ML20198D643

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Partially Withheld Assessment of Allegation AQ-121 to Allegation Category Qa/Qc 7, QA Implementation Re Installed Structures Not Meeting Design Drawing Requirements
ML20198D643
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Wenczel V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59 NUDOCS 8605230342
Download: ML20198D643 (4)
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1. Allegation Category: QA/QC 7, QA Implementation
2. Allegation Number: AQ-121
3. Characterization: There is a concern that the program controls for areas not-constructed according to ASME Code requirements are considerably less structured than in those areas constructed according the ASME Code. It is further stated that some installed structures did not meet design draw-ing requirements; there are also concerns that the lead QC group leader (the QC lead) was inappropriately approving changes to travelers for non-ASME structures.
4. Assessment of Safety Significance: The NRC Technical Review Team (TRT) reviewed applicable procedures, instructions, specifications, codes, and standards to determine whether appropriate program controls were established for non-ASME structural steel construction. These documents were also reviewed for their conformance to Texas Utilities Electric Company (TVEC) commitments and NRC requirements for structural steel fabrication, erection, installation, inspection, and material traceability. In general, non-ASME program controls were established in the specifications, procedures, and instructions, except in the-following instances.

First, no written procedures we're established for the inspection of embedded anchor bolts, even though there was a statement on the operation traveler that " nuts on anchor bolts shall be snug tight." (Operation trav-elers are checklists normally used for routine inspections by the QC in-spectors.)

Second, the baseplate hole size corresponding to the anchor bolt size was not specified in the inspection procedures. Based on information from TUEC representatives, approximately 10 percent of all steel construction used embedded anchor bolts. To ensure quality, the QC inspectors normally would detect these deficiencies during inspections based on information in operation travelers or on design drawings.

Third, structural assembly verification cards (SAVCs) were used in the QC inspection for material traceability. There were no written instructions concerning the SAVCs, nor were they addressed in a principal QC inspection instruction, QI-QP-11.14-1, Rev. 18.

Fourth, TUGC0 procedure CCP-22, Rev. 3, " Table of Contents," identifies paragraph 4.6 as " Inspection-Category I," and the scope of work statement in paragraph 1.2.1 indicates that the inspection of Category I items was covered by this procedure. Although paragraph 4.6 in the procedure was titled " Attachments to Building Structure," there were no specific sec-tions in the procedure that related to the inspection of Category I structures.

In regards to installed structures, the TRT interviewed four QC inspectors and one QC supervisor whose primary functions were to inspect steel struc-tures that had been installed and which were not subject to ASME Code re-quirements. During the interview, the TRT learned that prior to April '

1983, all of the concerned individual's work was performed in piping sys-tems which were subject to ASME Code requirements. The worr which gave

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rise to the concern was the work the concerned individual had done as a QC inspector in structural steel construction that was not subject to ASME Code requirements. After a lengthy discussion with the individual about program controls of the Code applications between non-ASME work and ASME work, the TRT formed the opinion that the individual made an inappropriate comparison of ASME Code work to the requirements of non-ASME Code work.

All other QC inspectors interviewed said that proper controls existed for non-ASME steel constructions. In fact, they believed that the plant was being built in a proper manner in this area.

In assessing the issues of design drawing requirements and the QC lead changing travelers, the Thi held discussions with the TUEC representatives about design changes made to design drawings through the use of design change authorizations or component modification cards and about the QC lead modifying travelers to determine whether appropriate controls were esta-blished for the non-ASME work. The TRT found that TUEC did have procedures to control these activities (References 2, 3, 4, 5, 6, 7 and 8).

The TRT also performed field inspections of two steel structures (in the auxiliary building) that had been inspected previously by the non-ASME QC group to determine whether the program controls were fully implemented in accordance with established procedures and instructions.' Based on compari-son of procedures, inspection criteria, and inspection results, the TRT determined that the controls had been implemented, except in one area, where minor discrepancies (missing washers) were identified in an anchor bolt I installation.

5. Conclusion and Staff Positions: After reviewing documents, interviewing QC personnel and TUEC representatives, and conducting field inspections, the TRT finds that program controls for the non-ASME work were established and implemented. The TRT found no physical evidence of lack of program controls for non-ASME work in the areas of structural steel construction, except for a minor discrepancy in anchor-bolt installation. That part of the concern associated with a minor discrepancy in the installation of anchor bolts was substantiated.

The AQ-121 concerns and issues came from an NRC special review team report.

On March 25, 1984, a close-out interview was conducted with the individual expressing these concerns and issues. No new concerns or issues were identified. .

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7. Attachments: .

Reference Documents:

1. Design change authorization No. 1213 Rev. 7. (Structural steel inspection pertaining to missing washers on embedded anchor bolt.)
2. Procedure CCP-22, Rev. 3, " Structural Steel Erection."
3. Instruction QI-QP-11.2-1, Rev. 16, " Installation of Hilti Drilled-in Anchor Bolts."
4. Instruction QI-QP-11.1d , Rev. 18, " Inspection of Site Fabrication and Installation of Structural and Miscellaneous Steel."
5. Instruction QI-QP-11.14-5, Rev. 10, " Inspection of Platforms and Stairways Installed in Seismic Category I Structures."
6. Gibbs & Hill, Inc specification 2323-SS-16B, " Structural Steel (Category I)."
7. Procedure CP-CPM 6.3, Rev. II, " Preparation, Approval, and Control of l' Operation Travelers."

.8. TUGC0 Nuclear Engineering drawing update activities, April 1984.

9. Procedure THE-DC-7, Rev. 5, " Preparation and Review of Design Drawings."
10. NRC Special Review Team Report, dated July 13, 1984, page 64.
8. This statement prepared by: Ak _

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V. Wenczel, TRT Date Technical Reviewers Reviewed by: #/ Eqag3_ h7 H. Livermore Date Group leader 0-247

Approved by:

V. Noonan Date Project Director S

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