loa.st Level II in accordance with applicable '!U Electric and Brown & Root inspector certification requirements.
4.4.3 SET personnel had, as a minimum, 5 years of management /oupervisory level experience in QA/QC, and met the qualification requirements specified in the CFRT Program Plan. .
4.4.4 QA/QC Review Toaa personnel met the qualification requirements specified in the CFRT Program Plan and had, where required, prior experience in the area of inspector qualification / certification and training.
4.5 Procedures The following QA/QC Review Team procedures and instructions were applicable to this action plan:
QI.005, "Evaluation of Inspector Forformance" CFF 025, "QC Inspector Qualification Evaluation" 4.6 itar.dards/Accostance Criteria Per FSAR commitments, the following standards / acceptance criteria applied to this action plan:
CPSRS Quality Assurance Program Requirements Regulatory cuide 1.58, Revision 1 ANSI N45.2.6 1978 ASME Code Requ.t;rements ASNT SNT TC 1A O
Revisten: 1 Pego 21 of 138 ISAP 1.d.1 l (Cont'd) 4.0 CFRT ACTION FIAN (Cont'd) 4.7 Decision Criteria There were three primary decision points in the action plan. At each decision point, criteria were established to ensure that action continued to be taken on questionable items until an adequate and documented basis existed for disposition.
4.7.1 Phase I Evaluation Unless an inspector's available qualification documentation clearly met the criteria of Attschments 2 or 3, the documentation was referred to Phase 11 evaluation.
4.7.2 Phase II tvaluation Phase I concerns were evaluated along with additional ,
information provided by TU tiectric or Brown & Root to concerns. whether a basis existed for resolving the determine If not, che inspectors in question were placed into Phase III for further evaluation.
4.7.3 Ivaluation of Phase III Results The results of the Phase III reinspections were reviewed to determine if an inspector was acceptable, if there was substantial positive information available, if he was of indeterminate acceptability, or if he failed. Additional evaluations were conducted for indeterminate and failed inspectors.
5.0 IMFI.DLINTATION OF ACTION F1AN AND DISCUSSION OF RESUI.TS 5.1 Introduction The major objectives of this Action Flan were as follows:
To address the specific TET concerns stated in $$ER 7 by assessing the qualifications of all TU Electric electrical QC inspectors and assessing the qualifications of all ,
current QC Brown & Root QC inspectors and current TV Electric inspectors.
! These assessments comprise the original scope of '.SAF,I d.1.
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RevisLon: 1 Pago 22 of 138 RESULTS REPORT ISAP !.d.1 (Cont'd) 5.0 IMF1JMEFTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (C To evaluate the adequacy of the qualifications of all inspectors identified during documentation reviews associated with ISAFs VII.c, VII.a.8, VII.b.1, and VII.b.3. These evaluations provide additional infocuation regarding the validity of the documentation that was reviewed during the implementation of these ISAFs.
To determine the overall adequacy of the CPSES QC inspector certification program utilising the data from the evaluations described above and the results of ISAF I.d.2.
In those cases where inspector qualifications could not be verified by Phase I and Phase II evaluations of the applicable certification files, a Phase III reinspection of a portion of each such inspectors work was initiated to confirm the capability of the inspector to con het the required inspections. Additiemal evaluations were required to be conheted to identify the impaat on the safety of affected equipment for those inspectors who failed Phase III.
Implementation of this Action Plan was complemented by ISAP I.d.2, which evaluated the adequacy of the current TU Electric QC inspector certification program (both procedures and implementation) in meeting FSAR commitments.
In addition, during the course of the implementation of ISAP 1.d.1. the current Brown
& Root QC inspector certification procedures were reviewed to verify the adequacy of the current Brown & koot QC inspector certification program.
The combined results of ISAP 1.d.1 and ISAP 1.d.2 provide the basis for final conclusions on the past adequacy of the TU Electric and Brown & Root QC inspector certification programs reported in Section 6.0 of this Results Report.
The results of the implementation of this Action Plan are described in this Results Report as follows:
Section 5.2 - original I.d.1 Scope Section 5.3 Evaluations Associated with Related ISAFs e
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R:vistan: 1 RESULTS REPot?
Pcgo 23 of 138 ISAP I d.1 (Cont'd)
O 5.0 IMPf2GNIATI00f CF ACTION FIM AND DISCUSSION O Section 5.4 other Actions 5.4.1 Review of Brown & Root QC Inspector certification Procedures 5.4.2 - Qualification Records System Review 5.2 Oriainal I.d.1 Scone _ -
The original scope of ISAP I.d.1 consisted of the evaluation of all TU Electric historical and current electrical QC inspe<, tors, all Brownremaining current
& Root QC TU Electric QC inspectors, and all current inspectors.
During the implementation of this portion of this Action Plan, inspector qualification doctments for a reviewed.*
were total of 319 TU Electric and Brown & Root QC inspectors Implementation of this portion of the Action Plan began in October 1984 and was coupleted in January 1987. During the O course of the activities, the roles of the various groups responsible for implementing the Action Plan (TAC, SET, and the QA/QC Review Team) changed and evolved.
Nevertheless, the work was still conducted in three phases, as prescribed in Sections 4.1.1, 4.1.2, and 4.1.3 of the ISAP. The following sections describe the methodology and results of the work that was conducted during each phase.
5.2.1 Phase I .
During Phase I, training, qualification, certification and reeertification files for all TU Electric historical electrical QC inspectors and all current TU Electric and Brown & Root QC inspectors were reviewed.
Thirty four of these 319 inspectors were current Brown & Root inspectors who were also certified by TU Electric. Thus there were actually only 285 individuals who were certified inspectors.
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R:visien: 1 REsVLTS REPORT 'C83 2' 8f 138 ISAP I,d.1 (Conc'd) '
$0 IMFLDGNTATION OF ACTION PLAN AND DISCUSSI006 0 Table 1 details the numbers and types of QF. inspectors
. whose certification packages were reviewed during the Laplementation of Phase I by the QA/QC Review Team.
Documentation of Phase ! reviews for each of the 319 inspectors files. is contained in the ISAF I.d.1 Results Report O
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R3visten: 1 Pao. 25 of 138 ISAF I.d.1 (Cont'd) 5.0 INFIJMINTATION OF ACTION PLAN AND DISCUSSION av i
QC INSPECTORS REVIIVED DURING PHASE I ORICIMAL I.d.1 SCOPE 1.
TU Electric Total
- Historical Electrical QC Inspectors (Non.ASK!) 86 2.
Current TU Electrie QC Inspectors (Non ASME) 166 Total
- Electrical 33 Reviewed I&C/ Radiation Waste Management System -
4 Reviewed <
NDE/Thermolag 6 Reviewed Civil 2 Reviewed Protectiva Coa:ings 13 Reviewed i Test laboratory .
6 Reviewed Mechanical 44 Reviewed Level III 24 Reviewed Brown & Root QC Inspectors Maintainit.g i TU Electric Certs (Milti's) 34 Reviewed i
Note:
These 34 inspectors are alsa included with the 67 current Brown & Reet QC Inspectors noted in Itast 3, below, f 3.
Current Brown & Root QC Inspectors (ASNR) 67 Total
- 4 Total Nunber of Inspectors Reviewed 319
- NOTE:
, Current of MarchTU11,Electric 1985. QC inspectors are those employed onsite as *
, TU Electric aistorical electrical QC 4
inspectors are those who were not en the March 11, 1985 list and 1 were employed prior to that date.
inspectors are those eeployed easiteCurrent Brown & Root QC as of March 20, 1985.
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R: vision: 1 l Pass 26 of 138 ISAF I.d.1 (Cont'd) l 5.0 IMFI.ENINTATION OF ACTION FIAN AND DISCUSSION OF RE of the 319 inspectors reviewed during Phase I, only 17
- Brown & Root inspectors stintaining TU Electric QC certifications, one cost lab inspector, one TU Electric aschanical inspector, and one historical electrical inspector were not advanced into the Phase II evalustion.
5.2.2 Fhase II The objective of Phase II was to evaluate qualifications further that could not be verified in Phrse I amd. based on the results of that evaluation, determine whid.
inspectors required further evaluation during Pho a III.
In the case of TU Electric QC Inspectors, the SET reviewed the results of the Phase I screening process condueced by the QA/QC Review Team and, based on this review, resolwd some concerns and documented the remaining concerns on j Inspector Certification Evaluation Summaries (ICES).
These forms were transmitted to TU Electric for further i action and resolution of the outstanding concerns. !
Attachment 4 categorizes the concerns regarding TU Electric inspectors that were identified during Phase I ;
and evaluated during Phase II by number and type.
In the case of Brown & Root QC Inspectors, the SET worked directly with Brown & Root personnel to evaluate and resolve the Phase I evaluation results prepared by the QAAC Review Team. After review of the concerns and resolution of these concerns where possible, the SET documented the results on ICES for each inspector.
At*e hment 5 categorises the concerns regarding Brown &
Root QC inspectors that were identified durf.ng Phase I and evaluated during Phase II by number and type.
After receiving TU Electric responses to concerns l
regard!.ng TU Electric inspectors on 1C13 and after coupletion of the ICES by the SET for each Brown & Root QC inspector, the Review Team laader, the Deputy Review Team Leader, or the lasua Coordinator reviewed the ICES to
( determine which inspectors were acceptable and which inspectors required further evaluation in Phase III. In the e,ase of Brown & Root QC inspectors, 65 of the total of 67 inspectors. evaluated in Phase II were determined to 9'
Revision: 1 RESULTS__p!=ojt ISAP 1.d,1 (Cont'd) 5.0 IMPLDGNTATION OF ACTION PLAN AND DISCUSSION O have acceptable qualifications at the completion of the Phase 11 process.
For TU Electric (t inspectors, 191 of
. 232 inspectors evaluated in Phase II wot;e determined to have sectptable qualifications. The majority of concerns .
resolved during Phase II evaluations related to the following Root typical actions taken by TU Electric or Brown &
as applicable:
Missing, misfiled or backup documentation that related to activities or items such as on the job trainine, examinations, recortifications, and physical examinations were located and placed in the files Education and/or experience that had not previously been verified was verified.
Additional information regarding related work experience was obtained.
, Detail. regarding lapsed certifications or lapsed physical examinations were provided for O evaluation.
Table ? categorides the 43 inspectors that were placed into Phase III as a result of Phase II evaluations.
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Revision: 1 Rg3UI.TS REPORT Pogo 28 of 138 ISAP I.d.1 (Cont'd) 5.0 IMPI2MINTATI0tt OF ACTION PLAN AND DISCUSSION OF R
. TABLE 2 QC INSPICTotS PTACED IFf0 PHASE III
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ORIG!ltAL I d.1 SCOPE Inspector Certification Number to Phase III TU Electric Historical Electrical QC Inspectors 22 Current TU Electric QC Inspectors Electrical y 7 I&C/ RUMS 1 -
NDI/Thermolag 2
Civil 0
Protective Coatings 1 Test Laboratory 0 Mechanical 3
Level III 4 Current Brown & Root QC Inspectors Maintaining Non ASME Ceres (Hilti's) 1 Current Brown & Root QC Inspectors 2 Total Number of QC Inspectors to Phase III 43 l ..
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Revision: 1 153UI.TS REPORT ? css 29 of 138 ISAP I.d.1 (Cont'd)
O 5.0 IMPIRGNTATION OF ACTION PIAN AND DISCUSSION O During the Phase I and Phase II evaluations, a probles was identified that was closely related to QC inspector qualifications but which was not directly tied to individual inspector capabilities. For the purposes of this report, has been termed the "NDE exclusion" Three probles.this proble electrical inspection procedures for conduit, cable tray, and cable tray hangers contained requirements for visual inspection of welding during varying periods of time from December 1978 to December 1979. During these periods of time, the procedures did not clearly specify that welding inspections were only to be conducted by inspectors certified to inspect AUS welds visually. During these same periods of time, electrical inspectors were trained and certified to those same procedures but in a number of
- ases were not trained and certified to coaduct the welding inspections required by the inspection procedures.
Although the inspector certifications issued to these inspectors for these three procedures did not exclude welding inspection, the certification backup documentation l
i O clearly did. Although TU Electric was of the opinion that inspection personnel during these periods of time clearly understood that welding inspections covered by these procedures could only be conducted by inspectors certified to inspect AUS welding, the procedwas and certifications were not clear that this was the case. Although the 'NDE exclusion" problem is primarily related to a lack cf clarity in the three inspection procedures, the QA/QC Review Team decided to place inspectors without welding inspection qualifications and who had been certified to these proceaures during this ties frame into Phase III.
The purpose of placing the inspectors into Phase III was to determine if welding inspections were or were not conducted by unqualified elect:ical inspectors. A detailed explanation of this probles and the results of l the evaluation is in the Summary of Phase III Results for i Oriainal I.d.1 Scope beginning on Page 37.
Attachment 6 provides tescriptions nf why each inspector i
was placed into Phase III. However, the reasons may be summarized as follows:
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Revisten: 1 Pago 30 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) 5.0 IMFIJNINTATION OF ACTION PIAN AND DISCUSSION OF Lack of experience 13 Lack of education - 8
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Failed examination -
8 NDE exclusion - 6 Lacked experience and NDE exclusion - 4 Lack of experience and education - 4 i
i Except for nro Brown & Root inspectors, all of these
) inspectors were TU Electric QC inspectors (non ASMI). The two Brown & Root inspectors were claced into Phase III
- because scored. of failed examinations that were incorrectly i
5.2.3 Phase III
{
- The objective of the Phase III evaluations was to i determine whether the inspectors were able to conduct inspections satisfactorily despite weaknesses in their documented qualifications. A further objective was to I determine whether additional evaluation and/or inspection i of hardware was required if inspectors were incapable of I
conducting inspections or if inspectors were identified l whose abilities to conduct inspections properly were indeterminata.
Whra
- an individual irspector was identified as requiring a
.hase III evaluation, the QA/QC Review Teas requested that IT Iloctric provide a chronological listing of the inspections performed by the inspector during the first 90 days after issuance of the questionable certification or for the first 50 inspections, if less than 50 were conducted in the inicial 90 day period. Only reinspections that were of a type appropriate to nearurs the ability of the inspector in the area of questionable certification were utilised. In the cases that involved failed examinations or NDE exclusions, only the specific types of inspittions in which the certification problem occurred inspections. were utilized to obtain the required 50 O
Revision: L
. RESULTS RIP RT Psg3 31 of 138 ISAP I.d.1 (Cont'd) '
5.0 INFIBGNTATION OF ACTION PLAN AND DISCUSSION OF IF,$J1, To provide the required listins for eacii inspector, TU Electric obtained a print out from a site CL* cerized l
- 1 data base from which a listing of inspections corducted by '
individual TU Electric inspectors can be obesined, Utilizing the print out, TU Electric then obtained copies i of the inspection reports that document the inspectiens on j che print out and reviewed them to identify 1 1
non recreatable and inaccessible inspections. As a minimum,10 percent of this ins',,ection identification and report evaluation work conducted by TU Electric was reviewed by the QA/QC Review Team to deterisins adequacy.
TU Iloctric then provided the listing of accessible and recreatable inspections to the QA/QC Review Team, along with associated drawings, QC inspection procedures, and inspection reports completed by the inapector in question.
Prior to conducting the reinspections, each applicable checklist attribute was reviewed by a QA/QC Review Tese uvel III inspector and a TU Electric or Brown & Root QC representative and was identified as a recreatable or nonrecreatable attribute and as an objective or subjective attribute as defined by Section 4.1.3 of this Results Report.
i The reinspections were then conducted by an appropriately qualified TU Electric or Brown & Root QC inspector who had not been personally involved in the inspection activities in question.
The reinspections were all witnessed and the resulta recorded on reinspection escrix forms by qualified QA/QC Review Team inspectors. The reinspection matrix forms
, identify applicable inspection attributes, whether the i attributes are nonrecreatable or inaccessible, whether the attributes are objective or subjective, the results of the original inspections, and the results of the reinspections. Typical disagreements noted between the original inspections and the reinspections included the following:
Hardwar. iteam with discrepant conditions not noted during the original inspection.
Requirespnes the. were in effect at tn. cle 4 the cuginal inspection were used so identify these conditions. If the noted conditions were stin,, discrepart. in terms of the latest O
k Revision: 1 Pogo 32 of 138 RESUL.TS REPORT ISAF 1.d.1 (Conc'd) '
5.0 IMFI.IIGNTATION 07 ACTION P!aN AND DISCUSSION OF RESUI.T5 (Con inspection requirements the cowlition was s documented in accordance with TU Electric or 3rown & Root nonconformance procedures.
Failure af the inspector to document the inspection properly.
Examples include failure to record required inspection information correctly, such as ,
material traceability or identification numbers, specification or drawing numbers and revisions, and failure to record properly the inspection of each attribute requiring inspection.
In addition to the reinspection astrix forms, the QA/QC Review Teen prepared a data base repore for each reinspection. This data base report recorded the number ,
of satisfactory decisions made by the original inspector along with the number ef unsatisfactory decisions made.
l The totals from these forms provided the numbers fror l which the final disagreement rates for each inspector were calculated. It should be noted that multiple decisions may be associated with an attribute. For example, if an ites contained six welds and the attribute to be inspected '
i involved chx hing for weld site, this attribute would have l six decisions aseocisted witt. it. If one weld was under l size that was missed 'ny the original inspector and the
! remainder wre satisig: tory, there would be five correct decisions .411 one weatisfactory decision. The final disagroceent rates in percent for an inspector were calculated by dividing the total number of unsatisfactory decisions b:: the total number of decisions and multiplying by 100.
A separate verific'ation of the accursey )f the TU Electric computer data base used to identify the lista of insysettons for inspectors was onducted bf the QA/QC Er.iew Team. h TU Iloctric computer daea base was originally developed to provide TU Eltetric Operations with listings to plant of construction generated doeunents relating equipment. Its purrese was nat to identify inspections conducted by in61viduct inapectors. The data l base is, however,
- che only cormentant mechaniac available l 0 t i
_ _ _ _ _ _ _ - - - - - - - - - - - - - - - - - - - - ^ ^ ~ ^ ^
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Revision: 1 Pags ?3 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) '
5.0 IMPLEMINTATION OF ACTION PIAN AND .nt'd) DISCUSSIO to obtain this information other char :.9 the manual examination reports. of a large number of indiv11ual inspection This verification consisted of selection of 113 inspection Inspection.R6 reports from 1979 through 1986 from TU E M eric port logs. Individual ins;4ccors ver identified from the inspection reports. It was then '.an determined if these inspections were included in the computer data base.
where over 80s Except for two years (1980 and 1981),
of the reports were included, substantial omissions in the verification process. data base were ideneifisd during this The potential incompleteness of the data was considered during evaluation of the Phase III data and isReport.
the Results identified where applicable in this section cf The following paragraphs summarise the results of the Phase III evaluations. Results of the Phase III -
evaluations for each inspector have been categorised is one of the following four ways:
Acceptable or Of No Concern i
In these cases, either the targeted number of 50 reinspections have been successfully completed or other factors eliminate have been identified that any concern. For example, there would be no concern if there was evidence that an inspector did not conduct any inspections in the area of a nuestionable certification.
Substantial Positive Informathn In these cases, there is a suhetantial amount of information indicating that an inspector was capable of properly conducting required inspections or that the inspector never conducted inspections in the area of concern.
However, the because cf the lack of completeness, available information is noc conclusive.
i An example would be the case of an inspector for which only 27 recreatable inspactions instead of the :argeted 50 could be identified all of whic i were successfully reinspected within the
, alidand disagreement cstea.
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Revision: 1 RESUI,TS RCPgop Pego 34 of 138 ISAf I.d.1 (Ccnt'd) -
5.0 IMFIRGNTATION OF ACTION FIM AND DISCUS 3 ION Indeterminate In these cases, there is insufficient
- information to make any datera104 tion of an inspector's capability. An example would be if no recreatable or only a ass 11 nua;.or of recreatable inspections could be conducted, leaving the ability of the inspector tom onduct the required inspections properly unknown.
Failed In thsse cases, there was less than a 954 agrecaent rate for objective type attributer or 909 for subjective type attributes after sample expansion es specified in Section 4.1.3.
TU Electric Histories 1_ Electrical 00 3 apeeton Twenty two TV Electric historical f/* inspectors were referred to Phase III for further evaation.
. The
'atailed reaults of these Phase III eva. tations, including the reintpection resulta, are described 1. Attachment 7.
The thesefollcwing inspectore. cable depicts the evaluation results for i
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(Cont'd) 5.0 IMFMNENTATION OF ACTION PIAN AND DISCUSSION OF RESU
. TABLE 3 e
TU Electric Historical Electrical QC Inspector Phase III Evaluation Results INSPECTOR EVALUATION P43'JLT IM3TECTOR EVALUATION RESULT HE-1 NDE Exclusion HE.12 Acceptable, NDE HE 2 Itxlaterminate Exclusion HE 3 HE-13 Indeterminate No Concern HE 14 HE 4 Indeterminate Accestable
.HE ! HE 15 NDE Exclusion Acceptable RE 16 HE 6 Indeterminate NDE NDE Exclusion ME 17 Acceptable Exclusion HY. 7 Acceptable HE 8 HE Il Indeterrinate Failed HE 9 HD19 Indatetuinate teemptal'.e HJ 20 No Concern, NDE HE 10 Exclaston Substantial Positive HE 21 Substantial Positive.
HE 11 Acceptable NDE Exclusiot.
HE 22 Subatantial Posi.tive TU Electric current Electrical QC Inspectors Seven TU Electric current electrical QC inspectors were referred to Phase III for further evaluation. The detailed results of these Phass III evaluations, incivding the reinsoection results, are described in Attachment 8.
The follow 1 q table depicts the evaluation results for tAaea inspectors.
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TABLE 4 TU Electric Current Electrical QC Inspector Phase III Evaluation Results INSPECTOR.
l EVALUATION RESULT CE 1 CE 2 Substantial Positive No Concern CE 3 CE 4 Substantial Positive Acceptable CE 5 CE 6 NDE Exclusion No Concern CE 7 Acceptable -
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TU Electric Current I&C/ Radiation Waste Management ' v. au (R'JMS) QC Inspectors One insyctor, IC 1, was placed into Phase III for waluation. The detailed results of this evaluation, including reinspection results, are dancribed in Attachment 8. IC-1 was evaluated to be acceptable.
,TU Electric Current NDE/Thermolcz QC Inspectors Two inspec uts, R 1 and Irt 2, were placed into Phass III for evaluation.
Attachment 8. The detailed results are described in l acceptable. Irf 1 and NT-2 were both evaluated to be TU tiectric Current Protsetive Coatinas QC Inspectors _
One inspector, PC 1, was placed into Phase III for m luation from this grouping. The detailed results are described in Attach *ent 8. PC 1 was of no concern.
TU Electric Current Nechanical QC Inspectors Three inspectors were rtfarred to Phase III for further evaluation froii*this gro sp. The detailed evaluation results are described in Attachment 4. The following table depicts the evaluation results.
Revision: 1 Pass 37 of 138 ISAP I.d.1 (Cont'd)
O 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSIO TMu 5 TU Electric Curr5nt Mechanical OC Insoectors Evaluation Resu INSPECTOR EVALUATION RESULTS NM 1 Acceptable NM 2 NM 3 Indeterminate NDE Exclusion s.
TV Electric current Level III OC Insoectors 1here were Phase III. four inspectors in this category placed ince' in Attachment The 8. detailed evaluation results are described The following table depicts the results of the evaluations.
O TAALE 6 TU Electric current Level III OC Inspectors Evalstion Results INSPECTOR EVA12ATION RESULTS L1 No Concern L2 No Concern L3 L4 No Concern NDE Exclusion Current Brown & Root OC Inspectors Maintainina TU Electric Cer:ific.ations (Hilti Boles)
One Hilti bolt inspector, HB.1, required Phase III evaluation in this category. Detailed evaluation results are discussed in Attachmest 8. HB 1 was evaluated to be of no concern l...
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Revision: 1 Pego 38 of 138 ISAF I d.,1 (Cont'd) 5.0 JMFLEIGNTATION OF ACTION FLAN AND DISCUSS Current Brown di Eoot QC Insoectors Two from inspectors, this categorAM 1 and AM 2, were placed into Phase III be of no concern.y AM 1 sad AM-2 were both evaluated to Details are contained in Attachment 9.
_ Summary of Phase III Results for Oriainal I.d.1 Scope Ten inspectors NDE were evaluated in Phase III because of the exclusion probles.
h inspectors are HE 1, HE 6, HE 12, HE 15, HE 16, HE 20. HE 21, CE 5, NM-3, and L e.
h inspection procedures involved were QI-QF 11.3 4, "Exposed Conduit, Condulet. Electrical Box and Support Inspection"; QI-QF 11.3-5, "Cable Tray Inspections"; and QI-QF-11.3 2, "Cable Tray Hanger Inspection". N first two procedures visual did not originally contain requirements for weld inspection. In December 1974, QI-QF 11.3 4 was revised to include visual inspection of welds.
QI-QF 11.3 5 was similarly revised in January 1979.
QI-QF 11.3 2 was originally issued in June 1978 and included requirements for visual inspection of welds.
Although it was TU Electric's practice to use only AWS 3 Level II certified inspectors to conduct these T
, inspections, these three procedures did not clearly define this practice, and the inspection checklist included an
( attribute for the visual inspection results to be recorded.
l h oe procedures were revised in December 1979 to exclude visual welding inspection clearly from their scope.
During the evaluation, five instances were identified in which visual weld inspections were conducted by inspectors HI 1 and HE 12 during this cias period.
Because of inaccuracies in the computer data base, it is likely that cases other than those identified during the Phase III evaluation exist. Also, inspectors certified prior to December 1978 to QI.QF 11.3 4 or prior to January 1979 to QI-QP 11.3-5 without qualification to conduct visual welding would not have been identified for Phase III evaluation by the QA/QC Review Team because the l procedures at that time did not contain requirements for visual weld inspection. However, following the procedural revisions that added visual welding, these same inspectors would have been subject to the same NDE exclusion problem as those identified by the,QA/QC Review Team for Phase III 1
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Rovtston: 1 Pego 39 of 138 l RESULTS REPORT ISAF I.d.1 (Cont'd)
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INFIEGNTATION OF ACTION FIAN AND DISCUSSION OF R l evaluation after the procedure revisions. It is concluded that, because of the procedural weaknesses identified i
above, a small percentage of welds visually inspected in eccordance with QI QF 11.3 2, QI-QF 11.3 4, and QI-QF-11.3-5 between December 1978 and December 1979 wer inspected and accepted by unqualified inspectors. QA/QC Program Deviation Report PDR 56 was written to document this condition.
QA/QC Program Deviation Report PDR 70, involving inspector IC-1, was issued to document the lack of definitive procedural requirements relating to the identification of instrumentation supports.
Of the 22 TU Iloctric historical electrical inspectors referred to Phase III, six have been verified to be acceptable and capable of satisfactority conducting inspections because the targeted number of reinspections were limitsconducted andISAF specified by the results I.d.1. were within the error One inspect;or had 49 instead of the targeted 50 reinspections. It is felt that there is sufficient information to judge that this O inspector was capable of conducting the required inspections. Two inspectors were determined to be of no concern because work is to be reinspected as part of a corrective action program or no work had been conducted in the area of concern. An additional three inspectors were only involved with the NDE exclusion probles noted above.
One inspector did not have the required 50 reinspections but had 28 reinspections.
There is a substantial amount of information available that this inspecent was capable of satisfactorily conducting inspections. Two other inspectors had the required 50 reinspections with acceptable results but, because of the cias periods which elapsed between their initial certifications and the reinspections, there is a lack of conclusive evidence that they were initially capable of conducting the required inspections. However, there is a substantial amount of positive acceptable.
evidence that they were both initially Six inspectors were considered to be indeterminate as to their ability to satisfactorily conduct inspections. For four of these six, only non recreatable cable pulling and neggering inspections were identifie'd. For the remaining two indeterminate O
Revision: 1 Pago 40 of 138 ISAF I.d,1 (Cont'd) 5.0 IMPLDGNTATION OF ACTION PLAN AND DISCUSSION OF inspectors, no recreatable inspections could be identified for one and one had only 12 recreatable inspections with an objective error rate above the acceptable limit (7.294 versus-54 required). One inspector failed Phase III based upon the combined results of an initial group of 50 reinspections and a second group of 50 reinspections.
Thors was a total of 19 TU Electric current QC inspectors referred to Phase III. Three of these inspectors have been discussed above in the description of the NDE exclusion issue. Six of these inspectors
! have been verified to be acceptable and capable of satisfactorily conducting inspections because the targeted number of reinspections were conducted within the error limits specified by ISAF I.d.1. Another seven were judged 1 to be of no concern because they had either not conducted inspection related activities, had not conducted safety related inspections or the area o* concern is to be ;
reinspected as part of a corrective action program. For one inspector there was substantisi positive evidence that this individual did not conduct inspections involving discrepant certifications and for one inspector, 21 reinspections provided substantial pos!tive information that this individual was capable of conducting the required inspections. The capability of one inspector was indeterminate.
In the case of Brown & Reet current QC inspectors (ASME).
one inspector was verified to be of no concern because no inspections were conducted which involved the certification in question. The second inspector was also of no concern because the musber of inspections were limited and were restricted to simple activities or l conducted under the direct supervision of a qualified 1avel II inspector.
The overall results of the Phase III evaluations, as described above, are suunarised in Table 7.
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Revisien: 1 Pag 2 41 of 138 ISAP I.d.1 (Cone'd) 5.0 NATION OF ACTION PLAN AND DISCUSSION OF RESU TABLE 7 i
SUlWARY OF PHASE III EVAMfATION RESULTS 1.
NDE Exclusion' - Problems identified with 2 of 10 inspectors indicate further evaluation is required.
2.
TU Electric Historical QC Inspectors Acceptable or No Concern 9
Indeterminate
- 6 NDE Exclusion Only (see 1 above) 3 Substantial Positive Information 3 Failed 1
TOTAL 22 3.
TU Electric Current QC Inspectors (Includes Brown & Root Current QC Inspectors Maintaining Non ASME Certifications)
Acceptable or No Concern 13 Indeterminate
- 1 NDE Exclusion only (see 1. above) 3 Substantial Fositive Information 2 TOTAL 19 4
Brown & Root Current QC Inspectors Acceptable or No Concern 2
TOTAL 2 O
Revision: 1 RESULTS REPORT Pess 42 of D8 ISAP I.d.1 (Cont'd) 5.0 IMFIRENTATION OF ACTION P!AN AND DISCUSSION OF R 5.3 Evaluations Associated With Related ISAPs As described in Section 4.2, all inspectors who were identified during documentation reviews associated with ISAPs VII.c, VII.a.8, VII.b.1, I.d.1 type and VII.b.3 were subjected to a three phase evaluation.
associated with each ISAP are as follows:The numbers of evaluated insp ISAP VII.c -
237 ISAP VII.a.8 -
19 ISAP VII.b.1 -
J Total 268 Seven inspectors were identified that were associated with 1547 '
VII.b.3.
However, all seven had previously been evaluated with ISAPs VII.c, VII.a.8, or the original scope of ISAP I.d.1. In addition, a significant number of inspectors who were identified in association with ISAPs VII.c, VII.a.8. and VII.b.1 had already been svaluated in the original scope of ISAP 1.d.1 and are not included in the above numbers. For the purposes of this portion of the report, the inspectors have been grouped as TU Ilectric historical QC inspectors, Brown & Root historical QC inspectors, and subcontractor QC inspectors. Historical QC inspectors are, as for the original I.d.1 scope TU tiectric QC inspectors who terminated employment prior to March 11, 1985 inspectors who carminated employment prior to Marchand 20,Brown 1985 & Root QC .
Six inspectors (three TU Electric and three Brown & Root) were I identified that should have been classified as current inspectorse
( Of these six, one was hired after the March 1985 princ outs were issued, four worked in receiving inspection and were not included in the March 1985 print outs, and one was inadvertently left out of the original ISAP 1.d.1 scope of work by the QA/QC Review Team.
None of these six were sent to Phase III evaluation and, for ease of reporting, are included with the historical inspectors evaluated during this portion of the work.
Although they are included with the historical inspectors in this portion of the report, they have been properly categorized as current inspectors in the overall suanary of results contained in Section 5.6.
The evaluations were conducted in three phases, as described in Sections 4.2.1, 4.2.2,, and 4.2.1 of the ISAP.
The following sections describe the 'iiechodology and results of the work that was conducted during each phase:
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RR3ULTS REPomT Pag 8 43 of 138 l ISAP I d.1 (Cont'd) 5.0 IMPIRGNIATION 5.3.1 OF ACTION PLAN AND DISCUSSIO Phase I During Phase I, training, qualification, certification and recortification files for all TU tiectric, Brown & Root, and subcontractor QC inspectors associated with related i ISAPs (ara not previously evaluated under the original scope of ISAP I.d.1) were reviewed by QA/QC Review Team personnel assigned to the ISAP I.d.1 Issua Coordinator.
In addition, these same personnel reviewed DRs related to :
QC inspector certification referred to them from ISAPs VII.c, VII.a.8, VII.b.1, and VII,b.3, and validated or !
invalidated them as appropriate.
Table 8 details the numbers and types of QC inspectors whose certification packages were reviewed during the implementation of Phase I reviews for this portion of the work.
Documentation of Phase I reviews for each of the 268 inspectors Report files. is contained in the ISAP I.d.1 Results One TU Electric inspector, inadvertently historical overlooked electrical in the cristnal QC I.d.1 scope of evaluation.
work, is included in this portion of the Of the 268 QC inspectors reviewed during the implementation of Phase I on this portion of the work, only one TU Iloctric historical mechanical QC inspector, two TU Ilectric historical civil QC inspectors, four Brown
& Root historical mechanical QC inspectors, and one Brown l &
II Root civil QC inspector were not advanced into the Phase evaluation, t
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TA31.E 8 QC INSPECTORS RIVIEVID DURING PHASE I RIIATED ISAPs
- 1. TU Electric Historical QC Inspectors Electrical Nechanical 1 Reviewed Civil 49 Reviewed 15 7.aviewed
- 2. Brown & Root Historical QC Inspecccra Mechanical Civil 136 Reviewed 20 Reviewed
- 3. Subcontractor QC Inspectors
- 1. W. Hunt Chicago Bridge & Iron 8 T.eviewed Nason Johnston 6 Reviewed Freese & Nichols 13 Reviewed Bahnson 6 Reviewed 14 Reviewed
- 4. Total lhaber of Inspectors Reviewed - 268 1
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Revision: 1 Pegn 45 of 138 ISAP I.d.1 (Cont'd)
O 5.0 IMF12GiffATIC3 OF ACTION FIAN AND DISCUSSION O Results of the Phase I reviews were documented on ICES by
! the QA/QC Review Team and transmitted to TU Iloctric f further applicable.
action and resolution of outstanding concerns, where:
Specific concerns identified in validated DRs related to QC inspector certification were included in the ICES.
portion of the work were similar in nature to thoseThe conc depicted in Attachments 4 and 5.
During Phase I review of DRs, a probles regarding proper documentation of weld fit up, weld joint alignment, and finished was joint inspections by Chicago Bridge & Iron (CB&I) identified, h ea inspections were documented on a temporary form by the CB&I inspectors and the results transferred by a QA supervisor onto a permanent record.
The temporary forms were then destroyed and there was ao record of who conducted the inspection nor the initial results of the inspection.
QA/QC problem. FDR 7 was issued documenting the inspection recor Additional research including interview of a CB&I supervisor, was conducted by the QA/QC Review Team.
- i. A list of all inspectors was developed and the qualifications of these inspectors reviewed. It was determined that they all had adequate qualifications to conduct the subject inspection. Based on the qualifications of the personnel, the C&6I procedures, and the interview, it was concluded by the QA/QC Review Team that the required inspections were conducted by personnel who were adequately qualified to perform the work.
5.3.2 Phase II As for the original I.d.1 scope of work, the objective of Phase 11 for this portion of the work was to evaluate qualifications further that could not be verified in Phase I and, based on the results of that evaluation, determine which III.
inspectors required further evaluatico during Phase l
Upon receipt of the ICES from the QA/QC Review Team, TU Electric conducted additional investigations of the identified concerns and provided written responses to these concerns along with,any additional relevant information wftish might be useful in resolving the concerns. After receiving TU Electric responses to i l
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Rovisien: 1 Fogo 46 of 13g RESULTS REPORT ISAF I.d.1 (Cont'd) 5.0 IMFIENINTATION OF ACTION FIAN AND DISCUSSION OF RSSUL concerns re5arding the QC inspectors, the Issue Coordinator or the Deputy Review Team Leader reviewed the ICES to determine which inspectors were acceptable and which inspectors required further evaluation in Phase III.
Of the-total of 260 inspectors reviewed during Phase II, 234 were determined to have acceptable the completion of the Phase II process. qualifications Table 9 at categorizes the 26 inspectors that were placed into Phase III during this portion of the work as a result of Phase II evaluations.
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Revisten: 1 RESULTS R.EFORT Page 47 og 13g I ISAP I.d.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSIO TA312 9 QC INSPECTORS FIACID INTO PHASE III RK1ATED ISAPs l
)
Inspector Certification l Number to Phase III I TU Electric Historical QC Inspectors Electrical Mechanical 0 Civil 9 0
3rown & Root Historical QC Inspectors Mechanical -
Civil 7 0
Subcontractor QC Inspectors R. W. Hunt Ou -
Chicago Bridge & Iron 1 Mason Johnston 0 0
Freese & Nichols Bahnson 0 J
Total Number of QC Inspectors to Ihase III 26 lO
Rovision: L RESULTS REPORT Pass 48 of 138 ISAP I.d.1 (Cont'd) 5.0 IMFLINEEATION OF ACTION PIAN AND DISCUSSION Attachment was placed 10 intoprovides descriptions of why each inspector Phase III.
summarized as follows: However, the reasons may be
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Insufficient experience - 13 Insufficient education -
6 Insufficient experience and education -
3 Failed exas -
2 Questionable work -
1 5.3.3 Phase III Thc objective and methodology for conducting Phase III i evaluations for this portion of the work was identical to that described in Section 5.2.3 of this Results Report. -
- The following paragraphs summarises the reeults of the
! Phase III evaluations which have been categorized in a l
manner work. identical to those for the original I.d.1 scope of k
TU Electric Historical Mech ==ical OC Inspectors Nine TU Electric historical mechanical QC inspectors were referredoftothe portion Phase work.III for further evaluation during this The detailed results of these Phase III evaluations are contained in Attachment 11. The following inspectors,table depicts the evaluation results for these i
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Revision: 1 REStJI.TS REPORT Pc53 49 of 138 ISAF I.d.1 O 5.0 (Cont'd)
IMPLEMINTATION OF ACTION PIAN AND DISCUSSION TABLE 10
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TU Electric Historical Mechanical QC Inspector Phase III Evaluation Results INSPECTOR EVALUATION RESUI.TS TMal Acceptable IM 2 TM 3 No Concern TM-4 Substantial Positive TM.5 Substantial Positive Acceptable TM.6 TM.7 Failed Acceptable IM 8 -
1M 9 No Concern Indaterminate j
Brown & Root Historical Mechanical QC Inspectors Seven Brown & Root historical mechanical QC inspectors were placed into Phase III during this portion of the work, the detailed results of these evaluations are
, described in Attachment 12.
the evaluation results for these inspectors.The following table de TABLE 11 Brown 4 Root Historical Mechanical QC Inspector Phase III Evaluation Results INSPECTot EVALUATION RESULTS BM 1 BM.2 Indecoruinate SM 3 Substantial Positive BM 4 Indeterminate Failed BM 5 Failed BM.6 BM 7 '.
- Substantial Positive Indaterminate O
y
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l Revision: 1 Page 50 of 138 RESULTS REPORT
(~g ISAP I.d.1 s ,)
i (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd)
Subcontractor QC Inspectors A: total of ten subcontractor QC inspectors were placed into Phase I1I during this portion of the work.
Descriptions of the evaluations for these inspectors are contained in the following paragraphs.
HU-1, who was certified by R. W. Hunt as a concrete
-inspector in June 1976, was placed into Phase III because of lack of experience. He was identified during implementation of ISAP VII.c only because his signature, transmitting test data prepared by others, was annotated l with an indication that he was a Level II inspector. This individual's actual job title was Administrative Assistant Manager and it appears, based on documentation identified during ISAP VII.c implementation, that he was not assigned responsibility for performing inspections. This was confirmed in an interview conducted with this individual l by the QA/QC Review Team where he stated that he had not l performed inspections during his employment at CPSES.
O Based on this information there is no further concern regarding this individual's ability.
Nine Bahnson inspectors, who were responsible for conducting HVAC duct and duct support inspections, were placed into Phase III. BN-1 lacked adequate education and l experience; BN 2, 3, 4, 5, 6, 7 and 9 lacked adequate i
experience; BN 8 lacked adequate education; and BN 4 had conducted questionable work while employed by Brown & Root (see BM 3) as a mechanical QC inspector. Because the Bahnson record systen did not allow ready identification of inspections conducted by indivit :41 inspectors and because a major corrective action program was being developed to correct other significant problems, no reinspections of these inspectors work were conducted.
However, QA/QC PDR 45 vos issued documenting the inadequacies of the certifications of these inspectors and requesting that these inadequacies be factored into the overall corrective action program for Bahnson installed equipment.
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Revision: 1 Pego 51 of 138
_RESULTS REPORT
(
ISAP I.d.1 I (Cont'd) 5.0 IMPI.EMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd)
Summary of Phase III Results Associated with Related ISAPs Of, the nine TU Electric historical mechanical QC inspectors evaluated in Phase III, three were determined
, to be acceptable because the targeted number of reinspections were exceeded and the results were within the specified error limits. Two inspectors were I
determined to be of no concern. For an additional two inspectors, there was a substantial amount of information available that they were capable of conducting the required inspection. The capability of one inspector was indeterminate based on the lack of recreatable inspections l and computer data base inaccuracies. One inspector failed when the reinspection results for instrumentation inspections and tubing welding inspection fell outside the acceptable error rate limits.
i Of the seven Brown & Root historical mechanical QC inspectors placed into Phase III, there was a substantial amount of positive information for two inspectors, indicating that they were capable of conducting the required inspections. Three inspectors' capabilities were ,
l indeterminate based on the lack of recreatable inspections l and computer data base inaccuracies. Two inspectors failed because of reinspection results fallins outside ISAP I.d.1 specified limits. ,
l Of the con subcontractor QC inspectors placed into Phase III, one inspector was identified as being of no concern because he did not conduct inspections. The remaining nine inspectors were from Bahnson and, because inspections conducted by individual inspectors could not be easily identified, no reinspections were conducted. A QA/QC program deviation, QA/QC PDR 45, was issusd to document the Bahnson certification inadequacies.
Three other QA/QC program deviations were issued as a result of Phase III activities for this portion of the work. QA/QC PDR 79 was issued as a result of questionable resolution of TU Electric and Brown & Root identified concerns regarding the adequacy of QC inspector certifications for QC inspectors TM 6, BM 1, and BM 3.
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Revision: 1 Pago 52 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Two other QA/QC program deviations, similar to each other, were issued. QA/QC-PDR-81 was issued when six inspections of welds on. electrical equipment supports conducted by i BM 3 and BM 7 could not be reinspected because no original I inspection acceptance criteria could be identified. In )
addition, QA/QC PDR 80 was issued when inadequate acceptance criteria for inspection of cable tray welds, !
for inspections conducted by the same two inspectors, were i also identified.
5.4 Evaluation of QA/QC Program Deviations A total of seven QA/QC program deviations were issued during the implementation of this ISAP. Each of these PDRs was evaluated by the QA/QC Review Team to determine if it should be classified as a QA/QC program deficiency. A QA/QC program deviation is classified as a QA/QC program deficiency if it meets one or both of the following criteria:
Inadequacy of a QA/QC program tienent such that
's substantive reviston of the program or other corrective action is required to bring it into compliance with the regulatory requirements, FSAR commitments, or other licensing commitments; or Extensive evaluation is required to determine the effect on the quality of construction.
'ho following are descriptions of the results of these evaluations.
l 5.4.1 QA/QC PDR 56 This PDR was issued to document the NDE exclusion problem that is described in detail in Section 5.2.3 of this Results Report. In summary, three electrical inspection procedures for conduit, cable tray, and cable tray hangers contained requirements for visual inspection of welding during the time period between December 1978 and December 1979. The procedures did not clearly specify that welding inspections were only to be conducted by inspectors certified to inspect AWS welds. During this same period of time, electrical inspectors were trained and certified to these procedures but were not trained and certified to O
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R Revision: 1 Pago 53 of 138 l RESULTS REPORT I ISAP I.d.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION P11.N AND DISCUSSION OF RESULTS (Cont'd) ;
conduct the weld inspections. During Phase III I evaluations, five instances were identified where welds were inspected by inspectors who had not been trained and certified to conduct weld inspect. ions per AVS j requirements.
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An evaluation was conducted by the QA/QC Review Team to l determine if this deviation should be classified as a QA/QC program deficiency. Based on the small number of
)
occurrences of problems, and the low probability of a major problem remaining undetected, it was concluded that neither an extensive evaluation nor extensive corrective action would be required. As a result, the PDR remained classified as a QA/QC program deviation. PDR 56 requests TU Electric to conduct.an evaluation of the potential impact of this probles'on the hardware. ,
5.4.2 QA/QC PDR-70 QA/QC Program Deviation Report PDR 70 was evaluated by the QA/QC Review Team to determine if it should be classified as a QA/QC program deficiency. This deviation, involving inspector IC 1, documented the lack of definitive requirements relating to identification of instrumentation supports. Because use of proper material had been previously verified by QC during fabrication of the support, this identification problem is not related to the !
adequacy of support material, nor is it indicative of any actual problem with the ability of the instrumentation supports to perform their function. Therefore, it was determined by of the QA/QC Review Team that neither an extensive evaluation nor extensive corrective action was required, and PDR 70 remained classified as a QA/QC progras deviation.
5.4.3 QA/QC PDR 7 QA/QC PDR 7 was issued to document that CB&I destroyed temporary forms that documented weld fit up, veld joint ;
alignment, and finished joint inspection. As a resuit, there were no records of who conducted the inspections nor 1 the results of ths initial inspections. The QA/QC Review Team identified all the inspectors who had conducted these inspections and determined that they were all adequ tely 0
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I Roviaign: 1 Pc5o 54 of 138 RESULTS REPCRT ISAP I.d.1 O (Cont'd) 5.0 IMPLEMENTATION OF ACTION PiM AND DISCUSSION OF RESULTS (Cont'd) qualified to conduct these inspections. Because neither extensive carrective action nor extensive evaluation to determine hardware impact was required, QA/QC PDR 7 remained classified as a QA/QC progras deviation.
5.4.4 QA/QC PDR-79 QA/QC PDR 79 was issued as a result of questionable resolution of the adequaev of QC inspector certifications for QC inspectors TM 6, BM 1, and BM 3. In theso esses and in others, when reinepection of work done by .{
inspectors with questionable capabilities was conducted by TU Electric and Brown (v Root, documentation of these reinspections was inconglete. Ir. addition, proper consideration of dats baire inac:uracies in identifying the original inspections was not made by TU Electric. At times, problems with individual ir.spectorm would be documented on NCRs and at other times, documentation was in the form of menos. The QA/QC Review Team determined tht.t QA/QC-PDR 79 was a QA/QC program deficiency because of the rather extensive evaluatic.ns that will be required O. of TU Electric to verify that problems with QC inspector's capabilitiis were satisfactorily resolved, thus eliminating concern regarding the impact of this problem on the adequacy of construction.
5.4.5 QA/~40 PDR 80, 81 Two QA/QC program deviations, similar to each other, were issued. QA/QC PDR 81 was issued when six inspections of welds on electrical equipment supports con heted by BM 3 and BM 7 could not be reinspected because no original inspecticn acceptance criteria could be identified. In addition, QA/QC-PDR 80 was issued when inadequate acceptanes criteria for inspection of cable tray welds, for inspections conducted by the same two inspectors, vera a'.so idsocified. Both QA/QC PDR 80 and 81 were determined +
to be QA/QC program deficiencies by the QA/QC Review Taan because of the likelihood of rather extensive evaluati - '
being required to determine the impact on the adeouscy %.-
construction.
$ ?w t c~
t n
I
R:visicn: 1 Pcg3 55 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF R'ISULTS (Cont'd) 5.4.6 QA/QC PDR 45 This PDR documented specific certification discrepancies for nine Bahnson inspectors, along with certain certification procedure inadequacies. Normsl Phase III evaluations of these inspectors were not er,nducted because i'.apections conducted by individual in.1pectors could not be easily identified. The QA/QC Review Team determined that this PDR was a QA/QC program deficiency because an extensive evalua': ion was required to determine the effect of the problems on the quality of construction. The root cause/ generic implicction analysis of this QA/QC progra.a deficiency is discursed in Section 5.8 of this Results '
Report.
The root cause/ generic impliestion analyses for QA/QC PDR-79, 80, 81, and 45 sie discussed in Section 5.8 of this Results Report.
5.5 Other Actions Conducted 5.5.1 The QA/QC Review Team reviewed the current Biown & Root QC inspector cere.ification procedures to verify that they adeq tately address ANSI N45.2.6 and Regulacary Cuide 1.58 as invoked by the FSAR. The fellowing procedures were reviewed:
CP-QAP 2.1, Revision 13 "Personnel Training and Qualificatf.on," dated February 18, 1986 QI-QAP 2.1 5, Revision 9. "Training and Certification of Mechanical Inspection Personnel," dated November ?O, 1985 including l
Document Change Notico numbers '!, 3, and /- 1 QI-QAP 2.1 1, Revision 7, "Nondestructive ;
Examination Personnel Certificat'...n," dated '
November 20, 1983, includin5 Document Change Notice number 1. !
QI-QA2 2.1-1, in conjunction with CP-QAP 2,1, covers qualification of Brown & Root NDE inspectors. These ;
procedures were reviewed and daterminsd to address the l
requirements of ASNT SNT TC-1A, 1980 satisfactorily, j QI-QAP-2,1 5, in conjenecion with CP-QAP 2.1, ce, vers i l
m m a l
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^
ISAP I.d.1 (Cont'd) 5.0 IMP 1.EMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd)
- qualification of Brown & Root mechanical inspectors.
These procedures were reviewed and determined to address the requirements of ANSI N45.2.6 1978 and USNRC Regulatory Guide 1.58, Revision i satisfactorily.
5.5.2 Qualification Records System Review During 1985, an internal action was undertaken by TU Electric to improve their QC inspector qualification records systen and procedures. This action was related to but separate from the actions prescribcd in ISAPs I.d.1 and I.d.2. -
W 51ectric acquired sn experienced training specialist to coordinate this effort. The primary output of this effort was the issuance in August 1985 of QI-QP 2,1-23, "Training / Certification Records Processing." Thi2 procedure provided requirements for d.e review, proper j access, control, safekeeping, and preservation cf training / certification records. QI-QP-2.1 23 was rerieved and evaluated as satisfactory by the QA/QC Review Team t during implementation of ISAP I.d.2. The files of carrent active inspectors were revised and upgraded by TU Electric to comply with QI-QP 2,1 23. In addition, p neric DR
- C87 Oll37 was ir ued by TU Electric to doc ment record problems in iractive training / certification files, and an ongcing effort is undarway to put these files in order.
5.6 overall Summary of Results of the 148 W Electric historical QC inspectors reviewed during Phase I and II, 31 were referred to Phase III for further examination. The Phase III evaluations determined that 17 cf these 31 were acceptable, of no concern, or were in Phase III only becotse of the NDE exclusion problem. For an additional five inspectors, there was a substantial amount of positive information that they were capable of conducting the required inspections or had not performed inspections in the area of concern. For the remaining nine 1.upectors, seven were indeterminate because of the lack o'. recreatable inspe::tions and two failed based on reinspection results.
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-. . _- . _ _ . _. _ _ _ . - - - ~
Revisien: 1 Pc50 57 of 133 RESULTS REPORT ISAP I.d.1 (Conc'd) 5.0 IMPLD(Eh?ATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd) l A total of 169 TU Electric current QC inspectors was reviewed,
, and 19 wu a placed into Phase III for further evaluation.
Sixteen wa>:e determined to be acceptable, of no concern, or were in Phase-III'only because of the NUE exclusion problem. There was a substantial amount of positive information that two inspectors were capable of conducting the required inspections.
One inspector's capability was indeterminate because of the lack of recreatable inspections.
i of the 153 Brown & Root historical QC inspectors avaluated, 7 ;
were referred to Phase III. For two inspectors, chere was a ;
substantial amount of positive iaformatiem available that chey were capable of conducting the required inspections. Threa inspect: ors' capabilitieo vers indeterminate and two inspectors F
failed based en reinspection results.
Seventy Brown & ~ me current QC inspectors vere also evaluated with the result tint two inspectors were placed into Phase III.
These two inspectors were detarained to be of no concern because of other factors.
Table 12 summarizes the rssults of the evaluation of TU Electric and Brown & Root QC inspectors described above, ,
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Rcvision: 1 RESULTS REPORT ISAP I d.1
() (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd)
. TABLE 12 OVERALL
SUMMARY
OF ISAP I.d.1 EVALUATION RESULTS Percent Percent Acceptable Substantial Number Number to or no Positive Percent Group Evaluated Percent Phase III Concern Information Indeterminate Failed
- 1. TU Electric 148 31 90.5% 3.44 4.7% 1.4%
Historical
- 2. TU Electric *169 19 98.2% 1.2% 0.e4 ..
Current
- 3. Brown & Root 153 7 95.44 1.3% 2.04 1.3g Historical
- 4. Brown & Root 70 2 loog ..
O Current j 5. Total *S40 59 95.6% 1.7% 2.04 0.7%
Personnel l Certified l
l
- NOTE -
The 169 Current TU Electric and the 540 Total Personnel Certified include 34 Brown & Root QC inspectors who were also certified under TU Electric's certification program to inspect Hilti Bolts.
l I
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Ap
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A total of 47 Fubcontractor QC inspectors wore evaluated in Phase I and II. Of these 47, 10 were placed into Phase III for further evaluation. One of the ten was an R. W. Hunt QC inspector uho was determined to be of no concern because he did not conduct inspections. The remaining nine inspectors were from Bahnson.
Concerns regarding the cartifications of these nine inspectors were documented in a QA/QC program deficiency which will be addressed by TU Electric in their Corrective Action Program to resolve concerns in the overtil work cenducted by Bahnson. No subcontractor QC inspectors frea CB&I, Mason Johnston, or Fteese
& Nichols required Phace 7t. avaluati as.
As could be expected, a higher incidence of problems that required Phana III evaluations occurred in the TU Electric and Brown & Ro9t histortes. QC inspectoi* groupings. Problems with TU Electric QC inspecte i.srticularly in the historical electrical QC inspe tor groupit. vers more prevalent, on a percentage basis, than for Brown & Root. The four inspectors who failad Phase III based on reinspection results were all in the historical DC inspector groupings, two from TU Electric and two from Brown & Root. Of the seven indeterminate inspectors, only one TU ElectrAc QC inspector fell into the current QC inspector groupings and the remainder were included in the historical QC inspector groupings.
lh 5.7 Trend Analysis A total of $87 inspectors who were certified by TU Electric, Brown & Root, and subcontractors were included in Phase I and Phase II evaluations associated with the oriB inal ISAP I.d.1 scope and related ISAPs.
These evaluations determined that the qualifications of 69 inspectors required further evaluation in Phase III to determine whether, despite devia tions from qualification requirements, they were capable of satisfactorily conducting inspections for which they were certified. The substantial number of inspectors failing the Phase II evaluations is considered to constitute a trend. This trend can be furr.her depicted by organizations as follows:
TOTAL NUMBER TO PERCENT TO ORGANIZATION EVALUATED PRASC III PRASE I[I TU Electric 317 50 l', . 8 %
Brown & Root 223 9 4.0%
Subcontractors 47 10 ;.l.3%
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Page 60 of 138 RMtf2.TS D.EP,CE ISAP I.d.1 (Cont'd)
V) r 5.0 IMPLEMENTATION OF ACTION F E AND DI$CUSSION OF TESULTS (Cont *d)
The following see.tians describe the results of che trend analyses for TU Electric, Arown & P.oot, and the subcentracec,rs:
5.7.1 TU. Electric A total of 50 TU Electric QC inspectors, out of 317 evaluated, were placed into Phase III. Of these 50 inspectors, 40 were avaluated in Phase III to be acceptr.ble, of no concern, or there was substantial positive information that they were t:apable of performing the required inspections. Two inspectors failed but the root cause analyses, contained in Secticn 3.8, indicaced that only one of the two failed inspectore is cause for concern. Eight cf the $0 inspectors eho vera evaluated 1.n .
Phase III were indeterminate because of the lack of recreatable inspections. Six of the eight indeterminate inspectors were historical electrical inspectors, one ves a historical mechanical inspector, and ona was a current mechanical inspector.
Five of the sit indeterminate electrical inepectors conducted a substantial number of cable pullin;;
- O inspections. Most of the important attributes related to cable pulling are nonrecreatable. Far example, checking that the raceways were free of cable pulling hazirds, verification that conduit raceways were swabbed, verification of cable lubricant type, and veri.fication of pull cension are all important attributes that ensure cables are not damaged during the installation process and that are not reersatable. Although subsequent testing (i.e. , ineggering) provides some information regarding damage, sozo 'oroblems (attributable to damage) cay not be uetectable or occur ur.til sesocin later during the operation of the station. ISAP VII.c pig.ced substantial 3 reliance on the inspection documentation for cable installation. Based on the lack of reinspection inforwition, the quantity of indeterminate inspectors, and the substantial lack of experience of these indeterminate inspectors, a concern remains regarding the adequacy of the cable installation inspections. Thus, these 3 indeterminate electrical inspectors constitute an unclassified trend and a root cause/ generic implication analysis is includof in Section 5.8 of thic Results Report.
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ISAP I.d.1 J (Cont'd) 5.0 IMP!.EMENTATION OF ACTION PIAN AND DISCUSSION OF RESULT.* (Cont'd)
As stated above, only two of tha 317 TU Electric inspectors were determined to have failed Phase III evaluation, ard only one of the two was determined to have qu6stionable capabilities to conduct inspections properly.
The overall combined error rati for these two inspectors was 5.194 compared with an overall error rate of 2.574 for the remaining TU Electric Phase III inspectors. A review of the nonconformances that were identified during the reinspections of the er failed inspactors wse conducted by the QA/QC Review Texts. No previously unidentified type of construction deficiencies, unclassified deviations, adverse or unclassified trends were found during this review of the nonconformances. There were three nonconformances identified, all out of-scope of the original inspection requirements, that were likely to have been categorized as construction deficiencies. Two of these deficiencies involved loose conductor terminations en terminal blocks and one involved cracked Weidauller terminal blocks. Because these deficiencies were outside the scope of the original inspection requirements they were not counted as inspection errors. In addition, ISAP VII.c had identified similar problems and corrective action was already underway that would have corrected these deficiencies. None of the other nonconformances were of concern nor were they related to existing CPRT findings.
It is concluded that no adverre treno exists regarding the remaining TU Electric QC inspectors who were placed into Phase III. This conclusion is based en the following considerations:
- 1. Eighty percent of the TU Electric QC inspectors placed into Phase III were determined to be acceptt.ble, no concern, or there was a substantial amount of positive information indicating that they were capable of conducting required inspections.
- 2. The overall error rate of TU Electric inspectors placed into Phase III, including the failed inspercors, e/as 2.93t. This is not
- substantially highur than the overall deviation races identified durin5 implementation of ISAP VIIJc, particularly cransidering that the ISAP I d.1 methodology, which considers small I
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(Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSI'JN OF RESULTS (Cont'd) documentation discrepancies as errors in addition to hardware deviations, will result in higher calculated error rates than will ISAP VII.c reinspection results.
- 3. While the overall error ratos of the two failed inspectors were somewhat 1stger than the error rates for the other Phase III in:pectors, the majority of the errors made by the failed inspectors were paperwork errors chat did not translate into hardware concerns. For inspector TM-6, where there was actual hardware concern, a contributing factor to the poor performance was unclear, inadequate, and difficult to-use inspection requirements.
- 4. The majority (584) of the TU Elactric QC inspectors placed into Phase III were electrical inspectors. All TU Electric electrical inspectors were evaluated during implementation of this ISAP. There are no additional '
evaluations to be done in this area.
Except for the area of cable installation, the reinspection results, as summarized above, provide adequate positive information to conclude that additional evaluations of the indeterminate and remaining unevaluated TU Electric QC inspectors are not warranted. Additional engineering evaluatiot. of the area of cable insta.5'ation is warranted and is discussed further in Sections 5.8 and 6.0.
5.7.2 Brown & Root
{ A total of nine Brown & Root QC inspectors, out of 223 evaluated, were placed into Phase III. Of these nine inspectors, four were evaluated in Phase III to be acceptable, of no concern, or there was substantial positive information that they were capable of performing the required inspections. Two inspectors failed but the root cause analyses, contained in Section 5.8, indicated that only one of the two failed inspectors is cause for concern. Three of the nine inspectors placed in:o Phsse III were indeterminate because of the lack of recreatable 1
inspecticns.
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' ISAP I d.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd)
'vo of the indeterminate inspectors, BM 1 and BM 3, had
' previously been identified by Brown & Root and TU Electric as inspecte.rs with questionable capabilities. Both had been evaluated but QA/QC PDR 79 was issued, in part, hacause of questions regarding the adequacy of these evaluations. The indeters'.nate status of those two
[ inspectors should be resolved in conjunction with the resciution of QA/QC FDR-79 by TU Electric. This will leave only one indeterminate inspector.
There was only a limited number of reinspections conducted during Phase III evaluations of the nine Brown & Rooc QC inspectors. The overall combined error rates for the two failed insp9ctore, only one of whom is a concern, was 7.894. The overall error rate for the one additional QC s
inspector for whom reinspections were conducted was 1.5%.
r A review of the nonconformances that were identified during the reinspections of the two failed inspectors was
[
condueced. No previously unidentified construction deficiencies, unclassified deviations, adverse or unclassified trends were found during this review of the nonconformances. Three nonconformances were identified that were related to existing CPRT identified findings or ongoing TU Electric correctise actions. Two of these e
- nonconformances involved improper clearances estveen pipes
- and supports snd are related to an ISAP VII.c identified adverse trend for which reinspections are being conducted.
One nonconformance involved a cable tray hanger clamp enat did not have full bearing. The cable tray hangers are being reinspected as part of an ongoing n! Electric c
' correctiva action program and the reinspections include attributes that would identify this type of problem. No effort was made to deternine if these nonconformances were construction deficiencies because of the existence of ongoing corrective cetion program: that hSve been established to resolve these type cf generic problems.
None of the other nonconformances were of concern nor were they related to existing CPRT findings.
It is concluded t;iat no adverse trend exists regarding Brown & Root QC inspectors placed into Phase III. This conclusion is based on the following considerations:
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. were placed into Phase III for evaluation. This is e much lower percentage than for TU Electric.
In addition, unlike TU Electric, where lack of experience was the primary cause for inclusion in Phase III, there was no clear pattern of causes for inspectors being placed into Phase III.
3
- 2. Two hundred and eighteen of the 223 Brown & Root QC inspectors evaluated (97.8%) were acceptable, of no concern, or there was a substantial ascunt of positive information available that they were capable of performing the rsquired inspections.
- 3. The overall combined rei npection error rate for the three Brown & Root anspectors for whom reinspections were conducted was 6.554. These results appear to be consistent with the larger amount of reinspection results collected for the TU Electric QC inspectors. While the overall error rates for the two failed Brown & Root QC inspectors were somewhat larger than the other TU Electric and Brown & Root QC inspectors placed into Phase III, a substantial amount of the errors were anociated only with paperwork errors.
No additional evaluations of the remaining unevaluated Brown & Root QC inspectors are warranted based on the results of this trend evaluation.
5.7.3 Subcontractors For subcontractor QC inspectors, problems were primarily related to Bahnson QC inspectors. Of the total of ten subcontractor inspectors placed into Phase III, nine were Bahnson inspectors and one, who was determined to be of no concern, was a R. V. Hunt inspector. Because a QA/QC program deficiency was prepared to address the Bahnson QC inspector certification problem, this area will not be included in this trend analysis. With regard to the 1
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Page 65 of 13; Rf:3ULTS REPORT ISAP I.d.1 (Cont'd) '
5.0 IMPI.EMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd) remaining subcontractors, no adverse trend is censidered to exist, based on only one inspector, who was certified in the early stages of the Project in 1976, being placed into Phase III. This inspector conducted no inspections.
The QA/QC program deviation reports that were issued as a result of the implementation of this ISAP vere reviewed for trends.
Seven QA/QC program deviation reports were issued during the course of the work. Of the seven PDRs, four addressed procedure problems. Two of the four procedure problems were determined to be QA/QC program deficiencies. The root cause(s) of the problem of inadequate inspection procedures will be addressed in the Collective Evaluation Report. Two of the remaining three PDRs are QA/QC program deficiencies, which require root cause/ generic implication analysus. Therefore, no trending of these is required. The remaining PDR is restricted to an inspection record problem involving only CB&I and does not constitute a trend.
5.8 Root Cause ard Generic Implication Analyses ISAP I.d.1 requires toot cause/ generic implication analyses to be conducted for all inspectors who failed Phase III evaluation. In addition, the CPRT Program Plan requires root cause/ generic implication analyses to be conducted for QA/QC program deficiencies and unclassified trends. The following paragraphs contain the root cause/ generic implication analyses for the four failed inspectors, fout QA/QC program deficiencies, and one unclassified trend identified during implementation of this ISAP.
5.8.1 Inspector HE-8 Root Cause HE 8 failed Phase I'.I evaluations primarily because -
errors related to one attribute. The attribute in question required inspection of site installed internals in electrical panels and boxes. The inspector marked this attribute "satisfactory" in 'ar.ny esses when there were no site-installed internals. The overall result of these errors was that additionr.1 inspections were conducted of vendor-supplied internals that were not required to be site inspected. If this one troublesome attribute were removed from the overall results, the inspector would have O
Revision: 1 pts 3 66 of 138 RESULTS REPORT I ISAP I.d.1 D) (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) fallen well within the required error limits. The exact root cause of the problem with the one attribute cannot be determined, but inexperience may have been a factor. A detailed description of the root cauce analysis is contained in Attachment 13.
Generic Implications Based on the root cause analysis conducted for the Phase III failure of inspector HE 8, no further reinspections of this inspector's work are required. The failure was primarily related to one attribute. The errors related to this attribute resulted only in additional unrequired inspections being conducted which, in turn, had no adverse hardware impact.
Discounting this problem attribute, HE 8 had a composite objective error rate of 1.364 and a composite subjective error rate of 0.004. These error rates fall well within the ISAP I.d.1 error rate limits.
b) s, 5.8.2 Inspector TM 6 Root Cause A review of the reinspection results for this inspector indicates that the work evaluated consisted of Hilti bolt inspections, instrumentation inspections, and instrumentation tubing-weld inspections. The following are the reinspectior. results for each of these types of inspections:
Objective Error Subjective Error Type Rate Rate Hilti Bolts 1.70% 3.384 1
Instrumentation 28.174 On Instrumentation Tubing Welds .30 On Y
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As stated earlier, the results of the Hilti bolt reinspections are satisfactory. The reinspection results for the instrumentation inspections indicated a 28.17%
disagreement rate. This was based on 40 disagreements out of 142 objective decision points. Investigation indicated that 17 of these disagreements were against attributes that had been marked acceptable for which there were no defined acceptance criteria. These disagreements are not attributable to inspection orror. They are procedural inadequacies. No QA/QC program deviation report was issued to document these procedural problems because TU Electric had already issued Stop Work order 85 05 in October 1986. This Stop Work Order was issued because of inadequate installation and inspection criteria for instrumentation. Resolution of this overall TU Electric-identified problem will resolve the specific problers identified by the QA/QC Review Team. Of the remaining 23 disagreements, 10 were for marking attributes satisfactory that related to nonsafety-related items.
These attributes should have buen marked not applicable (NA). The remaiMng 13 disagreements were spread among nine attributes, with the largest number against any one attribute being three. These all appear to be related to inspection error with no apparent pattern. These 13 disagreements alone are sufficient to fail the inspector in this aren.
The reinspection rssults for the instrumentation tubing welds resulted in 106 disagreement.s out of 1,466 objective decision points. Ninety three disagreements occurred because TM 6 had marked the attribute for veld reinforcement satisfactory when the welds that were being inspected were fillet welds. This attribute should have i been marked NA. The veld inspection checklist that was being used was a general checklist that applied to both butt and fillet welds. TM 6 did mark othcr attributes on the checklist, such as backing strip and purge daa, as NA as should have been done. Based on data obtained from ;
reinspection results on other inspectort,, it was l apparently common practice for TU Electric inspectors to check this attribute satisfactory for fillet welds.
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ISAP I.d.1
[)
.v (Cont'd) '
5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd) of the remaining 13 disagreements, four were for inspections for which the required inspection report (IR) was not prepared. Another three were for marking an attribute for inspection of flex tubing NA when flex tubing was installed. The remaining six disagreements were for referencing the incorrect revision of the inspection procedure on the inspection report.
The lack of education and experience of this inspector, when coupled with the inadequate and confusing TU Electric instrumentation inspection requirements, virtually guaranteed the failure of this inspector to meet ISAP I.d.1 reinspection acceptance criteria in this area. TM,6 was capable of conducting the less complex and better defined inspections of Hilti bolts. Also, for instrumentation tubing welds, the bulk of the errors involved incorrectly accepting one attribute that was not applicable. By far the majority of this inspector's problems involved failure to fill out paperwork properly '
and to comply with existing paperwork requirements. These f-~
( ,)g errors can likely be attributed to lack of education and experience.
The root causes of this inspector's failure are the lack of education and experience and marginal and unclear inspection requirements.
Cenerie Implications Inspector TM 6 held TU Electric certifications for inspection of concrete anchor bolts, instrument tubing fabrication and instrument and tubing installation, and fabrication of instrument supports and rack assemblies.
He also held Brown & Root certifications for liquid penetrant and visual weld examinations.
The root cause analysis indicates that the major area of hardware concern is this inspector's lack of capability in the area of instrumentation inspections. These inspections were complex and were guided by inspection requirements that were marginal, difficult to understand, and in areas, inadequate, However, inspector TM 6 may have asde a hi,gher than desirable number of inspection errors on more complex inspeccions, such as instrumentation supports. For less complex inspections, O
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TM 6 appears to have been capable of conducting required vork adequately. The problems in the tubing weld inspection area are centered on one steribute that is not related to the acceptability of the hardware. The incorrect marking of this attribute appears to be a common problem for TU Electric inspectors as it was apparently the practice to mark it satisfactory rather than NA. See Section 5.10 for further recommendations.
5.8.3 Inspector BM 4 Root Cause Inspector BM 4 failed the Phase III evaluation with a 9.51% objective attribute disagreement rate. A total of 50 reinspections, consisting of 610 objective decision points, were conducted. Fifty eight of the 610 decision points were in error. Although 32 of the 50 reinspections were of Hilti bolts, all 58 of the errors were associated with the 18 pipe support inspections. The errors were grouped as follows:
lll Attribute Number of Errors Undersized fillet velds 29 Location of support 14 Bolt hole location 8 Dimensions not per ISO 3 Base plate dimensions 3 configuration of weep hole 1 It is concluded from the error grouping that veld inspection is an area of concern for this inspector. Veld reinspections were limited to size, length, and location.
Remaining veld reinspection attributes, such as sisg, undercut, veld splatter, etc., were considered to be nonrecreatable because the welds were painted. The ability of this inspector to inspect these other weld inspection attributes properly is also questionable.
The errors related to support location require discussion.
Although information is currently available from which support locat(on could be determined, the information apparently available to EM 4 at the time of the inspection did not contais this information. The supports that were O
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Page 70 of 138 RESULTS REPORT
, . I ISAP I.d.1 O (Cont'd) i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) reinspected were correctly located. Under the circumstances, it may be appropriate to discount these 14 errors. 'However, even when discounting them, this inspector still fails. The remaining errors all involved the inspector's failure to verify the overall configuration of the support to the drawing requirements properly.
The supports that were reinspected were classified as ASME Class 3. At TU Electric's request, no further reinspectior: of pipe supports inspected by BM 4 were conducted because of the Hardware Validation Prograa (HVP) then being developed.
Based on the above analysis, it is concluded that this inspector was not capable of inspecting pipe supports properly. In particular, his ability to inspect velds does not appear to be adequate. No problems were identified regarding this inspector's ability to inspect Hilti bolts. No clear cause for the identified lack of j
O m
ability can be determined. However, pipe support inspections are complex inspections and BM 4's lack of formal education could possibly have been a hindrance to his ability to conduct the work properly.
Generic Implications i Inspector BM 4 held Brown & Root certifications for visual ;
examination of welds (ASME and AWS), mechanical installation and fabrication inspection (MIFI), liquid penetrant examination, concrete anchor bolt inspection (CEI.20), and vacuum box leak testing. He also held a TU Electric certification for inspection of concrete anchor bolts (QI.QP 11.2).
The TU Electric computer data base shows only ASME pipe
' support inspections having been conducted by this inspector until his termination date of September 1980.
As mentioned earlier, ISAP I.d.1 reinspections were terminated at the request of TU Electric because they expected the HVP that was under development to address any problems. This corrective action program will resolve all concerns regarding pipe support inspections with one
] exception. Review of the HVP indicates that veld 3
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- reinspections under this program are limited. The HVP requires reinspection of welds only for length, location,
~
and cracking. Other attributes, specifically weld size, are not included in the HVP. There is a possibility that undersized welds in pipe supports originally inspected by BM 4 may exist, even after completion of the HVP. Other veld problems, such as slag, undercut, etc., could also possibly exist because of uncertainty regarding this inspector's capability to conduct veld inspections. Based on Phase III results, the certifications likely to be of most concern are visual welding certification and the MIFI certification. Although the computer data base was reasonably accurate during the time period in question, some errors could still exist and inspections conducted by this inspector may not be identified in the data base. . TU Elactric did conduct a manual record search for Unit 1 except for ASME pipe supports and no additional inspections were identified.
The generic implications extend to all veld inspections performed by this inspector. The HVP addresses only three veld attributes, with reinspections through coatings, for Unit 1 and Common. Additional evaluations beyond the HVP will be required to address the generic implications. See Section 5.40 for further recommendations.
5.8.4 Inspector BM 5 Root Cause The 78 pipe veld inspections that were reinspected for this inspector were all of socket welds. Out of 936 decision points, there were 78 objective disagreements.
All 78 diregreements were for marking the attribute for weld reinforcement satisfactory rather than NA for l fillet welds. This same situation occurred for inspector i
TM 6 and a. well as other inspectors identified during I.d.1 evaluations. No other disagreements, either objective or subjective, were identified during the reinspections for this inspector.
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V y
(Cont'd) 5.0 IMPI.EMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd)
Generic Implication The practice of marking reinforcement satisfactory rather than NA on the generic weld inspection checklist appears ~
to be common for TU Electric weld inspectors. Other attributes that are clearly not applicable were marked NA.
It is concluded that this practice had no potential for negative impact on the hardware. Fillet veld sizes, based on reinspection results, were adequately inspected.
5.8.5 QA/QC PDR 79 Root Cause This PDR identified the following conditions with regard to previous TU Electric and Brown & Root efforts to resolve concerns regarding QC inspector qualifications:
- 1. Problems were sometimes. documented on NCRs and other times were documented by internal menos.
- 2. Reinspection results were not fully documented and, in one instance, either were not done or were incorrect.
- 3. The computer data base was utilized to identify inapections where 1004 reinspection had been determined to be required. However, this data base is incomplete.
Based on the varying methods that were usad to evaluate ,
and resolve similar problems, the root cause of the first two conditions is that no clear policy or set of guidelines existed on how such problems should be resolved. Although use of the nonconformance system was one means of resolving these type of concerns, it was not a requirement that this system be utilized for these concerns. Whether such problems were handled under a formal nonconformance system or by evaluations out-ide the nonconformance system, the investigations and results of these investigations should have been clearly documented.
The problem regarding utilization of the data base by Quality Assura,nce Group personnel can be attributed to O
]
R:vicien: 1 Page 73 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd) oversight on the part of QA personnel. The personnel involved in the resolution of QC inspector problems were not responsible for the data base and, in general, had no reason to suspect that it was inaccurate.
Ceneric Implications It is possible that some of the past evaluations and dispositions conducted for suspect QC inspectors from TU Electric and Brown & Root are iudequate and that hardware that should have been reinspected as part of the evaluations / dispositions was not reinspected. See Section 5.9 for recommended corrective action.
5.8.6 OA/QC PDR 80, 81 These PDRs document inadequate inspection procedures and inadequate acceptance criteria for inspection of cable tray velds and welds on electrical equipment supports.
Because a number of inadequate inspection procedures were identified during implementation of other CPRT activities, the root cause/ generic implications of these inadequate procedures are being determined during the Collective Evaluation process. Therefore, these two PDRs have been referred to Collective Evaluation and will be included in the root cause/ generic implication analyses reported in the CPRT Collective Evaluation Report.
5.8.7 QA/QC PDR 45 Root Cause This PDR documents problems with the certifications of Bahnson QC inspectors and with the Bahnson QC inspector i
certification program. In addition to the problems tegarding individual QC inspector certifications and certification program inadequacies noted in this PDR, implementation of ISAP VII.c identified deviations during reinspections that resulted in an unclassified trend. The root cause analysis for this unclassified trend of
( hardware deviations was determined to be a i less than adequate development and implementation of an l overall HVAC program to ensure that HVAC supports were j
installed in accordance with design requirements. The QC inspector certification problems formed a portion of this overall program problem.
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Revision: 1 Page 74 of 138 RESULTS REPORT g-- ISAP I.d.1
) (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
' Because TU Electric made a decision to terminate Bahnson services in early 1987, this root cause analysis wil'.
concentrate only on why TU Electric failed to identify the overall Bahnson problems, including the inspector cercification problem, rather than on determining what the specific internal causes were within the Bahnson organization.
A detailed description of the history of Bahnson program problems and the root cause analysis is contained in Attachment 14 In summary, the probable root cause of why TU Electric did not identify and correct Bahnson problems in a timely fashion was the failure of previous TU Electric QA management to ensure that Bahnson was implementing an effective QA program. This occurred because TU Electric had not established an effective subcontractor monitoring program that would identify and correct subcontractor problems in a timely fashion. In addition, previous TU Electric QA management failed to identify the seriousness of the Bahnson problems that had O been identified. There were a number of major contributors to this root cause as follows:
TU Electric did not conduct ongoing QA surveillances of Bahnson activities for an extended period of time (19801984). Industry experience has shown that an ongoing, day to-day QA surveillance program with heavy emphasis on hardware related activities is desirable, if not necessary, to supplement QA audit programs.
There was not an effective interface between the Engineer and Bahnson in that no effective review of Bahnson installation drawings to verify they met the design intent was conducted. Had such a review been conducted by the Engineer, many problems would likely have been eliminated.
There was a change over of responsibility for overall control of Bahnson from Brown & Root to TU Electric which occurred in 1980 and resulted in a failure to continue to identify, pursue, and resolve Bahnson problems.
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R:visien: 1 Pcg3 75 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) 5.0 IKPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd)
There was a poor interface between TU Electric's site QA organization and the Dallas QA organization. This resulted in a lack of coordination of resolution of problems identified during procedure reviews conducted by Site QA and audits conducted by Dallas QA.
Generic Implications The potential generic implication of this QA/QC program deficiency is that problems relating to site subcontractors, other than Bahnson, may have gone undetected by TU Electric. This implication is more appropriately addressed by the CPRT Collective Evaluation process and has been referred to Collective Evaluation for resolution. See Section 5.9 for recommendations for correction of this specific problem.
5.8.8 Unclassified Trend for Indeterminate TU Electric QC Inspectors Conducting Cable Pulling Inspections Root Cause A substantial percentage (15.8%) of TU Electric QC inspectors evaluated during implementation of this ISAP were placed into Phase III.
Over half (584) of these inspectors that were placed into Phase III were electrical inspectors. A substantial amount of information regarding the root cause of the problems that resulted in TU Electric electrical inspectors being placed into Phase III can be obtained from the ISAP I.d.2 Results Report. That Results Report identifies weaknesses in the TU Electric certification procedures that would be likely to lead to the types of problems found in the qualifications of Phase III inspectors. For example, of the 50 TU Electric QC inspectors placed into Phase III, lack of experience was a cause or one of the causes for inspectors being placed into Phase III in 27 cases. Prior to August 1985, the TU Electric procedures generally gave only guidelines for experience rather than specifying minimum requirements or specific alternstes to the recosamended experience levels.
This inevitably led to a lack of consistency in decisions on the acceptability of individuals being made by different persons. Thus, a sizable number of IV Electric
Revisien: 1 l Page 76 of 138 RESULTS REPORT
{
O' ISAP I.d.1 (Cont'd) i t
I 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd) inspectors were placed in Phase III based on lack of experience because no definitive set of requirements were utilized in' determining what was an acceptable level of experience.
The root cause of the unclassified trend for indeterminate TU Electric QC inspectors conducting cable pulling inspections is inadequate QC inspector certification procedures, i
, Generic Isolications Because extensive reinspection results were available for TU Electric QC inspectors who conducted other types of inspections and because these results were generally satisfactory, the area of concern regarding indeterminate inspectors is limited to the tres of cab 1:. pulling. The combination of a substantial .. umber of indeterminate inspectors and the heavy reliance of ISAP VII.c on the documentation produced by some of these same inspectors i.O does not provide adequate information to conclude that l cable installation at CPSES was always properly conducted
)
without cable damage that might result in later hardware '
problems. See Section 5.9 for recommended corrective j action.
t 5.9 Recommended Corrective Action r
Based on the results of the ISAP I.d.1 evaluations described in !
previous sections of this report and requirements of Appendices E '
4 and H of the CPRT Program Plan, the following recommendations for j
addicional corrective action have been identified:
- 1. QA/QC.PDR 79 documented problems regarding the proper i
resolution of problems identified by TU Electric and Brown ,
& Root involving QC inspectors. It is recommended that TU l
Electric review inspector certification files to identify cases where these problems occurred and evaluate these j
cases to verity that they were properly resolved. All ;
], cases identified should be evaluated considering the following points:
3 4
Doeil adequate documentation of the resolution of the problem exist? '
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Revisien: 1 Page 77 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) 5.0 IMPLE.ENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Were reinspections, where conducted, adequate?
Was proper consideration given in the disposition to computer data base inaccuracies?
It is also recommended that TU Electric develop additional policies or guidelines to ensure that any future QC inspector performance inadequacies are resolved in a consistent manner with adequate technical reviews and documentacion.
- 2. QA/QC PDR 80 identified inadequate procedures for inspection of cable tray welds. Specifically, veld inspection attributes such as size, length, and location were not specified and for a one month period, there were no criteria for veld inspection. TU Electric should investigate this problem to determine the length of time that it existed and the possible impact of the inadequacies on the acceptability of installed cable tray.
- 3. QA/QC PDR 81 identified six welding inspections of electrical equipment supports for wh!.ch there are no criteria for veld inspection. TU Electric should investigate to determine the extent that inspections in this area may have been conducted without appropriate inspection criteria and what impact this practice may have had on the equipment.
- 4. QA/QC PDR 45 identified that a number of Bahnson inspec*. ors were not properly certified and identified problems in the Bahnson inspector certification program.
TU Electric should conduct an evaluation, considering corrective action programs planned and underway, for evaluating the impact on the Bahnson installed equipment of the inspectors with questionable qualifications. The overall impact of the discrepancies in the inspector certification program should also be considered during this evaluation. TU Electric should also verify that their current QA program is adequate to control site contractors in accordance with 10CFR50, Appendix B and FSAR requirements and is adequate and to preclude the repetition of similar problems with other sits contractors. '
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( (Cont'd) 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd)
. 5. TU Electric should conduct additional evaluations to determine the impact, if any, of the unclassified trend for indeterminately qualified TU Electric QC inspectors conducting cable pulling inspections on the adequacy of installed electrical cable.
- 5.10 Recommendations for Improvement A number of QA/QC program deviations were identified during implementation of this ISAP that were judged by the QA/QC Review Teau to not be QA/QC program deficiencies. In addition, the failure of inspectors TM 6 and BM 4 to pass the ISAP I.d.1 Phase III acceptance criteria was determined not to be a QA/QC program i deficiency, adverse trend, or construction deficiency.
Never the less, based on the understanding of these deviations that resulted from the QA/QC Review Team svaluations, the recommendations for improvement are made.
- 1. It is recommended that TU Electric take further action to resolve hardware concerns related to possible acceptance of unsatisfactory work by inspectors TM 6 and BM 4. Root
(~'f}
s,- cause/ generic implication analysis indicates that there is no concern regarding hardware for the two remaining failed inspectors HE 8 and BM 5. The following are additional details regarding this recommendation for TM 6 and BM 4:
TM 6 The TU Electric resolution should consider the following factors:
- 1) The root cause/ generic implicacian analysis indicates TM 6 had difficulty with complex inspections, but was capable of conducting simple, reasonably well defined inspections tasks.
- 2) The planned corrective action for instrumentation should be reviewed by IV Electric to assure that it resolves procedural inadequacies typical of
. those identified during the root cause analysis for TM 6.
m
, - , - . _ . _ _ , . 4 - ._
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RESULTS REPORT ISAP I.d.1 (Cont'd)
)
j 5.0 IMPLEMENTATION OF ACTION PIAN AND DISCUSSION OF RESULTS (Cont'd)
- 3) Because of data base !naccuracies, some inspections conducted by TM 6 may not be identified.
BM 4 The TU Electric resolution should consider the following factors:
- 1) The HVP does not cover veld size or veld quality, areas for which BM 4 was found unsatisfactory or questionable.
- 2) Because of data base inaccuracies, some inspections conducted by BM 4 may
- be identified.
2.
QA/QC PDR 56 identified the fact that a small number of visual weld insp3ctions were conducted by unqualified inspectors. The periods of time and inspection procedures in question are identified in Section 5.2.3, Summary of Phase III Results, of this Results Report and in the PDR.
It is recommended that TU Electric evaluate the impact, if any, of this problem in the identified areas and time frames to determine if additional action is required.
Consideraticn should be given to possible data base inaccuracies and to any evaluations and corrective action programs planned or underway when conducting this evaluation.
3.
QA/QC PDR-70 identified the fact that there was a lack of definitive requirements specified regarding marking, inspection and recording of marking of instrumentation supports. Based on the lack of definitive requirements and apparent informal practices that evolved in this area, it is recommended that TU Electric evaluate and determino whether past practices regarding instrumentation marking and documentation were adequate for installed instrumentation supports.
- 4. QA/QC-PDR 7 identified a lack of CB&I records documenting inspection of weld fit up, alignment, and final visual inspection. it is recommended that TU Electrie, in conjunction with the recommended action for QA/QC PDR 45, O
a Rsvisicn: 1 Page 80 of 138 RESUI.TS REPORT
(]
\, /
ISAP I.d.1 (Cont'd) '
5.0 IMPLDtENTATION OF ACTION PIAN AND DISCUSSION OF " SULTS (Cont'd) ensure that their current system for control of site contractors is adequate to prevent similar problems from occurring.
6.0 CONCLUSION
S The following conclusions have been reached as a result of the implementation of this Action Plan:
The evaluation confirmed the validity of the NRC issues identified in NUREG 0797, Supplement 7, Page J-110.
The ongoing Brown & Root QC inspector certifiestion program as defined in the procedures referenced in Section 5.5.1 of this Results Report is satisfactory. The ongoing TU Electric QC inspector certification program has previously been evaluated and i
found satisfactory as d9scri*udd in the ISAP I d.2 Results Report.
, []
The TU Electric QC inspector certification program, particularly l
V the historical electrical QC certification portion, produced a substantial number of inspectors who were eartified with questionable qualifications. The TU Electric QC inspector certification program improved over time an illustrated by the fact that initially, 93.9% of TU Electric historical QC inspectors were acceptable, of no concern, or there was substantial positive information that they were qualifted. This figure increased to 99.4% for TU Electric current QC inspectors.
I A similar similar improving situation existed for Bro =Tt & Root.
However, the Brown & Root program never produced as high a
! percentage of inspectcrs with questionable certifications as the TU Electric program. This can be attributed to the following factors:
- 1) The Brown & Root QC inspector certification procedures were reasonably good.
- 2) The Brown i . sit QC inspector certification program was primarily a: ;cted to mechanical and NDE type inspections .
- s bese inspector certification requiremes .1 .cta.ed by ASME and ASNT SNT TCIA, were more pret.isi .
!.4.ined than the requirements for civil and electrical type inspections.
C
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ISAP I.d.1 (Cont'd) i 1
)
6.0 CONCLUSION
S (Cont'd)
,. 3) The checks and balances inherent in an ASME program, including ANI monitoring and periodic ASME surveys, played a: positive role in ensuring that the Brown & Root QC inspector certification program was in compliance with requireme nt.* .
The past TU Electric QC inspector certification program, despite the procedural inadequacies described in the ISAP I.d.2 Results Report, was adequate in that its application consistently resulted in the certification of a high percentage of inspectors capable of conducting the required inspections. The Brown & Root QC inspector certification program was also adequate for the same reason. This conclusion is cupported by the following results:
- 1) The overall error rate for all Phase III inspectors for whom reinspections were conducted was 3.11%. This is not substantially higher than the overall deviation rate identified during ISAP VII.c reinspections, particularly when consideration is given to the fact that ISAP I.d.1 methodology will result in an inherently higher error rate than vill be identified by ISAP VII.c reinspections
- 2) Review of CPRT ISAP results, particularly ISAP VII.c, reveals that the caust of significant hardware problems remaining undetected was generally not attributed to inspector error.
- 3) The TU Electric program for certifying electrical QC inspectors was an area of particular concern on the part of the NRC TRT. Therefore, all historical and current TU Electric electrical QC inspectors were evaluated during implementation of this ISAP rnd, except for the area of cable pulling inspections for which no recreatable inspections could be conducted, no areas of concern were identified or remain unresolved.
l
- 4) TU Electric evaluated all the nonconformances that were written to document the hardware discreparcies that were identified during Phase III reinspections to determine if any were reportable to the NRC in accordance with 10CFR50.55(e) roquirements. None of the nonconformances were reportab). .
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Rsvision: 1 RESULTS REPORT O ISAP 1.d.1 i
V (Cont'd)
6.0 CONCLUSION
S (Cont'd)
Results of the trend analysis in Section 5.7 indicate that no further action is warranted regarding the CPSES QC inspectors who have not been subjected to ISAP I.d.1 type evaluations.
Additional action, as detailed in Section 5.9, should be taken by TU Electric to resolve specific outstanding concerns regarding the unclassified trend for indeterminately qualified QC inspectors inspecting cable pulling.
With the exception of the u lassified trend for indeterminately qualified inspectors conducting cable pulling inspections, there is no significant indication of any adverse impact on the results of ISAP VII.c because of unqualified inspectors having originally conducted work on inaccessible or nonrecreatable attributes. In reaching this conclusion, consideration was given to the evo failed inspectors for whom there was potential hardware impact.
These two inspectors appeared in six ISAP VII.c populations.
Inspector TM 6 was involved in sample items from the piping welds (PIWM), tubing welds (TUWM), and instrument support (INSP) populations. Inspector BM 4 was involved in samples from the fuel pool liner (FPIJt), large bore pipe supports rigid (LBSR),
and small bore pipe supports (SBPS) populations.
Because determinations of the adequacy of nonrecreatable attributes in these populations depend upon satisfactory documentation, some of which was signed by these two inspectors, an evaluation of the impact of potsntially questionable documentation on the conclusions presented for these populations was undertaken. This evaluation included an analysis of the nonconformances identified during ISAI I d.1 reinspections of I these evo inspectors' work. This analysis took into account the nature and scope of the reported nonconfotmances and considered the possibility that such nonconformanc o aight result in a construction deficiency, adverse trend, or an unclassified deviation or trend for these six populations.
The analysis determined that with three exceptions, the reported nonconformances were all of a relatively minor nature, and were similar to deviations noted during the ISAP VII.c reinspections of randotuly selected sample items frca applicable populations.
The three exceptions were related to an existing adverse trend and an established TU Electric corrective action program. These
' conditions would have been corrected by existing corrective action programs. It'was therefare concluded that inspection discrepancies of the type and severity documented during this ISAP implementation, whether they were to occur on a reinspection O
R0 vision: 1 Page 83 of 138 RESULTS REPORT, ISAP 1.d.1 (Cont'd) '
6.0 CONCLUSION
S (Cont'd) or on a document review steribute, would not result in a construction deficiency, adverse trend, or unclassified trend or deviation: occurring or being identified that was not already covered by existing corrective action. Thus, the conclusions presented in the ISAP VII.c Results Report remain valid.
Recommendations for additional actions regarding these two inspectors are included in Section 5.10. A summary of the evaluation of deviations regarding QC inspector certifications identified during implementation of ISAP VII.c is contained in Attachment 15.
7.0 ONGOING ACTIVITIES The CPRT considers the implementation of this ISAP to be complete.
There are no ongoing activities except those being conducted by TU Electric to resolve the recommendations contained in this Results Report.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE PVTURE O'
Both the current TU Electric and Brown & Root QC inspector certification programs are adequate. Continued mana;;ement involvement in regularly evaluating the adequacy of these programs and their subcontractor programs and promptly correcting any identified discrepancies should avoid further problems.
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R:visicn: 1 RESULTS REPORT ISAP I.d.1
( (Cont'd)
Attachment 1 Inspector Certification Evaluation summary Name:
sse:
Applicable Education:
Manner of Verification:
Applicable Verified Prior Experience:
Initial and Discrepant certifications:
Level Certification Date Certified 1
Discrepancies Noted:
1 1
l i
i e
a
} Signature:
Date:
. - , . ~ - , . - . , - _ - .
R;visien: 1 Page 85 of 138 RESULTS REPORT ISAP I,d.1 (Cont'd)
Attachmenc i (Cont'd)
. lame
- SSs:
~
Recommended Corrective Action:
Signature:
Date:
Corrective Action Taken:
Signature:
Date:
Acceptable _
_ Unacceptable Signature:
Signature:
Date:
Date: I O'
":0";r d ..
ISAP I.d.1 (Cont'd)
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e Revision: 1 RESULTS REPORT 850 88 of 133 h ISAP I.d.1 V (Cont'd)
Attachment 4
.The following pages of this attachment categorize the concerns regarding TU
- Electric inspectors that were evaluated during Phase II. On January 30, 1981, TU Electric committed to ANSI N45.2.6 and Regulatory Guide 1.58. As explained in Section 4.1.2 of this Results Report, pre 1/31/81 and post-1/30/81 Phase II evaluation criteria differed. This difference is reflected in the summary charts on the following pr;;es of this attachment.
The following is an explanation of the categories:
- 1. Cert issued without education During the review, there was no objective evidence available to indicate that the indivirtu:1 had the proper education to support certification.
- 2. Cert issued without experience During the review, there was no objective evidence available to indicate that the individual had the proper experience to support certification.
- 3. Verification education and experience NRC IE Circular No.
80-22: "Confirmation of Employment Qualifications" which recommends verification of technical and education qualifications, dated 10/2/80, was used as the requirement date.
4 Physical requirements During the review, missing eye exam certs, lapse in eye exams, etc., were identified.
- 5. Indoctrination / Training During the review, no objective evidence was training has available been to show that indoctrination and/or formal completed.
- 6. OJT/ Training / Experience / Exams '. Concerns were identified with waivers of OJT, training, experience and exams.
- 7. Exam (V, F/P, 0) During the review, the exams contained errors, omissions, were missing, etc.,
- 8. Certification /recertification problems During the review, concerns were identified such as lapses in certifications, no i
annual evaluation, failure to exclude NDE, etc..
I 9.
' Documentation Concerns were identified with airsing documentation, missing signatures, incomplete documents, conflicting documents, etc..
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- ._. - _- - - - -- - - ^ - -
I Rovision: !
Pege 89 of iM RESULTS REPORT ISAP 1.d.1 (Cont'd)
Attachment 4 (Cont'd) l CURRENT TUGCO OC INSPECTORS - 166 TOTAL PRE 1/31/81 POST 1/30/81 ANSI PROCEDURE ANSI PROCEDURE
- 1. CERT. lSSUED W/O 4 2 2 1 EDUCATION
- 2. CERT. ISSUED W/O 7 2 20 2 EXPERIENCE
- 3. EDUC./EXP. NO ED: 2 ED: 16 VERIFICATION EXP:1 EXP:14 {
- 4. PHYSICAL REQUIREMENTS 4 34
- 5. INDOC./ TRAINING 48 77
- 6. WAIVERS 37 153 OJT/ TRAINING /EXPJEXAM
- 7. EXAMS (W,F/P,0) 5 50
- 8. CERT./ RECERT. 1 17 118
- 9. DOCUMENTATION 57 357 TOTALS 15 172 52
. 792 O.
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I
Revision: 1 Pego 90 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 4 (Cont'd)
TUGCO HISTORICAL ELECTRICAL QC INSPECTORS - 86 TO PRE 1/31/81 POST 1/30/81 AN5i PROCEDURE ANSI PROCEDURE
- 1. CERT. lSSUED W/O 2 1 EDUCATION
- 2. CERT. lSSUED W/O 24 2 7 EXPERIENCE 1
- 3. EDUC./EXP. NO ED: 25 VERIFICATION ED: 16 EXP: 3 EXP: 6
- 4. PHYSICAL REQUIREMENTS 12 11
- 5. INDOC./ TRAINING 38 6
- 6. WAIVERS OjT/ TRAINING!EXP./ EXAM 34 72
- 7. EXAMS (W,F/P,0) 31 14
- 8. CERT. / RECERT. 11 26 37
- 9. DOCUMENTATION 73 63 l TOTALS 65 216 30 204 l
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Revision: 1 Pcgo 91 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) '
Attachment 5
. The Brownfollowing page of this attachment categorize the concerns regarding
& Root inspectors that were evaluated during Phase II. On January
,30, 1981, TU Electric committed to ANSI N45.2.6 and Regulatory Guide 1.58.
As explained in Section 4.1.2 of this Results Report, pre 1/31/81 and post 1/30/31 Phase'II evaluation criteria differed. This difference is reflected in the summary chart on the following page of this attachment.
The following is an explanation of the categories:
- 1. Cert issued without education During the review, there was no objective evidence available to indicate that the individual had the proper education to support certification.
- 2. Cert issued without experience - During the review, there was no objective evidence available to indicate that the individual had the proper experience to support certification.
- 3. Verification education and experience NRC IE Circular No.
80 22: "Confirmation of Zarployment Qualifications" which recommends varification of technical and education qualifications, dated 10/2/80, was used as the requirement date.
4 Physical requirements During the review, missing eye exam l certs, lapse in eye exama, etc., were identified,
- 5. Indoctrination / Training During the review, no objective evidence was available to show that indoctrination and/or formal training has been completed.
- 6. OJT/ Training / Experience / Exams - Concerns were identified with waivers of OJT, training, experience and exams.
- 7. Exam (V, F/P, 0) During the review, the exams contained errors, omissions, were missing. etc..
- 8. Certification /recertification problems During the review, concerns were identified such as lapses in certifications, no annual evaluation, failure to exclude NDE, etc..
- 9. Documentation - Concerns were identified with missing documentation, missing signatures, incomplete documents, conflicting documents, etc..
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Revision: 1 RESULTS REPORT ISAP I d.1 (Cont'd)
Attachment 5 (Cont'd)
CURRENT B&R QC INSPECTORS - 67 TOTAL PRE 1/31/31 POST 1/30/81 ANSI PROCEDURE ANSI PROCEDURE
- 1. CERT. ISSUED W/O EDUCATION
- 2. CERT. ISSUED W/O EXPERIENCE I
- 3. EDUC./EXP. NO ED: 1 VERIFICATION ED: 4 EXP:3 EXP:10
- 4. PHYSICAL REQUIREMENTS 1 j
- 5. INDOC./ TRAINING g 4 4j
- 6. WAIVERS j j4 OJT/ TRAINING /EXP./ EXAM
- 7. EXAMS (W,F/P,0) ~
29 153
- 8. CERT./ RECERT. 1 23 120
- 9. DOCUMENTATION 50 126 TOTALS 5 112 19 456 O
R visien: 1 P:go 93 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 6 Explanation for Placing into Phase III Original I.d.1 Scope Historical Electrical HE-1 The Technical Training Outline stated that NDE visual was to be excluded
( from the QI-QP 11,3 5, "Cable Tray Inspections", certification; however, the exclusions were not noted on the certification.
HE 2 This individual was certified Level II, "Electrical Cable Installation Inspections", with insufficient experience to support certification. It was also noted that the H.S. education was unverifiable due to unknown maiden name.
HE 3 This individual failed che QI-QP 11.3 46, "Electrical Inspection of Electrical Conductor Seal Assemblies", examination and was subsequently certified to this procedure via the Level II to CP-QP 11.3 "Electrical Inspection Activities".
HE 4 This individual was certified Level II to QI-QP-11.3-13, "Inspection of
'Hilti' Drilled in Bolts, Hole Patch and Torque Unistrut Material", with insufficient experience to support certification.
HE 5 This individual was certified Level I to QI-QP 11.3 26 "Electrical Cable i
l Installation Inspection", with insufficient education and experience.
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Revision: 1 Pcg3 94 og 133 RESULTS REPORT ISAP I.d.1
/~~} (Cont'd)
'N ,j Attachment 6 (Cont'd)
. HE 6 This individual was certified Level I to QI-QP 11.31, "Embedded Conduit and Sleeve Inspection", and to QI-QP 11.3 11, "Conduit Fabrication Inspection", with insufficient experience to support certification. Also, QI-QP 11.3 5, "Cable Tray Inspection", did not exclude NDE as required by the Technical Training Outline.
HE 7 This individual was certified Level II to QI-QP 11.313. "Inspection of
'Hilti' Drilled in Bolts. Hole Patch, and Torque Unistrut Material", to QI-QP 11.3 11 "Conduit Fabrication Inspection", and to QI QP 11.3 4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection", with insufficient education to support certification.
HE 8 This individual was certified Level II to QI QP 11.3 30, "Class 1E Conduit
() Fabrication" and QI-QP 11.03 28, "Class 1E Cable Terminations", with insufficient prior experience to support certification.
HE 9 This individual was certified Level I to QI-QP 11.3 23, "Class 1E Conduit Raceway Inspections", without the education to satisfy the requirement of Reg. Cuide 1.58 and ANSI N45.2.6.
HE 10 This individual was certified Level I to QI-QP 11.3 26 "Electrical cable Installation", with insufficient experience to support certification as required by ANSI N45.2.6.
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R;visisn. 1 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 6 (Cont'd)
'HE ll This individual was certified Level I to QI-QP 11.3 28, "Class 1E Cable Terminations", with insufficient experience to support certification.
HE 12 This individual was certified Level II to QI-QP 11.3 5, "Cable Tray Inspections", with insufficient experience to support certification. Also, and Technical the QI-QP-il.3 Training 4, Outline for QI-QP 11.3 5, "Cable Tray Inspections" "Exposed Conduit, Condulet, Electrical Box and Support Inspections", stated that NDE was to be excluded from these certifications.
This exclusion was not noted on the certification.
HE 13 This individual was certified Laval I to QI-QP 11.3 26 "Electrical Cable Installation Inspections", with insufficient education and experience to support certification. -
HE 14 This individual was certified Level I to QI-QP 11.3 24, "Inspection of cable Repairs", to QI-QP 11.3 38, "Class lE Electrical Equipment Installation", and to QI-QP ll.3-28, "Class lE Cable Terminations", vichout the education to satisfy the requirements of Reg. Guide 1.58.
HE 15 The Technical Training Outline stated that NDE was to be excluded from the QI-QP 11.3 4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection", certification. The exclusion was not noted on the certification.
HE 16 The Technical Training outline stated that NDE was to be excluded from the QI-QP 11.3 4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection", certification.
certification.
The exclusion was not noted on the O
Revisien: 1 Pcg3 96 et 133 RESULTS REPORT ISAP I.d.1
[~)
V (Cont'd)
Attachment 6 (Cont'd) l HE.17 This individual was certified Level II to QI.QP 11.3 26. "Electrical Cable Installation Inspections", QI.QP.11.3 27, "Class 1E Power Cable Meggering",
and VT Limited, Class V Hangers, wit' insufficient experience to support certification.
HE.18 This individual was certified Level I to QI.QP 11.3 26, "Electrical Cable Installation Inspections", with insufficient experience as required by ANSI N45.2.6.
HE.19 This individual was certified Lavel II to QI.QP 11.3 26. "Electrical Cable Installation Inspection", with insufficient experience to support 3
certification.
-- HE.20
\' #
The Technical Training Outline for the Level II QI.QP.11.3 4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection", stated that NDE was to be excluded from the certification. The exclusion was not noted on the certification. Also, this individual was subsequently certified to mechanical Level III with insufficient experience.
HE.21 This
'Hilti' individual was certified Level I to 35 1195.CEI.20. "Installation of Drilled in Bolts", with insufficient experience to support certification. Also, the Technical Training Outline for QI.QP 11.3 4, "Exposed Conduit, Condulet. Electrical Box and Support Inspection", stated that NDE was to be excluded from the certification. The exclusion was not entered on the certification.
HE.22 This individual was certified Level I to 35 1195 CEI.20, "Installation of
'Hilti' Drilled in Bolts", with insufficient experience to support certification.
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R;vistan: 1 Page 97 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 6 (Cont'd)
. Current Electrical CE 1 f
This individual failed the exam for QI-QP ll.3 42, "Electrical Inspections of Seismic CAT I Instrument Rack Assemblies", and failed the exam twice for !
CP-QP ll.2, "Surveillance and Inspection of Concrete Anchor Bolt l Installation". The inspector was subsequently certified Level II to the CP-QP ll.3, "Electrical Inspection Activities", which encompassed the QI-QP ll.3 42 certification. It was also indicated that the Level II CP-QP 11.3 certification encompassed the failed CP-QP ll.2 certification. l CE 2 This individual failed the exam for QI-QP 11.3 42, "Electrical Inspection l
of Seismic CAT I Instrument Rack Assemblies", and was subsequently certified Laval 11 all electrical to CP-QP 11.3, "Electrical Inspection Activities".
QI-QP 11.3 42. The all electrical certification did not exclude CE 3 This individual failed the exam for QI-QP 11.3 50, "Cable Crip Support Installation Inspection", and was subsequently certified Level II all electrical to CP-QP 11,3,
- Electrical Inspection Activities". The all electrical certification did not exclude QI-QP 11.3 50.
CE 4 This individual was certified to CEI 20, "Electrical Hilti Bolt Inspections", with no prior experience to support certification.
CE 5 The Technical Training Outline for the QI-QP 11.3 4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection", certification noted that non destructive examination (NDE) for veld inspections was not to be included. The certification did not exclude RDE.
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R:visign: 1 I RESULTS REPORT g) g v
ISAP I.d.1 (Cont'd)
I Attachment 6 (Cont'd)
.CE 6
'This individual failed the exas for QI.QP 11.3 29, "Electrical Separation" ,
and was subsequently certified Level II all electrical to CP-QP 11.3, "Electrical QI-QP Inspection Activities", with no exclusions regarding 11.3 29.
Elect. Level III)The recertification recommendation form indicated (via the that QI-QP 11.3 29/QI QP 11.3 29.1 and QI-QP 11.3 33 should be excluded from the CP-QP 11.3 certification.
CE 7 This individual was certified level I to QI-QP 11.3 28, "Class 1E Cable Terminations",
N45.2.6. with no verifiable electrical experience as required by ANSI I&C/RVMS IC 1 This individual was certified I4 vel I to QI-QP 11.8 5, 6, and 8, O "Inspection of Instrument Tubing Fabrication and Installation, and Instrument Installation", with insufficient experience to support certification as required by ANSI N45.2.6.
NDE/Thermolam NT 1 This individual was certified Level I to CP-QP 11.2, "Surveillance and Inspections of Concrete Anchor Bolt Installation", and to QI-QP 11.015 "Verification of Base Plate for Grouting", with insufficient experience to support certifications as required per ANSI N45.2.6.
NT 2 This
'Hilti' individual was certified Level I to QI-QP 11.2 1, "Installation of Drilled in Bolts", with insufficient education to support certification as required by Reg. Guide 1.58.
Protective Coatinas
- PC 1 i
This individual was certified livel II for Concrete and Steel Coatings i without sufficient education as required per Reg. Guide 1.58 and ANSI N45.2.6.
1
R:visten: 1 Page 99 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 6 (Cont'd)
. Mechanical NM 1 The educational requirements to support certification as a Level I to CP-QP-11.2, "Surveillance and Inspection of Concrete Anchor Bolt Installation", could not be validated.
NM 2 This individual was certified Level I to CP-QP 11.2, "Surveillance and Inspection of Concrete Anchor Bolt Installation", with insufficient education as required by Reg. Guide 1.58 and ANSI N45.2.6.
NM 3 The Technical Training outline stated that non destructive examination (NDE) was to be excluded from QI-QP ll,3 4, "Exposed Conduit, Condulet, Electrical Box and Support Inspection *, certification dated 7/16/79, however, no exclusions were noted on the certification.
Level III L1 This individual is categorized as a Level III due to his certification status at the time of review. He was initially certified Level II to CP-QP 11.2, "Surveillance and Inspection of Concrete Anchor Bolt Installation", without a H.S./CED as required by Reg. Guide 1.58.
L2 This individual was certified Level III electrical with insufficient education 1,58 and ANSI andN45.2.6.
experience to support certification as required by Reg. Guide L3 This individual was certified Level III, "Protective Coatings", with insufficient experience to support certification as required by Reg. Guide 1.58 and ANSI N45.2.6.
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1 i
Revisicn: 1 Pcgo 100 of 138 RISULTS REPORT I ISAP 1.d.1 (Cont'd)
Attachment 6 t (Cont'd)
,L 4 This individual is categorized as a Level III due to certification status at the time of review. The Technical Training Outline for the Level I QI-QP 11.3 2 certification, "Cable Tray Hanger Inspections", noted that non destructive examination for veld inspections was to be excluded. The certification did not state this exclusion.
Brown & Root Non ASME HB 1 The exam for CP-QP 11.2, "Surveillance and Inspection of Concrete Anchor Bolt Installation", certification was incorrectly scored allowing certification based on a failed exas.
Brown & Root ASME AM 1 The general exam for the Level II Mechanical Fabrication Inspector was
( incorrectly scored, allowing certification based on a failed examination.
AM 2 The general and specific exam for the Level I Mechanical Fabrication Inspector were incorrectly scored, allowing certification based on failed examinations.
1 4
9 9
1
R:visten: 1 Page 101 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 7 Phase III Evaluation of TU Electric Historical QC Inspectors Original I.d.1 Scope Twenty two TU Electric historical QC inspectors were referred to Phase III for further evaluation. The results of the Phase III reinspections are tabulated on the last page of this attachment. Historical electrical inspectors HE 5, 9, 11, 12, 14, and 17 all had at least 50 inspections reinspected with acceptable results. Because the target number of inspections was obtained within a time frame reasonably close to issuance of the discrepant certification, possible inaccuracies in the computer data base for these inspectors are considered to have no impact.
Inspectors HE 1,15, and 16 were placed into Phase III only because of the KDE exclusion problem. Inspection reports for the applicable periods of time were identified from the data base to determine if visual veld inspections had been conducted by these inspectors. For HE 15, 184 cable pulling inspections had been conducted between October 1979, when the certification was issued, and December 1979, when the , visual veld inspection requirements were removed from the procedure. No visual veld inspections conducted by this inspector were identified. Similarly HE 16 conducted 53 conduit inspections between September 1979, when the ,
certification was issued, and December 1979, when the procedure was revised. No visual veld inspections conducted by this inspector were identified. In the case of HE 1, $1 cable tray inspections were identified as having been conducted between July 1979 and December 1979, when the procedure was revised.
Of the 51, three were found signed off as having visual veld inspections conducted by this inspector. Two of the three had been reinspected 'sy qualified inspectors because the original inspection had been identified as unsatisfactory by HE 1. There was no evidence that the1.remaining item had been reinspe ted af ter acceptance of the velding by HE This item was covered with Thermolag and was identified as inaccessible. The time periods in question coincide with a time period in which the computer data base was less accurate than desirable. Concerns regarding the NDE exclusion problem have been documented in QA/QC PDR 56, l vhich is discussed in Section 5.2.3 of this Results Report, i I
HE 2, who had only been certified go conduct inspections of cable pulling, !
vas placed into Phase III because of insufficient experience and the inability to verify high school education because of name changes. The print out identified approximately 68 of this type of inspections. This work had been conducted between March 1980 and July 1980 when the data base was reasonably accurate. Because cable pulling has been identified as a non recreatable inspection,'the ability of inspector HE 2 to conduct inspections properly is indeterminate.
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R visten: 1 RESUI.TS REPORT Fase 102 of 138 ISAP I.d.1 (Cont'd) s.ttachment 7 (Cont'd) i I
- HE.3 failed the examination relating to the procedure for inspection of
. electrical conductor seal assemblies. This person was placed into Phase III because of the subsequent issuance of an 'all electrical certification" without rotesting and without exclusion for conduct of inspections to the subject procedure. An "all electrical certification" encompassed certification to all existing electrical inspection procedures. During the time period in question (October 1983 to September 1985), the computer data base identified seven inspections conducted per the procedure. Further examination of the inspection reports indicated that the inspections should have been conducted using a different procedure. As a result, TU Electric issued NCR E86 250456 to re evaluate the equipment that had been inspected.
This inspector was also evaluated under TU Electric CAR 0$0 regarding inspection of pre insulated environmentally sealed splices and, as a result, witnessed wasby terminated because documented inspections hs.d not actually been the inspector. The period between October 1983 and September 1985 was one in which an undesirably high error race in the computer data base vcs identified. Because of this, W Electric conducted a manual 3
j search of the inspection packages for all applicable electrical conductor seal assemblies and identified five that had been inspected by HE.3, W Electric was requested by the QA/QC Review Team to reinspect and/or evaluate the acceptability of these assemblies. TU Electric agreed to do (O so.
TU Electric is also proceeding to resolve concerns identified in the above referenced NCR and CAR. There is no further concern regarding this inspector's ability to inspect the subject electrical conductor seal assemblies adequately.
HE-4 was placed into Phase III because this individual had been certified Level II to several electrical inspection procedures without having sufficient experience in April and June 1979. The data base identified over 1,000 inspections between April 1973 and February 1980. One thousand
' one hundred and sixty three of these inspections were cable pulla and meggering that were determined to be non recreatable. Meggering of all i safety related electrical cables is repeated during startup testing. For this reason there is no further concern regarding maggering inspections conducted by HE.4 Twelve conduit and raceway inspections that were conducted in April and May of 1979 sere identified as recreatable. These twelve inspections were comprised of 96 objective decisions, seven of which were incorrect, and 16 subjective decisions, all of which were correct.
! The objective disagreement rate of 7.294 for these twelve inspections falls outside of the 54 limit. The ability of this inspector to conduct inspections properly for the procedures for which he was certified is indeterminate.
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- tr R;visten: 1 RESULTS REPORT ISAP !.d.1 (Cont'd)
Attachment. 7 (Cont'd
- HE 6 was initially certified without having sufficient experience to inspect embedded conduit and sleeves and conduit fabrication in December 1978.
In addition, the NDE exclusion problem for cable tray inspection was evaluated between June 1979 and December 1979. No inspections for this inspector other than coatings inspections were identified in the computer data base between December 1978 and January 1980, which was the time period of concern. This was in a period in which the compute r data base was determined to be less accurate than desired. A manual search of Unit 1 inspection records was conducted by TV Electric for this period of time.
No thisinspections, other than coatings inspections, were identified during search. Because coatings were declassified as non safety related, none of the coatings inspections were reinspected. Because the manual records search diri not include Unit 2 records, the sbility of this inspector to conduct inspections adequately is indeterminate. Concerns regarding the NDE exclusion problem have been documented in QA/QC PDR 56, which is discussed in Section 5.2.3 of this Results Report.
HE 7, who was placed :.nto Phase III bece.use of insufficient education, was certified to inspect Hilci bolts, conduit fabrication, and conduit and support installation.
Over 200 inspections were identified as having been conducted during the period of concern between July 1979 and January 1980.
A total of 49 recreatable inspections was identified and reinspected with satisfactory results. Although this is one short of the desired 50 inspections, there is a sufficient amount of data to conclude that this inspector was capable of conducting the required inspections.
HE 8 was placed into Phase III because of insufficient experience to support the initial certifications to inspect conduit fabrication and electrical termination inspections in November 1980. Fifty recreatable electrical termination inspections, initially conducted between November 1980 and March 1981, were reinapected with a 6.244 disagreement rate on objective attributes.
Because the objective disagreement rate exceeded the five percent limit, an additional 50 recreatable inspections were selected for reinspection. These inspections that were initially conducted between March 1981 and October 1981 were also all termination inspections. The composite results of the first 50 reinspections and '.he second 50 reinspections rate.
disagreement were 5.40% objective disagreement rate and 0.004 subjective Because the composite reinspection results for objec.tve attributes exceed the 54 limit. HE 8 failed the Phase III evaluation. A root cause/ generic implication analysis of the failure of this inspector to meet the Phase III acceptance criteria was conducted and is described in Section 5.8 of,this Results Report.
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Rsvisten: 1 REstJ1.TS REPORT tale 104 of 138 ISAP I.d.1 qj (Cont'd)
Attachment 7 (Cont'd HE 10 was placed into Phase III because of lack of experience for the
' initial certification. For the time period in question, which was March 1983 to June 1984,:a total of 54 inspections was identified by TU Electric from the computer data base. Of the 54, 28 inspections were recreatable and were reinspected with satisfactory results. The accuracy of the data base is lower than desirable for the applicabie time period. However, there is substantial positive evidence based on the 28 inspections that were reconducted that this inspector was capable of satisfactorily accomplishing the required inspections.
HE 12 was placed into Phase III becaure of lack of experience for his initial certification for cable tray inspection and beccuse, between July 1979 and Decemb*r 1979, the NDE exclusion problem for cable tray and conduit inspection existed. As shown on Attachment 7, 50 ree iacable inspections were reinspected from the time of his initial certification with acceptable results. With regard to the NDE exclusion probles IV i Electric identified 72 cable tray and 75 conduit inspections from the computer data base that had been conducted by this inspector. One visual weld inspection of cable tray was identified that may have been conducted by this inspector. In addition, during the processing of other p reinspection documentation, the QA/QC Review Team identified another visual lQ weld inspection of cable tray that had been conducted by this inspector during the time period in question. HE 12 is acceptable except for the NDE exclusion problem, which is documented in QA/QC FDR 56, which is discussed in Section 5.2.3 of this Results Report.
HE 13 was placed into Phase III because of insufficient education and experience to support his certification for cable pulling ard maggering.
The computerized data base identified over 300 inspections, all cable pulling, conducted during the tir.s of comern between July 1980 and October i
1980, ouring which the data base was reasonably accurate. Three of the inspections were conducted prior to issuance of the certification in July 1980.
TU Electric has issued NCR E86 105066% to document and resolve this problem. Cable pulling and megjering have been identified as non recreatable inspections and the ability of this inspector to conduct inspections adequately is indeterminate.
i i HE 17 was placed into Phase III because he had insufficient experience to support his initial certification in July 1980 to conduct electrical cable pulling inspections. In September 1980 he was certified to conduct meggering, also with minimal experience, and in November 1980 he received certifications that allowed the inspection of Class V pipe support hangers.
There was also insufficient experience to support the latter certifications. Electrical cable installation and meggering inspections are not recreatable inspections. Fifty reinspections of Class V pipe
s R;visien: 1 Page 105 of 138 RESULTS REPORT ISAP I d.1 (Cont'd)
Attachment 7 (Cont'd
- supports were successfully conducted. Considering the relative difficulty of pipe support inspections, these reinspections provide reasonable assurance that HE.17 was capable of conducting inspections for which he had been certified despite the lack of required experience. HE.17 is acceptable.
HE 18, vhe was placed into Phase III because of insufficient experience, was certified only to inspect cable pulling and maggering. The data base identified over 400 cable pull inspections between March 1983 and May 1983.
This time frame is during a period in which the data base accuracy is less than desirable. Cable pulling and meggering have been identified as non recreatable inspections, and the ability of this inspector to conduct inspections adequately is indeterminate.
HE 19, who was certified only to inspect cable pulling and meggering, was placed into Phase III because of a lack of experience. The computerized data base for HE.19 identified over 1,000 cable pull and maggering inspections betws ea February 1980 and June 1980, the period in question.
This time frame is in a period during which the computerized data base appears to be reasonably accurate. These inspections have been identified as non recreatable, and the ability of this inspector to conduct inspections adequately is indeterminate.
HE.20 was initially placed into Phase III because of the NDE exclusion problem for conduit and support inspection. The period of time of concern was from July 1979 until December 1979. From the computer data base, TU Electric identified 91 inspections during this time frame and no visual inspections of welds were conducted by this inspector. This work was accomplished during the time in which the computer data base was less accurate than desirable. In April 1984 this same inspector was certified as a Level III mechanical /velding inspector with insufficient experience.
In June 1984 this inspector was transferred to TU Electric Dallas office as a QA auditor and was not utilized as a Level III inspector at Comanche
- Peak, Concerns regarding the NDE exclusion problem have been documented in QA/QC PDR.56, which is discussed in Section 5.2.3 of this Results Report.
No concerns exist regarding the Laval 12I emchanical/ welding certification because HE 20 did not utilize this certification. HE 20 had a four year college degree and substantial experience in the electrical area. There were no concerns identified regardird his electrical inspection certifications or his auditor certifications.
HE 21 was placed into Phase II,I because of insufficient experience to support his initial certification in October 1978 for inspection of Hilti bolts. He was also in Phase III because, between July 1979 and December 1979, the NDE exclusion problem for conduit raceway inspections existed, From the computer data base, TU Electric identified approximately 75 l 1
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Revision: 1 Page 106 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 7 (Cont'd j inspections of cable tray hange.s (probably of Hilti bolts for the hangers) from October 1978 until July 1979. None of these inspections were reinspected because of.the extensive rework program being conducted by TU Electric on cable tray hangers. It is possible that this inspector also conducted other inspections during this same time period that do not appear on the data base because of data base inaccuracies. Fifty recreatable conduit raceway inspections that were conducted between July 1979 and August 1979 were identified. These items were reinspected with acceptable results. Because of the extensive period of time (nine and one-half months) between his initial certification and the recreatable inspections, there is not c.onclusive evidence that this inspector was initially capable of conducting the required inspections. However, the results of these 50 reinspections provide a substantial amount of positive information that HE 21 was his lack capable of initially eceducting the required inspections despite of experience. 'Jith regard to the NDE exclusion problea, TU Electric identified 201 conduit inspections from the computer data base for which no visual weld inspections were conducted. The NDE exclusion problem is documented in PDR 56, which is discussed in Section 5.2.3 of this Results Report.
HE 22 was also pla:ed into Phase III because of insufficient experience to support his certification in October 1978 for inspection of Hilti bolts.
l The computer data base identified 101 cable tray hanger inspections (probably of Hilti bolts for the hangers), two lighting conduit inspections, two lighting termitiation inspect.'.ons, and nine conduit fabrication inspections between October 1978 and April 1979. No inspections were identified between April 1979 and December 1979. The 114 ie.speccions described above were identified as nonrecreatable. It is l
' possible that other inspections were conducted that were not identified because of computer data base inac::uracies. In December 1979 and January 1980, 50 recreatable conduit inspections were conducted. These were i
I successfully Jainspectad. HE 22 was initially certified for this type of conduit inspection in December 1979.
i Because of the 14 1/2 month period between the initial Hilti bolt certification and the recreatable conduit inspections, there is a lack of conclusive evidence that this inspector was initially capable of conducting :he required Hilti bolt inspections.
However, the results of these 50 conduit reinspections, which are more difficult to conduct than Hilti bolt inspections, provide a substantial amount of positive information that HE 22 was capable of initially conducting the required inspections despite his lack of experience.
l The reinspection results for the TU Electric historical QC inspecens are tabulated on the following page.
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a Revision: 1 Page 107 of 138 RESULTS REPORT I
ISAP I.d.1 '
(Cont'd) i Attachment 7 (Cont'd l
Historical Electrical Error Rate Reinspections Inspector Conducted Subjective Objective HE 1 NDE Exclusion - -
HE-2 0 - --
HE 3 0 - --
HE 4 12 04 7.294 HE 5 50 On 3.81%
HE 6 0 -- -
NDE Exclusion - --
HE 7 49 6.19% 4.964 HE 8 100 HE 9 On 5.404 84 4.19%
HE 10 3.89%
?. 8 On 4.41%
HE 11 90 HE-12 On 3.91t 50 0.654 4.734 NDE Exclusion - --
HE-13 0 - --
HE 14 50 HE-15 On 0.764 NDE Exclusion -- --
HE-16 NDE Exclusion -- --
HE 17 50 HE-18 On 4.204 0 - -
HE-19 0 -- --
HE 20 NDE Exclusion -- --
0 -- -
HE-21 50 04 0.26%
NDE Exclusion -- -
HE-; 50 6.454 4.724 8
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Revision: 1 Page 103 of 138 RESULTS REPORT ISAP I.d.1
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Attachment 8 Phase III Evaluation of TU Electric Current QC Inspectors j Original I.d.1 Scope The following sections:of this attachment describe the detailed Phase III evaluations that were conducted for TU Electric current QC inspectors These are grouped as electrical QC inspectors, I&C/ radiation vaste management system QC inspectors, NDE/thermolag QC inspcetors, mechanical QC inspectors, protective coatings QC inspectors, Level III QC inspectors, and Brown & Root inspectors maintaining TU Electric certifications. The reinspection results are tabulated on the last pages of this attachment.
TU Electric Current Electrical QC Inspectors Seven TU Electric current electrical QC inspectors were referred to Phase III for further evaluation. The results of the Phase III reinspections are shown on the last pages of this attaennent.
CE-1 failed examinations for inspection of instrument racks and Hilti bolts.
CE-1 was placed into Phase III because of the subsequent issuance i of an "all electrical certification" that did not exclude these two areas for which no re exaninations had been conducted. An "all electrical O certification" encompassed certification to all existing electrical inspection procedures. During the period in question between May 1982 and l
t February 1985, the data base showed over 5,000 inspections, none of which were for instrument racks, and 32 of which were for Hilti tults. A manual review of all the inspection records for all safety-related instrument racks was conducted by TU Electric, and it was verified that CE 1 did not conduct any inspections of inst:.usent racks. Therefore, no concerns remain regarding inspection of instrument racks by this inspector. Of the 32 Hilti inspections, 21 were recreatable and were reinspected. Results of these reinspections were within the error rate limits. There is substantial, but not conclusive, evidence that this inspector was capable of inspecting Hilti bolts.
CE 2 also failed the examination for the inspection of instrument racks and was subsequently certified in same manner as CE 1 without an exclusion for this type of inspection. ior the period between December 1982, when the certification was issued, and December 1984, when this type of inspection was excluded from the certification, the data base shows over 4,000 inspections were performed, none of which included inspection of instrument racks. The manual review of all the inspection records for all instrument racks that was conducted by TU Electric s so confirmed that CE 2 did not conduct any inspections of instrument racks. No concerns remain regarding this inspector. '
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Revision: 1 Page 109 of 138 RESULTS P.EPORT ISAP I.d.1 (Cont'4)
Attachment 8 (Cont'd)
In a marmer similar to that for CE 1 and CE 2, CE 3 failed an examination to conduct cable grip support installation inspections and was subsequently issued an all electrical certification without re-examir.ation in this area.
The applicable time period between April 1983 and January 1986 showed over 2,000 inspections being conducted, none of which were for this activity.
The inspections shown in the computer data base provide substantial positive information that irstallations.
this inspector did not inspect cable grip support However, because of computer data base inaccuracies, a totally conclusive determination cannot be made from the available information.
CE-4 was placed into Phase III because of lack of experience to support a certification in December 1978 to inspect Hilti bolts. In January 1979, CE-4 was certified to inspect cable trays, also with insufficient experience.
1979.
The computer data base did not list any inspections until June A total of 50 recreatable cable tray inspections were identified in the period from June 1979 until November 1979 and were successfully reinspected. These reinspection results provide adequate evidence tha CE 4 was capable of conducting inspections for which h) had been certified despite the lack of required experience. CE 4 is acceptable.
CE 5 was placed into Phase III because of the NDE exclusion problem for conduit support inspectionr, for the period of time from September 1979 until December 1979. Fror, the data base, TU Electric identified 44 of these inspections for which no visual inspections of welds were conducted.
The time period in question was during a period when the data base was less accurate than desirable. Concerns ragsrding the NDE exclusion problem have been documented in PDR 56, which is discussed in Seccion 5.2.3 of this Results Report.
CE 6 failed an examination for electr!. cal separation inspection and was subsequently certified all electrical in December 1982 without re examination in this area. Because of this and the fact that two years later he was again recertified all electrical despite recoannendations from the Level III electrical inspector that electrical separation inspection and inspection of the surface preparation of penetration veld neck flanges be excluded, CE 6 was placed into Phase III.
The data base indicated that over 9,000 inspections were conducted during the period in question between December 1982 and May 1986, none of which covered the areas in question.
Subsequent information not obtained from the computer data base was identified by TV Electric and made available to the QA/QC Review Team.
This information indicated that; CE 6 had conducted a substantial number of electrical separation inspections. An interview of this inspector by the 1 QA/QC Review Team indicated that he had not conducted any inspections of the surface preparation of penetration veld neck flanger,, and no further
Revision: 1 Page 110 of 138 i R_ESUI.TS REPORT l ISAP I.d.1 (Cont'd)
Attachment 8 (Cont'd)
- evaluation in this area is required. Data base inaccuracies during the
- time period in ques-tion exist, and electrical separation inspections are not recreatable. However, TU Electric has initiated NCR CE 87 4577, which will problems. result in an overall program to correct generic electrical separation This program will encompass reinspections of electrical separation that were conducted by this inspector. Therefore, the ability of this inspector to conduct inspections of electrical separation adequately is of no further concern.
CE-7 was placed into Phase III because of insufficient experience to support his November 1983 certification for cable termination inspections.
A total of 50 recreatable inspections was identified in the period between December 1983 and March 1985. It should be noted that all but fcur of these inspections occurred in the December 1983 to June 1984 time frame.
Of these remaining four, three were conducted in September 1984 and one in March 1985. These 50 inspections were reinspected with results within the agreement race guidelines, indicating that CE 7 was capable of conducting the required inspections despite the lack of required experience. CE 7 is acceptable.
i O TU Electric Current I&C/ Radiation Vaste Management System (RWMS) QC Inspectors IC 1 was placed into Phase III because of an inadequate amount of experience to support his certification in March 1982 for instrumentation inspection. A total of 50 recreatable instrumentation inspections were identified in the computerized data base and reinspected. Thirty of these inspections fell into the first 90 days and 20 into the second 90 days.
Just after these reinspections were completed and before the data was compiled, an additional 21 Hilti bolt reinspections were identified in the first 90 days. The composite results of the 30 instrumentation reinspections and the 21 Hilti bolt reinspections for the first 90 days was a 5.06% objective disagrnement race and a 1.324 subjective disagreement rate, which fell slightly outside the ISAP I.d.1 acceptable rates. It was noticed that the instrumentation reinspection results were not as good as those for the Hilti bolt reinspections. The results of the 50 instrumentation reinspections were then compiled and determined to be a 6.64% objective disagreement race and a 1.894 subjective disagreement rate.
There were no objective disagreements and only a 14 subjective disagreement rate for the 21 Hilti bolt reinspections. Analysis of the reinspection data indicated that a large number of disagreements were concentrated on the attributes that required identification and recording of unique identification numbers on instrumentation system supports and racks.
Further investigation revealed that the historical TU Electric requirements were vague and ambiguous in this area. As a result, QA/QC PDR 70 was O
- ,..- ._,._ _ ,_ _ _,_ __ __.._._ ___..___.___ _ __.._ __.__ __ _ ._ _____. _ _ . . ~ _ . ,
Revision: 1 Page 111 of 138 ISAP I.d.1 (Cont'd) ,
1 Attachment 8 (Cont'd) issued to document this lack of definitive requirements relating to identification of instrumentation supports. Because of this problem, the ;
results regarding this attribute have been excluded from the reinspection results for IC 1, IC 1 has been found to be acceptable based on the composite results of the 50 instrumentation inspections and the 21 Hilti bolt inspections.
TU Electric Current NDE/Thermolag QC Inspectors Inspector NT-1, who was placed into Phase III because of insufficient experiince in the areas of Hilti bolt and baseplate grouting inspection, had 50 reinspections conducted on his first three month's work with acceptable results.
negative impact on these Possible data base inaccuracies did not have any results.
NT 2 was placed into Phase III because he was certified to conduct Hilti bolt inspections in November 1983 without a high school CED. NT-2 obtained a high school GED in March 1984. Fifty reinspections were conducted with acceptable results for this inspector. These 50 reinspections consisted of 36 Hilti bolt and two Richmond Insert inspections initially conducted l
between December 1983 and April 1984 and an additional 12 visual veld inspections initially conducted in July and September 1985. NT-2 was certified to inspect velds visually in June 1985. Since both the 38 Hilti bolt / Richmond Insert inspections and the 12 velding inspections occurred close to the initial applicable certifications, they were considered to be adequate measures of any impact that lack of education may have had upon this inspector's ability to conduct the required inspections. NT-2 is acceptable.
TU Electri Current Protective Coatings QC Inspectors There was one inspector (PC 1) in this area placed into Phase III because of lack of education. He was certified only to inspect coatings. The computer data base identified over 3,000 inspietions performed between October 1977 and May 1982. All inspections we e coatings inspections.
Because protective coating are no longer classified as safety related at CPSES, none of these inspections were redone, bo concerns remain regarding this individual. ,
l TU Electric current Mechanical QC Inspectors I
Inspector NM 1 had the require,d number of reinspections conducted with l acceptable results. NM 1 was'placed into Phase III because the education cited in his certification documentation could not be validated. He was initially certified to inspect Hilti bolts in April 1982. The 50
l Revision: 1 Page 112 of 138 RESUI.TS REPORT ISAP I.d.1 (Cont'd)
Attachment 8 (Cont'd) {
.reinspections that were conducted consisted of 30 Hilti bolt inspections I
.' originally conducted in April and May 1982 and 20 instrumentation inspections originally; conducted in September, November, and December 1982. l The reinspection results indicate that this inspector was capable of 1 conducting the required inspections despite the lack of required education.
NM-1 is acceptable. !
NM 2 was certified in December 1983 but had no high school GED until February 1984.
This inspector's certifications were inactivated by TU Electric in September 1985 because of his failure to pass an examination for visual inspection of welding. As a result, TU Electric issued NCR M85-200285.
The data base identified a total of 439 inspections, primarily of cable tray hangers, conducted by this inspector from December 1983 until
- eptember 1985, the time period in question. No cable tray hangers were reinspected because of the extensive rework program being conducted on cable tray hangers. None of the remaining inspections (27) could be recreated.
The ability of this inspector to conduct the required inspections adequately is indeterminate.
In the case of NM 3, the NDE exclusion probles relating to inspection of t conduit raceways occurred during the period between July 1979 and December l 1979. From the computer data base, TU Electric identified that 91 conduit i
raceway inspections were cor. ducted, none of which included visual inspection of welds. This work was accomplished during a period of time in which the data base was less accurate than desired, and these inaccuracies should be considered during resolution of the NDE exclusion problem.
Concerns regarding the NDE exclusion problem have been documented in PDR-56, which is discussed in Section 5.2.3 of this Results Report.
TU Electric current Laval III QC Inspectors There were four inspectors from this category placed into Phase III.
Because Level III inspectors do not normally conduct field inspections, the circumstances regarding each of these individuals requires e,glanation.
Inspector L 1 was initially certified as a Level II inspector for Hilti Boles and cable repair in September 1980. In January 1981, ANSI N45.2.6 and Regulatory Guide 1.58 became TU Electric commitments, and inspectors were required to have a high school diploma or a GED. Because this i
inspector did not receive a high school GED until May 1982, he was placed into Phase III for this period of time. No inspections were included in the computer data base during this time frame, for which most of the data base appeared to be reasonably \, accurate. 'In addition, the position that this individual held during this period of time did not normally involve l conducting inspections. No concern remains regarding this individual's
! certification package discrepancies or on possible hardware impact.
O
Revision: 1 Page 113 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd) l l
Attachment 8 (Cont'd)
I
- L 2 was initially certified as a Level III Electtical in July 1982. It was !
discovered by TU Electric in May 1985 that he had neither the required education nor experience for: thic certification. A review of this individual's work by TU Electric indicated that he had not certified any inspection personnel nor had he conducted any inspections. He had, l however, been involved in the revision and/or approval of nine TU Electric inspection procedures. As a result, the QA/QC Review Team reviewed these l nine inspection procedure revisions and determined that the changes were I either editorial changes or process improvements. No concerns remain regarding this individual's discrepant certifications or on possible hardware impact.
L 3, who was certified as a Level III Coatings inspector in January 1984, was placed into Phase III because of insufficient experience. The computer data base identified approximately 12 inspections, all of coatings, as having been conducted by this individual. Because coatings are no longer classified as safety related, no reinspections were conducted. No concerns remain for this individual.
L 4 was placed into Phase III because of the NDE exclusion problem relating to inspection of cable tray hangers. The period of time in question was from October 1979 until December 1979, during which the computerized data base identified six cable tray hanger inspections. No visual weld inspections were identified as having been conducted by this inspector I
until after his certification in this area in early January 1980. This l work occurred during a time in which the computerized data base was less accurate than desirable. Concerns regarding the NDE exclusion problem have been documented in PDR 56, which is discussed in Section 5.2.3 of this Results Report.
l Current Brown & Root QC Inspectors Maintaining TU Electric Certifications
! (Hilti's) only one Hilti bolt inspector was evaluated in this category. This inspector (H3 1) was certified for inspection of anchor bolts in March 1984 after faili g his examination (incorrectly scored). A search of the computerierd data base between March 1984 and Augusc 1986 identified over i
' 300 inspec m.,ns, but only seven were anchor bolt inspections. Of these seven, two ware recreatable. The seven inspections were conducted on ASME supports and equipment for which the discrepant TV Electric certification was not applicable. As a result of tnis information, Brown & Root revoked his ASME certification in this, area, conducted retraining, and successfully re examined him. An interview .vas conducted by TU Electric QA with HB 1, and he stated that he had not performed any inspections of Hilti bolts O
1
Revision: 1 Page 114 of 138 RESULTS REPORT
)
ISAP I.d.1 v (Cont'd)
Attachment 8 (Cont'd) under the discrepant TU Electric certification, In addition, the Hardware
.' Validation Program for ASME pipe supports includes reinspection of Hilti bolts. No outstanding; concerns regarding this inspector remain.
The reinspection results for TU Electric current QC inspectors are tabulated on the following two pages of this attachment.
O O
9 RSvision: 1 RESULTS REPORT l ISAP I.d.1 (Cont'd) i Attachment 8 (Cont'd)
Current Error Rate Electrical Reinspections Inspector Conducted Subjective Objective CE 1 21 5.004 2.67%
CE-2 0 -- --
CE-3 0 -
CE 4 50 On 1.82%
CE-5 NDE Exclusion -- --
CE-6 0 -- --
CE-7 50 On 2.17%
I6C/RWMS Inspector IC-1 71 1.31t 2.72%
NDE/Thermolag Inspector NT-1 50 8.454 NT-2 0.67%
50 On 2.954 Protective Coatings Inspector PC 1 Coatings only - --
Non ASME Mechanical Inspector NM 1 50 4.284 gg.2 1.20%
0 - -
NM 3 NDE Exclusion - -
Level III Inspector L.1 0 . --
L.2 0 '.. - -
L3 Coatings Only - -
L4 NDE Exclusion -- -
Revision: 1 RESULTS REPORT ISAP I.d.1 O (Cont'd)
Attachment 8 (Cont'd)
. B&R ASME Inspectors
- Maintaining TU Electric Error Rate Non ASME Reinspections Certifications Conducted Subjective Objective HB 1 2 og og i
O i
t-t t
i O
4 I- -
- e e w=.W es v- - w g w- w w, a-ww-w,--,-.--nw . - - - - - - - - - - - - - - - - , - -~- -
Rsvision: 1 Pego 117 of 138 RESULTS REPORT ISAP I.d.1 i
(Cont'd)
Attachment 9 i
Phase III Evaluation of Brown & Root Current QC Inspectors l Two inspectors placed into Phase III in this area were evaluated. AM 1, whose examination had been incorrectly scored, had failed the examination for mechanical fabrication inspection. The data base indt:ated only one mechanical fabrication inspection was performed betweer. July 1980 and February 1981, the period in which the inspector held the discrepant certification.
This inspection was not recreatable because the inspection had been reconducted. The time period in question coincided with the time period in which the computerized data base is considered to be reasonably accurate.
No concerns remain regarding this individuals discrepant certification or any possible impact on the hardware.
AM-2 also failed the examinat ..on for mechanical fabrication inspection but had been certified in July 1983 because the examination had been incorrectly scored. When the examination error was identified, Brown &
Root re-examined him and recertified him in June 1986. From a search of the computer data base, Brown & Root identified 38 inspections conducted unde. this certification. None of these inspections were recreatable. A review of the associated inspection reports indicated that the inspections consisted primarily of verification of proper transfer of material heat numbers during cutting operations in the fabrication shop. The only other lh activity identified was participation in hydrostatic testin5 of RPV Control Rod Drives under the supervision of a Level II inspector. AM 2, who is still employed as an inspector at CPSES, was interviewed by the QA/QC Review Team.
This interview confirmed that the above activ.cies were the only ones conducted by this individual under this certification. AM 2 spent the bulk of his time conducting radiography and only helped in the areas noted above on an as-needed basiswhen his radiography work load would allow. Based on the AM-2 interview, verification that applicable inspections were limited to hydrotests under Level II supervision and to material heat number transfer verification, and coupled with the simplicity of the involved inspections, no concerns remain regarding this individual's discrepant certification or any possible impact on the hardware.
Error Rate Reinspections Inspector Conducted Subjective Objective AM 1 0 - -
AM 2 0 - -
O
Revision: 1 Page 118 of 138 RESULTS REPORT
N ISAP I d.1
[Y (Cont'd)
Attachment 10 Explanation for Placing Inspectors for Related ISAPs Into Phase III l
TU Electric Histor0 cal Mechanical TM-1 This individual was certified Level I to CP-QP 11.2, "Surveillance &
Inspection of Concrete Anchor Bolt Installation," on 3/17/82, CP-QP 11.10 "Inspection of Electrical Raceway / Support Systems" on 3/26/82, and CP-QP-11.14, "Structural Steel Inspection Activities" on 3/26/82 with no high school diploma or GED as required by Regulatory Guide 1.58.
TM 2 This individual was certified Level II to QI-QP 11.81, "Instrument and Tubing Installation Inspection", and to QI-QP il.8 3, "Instrument Installation Inspection", on 8/6/80 with insufficient experience to support the Level II certification.
TM 3
.(
This individual was certified Level II to QI-QP 11.81, "Instrument and i
Tubing Installation Inspection", and to QI-QP 11.8 2, "Inspection of the
( Fabrication of Instrumentation Supports and Rack Assemblies", on 1/15/80 vith insufficient experience to support the Level II certification.
i TM 4 This individual was certified Level II to CP-QP 11.2, "Surveillance &
Inspection of Concrete Anchor Bolt Installation" on 11/30/80 with insufficient experience to support the Level II certification.
TM 5 i
This individual was certified Level I to CP-QP 11.2, "Surveillance and Inspectiens of Concrete Anchor Bolt Installation", on 8/28/81 with insufficient 1.58.
experience to suppert certification as required by Reg. Guide TM 6 This individual was certified Level I to CP-QP 11.2, "Surveillance &
Inspection of Concrete Anchor Bolt Installation", on 11/5/80 with insufficient experience and had'not received a CED as indicated. This
!v O
Ravision: L RESUI.TS REPORT ISAP I.d.1 (Cont'd) l Attachment 10 (Cont'd)
. individual was then certified Level II to QI-QP 11.8 1, "Instrument and
- Tubing Installation. Inspection", on 2/11/81 with insufficient experience and no GED as required.
TM 7 This individual was certified Level I to CP-QP ll.2, "Surveillance &
Inspection of Concrete Anchor Bolt Installation", and to CP-QP-11.10,"
Inspection of Elect. Raceway / Support Systems", on 12/15/82. His education could not be verified as required by Reg. Guide 1.58.
TM 8 This individual was certified Level II to QI-QP-il.4 1 through 17, Coating Inspections, on 10/9/80 with insufficient experience to support the Level II certification.
TM 9 This individual was certified Level I to CP-QP il.2, "Surveillance &
Inspection of Concrete Anchor Bolt Installation," on 11/13/80 with no high school diploma or GES and a lov test score on the exam. This individual was re examined on 12/16/83, failed the exam, and the certification was not re-issued.
Brown 6 Root Historical Mechanical BM 1 The education and the relevance of experience used as the basis for certification could not be substantiated. The certifications were for visual examination (VT) and Fabricator Inspector (MIFI) granted 9/8/80.
BM 2 This individual was certified Level II visual examination (VT) on 8/11/78 after re administration of the same exam one day after failure with no documentation of retraining to show evidence of capability.
BM ">
This individual was certified to Visual Examination (VT) and Liquid Penetrant Examination (PT) on 10/26/78 and to QI-QP-11.3 2, "Cable Tray Hanger Insp.", to QI-QP 11.3 4,'"Exposed Conduit, Condulet, Elect. Box &
Support Insp.", and to QI-QP il.3 5, "Cable Tray Insp", on 3/21/79.
However, there was documented evidence that the activities performed by
Revision: 1 Pags 120 of 138 RESULTS REPORT
(
G ISAP I.d.1 (Cont'd)
Attachment 10 (Cont'd)
.this individual were considered to be questionable (i.e. performed cable l tray hanger and accepted required welds that had not been performed and weldsents were accepted that could not have been welded per the design drawing), but no documentation of corrective action was available.
BM 4 This individual was certified Level II for Liquid Penetrant Examination (PT) on 7/19/79 and Leak Testing (LT) on 8/24/79 based on having a high school diploma. However, this individual had not graduated from high school.
BM 5 This individual was certified Level II for visual examination (VT) on 1/26/78 after having taken the Practical Exam twice the same day, first failing and then passing it.
BM 6 This individual was certified Level II for Liquid Penetrant Examination O (PT) and Visual Examination (VT) on 1/30/79 based on a BA Degree.
this individual's education could not be substantiated at either the high However, school or college level.
BM 7 This individual was certified Level II for Visual Examination (VT) on 7/20/78 without sufficient experience to support the Level II certification.
Subcontractor QC Inspectors Hunt l HU-1 This individual was certified as a Level II concrete inspector on 6/28/76 with insufficient experience to support the Level II certification.
l O
l
Rovision: 1 Page 121 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 10 (Cont'd)
.Bahnson BN-1 This individual was certified as a QC Inspector (no level designator) with insufficient education and experience to the support certification. There was no objective evidence of OJT, and no written exam was available to substantiate capability.
BN 2 This individual was certified as a QC Inspector (no level designator) with insufficient experience to support the certification. There was no evidence of a written exam to substantiate capability.
BN-3 This individual was certified as a QC Inspector (no level designator) with insufficient experience to support certification. There was no objective evidence of OJT and no written exam to substantiate capability.
BN 4 This individual had performed questionable work while employed by Brown &
Root (see BM 3).
BN 5 This individual was certified as a QC Inspector (no level designator) with insufficient experience to support certification. There was no evidence of a written exam to substantiate capability.
BN 6 This individual v2s certified as a QC Inspector (no level designator) with insufficient experience to support certification. There was no evidence of a written exam to substantiate capability.
BN-7 This individual was certified as a QC Inspector (no level designator) with insufficient experience to support certification.
O
Revision: 1 RESULTS REPORT l
ISAP I.d.1 1 (Cont'd)
Attachment 10 (Cont'd)
.BN.8 This individual was certified as a Level II, with insufficient education to support certification.
BN 9 This individual was certified as a Level II, with insufficient experience to support certification.
O 6
0 0
0~
Rovision: 1 Page 123 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 11 Phase III Evaluation of TU Electric Historical Mechanical QC Inspectors Related ISAPs I
Nine TU Electric historical mechanical QC inspectors were referred to Phase III for further evaluation during this portion of the work. The overall results of these Phase III reinspections are shown on the last page of this attachment. Descriptions of the evaluations for each of these inspectors are contained in the following paragraphs.
Inspector TM-1 was placed into Phase III because of inadequate education to support his initial certifications for inspection of Hilti bolts, electrical supports, and structural steel. The computer data base identified over 500 electrical support inspections during the initial 90 days after certification from March 1982 to June 1982. This was a period l during which the computer data base accuracy was less than desirable.
However, 110 reinspections from the initial 90 day period after (
j certification were conducted with satisfactory results. Inspector TM 1 is acceptable.
l TM-2 was placed into Phase III because of insufficient experience to f support certification for inspection of instrumentation. The computer data base identifiec'approximately 69 Hilti bolt inspections, 16 of which were recreatable, during the period of concern between August 1980 and October 1980. This was during a period of time when the computer data base was reasonably accurate. The 16 recreatable inspections were reinspected with satisfactory results. Although the Hilti bolt inspections are not a direct measure of this inspector's ability to conduct instrumentation inspections, the ability to conduct these 16 inspections properly provides some additional confidence that if this inspector did conduct unidentified instrumentation inspections, the results would be satisfactory. The combination of the 16 Hilti bolt inspections, the lack of instrumentation inspections in the computerized data base, and the short period of the time of concern, provide reasonable assurance that this inspector is of no Concern.
TM-3 was also placed into Phase 3 because of insufficient experience to support certification for inspection of instrumentation. The time peried in question was January 1980 through November 1980. This time period coincides with the time period during which the computer data base was reasonably accurate. A total of 176 inspections were identified from the computer data base.
Of the 176 inspections, 40 were recreatable and were reinspected with acceptable results. The 40 inspections, which were all of instrumentation or instrumenta, tion supports except for two Hilti bolt inspections, were originally conducted between March 1980 and November 1980.
These 40 reinspections provide substantial positive information that this inspections. was capable of satisfactorily performing the required inspector
Rovision: 1 Page 124 of 138 RESULTS REPORT ISAP I.d.1
(']/
s,, (Cont'd)
Attachment 11 (Cont'd)
. The computer data base identified over 500 Hilti bolt inspections for
- inspector TM 4. The time period of concern was between November 1980 and July 1981. TM 4 wa's placed into Phase III because of lack of experience to support the initial certification for inspection of Hilti bolts. During time frame of concern when the computer data base was reasonably accurate, a total of 51 recreatable inspections were identified and reinspected with acceptable results.
Because these 51 inspections extend over a period of eight months there is less than conclusive evidence that this inspector was initially capable of conducting the required inspections. However, the overall acceptability of these 51 inspections provide a substantial amount of positive information -hat TM 4 was capable of satisfactorily conducting the required inspections.
TM-5 was placed into Phase III because of insufficient experience for certification to inspect Hilti bolts. During the period of concern from August 1981 through November 1981 the computer data base identified over 500 Hilti bolt inspections. A total of 260 inspections was reinspected with satisfactory results. TM 5 was acceptable.
TM 6 was placed into Phase III because of insufficient education and i \ experience to support initial certifications issued for Hilti bolt inspection in November 1980 and for instrumentation inspection in February 1981. For the Hilti bole certification, 51 inspections conducted between November 1980 and February 1981 were reinspected with acceptable results.
TM 6 was capable of conducting Hilti bolt inspections. For instrumentation, a total of 30 recreatable inspections were identified,19 of which had been conducted between July 1981 and December 1981 and the i remaining 11 between December 1981 and June 1982. The results of the reinspections for these 30 inspections were unsatisfactory with an objective disagreement rate of 28.174. Subsequent to conducting the instrumentation inspections it was discovered that 35 recreatable instrumentation tubing veld inspections had been conducted by TM 6 between December 1981 and January 1982, a period of time that fell between the initial and final 11 instrumentation inspections described above. These 35 inspections were reinspected, also with unacceptable results. Inspector TM 6 was esployed until July 1982 and in December 1982, TU Electric l prepared NCR No. I 82 02354S, Revision 1 which stated that it had been determined that a 1004 reinspection of instrumentation installations inspected by TM 6 was required. Although a number of nonconforming conditions were identified during the disposition of this NCR, the TU Electric reinspections were not completely documented and did not identify some discrepant conditions. QA/QC PDR 79 was issued to document this condition as well as other re11ted problems regarding TU Electric disposition of QC inspector certification problems. An additional 67 O
l
Rcvision: 1 Page 125 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 11 (Cont'd)
,. recreatable instrumentation tubing weld inspections were reinspected with unacceptable resul,ts. All recrectable or accessible instrumentation inspections that have_been identified have been reinspected. TM 6, although acceptable for Hilti bolts, failed.
TM-7 was placed into Phase III because of insufficient education. A total of 130 recreatable support inspections conducted during the first 90 days after this inspector's initial certification in December 1982 were reinspected with satisfactory results. TM 7 is acceptable.
TM 8 was placed into Phase III because of insufficient experience to support the initial certification for inspection of protective coatings.
No other certifications were held during the period of concern between October 1980 and May 1981 when the computer data base was reasonably accurate.
The computer data base identified approximately 750 coatings inspections as having been performed by this inspector. No reinspections were performed because of the reclassification of coatings as non safety related. There are no remaining concerns with this individual.
TM 9 was placed into Phase III because of lack of education to support certification to inspect Hilti bolts in November 1980. This inspector had previously been certified for visual weld inspection by Brown & Root in accordance with ASNT SNT TCLA requirements. ASNT SNT TCLA requirements for education and experience are less restrictive than Regulatory Guide 1.58 requirements. The computer data base identified over 1500 ASME pipe support and spool weld inspections between November 1980 and July 1984 Seven of these inspections were recreatable spool weld inspections that vare reinspected. The remaining ASME pipe support inspections were not reinspected because of planned TU Electric corrective action in this area.
A manual search of inspection records for Unit 1 did not identify any additional recreatable inspections. This inspector was ratested for inspection of Hilti bolts in December 1983 after the normal termination of his Hilticertification and failed the examination. He was not recertified for bolt inspection. The ability of this inspector to inspect Hilti bolts adequately is indeterminate.
The reinspection results for these Phase III evaluations are shown on the following page of this attachment.
O i
Revision: 1 Page 126 of 138 RESULTS REPORT
~
ISAP I.d.1 (Cont'd)
Attachment 11 (Cont'd)
Historical Error Rate Mechanical Reinspections Inspector Conducted subjective Objective TM 1 110 4.07% 3.124 TM 2 16 5.414 On TM 3 40 TM 4 On 2.924 51 3.964 0.254 TM 5 260 8.200 0.43%
TM 6 (Hilti bolts) 51 3.384 1.704 TM 6 (other) 132 04 9.08%
TM 7 130 3.554 3.01%
TM 8 0 -- --
TM 9 7 04 04 O
I l
- l 1
l O
R:visien: 1 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 12 Phase III Evaluation of Brown & Root Historical Mechanical Inspectors Related ISAPs Seven Brown & Root historical mechanical QC inspectors were placed into Phase III during this portion of the work. The results of reinspections conducted during Phase III evaluations are shown on the last page of this attachment. Descriptions of the evaluations for each of these inspectors are contained in the following paragraphs.
Inspector BM 1 had insufficient education and experience to support his initial certifications for visual weld inspection and mechanical installation and fabrication inspection in September 1980. In December 1981, this same inspector was certified Level III for mechanical equipment installation inspection, also with insufficient education and experience.
No recreatable inspections were identified from the computer data base. A manual search of Unit 1 inspection records identified a small number of additional inspections, all of which were nonrecreatable. TU Electric had identified concerns regarding the ability of this inspector in 1984 and had committed to a 1004 reinspection of his work. Documentation of these reinspections is limited and, based on the Unit 1 manual records search, incomplete. This situation is also addressed in QA/QC PDR 79, that was initially written to address questionable resolution of certification problems relating to TU Electric QC inspector TM 6. The ability of inspector BM 1 to conduct the required inspections satisfactorily is indeterminate.
During Phase I reviews, it was noted by the QA/QC Review Team that inspector BM 2 had failed an examination for visual weld inspection.
Because the same examination was administered the following day with no evidence of additional training, BM 2 was ultimately placed into Phase III for additional evaluation. The computer data base contained over 2,000 entries, and 50 recreatable pipe veld inspections were identified and reinspected. These inspections had been originally conducted over a period of time from August 1978 to July 1980. Although only eight of the 50 inspections were conducted in the first 90 days after certification, the agreement rates were well within the limits. Although not totally conclusive, there is a substantial amount of positive information that BM 2 was capable of conducting the required inspections.
BM 3 was placed into Phase III because information contained in his certification file indicated that inspections of non existent velds had been documented by this inspector. This problem had originally been identified by the NRC. The lack of documentation of the evaluation and correction of thiS concern by 'Atown & Root is addressed in QA/QC PDR 79 referenced under evaluations for TM 6 and EM 1 above. The computer data O
V l
Rcvision: 1 RESULTS REPORT O ISAP I.d.1 V (cont'd)
Attachment 12 (Cont'd)
- base identified over 200 cable tray hanger inspections conducted by this f
inspector.
These cable tray hangers were not reinspected because of the cable tray hanger corrective action program. A manual search of the inspection records for Unit 1 identified five inspections of welds on electrical equipment supports that could be recreated. However, because no inspection criteria for these inspections could be identified, QA/QC-PDR 81 was issued and the inspections were considered to be non recreatable for ISAP I.d.1 purposes. The manual search also identified 15 cable tray wold inspections that could be recreated. In a similar fashion, the original inspection criteria were identified to be incomplete and the inspections could not be recreated. QA/QC-PDR-80 was i.ssued to document this problem.
The ability of this inspector to conduct inspections properly is indeterminate.
BM 4, who was initially certified in July 1979, was placed into Phase III because of lack of education. Fifty recreatable inspections were identified durf ng the time period between January 1980 and May 1980. These 50 inspections, consisting of 32 Hilti bolt reinspections and 18 pipe supports, were reinspected with a 9.51% objective attribute disagreement I
/
rate, which is well outside the acceptable 54 limit. All 32 Hilti bolt O) inspeccions were associated with ASME pipe supports. The computer data base was researched for additional inspections from May 1980 until the termination date of this inspector in September 1980. The only inspections identified during this time frame, when the data base was reasonably accurate, were pipe support inspections, which were not reinspected because of the TU Electric corrective action program being implemented in this area. '1his inspector failed the evaluation of his inspection capabilities.
A root, cause/ generic implication analysis of the failurs of this inspector to meet the Phase III acceptance criteria was conducted and is described in Section 5.8.
In January 1978, BM 5 was given a practical examination for visual inspection of welds as part of the re certification process. Because this inspector failed the initial examination and was given the same examination l with acceptable results the second time on the same day, BM 5 was placed i
into Phase III. A total of 78 pipe veld inspections were identified during the 90 day period and were reinspected with an objective disagreement rate of 8.33 percent. This disagreement rate falls outside the ISAP I.d.1 limit for acceptability. Prior to conducting any further reinspections, a root cause/ generic implication analysis was conducted. This analysis, described in Section 5.8, indicated that the failure was related to one attribute that had no negative impact on,the acceptability of the hardware being inspected. Although BM 5 technically failed Phase III, the root cause/ generic implication analysis indicated that no further reinspections or evaluations were required.
4
Revision: 1 Page 129 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 12 (Cont'd)
.BM-6 was placed into Phase III because of insufficient education. Because
' of concents regarding this inspector's ability Brown & Root reconducted ever 300 tiquid panetrant inspections in 1979 that were originally conducted by this inspector on the fuel pool liner with acceptable results.
From the hanger computerized data base, TU Electric identified only 21 cable tray inspections. These cable tray hangers were not reinspected because of the corrective action program in this area. A manual search of Unit i records did not identify any additional recreatable inspections. Although no reinspections were available for witness by the QA/QC Review Team, the extensive number of reinspections conducted by Brown & Root with no identified discrepancies provides a substantial amount of positive information inspections.
that this inspector was capable of conducting the required BM 7 was placed into Phase III because of insufficient experience to support certification for visual inspection of welds in July 1978.
Although over 2,000 inspections were identified in the computer data base, they were all cable tray hanger inspections, which were not reinspected because of the TU Electric corrective action program, or conduit inspections that were not recreatable. A manual search of Unit 1 inspection records identified 94 cable tray weld inspections and one electrical equipment support veld inspection that eculd be recreated, but, as for inspector BM 3, inadequately defined inspection criteria made these inspections non recreatable. Thesc problems are documented in QA/QC PDR 81 and QA/QC PDR 80. The ability of this inspector to conduct the required inspections adequately is indeterminate.
The reinspection results for these Phase III evaluations are shown on the following page of this attachment.
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Revision: 1 Page 130 of 138
' ISAP I.d.1 (Cont' d)
Attachment 12 (Cont'd)
' Historical Error Rate
. Mechanical Reinspections '
Inspector -
Conducted Subjective Objeccive BM 1 0 . . ..
BM-2 50 On 1.78%
BM.3 0 . . ..
BM.4 50 5.004 9.51%
BM.5 78 04 8.334 BM 6 0 . . ..
BM.7 0 . . .. ,
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t e
T- ww- - , , -- - . - - - , - , -- ,_,---,,,__--------.--eww__.-,, - , , -,-w-,,wc,--
, ,w- --e,-,y-,--y---,-----------y--,--=myww-y- -w . - - - ,-y,
l Revision: 1 Page 131 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 13 Root Cause Analysis of Phase III Failure for HE 8 4
Inspector HE-8 failed the Phase III evaluation. This individual was certified as a Level II inspector for conduit fabrication and electrical cable termination inspections in November 1980. At the time of certification, HE-8 was a high school graduate and had six months experience as a electrical QC inspector trainee. TU Electric procedures stated that this inspector "should" be a high school graduate and have two years experience in electrical inspection and testing. ANSI N45.2.6 -
1978, which along with Regulatory Guide 1.58 became a TU Electric commitment in January 1981, recommends that a Level II inspector with a high school diploma have three years of related experience in equivalent inspection, examination, or testing activities. Forty hours of on-the job training were normally given by TU Electric to candidates for certification in the rwo areas in question. HE 8 received the standard forty Fours of on the job training for the conduit fabrication inspection certification and 69 hours7.986111e-4 days <br />0.0192 hours <br />1.140873e-4 weeks <br />2.62545e-5 months <br /> for the cable termination inspection certification.
Examination scores were 844 for cable termination inspection and 87% for conduit fabrication inspection. A grada of 80% was considered passing by TU Electric. There was a significant lack of experience for this inspector from what was normally required. The additional 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> of on the job training in the one area was considered inadequate by the QA/QC Review Team to compensate for this lack of experience; thus, this inspector was placed into Phase III.
A review of the reinspection results was conducted to determine if particular attributes or areas played a more significant role than others in this inspector's failure. In the first 50 reinspections there ve $
581 objective decision points, of which 55 were in arror. Of these $5 disagreements, 40 involved one attribute. In the second 50 reinspe there were 1323 decision points, of which 64 were in error. Fo e' c i c.t sv .*
these 64 were also related to one attribute, which was the same crit ;
that involved the 40 errors in the first 50 reinspections. 1"he recaaung 15 errors in the first 50 reinspections and the remaining 15 erri im second 50 reinspections were distributed among 12 different attributes / items with the maximum number of errors relating to any si a attribute bein5 8.
The attribute with 89 errors (40 plus 49) required the inspector to verify internals in panels and boxes. The detailed procedural instructions relating to this attribute clearly indicated that this inspection was only to be conducted on field installed components. The 89 errors involved HE 8 marking this attribute as "satisfactory" when there were no field installed components. The attribute should have been marked "not applicable". There were some cases identified in the 100 reinspections where HE 8 correctly marked the checklist "not applicable". Two other inspectors in Phase III ll
Revision: 1 Page 132 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 13 (Cont'd)
'during this same time frame that had reinspections of terminations had similar problems with this attribute. Tha not result of these errors appears to be that many vendor installed components received an additional site inspection that was not required. When these 89 errors are removed from the composite inspection results, the objective attribute error rate is 1.364. Except for this one problem attribute, for which there is no negative limits.
hardware impact, HE 8 fell well within the acceptable error rate The exact cause for HE 8's problem with this attribute cannot be determined. Although two other inspectora during this same tin,e frame had similar problems, other inspectors in a sosewhat later time frame did not have similar problems, althcugh the inspection requirements were essentially the sama.
problem, Inexperience may have been a factor in causing this f
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Rovision: 1 Page 133 of 138 RESULTS REPORT ISAP I.d.1 (Cont'd)
Attachment 14 Root Cause Analysis of QA/QC PDR 45 The CPSES HVAC subcontractor's (Bahnson) lack of a satisfactory inspector certification program was one of a number of problems identified regarding this subcontractor's performance. ISAP VII.c determined that the frequency and the potential severity of some deviations resulted in an unclassified trend.
The root cause was determined to be a less than adequate development and implementation of the HVAC contractor's program to ensure that HVAC supports were installed in accordance with the design. The discrepancies noted in the Bahnson inspector certification files clearly indicate that Bahnson's control of inspector qualifications was l less than adequate. TU Electric failed to ensure that Bahnson developed i
and implemented an effective QA Program.
In an effort to determine the reason that Bahnson vaa not adequately controlled by TU Electric, the procurement history of Bahnson services by Brown & Root and TU Electric was reviewed.
l Bahnson was awarded the contract in 1977 by Brown & Root. The contract between Bahnson apa Brown & Root contained appropriate quality assurance requirements.
Brown & Root conducted a pre-award survey of Bahnson and Bahnson's l i findings. contract award was conditional on the correction of four major In addition, Brown & Root performed revieve of the Bahnson QA Program and procedures and conducted surveillance and audits of Bahnson work activities during 1978 and 1979. Significant problems were noted by Brown & Root and corrective action was pursued.
TU Electric started to sssume control of Bahnson in 1980. This transition was evidenced by a TU Electric /B&R joint QA audit conducted in February 1980. During 1980 and 1981 the responsibility for the control of the Bahnson QA Program shifted from Brown & Root to TU Electric. The TU Electric / Brown & Root audit conducted in February 1980 resulted in 14 deficiencies, six concerns and two observations. In March 1981 another joint TU Electric / Brown & Root audit revealed 11 deficiencies in the implementation of the Bahnson QA Program. However, there is no evidence of any surveillances having been conducted of Bahnson during 1980 or 1981 by either Brown & Root or TU Electric.
In April 1982 TU Electric conducted an audit of Bahnson that resulted in no deficiencies being noted. This audit failed to discover any of the problems that were noted by the NRC in early 1983. j O.
O
R3 vision: 1 RESULTS PEPORT ISAP I.d.1
( (Cont'd)
Attachment 14 (Cont'd)
During 1983 and the- first half of 1984, TU Electric conducte<8 -5he audits of Bahnson activities that resulted in over 50 deficiencier being identified. Even though Bahnson was attempting to correct specific identified problems, their o'erall programmatic controls vare weak. It is noteworthy that TU Eleccric did not reach this conclusion until a new supervisor was assigned to th's TU Electric QA Services Group. As a result of this evaluation, a meeting was held with Bahnson management, and TU Electric inspection personnel were assigneti to observe and verify the adequacy of the Bahnson effort. It seems clear that the previous TV Electric management failed to appreciate the meaning of the previous audit results and the need to take more aggressive action to improve the effectiveness of the Bahnson QA Program.
During the second half of 1984, Bahnson's performance apparently improved and TU Electric decided in early 1985 to audit Bahnson only on an annual l
basis 1983.
in lieu of the quarterly audits that had been conducted since early TU Electrie inspection personnel also ceased routine inspections at i
l thic time.
f In early 1986, a comprehensive site surveillance prograai was implemented on Bahnson activities under the direction of the TU Electric Site QA Organizatir1. Thess surveillances resulted in many deficiencies. It became cl..e that significant problems remained uncorrected. The Bahnson contract was terminated by TU Electric in early 1987.
The lack of delineation of responsibilities between TU Electric and Brown 6 Root may have contributed to the lack of effective control of Bahnson. In l addition the lack of defined organizational interfaces between TU Electric l
Site QA and TU Electric Dallas QA contributed to a lack of appreciation of the magnitude of problems being noted in the Bahnson QA Program. There did i not appear to be a clear understanding of which group was responsible for conducting surveillance of Bahnson.
l TU Electric QA did not implement a comprehensive system to verify the adequacy of Bahnson's activities. It appears that TU Electric intended to exercise QA control primarily by means of an annual audit of Bahnson activities. Given the complexity of the Bahnson HVAC scope of work and the quality problems noted by Brown & Root, TV Electric management should have been aware that additional measures were necessary. Review of TU Electric site QA procedures indicates that procedure CP-QP 19.2 entitled "Site Surveillance" was developed in,1979. However, it was deleted in January 1980. Procedures CP-QP 19.0 arid CP-QP 19.6 vaguely reference site surveillance; however, it is not clear that they were ever intended to apply to surveillance of Site subcontractors. As a result, no TU Electric surveillances were performed of Bahnson until 1984 O
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ISAP I.d.1 (Cont'd)
Attachment 14 (Cont'd)
- TU Electric had a system for conducting reviews of Bahnson procedures.
This system ensured that the-appropriate Bahnson procedures were routed to Brown & Root, TU Electric Engineering, TU Electric QA and also Cibbs & Hill Engineering. However, it was not clear what the review responsibilities of the various groups were.
Therefore many problems that were noted during the implementation of Bahnson's QA Program were not identified and corrected during the review process.
As previously discussed, it does not appear that there <as any exchange or coordination of information between TU Electric's Site QA organization, which was reviewing Bahnson's procedures, and the TU Electric Dallas QA organization, which was conductin5 audits of Bahnson.
The failure to implement a comprehensive system consisting of effective reviews, surveillances, and audica was caused by the apparent lack of full appreciation by previous W Electric QA management of TU Electric's role in ensuring that Bahnson was implementing an effective QA Program. This is considered to be the root cause.
A contributing cause for W Electric's lack of control of Bahnson was determined to be the lack of an effective engineering interface between Gibbs u Hill and Bahnson. The Engineer did not review the contractor's fabrication drawings to verify that these drawings met the design intent of the specification.
If these types of reviews had been conducted it is likely that the inaccurate data and inadequate duct support drawings would have been noted and corrected in a timely manner. This review process would also have resulted in fabrication being done to reaseubly accurate drawings and it would have been far less difficult to prepare the as built drawings.
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g Revision: 1 RESUI.TS REPORT ISAP I.d.1
{O/ (Cont'd)
Attachment 15 Summary of the Results of the I f I d.1 Evaluations of ISAP VII.c QC Inspector Certification Deviations ISAPVII.cdocumentatiAnreviewsofinspectiondocumentationincludedthe verification that the inspector who prepared the inspection documentation was properly certified.
Specifically, the following attributes related to QC inspector certification were checked for each documentation review package:
A valid certification exists for the inspection activity being c o nduc'.e d ,
The level of certification (i.e., 14 vel I, II, or III) was appropriate for the inspection work being conducted, and The inspection work was conducted during the period for which the certification was valid.
Approximately 3,600 Deviation Reports (DRs) were written during implementation of ISAP VII.c and were evaluated by ISAP I.d.1 personnel.
O Approximately 1,800 of these DRs were determined to be valid. These valid DRs were categorized by type for evaluation purposes. The following are descriptions of categories, the quantity of valid DRs in each category, and a characterization of the impact of the deviations:
- 1) Inspector not Certified in the Area, Discipline, or Procedure for the Type of Inspection Performed There were a total of 950 valid DRs isr.'M in this category. This category pointed out that a specific certification had not been issued i
for the inspection instruction being utilized by the inspector as required by certification procedures. During the evaluation of these DRs by the I d.1 personnel, an investigatinn was conducted to determine whether records of training and examinations, related specifically to the activities that had been performed, existed.
The individuals evaluated in this category, despite not having ths
' proper certification, were determined to have the necessary background and experience and sufficient amounts of training and examinations to show capability and they were considered to be qualified to perform the required inspections.
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Attachment 15 (Cont'd)
'2) Inspectors Certified to General Inspection Procedural Series (CP-QP- ) Without Training or Examination Documentation Related Directly to Area Being Inspected There were a total of 183 valid DRs issued in this category. During the evaluation of the DRs, if applicable documentation of training and examinations could not be located, the DRs were validated. Further evaluations were conducted to determine if the individual was capable of conducting the required inspections. These evaluations considered the individuals overall experience and education, certifications held in the same area or discipline but issued by another contractor (i.e.,
a TU Electric QC inspector holding Brown & Root QC inspector certifications), or a similar certification closely related to the inspection vork that was performed.
The individuals evaluated in this category, despite not having the proper certification, were determined to be capable to perform the required inspections.
- 3) Inspector Certification not Current at the Time of Inspect!on ,
A total of 157 valid DRs were issued in this category. This category of DRs identified inspectors who had performed inspections during the time period after su Q ssful completion of training and examinations but prior to the completion of the official certification documentation. They also identified inspections that occurred after (xpiration of certifications but prior to racertification.
The individuals in this category, despite not having valid certification documentation, were determined to be qualified to conduct the required certifications by virtue of the fact that training and examinations had been successfully completed or they had been performing inspections continuously in the area of certification and the certifications had lapsed for only a relatively short period of time.
- 4) Inspector Certified Without Certification Expiration Date Noted on certification Form After January 1981 A total of 116 valid DRs were issued in this category. ANSI N45.2.6, which became a requirement in January 1981, required ceret fication expiration dates to appea'r on certification documentation. Although Oi
\T Revision: 1 Page 138 of 138 RESULTS REPORT ISAP I.d.1 C (Cont'd)
Attachment 15 (Cont'd) the documentation was technically incorrect, the related inspections were all conducted during the period of times in which the certifications were valid.
- 5) Inspector Certified 14 vel I Vhere 1.avel II Certification was Required Six valid DRs were issued in this category. These six DRs involved three inspectors who signed attributes without a co signature by a Level II inspector. Further evaluations of these inspector's qualifications, including education, experience, training, etc.,
versus the attributes in question, determined : hat they were capable of conducting the required inspections.
- 6) Individual Conducting Inspection was not a QC Inspector only one DR was issued in this category. This DR identified a case in which one of four attributes for inspection of the fuel pool liner was conducted by an individual who could not be identified. This is an isolated case and because the fuel pool liner is not safety related, there are no 'urther concerns regarding this DR.
- 7) Inspector Lacked Sufficient Education and/or Experience A total of 373 DRs, involving 14 inspectors, were placed in this category. These DRs would have been invalidated under normal circumstances, except that the Phase I and II evaluations identified insufficient lack of education and/or experience that resulted in these inspectors being placed into Phase III for additional evaluation. The Phase III evaluations determined if the individuals were capable of performing the required inspections despite their lack of education and/or experience. The 14 inspactors are HE 1, HE 4, IC 1, NM 1. TM 1. TM 5, TM 6, TM 7, BN 2, BN 5, BN 6, BN 7, BN 8, and BN 9. The results of the Phase III evaluations are summarized in this Results Report.
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O COMANCHE PEAK RESPONSE TEAM
, ;RESULTS REPORT .
1 ISAP: VII.b.3
Title:
Pipe Support Inspections REVISION 1 4
O A I
&~ tt./ ts / 61 Coordlnator Date Review Team Leader L OAA [1 Date
,,/,. /n
&-Y. l __ /3/Z3fl? __
Johnylieck,ChairmanCPRT-SRT Date 0 .
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P.evision: 1 Page 1 of 62 13 RESULTS REPORT ISAP VII.b.3 Pipe Support Inspections
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (NURIG 0797, Supplement No. 11, Page 0-282)
"The TRT conducted a series of inspections encompassing as-built safety-related pipe support... installations. These inspections were of completed systems or components that had been previously inspected and accepted by TUEC QC as meeting the respective construction and installation requirements."
- Pipe Support Inspections The TRT inspected 42 pipe supports in Unit 1, 37 of which were randomly selected while five originated from an alleger's list. Forty-six deviations were identified in the supports inspected. Tables 1 and 2 summarise the results of this TRT inspection effort.
The TRT also inspected 92 pipe supports in Room 77N of the O- Safeguards Building, Unit 1. Table 3 summarises the results of this TRT inspection effort.
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Deficiencies With High Rate of Occurrence The TRT identified six specific deviation types which need further evaluation to assess their generic implications. The
, six deviation types are listed in Table 3. The TRT concern is that these deviation types may have a high rate of occurrence throughout plant safety-related systems.
i 2.0 ACTION IDENTIFIED BY NRC (NUREC 4797, Supplement No. 11 Pages 0-277 and 0-278)
"Evaluate the TRT findings and consider the implications of these findings on construction quality. . . . . . examination of the j ., potential safety implications . . . should include, but not be I
limited to the areas or activities selected by the TRT."
"Address the root cause of each finding and its generic implications..."
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Revision: 1 Page 2 of 62 O RESULTS REPORT ISAP VII.b.3 (Cont'd) 2.0 ACTION IDENTIFIED BY NRC (Cont'd)
- 'Ad ress the collective significance of these deficiencies "Propose an action plan... that will ensure that such problems do not occur in the future."
3.0 BACKGROUND
As described in Section 1.0, the NRC TRT inspected two samples of pipe supports in Unit 1 and Comon areas. Although a substantial number (134) of the various types of pipe supports were included in the two NRC TRT samples, these samples were not necessarily selected using a statistically random selection method and, therefore, the supports in the samples are not necessarily representative of the total population of supports contained in Unit 1. Unit 2, and Common areas.
The original intent of ISAP VII.b.3 was to investigate the specific NRC TRT concerns by reinspecting the supports that had been inspected by the TRT to verify the validity of their findings.
Based on the results of this validation, additional supports would have been inspected as necessary to reach a final conclusion regarding the adequacy of construction of pipe supports at CPSES.
Subsequently, a decision was made to conduct a separate and broader investigation of the adequacy of construction of CPSES in accordance with ISAP VII.c. "Construction Reinspection /
Documentation Review Plan." Included within the scope of ISAP VII.c was a statistically based reinspection of pipe supports selected from Units 1, 2, and Common areas. As a result, the scope of ISAP VII.b.3 was changed to cover only the validation of the NRC TRT findings. The results of the reinspections conducted by ISAP VII.c and.ISAP VII.b.3 will be combined during the collective evaluation phase of the Quality of Construction Program.
The issue of "Hilti Kvik" bolt embedment length raised by the NRC TRT (Item No. 5 in Table 3) is not addressed in this ISAP, but is addressed in ISAP VII.b.4, "Hilti Anchor Bolt Installation", and in the Cable Tray Design Adequacy Verification Program.
As stated above, the NRC TRT samples are not necessarily O statistically representative of the entire population of pipe supports contained in Units 1, 2, and Comon. Where construction deficiencies were identified, recommendations for additional evaluations and corrective action were based on root cause/ generic
.c . ~ . . .-- - . - - - . _ - . _ - - - = - - - - - .-
. l Revision: 1 l 3 Page 3 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
3.3 BACKGROUND
(Coup'd) '
j- implication analysis results rather than sample expansion criteria.
The non-safety-significant construction deviations identified ,
during the ISAP VII.b.3 reinspections were evaluated on a iinited basis for adverse trends by comparing them for commonality and l
. reviewing thee for an indication that an undetected deficiency could occur elsewhere in the CPSES supports. This analysis,
- coupled with the VII.c investigation for pipe supports, will allow conclusions to be drawn for the-entire pipe support population.
Where the individual or comman deviations did not appear to indicate the likelihood of an undetected deficiency occurring :
) elsewhere, the Results Report statas that there was no indication '
of an adverse trend. In certainLinstances QA/QC Program Deviation Reports (PDRs) were written to cover id,entified concerna relative I
to the implementation of QA program requirements.
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, 4.0 CPRT ACTION PLAN ,
4.1 Scope and Methodolony 1
^
i The objective of this action plan was to investigate the TRT findings pertaining to pipe supports (except as described in ,
I Section 3.0 above), to determine their validity and to assess i their effect on the quality of construction. ,
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The following taska have been completed under this ISAP in '
! order to accomplish the stated objective Reinspected the TRT sample to investigate the extent to f j which the TRT identified deviations were valid.
i
- Evaluated deviations for safety significance and j -
performed trend analyses.
-1 Determined the root cause, generic implications and programmatic concerns for construction deficiencies and q;
adverse trends.
1
- 4.1.1 Verification of the TRT-Identified Deviations the procedures and reference codes covering the pipe supports inspected by the TRT were reviewed, and l reinspection checklists of TRT identified deviations were developed. Reinspec' tion packages, including i i
Revision 1 Page 4 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
- 4.0 CPRT ACTION PLAN,(Cont'd)- .
checklist i, instructions and all documents and drawings necessary to perform and document the required reinspections were prepared.
Reinspection of hardware inspected by the TRT was performed. The reinspection results vera compared to the TRT findings.
4.2 Participant's Roles and Responsibili.cies The organizations and personnel that participated'in this effort are described below with their respective scopes of work. .
4.2.1 TUGCO - CPSES Project 4.2.1.1 Scope Assisted in the identification and provision of all necessary l specifications, drawings, procedures and other documentation necessary for the execution of this action plan.
Assisted in establishing a list of all items in each pipe support populetion.
Processed NCRs that were generated
, due to this action plan.
i 4.2.1.2 Personnel
. Mr. D. Snow TUGC0 QA/QC Mr. J. Finneran TUGC0 Ergineering i 4.2.2 CPRT QA/QC Review Team l
4.2.2.1 Scope All actfvities specific to this action plan that are not identified above are the responsibility of the QA/QC Review Teaa.
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. .s Revision: 1 Page 5 of 62 O
V RESULTS REPORT ISAP VII.b.3 (Cont'd) 4.0 CPRT ACTION PLAN;(Cont'd).. '
4.2.2.2 Personnel Mr. J. L. Hansel Review Team Leader Mr. L. F. Fendo Issue Coordinator (Prior to 05/07/87)
Mr. J. Adam Supervisor - SSEG (Prior to 01/01/87) 4.2.2.3 Personnel Mr. J. L. Hansel
- Review Team Leader Mr. J. P. Tableriou Issue Coordinator (Effective 05/07/87)
Mr. R. Miller Supervisor - SSEG (Effective 01/01/87) 4.3 Qualifications of Personnel Where tests or inspections required the use of certified inspectors, qualification was to the requirements of ANSI
' N45.2.6 at the appropriate level. Third-party inspectors were certified to the requirements of the third-party employer's Quality Assurance Program and specifically trained to the requirements of the quality procedures developed under this action plan.
Other participants were qualified to the requirements of the CPSES Quality Assurance Prop. ram or to the specific requirements of the CPRT Program Plan.
4.4 P r~oc e' dure s This action plan was conducted in accordance with existing CPSES procedures and CPRT procedures as applicable to specific action plan activitt s. -
Inspection procedures developed for this action plan are as follows:
QA/QC Review Team Quality Instructica QI-037:
O "Reinspection of Pipe Supp9rts; TRT Issues - Pipe Supports in Rm 77N. Safeguards Building. Unit 1."
QA/QC Review Team Quality Instruction QI-058:
"Reinspection of Pipe Supports; TRT Issues - 42 Pipe Supports."
1 Revision: 1 Page 6 of 62 O
d RESULTS REPORT ISAP VII.b.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
QA/QC Review Team Quality Instruction QI-061:
"Documentation Review of TRT Issues - 42 Pipe Supports."
4.5 Acceptance Criteria Acceptance criteria were based upon a review of the following:
4.5.1 Site construction procedures and QC inspection procedures acceptance criteria for pipe support installations.
4.5.2 A detailed review of specifications, drawings, referenced codes and standards in order to identify and verify minimum acceptance criteria ne::essary to evaluate the TRT findings.
d QA/QC Review Team Quality Instructions identified in Section 4.4 and inspection checklists contained in these Quality Instructions were developed based on the results of this review. These Quality Instructions contain the miniaua acceptance criteria necessary to validate the TRT findings.
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Summary of Action Plan Implementation The January 8, 1985, letter from the NRC to TUCCO and SSER 11 were reviewed to identify the specific pipe supports inspected by the TRT. These supports are categorized into two
. populations:
-(1). TRT seues - Pipe Support in Room 77N, Safeguards Building, Unit 1 (PS7N), and (2) TRT Issues - 42 Pipe Supports (PS42).
The supports in each of these populations were reinspected by the CPRT to confirm the existence of the hardware deviations identified by the TRT.
More extensive inspections of pip'e supports were performed under ISAP VII.c. These supports are included in the the following three VII.c populations:
Revision: 1 Page 7 of 62 O RESULTS REPORT ISAP VII.b.3 (Cont'd) 5.0 IMPLEMENTATION O'F ACTION PLAN AND DISCUSSION O'T RESULTS (Cont'd)
(1) Large Bore Pipe Supports-Rigid (2) Large Bore Pipe Supports-Non-Rigid (3) Small Bore .?ipe Supports The extent to which each pipe support was inspected (for PS7N and PS42 supports) was v.ot limited to those specific characteristics against which deviations were found by the TRT on that support. Instead, each support in the PS42 population was inspected for all applicable characteristics for which deviations were found by the TRT in the PS42 population.
Similarly, each support in the PS7N' population was inspected for all applicable characteristics for which deviations were found by the TRT in the PS7N population.
O The NRC did not identify which Code Class 1, 2 and 3 supports were inspected in Room 77N of the Safeguards Building; therefore, all Code Class 1, 2 and 3 pipe supports in Room 77N with attributes corresponding to those support characteristics identified by the TRT for the PS7N population were included on the PS7N population items list. As a result, the CPRT inspected 178 supports in Room 77N compared to the 92 supports inspected by the TRT in Roos 77N.
5.2 Evaluation and Categorization of Inspection Findings 5.2.1 Comparison of CPRT Inspection Results With TRT Inspection Results The TRT inspected 42 supports selected from Unit 1 and Common areas. The deviations found by the TRT for these supports are listed in Table 2. A comparison of
, the CPRT inspection results with the TRT inspection
. results was made for the purpose of verifying the TRT
.. findings. The res'alts of these comparisons are shown in Table 4. Based on this comparison it was concluded that the TRT inspection results are substantiated by the CPRT inspection results.
The TRT also inspected 92 anubber and strut type supports in roos 77N. The deviations found by the TRT O for these supports are listed in Table 3. A comparison of the CPRT inspection results with the TRT inspection results was made for the purpose of verifying the TRT findings. The results of these comparisons are shown
a h
Revision: 1 Page 8 of 62 O RESULTS REPORT ISAP VII.b.3 (Cont'd) 5.0 IMPLEMENTATION'0FA'CTIdNPLANANDDISCUSSIONOFRESULTS(Cont'd) in Table 5. Based on this comparison it was concluded that the TRT inspection results are substantiated by
, the CPRT inspection results for those items reinsoected.
i 5.2.2 Descriptiot. of Deviations Tables 6 and 7 list the total number of CPRT deviation reports; construction deficiencies, and trends for each characteristic. Unclassified deviations are included in the total number of CPRT deviation reports listed in these tables. Unclassified deviations were not ,
evaluated for safety significance as previously
, identified construction deficiencies, adverse trends or l unclassified trends resulted in corrective action i
recommendations that encompass these deviations. The characteristics (column 1) are those identified by the TRT that are applicable to each population. The tables also list the total number of supports that were reinspected'for each characteristic.
Six construction deficiencies were identified as follows:
- No locking device for threaded fasteners
- Pipe clearances with support out-of-tolerance
- Pipe clamp locknut loose j
- Strut aisalignment i
- Load pin locking device (cotte,r pin) missing i
2 *
- Broken and missing lockwire an snubber
. adapter plate bolting l One unclassified deviation that is the same type of
{ deviation as has been identified in the ISAP VII.c pipe j support populations as a construction deficiency is
- identified as follows
l - Loose jaa nut on barrel of strut l
l
}
_ . ,_ - _ ~ - - _ . _. -- . - _ ~ _ - . _ - .
Ravision 1 Page 9 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
- 5.0 IMPLEMENTATION OF ACTIO'N PLAN-AND DISCUSSION *OF RESULTS (Cont'd)
A construction deficiency for pipe clamp halves not parallel was identified in Revision 0 of this report.
A subsequent reanalysis of the deviation by the SSEG determined that the deviation was not safety-significant; therefore, it has been deleted from the list of construction deficiencies in this report.
5.3. Analysis of CPRT Findinas for PS42 Pipe Supports (See Table 7) 5.3.1 No Locking Devices For Threaded Fasteners i
I There are a total of 56 threaded fasteners (studs and bolts with nuts securing them in place) on 19 supports.
Forty-three fasteners on 17 supports have a deviation reported for no locking devices. Locking devices are an ASME Code requirement. ASME Code-approved locking devices are locknuts, upset threads, jaa nuts and drilled and wired nuts.
The absence of locking devices increases the possibility for bolts and studs to work loose under operating conditions. Loose or missing bolts and studs could result in the loss of the pipe support capability
! to transfer loads by causing a load-carrying component 1
to become disengaged from the support assembly.
Therefore, these deviations were determined to be construction deficiencies. These deficiencies were consolidated into one generic construction deficiency for the identified deviations. .
. See Section 5.5.2 for root cause and generic implications analyses.
l 5.3.2 Minimum Edge Distance On Baseplate Violated n ere are a total of 47 baseplates on 35 supports. Two baseplates on two supports have a deviation reported for violation of minimum edge distance (distance from center of bolt hole to edge of baseplates). Miniaua edge distances are required to prevent the bolts from overstressing the baseplate between the bolt hole and the plate edge. '
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Revision: 1 Page 10 of 62 (D
s RESULTS REPORT ISAP VII.b.3 (Cont'd)
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5.0 IMPLEMENTATION OF ACTION' PLAN AND DISCUSSION OF RESULTS (Cont'd)
One baseplate had one bolt (1-inch diameter) with an edge distance of 1-3/8 inches. The design drawing specified 1-1/2 inches. The other baseplate had two bolts (3/4-inch diameter) with edge distances of 1-1/16 inches. The design drawing specified 1-1/8 inches.
The minimum edge distances required by the ASME Code are 1-1/4 inches for 1-inch diameter bolts and 1-inch for 3/4-inch diameter bolts. It was concluded that the baseplates meet ASME Code requirements and the baseplates and bolts could perform their intended function. These deviations were evaluated to be not safety-significant. Review of the deviations did not indicate that an adverse trend existed.
5.3.3 Baseplate Hole Location Dimension Out of Tolerance There are a total of 47 baseplates on 35 supports. Ten g j baseplates on nine supports have a deviation reported for baseplate bolt holes being out of location from those specified on the design drawings. Changes in bolt hole locations result in changes in baseplate stresses and bolt loadings.
The support member (e.g. , tube steel) attachment locations on the baseplate are specified on the design drawings. The anchor bolt hole locations on the baseplates are specified on the design drawings relative to the centerline of the attaching support member. The tolerance on the drawing location dimensions is t 1/4 inch.
Brown & Root construction procedure CP-CPM-9.10 allows alternate bolt hole patterns to be drilled in baseplates when the holes cannot be located as specified on the design drawing. This is done by
., construction craft personnel to avoid interferences 1
with rebar. Upon completion of an alternate hole pattern, a Component Modification Card (CMC) is required to be initiated by construction if the alternate hole pattern is outside the location tolerance of 1 1/4 inch. The CMC is reviewed by engineering and, if approved, becomes an engineering-authorized design change.
( ,
1 l
l l Revisica 1 l Page 11 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION ,0F RESULTS (Cont'd)
[ The following paragraphs describe the specific baseplate hole deviations reported by the CPRT.
Four supports had baseplate bolt holes reported out of drawing location by less than 1 inch. Resulting baseplate stresses ranged from 10 percent to 74 peecent of allowables and bolt loads ranged from 23 percent to 84 percent of allowables in the deviating condition.
Five supports had baseplate bolt holes reported out of drawing location by 1 inch or more. One of these supports had a hole out of location by 2-5/16 inches.
Baseplate stresses ranged from 16 percent to 76 percent of allowables and bolt load's ranged from 19 percent to 72 percent of allowables in the deviating condition.
In addition to the nine supports with deviations O' identified by the CPRT the TRT identified baseplate holes out of location on two PS42 supports. The following paragraphs describe the TRT findings and the CPRT findings for these two supports.
Two botton bolt holes on one baseplate for support CC-1-126-010-F33R were reported by the TRT to be 3 inches closer to the centerline of the attaching frame aanber than was specified on the design drawing. The support had been final QC-inspected and accepted prior to the TRT inspection. The TRT inspected the support to Revision 2 of the design drawing. 'Ihe design drawing was revised after the TRT inspections (Revision CP-1 issued June , 1985) to show field conditions by lowering the att- .ing frame member by approximately 3-1/4 inches relative to the baseplate. . CPRT Inspections were performed to Revision CP-1; therefore.
a deviation was not reported by the CPRT. Analysis of the baseplate and bolts for the field configuration shows that bolt loads and plate stresses are within allowable loads and within ASME allowable stresses.
Bolt loaJs decreased by 7% and baseplate stress increased by 4.5% as a result of shif ting the f rame member down by approximately 3-1/4 inches on this particular support.
O .
Revisign 1 Page 12 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
' 5.0 IMPLDHENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cone.'d) 1 Bolt holes on one baseplate for support
. CC-X-039-007-F43R were reported by the TRT to be out of location from the location specified on the design l drawing. Bolt holes were out of location by approximately 1 inch. This support also had been final QC-inspected and accepted prior to the TRT inspections.
The TRT inspected the support to Revision 4 of the design drawing. The CPRT inspected the same support to Revision CP-1, which was issued after the TRT inspections to show the bolt holes as located in the field. Therefore, a deviation report was not generated by the CPRT. Eleven supports out of 35 supports with baseplates had baseplate bolt holes out of design location when supports CC-1-126-010-F33R and f
CC-X-039-007-F43R are included in the total.
Out of 11 supports with bolt holes out of location, O CMCs had been prepared (prior to TRT) for eight of the supports (including CC-1-126-010-F33R and CC-X-039-OO7-T43R) showing alternate bolt hole locations on the baseplates. These alternate bolt hole locations shown on the CMCs were not correct. The erroneous bolt hole locations shown on the CMCs were incorporated into the eight design drawings. CMCs were not prepared for the remaining three supports as required by procedures; therefore, the design drawings for these supports also have erroneous hole locations.
To summarise, incorrect CMCs were prepared and subsequently incorporated into the design drawings in
. eight of 11 cases. Brown & Root QC inspection did not detect the erroneous dimensions on the CMCs or on the design drawings. In three cases, CMCs were not prepared as required. Altogether 11 erroneous design drawings were issued as final as-luilt designs. It was determined that these supports could perform their intended function. None of the deviations was safety-significant.
A QA/QC Program Deviation Report (PDR 075) has been prepared to address the erroneous design drawings. See Section 5.6.6 for further discussion of this problem.
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Revision: 1 Page 13 of 62
-s RESULTS REPORT ISAP VII.b.3 (Cont'd) 5.0 IMP 1.EMENTATION O'T ACTION 'Pl.AN AND DISCUSSION 5F RESULTS (Cont'd) 5.3.4 Spherical Bearir.g/ Washer Gap Excessive There are approximately 52 spherical bearings on 22 supports. Six bearings on five of these supports have a deviation reported for excessive gap between the spherical bearings and the bearing washers; one bearing on a support different from the above five was reported to be partially dislodged.
Spherical bearings are staked into the snubbers and struts. These bearings transfer loads between support seabers. NRC I&E Circular 81-05 "Self-Aligning Rod End Bushings For Pipe Supports", identified a problem with staked bearings becoming dislodged from snubbers and struts. Total bearing dislodgement would render the supports inoperable. Washers were provided by the support vendors to center the bearing in the gap O between the ears of the bracket or pipe clamp and to prevent the bearings from becoming totally dislodged if the staking becomes ineffective.
1 A small gap between the bracket / clamp ears is, by itself, sufficient to prevent total bearing dislodgement. However, some designs do not have gaps
, small enough to prevent total dislodgement; therefore, bearing washers were provided to center the bearings in the gap between the bracket / clamp ears. Centering the bearing permits a larger gap to be used while still preventing total bearing dislodgeewnt for some designs.
The remaining gap or clearance between bearing and
- washers, after the bearing washers are installed, is required to be less than the thickness of one vendor-supplied washer.
j .
, one bearing had a 5/8 inch gap; the other five bearings had gaps of 3/16 inch or less. The bearing with the 5/8 inch gap had two 1/8 inch thick washers installed.
one on each side of the bearing within a rear bracket.
These washera are thinner than required and resulted in the excessive gap. One bearing within a pipe clamp has a 3/16 inch gap reported and no spherical bearing washers were installed. Two washers 3/32 inch thick O should have been installed. The absence of washers resulted in the excessive g'ap. The four remaining bearings had gaps of 3/16 inch or less. All of these had spherical bearing washers installed. It was
. _ . = _ _ _- - .. _.
Revision: 1 Page 14 of 62 l
RESULTS REPORT ISAP VII.b.3 (Cont'd) 2 '
5.0 IMPLEMENTATION 0,F AC' TION PLAN AND DISCUSSION OF RESULTS (Cont'd) determined that the bearings on all five of these supports were not dislodged and they could perform their intended function. All of these deviations were evaluated to be not safety significant.
One support that did not have excessive spherical bearing gaps did have a bearing dislodged by 1/16 inch (not totally dislodged). It was determined that this support could perform its intended function and that the deviation was not safety significant.
It should be noted that correct installation of the ,
vendor specified washers is pot sufficient to prevent I partial dislodgement of the spherical bearings. Missing washers or excessively thin washers only increase the amount of possible dislodgement and could lead to total dislodgement for some designs. A QA/QC Progran O Deviation Report (PDR 076) has been prepared to document these conditions. See Sections 5.4.1 and 5.6.5 for further discussion of this problem.
5.3.5 Spherical Bearing Contamination ,
1 There are approximately 52 spherical bearings on 22 i l supports. Thirty-two bearings on 15 of these supports have a deviation reported for paint deposits on spherical bearing surfaces. '"lie spherical bearings transfer pipe support loadings from snubbers and struts to other pipe support components while allowing pipe j movements in unrestrained directions.
' l It was determined that the paint did not reduce the '
load carrying capability or limit the movement of the !
l spherical bearings. All of the deviations were
. evaluated to be not safety-significant, and a review of
., the deviations did not indicate that an adverse trend existed. Corrective action has been initiated by TUCCO to inspect the spherical bearings for freedom to gimbal via the Hardware Validation Program. This is a pipe support reinspection program initiated by TUGC0 which, together with other corrective action programs, covers most safety-significant pipe support hardware attributes. ,
4
-r--- --- -,- -,m - - -- - _ _ , , - , - -,,-e .w , r 4 y- - - - ----
R;visiOs 1 I Page 15 of 62 (O
v RESULTS REPORT ISAP VII.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3.6 Snubber Adapter Plate Bolting - I'nsufficient Thread Engagement Extension kits and brackets are connected to snubbers by bolting them to snubber adapter plates. Brown &
Root construction and inspection procedures specify minimum thread engagement lengths of bolts in snubber adapter plates. These minimum bolt engagement lengths are less than the thickness of the snubber adapter plates.
The TRT concerns were that minimum bolt engagement lengths should be equal to the snubber adapter plate thickness and that the minimum bolt engagement allowed by the Brown & Root procedures is inadequate. CPRT inspection results reported bolts with thread engagement less than the thickness of the plateg however, no deviations from the minimum engagement lengths used by Brown & Root were reported. Design v concerns relative to snubber adapter plate bolting have been transmitted to the Project on QA/QC-RT-10046. The adequacy of this condition will be evaluated by the Proj ec t .
5.3.7 Insufficient Thread Engagement. Threaded Rod There are approximately 30 threaded rods in the coupling or strut on 18 supports. One threaded rod 1/2 inch in diameter on one spring type support has a deviation reported for the threaded rod not being visible through the coupling sight hole. Sufficient
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thread engagement is assured when the threaded rod is visible through the sight hole.
It was determined that 5/8-inch of thread engaaement
, existed on the support, allowing development of full rod strength, and that the support could perform its intended function. This deviation was evaluated to be not safety-significant.
Another deviation was reported for a strut type support that did not have a sight hole through which threaded rod engagement could be verified. This condition was p evaluated, and it was found that a star stamp was Q present on one end of the strut body. The star stamp indicates that the threads at the end of the rod j engaged in the strut body had been upset (spoiled) to i
prevent the rod from becoming disengaged (unscrewed) l
Revisient 1 Page 16 of 62
() RESULTS REPORT ISAP VII.b.3 (Cont'd) 5.0 IMPLEMENTATION 0F ACTION. PLAN AND DISCUSSION OF RESULTS (Cont'd) and to assure proper thread engagement. Dimensional checks were made for the other end, which determined that sufficient thread engagement existed. It was determined that the support can still perform its intended function.
l Both deviations were evaluated to be not safety-significant, and a review of the deviations did not indicate that an adverse trend existed.
5.3.8 Snubber / Strut Load Pin Locking Device Broken Or Missing There are a total of 64 load pins on 24 supports. Two load pins on two of these su'pports have a deviation reported for broken or missing cotter pins or snap rings. The cotter pins and snap rings hold load pins in place. The load pins hold components of the pipe O support assembly together. A support will lose its load carrying ability if the load pin is not present or not properly engaged in the support assembly.
One load pin had a broken cotter pin and one load pin had a missing snap ring. A construction deficiency exists for a missing cotter key on a PS7N support. The corrective action that has been recommended as a result
. of the construction deficiency extends to these supports. Therefore, no trend evaluation was performed for these deviations. See Section 5.4.2 for a description of the construction deficiency, for analysis of additional similar deviations, and for conclusions.
5.3.9 Load Side of Pipe Clamp Halves Not Parallel
. There are a total of 21 pipe clamps on 18 supports.
. Seven pipe clamps on seven of these supports have deviatiens reported for load side of pipe clamp (ears) not parallel.
Clamps that are out of parallel by excessive amounts could result in the load pin being overstressed, increase the gaps between the spherical bearings and washers, or cause interference between clamps and O support eyerods. ,
Revisicn 1 Page 17 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
- 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OT RESLTLTS (Cont'J)
Three clamps had ears that were spread apart 3/16 inch or less, resulting in increases in load pin stress.
None of these clamps had excessive spherical bear'ag gaps. The load pin stresses were within ASME Code allowable stress. It was determined that these clamps could perform their intended function.
One clamp had ears that were spread apart 5/16 inch, causing an increase in load pin stress. In its deviating condition, the stress in the load p',n is approximately 23% of the allowable. It was determined that this clamp could perform its intended function.
Three clamps had ears that we're inclined closer together by 3/16 inc.N or less. The load pin stresses were not increased by this condition. It was determined that this c. asp did not interfere with the support eyerod and it could perform its intended O- function.
None of these deviations was evaluated to be safety-significant. See Section 5.4.3 for analys1s of additional similar deviations and for conclusions.
5.3.10 Pipe Clearance With Support out of Tolerance A total of 22 supports have clearances specified between pipe and support. Eight of these supports have a deviation for pipe clearances out of tolerance. The specified clearances between pipe and support allow the
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support to restrain the pipe in the desired direction vhile permitting pipe movement relative to the support in unrestrained directions. Deviations from the specified clearance could impair the function of the support or piping system.
One box frame support for a 12 inch pipe has 0.012 inch total clearance top to bottom between pipe and support. 0.032 inch total clearance side to side.
Minimum required clearance top to botton is 0.032 inch. Minimum required clearance side to side is 0.062 inch. One box frame support for a 12 inch pipe has 0.027 inch total clearance top to bottom between pipe and support. Minimum required clearance top to bottom
Revistant 1 Page 18 of 62 RESUI.TS REPORT ISAP VII.b.3 l (Cont'd)
- 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION DF RESULTS (Cont'd) is 0. '32 inch. It was determined that the diametrical expansion of these pipes will not reduce the clearance to zero inches and the supports can perform their intended function.
One box frame support for a 12 inch pipe has more than 3/16 inch total clearance side to side between pipe and support. Maximum permitted clearance is 3/16 inch. It was determined that the clearance on one side of the pipe is 0 inches and is 3/16 inch to 1/4 inch on the other side of the pipe. The clearance varies from 1/4 inch to approximately 3/16 inch across the width of the box frame structural member.. It was determined that the supoort could perform its intended function.
One box frame support for a 12 inch pipe has no clearance top to bottom. Minimum requited clearance O top to botton is 0.032 inch. One box frame support for a 6 inch pipe has 0.025 inch clearance between pipe and support at top and 0.025 inch clearance at bottoa. No clearance is permitted between the bottom of the pipe and the support (in the gravity direction). One box frame support for a 10 inch pipe has 0.015 inch clearance between pipe and support at top and 0.015 inch clearance at the bottom. Another box frame type support for a 1-1/2 inch pipe has 0 inch clearance between pipe and support at top and 1/16 inch clearance at bottoa. No clearance is permitted between the bottom of the pipe and the support (in the gravity direction). It was determined that one of these
,, supports could perform its intended function. Safety significance evaluations were not performed on the deviations on the other three supports because these deviations were already addressed by an existing
. corrective action program.* Therefore, these deviations we'e left as unclassified deviations.
One deviation is for no clearance between a pipe (specifically a circumferential butt veld) and a steel plate on a U-bolt type support, which bound the pipe in the support. It was determined that the bound pipe
- This corrective action program is the ' Project's Hardware Validation Program (HVP) in which all safety-related pipe supports will be reinspected for a large number of attributes.
. . . . ., \
Revision 1 Page 19 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
" 5.0 IMPLEMENTATION Of ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) would cause an equipment nozzle to become overloaded and resulted in a construction deficiency. Therefore, no trend evaluation was performed for these deviations.
See Section 5.5.3 for root cause and generic implications analyses for this construction deficiency.
5.3.11 Pipe clamp Locknut Loose There are a total of 12 pipe clamp bolts with nuts and locknuts installed on four supports. They are all ITT-Grinnell supports, which are supplied with locknuts. One of these supports has a deviation reported for a loose locknut on a pipe clamp bolt. The locknut prevents the nut from turning relative to the bolt that holds the two halves of the pipe clamp together.
The loose locknut increases the probability that the pipe clamp bolt will work loose. A generic construction deficiency has already been identified for missing locking devices (see Section 5.3.1). Because this devia' ion was judged to have the same effect on support functionality as the deviations that comprised the generic construction deficiency, it was included in the same safety-significance evaluation as the deviations for missing locking devices and was determined to be a construction deficiency. See Section 5.5.4 for root cause and generic implication analyses for this construction deficiency.
5.f.12 Snubber /Svay Strut Misalignment There are a total of 26 anubbers and struts on 22 supports. Two struts on two of these supports have a deviation reported for strut aisalignment. The .
snubbers and struts transfer loadings from the pipe to l the building.
Two struts were reported out of alignment with the associated pipe clamps / brackets. One of these deviations was reported for a strut that was not within location tolerances, causing the angle between strut and pipe clamp to change. 'This resulted in changed support loadingst however, at was determined that this support could perform its intended function. The n
Revision: 1 Page 20 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
I 5.0 IMPLD(ENTATION OF ACTION' PLAN AND DISCUSSION OF RESULTS (Cont'd) second deviation was reported for a strut out of alignment with a pipe clamp by more than the allowable 5 degrees offset angle. This caused additional moment forces on the support components that resulted in a construction deficiency. Therefore, no trend evaluation was performed for these deviations.
See Section 5.5.5 for root cause and generic implications analyses.
5.3.13 Snubber Cold Set Dimension Does Not Match Drawing The length of the snubber ta the initial distance from the load pin center line to the back of the snubber (e.g., length of installed snubber) when the pipe is in the cold condition prior to systen preoperational tests. The snubber length is specified to prevent the ll snubbers from "bottoming" during expected pipe movements.
Snubbers are designed to extend and retract, allowing the pipes to expand thermally and to move under steady forces, such as deadweight loads. The piping systems move at snubber locations during system testa due to thermal expansion and deadweight loads, and do not necessarily return to their initial positions when they cool down or when the system fluid is removed. In order to assure the snubbers do not "botton", TUGC0 test procedures require the snubber lengths to be seasured and recorded during system preoperational
. tests. Snubbers that have measured lengths that could cause bottoming are identified during testing and referred to engineering for further action. The measured lengths of the remaining snubbers are accepted, even if they dif fer froa the initial design drawings.
There are 13 snubbers in the PS42 support population.
The snubber lengths on seven snubbers were recorded as being out-of-tolerance from the dimensions shewn on the design drawings by the CPRT. (Deviation reports were not required by the QI for these dimensions. Recording 9 of :he dimensions was requ, ired only because snubber length, though not recreatable after testing, was a TRT concern.)
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Revision: 1 l Page 21 of 62
]
RESUI.TS REPORT ISAF VII.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The lengths on five snubbers are within 2 1/8 inch of .
the accepted lengths during testing; therefore, these !
dimensions meet construction requirements and do not have an adverse effect on the operability of the snubber.
One support, which was removed (eliminated) after CPRT inspection, was out of tolerance by 1/16 inch. This would not have had an adverse effect on the operability of the snubber.
The remaining support differed from the test dimension by 1/4 inch. It was determined that there is no adverse effect on the operability of this snubber.
No safety-significant findings were identified and review of the findings did not indicate that an adverse trend existed.
5.3.14 Snubber Orientation Does Not Match Drawing ,
The snubber orientation (and to end) is specified on the pipe support design drawings. Brown & Root construction and inspect don procedures permit the 1 anubber assemblies to be installed 180' end to end from the orientation shown on the drawing.
This characteristic was observed, and the results recorded, because the issue was raised by the TRT.
Deviation reports were not required to be initiated
., because reverse orientation of the snubbers is ,
permitted by Brown & Root procedures and does not prevent the snubber from performing its intended function. Snubbers transfer loadings between the pipe l ,
and building in their axial direction only. Reversal !
of the snubbers (and to end) does not effect the load-carrying ability or the function of the snubber. The :
CPRT inspectors recorded three snubbers reversed (and i
to end) from the orientation shown on the drawing, j Based on the above information, it was determined that l reversal of the snubbers has no safety significance.
1
Revisient 1 Page 22 of 62
() RESULTS REPORT i
ISAP VII.b.3 (Cont'd)
' 5.0 IMPLEMENTATION 0F ACTIOW. PLAN AND DISCUSSION OF RESULTS (Cent'd) l 5.3.15 Component Type /Model Does Not Match Drawing A total of 30 supports have Hilti bolts. Two of these l supports have a deviation reported for Hilti bolts that l do not match those specified on the drawing. These deviations are addressed in the Results Report for ISAP VII.b.4, "Hilti Anchor Bolt Installation."
No other deviations were reported for component type /sodel not matching drawing.
The TRT identified supporte SI-1-090-006-C41K and RC-1-052-020-C41K as having snubber model numbers that do not match the model numbers on the design drawing bill of material. Support RC-1-052-020-C41K contains one snubber assembly that is specified in the bill of material by NPSI number SMA-IL-SO. Assemblies are composed of the snubber plus additional hardware.
O. Inspections determined that the correct model snubber is installed. The model number marked on the snubber is PSA-IL, which was supplied to NPSI by Pacific Scientific for use in their SMA-IL-50 assembly.
1 Support SI-1-090-006-C41K contains two snubber assemblies that are specified in the bill of material by NPSI number SMA-3-BA. The installed snubbers are marked PSA-3. Inspections determined that the correct model snubbers are installed. The model number PSA-3 that was marked on the snubbers, which ware supplied to NPSI by Pacific Scientific for use in their SMA-3-RA assembly, is a Pacific Scientific model number.
5.3.16 No Identification Por Support Materials, Parts, and Components Identified A replacement part (svay strut eyerod) for support CT-1-013-014-S32R was identified by the TRT as not having material identification on the hardware or in the support documentation package traceable to the origin of the part. The material identification log (MIL) did not list any identification traceable to the origin of the replacement part. A stallar problem was identified by the TRT for pipe supports O CC-1-126-012-F33R, CC X-039-005-P43R, and AP-1-035-Oll-S33R.
l l
Revision: 1 l Page 23 of 62 !
RESULTS RETORT ISAP VII.b.3 (Cont'd)
' 5.0 1MPLEMENTATION 0,F ACTIONLPLAN 'AND DISCUSSION OF RESULTS (Cont'd)
At the time of installation, it was acceptable by procedura for QC to sign off on the design drawing Bill of Materials for material acceptability. No material identification log was found for these supports, however, a QC-signed Bill of Material was located in each support package. All materials on the above supports and on support CC-1-126-013-F33R, which was also reviewsd for material traceability, were traceable to a heat number, to a material identification code, or to a receiving and inspection report that gave acceptable heat numbers.
Material identification evalpations in this section were limited to the five supports identified by the TRT. No deviations were identified during these evaluations.
5.3.17 Weld Porosity Excessive No deviations were reported for weld porosity.
5.3.16 Weld Undercut Excessive No deviations were reported for veld undercut.
5.3.19 Wald Length Undersized No deviations were reported for veld length being undersized. However, in the course of evaluating the construction adequacy of welding in ISAP VII.c it was
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found that engineering had not issued complete instructions for certain types of tube steel welded
. connectionc. This condition was reported on a QA/QC Program Deviation Report (PDR-04). The adequacy of this condition is being evaluated in the pipe support stress reconciliation analysis.
5.3.20 Wald Leg Or Effective Throat Undersize There are approximately 430 welded joints on 43 supports. Four welded joints on four supports have deviations reported for undersize seld leg (or i effective throat). The strength of the weld is l directly proportional to the weld effective throat i size.
Revision: 1 Fahe 24 of 62 RESULTS 7tEPORT ISAP VII.b.3 (Cont'd)
- 5.0
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IMPLEHENTATION OF AC' T ION; PLAN AND DISCUS 3 ION QF RESULTS (Cont'd)
One of these welds was reported as being undersize due to excessive grinding. This deviation is discussed in Section 5.3.24.
Three fillet welds were reported as being undersize by 1/32 inch to 1/16 inch for portions of their lengths.
An evaluation determined that these welds could adequately carry the loadings, and weld strength was within ASME Code allowables. All deviations for undersize welds were evaluated to be not safety significant, and a review of the deviations did not indicate that an adverse trend existed.
5.3.21 Weld Called Out on Drawing D'oes Not Exist in Field No deviations were reported'for missing welds; however, the design drawing for support CC-1-126-013-F33R O specified a 1/4-inch fillet weld connecting Item 5 to Item 6. This weld does not exist on the support.
Component Modification Card (CMC) 87927, Revision 4, issued March 2, 1983, deleted thic weld but this change was not incorporated into the design drawing.
5.3.22 Welds Added in Field are not Reflected on Drawing 1 Approximately 16 additional welds were identified on support AF-1-001-702-S33R. These welds were not specified on Revision 2 of the design drawing used during CPRT inspections.
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Four additional welds were located in four inside corners of the support frame. The previous revision
, (Revision 1) of the design drawing specified welds in these locations. The four welds appear to be extra due to a drawing error and do not adversely affect the function.of the support.
The remaining extra welds are on shin plates between pipe and frame. The design drawing specifies "field i shin to suit" via a note on the design drawing. These "
shims and their associated welds are required to meet maximum allowable clearance requirements between pipe and frame.
O ,
Thess 16 additional welds were not identified as deviations. The QI required additional welds to be recorded only. No extra welds were reported on other +
supports.
l Revicica: 1 Page 25 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION. PLAN.. AND DISCUSSION OF RESULTS (Cont'd) 5.4.23 Excessive Grinding Resulting In Minimum Thickness Violations (Weld Cleanup)
There are 43 supports with approximately 430 welded joints. One of these supports has a deviation reported for excessive grinding of weld and plate. One fillet weld was reported with the effective throat reduced up to 1/16 inch below the specified size for approximately 25% of its langth due to excessive grinding. Also, the adjacent plate thickness was reduced up to 3/32 inch below specified riste thickness of 1/4 inch in the vicinity of the reduced weld.
It was determined that the veld stress at the undersized throat area and the plate shear stress at the reduced thickness area resulting from the maximum applied loads are 21 and 15 percent of allowable N stress, respectively, in the deviating condition.
Consequently, the veld can easily carry the design loads. The deviation was not safety-significant. No trend analysis was performed for this single deviation.
It was determined that the bending stresses in the plate (remote from the defects due to grinding) exceeded the allowable stress by 80%. The plate is only 1/4 inch thick and appears to be undersized due to an incorrect design. Design Adequacy Request No. 170 was submitted to DAP for evaluation of the undersized plate. Evaluation of this condition resulted in DIR-2457 being issued to the Project identifying the problem.
1 5.3.24 Lack of QC Inspector Initials (for Acceptance) On Weld Data Card
~
A total.of five pipe supports were reviewed for the presence of QC inspector initials for inspection hold points on Multiple Weld Data Cards. One of these pipe supports has a deviation reported for lack of QC Inspector initials on a Multiple Weld Data Card (MWDC) for an inspection hold point. The inspection hold point was for additional welding required by CMC 87927 Revision 5 dated one day after the last inspection on O the MWDC. No alternate dbcumentation could be located to substantiate that the QC inspector was present to perform the requisite inspections at the holdpoint.
However, a review of the MWDCs, the Weld Filler Material Log, and the CMCs provided assurance that the
i ' ;
Revision: 1 Page 26 of 62
) RESULTS REPORT ISAP VII,b.3 (Cont'd)
~ 5.0 IMPLEMENTATION OF ACTION' PLAN AND DISCUSSION OF RESULTS (Cont'd) additional welds on the support were properly performed and inspected. It was concluded that the CMC was prepared af ter the work was completed for the purpose of changing the design drawing. No trend analysis was performed for this single deviation. The deviation was not safety-significant.
5.3.25 Support ID Missing or Incorrect All 43 supports are required to be marked with an identification number given on the design drawing.
Three of these supports have a deviation reported for missing identification numbers and two have a deviation reported for illegible identification number;;. These five supports are plain steel frame type supports.
Each support configuration and location was found i.o be z
v} in general agreement with the design drawing and hanger
- location drawing. Each of these supports also has a documentation package in the vault with inspection reports and drawings; confirming that these supports were QC-inspected and accepted.
These deviations had no effect on the load-carrying capacity of the support or on the ability of the support to perform its function and were evaluated to be not safety-significant. Therefore, no trend analysis was performed.
5.3.26 Configuration Does Not Match Drawing
~
Out of a total of 43 supports, seven deviations were reported on a total of six supports for configuration not matching the drawing.
One deviation was reported for a steel member welded to a baseplate that was rotated 6 degrees. An evaluation indicated that the allowable stresses were not exceeded and the support could perform its intended function.
One deviation was reported where three shims between pipe and steel frame were installed; two were specified
(' on the drawing. An evaluation concluded that there was
\ no change in the support stresses due to the added shim and the support could perform its intended function.
~.
Revisicn: 1 Page 27 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
' 5.0 IMPLEMENTATION QF ACTION > PLAN AND DISCUSSION 0F RESULTS (C>nt'd)
Two deviations were reported for a dimension (distance from building wall to centerline of pipe) being out-of-tolerance. This distance is shown on the pipe support design drawing and is used to determine pipe support component lengths to ensure the support will adequately span this distance when installed in the field. One deviation was for a strut support that deviated by 2-1/8 inches and one for a snubber support that deviated by 2 inches on 4 foot and 7 foot dimensions respectively. An evaluation concluded that the supports were well within their length' adjustment range as installed and could perform their intended function. .
One deviattoa was reportad for a sheet metal plug installed insf.de a ar,anchion; the plug was not shown on the drawing. An evaluation concluded that the plug was f~'\ deliberately installed to act es insulation protection l
l Nd for the pipe run and does not change the stress levels l in the support. It was concluded that the support could still perform its intended function.
One deviation was reported for a larger beam installed than is specified on the drawing. An evaluation concluded that the larger beam did not result in an increase of the stress levels in the support and the support could still perform its intended function.
One deviation was reported for a baseplace being 1-inch l thick. The drawing specified a 7/8-inch baseplate. An evaluation concluded that the stresses in the baseplate l -
decreased and consequently there was no detrimental
> impact on the functional capability of the support. It was determined that the support can still perform its
. intended function.
All of these deviations were evaluated to be not safety-significant, and review of the deviations did l not indicate that an adverse trend existed.
5.3.27 Loose Locknut (Jam Nut) on Barrel of Strut l There are a total of 17 locknuts on 13 struts contained
- in 11 supports. Struts art fixed-length load-carrying l support members. One of these supports has a deviation reported for a loose locknut on the barrel of a strut.
Revisions 1 Page 28 of 62 RESULTS REPORT
(}
ISAP VII.b.3 (Cont'd)
' 5.0 IMPLDIENTATION OF ACTION,. PLAN /ED DISCUSSION OF RESULTS (Cont'd)
One threaded eyerod f: screwed into each end of the strut barrel. The ey lods at the ends of the strut barrel have opposite-hand threads. The locknut adjacent to the barrel of the strut prevents the strut barrel from turning relative to the eyerods to prevent the strut length from extending or contrecting.
Changes in strut length could change the loadings on the strut, thereby rendering the strut inoperable.
This deviation is comparable to the construction deficiency identified for Loose Jan Nuts in the ISAP VII.c Large Bore Pipe. Supports-Rigid population.
Corrective action has been reconaended to TUGC0 for the construction deficiency identified in ISAP VII.c.
Therefore, it was decided not to evaluate this deviation, and it was declared to be an unclassified deviation. It was concluded that the root cause and generic implication analysis and the reconaended corrective action in Section 5.6.1 of this Results Report and in the ISAP VII.c Results Report is sufficient to assure appropriate corrective action.
l 5.3.28 QC Inspector Qualification There were eight deviations written for improper certification of QC inspectors. These deviations, which involved seven inspectors, were referred to the '
ISAP I.d.1 Issue Coordinator for evaluation. One deviation was invalidated. The remaining six QC inspectors were evaluated in accordance with ISAP I.d.1 l evaluation methodology. It was determined that five of i - the inspectors were qualified and one inspector was not ,
l properly qualified during this evaluation process.
l These deviations and inspector qualifications are i ,. addressed in the Results Report for ISAP I.d.1, "QC l .
, Inspector Qualifications." Refer to that report for
. conclusions.
l 5.4 Analysis of PS7N Pipe Support Deviations (See Table 6) i 5.4.1 Excessive Spherical Bearing Clearance There are approximately 360 spherical bearings on O approximately 150 supports, Fifty-three bearings on 43 of these supports have a de'viation reported for excessive gap between the spherical bearings and the bearing washers.
l l
Revisient 1 l Page 29 of 62 RESULTS REPORT
. ISAP VII.b.3 (Cont'd)
- 5.0 IMPLEMENTATION OF ACTION,. PLAN AND DISCUSSION OF RESULTS (Cont'd)
One bearing in a rear bracket did not have any spacers installed. Another was partially dislodged by 1/8-inch. It was concluded that all of the bearings as-found could perform their intended function. These deviations we o evaluated to be not safety-significant.
See Section 5.3.4 for analysis of excessive bearing gaps and partially dislodged bearings.
5.4.2 Load Pin Locking Device Missing There are approximately 390 load pins on 166 supports.
Sixteen supports have's deviation reported for broken, ,
missing, or undersized cotter pins or snap rings. The '
cotter pins and snap rings hold load pins in place.
The load pins hold components of the pipe support assembly together. A support will lose its
() load-carrying ability if the 1 cad pin is not present or not properly engaged in the support assembly.
One support has two missing cotter pins, one on each load pin. The load pin axes are in tha vertical (gravity) direction. The top cotter pin for one of the load pins is missing; the bottom cotter pin for the other load pin is missing. It was determined that the
' load pin with the missing top cotter pin could slip out of the support assembly, causing the support to be inoperable. It was determined that the missing cotter pin is a construction deficiency. The remaining deviations were either shown to be not safety-significant or were not classified because they were similar to the one that was determined to be a ;
construction deficiancy and would be addressed appropriately by the recommended corrective action. -
~
' See Section 5.5.6 for root cause and generic
., implications analyses.
5.4.3 Pipe Clamp Halves Not Parallel There are approximately 150 pipe clamps on 138 supports. Approximately forty-five of these supports '
have deviations for load side pipe clamp halves not O parallel. Pipe clamps, when properly installed with the correct parts and bolt ' tightness, should have the load side of the pipe clamp approximately parallel.
3l R';visien 1 Page 30 of 62 l
(J,~~) RESULTS REPORT ISAP VII.b.3 (Cont'd) 5.0 IMPLDfENTATION OF ACTION, PLAN AND DISCUSSION OF RESULTS (Cont'd)
Approximately sixteen clamps had ears that were inclined closer together. The load pin stresses were not increased by this condition; neither was the spherical bearing gap increased. It was determined that the clamp ears did not interfere with the support eyerods and the clamps could perform their intended function.
Approximately 30 clamps had ears that were spread apart, causing increases in load pin bending stress.
The load pins had bending stresses within ASME Code allowables. It was determined ths.t these load pins could perform their intended function. None of these clamps had excessive bearing gaps. These deviations were evaluated to be not Jafety-significant.
A similar deviation was identifind in the ISAP VII.c p "Large-Bore Pipe Support-Rigid" population, Appendix x 25, as a construction deficiency. Therefore, no trend analysis was performed for these deviations.
Corrective action has bec,n reconnended by ISAP VII.c and has been incorporated into the Hardware Validation Program (HVP). This corrective a:tfon requires the reinspection of pipe clamps for the installation of the correct spacer.
Additionally, TUGC0 has issued Design Change Authorization (DCA) 49801 limiting the maximum gap between the pipe clamp halves at the load pin location on NPSI model SPC-06 pipe clamps. The DCA is based on a NPSI letter recommending further conservatism on the SPC-06 pipe clamp. 'Ihe gap is controlled by the installation of the proper spacer. No other gap dimensional limitations at the load pin locations were
, specified by NPSI for other pipe clamp sizes, other
, than the inherent gaps which result from the proper
. installation of the pipe clamps.
The corrective action in ISAP VII.c and the issuance of the DCA by TUGC0 as described above, combined with pipe clamp installation in accordance with vendor instructions, provide adequate assurance that vendor requirements for parallelism are met. The vendor installation instructions ,should be retained in TUGC0 construction and inspection procedures.
m
. R vision: 1 Pego 31 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
, 5.0 IMPLEMENTATION OF ACTION PLAN ~AND DISCUSSION OF RESULTS (Cont'd)
. 'r. .
A construction deficiency for an'NPSI SPC-06 pipe claap with halves not parallel was identified in Revision 0 of this report for one of the above deviations based on an analysis by SSEG. A subsequent reanalysis of the deviation considering the load applied at the ends of the load paddle rather than distributed over the load paddle width and considering the load reacting at the inside edge of each clamp ear rather than at the center of each ear was performed by Stone & Webster. The SSEG determined from the results of this analysis that the deviation was not safety-significant.
Design concerns relative to the adequacy of pipe clamp load pins have been transmitted to the Project on QA/QC-RT-10046. The adequa'cy of load pins will be evaluated by the Project.
5.4.4 Snubber Adapter Plate Bolting - Insufficient Thread Engagement CPRT reinspection results reported snubber adapter plate bolts with less than full thread engagement in the snubber adapter plate; however, no deviations from the CPRT reinspection procedura requirements were reported. See Section 5.3.6 of this report for additional discussion on this subject.
5.4.5 No Locking Devices For Threaded Fasteners There are approximately 320 threaded fasteners (studs and bolts with nuts securing thea in place) on 144 supports. Approximately 300 fasteners on 136 of these supports have a deviation reported for no locking
, devices. One of the supports without locking devices was a frame type support fabricated from tube steel
. containing SA-36 threaded rod in a structural joint.
. Three of the supports are snubbers with broken and missing lockwires on adapter plate bolting. The ream bia;; supports had missing locking devices, primarily on pipe clamp bolting.
The absence of locking devices increases the possibility for bolts and studs to work loose under operating conditions. Loost or missing bolts and studs O could result in the loss of the pipe support capability to transfer loads by causing a load-carrying component to become disengaged from the support assembly.
Revision: 1 Page 32 of 62 l RESULTS REPORT
(}
ISAP VII.b.3 (Cont'd)
. 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
All 'fothese deviations were evaluated in a single safety significance evaluation and were determined to be construction deficiencies. The construction deficiencies for missing locking devices were incorporated into the generic construction deficiency identified in Section 5.3.1. The construction deficiencies for broken and missing lockwires were consolidated into a generic construction deficiency for broken and missing lockvires on snubber adapter plate bolting. See Section 5.5.2 for root cause and generic implication analyses for the construction deficiency on missing locking devices and Section 5.5.7 for root cause and generic implications for the construction deficiency on broken and missing lockwires.
5.4.6 Support ID Missing or Incorrect All 178 supports are required to be marked with an i
O identification number given on the design drawing. One of these supports has a deviation reported for a snubber with an incorrect identification number. The identification number on the support drawing is SI-1-079-009-S42X. The number on the installed snubber is SI-1-076-002-S22K. Inspection records show that the installed snubber was salvaged from support SI-1-076-002-S22K. Another support containing a
' snubber has a deviation reported for no identification number. It was determined that these snubbers are the correct model and size and there is no effect on the load-carrying capacity of the support or on the ability of the support to perform its function. No other deviations were reported for missing or incorrect support identification. No trend evaluation was performed for these two deviations.
5.5 Root Cause and Generic Implication Evaluation This section pro'vides the root cause and generic implications analyses for tha construction deficiencies identified during i
the implementation of this Action Plan. These are listed below.
Construction Deficiencies No Locking Devices for Thrteded Fasteners (See Section i
5.3.1 and 5.4.5) l
__ 1 R;visient 1 i Pcg3 33 of 62 '
I RESULTS REPORT ISAP VII.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Pipe' Clearance with Support Out of Tolerance (See Section 5.3.10)
Pipe Clamp Locknut Loose (See Section 5.3.11)
Strut Misalignment (See Section 5.3.12)
Load Pin Locking Device (Cotter Pins) Missing (See Section 5.4.2)
Broken and Missing Lockwire on Snubber Adapter Plate Bolting (See Section 5.4.5) '
5.5.1 Background Information ,
Brown & Root fabricated, installed and inspected the ASME Code Class 1, 2, and 3 pipe supports in Unit 1 and Common areas. Fabrication and installation of most of O the Unit I and Common supports commenced in the latter part of 1979 and continued through 1983. Most of the supports were QC-inspected during this period.
Fabrication, installation and inspection were performed to the Brown & Root procedures listed below.
CP-CPM-9.10. "Fabrication of ASME Related Component Supports", effective from 9/30/80 to present (Revision 15).
- QI-QAP-11.1-28, "Fabrication Installation Inspections of ASME Component Supports, Class 1, 2, and 3", effective from 9/8/80 to present (Revision 34).
QI-QAP-11.1-28A, "Insta11stion Inspections of ASME Class 1, 2, and 3 Snubbers", effective from 10/29/82 to present (Revision 5).
CP-QAP-12.1, "Inspection Criteria and Documentation Requirements Prior to System N-5 Certification", effective 2/22/82 to present (Revision 6).
When a sufficient amount of piping, equipment, and pipe 3 supports was installed (permanent supports and sometimes temporary supports), the Startup Group, which was not under Brown & Root supervision, performed
._ . . . - . . ~ . .
Reviciens 1 Pcgs 34 cf 62 RESULTS REPORT ISAP VII.b.3 (Cont'd) 5.0 IMPLDfENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) systita tests. These tests conumenc'ed in the latter part of 1980 for most of the systems in Unit 1 and Conunon and continued into 1983.
Final system walkdown inspections and N-5 certification by Brown & Root were completed in the latter part of 1983 for Unit i and Common.
After N-5 certification (1983), Brown & Root turned the systems over to TUCCO. The TUGC0 Startup Group checked the cold position spring hanger and snubber settings on systems using TUGC0 Startup Procedure XCP-ME10. All ASME III systems in Unit 1 and Common Areas were turned over to TUGC0 Operations by the latter part of 1984.
In early 1985 the TUCCO Operations Group parformed thermal expansion rests on systems that operate above 200*F to check and adjusted (if necessary) anubber O travel settings and spring hanger settings at various temperature plateaus using TUCCO Startup Preoperations Test Procedure 1-CP-PT-55-11.
The CPRT performed the bulk of their pipe support inspsetions during the latter part of 1985, two years or more after the supports were QC inspected and
- accepted. The CPRT found some supports that were misaligned, bent, had loose nuts sad broken and missing cotter keys, all of which could have occurred after the supports were initially QC inspected and accepted.
Therefore a QA/QC Program Deviation Report (PDR-L61) was prepared to identify a situation where adequate procedures and controls for preserving pipe supports in their proper QC-inspected and accepted configuration,
, , were apparently not in place.
t 5.5.2, No Locking Devic.es on Threaded Fasteners i .
A construction deficiency exists for No Locking Devices
- on Threaded Fasteners. This deficiency is comparable to construction deficiencies identified for Inappropriate Locking Devices in the following three populations of ISAP VII.c, "Construction Reinspection / Documentation Review Plan"
Large-Bore Pipe Supports - Rigid Large-Bore Pipe Supports - Non-Rigid Small-Bore Pipe Supports i
Rcvisient 1 Pega 35 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTIONkPLAN AND DISCUSSION OF RESULTS (Cont'd) 1 It was determined that the root cause and generic implications analyses performed for these VII.c construction deficiencies encompass the deficiency identified for No Locking Devices on Threaded Fasteners in this ISAP. See Section 5.6.1 for recommended corrective action.
4 5.5.3 Pipe Clearance with Support Out of Tolerance A construction deficiency exists for a pipe wedged between a U-bolt and a steel plate on support CC-X-039-005-F43R. The pipe wall is bearing against the U-bolt and a pipe circumferential butt ' weld near the U-bolt is bearing against a steel plate on the support diametrically opposit,e from each other.
The pipe support design dravicg specified 1/16 inch clearance between the pipe and U-bolt ar.d between the pipe and the plato. Brown & Root Construction l Procedure CP-CPM-9.10 gives generic tolerances tor the
! pipe clearance specified on the drawing. Brown & Root
, inspection procedure QI-QAP-11.1-28 gives the same generic tolerances as Construction Procedure CP-CPM-9.10 for pipe cler.rance diminsions.
The fact that the weld was within the support envelope is an apparent violation of Gibbs & Hill Pipe Hanger and Support Specification 2323-MS-46A, which contains j requirements for minimum axial distances between pipe circumferential bute welds and pipe supports. Howevar, I neither the Gibbs and Hill Piping Erection l
Specification 2323-MS-100, which provides requirements for support erection, nor the Brown & Root construction and inspection procedures contains these requirements.
, However, as previously stated, clearance requirements between pipe and support were included in the Brown &
. Root' procedures.
~
The same i:onstruction and inspection procedures tht.t pertain to pipe support clearances are applicable to both U-bolt and frame type supports. Therefore, the root cause and generic implications analyses will be the same for both cases.
1 O s l
Revision: 1 Pege 36 of 62
-3 RESULTS REPORT d ISAP VII.b.3 (Cone'd) 5.0 IMPLEMENTATION OF ACTION' PLAN AND DISCUSSION OF RESULTS (Cont'd)
An adverse trend exists for Gaps or clearance in the following populations of ISAP VII.c:
Large-Bore Pipe Supports - Rigid Small-Bore Pipe Supports It was determined that the root cause and generic implications analyses performed for the adverse trends addressing Caps in the aforementioned populations encompass the construction deficiency for unacceptable clearance in this ISAP. See Section 5.6.3 for recommended corrective action.
5.5.4 Pipe Clamp Locknut Loose A construction deficiency exists for a loose locknut on an ITT Grinnell pipe clamp bolt. ITT Grinnell pipe clamp bolts are supplied with nuts and locknuts, f3 l (s,) The support, including pipe clamp, was installed in
! mid-1980 and inspected on 6/13/80. This was prior to j the issuance of QI-QAP-il.1-28 and CP-CPM-9.10.
The rod ends on the strut were adjusted and the support was inspected on 6/4/82. The inspection was documented on a Hanger Inspection Report (HIR), Attachment 2 of
'. QI-QAP-11.1-28. This procedure requires fasteners to j
be tightened securely.
The support was inspected for N-5 certification on 7/11/83 in accordance with CP-QAP-12.1; Revision 7.
This procedure did not require a check for fasteners to be tightened securely.
Because of the long period of time betwee'n the last
~
documented inspection and the CPRT inspection, and due to the limited amount of information available, it is not possible to determine the specific root cause for this deficiency. A QA/QC Program Deviation Report, PDR-061, has been initiated to address the preservation of pipe suppor:s in their QC-accepted configuration.
See Section 5.6.1 for recommended corrective action.
It should be noted that loose locking devices were also O found in VII.c inspections'pf pipe supports.
Revisient 1 l Pege 37 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd) !
.' 1 l
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l 5.5.5 Strut-Misalignment A construction deficiet'.:7 exists for an ITT Grinnell ,
strut that is offset 6' with respect to the rear l bracket and offset 8' with respect to a pipe clamp.
The maximum allowable offset is 5'. Also, the rods that connect the strut body to the rear bracket and clamp were bent. The bent rod may have caused the centerline of the strut to go out of alignment.
A CMC dated 8/5/80 required the pipe clamp to be shifted several inches along the axis of th~e pipe from the specified position to avoid a pipe butt weld. The clamp was moved and the support was inspected and found satisfactory by QC on 9/17/80.
An item removal notice was issued on 2/10/81 to remove the support to allow the craft to work on the pipe.
lO
! (/
Records indicate that the support was reinatalled, inspec:ed and found satisfactory by QC on 2/18/81. The inspection procedure in effect at the time was QI-QAP-11.1-28, Revision 4. issued 12/8/80, which gives the following offset requirements with respect to the pipe clamp and rear bracket centerlines:
"Sway Strut Unit - maximum sway strut misalignment shall not exceed 6* for NPSI and 5' for ITT-Grinnell from the center line of the sway strut (12' and 10* included angle)."
A CMC dated 7/1/82 required the weld that attaches the rear bracket to the baseplate to be increased in size.
The weld size was increased and the support was inspected for welding only and found satisfactory on 9/2/82.
The support was inspected for N-5 certification on 4/13/83 in accordance with CP-QAP-12.1, Revision 5 issued 3/16/83. Although this procedure does not require a check for strut offset angles, the damage (bent rod) probably would have been apparent. The CpRT inspection that identified the deficiency was performed during the latter part of 1985, more than four years after the last QC inspection for offset.
O t
. Revisient- 1 Pegs 38 of 62 RESULTS REPORT k
ISAP VII.b.3 (Cont'd)
. 5.0 IMPLEMENTATION OF ACTION
- ' PLAN AND DISCUSSION OF RESULTS (Cont'd)
Because of the long period of time between the last documented inspection for strut offset, it is not possible to determine the specific root cause for this deficiency.
A QA/QC Program Deviation Report (PDR-061) has been initiated to address the preservation of pipe supports in their QC-accepted configuration. Corrective action will be taken by TUGCO. See Section 5.6.4 for recommended corrective action.
5.5.6 Load Pin Locking Device (Cotter Pins) Missing A construction deficiency ex,ists for a missing cotter pin on the upper end of a load pin on a strut type support. This deficiency is comparable to the construction deficiency identified for Fasteners (broken cotter keys) in the following population of ISAP VII.c Large-Bore Pipe Supports - Non-Rigid It was determined that the root cause and generic implications analyses performed for the construction deficiencies addressing Fasteners in the aforementioned ISAP VII.c population encompass the deficiency identified for Load Pin Locking Device (Cotter Pins)
Missing in this ISAP. See Section 5.6.2 for recosamended corrective action.
5.5.7 Broken and Missing Lockwire on Snubber Adapter Plate Bolting I
, Construction deficiencies exist for missing and broken I lockwire on snubber adapter plate bolting. These construction deficiencies were included in a generic construction deficiency for no locking devices on l threaded fasteners. The root cause and generic !
implications for these construction deficiencies are l similar to those identified for Fasteners (broken '
cotter keys) in the following population of ISAP VII.ct Large-Bore Pipe Supports - Non-Rigid l t
l t
...m.m.c.._-
l Rcvisient 1
Pcge 39 of 62
( RESULTS REPORT l
ISAP VII.b.3 (Cont'd)
. 5.0 IMPLEMENTATION OF ACT. ION PLAN IND DISCUSSION OF RESULTS (Cont'd)
~
The same procedures involving removing and replacing cotter keys apply to lockwire. It was determined that the root cause and generic implications analyses performed for the construction deficiencies addressing Fasteners in the aforementioned ISAP VII.c population encompass the deficiency identified for broken and missing lockwire on snubber adapter plate bolting. See Section 5.6.1 for recommended correctiva action.
5.6 Reconumended Corrective Actions Most of the findings encountered in this results report were also identified in the ISAP VII.c populations; therefore, the majority of the corrective actions will also be covered by ISAP VII.c corrective actions for similar findings.
The recommended corrective actions below include those for safety-significant findings and those for PDRs resulting from implementation of this ISAP.
5.6.1 No Locking Devices for Threaded Fasteners; Pipe Clamp Locknut Loose; Broken and Missing Lockwire on Snubber Adapter Plate Bolting; Looss Jan Nut on Barrel of Strut There are three construction deficiencies and one unclassified deviation.for missing and loose locking m
devices on threaded fasteners.
It is recommended that all ASME Class 1, 2, and 3 pipe support bolts and stude, other than high strength bolts used in high strength bolt applications, be inspected for the presence of approved locking devices and for proper locking device installation / tightness. This !
, inspection effort should include locking devices used on vendor-supplied ASME Class 1, 2, and 3 support components such as jam nuts used on the barrel of struts and safety wire used on snubber bolting.
5.6.2 Load Pin Locking Device Broken or Missing A construction deficiency exists for a missing cotter ,
pin on a strut type support in Room 77N.
It is recommended that all ASME Code Class 1, 2, and 3 O pipe supports and Class 5 dnd 6 pipe supports within the ASME III pipe stress boundary be inspected for broken, missing, and undersized cotter pins and snap
I l
Rcvisient 1 Page 40 of 62 l
RESULTS REPORT '
N ISAP VII.b.3 (Cont'd)
. 5.0 IMPLDfENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) rings. Brohen,missingorundersizedcotterpinsand snap rings should be replaced with vendor qualified or !
engineering-approved items. The inspection and rework l effort should be performed on the basis of ;
engineering-approved procedures which indicate specific cotter pin / snap ring sizes for load pins for each support model/ size.
5.6.3 Pipe Clearance With Support Out of Tolerance; A construction deficiency exists for insufficient clearance between a U-bolt pipe support and a pipe circumferential butt veld on a PS42 pipe support.
It is recommended that inspection procedures be modified to include minimum axial distances between pipe butt welds and supports so as not to impair the function of the support, pipe or adjacent equipment.
f- 3 All ASME Code Class 1, 2, and 3 pipe supports
, ()
(including frame type supports) and Class 5 and 6 pipe j supports within the ASME III pipe stress boundary i should be inspected to this new criterion for proper axial distance from pipe welds and to existing criteria for proper gap (clearance) between pipe and support.
l 5.6.4 Strut Misalignment A Construction Deficiency exists for a strut aisaligned with a pipe clamp for a PS42 support.
All snubbers, struts and spring type supports on all
_ ASME Code Class 1, 2 and 3 pipe supports and Class 5 and 6 pipe supports within the ASNE III pipe stress boundary should be inspected for correct angularity of
, the support centerline with respect to pipe support clamps and pipe support brackets; for damage such as
, bent rods; and for angular or linear dimensions that affect support orientation with respect to the building and piping as shown on the design drawings.
QA/QC Program Deviation Report 061 was issued to TUGCO.
It documented insdequacies in current procedures and controls for effectively maintaining completed pipe O supports in the QC-accepted configuration. This PDR was evaluated by the QA/QC' Review Team to determine if
... . . . . . . . . .. =
Revisien: 1 Page 41 of 62 l p RESULTS REPORT b ISAP VII.b.3 (Cont'd)
, 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) it sI1ould be classified as a QA/QC pr) gram deficiency.
Because the action required to correce existing procedures and develop any additional procedures that might be required is not considered extensive, the QA/QC Review Team determined that PDR 061 is not a QA/QC program deficiency. Past hardware problems are being resolved by the corrective action developed to resolve the related construction deficiency.
5.6.5 Spherical Bearing / Washer Gap Excessive; Spherical Bearing Partially Dislodged QA/QC Program Deviation Report 076 has been issued to TUGC0 with the following recommendations.
All ASME III Code Class 1, 2 and 3 anubbers and struts and Class 5 and 6 anubbers and struts within the ASME III pipe stress boundary should be inspected for proper O spherical bearing seating in the eyerod; installation of acceptable spherical bearing spacers; and proper gap between the spherical bearing and bearing spacers. The sizes of vendor-supplied sphe,rical bearing spacers and maximum allowable gaps in rear brackets and pipe clamps for each type / size snubber and strut should be determined and specified in the inspection procedures.
~
PDR-076 was evaluated by the QA/QC Review Team to determine if it should be classified as a QA/QC program deficiency. The procedural changes that are required to assure proper installation and inspection of spherical bearings to prevent recurrance of the
~
identified problems are not extensive. In addition, the Hardware Validation Program developed by TUCCO had
, already addressed reinspections in this area. Based on these. factors, the QA/QC Review Team determined that
, this PDR was not a QA/QC program deficiency.
5*.6.6 Baseplate Hole Location Dimension Out of Tolerance QA/QC Program Deviation Report 075 has been issued to TUGC0 with the following reconnendations.
Baseplates on all ASME III Code Class 1, 2 and 3 supports and Class 5 and 6 supports within the ASME III O pipe stress boundary should,be inspected for compliance
e - ~
R:visient 1 Page 42 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
. 5.0 IMPLEMENTATION OF ACTIO PLAN'AND DISCUSSION OF RESULTS (Cont'd) with final design drawings for proper hols locations, support member locations on baseplates, and edge distances.
PDR-075 was evaluated by the QA/QC Review Team to determine if it should be classified as a QA/QC program deficiency. No extensive procedural evaluation or revisions are required to prevent recurrence of this problem. In addition, pipe support corrective action (see DCN-5 dated February 13, 1987 and Appendix 2 to Procedurs CP-QAP-12.1, Revision 18) developed by TUGC0 included reinspection of bolt hole locations. Based on these factors, the QA/QC Review Team determined that this PDR was not a QA/QC program deficiency.
6.0 CONCLUSION
S The CPRT reinspected 220 supports for the purpose of substantiating the TRT findings and assessing the impacts of the TRT findings on construction quality. Additionally, more than 300 supports were reinspected under ISAP VII.c for the purpose of assessing construction quality. Many of TRT findings were substantiated.
Corrective actions were recommended in this report for construction deficiencies, program deviation reports and unclassified deviations. TUGC0 has initiated corrective action for many of the recommendations. Areas where corrective action has not been recommended in this report are welding and pipe support documentation. No inspection findings impacting support functional capabil.ity were identified in these areas.
The recommendations in this Results Report and in the ISAP VII.c and ISAP I.d.1 Results Repor:s are sufficient to satisfactorily resolve.the TRT issues.
7.0 ONGOING ACTIVITIES There are no ongoing activities.
O 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE Implementation of the recommendations in this report and in the ISAP VII.c Results Report will preclude occurrence in the future.
. - . . - . . . - r. w Revisient 1 Pcge 43 of 62 O RESULTS REPORT j O
ISAP VII.b.3 (Cont'd)
Table 1 5
Pip's Supports in Unit 1 -
Supports Inspected by TRT As-Built Group *42 Class 1 Supports Inspected 4 Class 2 Supports Inspected 14 Class 3 Supports Inspected 24 Hangers With Problems.
26 Total Problems Identified 46 Procedure Adequacy Problems 5 Hardware-Related Problems 16 As-Built Drawing Related Problems 8 Component Identification Problems , 2 Weld-Related Problems 10 QC Record Problems 1 Material Identification Problems 4 Welds Inspected Without Paint by TRT 305 O Welds Inspected With Paint by TRT Total Welds Inspected by TRT 89 394 Welds Needing Wald Repair 10
% of Welds Inspected 2.5%
Supports Needing Welding Repair 6 l % of Supports Inspected 14%
l l
NO. OF SUPPORTS BUILDING __
SYSTEM INSPECTED
~
Containment Safety Injection (SI) 1 Containment Reactor Coolant (RC) 6 Containment Residual Heat Renoval (RHR) 2
, Fuel Handling -Component Cooling (CC) 11 Safeguards Residual Heat Removal (RHR) 1 Safeguards Containment Spray (CT) 8 Safeguards Domineralized Water (DD) 1 Safeguards Auxiliary Feedwater (AF) 8 Auxiliary Chemical Volume & Control (CS) 1 Ssfeguards Main Steam (MS) 2 Safeguards Chilled Water (CH) 1 0 .
All 42 pipe supports inspected by the TR'T had been previously accepted by site QC.
, O .
O ( ).cion: 1 1m 0 44 cf 62 RESULTS REPORT s
ISAP VII.b.3 (Cont'd) .
- Table 2 Pipe Supports in Unit 1*
PROBLEM CATECORY HANGER NO. NO. OF PROBLDfS TYPE
- l. No locking device for' threaded fasteners RC-1-901-702-C82S 2 Hardware problem CS-1-085-003-A42K
- 2. Min. edge distance (on base plate) violated CC-X-039-006-F43R 1 Hardware problem
- 3. Base plate hole-location dimensions out of tolerance CC-X-039-007-F43R 4 As-Built prob'lem CC-1-126-010-F33R _
CC-1-126-Oll-F33R CC-1-126-012-F33R , s 5 Spherical bearing / washer gap excessive CC-1-126-015-F43R 4 Hardware problem RC-I-052-016-C41K RC-1-052-020-C41K
, MS-1-416-001-S33R 5 ., Spherical bearing contamination SI-1-090-006-C41K 2 Hardware problem MS-l-416-002-S33K**
- 6. Snubber adapter plate-insufficient thread engagement MS-1-416-002-S33K 3 Procedure problem SI-1-090-006-C41K -
CT-7-013-012-S32K .
?
- 7. Insufficient threaded eng'at, threaded rod RC-1-901-702-C82S 1 Hardware problem (sight holes)
All 42 pipe supports inspected by TRT had been previously accepted by site QC.
Revision 2 (dated January 7,1983) of pipe support drawing changed the mark number from MS-1-416-002-S33R to MS-1-416-002-S33K. '
- ~t
(' '
(/)
x-ions 1 45 cf 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
Table 2 (Cont'd)
PROBLEM CATECORY HANGER NO. NO. OF PROBLEMS TYPE
- 8. Snubber / Strut lo'd a pin locking s device broken or AF-1-001-014-S33R I liardware problem missing
- 9. Load side of pipe clamp halves not parallel AF-1-001-001-S33R 2 Procedure problem AF-1-001-014-S33R ,
- 10. Pipe clearances with support out of tolerance CC-1-126-013-F33R 2 _ Hardware problem AF-1-001-702-S33R
- 11. Pipe clamp locknut loose AF-1-035-Oll-S33R 1 Hardware problem
- 12. Snubber / Sway strut misalignment CC-I-126-014-F43R 2 Hardware problem RC-I-OS2-020-C41K
- 13. Snubber cold set dimension does not match drawing CS-1-085-003-A42K 1 As-Built problem 14 .-' Snubber orientation does not match drawing CT-1,-005-004-S22K 2 As-Built problem CT-1-013-010-S22K
- 15. Component type /model no. Installed does not match SI-1-090-006-C41K 2 Compon. ID problem drawing RC-1-052-020-C41K
- 16. No identification for support materials, parts, and CT-1-013-014-S32R 4 Material components identified. CC-1-126-012-F33R identification CC-I-039-005-F43R problem AF-1-035-Oll-S33R
- 17. BRP column line dimension does not match BRHL Support not affected 1 As-Built problem dimension
- 18. Wald porosity excessive AF-1-001-001-S33R 1 Weld-related problem
4 f 62 RESULTS REPORT i,'
ISAP VII.b.3 (Cont'd)
Table 2 (Cont'd) l l
PROBLEM CATECORY HANGER NO. NO. OF PROBLEMS TYPE
- 19. Weld undercut oncessive AF-1-001-702-S33R 1 Weld-related problem
, 20. Weld length undersized AF-1-001-001-S33R I Weld-related problem i
i l 21. Weld leg or effective throat undersized AF-1-001-001-S33R 3 Weld-related problem I ,.
RH-1-006-012-C42R
- CC-I-039-007-F43R
- 22. Weld called out on drawing does not exist in field CC-1-126-013-F33R 1 Weld-related problem
- 23. Welds added in field are not reflected on drawing AF-1-001-702-S33R 1 Weld-related problem numerous welds
- 24. Excessive grinding resulting in min. thickness AF-1-037-002-S33R 2 Weld-related problem l -
violations (weld clean-up) CT-1-013-014-S32R t
46 Total problems identified by TRT l
Revisic38 1 Pcge 47 ef 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
' Table 3 Summary of', Additional TRT Inspections AREA: Room 77N, El 810'-6" Unit 1, Safeguards Bldg.
% SUPPORTS DEVIATION NO. OF SUPPORTS NO. OF SUPPORTS WITH TYPE INSPECTED WITH DEVIATIONS DEVIATIONS Item 1. Excessive Spherical 92 5 5.4%
Bearing Clearance Item 2. Load Pin Locking 92 14 15.2%
Device Missing ,
Item 3. Pipe Clamp Halves 40 9 22.5%
Not Part11e1.
Item 4. Snubber Adapter Plate 19 *13 to be
\s- Bolts With Less Than determined Full Thread Engagement AREA: Cable Spread Room 133, El 807'-0" Unit 1, Auxiliary Bldg.
I BOLTS DEVIATION NO. OF BOLTS NO. OF BOLTS WITH TYPE INSPECTED WITH DEVIATIONS DEVIATIONS Item 5.** Hilti Kwik Bolt 24 3 12.5%
Does Not Meet Minimua EmFedmont***
Areat Unit 1 Item 6. Locking Devices for '
Threaded Fasteners Bolts had less than full thread engagement.
l Found by the TRT during inspections of electrical support baseplates, l
- Taking into account the "allowed" slippage of the bolt for a distance of O one nut thickness due to torquins (Ref. "Installation of Hilti Drilled-In Bolts" 35-1195-CEI-20. Revision 3, Paragraph 3.1.4.1) and the minimum specified embedmont, the above Hilti bolts violated the "effective" embedment requirements.
O
- O' Revicion:
Pega 1
48cf62(Nd)
RESULTS REPORT l ISA' VII.b.3 .
(Cont'd)
Table 4 Comparison of Inspection Results for PS42 Supports
- 8 HANGER f/
PACKAGE # TRT FINDINGS CPRT FINDINGS
- REMARKS AF-1-001-001-S33R 1. Load side of pipe clamp halves 1. Not able to verify. The NRC letter dated I-S-PS42-01 not parallel , January 8, 1985 says this
- 2. Weld porosity excessive 2. Same as 1. above. support was scrapped and
- 3. Weld length undersized 3. Same as 1. above. rebuilt af ter the TRT
- 4. Weld leg or effective throat 4. Same as 1. above. inspection.
undersized a s'-
AF-1-001-702-S33R 1. Pipe clearances with support 1. Verified 1. Out of tolerance.(.015" I-S-?S42-04 out of tolerance clearance on top and botton)
- 2. Weld undercut excessive 2. Not able to verify 2. Weld undercut was
. 3. Welds added in field are not 3. Verified repaired prior to TRT reflected on dwg. -
inspection.
AF-1-001-014-S33R 1. Snubber / strut load pin locking 1. Verified -
I-S-PS42-02 device broken or missing (broken cotter pin)
- 2. Load. side of pipe clamp halves 2. Verified not parallel O All of the CPRT findings are not shown in this tabic. Only the CPRT findings that correspond to the TRT findings for the twenty-six (26) supports are shown in this table.
~r --r
Revicico Paga 49 cf 62's /
Ih RESULTS REPORT ISAP VII.b.3 '
(Cont'd)
Table 4 (Cont'd) i l HANGER #/ .
PACKACE # TRThINDINGS CPRT FINDINGS REMARKS
- AF-1-035-Oll-S33R 1. Pipe clamp locknut loose 1. Verified I-S-PS42-05 2. No identification for support 2. Verified materials, parts and components -
on the Material Identification Log (MIL) er in documentation package. -
AF-1-037-022-S33R 1. Excessive grinding resulting 1. Verified - s'
- I-S-PS42-07 in min. thickress violations of baseplate and weld size at baseplate.
CC-1-126-010-F33R 1. Base plate hole location 1. Verified 1. Revision CP-1 (Issued I-S-PS42-09 dimensions out of tolerance June 26, 1985) lowered (support member 3" lower than the centerline of the specified relative to upper bolt support by holes) -
approximate ,-1/4" from its position on the previous Revision C1RT 5
inspections were performed to revision
) CP-1 and acceptance satisfactory.
f CC-1-126-Oll-F33R 1. Base plate hole location dimensions 1. Verified I-S-PS42-10 out of tolerance 4
i l
l
^
t s
- f. i D} Revicion:
P.cg2 50 cf 6'id 1:f RESULTS REPORT 1
ISAP VII.b.3 ' ,
(Cont'd)
! Table 4 (Cont'd) i .
HANCER f/ .
j PACKAGE # TRT' FINDINGS CPRT 7INDINGS REMARKS OC-1-126-012-F33R 1. Base plate hole location 1. Verified I-S-PS42-Il dimensions out of tolerance
- 2. No identification for support 2. Verified -
materials, parts and components on the Material Identification Log .-
(MIL) or in documentation
- packsge. -
CC-1-126-013-F33R 1. Pipe clearances with support 1. Verified I-S-PS42-12 out of tolerance 1 2. Weld called out on dwg. does 2. Verified 2. CMC 87927 Revision 4 l not exist in field (1/4" fillet (Issued March 2, 1983) 4 connecting item 5 to item 6 missing) changed the weld symbol to delete this weld but has not bean incorporated into the
-d,rawing.
- 3. No QC inspector initials or signature 3. Verified in signature block on veld data card CC-I-126-014-F43R 1. Snubber / sway strut misalignment 1. Verified I-S-PS42-13 (exceeded 5* from centerline cf strut CC-1-126-015-F43R 1. Spherical bearing / washer gap 1. Verified I-S-PS42-14 excessive l
Pcg2 51 ef 62 \
I RESULTS REPORT ISAP VII.b.3 i
(Cont'd)
Table 4 1
(Cont'd)
HANGER d.'
- PACKAGE I TRT IINDINGS CPRT FINDINGS REMARKS CS-1-085-003-I.42K 1. No locking device for threaded 1. Verified I-S-PS42-20 fasteners on clamp holta
- 2. Snubber cold est dimension does 2. Verified 2. Per QI-058 the ERC not match dwg. inspector was required to-record the cold set dimension. Recorded was 8-3/4" versus 8-1/8" required. An out of scope observation has been generated per CPP-020.
CT-1-005-004-S22K 1. Snubber orientation does r.ot 1. Verified I-S-?S4R~21 match dwg. (installed opposite end to end) -
CT-1-013-010-S22K 1. Snubber orientation does not 1. Not able to verify. 1. This type of finding I-S-PS42-24 match dwg. (installed opposite ha~s been verified for end to end) other similar type supports.
CT-1-013-012-S32K 1. Snubber ad-pter plate bolts 1. Verified I-S-PS42-26 with less than full thread engagement
O O Revicions -1 Pasa 52 cf 62O RESULTS REPORT ISAP VII.b.3 ~
(Cont'd) -
Table 4 (Cont'd) l HANGER f/ a PACKAGE I TRT 8 FIDE)INCS CPRT FINDII3CS l RFMARKS
, CT-1-013-014-S32R I. No identification for support 1. Verified 7
l I-S-PS42-28 mat'1, parts and components ,
i on the Material Identification Log -
(MIL) or in documentation package (for evey strat eyerod) ,-
- 2. Excessive grinding resulting in 2. Not able to verify. 2. This type of finding j min. thickness violations (notching been verified for other of rear brackets during weld clean-up) s'upports.
]
CC-X-039-005-F43R 1. No identification for support 1. Verified I-S-PS42-15 met'1. parts and components on the Material Identification Log (MIL) or in documentation package.
CC-X-039-006-F43R 1. Minimum edge distance (for base 1. Verified I-S-PS42-16 plate holes) violated 1
CC-I-039-007-F43R 1. Base plate hole location dimensions 1. Verified 1. TAT inspection I-S-PS42-17 out of tolerance performed to Revision 4 (Issued April 25, 1983). ERC inspection performed and accepted to Revision CP-1.
- 2. Weld leg or effective throat 2. Not able to verify.
undersized (5/16" Fillet 1/16"
! undersized across top of tube steel)
MS-1-416-001-S33R I. Spherical bearing / washer gap 1. Verified I-S-PS42-31 excessiv: '
+
I
O O Revicions Paga 53 cf 62 1
,' RESUI.TS REFORT ISAP VII.b.3 (Cont'd) -
Table 4 (Cont'd)
HANCER f/ .
PACKACE f TRT WINDINGS CPRT FINDINGS RDIARKS MS-1-416-002-S33K 1. Spherical bearing contamination 1. Verified I-S-PS42-32 2. Snubber adapter plate bolts with 2. Verified less than full thread engagement .
(0.095 " less than full engagement)
RC-1-052-016-C41K 1. Spherical bearing / washer gap 1. Verified 1. S'p'acers not installed.
I-S-PS42-34 excessive , g RC-1-052-020-C41K 1. Spherical bearing / washer gap 1. Not able to verify. 1. This type of finding I-S-PS42-35 excessive has,been verified for other similar type supports.
- 2. Snubber / sway strut misalignment 2. Not able to verify. 2. Same as 1. above.
,. (exceeded 5* from centerline of snubber) .
- 3. Component type /model no. (snubber 3. Verified model number) does not match dwg. -
RC-1-901-702-C82S 1. No locking device for threaded 1. Verified 1-S-PS42-37 fastener (load bolt) at beam attachment.
- 2. Insufficient thread engagement 2. Verified (threaded rod not visible through sight hole)
RH-1-006-012-Ci2R 1. Weld leg or effective throat 1. Verified I-S-PS42-40 undersized (1/4" fillet connecting item 5 to item 7) )
i i
i
_ . _ . - . - _ _ _ - - n. .,.
Revision: 1 Pasa 54 cf 6E 1 .
i ,
RESULTS REPORT l ISAP VII.b.3 ,
(Cont'd)
~
j Table 4 (Cont'd)
HANGER f/ .
PACKAGE i TRT"FINDINGS CPRT FINDINGS REMARKS 1 SI-1-090-006-C41K 1. Spherical bearing paint 1. Verified I-S-PS42-42 contamination
- 2. Spubber adapter plate bolts 2. Verified -
with less than full thread engagement. ,- ,
- 3. Component type /model no. does not 3. Verified match dwg. ,c ,1 L
O
>w.-. - , --
Revision: 1 Pege 55 of 62 RESULTS REPORT
~
ISAP VII.b.3 (Cont'd) inble 5 Comparison of Inspe,cti$n Results for PS7N Supports AREA: Room 77N, El 810'-6" Unit 1, Safeguards Bldg.
NO. OF SUPPORTS NO. OF SUPPORIS j CHARACTERISTIC INSPECTED WITH DEVIATIONS TRT CPRT TRT CPRT Item 1. Excessive Spherical 92 150 5 43 Bearing Clearance (approx)
Iten 2. Load Pin Locking 92 166 14 16***
Device Missing t
Item 3. Pipe Clamp Halves 40 138 9 45 Not Parallel Ites 4. Snubber Adapter Plate 19 35 *13 0 Bolts With Less Than Full Thread Engagement
, AREA: Unit 1 Ites 6. Locking Devices for 144 136 1
[ Threaded Fasteners r
' AREAt Cable Spread Room 133. El 807'-0" Unit 1, Auxiliary Bldg. I i
. NO. OF BOLTS NO. OF BOLTS
! CHARACTERISTIC INSPECTED WITH DEVIATIONS l
5.**
! Ites Hilti Kwik Bolt (ISAP VII.b.4 Results Report addresses Hilti bolt Does Not Neet- embedaant lengths for all populations except cable tray supports. Hilti bolt embedmont lengths for 4
Minimus Embedment l cable tray supports are addressed under the cable ;
j tray design adequacy verification program.) "
I
- Number of bolts (not supports) with less chan full thread engagement.
i I
Found by the TRT during inspections of electrical support baseplates. Refer to ISAP VII.b.4 Results Report for Hiltf. Bolt inappetion resul:s.
- Included are supporto with missing, broken and undersized locking device.s. ;
l
! i
w-
....-..4Y R0visica: 1
. Pego 56 cf 62 RESULTS REPORT ISAP VII b.3 (Cont'd)
Table 6
,CPRT De'viation Reports for PS7N Number Number of Character- of Deviation Number of istic Supports Reports Construc tion Deficiencies Trends Remarks Excessive 150 43 0 Trend spherical (approx) bearing clearance.
O, Load pin locking 166 16 1 N/A*
device missing.
Pipe clamp 138 46 0 None QA/QC-RT-halves not 10046
' parallel.
Snubber 35 0 0 None QA/QC-RT-adapter 10046
. plate '
bolts with
-ler.s than required engagement. -
- Adverse and unclassified trends have not been declared for characteristics with one or more construction deficiencies due to the extent of the recommended corrective action.
Revision 1 P ge 57 cf 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
- Table 6 (Cont'd)
Number Number of Character- of Deviation Number of istic Supports Reports Construction Deficiencies Trends Remarks Missing 144 140 1 N/A Generic DR 1 cking (Generic for includes device for 140 DRs) construction threaded deficiencies fasteners.
- for snubber lockwire.
Support ID O missing or incorrect 178 2 0 None i
E 6
O '
e h
l l
l
~
Revisicnt 1 Pcge 58 of 64
} RESULTS REPORT J
ISAP VII.b.3 (Cont'd)
Table 7 CPRT'Dev'istion- Reports for PS42 Character- Number Number of istic of Deviation Number of Supports Reports Construction Deficiencies Trends Remarks No locking 19 18 1 N/A*
devices for (Generic for threaded 18 DRs) ,
fasteners.
Minimum edge 35 2 O None distance on i
baseplate violated.
Baseplate hole 35 9 0 Trend QA/QC location dimen. PDR 075 out of written.
tolerance.
Spherical 22 % 0 Trend QA/QC bearing / PDR 076 washer , written.
gap excessive.
Spherical 22 15 ., O Trend
~*
bearing contamination.
Adverse and unclassified trends have not been declared for deviation types with one or more construction deficiencies due to the extent of the recommended corrective action. ,
i
R;vicions 1 P 32 59 of 62 7- , RESULTS REPORT
- ISAP VII.b.3 (Cont'd)
- Table 7
, (Cont'd)
Character- Number Number of istic of Deviation Number of Supports Reports Construction Deficiencies Trends Remarks Snubber adapter 11 0 0 None QA/QC-RT-plate 10046 insufficient thread engagement. ,
Insufficient 18 2 0 None thread engagement threaded rod Load pin 24 2 0 N/A* CD identi-locking device find for broken or PS7N missing. sup port .
Load Side of 18 7 0 None pipe clamp
- halres not parallel.
Pipe clearance 22 8 1 N/A*
l with support out of --
- tolerance.
l Tipe clamp 4 1 1 N/A*
locknut loose. (Included in generic CD)
I L
Snubber / strut 22 2 N/A*
O 1
misalignment. '
I 1
.--~;, ,y Rsvisiest 1 Page 60 of 62 RESULTS REPORT ISAP VII b.3 (Cont'd) .
Table 7 (Cont'd)
Character- Number Number of istic of Deviation Number of Supports Reports Construction Deficiencien Trends Remarks Snubber cold
- 11 0 0 None set dimension i does not astch drug.
- 11 0 0 None orientation does not match dtv3 l
Component 43 2 0 None type /model does not match drvg.
No identification 5 0 0 None for support materials, parts I and components on hardware or in documentation package. (e.g., '
on MIL) l ' Wald porosity 43 0 0 None r excessive
Weld undercut 43 0 0 None excessive.
O
- Not a deviation per QI-058, the only requirement is to record saubber cold set dimensions and to identify those snubbers rotated 180'.
.. . . . . . . . . ~ ...mW
. Revisient 1 Pcgo 61 of 62 RESULTS REPORT ISAP VII.b.3 (Cont'd)
Table 7 (Cont'd)
Character- Number Number of istic of Deviation Number of Supports Reports Construction Deficiencies Trends Remarks Weld length 43 0 0 None undersize Weld les or 43 3 0 . None effective throat undersize.
Weld ot drawing 43 0 0 None does not exist in field.
Welds added in
- 43 0 0 None field not on drws.
Excessive 43 1 0 None Design grinding Adequacy resulting in Request minimum . 170 thickness Oiolations (weld cleanup). .,
No QC inspector ' '5 1 0 None i
initials (no QC acceptance or
, buy-of f) en weld data card.
- Not a deviation per QI-058, the only requirement is to record extra weld.
. Revision: 1 Pcge 62 of 62 j l
1 l
RESULTS REPORT ISAP VII.b.3 (Cont'd)
Table 7
, (Cont'd) ,
Character- Number Number of istic of Deviation Number of Supports Reports Construction Daficiencies Trends Remarks Support ID 43 5 0 None missing or incorrect
- Configuration 43 7 0 None Does Not Match Drawing O
- Loose locknut 11 1 0 N/A on barrel of (Unclassified strut Deviation) s
- These deviation types were not explicitly identified by the TRT.
I