ML20198B914

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Rev 2 to Isap VII.b.1, Onsite Fabrication
ML20198B914
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/13/1986
From: Beck J
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20198B872 List:
References
PROC-860313, NUDOCS 8605220175
Download: ML20198B914 (9)
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COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAk- VII.b.1

Title:

Onsite Fabrication Revision No. 0 1 2 Reflects Comments Description Original Issue On Plan ReflecthlanComments on Prepared and (

Reconunended by: g j Review Team Leader ;/ / , ,

Date l S[ / AV Tb }) &b Approved by:

Senior Review Team Cl ' .

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Ravision: 2 Paga 1 of 8 ISAP VII.b.1 Onsite Fabrication

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (USNRC Letter January 8, 1985, Issue 8 Onsite Fabrica* ion)

"The TRT findings regarding onsite fabrication shop activities indicated that:

A. The scrap,and salvage pile in the fabrication (fab) shop laydown yard was not identified and did not have restricted access.

B. Material requisitions prepared in the fab shop did not comply with the applicable procedure.

C. The fab shop foremen were not familiar with procedures that controlled the work under their responsibility.

D. Fabrication and installation procedures did not include information to ensure that Brown & Root fabricated threads conformed to design specifications or to an applicable standard. l 5

E. Indeterminate bulk materials that accumulated as a result of site cleanup operations were mingled with controlled safety and non-safety material in the fab shop laydown yard.

F. Site surveillance of material storage was not documented.

G. Work in the fab shop was performed in response to memos and sketches instead of hanger packages, travelers, and controlled drawings .

2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT findings and consider the implications of these findings on construction quality. . . . examination of the potential safety implications should include, but not be limited to the areas or activities selected by the TRT.

- " Address the root cause of each finding and its generic implications... ,

" Address the collective significance of these deficiencies...

" Propose an action plan...that will ensure that such problems do not occur in the future."

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Ravision: 2 Paga 2 of 8 ISAP VII.b.1 (Cont'd)

3.0 BACKGROUND

This action plan involves the fabrication shop identified as a part of the NRC item on material traceability, and addressed by Issue-Specific Action Plan VII.a.1, " Material Traceability".

CPSES Safety Evaluation Report Supplement No.11 (SSER 11), May 1985, Appendix.0, Allegation AQ-138 (pages 0-145 to 0-153) discussed fabrication shop activities under QA/QC Category SB, Onsite Fabrication. Specifically, Allegation AQ-138 consists of 12 elements:

1. Personnel asked to perform work without knowledge of paperwork.
2. Paperwork illegal due to post dating.
3. Non-safety material mixed with safety-related material.
4. Personnel directed not to mark indeterminate material as scrap.
5. Electrical and iron fab shop material consolidated and mixed.
6. Electrical personnel used undocumented material.
7. ASME QC personnel in iron fab shop did not check Brown

& Root threads.

8. Undocumented weld repairs made on base metal.
9. Threaded rod cut without QC verification of heat numbers.
10. Arc cut done too close to cut line.
11. Beam clips may have been cracked during bending.
12. Chain and triple hook fabricated without regard to procedures.

The NRC conclusions to Allegation AQ-138 (page 0-152) are:

Subscantiated: Item 1.

Not substantiated: Items 3, 4, 5, 7, 9, 11.

- Unable to substantiate: Items 2, 6, 8, 10, 12.

t Ravicion: 2 Psge 3 of 8 ISAP VII.b.1 (Cont'd)

3.0 BACKGROUND

(Cont'd)

However, SSER 11, Appendix P lists seven (7) Allegation AQ-138 concerns or deficiencies under QA/QC program area 4. Construction and Testing (page P-14). (Note that the QA/QC program areas of Appendix P are not the QA/QC categories of Appendix 0.) The seven (7) AQ-138 concerns or deficiencies, referenced to SSER 11, Appendix P, are:

1. Parts fabricated without hanger package, traveler, or drawings.
2. Scrap and salvage material not marked or restricted access.
3. Indeterminate material mingled with safety-related material. .
4. Fabrication procedures did not identify design standards for threads.
5. Material requisitions did not comply with procedures.
6. Random QC surveillance of storage areas not performed.
7. Unused material not returned to warehouse.

Concerns 1 through 6 were included in the NRC-TRT January 8, 1985 letter as Items 8G, 8A, SE, 8D, 8B and 8F respectively (vee paragraph 1.0 above also). NRC-TRT January 8, 1985 Iten 8C (Shop Foreman familiarity with procedures) was identified onP/ in SSER 11, Appendix 0 (page 0-146), but was not included in hjpendix P.

Adequacy of craft training is addressed in ISAP I.d.3. Concern 7 (above) was first identified in Appendix P, and will be addressed in ISAP VII.a.l.

Background and historical information will be obt#ined and evaluated as a part of the implementation of thiv action plan.

t A preliminary investigation indicates that only a small amount of safety-related work was performed in the ont 't.e fabrication shop prior to January 1980. The program of procraural and management controls applied to ensite fabrication sho" activities has evolved with time as a result of corrective actic s to problems identified by both internal and external sources. *ae work activities performed at the onsite fabrication shop range from simple cutting of material through the fabrication of Tamplex items which involve fit-up, welding, and machining operations. Based upon this preliminary investigation, a directed approach for selecting fabricated items for review will provide a more effective means to assess a representative cross-section of activities over the time Period than will a random sample process.

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e R: vision: 2 Page 4 of 8 ISAP VII.b.1 (Cont'd) 1 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology 4.1.1 This Issue-Specific Action Plan assesses the adequacy of the procedural and management control of fabrication shop work activities at CPSES. The evaluation will consider the evolution of procedural and management controls with time and provide an assessment of the current program.

This action plan consists of two separate areas of evaluation:

4.1.1.1 Concerns which may be evaluated by review of safety related fabrication document packages:

Material requisitions not properly completed.

Fabricated thread conformance.

Fabrication to memos and sketches.

4.1.1.2 Concerns which may be evaluated by review of procedures, survey, surveillance, and audit records to identify trends and corrective action effectiveness:

Scrap and salvage area control Safety, non-safety and bulk material segregation Site surveillance of material storage 4.1.2 The specific methodology is described below.

4.1.2.1 Identify, obtain, and review applicable material storage, fabrication, and inspection procedures in effect for both ASME and non- .

ASME safety related work in onsite fabrication shops. Evaluate procedural adequacy with respect to controls for material traceability, fabrication processes and item acceptability.

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Ravision: 2 Pags 5 of 8 i- ISAP VII.b.1 (Cont'd) i

! 4.0 CPRT ACTION PLAN (Cont'd)

4.1.2.2 Categories of both ASME and non-ASME i

safety-related fabricated items will be selected for review in such a manner as to provide a reasonable cross-section of onsite fabrication shop activities during January l 1980 through December 1985.

- Fabrication shop activities include the following groups of work activities:

, a) Cutting of material and material

! identification transfer.

b) Fitup and welding.

c) Machining; threading, etc.

Fabricated items selected for review will represent at least two (2) of the above i groups of work activities. A minimum of three (3) items per calendar quarter will be selected over the January 1980 through December 1985 time period for a minimum total of 72 items.

. Review the completed fabricat$on packages'for the selected pieces for adequacy of material

identification, applicable drawings and i procedures used, and fabrication and .

inspection sign offs. If no discrepancies are identified, document the results and i close the action item.

4.1.2.3 If documentation discrepancies are identified, a visual reinspection of the selected items in situ for welds, dimensions, fasteners, material identification, component identification, etc., will be performed (to confirm or resolve the discrepancies)

depending upon the nature of the discrepancy. ,

! Based upon the review in Section 4.1.2.1, and hardware reinspection, checklists developed

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under ISAP VII.c, appropriate inspection

. attributes and accept / reject criteria will be developed for this reinspection.

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, Rtvision: 2 Page 6 of 8 ISAP VII.b.1 (Cont'd) 4.0 'CPRT ACTION PLAN (Cont'd)

Deviations identified will be documented as either a construction deviation or a QA/QC program deviation and evaluated in accordance with CPRT program requirements.

4.1.2.4 Review storage and surveillance procedures and records for adequacy of requirements, identification of trends, and effectiveness of corrective action.

4.1.2.5 A detailed analysis will be conducted on the data from the reviews in paragraphs 4.1.2.1 through 4.1.2.4. Data will be analyzed to l .

determine if the shop fabrication activities have met the requirements of 10CFR50 Appendix B, Criteria V, IX, and X and the FSAR.

4.1.2.6 Provide any discrepancies related to material l traceability to ISAP VII.a.1 Issue Coordinator for integration into that action plan.

4.2 Participant's Roles and Responsibilities The organizations and personnel that wiil participate in this effort are described below with their respective scopes of work.

4.2.1 TUGC0 4.2.1.1 Scope Assist the QA/QC Review-Team in obtaining information regarding the identity and location of all Fabrication shops used during the life of CPSES Unit 1&2 Construction.

Assist in'the identification and provision.of all necessary specifications, drawings, pr_ocedures and other-documentation ne'cessary

. for the execution of this action plan.

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Rsvision: 2 Paga 7 of 8 ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Assist in determining the type of items fabricated onsite in the respective fabrication shops.

Process NCRs that may be generated due to this action plan.

4.2.1.2 Personnel Mr. D. W. Snow TUGC0 QA/QC Coordinator Mr. C. R. Hooton Project Coordinator -

(CPPE) 4.2.2 CPRT Safety Evaluation Group 14.2.2.1 Perform evaluations for safety significance.

4.2.2.2 Personnel Mr. J. A. Adam SSEG - Supervisor 4.2.3 CPRT QA/QC Review Team 4.2.3.1 Scope All activities not identified in 4.2.1 and 4.2.2 above will be the responsibility of the QA/QC Review Team.

4.2.3.2 Personnel Mr. G. W. Ross Issue Coordinator l

Mr. J. L. Hansel QA/QC Review Team Leader 4.3 Qualifications of Personnel Where test or inspections require the use of certified inspectors, qualification will be to the requirements of ANSI N45.2.6 at the appropriate level. Third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program and specifically trained to the requirements of the quality procedures developed under this action plan.

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-. "' . ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) <

Otherparticipantswillbequa'[ifiedtotherequirementsof ~

the CPSES Quality Assurance Program, or to the specific requirements of the CPRT Program Plan.

4.4- Procedures Checklists, guidelines, data sheets, and flowcharts may be developed as an integral part of the evaluation. These will be retained te support justification of the conclusions.

4.5 Standards / Acceptance Criteria Acceptance criteria will be based on a review of shop -

~s. fabrication procedures, QC inspection procedures, codes and standards, drawings and sketches.

Fabrication rhop work activities will be accepted if all required documents are-present J and correctly identify drawings and process procedurea used, inspection criteria satisfied, material identification and type, and authorized sign offs attesting to the adequacy of the iteme and documentation.

, 4.6 Decision Criteria This action plan will be closed if no construction deficiencies, QA/QC program deficiencies or adverse trends are identified.

s i If a construction deficiency, QA/QC program defici.er.cy or adverse' trend is identified, root cause and generic implication analyses will be conducted. Additional reviews and/or reinspections will be conducted as required. The scepe fr of these additional reviews and/or reinspections shall be

'y suffi:ient that when the results are coupled with the root

. cause and generic implication analyses, there is reasonable assurance that no further unidentified deficiencies exist.

The action plan will then be clo.4ed.

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