ML20151N909
| ML20151N909 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/23/1985 |
| From: | Barnes I, Ellershaw L, Hale C, Andrea Johnson, Will Smith, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20151N849 | List: |
| References | |
| 50-445-85-13, 50-446-85-09, 50-446-85-9, NUDOCS 8601030202 | |
| Download: ML20151N909 (45) | |
See also: IR 05000445/1985013
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APPENDIX E
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. COMANCHE PEAK RESPONSE; TEAM ACTIVITIES INSPECTION RE, PORT.
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O. S. NUCLEAR REGULATORY COMMISSION-
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REGION IV
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NRCJInspection Reports:
50-445/85-13
Permit: CPPR-126:
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50-446/85-09
CPPR-127
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Dockets': ~50-445.
Category:
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50-446'
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Applicanti Texas Utilities, Electric Company (TUEC)
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' Skyway Tower
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400 North Olive-Street
Lock Box 81'
Dallas, Texas
75201'
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Facility Name:
Comanche Peak Steam Electric Station (CPSES), Units 1 and 2
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-Inspection At:
Glen Rose, Texas
' Inspection Condu ed: September 1-30, 1985
Inspectors:
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L. E. Ellershaw, Reactor Inspector, Region IV
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CPSES. Group
.(paragraphs 1, 5.d, 5.g-5.1, 5.k-5.n, 5.t-5.v)
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W. F. Smith, Resident-. Reactor Inspector (RRI),
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Region IV CPSES Group
(paragraphs 1, 5.j)_
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C. J. Male, Reactor Inspector, Region IV CPSES
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(paragraphs 1, 2.a-2.b, 3, 4, 5.e, 5.f, 5.o-5.s)
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A. R.-Johnson, Reactor Inspector,' Region IV
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CPSES Group
(paragraphs
1,~ 2.c-2.e, 5.a-5.c, 5.v)
Consultants:
EG&G - R. Bonnenberg, L. Jones, A. Maughan, W. Richins,
R. VanderBeek
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Parameter - J. Birmingham, D. Brown, J. Gitison, K. Graham,
D. Jew, T. Young
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Reviewed By:
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I. Barnes, Group Leader, Region IV CPSES Group
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Approved:
T. F. Westerman, Chief, Region IV CPSES Group
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Inspection Summary
' Inspection Conducted:
September 1-30, 1985 (Report 50-445/85-13; 50-446/85-09)
Areas Inspected:
Nonroutine, unannounced inspection of applicant actions on
previous inspection findings, Comanche Peak Response Team (CPRT) procedures and
instructions, and CPRT issue - specific action plans (ISAPs). The inspection
involved 2339 inspector-hours onsite by 6 NRC inspectors and 11 consultants.
Results: Within the three areas, inspected, two violations (erroneous and'
missing conduit identification, paragraph 2.e; observation of an accepted
flange joint in a broken condition, paragraph 5.v); and three deviations (issue
of inspection verification packages with missing, incomplete and/or incorrect
documents, paragraphs 5.u and 5.v; failure of ERC inspectors to note conditions
which violated drawing requirements, paragraph 5.v; incorrect population
development for ISAP V.d, paragraph 5.m) were identified.
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DETAILS
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Persons Contacted
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'J. Arros, TERA Civil / Structural Issue Coordinator
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W. Bailey, ERC Supervisor, QA/QC Reinspection Engineering
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D.' W. Braswell, TUGC0 Engineering Superintendent
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C..I. Browne,-Project Manager, R. L. Cloud & Associ nes, Inc.
- R. E. Camp, Assistant Project General Manager, Unit 1 (Impell Corp.')
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- J. D. Christensen, ERC Deputy QA/QC Review Team Leader
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- J. Finneran, TUGC0 Lead Pipe Support Engineer
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- S. M. Franks, Special Projects and Technical Support Lead (Impell-Corp.)
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- J. B. George, TUGC0 Vice President, Plant General Manager
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- P. E. Halstead, TUGC0 Site QC Manager
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J. L.: Hansel, ERC QA/QC Review Team Leader
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'*C. R. Hooten, TUGC0 Project Supervisor, Civil / Structural Engineering
- J. _ C. Kuykendall, TUGC0 Manager, Nuclear Operations
H. A. Levin, CPRT Civil / Structural / Mechanical Review Team: Leader
- K.'L. Luken, Lead Startup Engineer (Westinghouse)
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- D. M. McAfee, TUGC0 QA Manager
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- J. T.~ Merritt, Jr. , TUGC0 Assistant Project General Manager -
' *S. P. Helancon, CPRT Issue Coordinator
- C. K. Moehlman, TUGC0 Project Mechanical Engineer
- C. E. Scott,.TUGC0 Startup Manager-
G. M. McGrath, TUGC0 Licensing / Compliance Supervisor
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W. J. Nixon, TUGC0 Results Engineering Supervisor
M. Obert, TRT Issue Coordinator
A. Patterson,'ERC Engineering Supervisor
C. Spinks, ERC Inspection Supervisor
T. G. Tyler, CPRT Program Director (Energex)
- W. I. Vogelsang,'TUGC0 Electrical Coordinator
/*C. H. Welch, TUGC0 QC Services Supervisor
- M. J. Wise, CPRT Testing Review Team Leader
- Denotes those persons who attended the exit interview.
The NRC inspectors also contacted other CPRT and applicant employees
during this inspection period.
2.
Applicant Actions on Previous Inspection Findings
a.
(0 pen) Unresolved Item (445/8511-U-01):
Procedure CPP-001,
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" Preparation of Project Procedures and Quality-Instructions," has
been revised (Revision 1) to provide additional guidance / direction in
the development of Quality Instructions (QIs). Unclear requirements
noted in NRC review of QI-008 (i.e., paragraphs 2.a, 4.d, 8.a, 8.b,
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8.c, 10, 11, 12.a.1, 12.9.2, 12.b.1, 12.b.2, 12.c.2, 12.d.2,
12.e.2.b) have been suitably resolved in Revision 2 of this document
which was issued on September 9, 1985.
Addstional Region IV review
with respect to QI-014 has been deferred until after completion of
the NRR evaluation of statistical populations.
This unresolved item
will remain open pending resolution of QI-014 and completion of
evaluation of QIs applicable to all engineering disciplines.
b.
(0 pen) Deviations (445/8511-D-01 and 445/8511-D-02):
These items
will remain open pending receipt and evaluation of the applicant's
response.
c.
(0 pen) Open Item (445/8511-0-14):
Additional inspection of this open
item, pertaining to observation of a damaged fire wrap blanket on
conduit C14B11217, has been performed.
No other instances of fire
wrap blanket damage were observed during this reporting period.
TUGC0 has initiated Nonconformance Report (NCR) E-85-101340S with
respect to the conduit C14B11217 fire wrap damage.
This item will' remain open pending further NRC inspection.
d.
(Closed) Open Item (445/8511-0-15):
Further review of this open
item, pertaining to observation of two sections of cable tray with
covers removed, showed that the cover removal had been previously
authorized by Item Removal Notice (IRN) E05257CB and NCR E85-100513.
e.
(Closed) Open Item (445/8511-0-33):
Additional NRC inspection of
this open item was performed in this reporting period. . Procedure
QI-QP-11.3-8, Revision 0, issue date July 7, 1978, " Identification
and Color-Coding Inspections," requires that the presence of ccnduit
identification be verified at both sides of all walls and slabs
through which conduit passes.
Procedure QI-QP-11.3-23.7, Revision 1,
issue date January 5, 1980, " Verify Conduit Identification," requires
also that conduit be identified as stated above and addresses the use
of identification. templates for embedded conduits which are flush
with the surface of walls and floors.
The NRC inspection showed
several instances where required sleeve conduit identification was
missing. 'One example was-also noted of an incomplete identification
marking.
ERC inspections have'also identified-instances where
conduit sleeves have not been included in the cable routing
schedules.
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The failure to sccomplish required conduit identification to provide
for control of cable routing is a a violation (445/8513-V-01).
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(Closed) Open Item (445/8511-0-34):
Further inspection of this open
item, pertaining to absence of identification tags on the outboard
side.of electrical-penetration assemblies, showed that tags were not
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required by the applicable specifications; i.e., Specification
Nos. 2323-ES-100 and 2323-ES-12/12A.
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(C-losed) Open Item (445/8511-0-35):
Further inspection of this open
item, pertaining to the presence of 1-inch openings in the bottom of
cable. tray section T130ECG41 and T130CCP80, showed that the opening
(i.e. , potentially representing a separation deficiency) in tray
T130ECG41 had been previously identified by the applic. ant and was
being corrected by Ccnstruction Operation Traveler AM85-309D-9400.
Additional examination of tray T130CCP80 showed that no other trays
or conduit were below the opening in the tray and therefore a
separation deficiency did not exist.
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3.
CPRT Program
Detailed NRC staff comments on the CPRT Program Plan, Revision 2, were
forwarded to the applicant by NRC letter of September 30, 1985.
has controlled procedures addressing their activities and TERA is
developing procedures for formal control of their activities (four are
issued).
Future Region IV inspection activities in these subject areas
are dependent upon issue of the umbrella QA program and the results of
NRC staff review.
4.
CPRT Procedures and Instructions
a.
Implementation of ERC Comanche Peak Procedures and Instructions
The NRC audits were conducted to determine if the ERC activities were
consistent with the requirements identified in the Comanche Peak
Procedures (CPPs).
(1) Audit of CPP-001,-002 and-004:
The NRC inspectors audited
CPRT's implementation of CPP-001, Revision 0, " Preparation
Review and Approval of Project Procedures and Instructions";
CPP-002, Revision 0, " Control of Correspondence and QA/QC Review
Team Documents"; and CPP-004, Revision 0, " Project Working
Files." No deviations from the commitments in CPP-002 and
CPP-004 were noted.
Several deviations from CPP-001,
Revision 0, were identified concerning the control of procedure
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revisions to CPP distribution manual holders and the retention
of' procedure review comments.
Two days after this NRC audit,
CPP-001, Revision 1, was issued resolving these deviations.
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(2)
Inspector Certification and Personnel Objectivity:
This is a
continuation of the NRC inspection of the implementation of
CPP-003, " Indoctrination, Training and Certification of
Personnel," that was initiated and documented in NRC Inspection
Report 50-445/85-11; 50-446/85-06.
Included in this inspection
are the results of reviews of the objectivity statements of all
CPRT personnel and the testing of ERC inspection personnel.
Personnel Objectivity:
One of the founding principles of the
CPRT program is that the program be conducted in such a manner
that its objectivity and credibility will not be questioned.
To
this end, the CPRT developed an objectivity questionnaire that
all personnel, except for clerical and certain administrative
personnel, were required to complete and sign. The NRC has
reviewed all currently completed questionnaires and compared
them with the individual resumes.
Errors were found in many of the completed questionnaires due to
individuals not being aware of contracts previous employers have
had with TUEC. These errors were satisfactorily corrected.
However, during this review two members of the Senior Review
Team (SRT) and two key members of the CPRT were noted to have
described previous contractual involvement with CPSES on their
objectivity questionnaires. Additional NRC review of this
matter will be made after receipt of the information requested
by the transmittal letter for NRC Inspection Report 50-445/85-11;
50-446/85-06.
Inspector Testing:
CPP-003 requires that all inspection,
examination, and test personnel take a written examination in
general QA principles and in their specific discipline, except
for those individuals coming directly from the Braidwood site.
The individuals were associated with ERC at that facility in a
similar corrective action program to CPSES and were consequently
permitted to transfer certifications obtained by examination at
that location. CPP-003 further requires a minimum passing grade
of 80%, failures may be retested only once and not in less than
three days.
Written tests have been given to inspection personnel beginning
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in December 1984, with the largest majority being given during
July and August 1985, when most of these personnel reported to
the site. The test questions are carefully controlled with
only limited and authorized access permitted.
All test
questions are maintained in a computer program.
Each type of
test (e.g. General QA, Mechanical Level II Specific, etc.) has a
pool of questions that is at least twice as large as the number
of questions that wculd appear on a given test.
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NRC review of two pools of test questions (General QA and
Mechanical Level II Specific) and a comparison of tests given at
different times verified that the practices described above were
being implemented.
Twenty-eight inspectors were. required to be retested.
Each of
these inspector's files was reviewed for test and retest dates,
and the questions on the tests and retests were compared for
duplication.
Six individuals were given retests in less than
3 days, five in December 1984, and one in January 1985. These
departures from the 3-day requirement for retest occurred, how-
ever, before the issuance of CPP-003, Revision 0, dated July 2,
1985, and appear to be isolated occurrences when retesting first
began.
No NRC deviations were identified.
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(3) Audit of CPPs-005,-006,-007 and-008: The following CPPs define
requirements for preparation of documents critical to the'
reinspection process: (1) CPP-005, " Establishing Populations";
(2) CPP-006, " Sample Selection"; (3) CPP-007, " Preparation of
Checklists and Data Base Reports"; and (4).CPP-008, " Preparation
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of Verification Packages."
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The NRC audit of these four CPPs was based on the selection of
nine completed verification packages from the ERC QA/QC Review
Team Records Center.
The Records Center also had files for the master population
list, population descriptions, population items list, and random
sample identification lists. The master population list was
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checked to assure each of the selected verification packages was
included.
In all cases the proper population description and
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population items list were on file for each verification package
audited. The applicable random sample identification lists
existed but these lists were formally checked out to the
engineers who were preparing verification packages. The
engineers were contacted and the lists produced. The NRC
inspector was informed that the lists would be returned to the
Records Center after preparation of all verification packages
and completion of the field reinspections.
The random sample identification list includes provisions for
documenting whether an accessibility check was made.
Justification is required if the accessibility check is not
made. The verification packages, according to CPP-007, should
contain inspection checklists and data base reports. All
packages in the sample contained both.
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A verification package'index,E required by CPP-008, was included
in each verification package. _ Supplementary in'spection-instruc-
tions, optional according to'CPP-008, were included in two of-
the nine verific& tion packages.
The,' adequacy of the documents
referenced in each verification package is a. subject considered
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in NRC audits of each ISAP No. VII.c population.
No NRC deviations were identified in the audit of these CPPs.
(4) Audit of CPPs-009 and-010: . The method chosen to audit the
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implementation of these CPF2 was to review the nine verification
packages referred to above to determine if CPP-009, " Performance
of Reinspections and Documentation Reviews," and CPP-010,
" Preparation of Deviation Reports," had been implemented.
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The inspection checklist in all nine verification packages was
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completed, reviewed,.and approved as required by CPP-009.
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'Of the verification packages reviewed, three included Deviation
Reports (DRs).. These were reviewed and approved by first and
second reviewers, in accordance with CPP-010.
No NRC deviations were identified,
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b.
Review and Implementation of TERA Onsite Procedures
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[TERAis'inthe,processofdevelopingandimplementing20. Design
LAdequacy Procedures.(DAPs) for use in controlling their Design
Adequacy Program onsite and offsite. At present, four DAPs have been
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-released and five have been released for interim use only.
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remaining 11 are in the final review process.
In addition, five
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civil structural and mechanical (CSM) procedures have been used as
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interim procedures until the DAPs are developed.
An'NRC inspection.was conducted to determine if the onsite TERA
effort in conducting the assigned ISAP tasks complied with the CPRT
Policies and Guidelines and, as applicable, DAPs or CSM procedures.
This inspection included four areas defined by the CPRT Policies and
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Guidelines: (1) " Policy on Testing and Inspection Personnel used in
Third Party Verification Activities", (2) " Developing Sampling Plans
and Random Samples for TRT Issues," (3) " Guide on Central and Working
Files," and (4) " Guide for Safety Significance Evaluations." .The
inspection also addressed, in part, the previously identified _open
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item (445/8511-0-37) which remains open until the site applicable
DAPs are issued, implemented,' and inspected.
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(1) Training Records:
This activity will be covered by DAP-15,
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' " Training and. Qualification," which has not been released.
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audit was. conducted using the TERA work instruction CSM-1.
A review of the TERA files showed that there was a Training and
' Qualification file on each onsite TERA employee, at present 12
individuals. Each file included a resume, an objectivity state-
ment, a training record, and a record of required reading. The
file for one individual was reviewed in detail and established
to contain all of the required information and approval.
No NRC deviations were identified.
(2) Sampling Methods:
No TERA DAP will be issued to cover sampling.
Therefore, the. TERA effort was inspected for compliance with the
CPhi Policies and Guidelines.
ISAP No. II.a, " Reinforcing Steel in the Reactor Cavity," was
chosen and the Issue Coordinator's file was inspected.
The ISAP
included tasks requiring sampling, review of pour cards, and
study of embeds.
The file concerning pour cards contained a population list, a
random number ordering of the population, a tabulation of the
results of the inspection, and a summary report on the pour
cards.
The file concerning embeds showed that the number of
embeds was small, so 100% were reviewed.
ISAP V.a, " Inspection for Certain Types of Skewad Welds in NF
Supports," was inspected for sampling methods.
A computer based list of hangers was used by TERA which identified
all hangers that contained skewed welds.
This list defined a
population of 359 hangers with skewed welds from which a
statistical random sample of 60 had been taken.
No NRC deviations were identified.
(3) Discrepancy Responsing:
Documentation and tracking of issues
and discrepancies is covered by DAP-2, which has been issued,
and by CPRT Policies and Guidelines on reportability of
deficiencies.
The file on Discrepancy / Issues Resolution reports (DIRs) was
audited and contained copies of three TERA originated DIRs dated
August 27, September 17, and September 25, 1985.
These had been
sent to the Generic Implication Coordinator for processing. One
of the three was considered by TERA to be potentially reportable
under 10 CFR 50.55(e) and the form, "Reportability Evaluations
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Check List," had been completed and attached to the DIR.
Disposition of the potentially reportable finding is and open
item (445/8513-0-01).
No NRC deviations were identified.
(4) Documentation System: TERA has developed a procedure, DAP-ll,
" Document Control." to control the documentation system. To
date, the procedure has not been released, so the audit compared
the TERA document control system to the CPRT Policies and
Guidelines.
The TERA onsite documentation system utilizes file numbers, file
indices, and file content logs and is being maintained in
accordance with the CPRT Policies and Guidelines.
The impact of
the procedure on work performed prior to its issue is currently
anopenitem;i.e.,(445/8511-0-37).
No NRC deviations were identified.
5.
CPRT ISAPs
a.
NCRs on Vendo- Installed AMP Terminal Lugs (ISAP No. I.a.5)
Status of CPRT Activity
In conjunction with the review of the AMP Incorporated Engineering
Evaluation Report EER-136, CPRT-Electrical is reviewing military
specification MIL-T-7928G which was utilized by AMP in the testing of
their terminal lugs. The CPRT-Electrical is currently assessing the
completeness of the central records files and finalizing actions on
this ISAP.
The results report has not yet been issued for this
activity.
Status of NRC Inspection Activity
The NRC inspector reviewed the process for the redispositioning of
NCRs E-84-01066 through E-84-01081 and the referenced NCR E-84-00972.
The NRC inspector identified that replacement of terminal lugs was
performed under Startup Work Authorization (SWA) No.19116 which was
verified to have been completed on May 3, 1984.
This SWA was worked
in conjunction with SWA No. 19249.
The NRC inspector examined 9 of the 16 6.9KV cubicles in which the
terminal lugs of concern are located.
The nine cubicles examined
contain approximately 80% of the terminal-lugs of concern. The NRC
inspector observed no terminal lugs bent in excess of 90 or twists
in excess of 45 .
No flaking, cracks, or other physical character-
istics were observed which could result in a loss of mechanical
strength. As a result of these observations, the NRC inspector found
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no reason to disagree with the conclusion of the disposition that
the terminals can be used "as is" and do not pose a service problem.
The NRC inspector is reviewing MIL-T-7928G concurrently with the
. review of the AMP Engineering Evaluation Report EER-136. The NRC
inspector has also made an initial review of the ERC central file for
ISAP No. I.a.5.
No NRC violations or deviations were identified,
b.
Flexible Conduit to Flexible Conduit Separation (ISAP No. I.b.1)
Status of CPRT Activity
The control board internal wiring analysis, (Revision 1) required by
the ISAP, was submitted by Gibbs & Hill (G&H) to TUGC0 on July 24,
1985, to demonstrate that existing circuits in main control panels
are protected, exclusive of existing SERVICAIR flexible conduit; and
to preclude the need for additional separation barriers. G&H is
currently modifying this analysis to address NRC comments.
The physical tests (short circuit and heat transfer) conducted on the
SERVICAIR flexible conduit to evaluate its adequacy as a barrier
under design bases conditions, have been partially completed.
Testing to establish worst case current condition in the heat
transfer test is in process as a result of further analysis by G&H.
Status of NRC Inspection Activity
The NRC inspector has reviewed ISAP No. I.b.1, Revision 3, and the
implementing CPRT QI; i.e., QI-004, Revision 4.
The NRC inspector is currently in the process of reviewing the G&H
control board internal wiring analysis, Revision 1.
No NRC violations or deviations were identified,
c.
Barrier Removal (ISAP No. I.b.4)
Status of CPRT Activity
NCRs were issued by TUGC0 as a result of TRT activities to assure
replacement of removed barrier material and rework of field
cabling which was in violation of the separation criteria.
Upon
completion of the dispositioning of the NCRs, CPRT-Electrical
requested ERC to inspect the rework. As a result of the inspection,
another cable separation violation was noted.
CPRT-Electrical
requested TUGC0 to issue a Design / Construction Significant
Deficiency Analysis Report for potential reportability
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under the provisions of 10 CFR 50.55(e).
The deficiency analysis
report was issued and addressed by TUGCO.
It was determined that the
noted deficiency was not reportable.
A revision was made to CPSES
Operations Maintenance Procedure INC-101 to address concerns of'
barrier material removal during maintenance.
Further activities on this issue will depend on the results of the
control board and vertical panel internal wiring separation analysis
associated with ISAP No. I.b.1.
The CPRT-Electrical is currently in the process of determining which
other separation issues will be addressed in the ISAP.
Status of the NRC Inspection' Activity
The NRC inspector has reviewed ISAP No. I.b.4, " Barrier Removal,"
Revision 3, dated June 26, 1985.
No CPRT quality instruction governs
this activity, other than the Senior Review Team (SRT) Draft Policies
and Guidelines which were approved for use by the SRT on February 28,
1985.
Assessment of the adequacy of this approach is an open item
(445/8513-0-02).
No NRC violations or deviations were identified.
d.
Electrical Conduit Supports (ISAP No. I.c)
Status of CPRT Activity'
A third party review is to be performed by TERA as part of ISAP
No. II.d, which deals with seismic design of control room ceiling
elements and will focus on the Unit 1 Damage Study Program for
greater than 2-inch conduit.
TERA is conducting a review of as-built
drawings for the selected 1 1/2-inch and 2-inch nonsafety-related
conduit runs which are being analyzed by G&H for seismic effects.
Some supports in seven conduit runs have been found to have stresses
greater than the specified allowables, when subjected to the G&H
seismic loads.
Two approaches are underway in an attempt to resolve the problem.
One approach deals with establishing a test program in an attempt to
obtain plastic deformation versus load data that will justify
increasing the allowable stress of certain support components.
In
conjunction, guidelines are being established for a walk-down evalua-
tion of predicted interactions with safety-related items resulting
from support failure and/or sway.
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Status of NRC Inspection Activity
The ISAP: and ~ related procedures have been reviewed for consistency
'
with FSAR requirements and NRC Technical Review Team (TRT) concerns
, '
pertaining to nonsafety-related conduit interactions with
4
safety-related items.
Procedures for selection of random samples
'
.were: reviewed for compliance with Appendix D of the CPRT Program
s
.
. Plan.
The engineering sample selection procedure is being reviewed.
>
~
' Review of the Damage Study for greater than 2-inch nonsafety-related
E,
conduit as'well as verification of the total population of 1.1/2-inch
' and 2-inch conduit has not been completed.
As-built drawings, which
,
will comprise a part of the final seismic analysis package, will be
reviewed along with the analysis.
No NRC violations or deviations were identified.
'
'e.
QC Inspector-Qualification (ISAP No..I.d.1)
,
.In.; response to the TRT reporting of a lack of supporting documentation
~in. inspector qualification files, ISAP No. I.d.1 was developed ~to
review and evaluate' all current inspector qualifications and also
historical electrical inspector qualifications.
The ISAP is structured
to be performed in three phases.
Phase One is a screening of' inspector
files by the ERC Certification Administrator (ERC-CA) for ASME
inspectors, and by TUGC0 Audit Group (TAG) for non-ASME inspectors.
Phase Two is an' evaluation of the qualifications by a Special Evalua-
tion Team (SET). -Phase Three is sampling reinspection of hardware
originally inspected by any inspector deemed to have insufficient
paper _ qualifications.
Status of CPRT Activity
Phase One is complete.
TAG and the ERC-CA have completed screening
of inspector files and transmitted the results to the SET.
This
screening documented discrepancies / deficiencies of various importance
j
from clerical errors to lack of a high school diploma.
Evaluation of
'
the effect'of these discrepancies / deficiencies is the role of.the SET
in Phase Two.
~
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SET has completed Phase Two review of all current non-ASME inspector
'
and historical electrical inspectors.
Review of ASME related
inspectors is approximately two thirds complete.
In performing its
review, the SET obtained additional clarification or backup documenta-
tion from TUGCO.
Phase Two status of current non-ASME and historical
i
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electrical. inspectors had not'been-issued as of the end of this
~
finspection period. .To date, six inspectors have been identified
.
4
for-Phase Three.
The sample reinspections for these individuals have
been completed.and results reports for each are in preparation.
- Status of NRC Inspection Activity
)For Phase One, the NRC inspector compared 12 screening reports with
-
.
the certification files. .This comparison found the reports to be
.
. accurate'and~ complete with the exception that non-ASME certifications
held by ASME inspectors had not been reviewed.
This exception has
been discussed with the issue coordinator and is an open item
.(445/8513-0-03).
.
For Phase'Two, the1NRC inspector reviewed five inspector qualification
files and compared them to evaluations by the SET.
In general, the
compIarisons agreed with the SET evaluations.
One exception was noted
with respect to an inspector's education level being insufficient as
documented; i.e., record of passing General Equivalency Diploma test
scores without copy of actual diploma.
This is an open item
(445/8513-0-04).
For Phase Three, the NRC inspector witnessed 24 of approximately 240
Phase Three'reinspections.
These inspections are controlled by
QI-005, " Procedure for Evaluation of Inspector Performance." This
procedure was reviewed by the'NRC inspector.
Comments on the procedure
were directed to the Issue Coordinator and were resolved by ERC memo
QA/QC-RT-483 or included in a subsequent revision.
,
The 24.w'itnessed ERC'reinspections showed ERC noting deficiencies and
' documenting them on the inspection' record.
The deficiencies were
also cocumented by an NCR fe cesolution.
No additional deviations
were noted by the NRC.instec'. r during these inspections.
Independent
reinspections of the LU 4ct. .ity is planned to be performed during a
subsequent inspectio.
The NRC inspector noted that deficiencies attributable to the original
,
inspector could potentially be missed in items that had been changed
by NCR rework.
This is an open item (445/8513-0-05).
No NRC violations or deviations were identified.
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Guidelines for Administration of QC Inspector Tests (ISAP No. I.d.2)
Status of CPRT Activity
Review and comment on Procedures CP-QP-2.1, " Training of Inspection
Personnel," and CP-QP-2.3, " Documentation with QA/QC Personnel
.
Qualification File," performed by the SET is complete. The applicant
has issued CP-QP-2.1, Revision 19, which addresses;the comments of
SET.
Review by SET of Revision 19 is not. complete.
4
Status of NRC Inspection Activity
The NRC inspectors have. reviewed Procedure CP-QP-2.1 for incorporation
of the TRT comments._ This review found all TRT comments addressed
-
except for the lack of a defined vehicle for familiarization of QC
-
. inspectors with changes in inspection procedures.
This is an open
item (445/8513-0-06 ).
,
4
No NRC violations or deviations were identified.
. -
- g.
Reinforcing Steel in the Reactor Cavity (ISAP No. II.a)
,
,
Status of CPRT Activity
TERA personnel informed the NRC inspector that the actions committed
to by ISAP No. II.a are complete with'the exception of a final
Everification of the completenesslof the pour card population. The-
.
,
final results report has been prepared and is currently being reviewed-
internally.by TERA.
,
Status of NRC Inspection Activity
Review of G&H analysis of the as-built condition of the Unit i
reactor cavity is complete. An evaluation of other plan items is
underway.pending the issuance of the final results report.
No NRC violations or deviations were identified.
'
~ h.
Seismic Design of Control Room Ceiling Elements (ISAP II_.d)
Status of CPRT Activity
-The TRT review of the seismic design of the ceiling elements installed
in the control room wAs conducted to verify design in accordance with
Regulatory Guide 1.29, " Seismic Design Classification," and FSAR
Section 3.78.2.8.
These documents require that seismic Category II
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16
and nonseismic items be designed in such a way that their failure
will not adversely affect the function of safety-related components
or cause injury to operators.
For the nonseismic items (other than the sloping suspended drywall
ceiling), and for nonsafety related conduits whose diameter is 2
inches or less, the TRT could find no evidence that the possible
effects of a failure of these items had been considered.
In addition,
the TRT determined that calculations for seismic Category II components
(e.g., lighting fixtures) and the calculations for the sloping
suspended drywall ceiling did not adequately reflect the rotational
interaction with the nonseismic items, nor were the fundamental
frequencies of the supported masses determined to assess the influence
that seismic response spectrum at the control room ceiling elevation
would have on the seismic response of the ceiling elements.
The applicant has evaluated the potential ir.teractions and determined
that the installation of seismic restraints to resist horizontal
motion would be required.
It was also decided to remove the sloping
suspended drywall along with its supports and replace. it with a
seismically qualified sloped ceiling.
Status of NRC Inspection Activity
During this inspection, ongoing measurements being taken of control
room ceiling anchorages to concrete were observed. A review of
drawings showing the proposed modifications was also conducted.
This item will be further reviewed during subsequent inspections.
No NRC violations or deviations were identified.
i.
Rebar in the Fuel Handling Building (ISAP No. II.e)
Status of CPRT Activity
TERA personnel informed the NRC inspector that the actions committed
to by ISAP II.e are complete.
The final results report has been
prepared and is currently b'ing reviewed internally by TERA.
e
Status of NRC Inspection Activity
Review of G&H calculai. ions is complete.
An evaluation of additional
plan items is being performed including:
(1) a review of the adequacy
of procedural controls governing rebar cutting, (2) a review of all
,
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17
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cases'for Units 1~and 2 where rebar cutting was requested for installa-
tion of Hilti bolts, (3) a review of the determination of the possibil-
ity of additional unauthorized rebar cutting, and (4) a review of
Hilti bolt installation work as performed by the construction crew
that installed the subject Hilti bolts.
No NRC violations or deviations were identified.
j
Hot Functional Testing (HFT) Data Packages (ISAP No. III.a.1)
.
In order to maintain a correlation between areas inspected and the
applicable sections of the ISAP, this inspection report will address
each area using the ISAP paragraph number assigned by the applicant.
During the previous inspection period of August 1-31, 1985, (See
Appendix E of Inspection Report 50-445/85-11), paragraphs 4.1.1
through 4.1.6 were followup inspected, and paragraph 4.1.7 was
- -
started but not completed as indicated below:
4.1.7
There were seven HFT preoperational test data packages that
were not previously reviewed by the TRT.
In this section
of the ISAP, the applicant committed to reevaluate these
~
packages in accordance with the guidelines established in
Attachment 1 of the ISAP. The NRC followup inspector
reviewed the documentation associated with the reevaluation
of each data package to determine that:
The applicant's reevaluation appeared to follow the
guidelines established by Attachment 1 of the Plan,
The documented questions raised by the reevaluation
were properly dispositioned and approved by the Joint
Test Group (JTG), and
The disposition approved by the JTG was not contrary
to regulatory requirements.
The following test data package reevaluations were followup
inspected:
(a) 1CP-PT-49-02, 1CP-PT-49-05, and 1CP-PT-55-10 were inspected
during the last reporting period.
The results are reported
in NRC Inspection Report 50-445/85-11, Appendix E.
(b) ICP-PT-57-09, " Check Valves and Hot Functional Safety
Injection." The reevaluation was documented on Test
Deficiency Report (TDR) 3987.
There were no comments made
by the applicant's reviewers, however, the NRC followup
inspector noted that several check valves did not pass the
_.
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18
acceptance criteria for leakage, and as such were documented
on six TDRs. The TDRs were closed on the basis that after
repair the retesting would be deferred to the post fueling
startup test program. This deferral was necessary at the
time, because the plant conditions (normal operating
temperature and pressure) required for testing were not
scheduled to be achievable until then. The NRC inspector
followed up to ensure all of the deferred valve retests
were clearly identified, so that documentation would show
that all of the objectives of ICP-PT-57-09 would be met
prior to initial criticality. The NRC inspector found that
all of the check valves except 1S1-8815 were retested
satisfactorily during December 1984, when the plant was
heated up to normal operating pressure and temperature for
thermal expansion retesting.
1S1-8815 was deleted from the
list of deferred valves on the basis that it was not a
reactor coolant system boundary as defined in Technical
Specification (TS) Table 3.4-1.
After this decision was
questioned by the NRC inspector, the applicant's representa-
tives produced a draft change to the Deferred Preoperational
Test Report showing the valve would be retested when
required plant conditions became available, but prior to
initial criticality (Mode 2). The NRC inspector was told
by the applicant's representative that this change would
have been made whether or not the original decision to
delete the valve was questioned by the NRC inspector,
because on April 9, 1985, TUEC had informed the NRC in a
letter (TXX-4431) that 1S1-8815 and four others would be
incorporated into TS Table 3.4-1.
During earlier reviews
of the TS, the NRC had requested TUEC to incorporate
ISI-8815 and 1-8900A, B, C and D into Table 3.4-1 because
they should be considered reactor coolant system boundary
valves whose operability should be verified through
surveillance testing.
1-8900A, B, C and D were already
tested during the preoperational test program in accordance
with ICP-PT-57-09.
For tracking and followup purposes, the
satisfactory retesting of 1S1-8815 is an open item
(445/8513-0-07).
During preoperational testing, TDR 1337 identified excessive
leakage during the seat leak test of 1-8900A, B, C and D.
Section 2.1 of ICP-PT-57-09 specified a maximum leak rate
of 45 milliliters per hour (ml/hr) for each valve. The
four valves were tested in parallel, which yielded a
combined leak rate of 84 ml/hr. The TDR was dispositioned
" acceptable" with a justification stating that the combined
leak rate could be as high as 180 ml/hr; i.e., 4 times 45.
When the NRC inspector questioned this rationale, the
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ml/hr/;is an acceptab1'e leak rate.
Thel surveillance-leak
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test acceptance criteria for;these valves.is 1 gallon per
minute.
The'preoperational test acceptance criteria.are
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, the valves have significant leakage.
The JTG considered'a
designed toLprecipitate;a. technical' evaluation if any of;
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leak rate of.84fml/hr from all four. valves acceptable and -
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F not indicative of a val've~ seating problem requiring repair.
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-justification:accordingly is Open Item (445/8513-0-08);
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(c) ICP-PT658-02,^" Residual Heat Removal at' Hot Functional:"
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- The' reevaluation was' documented in TDR 3990.
The NRC
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.(d) 1CP-PT-74-02, "Incore TC and RTD Cross Calitsration." . The
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reevaluation was documented in TDR 3876.
The NRC-inspectors
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found no violations or deviations,
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The reevalua-
(e) - 1CP-PT-91-01, " Loose . Parts Monitoring System."
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-tion was~ documented in TDR-3988.
The NRC, inspector.found
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no violations ~or. deviations.
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The applicant committed to_ reevaluate 20 completed test
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data packages?not associated with HFT. 0f.the 20 packages
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sampled,~13 had been reviewed previously by.the'NRC' operations
'
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resident inspectors. :The results of those. reviews'are documented-
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in variousiroutine inspecti.on reports.
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resident' inspectors', have been reevaluated in accordance with
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(a) .1CP-PT-04-01, " Station-Service' Water," documented in
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TDR 3918 as-satisfactorily reevaluated.
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7(b) ICP-PT-29-02, RT1, " Diesel Generator Control Circuit
Functional and Start Test,' Retest 1," documented in
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TDR 3902 as satisfactorily reevaluated.
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(c) 1CP-PT-29-04, " Diesel Generator Sequencing and Operational
~ Stability Test," documented in TDR 4066 as satisfactorily
-
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(d) 1CP-PT-37-01, RT1, " Auxiliary Feedwater System (Motor
Driven Pumps),-Retest 1,"
documented in TDR 3929 as
'
satisfactorily reevaluated.
(e) 1CP-PT-48-01, " Containment Spray' System," documented in
TDR 3930 as satisfactorily reevaluated.
(f) ICP.-PT-57-01, RT2, " Safety Injection Pump Performance,
-
Retest 2," documented in TDR 3920 as satisfactorily
,
reevaluated.
'
(g) 1CP-PT-57-02, " Centrifugal Charging Pemp Test," documented
in TDR 3921 as satisfactorily reevaluated.
', '
(h)' 1CP-PT-57-05, " Safety. Injection Accumulators Test,"
documented in TDR 3938 as satisfactorily reevaluated.
.
(i) 1CP-PT-57-06, "RHR ECCS Performance," documented in
-
TDR 3939 as satisfactorily reevaluated.
,
(j) ICP-PT-57-08, " Integrated SI-Emergency Power," documented
in TDR 3940 as satisfactorily reevaluated.
-
(k) 1CP-PT-64-02, RT2, " Reactor Protection Systems, Retest 1,"
documented in TDR 3931 as satisfactorily reevaluated.
(1) -1CP-PT-64-07, " Solid State Safeguards Sequence System,"
documented in TDR 3906 as satisfactorily reevaluated.
(m) 1CP-PT-64-10, " Safeguards Actuation Relay Test," documented
in TDR 3941 as satisfactorily reevaluated.
The NRC followup
inspector noted that there was_an unresolved inspection
report item that was identified during the prior review
conducted by the NRC resident inspector in February 1985.
'
The item (8502-10) was generated by NRC Inspection Report
50-445/85-02 dated September. 11, 1985.
The issue was the
apparent incomplete incorporation of a complex change to
the procedure using Test Procedure Deviation (TPD) No
1.
-
One of the changes was omitted from the:TPD, but the
justification was left in. Withou0 the' change being fully
-
implemented, the NRC resident inspector was unable to
determine if the test was satisfacurily completed.
In an
effort to determine why this problem did not appear in the
reevaluation summary report, the NRC followup inspector
interviewed three of the applicant's reevaluators and found
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ithat this problem had been previously identified during the
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- reevaluation and was resolved.
The applicant's representa-
tive indicated that-a documented resolution to Item 8502-10
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was forthcoming 'o the resident inspector. Since this-
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problem is.already being tracked..it is'not necessary to
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identify it further.
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Th'e remaining seven-completed preoperational test data packages
f
reevaluated in accordance with Attachment 1 of the ISAP were not
previously reviewed by the NRC resident inspectors. Therefore,
-
.the followup inspection was conducted on the following data
packages using the same inspection attributes listed in 4.1.7
above:
\\.
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(a)
1CP-PT-01-03, "125 Volt DC System," documented in TDR 3927
as satisfactory reevaluated.
i
(b)
ICP-PT-02-01, "118 Volt AC Class 1E Inverters," documented
in TDR 3917 as satisfactorily reevaluated.
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(c)
ICP-PT-02-10, RT1, "480 Volt Class 1E Switchgear and Motor
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Control' Centers," documented in TDR 3928 as satisfactorily
reevaluated.
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(d)
ICP-PT-02-17
"6.9 KV and 480 Switchgear Undervoltage
'
Functional Test," documented in TDR 3937 as satisfactorily
1
reevaluated.
,
(e) XCP-PT-07-01, " Control Room Heating and Ventilation System,"
4
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documented in TDR 3919 as satisfactorily reevaluated.
L
(f)
ICP-PT-58-01, " Residual Heat Removal System," documented in
,
TDR 3904 as satisfactorily reevaluated.
(g) ICP-PT-49-01, " Letdown, Charging and Sealwater System",
>s
documented in TDR 3905 as satisfactorily reevaluated.
'
No NRC violations or deviations were identified.
k.
Inspection for Certain Types of Skewed Welds in NF Supports
.
(ISAP No. V.a)
Status of CPRT Activity
,
>
The reinspection of 60 field fabricated NF supports containing 99
type 2 skewed welds has been completed.
The inspection attribute
i
which was the technical focus of'this issue dealt with geometric and
i
dimensional configurations in locations where a typical fillet weld
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22
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gage measurement was not possible. The welds were reinspected by ERC
inspectors using QI-006. The reinspection identified 14 type 2
skewed welds which deviated from drawing requirements; i.e., an
undersize condition existed.
Subsequent evaluation showed that one
of the conditions was valid, however, the applicable drawing also
showed that the weld was not required for structural integrity.
Another condition was identified as being a vendor fabricated
weldment, thus falling outside of the scope of this ISAP.
However,
the condition is valid and a NCR was initiated and evaluated
separately. That particular evaluation was conducted by identifying
all supports with type 2 skewed welds supplied by that vendor. A
total of 32 supports were identified and a random sample of 7 was
selected for reinspection. -The random sample of 7 supports contained
13 type 2 skewed welds, 12 of which were accessible. No further
undersized welds were identified. The remaining 12 conditions were
evaluated as being valid and NCRs were initiated.
Status of NRC Inspection Activity
The NRC inspector verified that Brown & Root weld inspection
Procedure Nos. CP-QAP-12.1, QI-QAP-11.1-26, QI-QAP-11.1-28 had been
revised to properly address type 2 skewed welds, including their
inspection and subsequent documentation. The NRC inspector
witnessed, in the previous reporting period, reinspections of seven
NF supports; each containing one type 2 skewed weld.
ERC inspectors
identified one undersize weld, which was documented in a NCR. The
results of independent NRC reinspections of type 2 skewed welds are
documented in Appendix F of this inspection report.
No NRC violations or deviations were identified.
1.
Design Consideration for PiJing Systems Between Seismic Category I
and Non-seismic Category I
3uildings (ISAP No. V.c)
Status of CPRT Activity
A list identifying all Units 1, 2 and common piping with a
seismic /nonseismic interface has been completed by Comanche Peak
Project Engineering. The results report has been prepared and is in
the review stage.
Status of NRC Inspection Activity
The review of the list identifying all Units 1, 2, and common piping
with seismic /nonseismic interface has been completed in order to
verify the validity of the list and to assure that no pipe lines have
_.
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23
been omitted. The NRC review of the information relative to
the auxiliary steam line and the recommendations to project Piping
-
and Supports Program and/or Design Adequacy Program will not begin
until issuance of the final results report.
No NRC violations or deviations were identified,
m.
Plugwelds (ISAP'No. V.d.)
Status of CPRT Activity
' Reinspection has been completed of (1) component supports and
baseplates, and (2) cable tray hangers, for presence of unauthorized
or undocumented plug welds. Generic design change authorization (DCA)
DCA 5347 permits plug welds in cable tray supports.
ISAP No. V.d
commits to third party review of the adequacy of this DCA.
The
implementation of this review will be inspected by Region IV in a
subsequent report period.
Plug welds in ASME,Section III component
supports are not permitted except by specific engineering authorization.
The reinspection was performed on the following four random samples:
(1) Random sample No. 1 consisted of 64 component supports and
baseplates representing Unit 1 and common.
(2)
Random sample No. 2 consisted of 61 component supports and
baseplates representing Unit 2.
-(3)
Random sample No. 3 consisted of 60 cable tray hangers
representing Unit 1.
(4) Random sample No. 4 consisted of 61 cable tray hangers
representing Unit 2.
The reinspection resulted in the identification of 23 plug welds in
14 cable tray hangers and no plug welds in component supports and
baseplates.
Documentation for all cable tray hangers containing plug welds was
reviewed. The results of this review showed that the plug welds in
13 of the cable tray hangers were authorized and~ documented, while
the documentation for cable tray FSE-00159-4182 was found to be
incomplete. These documentation packages are now undergoing a third
party review by TERA.
Status of NRC Inspection Activity
The NRC inspector witnessed approximately 15% of the 246 reinspections
conducted by ERC; i.e.,15 pipe supprts and baseplates and 23 cable
tray hangers.
Five plug welds in' cable tray hangers were identified
-
.
24
.:-
during the NRC witnessed reinspections.
A review of the respective
documentation packages revealed that these welds were properly
authorized and documented.
In addition, the NRC inspector independently inspected three component
supports and baseplates, and three cable tray hangers, none of which
were within the CPRT random samples.
Four plug welds were found and
verified on two baseplates which were part of a common component
support.
The documentation package was reviewed and it revealed that
the plug welds were authorized and documented.
During review of ISAP No. V.d, the NRC inspector established that the
two random samples of component supports and baseplates were required
to be exclusively ASME Code,Section III supports and baseplates.
However, subsequent to the completion of the CPRT reinspection
effort, a review of the two random samples revealed that just 39 out
of 64 and 35 out of 61, respectively, were actually ASME Code,
Section III supports and baseplates.
The failure to meet the commitments of ISAP No. V.d is a deviation
(445/8513-D-01).
n.
Installation of Main Steam Pipes (ISAP No. V.e)
Status of CPRT Activity
The specific engineering investigation of the main steam line installa-
tion is 100% complete and is undergoing review.
The report describing
the analytical evaluation of stresses and ::upport load changes has
been issued by R. L. Cloud & Associates (RLCA), and has been reviewed
by TERA.
Review and revision of procedures for pipe erection and
placement of temporary and permanent supports as well as engineering
significance of these procedures is also complete.
The TERA draft
results report is currently being reviewed.
Status of NRC Inspection Activity
About 75% of the RLCA stress report has been reviewed for adequacy
with respect to the methods of analysis.
The adequacy of the remainder
of the report cannot be assessed until the supporting computer
output, calculations, and piping models, received onsite September
26, 1985, are reviewed.
The assessment of NCRs and Piping Deviation
Request Forms that RLCA identified as being similar to the main steam
line installation problem has been completed.
All other items will
be reviewed when the final results report is issued.
No NRC violations or deviations were identified.
4
4-
O'
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25
'
-
o.
Document Control (ISAP No. VII.a.3)
Problems in"the document control area have been identified both by
the applicant and NRC Region IV.
This ISAP requires verification
that, latest design informat:on has been physically incorporated
and/or. considered for.other activities, as appropriate.
-Status of CPRT Activity
Verification of the above is being accomplished by ISAP Nos. III.d,
" Pre-Operational Testing," and VII.c, "Self-Initiated
Reinspection / Documentation Review Program." The issue coordinator is
>
awaiting input from these.
Status of NRC Inspection Activity
ISAP Nos. III.d. and VII.c. activities are currently being inspected
by NRC personnel.
NRC inspection of this ISAP will be initiated when
it achieves an active status.
p.
Audit Program and Auditor Qualification (ISAP No. VII.a.4.)
Status of CPRT Activity
The ERC issue coordinator reviewed the development of the TUEC Audit
Program dating back to 1978.
Support verification activities for
this time frame were also reviewed.
The results report is in prepara-
tion.
Status of NRC Inspection Activity
NRC inspection of this activity will commence upon issue of the
results report.
q.
Management Assessment (ISAP No. VII.a.5)
Status of CPRT Activity
ERC action has been deferred until results of an INP0 audit made in
July and August 1985 can be utilized by ERC to assess what improvements
should be made to the management assessment program.
Status of NRC Inspection Activity
NRC inspection will be initiated when this ISAP achieves an active
status.
1
.
.
26
r.
Fuel Pool Liner Documentation (ISAP No. VII.a.8)
Status of CPRT Activity
ERC has developed a check list for the review of fuel pool liner
documentation.
Sixty traveler packages have received an initial
review which identified a need to revise the check list to provide a
more indepth check of backup information on welders / welding.
A total
of 300 traveler packages will be selected from the sample population
for ERC review.
Status of NRC Inspection Activity
NRC inspection of this ISAP will be initiated during a subsequent
reporting period.
s.
Onsite Fabrication (ISAP No. VII.b.1)
Status of CPRT Activity
ERC has revised CPP-019, " Cluster Sampling for Issue Specific Action
Plan VII.b.1," to change the sampling method.
The ISAP is with the
SRT for review of the proposed revision.
Review of records or
inspections are being delayed until the SRT review is complete.
The
issue coordinator expects further activity in October.
Status of NRC Inspection Activity
NRC inspection will be initiated when CPRT inspection and review
activities achieve an active status.
t.
Valve Disassembly (ISAP No. VII.b.2)
Status of CPRT Activity
Reinspection of 92 valves from the combined random and engineering
sample of 101 has been completed.' Four DRs were initiated with
respect to installed bonnets having identification numbers which are
different from the identification numbers on their respective QA/QC
documents.
Two of the deviations were dispositioned as being nonsafety
significant by the Safety Significance Evaluation Group (SSEG) based
on a review of the applicable quality records, which revealed that
while the identification numbers differed the bonnets were of the
same type specified for these valves.
1
-~,
- - ,
--n--
c
ry.g
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L
y
,
,
27
.
,
'I
An SSEG effort to find quality records for the remaining two
'
incorrectly identified bonnets was not successful.
The bonnets have,
however, been identified by the SSEG as being of nuclear quality as
indicated by the NP marking observed on them.
ITT Grinnell, the
valve manufacturer, has stated that any nuclear grade valves shipped
t'o the CPSES site have a pressure rating of at least 255 psig.
,
' Maximum line operating and design pressures listed in the line
' designation tables for one of the two. valves in question are less
. than the 255 psig pressure rating and the deviation has been disposi-
tioned as nonsafety significant.
However, the design pressure for
the chemical volume control line associated with the remaining valve
is listed as 300 psig.
The safety significance of this deviation is
being evaluated.
Status of NRC Inspection Activity
.
The associated QI-018 has been reviewed for compliance with the CPRT
Program. Plan and referenced documents.
The ERC sample selection plan
has been reviewed for compliance with the CPRT program plan and has
been verified as having been implemented 'accordingly.
Seven reinspec-
'
'
tions have been witnessed and checklists for the 92 reinspected
valves have been reviewed for proper disposition of descrepancies or
deviations.
All DRs have been reviewed for concurrence and processing
in accordance with the CPRT program plan and ERC written procedures.
-
Safety Significant Evaluation Nos I-M-VALV-44-001 and I-M-VALV-56-001
have been reviewed for concurrence and procedure compliance, iThe
remaining two safety significance evaluations are currently under
review.
No NRC violations or deviations were identified.
u.
Pipe Support Inspections (ISAP No. VII.b.3)
Status of CPRf Activity
The reinspections being performed under ISAP No. VII.b.3 deal with
pipe supports located in' Room 77N and the 42' pipe supports previously
inspected by the TRT.
All other pipe support populations and their
samples are being reinspected under ISAP No. VII.c, " Construction
'
_
Reinspection / Documentation Review Plan."
"
.
One hundred and seventy-eight pipe supports in Room 77N have been
reinspected, resulting in the identification of 229 deviations; 36 of
N
which have been established as valid while the remainder are currently
being evaluated for validity and safety significance by ERC engineering.
ERC has not yet issued a QI with respect to reinspection of the TRT
,
42 pipe supports.
'
F
-
-
-
-
.
.
28
,
Status of NRC Inspection Activity
The NRC inspector has reviewed 01-037 and witnessed the following
seven reinspections to assure compliance with inspection procedure
requirements:
Verification Package No.
Unit No
I-S-PS7N-015
1
I-S-PS7N-027
1
I-S-PS7N-028
1
I-S-PS7N-064
1
I-S-PS7N-144
1
I-S-PS7N-170
1
I-S-PS7N-187
1
During the above reinspections, ERC identified the followint,
conditions to the NRC inspector as subject to evaluation as 70tential
deviations:
I-S-PS7N-015: Broken cotter pin.
.
I-S-PS7N-027:
pipe clamp parallelism was out of tolerance,
.
spherical bearing gap discrepancy, and
clamp bolts did not have locking devices.
~
I-S-PS7N-028:
(a) Pipe clamp parallelism was out of tolerance,
and
(b) locking devices for bolting missing.
I-S-PS7N-064:
Clamp bolts did not have locking devices.
I-S-PS7N-144:
Pipe clamp parallelism was ou' of tolerance,
excessive spherical bearing gap, and
clamp bolts did not have locking devices.
I-S-PS7N-170:
(a) Clamp bolts did not have locking devices, and
(b)cotterpinwasundersize.
Dispositions of the above findings are open items (445/8513-0-09
through 445/8513-0-14).
During review of inspection checklists, the NRC inspectors identified
a deviation from commitment (445/8513-D-02).
CPP-007, Revision 1,
requires the QA/QC Lead Discipline engineer to review the inspection
checklist package for accuracy, completeness, and conformance with
--
_ _ _ . _ . . .
_ . . .
. _ _ . _ -
- - _ _ - .
.___ __. _ _ - _ . . . - _ _ _ _ _ . - _
..
.
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,
h
29
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7
procedure.; Package Not I-S-PS7N-187, which had been approved by the
rq
_
QA/QC Lead Discipline Engineer, did not contain the required number
- %
,
of inspection forms for snubber brackets ~and also contained a form-
'
-
for pipe clamp inspections although a pipe clamp did not exist.
'
<
'
~
L
lv.
Construction Reinspection / Documentation Review Plan (ISAP No. VII.c)
o+
(1) Large Bore Piping Configuration
'
.
" Status of CPRT Activ'ity _
i
-
<
.
.
~
.
Reinspection of the 60 random sample large bore piping runs has
-
.
.
,
_
been completed and has resulted in the issuance of 16 DRs.
The
deviations ^ generally involve out-of-tolerance linear measurement
and location variations, insufficient pipe clearance between
'
t
'
'
. sleeves and ' adjacent equipment, and valve identification and
3
,
.
,
flow direction not being verifiable.
Evaluation of four DRs has
,
been completed, with the resultant conclusion that they were
,
nonsafety-related.
Reinspection of an dditional 39 items,
'
.
.
required to complete the engineering s
,,le,
is being initiated.
'
,
Status of NRC Inspection Activity
Inspection of this activity included review of QI-025, Revision 1,
~
,
,
.
!
dated' August 16, 1985, and examination of the sampling process
used for selection of large bore piping runs for reinspection.
1
Three ERC reinspections were witnessed by the NRC inspector;
}
i.e., Verification Package Nos. I-M-LBC0-050, I-M-LBC0-067, and
-
,
I-M-LBC0-074.
'
During the above reinspections, LiiC identified the following
conditions to the NRC inspector as subject to evaluation as
'
potential deviations:
'I-M-LBC0-050:
Expansion joint number not documented and a
flange at end of the pipe run was not installed. Note:
Subsequent
to the reinspection, the verification package was removed from
the sample due to construction being incomplete.
I-M-LBCO-067: Flanged section approximately 4 feet long was not
installed.- A decision had not been made on this verification
package'as of the end of the inspection period with respect to
retention in the sample.
Disposition of this finding is an open item (446/8509-0-01).
,
a
l
,
f'_..~,-,..-.__.l.___.~_._..~____.
.. _ .-. _ _ ._ ..- _ _ , - , .__ __ _ _.,..__,_
--
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,
,
- ,
l
- t '.
l'
30
,
.
~
,
,
,
~
.
a
l
- ( g
'
-It was ascertained, as a result of these inspection findings,
.
that accessibility walkdowns conducted on large bore piping runs
,
,
' '
prior to reinspection do not address a check for completion of
'
construction.
This.isanopenitem(446/8509-0-02).
.
.No NRC violations or deviations were identified.
!
'
- (2). Small Bore Piping Configuration
Status of CpRT Activity
Reinspection of the 60 random sample small bore piping runs has
been completed and has resulted in the issuance of 3 DRs.
The
,
identified deviations are related to out-of-tolerance linear
'
'
piping dimensions and inadequate clearance between the pipe and
adjacent piping. The evaluations'to assess safety significance
have not yet been performed. Reinspection of an additional 35
items required to complete the random engineering sample of
small bore piping runs has not been initiated.
l
l
Status of NRC Inspection Activity
Inspection of this activity included review of QI-026, Revision 0,
dated August 16, 1985, and examination of the sampling process
'
used for selection of small bore piping runs for re'nspection.
Three ERC reinspections were witnessed by the NRC inspector;
i.e., Verification Package Nos. I-M-SBC0-010, I-M-SBC0-052, and
I-M-SBCO-062.
l'
l
During the above reinspections, ERC identified the following
l
conditions to the NRC inspector as subject to evaluation as
l
potential deviations:
I-M-SBCO-052: Flow direction was not indicated on a valve.
I-M-SBCO-062: A linear pipe dimension and a valve stem angle
were not in accordance with the applicable isometric drawing.
l
Dispositions of the above findings are open items (446/8509-0-03
i
and 446/8509-0-04).
No NRC violations or deviations were identified.
(3)~ HVAC Plenums and Ducts
,
e
t
y ;~.
'
.
31
Status'of CPRT Activity
Reinspections.have been performed on 37 of the 60 items in the
random sample associated with the HVAC plenums and ducts.
The
reinspections have identified conditions which necessitated the
issuance of 31 DRs, none of which have been validated at this
time.
Status of_NRC Inspection Activity
E
Inspe.: tion of this activity included review of QI-039, Revision 0,
,
dated August 23, 1985, and examination of the sampling process
used for selection of HVAC plenums and ducts for reinspection.
Four ERC reinspections were witnessed by the NRC inspectors;
'
i.e. , Verification Package Nos. I-M-DUPL-015, I-M-DUPL-017,
I-M-DUPL-019, and I-M-DUPL-040.
,
During the above reinspections, ERC identified the following
conditions to the NRC inspector as subject to evaluation as
potential deviations:
I-M-DUPL-015:
Pittsburgh seam construction (level 2) found
,
.rather than required welded seam (level 3).
I-M-DUPL-017:
(a) Inadequate companion angle weld length and
excessive companion angle stitch weld spacing, and~(b) groove in
,
,.
weld from use of a grinder.
v
I-M-DUPL-019: (a) Companion angle thickness found to be 3/16-inch
rataer than specified 1/4-inch; (b) companion angle mating
groove weld had 3/8-inch long underfill, and (c) inadequate weld
length on access door flange corner tabs.
I-M-DUPL-040: (a) Vent lock caps not tight, (b) gasket was not
in full contact in two places, (c) short companion flange weld
lengths in two locations, and (d) excessive gap between companion
angle and duct.
- -
Dispositions of the above findings are open items (445/8513-0-15
through 445/8513-0-18).
ERC also noted the following deficiencies outside of the defined
inspection scope:
I-M-DUPL-015:
Bent companion flange screws.
I-M-DUPL-040:
Close proximity of an instrument tubing support
and, bent companion flange screw.
- _ _
..
.
32
Dispositions of the above findings are open items (445/8513-0-19
and 445/8513-0-20).
No NRC violations or deviations were identified.
(4) HVAC Equipment Installation
.
Status of CPRT Activity
Reinspections have been performed on 34 of the 60 items in the
random sample associated with HVAC equipment installation.
The
reinspections have identified conditions which necessitated the
issuance of 55 DRs, none of which have been validated at this
time.
Status of NRC Inspection Activity
,
Inspection of this activity included review of QI-023, Revision 0,
dated August 29, 1985, and examination of the sampling process
used for selection of equipment items for reinspection.
No ERC
reinspections were witnessed by the NRC inspector.
No NRC violations or deviations were identified.
(5) Piping System Bolted Joints / Materials
Status of CPRT Activity
ERC completed 66 reinspections of piping system bolted
joints / materials as of September 24, 1985.
This is from the
combined random and engineering sample total of 74.
Status of NRC Inspection Activity
The following eight ERC reinspections of piping system bolted
joints / materials were witnessed by the NRC inspector:
Verification Pkg. No.
Drawing No.
Flange No.
I-M-PB0M-31
BRP-CS-1-AB-001
1
I-M-PB0M-42
BRP-SI-1-SB-012
1
I-M-PB0M-41
BRP-CC-1-FB-001
6
I-M-PB0M-48
BRP-SW-1-SB-003
1
I-M-PB0M-53
BRP-WP-X-AB-210
1
I-M-PB0M-59
BRP-VA-X-AB-025
2
I-M-PB0M-62
BRP-CH-1-EC-0048
3
I-M-PB0M-63
BRP-CC-2-AB-022
1
,
_
-
. _
p.-
,
i'
t
[
-
33
i
'
i
During the above witnessed reinspections, ERC identified the
l
following conditions to the NRC inspector as subject to evaluation
'
as potential deviations:
'I-M-PBOM-48: Flange No. 1 (Drawing BRP-SW-1-SB-003) had a loose
,
nut.
l
I-M-PB0M-62: Flange No. 3 (Drawing BRP-CH-1-EC-004B) had two
studs without.the required one thread past the outer face of the
!
nut.
t
Dispositions of the above findings are open items (445/8513-0-21
and 445/8513-0-22).
'
--No NRC violations or deviations were identified with respect to
'
-
~
the witnessed activities.
.
During a NRC independent reinspection of Verification Package
.No.~I-M-PB0M-23 (i.e., flange No. 4 on Drawing BRP-SW-2-SB-018),
,
it was'noted that flange No. 6, about 1 foot away from flange
-
,
.
,
,
No. 4 on the same line, had 4 out of 12 studs with loose nuts.
'
e
,
q
,
Flange No. 6 was not part of the ERC population sample.
Further.
e
d
investigation revealed that flange No. 6 had Construction
Operation Traveler No. MP-82-4117-0400 signed off by construction
'
,
.and accepted by QC.
Paragraph 3.5.2.1 in Revision 7 of Brown
'
p
,
'and Root Procedure CPM-6.9E requires an IRN when breaking an
-
inspected flange.
No IRN had been issued to document the
observed condition.
The failure to comply with procedural
'
requirements for accomplishing this activity is a violation.
(446/8509-V-04).
,s
,
(6) Electrical Cables
Status of CPRT Activity
,
ERC completed 49 reinspections of sampled electrical cables as
'
of September 23, 1985.
Status of NRC Inspection Activity
The following three ERC.reinspections of sampled electrical
cables were witnessed by the NRC inspectors:
Verification Pkg. No.
Cable No.
~
I-E-CABL-007
EG104636
I-E-CABL-004
EG123625Z
I-E-CABL-030
ESBI-34
.
.
-.
.-
,
,
4
- 34
.
r,
5
During the above rein ~spections, ERC did not identify any condi-
tions to the NRC inspectors'as subject to evaluation-as potential
'
deviations.
-
.
No NRC violations or deviations were identified.
(7)= Electrical Conduit
,
,
Status of CPRT Activity
^
ERC completed 59 reinspections of electrical conduit as of
September 23, 1985.
Status of NRC Inspection Activity
The following six ERC reinspections of sampled electrical
conduit were witnessed by~the;NRC:
Verification Pkg. No.
Conduit No.
~
I-E-CDUT-027
ESB6-5
I-E-CDUT-035-
C12G03270
I-E-CDUT-044
ECB3-29
I-E-CDUT-076
C12008750
I-E-CDUT-077
C13G05532
I-E-CDUT-086
- C13030044
.During the above reinspections, ERC identified the following
conditions to the NRC inspectors as subject to evaluation as
potential deviations:
I-E-CDUT-027:-(a) Three piece connection fitting on run not
handtight, (b) less than the required 1-inch separation between
conduits ESB6-5 and C14013763, (c) less than the required 1-inch
separation between conduit ESB6-5 and tray T13KECH, and (d)
conduit is 1-inch rather than the required 3/4-inch size.
I-E-CDUT-044: (a) Locknut on conduit CB3-24-29 not tight, and
.
(b) locknut and bushing on conduit CB3-29 were not tight.
has subsequently validated deviations for these items.
I-E-CDUT-086: (a) Three piece coupling on conduit as it penetrates
ceiling was loose, (b) inside coupling loose but locknut tight,
and (c) less than 1-inch separation between conduit C13030044
and CIPACRZ2.
Dispositions of the above findings are open items 445/8513-0-23.
through 445/8513-0-25).
m c;7 - -
- .
.
k,
'
.
.
-
- -
35
m
.
,
,
'
.
ERC also noted the following deficiencies outside of the defined
inspection scope:
I-E-CDUT-027: (a) 3-inch stub on outlet box was not plugged per
requirements, and (b) an outlet box had two stripped cover
retaining bolts / screws.
I-E-CDUT-077: Cable from conduit C13G05532 to cable tray was
thermal lagged within 2-inches of conduit.
This removed the
2-inch slack requirement specified in Section 5.4 of
Procedure QI-014, Revision 0.
A notification was made by three
part memo SER101 to TUGC0 on September 16, 1985.
E85-101226SX has been initiated for this out of scope item.
-
Dispositions of the above findings are open items (445/8513-0-26
and 445/8513-0-27).
No NRC violati'ns or deviations were identified.
(8) Cable Trays
Status of CPRT Activity
ERC completed 55 reinspections of sampled cable trays as of
September'23, 1985.
Status of NRC Inspection Activity
c
,
The following ERC reinspection of sampled electrical cable tray
was witnessed by the NRC inspector:
e
Verification Pkg. No.
Cable Tray No.
I-E-CATY-129
T120RBK17-
x
_D'uring the above reinspection, ERC identified the following
condition to the NRC inspector as subject to evaluation as a
potential deviation:
The tray node identification was not
located per the drawing.
Disposition of the above-finding is an open item
(445/8513-0-28).
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Y
.
L
.
.
t
36
The NRC inspector also noted that an adjacent cable tray,
<
T130RCJ36 had a tray cover which was misaligned and improperly
secured.
TUGCO, when notified of this condition, generated NCR
No. E-85-101361S to initiate corrective action. The NRC
inspectors examined other trays in the general area of this
occurrence and determined that this was an isolated case.
t
No NRC violations or deviations were identified.
(9) Electrical Equipment Installation
Status of CPRT Activity
ERC completed 21 reinspections of electrical equipment installa-
tions as of September 20, 1985.
Status of NRC Inspection Activity
The following nine ERC reinspections of sampled electrical
equipment installations were witnessed by the NRC inspectors:
Verification Pkg. No.
Equipment No.
I-E-EEIN-45
IE15
I-E-EEIN-01
ECSA-1-8890B-1,2 & 3
I-E-EEIN-03
ECSA-1-HV-4725-1, 2 & 3
I-E-EEIN-012
ECSA-1-HV-4172-1, 2 & J
I-E-EEIN-039
ESCA-1-HV-5561
I-E-EEIN-052
ECSA-1-HV-4169-1, 2 & 3
I-E-EEIN-024
I-E-066
I-E-EEIN-029
ECSA-1-8512B
I-E-EEIN-042
ECSA-1-8511B
During the above reinspections, ERC identified the following
conditions to the NRC inspectors as subject to evaluation as
potential deviations.
I-E-EEIN-45: (a) Tag on the inspected penetration flange was
2E15 instead of the required IE15; (b) design change tag number
DCA6881 was attached to the flange, whereas the inspection
package had not identified the design change; and (c) the flange
bolt at location 9 o' clock was not fastened flush with the top
of nut as specified in the supplemental inspection instructions
to QI-010, Revision 0.
DRs I-E-EEIN-45-01 and I-E-EEIN-45-02
have been issued with respect to these findings and NCR
E85-101272SX has been initiated by TUGC0 to address the items.
_-. __ _ --_____ __
_ _ - . __
l
..
.;
,
.
37
L
i
I-E-EEIN-052: The electricil conductor seal assemblies (ECSAs)
were longer than the 20 plus or minus 1-inch requirement.
I-E-EEIN-039: (a) Assembly ECSA-1-HV-5561 had a bend radius
'
.
under the required 5-inch minimum, and (b) length of
ECSA-1-HV-5561 was longer than the 20 plus or minus 1-inch
requirement.
I-E-EEIN-03: (a) Assembly ECSA-1-HV-4725-3 had'a fitting that
- was not handtight, and (b) all three (ECSA-1-HV-4725-1, 2 and 3)
assemblies were longer than the 20 plus or minus 1-inch require-
i
ment.
t
I-E-EEIN-Oli (a) Two assemblies were missing their identification
tags, and (b) flex conduits C1388908-2 and 3 had bend radii
,
under the required 5-inch minimum.
1
I-E-EEIN-012: (a) A three piece coupling on ECSA-1-HV-4172-2 was
not handtight, (b) all three (ECSA-1-HV-4172-1, 2 & 3) assemblies
were longer than the 20 plus or minus 1-inch requirement, and
(c) assemblies ECSA-1-HV-4172-2 and 3 had bend radii that were
under the required 5-inch minimum.
,
Dispositions of the above findings are open items (445/8513-0-29
,
through 445/8513-0-34).'
During witnessing of I-E-EEIN-029 and I-E-EEIN-042, the NRC
-
. inspector r.oted that the verification packages indicated three
-
required cable seal assemblies per valve, but only one was
i
-installed per valve (on the closed limit switch assembly).
This
- anomaly was resolved through another document search.
Two
,
. generic change documents, DCA 19076 and FCN 10589, had been
issued, but not specifically identified against the package
,
drawings.
These change documents revised the number of cable
seal assemblies required per valve to one.
,
The failure by ERC Engineering to reference DCA 19076 and FCN
'
10589 in the verification package is a deviation (445/8513-D-02).
,
s
,
ERC also noted the following deficiencies outside of the defined
inspection scope:
,
I-E-EEIN-01: (a) Conduit identification on runs from JBIC-152G
to ECSA-1-8890B-1, 2 and 3 were illegible; and (b) the solenoid
valve's flex conduit had a missing digit on its identification
tab.
.
,
,
g,
,,e-+,
, ,,,,+---
-y,---,m,-
---m,---r
n,,,
we--,n-ww~-~-
,w.nn
nm
-nrm-en -- -
--w-
,,,-,---n.~~-nwn,,
,
.
..
38
I-E-EEIN-03: Rigid conduit identifications for runs from JBIC-2450
to ECSA-1-HV-4725-1 and 3 were illegible.
I-E-EEIN-024: (a) Conduits entering the top of the penetration
box enclosure were not properly terminated; (b) conduit C12018896
contained a nylon pull rope; and (c) at elevation 832 feet, in
the reactor building near the personnel hatch, the electrical
attachment to the sensing transmitter associated with the
accumulator No. 1 nitrogen insolation valve no. 1-8875A, safety
injection system was loose and appeared to be damaged.
Dispositions of the above findings are open items (445/8513-0-35
through 445/8513-0-37).
No NRC violations or additional deviations to 445/8513-0-02 were
identified.
(10) Instrumentation Equipment Installation
Status of CPRT Activity
ERC completed 57 reinspections at sampled instrumentation
equipment installations as of September 23, 1985.
ERC has attempted on three occasions to implement instrumentation
equipment installation documentation reviews.
These efforts
were unsuccessful due to the need for additional instructions in
the QIs for performing material traceability reviews (tubing).
Status of NRC Inspection Activity
The following three ERC reinspections of sampled instrumentation
equipment installation were witnessed by the NRC inspector:
Verification Pkg. No.
Instrument No.
I-E-ININ-005
1-LS-4795
I-E-ININ-016
1-LS-3378
I-E-ININ-060
1-LS-3376
During the above reinspections, ERC identified the following
condition to the NRC inspector as subject to evaluation as a
potential deviation:
I-E-ININ-005: The anti-torque indicators on the flexible hose
g
connections were misaligned by approximately 45 , indicating
posible excessive twist.
,
. #
.
39
,
4
N
Disposition of the above finding is an open item (445/8513-0-38).
The tubing size also could not be initially verified by ERC on
performing this inspection due to the absence of three required
documents in the verification package.
The ERC inspectors
subsequently obtained the three documents and verified that the
tubing was the correct size.
~
The failure of ERC Engineering to include necessary documents in
the verification package is a deviation (445/8513-D-02).
'
ERC also noted the following deficiency o'tside of the defined
u
,
inspection scope:
i
I-E-ININ-016: Train B (green) channel lighting conduit, at the
entrance to Room 99C, had a loose switch box.
The lights worked
r
intermittently when the box was moved.
Disposition of the above fin' ding is an open item (445/8513-0-39).
No NRC violations or additional deviations to 445/8513-D-02 were
identified.
(11) Reinspection of Concrete Placement
Status of CPRT Activity
A random sample of 60 concrete pours was, selected from a total
population of 7617 individual pours.
Those pours ranged in size
r
from 0.07 cubic yards (for 1 foot x 1 foot x 2 feet blockouts)
'
to several hundred cubic yards (walls, slabs, etc.).
Brown and
Root pour cards identify from 1 to'10 or more individual pours.
.In some cases a pour cards lists, for example, concrete pours
for a floor slab and several small concrete blockouts. . Sample
selection was based on a population of individual pours rather
.
than pour card thus greatly increasing the number of small (less
than 1-cubic yard) concrete placements that are inspected.
Nineteen of the 60 concrete placement inspection packages are
,
blockouts with less than 1-cubic yard of concrete.
A second
random sample of safe shutdown system related concrete pours has
not yet been identified.
Reinspection of the first random sample of 60 concrete pours was
initiated using QI-043, Revision 0, and is approximately 20%
complete.
Two deviations'have been identified relating to
,
m -
_
-
.
,
40
unfilled holes, voids, and debris in the concrete surface.
These deviations are currently being reviewed for validity and
safety significance by ERC Engineering.
Documentation review
procedures have not yet been issued.
Status of NRC Inspection Activity-
The NRC inspectors reviewed QI-043, Revision 0, and witnessed 6
reinspections representing 10% of the first random sample of 60
concrete placements.
ERC DR dispositions are being evaluated by
the NRC inspectors.
The following 6 ERC reinspections were
witnessed by the NRC inspectors:
Verification Pkg. No.
Concrete Placement No.
Unit
I-S-CONC-06
CPC-003-4832-003
C
- '~
I-S-CONC-08
CPC-105-M81D-191
1
I-S-CONC-12
CPC-002-I842-068
C
I-S-CONC-41
CPC-101-7853-001
1
I-S-CONC-47
CPC-201-9808-008
2
I-S-CONC-52
CPC-105-5844-001
1
During the above reinspections, ERC identified the following
conditions to the NRC inspector as subject to evaluation as
potential deviations:
I-S-CONC-52: (a) Unfilled holes were identified in two locations,
and (b) insulation was identified in one construction joint.
Disposition of the above findings is an open item (445/8513-0-40).
No NRC violations or deviations were identified.
(12) Small Bore Pipe Supports
Status of CPRT Activity
A random sample of 60 small bore pipe supports (2-inch and
smaller) was selected from a total population of 7947 derived
from the Hanger Installation Tracking System (HITS) as used by
construction site personnel.
The random sample consists of
approximately 68% box frame supports; 20% U-bolt type supports;
and 12% combined snubbers, sway struts and spring can/ constant
supports.
Reinspection is now approximately 95% complete.
Forty-five DRs relating primarily to Hilti bolt embedment, hole
spacing and edge distance in base plates, and pipe clearances,
have been initiated.
Reports are currently being reviewed for
validity and safety significance by ERC Engineering.
c-
'
~
.,
.
E
41
-
.
A second random sample of 60 small bore pipe supports associated
with safe shutdown systems is being selected.
Forty-two supports
from the first random sample have been identified as being
related to safe shutdown systems;.thus, are included in the
second sample's population.
Therefore, an additional 18 supports
will be selected for reinspection pending issuance of the
associated verification packages.
Documentation review of small bore pipe supports was initiated
using QI-020, Revision 0, issued September 16, 1985, and is
approximately 20% complete.
.
Seven DRs pertaining to documentation have been issued and are
currently being reviewed for validity by ERC Engineering.
Status of NRC Inspection Activity
NRC personnel have reviewed QI-019, Revision 1, (physical
inspection ) and QI-020, Revision 0, (documentation review).
Six reinspections have been witnessed representing 10% of the
first random sample.
Approximately 10% of the remaining ERC
-
reinspections are planned to be witnessed by NRC inspectors.
Independent NRC inspections have been initiated.
The following six reinspections were witnessed by the NRC:
Verification Pkg. No
Pipe Support No.
Unit
- I-S-SBPS-009
CH-1-AB-033-002-3
1
I-S-SBPS-019
CC-1-RB-004-007-3
1
I-S-SBPS-028
WP-X-AB-018-012-3
C
I-S-SBPS-035
CH-2-AB-015-008-3
2
I-S-SBPS-038
WP-X-AB-018-013-3
C
I-S-SBPS-049
CC-1-SB-043-009-3
1
During~the above reinspections, ERC identified the following
conditions to the NRC inspector as subject to evaluation as
.
potential deviations:
I-S-SBPS-028: (a) Incorrect bolt hole spacing, and (b) excessive
gap between the pipe and shim.
l
'
I-S-SBPS-035: Insufficient Hilti bolt embedment.
I-S-SBPS-038: Incorrect bolt hole spacing.
,
. , .
-
_. _ . _ _ . - _ . . - . _ .
_ - _ _ - _
.____m._
__m_._._
_.___-__.____m_
__. _ - _ _ . - . _ - _ . . _ _ . . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ --- _
__.___.__.
-
-a:i.._-m-_.
x
-
- .;
~~
'
.e
,
- .
/
9
-
.
-
,
n -
.
'
'
~
-
t
.
,
,
,
s
, .
42-
-
,
,
,
!
. Dispositions of the above findings are open items (445/8513-0-41;
,
,
,
through 445/8513-0-43).
-
,
No NRC violations or deviations ^were identified.
,
(13) Large Bore Pipe Supports - Non-Rigid
Status of'CPRT Activity
'
.
s.
The selected random samples consist of 60 safety-related pipe
. supports from the general population and 22 safety-related pipe
.
'
'
supports-from safe shutdown systems.
Reinspection by ERC is in-
process and is approximately 60% complete.
A total:of 126
. deviations have~been identified of which 31 have been determined
'to be valid. .The remainder are currently being evaluated for
validity and safety significance by ERC Engineering.
4
Status of NRC Inspection Activit.y
~
The NRC inspector has reviewed QI-029 and witnessed the following
' '
, three reinspections to assure , compliance with inspection procedure
requirements:
Verification Pkg. No.
Unit No.
I-S-LBSN-023
l'
I-S-LBSN-031
-
1
.
I-S-LBSN-037
1
Duri$gtheabovereinspections,-ERCidentifiedtherfollowing
conditions to the NRC inspector as subject to evaluation as
potential dev.iations:
.I-S-LBSN-023: .(a) Material identification missing from~one item;
(b) bill of material quantities for two items differed from
'
actual installed quantities; (c) bolt hole location, attachments
to base plate, and a component member location were out of
-
'
tolerance; (d) U-bolts had zero clearance; (e) base plate
violated' perimeter contact requirements; (f) locking devices on
nine 2-inch diameter bolts were missing;.(g) item 13 Hilti bolts
violated embedment requirements; (h) snubber extension piece
thread engagement could not be determined; (i) paint on spherical
bearings; (j) no welder identification.on integral Attachment
, ,
,
No. 4; and (k) seven undersize welds were identified.
-
I-S-LBSN-037: (a) Clamp bolts did not have locking devices, and
'
(b), paint was identified on spherical bearings.
e'
1
i
'
+
,
.,
'
s
,
'
p
>
-
-
, _
__
.
_ .
,
>
f
8
'
43
>
>
.
Dispositionso'fthe1aboveIindingsareopenitems(445/8513-0-44
and 445/8513-0-45).
No NRC' violations or deviations were identified.
(14) Large Bore Pipe Supports - Rigid
Status of CPRT Activity
The selected random samples consist of 61 safety-related pipe
supports from the general population and 28 safety-related pipe
supports from safe shutdown systems.
Reinspection by ERC is in
process and is approximately 57% complete.. A total of 90
deviations have been identified of which 25 have been determined
to be valid.
The remainder are currently being reviewed for-
validity and safety significance by ERC Engineering.
Status of NRC Inspection Activity
The NRC inspectors has reviewed QI-027 and witnessed the following
four reinspections to. assure compliance with inspection procedure
requirements:
Verification Pkg. No.
Unit
I-S-LBSR-047
1
I-S-LBSR-029
1
I-S-LBSR-048
1
I-S-LBSR-053
1
During the above reinspections, ERC identified the following
conditions to the NRC inspector as subject to evaluation as
potential deviations:
I-S-LBSR-047: (a) Inadequate thread engagement for Richmond
insert; (b) undersize fillet weld; and (c) cotter pin not
installed properly.
I-S-LBSR-029: Missing locking devices and dimensional
.
discrepancies.
I-S-LBSR-048: Shim not located properly and minimum clearance
'
discrepancies ~.
I-S-LBSR-053: Installation. tolerances were discrepant.
Dispositions of the above findings are open items (445/8513-0-46
through 445/8513-0-49).
.
L
.
.
.
44
During the reinspection of I-S-LBSR-047, the NRC inspector
identified two deviations from commitment in the areas of
verification package preparation adequacy and reinspection /
. verification. The responsible QA/QC discipline engineer indicated
.that Richmond inserts were not applicable for inspection on the
~ hecklist, when_both the bill of material and the design drawing
c
-listed Richmond inserts as being present (445/8413-D-02).
'
Paragraph 5.0 of QI-027, Revision 0, identifies note 30 as an
applicable inspection note which requires the inspector to
document any item that appears out of the ordinary as related to
construction of'the inspected item.
The ERC inspectors failed
to. document the existence of four 9/16" diameter drilled holes
in item 2 of ASME pipe support Mk. No. CT-1-053-436-C52R that
were not shown on the design drawing (445-8513-D-03).
It was
additionally noted that ASME N-5 Data Report activity was
complete for this support.
(15) Containment Liner and Tank Stainless Steel Liner
Status of CPRT Activity
'
A minimum number of 60 liner packages will be inspected using
QI-031, Revision 0.
Ninety-one packages have been issued and
inspection is approximately 80% complete based on the minimum
sample of 60.
Forty-seven deviations have been identified,
primarily due to excessive weld reinforcement. These deviations
are currently being reviewed for validity and safety significance
by ERC Engineering.
Status of NRC Inspection Activity
The NRC inspectors has reviewed QI-031, Revision 0, and witnessed
four reinspections.
ERC DR dispositions are being evaluated by
the NRC inspector. The four ERC reinspections witnessed by the
NRC were as follows:
Verification Pkg. No.
Joint No.
Unit
I-S-LINR-03
P-290
1
I-S-LINR-30
P-356
1
I-S-LINR-50
P-366
1
I-S-LINR-60
P-387
1
I-S-LIRN-06
17E
1
I-S-LINR-13
P-57
1
1-S-LINR-21
10E
1
I-S-LINR-51
15E
1
I-S-LINR-55
15-16(B2)
1
.
45
During the above reinspections, E;M identified the following
conditions to the NRC inspector as subject to evaluation as
potential deviations:
I-S-LINR-03: Excessive weld reinforcement.
I-S-LINR-30: Excessive weld reinforcement.
I-S-LINR-60: (a) Excessive weld reinforcement, (b) weld undercut,
and (c) unacceptable weld seam surface.
I-S-LINR-06:
Excessive weld reinforcement.
I-S-LINR-13:
Excessive weld reinforcement.
I-S-LINR-51: Unacceptable weld seam surface.
I-S-LINR-55: Weld undercut.
Dispositions of the above findings are open items 445/8513-0-50
through 445/8513-0-56).
During the reinspection of verification package Nos. I-S-LINR-06 and
I-S- LINR-51, the ERC inspector noted that the responsible QA/QC
discipline engineer wrote "NA" for not applicable on the checklists
for two base material local contour attributes. The attributes were
found during the physical inspection by the ERC inspector to be, in
fact, inspectable. New checklists were requested by the ERC inspector.
The failure of the discipline engineer to issue correct verification
packages is a deviation (445/85-13-0-02).
6.
Exit Interview
An exit interview was conducted on October 4, 1985, with the applicant
representatives denoted in paragraph 1 of this appendix. During this
interview, the NRC inspectors summarized the scope and findings of the
inspection. The applicant acknowledged the findings.
_ _