ML20198E859
| ML20198E859 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/06/1986 |
| From: | Barnes I, Ellershaw L, Hale C, Will Smith, Tomlinson D, Wagner P, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198E698 | List: |
| References | |
| 50-445-85-18-01, 50-445-85-18-1, 50-445-86-18, 50-446-85-15, 50-446-86-15, NUDOCS 8605280309 | |
| Download: ML20198E859 (26) | |
See also: IR 05000445/1985018
Text
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APPENDIX D
1
COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT
U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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NRC Inspection Report: 50-445/85-18 Permits: CPPR-126
50-446/85-15 CPPR-127
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- Dockets: 50-445 Category: A2
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50-446
Applicant: Texas Utilities Electric Company (TVEC) ,
Skyway Tower
s 400 North Olive Street
! Lock Box 81
j Dallas, Texas 75201
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Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 & 2 >
- Inspection At
- Glen Rose, Texas
Inspection Conducted: December 1-31, 1985
Inspectors: M I" l' I4
L.'E. Ellershas, Reactor Inspector, Region IV Date
,
CPSES Group
j (paragraphs 1, 5.e, and 6.e-6.r)
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. su \ Sf/ ff6
! W. F. Smith, Resident Reactor Inspector (RRI) Date
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Region
(paragraphs IV CPSES Group )
1, and 5.c
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C. J. 11, Reactor Inspector, Region IV
s/dsk
Date '
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(paragraphs 1, 4.a. and 5.b)
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P. C'. Wagner, Reagtor Inspector, Region IV
S/t/64
Dat'e
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i (paragraphs 1,3,4.b,5.a.and6.a-6.d)
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GROS 200309 860512
! G ADOCK 05000445 ,
PDR !
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D.'P. TomWs6n, Reactor Inspector, Region IV
S~-o Gb6>
Date
(paragraph 5.d)
Consultants: EG&G - J. Dale,
- A. Maughan,
i W. Richins,
R. VanderBeek,
V. Wenczel
Parameter - J. Birmingham,
J. Gibson,
K. Graham,
D. Jew
Reviewed By: ba e s 6/5/d'd
I. Barnes, Group Leader, Region IV CPSES Group Date
Approved: - -
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T. F. Westerm'an, Chief, Region IV CPSES Group Date'
Inspection Summary
Inspection Conducted: December 1-31, 1985 (Report 50-445/85-18; 50-446/85-15)
Areas Inspected: Nonroutine, unannounced inspection of applicant actions on
previous inspection findings, Comanche Peak Response Team (CPRT) issue - specific
action plans (ISAPs) and assessment of allegations. The inspection involved
1718 inspector-hours onsite by seven NRC inspectors and nine consultants. A
summary of NRR and IE audit / inspection activities is provided in paragraph 2 of
this appendix.
Results: Within the three areas inspected, four violations (failure to certify
inspectors in accordance with procedural requirements, paragraph 5.b; excessive
conduit length between an end device and its associated junction box, para-
graph 3.a; inadequate design change control measures with respect to assuring
performance of required actions, paragraph 6.d; absence of required identifica-
tion on thermo-lagged raceways, paragraph 6.b) and three deviations (failure to
document, disposition, and track drawing change discrepancies with respect to
effect on preoperational tests, paragraph 5.c; failure to comply with approved
instructions in performances of inspections, paragraphs 6.d, 6.f. and 6.n;
1 inadequate engineering review of piping isometric for applicability of an
inspection attribute, paragraph 6.r) were identified.
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DETAILS
1. Persons Contacted
C. T. Brandt, TUGCo Quality Engineering Supervisor
- R. E. Camp, Assistant Project General Manager, Unit 1 (Impell Corp.)
J. Cordoza, TUGCo System Engineer
- W. G. Counsil. Executive Vice President, TUGCo
C. G. Creamer TUGCo Mechanical Engineer
S. M. Franks, Special Projects and Technical Support Lead (Impell Corp.)
E. L. Gastenel, TUGCo System Test Engineer
- P. E. Halstead, TUGCo Site QC Manager
B. Holmes, TUGCo QC Electrical Supervisor
M. Keathley, ERC Lead Electrical QC Inspector
R. R. Komrow, TUGCo Senior Project Engineer
J. T. Merritt, Jr., TUGCo Assistant Project General Manager
G. M. McGrath, TUGCo Licensing / Compliance Supervisor
C. K. Moehlman, TUGCo Project Mechanical Engineer
A. A. Patterson, ERC Reinspection Engineering Supervisor
C. M. Puffer, TUGCo System Test Engineer
J. G. Red, TUGCo Technical Support Supervisor
J. E. Rushwick, CPRT Issue Coordinator
- A. B. Scott, TUGCo Vice President, Nuclear Operations
B. Shair, ERC Lead Electrical Engineer
M. Shealey, ERC Lead Mechanical QC Inspector
J. C. Smith, TUGCo Operations QA
C. Spinks, ERC Inspection Supervisor
P. Stevens, TUGCo Electrical Engineer
- J. F. Streeter, TUGCo Assistant to Executive Vice President
- T. G. Tyler, TUGCo CPRT Program Director
W. I. Vogelsang, TUGCo Electrical Coordinator
C. H. Welch, TUGCo QC Services Supervisor
J. R. Wells, TUGCo Director QA
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. NRR and IE Audit / Inspection Activities
a. NRR: An audit was performed on December 6, 1985, at Stone & Webster
Engineering Corporation (SWEC), New York City, New York, with respect
to status of piping and pipe support efforts, results of Procedure
CPP-8 engineering walkdown, and approach for resolution of special
technical issues. An audit was performed on December 10,1985, at
TERA, Bethesda, Maryland, of the system used to track CPRT status. A
site inspection was performed with Region IV participation during
December 12-13, 1985, of as-built information for Unit 2 cable tray
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supports. The results of the site inspection will be included in a
Region IV inspection report. A copy of the SWEC and TERA audit
reports will be placed in the Public Document Room upon completion,
b. IE: No inspection activity occurred during this report period.
3. Applicant Actions on Previous Inspection Findings
a. (Closed) Unresolved Item (445/8516-0-09): Apparent excessive length
of conduit between an end device and its associated junction box.
Additional review confirmed that the maximum conduit length require-
ment of Drawing 2323-El-1701, Revision 11, was applicable to this
installation. The failure to control the conduit length between the
end device and the junction box is an apparent violation
(445/8516-V-01). Additional information on this subject is contained
in paragraph 5.a of this appendix.
b. (0 pen)OpenItem(445/8511-0-14): Fire wrap damage. Additional
examples of damaged fire wrap blankets were observed on conduits
C15W11989, C15W11119, C15W16160, C14G19934, C14G19936, and C14Y11219.
The applicant has issued nonconformance reports (NCRs) E86-100003s
through E86-100008s for the above deficiencies. This item will
remain open pending NRC review of the Unit 1 area closecut procedures
which will, in part, require inspection for damaged fire wrap.
4. Assessment of Allegations
a. 4-85-A-34 (AQ-166): Inadequate Certification Testing of Electrical
Inspectors
It was alleged that inadequately structured tests were used to
certify electrical inspectors. The program for electrical inspector
qualification, training, testing, and certification has been
previously assessed by the NRC and is documented in NUREG-0797,
Supplement No. 7. The results of the NRC assessment are provided on
page J-58 of Appendix J, Supplement No. 7. The NRC found evidence
that the electrical QC inspector qualification program lacked pro-
grammatic controls and required the applicant to accomplish the
following: (1) evaluate the electrical inspector testing program and
develop a program that includes procedures for scoring retests, and
question disqualification; (2) justify bases for visual examinations;
(3) review all electrical inspector files for compliance with require-
ments;and(4)assessthegenericimplicationsoffindings.
The applicant responded to these NRC findings in Appendix C of the
CPRT Program Plan in ISAP Nos. I.d.1 and I.d.2. In ISAP Nos. I.d.1
and I.d.2, the applicant commits to, among other things, review the
qualification / certification of all current and historical electrical
inspectors and to reassess the total prcgram for inspector
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qualification / certification. NRC is currently evaluating the
responsiveness of the applicant's proposal and is inspecting the
implementation of the applicant's commitments.
In summary, the NRC substantiated the subject allegation during
earlier assessments and the applicant has initiated corrective and
preventive measures, which the NRC is continuing to inspect.
b. 4-85-A-103: Electrical Bonding Clamps and Improperly Rated Pump
Concerns were raised that: (1) the electrical cable tray grounding
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wire clamps were not acceptable because they were not Underwriters
Laboratory (UL) approved, and (2) the motors for the emergency diesel
generator (EDG) fuel oil (F0) transfer pumps were not of the
explosion proof design required for this application.
The concern over the acceptability of the cable tray grounding clamps
was based mainly on the fact that the devices were not marked with
identification which showed that they were acceptable to UL. NRC
inspector review of the grounding clamps in use showed that they are
[ Thomas & Betts Corporation, Catalog No. 10103, Grounding Connectors,
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made of malleable iron with a "Tabolite" finish.
Additional information from the manufacturer described "Tabolite" as
a tradename for electrozinc plating applied to the connectors and
showed that the connectors were UL listed in File E3066. Accordingly,
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the installed grounding clamps appeared to be acceptable.
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The concern over the acceptability of nonexplosion proof motors for
l the EDG F0 transfer pumps was also evaluated by the NRC inspector.
The National Electric Code (NEC), which is committed to by
Section 8.1.4.7 of the Final Safety Analysis Report (FSAR), was
reviewed to determine the normal industrial requirements for handling
flammable liquids. Since the EDG F0 is normally confined within a
closed system (from an underground tank through pipes to the transfer
pump through pipes to another tank), the NRC inspector determined that
the appropriate NEC classification for the EDG area was Class I,
Division 2. Article 501-8(b) of the NEC specifically allows the use
of nonexplosion proof mechanisms for handling flammable liquids in
Class I, Division 2 applications. Therefore, the NEC would not
require the use of explosion proof motors for the EDG F0 transfer
pumps.
The NRC inspector reviewed additional documents to further evaluate
the above concern.
A review of the FSAR showed the EDG FO was specified as No. 2 F0
(paragraph 9.5.4.2.2.5), and a review of the National Fire Code
produced the following additional information: (1) the flash point
for No. 2 F0 was indicated to be 126 F to 704 F (NFPA 325M); and
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(2) a flammable liquid was defined as a liquid with flash pc.nt below
100 F, while a combustible' liquid was one with a flash point above
100 F (NFPA 321).
Based on the above information, it was ascertained that the'EOG F0
was considered to be a combustible and not a flammable liquid.
Therefore, the electrical equipment installed to handle the EDG F0
was not required to meet the special precautians contained in
Article 500 of the NEC,,such as the use of explosion proof motors.
Accordingly, the use of nonexplosion proof motors for the EDG F0
Transfer Pumps was found to beJacceptable.
In conclusion, the concerns / allegations were not substantiated, nor
were areas of safety significance identified.
A copy of the inspection report will be providcd to the individuals
associated with these concerns.
5. CFRT ISAPs (Excluding ISAP No. VII.c)
a. Inspection Reports on Butt Splices (ISAP No. I.a)2) and Butt Splice
Qualification (ISAP No. I.a.3)
Status of CPRT Activity
Phase I and Phase II of the butt splice review have been completed.
TUGCo is presently performing Phase III of this issue under
NCRs E8S-100588s and E8-100630s. The required inspections and
procedure revisions for the butt splice qualification issue have been
completed. The draft results reports for these actions are being
prepared.
Status of NRC Inspection Activity
The NRC inspector performed a followup inspection of Unresolved
Item 445/8516-U-09 during this report period, as referenced in
paragraph 3.a of this appendix. The noted condition was observed
during witnessing of a reinspection of cable butt splices for two
solenoid valves, IHV-4631A and IHV-46318, for.. the primarytcoolant
sample supply return and isolation valves. . Detail 18C of ,
Drawing 2323-El-1701, Revision 11, which limits conduit length to -' -
15 feet between an end device and.its associated junction box, was
determined to be applicable to the cable for these solenoid valves. ,
The observed installed conduit length of approximately 30 feet is an
apparent violation (445/8518-V-01).
A reinspection of a field installed butt splice for electrical
penetration assembly IE76, for the Unit 1 containment spray isolation
valve tank, was witnessed during the period. The NRC inspector noted
during this inspection that the heat shrinkable tubing over vendor -
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installed outboard penetration conductor splices appeared to be
shorter than required by the tubing manufacturer. Additional review
raised questions in reference to the qualification and acceptability
of this assembly and other assemblies supplied by Bunker Ramo. This
issue is an unresolved item pending completion of an NRC special
inspection on this subject. (445/8518-U-02; 446/8515-U-01).
b. Guidelines for Administration of QC Inspector Tests (ISAP No. I . d. 21
Status of CPRT Activity
The Special Evaluation Team (SET) reviewed a sample of inspector
certificatiors which were given since the issuance of Revision 18 of
TUGCo Procedure CP-QP-2.1, "Trainirg of Inspection Personnel."
These certifications were reviewed to assess the implementation of
recent changes in the inspector certification program. Concerns
relative to certification of four inspectors were transmitted to the
TUGCo QC Manager. The TUGCo response is under evaluation by the SET.
Status of NRC Inspection Activity
The NRC inspector's review of the four SET questioned certifications
identified an apparent violation (445/8518-V-03; 446/8515-V-02). A
field performance demonstration was noted to have been administered
by a Level III who was not certified for that activity and on-the-job
training waivers were observed to have been granted without
identifying those procedures which formed the bases for the waivers,
c. Preoperational Testing (ISAP No. III.d)
During the NRC Technical Review Team (TRT) inspection of the
preoperational testing program, conclusions were reached indicating
that none of the related allegations and findings had safety signifi-
cance or generic implications, except that past document control
system problems may have affected the testing program. Details of
these conclusions and findings are in Safety Evaluation Report
Supplement No. 7 (SSER-7) dated January 1985. The primary concern
was that past preoperational testing may not have been conducted
using fully updated procedures because of the difficulties system
test engineers (STEs) had in obtaining design document updates.
In response to the TRT's concerns over possible past document control
impat.ts on testing, the applicant committed to actions that establish
measures to provide greater assurance that current design data was
utilized in testing, and to determine whether or not past document
control system problems had an adverse affect on the testing program.
In the ISAP, these commitments are broken down into three action
categories:
4.1.1 Assessments, administrative procedural changes, and training
to ensure an adequate program is in place to maintain test
procedures current.
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4.1.2 Detailed record reviews to determine the effect of DCC
problems on the testing program.
4.1.3 Determination of root cause(s) and evaluation of the
potential for generic implications.
The NRC followup inspection of actions taken in accordance with this
ISAP commenced with 4.1.1 during the previous inspection period of
November 1985. The results of this inspection are documented in
Appendix 0 of NRC Inspection Report 50-445/85-16; 50-446/85-13. For
tracking purposes, the paragraph numbers that appear in
ISAP No. III.d are indicated below. In this report period, inspection
continued with 4.1.2, which is a determination of the impact DCC
problems might have had on the testing program.
4.1.2.1 A random sampling program was established by the CPRT to
determine if DCC problems adversely affected the testing
program. First, the CPRT established the time period in
question, which was from the start of prerequisite testing
(prerequisite testing commenced before the start of
preoperational testing) until May 15, 1984. The May 15
cutoff date was set on the basis that CPSES Monitors Team
monitoring reports reported no significant DCC problems
that could affect testing past that date. Documentation
reviewed during this folloWJp inspection and TRT findings
reported in SSER-7 support this approach.
4.1.2.2 A review was performed to define the set of items to be
evaluated in the prerequisite testing and in the
preoperational testing areas. This review yielded a
population of potential test impact changes to design
documents from which to sample in accordance with the
sampling plans described in the'ISAP attachments. The NRC
inspector reviewed the documentation supporting this review
and found no problems.
4.1.2.3 The CPRT committed to perform a review of all prerequisite ,
test procedures (XCPs) to identify those which require the
use of documents controlled by DCC. All design documents
of this type were to be included in the prerequisite' test
population. The NRC inspector reviewed the documentation
population from which the random samples were drawn was
about 78,000 documents. There were no discrepancies found.
4.1.2.4 The CPRT committed to perform a review of preoperational
test procedures (pts) and retests to obtain a list of all
DCC-controlled flow diagrams and electrical schematics
that applied to preoperational testing during the period
of-interest defined in 4.1.2.1 above. Those tests that
were completely reperformed after the period of interest
were to be eliminated because any changes in_ design that
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might have been missed during the period of interest would
have been picked up by the subsequent reperformance test.
The resultant population of DCC-controlled documents
represented approximately 1100 items subject to change
without the Startup Organization being aware of it so that
the affected pts could be updated and/or retesting
performed. The NRC inspector reviewed the documentation
of the CPRT's review and sample population generation and
found no discrepancies.
4.1.2.5 As committed in the ISAP, the CPRT Task Force developed
detailed sampling plans as reflected in the attachments to
ISAP No. III.d. Upon reviewing the documentation files
supporting this action, the NRC inspector found no problems.
4.1.2.6 Examination of testing records was conducted on all 60 XCP
and all 60 PT sample items as evidenced by the signed
evaluation sheets which were reviewed by the NRC inspector.
The NRC inspector conducted a detailed inspection on
20 percent of the sample items. There were no problems
found in the XCP sample items; however, the PT sample items
showed that the STEs had failed in many instances to update
the pts prior to performance to show the current reference
drawing revisions. Section 4.9 of CP-SAP-21, " Conduct of
Testing," requires the STE to update the procedure prior to
performance to ensure the PT will adequately test the
current as-built design. Probing this further, the NRC
inspector checked all 60 PT sample packages and found that
34 of the packages contained data showing that pts were
conducted without evidence of having updated all of the
references. This finding was not identified and documented
by the CPRT as a discrepancy as committed in Appendix E to
the CPRT Program Plan. However, in all but three sample
packages, the CPRT conducted and documented a review of all
revisions since the tests were performed to ensure the
as-built systems were properly tested. No discrepancies
were identified. In the three cases where such a review
was not documented, the applicant's representatives assured
the NRC inspector that the review was performed in the same
manner as the others.
Since some of the samples referenced the same pts (because
many drawings are referenced in each PT), an actual total
of 26 pts were performed withcut the references updated in
accordance with CP-SAP-21, Section 4.9. Failure of the
CPRT Task Force to document and track this discrepancy is a
deviation from the commitment in Section D of Appendix E to
the CPRT Program Plan (445/8518-D-05).
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The issue of STE failures to fully update the referenced
drawing section of the pts was the subject of an unresolved
item (445/8502-08) and an open item (445/8502-12) in the
January 1 through February 28, 1985, NRC Inspection-
Report 50-445/85-02. These items were both closed in NRC
Inspection Report 50-445/85-14 (Appendix C) on the basis
that the drawing changes had no impact on the test. To
prevent this type of issue from emerging in the future, the
applicant has undertaken administrative control changes.
Review of these changes for acceptability by the NRC shall
be tracked as an open item (445/8518-0-06).
Twelve of the 60 sample items for pts did not have the
screening check lists fully completed. Screening check
lists were utilized by the CPRT to develop the minimum
sampling of 60 documents which have the highest probability
of impacting testing as a result of possible DCC problems.
The sample item numbers were P53, P104, P272, P298, P399,
P426, P432, P515, P518, PS20, P525, and P535. These items
included those discussed above which did not document a
CPRT Task Force review of all revisions made since the pts
were performed. Actions taken by the CPRT to complete
these records shall remain an unresolved issue pending
future discussion and followup inspection (445/8518-U-07).
The committed actions of 4.1.3, that is, the determination of root
causes, evaluation of the potential for generic implications, and
resultant corrective actions could not be inspected during this
report period because the final results report was not yet available.
Accordingly, the inspection will be performed at a later date and
shall be tracked to completion as an open item (445/8518-0-08).
d. Installation of Main Steam Pipes (ISAP No. V.e)
Status of CPRT Activity
The status of CPRT activity has not changed from the last reporting
period. The draft results report is being worked on by CPRT.
Status of NRC Inspection Activity
The CPRT performed repeat radiographic (RT) and Section XI ultrasonic
(UT) examinations on two welds in Loop 1 and two welds in loop 4 to
further support the analytical conclusions that the quality of piping
and welds was not affected by installation practices. NRC inspection
of these examination records confirmed CPRT findings that the quality
of the piping and welds was not affected. The NRC inspector also
verified that the RT and UT examinations were performed by personnel
certified to at least Level II in accordance with SNT-TC-1A-
requirements.
No NRC violations or oeviations were identified.
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e. Pipe Support Inspections (ISAP No. VII.b.3)
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Status of CPRT 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
Rainspection/ Documentation Review Plan."
(1) Room 77N Pipe Supports
Reinspection of the 178 oipe supports in Room 77N, identified as
, being nonconforming by the TRT, has been completed. Of the
238 deviations identified, 234 have been evaluated with 229
determined to be valid.
(2) TRT Issues - 42 Pipe Supports
Of the 42 pipe supports identified by the TRT as being
nonconforming, 40 have been reinspected by ERC. Physical
reinspections are being accomplished using ERC Quality Instruc-
tion (QI) QI-058, Revision 0. Of the 87 deviations identified,
to date, 46 have been evaluated and 44 were determined to be
valid.
Status of NRC Inspection Activity
(1) Room 77N Pipe Supports
To date, seven reinspections have been witnessed, none of which
occurred during this report period. Eight independent inspec-
tions have been conducted with the following one being performed
during this report period:
Verification Package No. Number System Unit No.
1-5-PS7N-061 H-CS-1-SB-054-013-2 Chemical 1
& Volume
Control
No NRC violations or deviations were identified.
(2) TRT Issues - 42 Pipe Supports
There were no NRC inspections performed in this area during this
report period.
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6. ISAP NO. VII.C
a. Electrical Cable
Status of CPRT Activity:
ERC completed 88 reinspections and 89 documentation reviews of
sampled electrical cable as of December 30, 1985.
Status of NRC Inspection Activity:
(1) NRC inspectors have, as of December 30, 1985, witnessed
21 reinspections, performed independent reviews of 10 documenta-
tion packages and performed 6 independent reinspections of
sampled electrical cable. The following three independent
reinspections of sampled electrical cable were performed in this
report period:
Verification Package No. System Cable No. Unit No.
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l I-E-CABL-025 Main Steam EG145713 1
I-E-CABL-026 Chilled Water
Recirculation Pump EG111199 1
I-E-CABL-092 Steam Generator
Loop 3 EG100475 1
(2) During the above independent reinspections, the following
conditions were identified:
I-E-CABL-026: (a) A cable run between T13GCCD71 and TBGCCM01
was not identified on cable schedule 2323-El-1700, and
(b) stainless steel banding had not been installed within
2 inches of the end of the separation' barrier material on conduit
C13G084248 as required.
These items were identified in the ERC reinspection and two
deviation reports (DRs) have been validated. However,
I-E-CABL-026 has been declared invalid by ERC based on incorrect
random digit selection and is being superseded by I-E-CABL-108.
Dispositions of these findings are an open item (445/8518-0-09).
I-E-CABL-092: (a) Conductor wire to terminal 3 at valve
1-HV-2493B had frayed insulation,-and (b) terminal lug
connections to the conductors connected to terminals 1 and 2 at
a
valve 1-HV-2493B were,not in accordance with procedures.
- Items (a) and (b) were identified in the ERC reinspection and NCR
E-85-101387 sx has been issued to_ correct these problems. !
Dispositions of these findings are an open item (445/8518-0-10). i
No NRC violations or deviations were identified.
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b. Cable Trays
Status of CPRT Activity
ERC has completed 90 reinspections and 84 documentation reviews of
sampled cable trays as of December 30, 1985.
Status of NRC Inspection Activity
(1) NRC inspectors have, as of December 30, 1985, witnessed 11 ERC
reinspections, performed 7 documentation reviews, and performed
6 independent reinspections of sampled cable trays.
(2) During this report period, an NRC inspection was conducted with
respect to compliance of cable tray and conduit identification
marking with program requirements. This review was initiated as
l a result of encountering difficulties in establishing the
j identities of certain cable trays and conduits during previous
inspections and was not specifically related to ERC inspections.
The following conditions were noted during this inspection:
(a) No identification or color coding existed on the following'
thermo-lagged cable trays (designated by letter T) and
conduits (designated by letter C):
o T14GADG02-03, T13GACN02-03, and T12GABQ15-16 in
Room 214 of the Unit 1 Auxiliary Building;
o conduit near conduit C1301S570 near the entrance to
Rooms 78 and 79 of the Unit 1 Safeguards Building;
o conduit to cable tray T130 SCC in Room 88 of the
Unit 1 Safeguards Building;
o T13G'ACD99 in Unit 1 Safeguards Building at elevation
i 790 feet (additional numbering problems existed in the
adjacent tray section); and
o conduit (which was partially identified as C14Y14) in
the Unit 1 Safeguards Building at elevation 832 feet.
(b) No color coding existed on the following thermo-lagged
cable trays and conduits:
o Located in the Unit 1 Safeguards Building:
T120SBC33 C13015570
T12GSBG10 C1305968
T12GSCE10
!
- , , - _.
. - - . -. . . .
- - - - .-. - . . - -. .
.- s
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o - Located in the Unit 1 Auxiliary Building: .
C13G13636'
t C13615200
i C14930881
, T13GACD10, 24, 26, 38, and 99
'
T12GABF33 and 36 ,
L T139ACA35, 42, and 75
- T129ABA13 and 17
i T14YAEH19,-20, and 25
l
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T14WAEF 19 and 20-
,
The above examples are an apparent violation of Gibbs.and Hill (G&H)
3
Specification 2323-ES-100, Revision 2, and Brown and Root (B&R)
] Procedure CP-CPM 10.3, Revision 9 (445/8518-V-11).
,
c. Electrical Conduit
i
Status of CPRT Activity
ERC has completed 72 reinspections and 72 documentation reviews of ,
- sampled electrical conduit as of December 30, 1985. The decrease
. from the numbers reported in NRC Inspection-Report 50-445/85-16;-
50-446/85-13 resulted from the invalidating of a number of selected
sample items because of inaccessible attributest The' packages which-
{ were determined to be invalid are being replaced with valid samples.-
j Status of NRC Inspection Activity
!-
i- The status of NRC inspection activity is unchanged from the previous
i
report period;.i.e., NRC inspectors have as of December 30,_1985,
j witnessed 14 ERC reinspections, performe'd 15 documentation package
i reviews and performed 5 independent inspections.of_ sampled electrical *
j conduits.
,
d. Instrumentation Equipment Installation-
! Status of CPRT Activity
i- ERC has completed 80 reinspections and-102 documentation reviews of
sampled' instrumentation equipment installations as of_ December 30, ,
1985. ;
1
Status of NRC Inspection Activity
,
(1) NRC inspectors have, as of December 30, 1985, witnessed 8 ERC~
reinspections, performed 5 documentation package reviews _and-
performed 7 independent-inspections of sampled instrumentation
equipment installations.
{ -
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.
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(2) During this report period, one independent inspection was
performed of Verification Package No. -I-E-ININ-053 (main steam
pressure transmitter 1-PT-2325, Unit 1) with the_following
inspection results:
(a) The tubing near the first " tee" from the instrument
appeared to have potential damage resulting from " weld
spatter";
(b) the tubing was not marked for size by color coding;
(c) the tubing was not marked for separation;
(d) the identification tag on the root valve was stamped
1-MS-020, 1-PT-2335 instead of the correct stamping of
1-MS-020, 1-PT-2325;
(e) the tubing had inverse slope at a point near the root valve
connection;
(f) separation spacing was not maintained on the tubing
routing; and
(g) the gland not was loose on the 3/8 inch globe drain valve.
Items (c) and (f) were identified in the ERC reinspection
report. Dispositions of these findings are an open item
(445/8518-0-12).
Items (a) and (g) are not attributes currently addressed by the
,
applicable ERC QI; i.e., QI-012. The failure of QI-012 to-
address these attributes is considered an unresolved item
(445/8518-U-13).
Items (b), (d), and (e) were not identified by the ERC
inspectors and were within the scope of QI-012. The failure to
identify these conditions is an NRC deviation (445/8518-D-14).
m
(3) During the NRC inspector's review of G&H Instrumentation )
Installation Specification 2323-MS-625, resulting from independent )
inspection activities for CPRT ISAP No. VII.C, it was observed i
that an incorporated design change authorization (DCA) required I
action by inspection personnel. DCA No.13,023 dated April 20,
1982, revised Section 9.0.g.10 of Specification 2323-MS-G25 to
add, " Tubing of instruments which are safety-related redundant
counterparts shall not be installed in contact with galvanized
material (zinc) wherever the tubing for these redundant counter-
parts is routed through the same fire zone. In all other
instances field erected tubing may contact galvanized material ~
(e.g., Unistrut Supports)." The engineering justification states,
mu
4
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"The concern here is fire precipitating zinc penetration into
stainless steel resulting in tubing failure. This could only be
a problem if safety-related tubing for redundant counterparts was
routed through the same fire zone. These instances will be
identified by a damage study walkdown of safety-related tubing in
fire zones and corrective action will be taken at that time."
However, a review of site documentation files, and discussions
with applicant personnel, revealed that this damage study
walkdown was not performed. Additionally, no information was
made available to indicate that it would be done. Subsequently,
the NRC inspector reviewed the following documents:
(a) TUSI " Field Design Change Control Procedure," CP-EP-4.6,
Revision 7, dated November 13, 1980;
(b) TUSI " Design Change Control Procedure-DCRP's," CP-EP-4.7,
Revision 0, dated November 30, 1979;
(c) TUSI " Field Design Change Control Instructions,"
CP-EP-4.6.1, Revision 8, dated February 22, 1982; and
(d) TUGC0 " Design Change Verification" Procedure, CP-QP-15.4,
Revision 0, dated August 17, 1981.
The review of these documents revealed that measures were not
established to assure the performance of design adequacy
verification / inspections required by DCA statements /justifica-
tions. The lack of such design change control measures is an
apparent violation of Criterion III of Appendix B to 10 CFR
Part 50 (445/8518-V-15).
e. Piping System Bolted Joints / Materials
Status of CPRT Activity
ERC has completed 73 reinspections of piping system bolted joints /
materials out of the total random and engineered sample size of 73.
Eight valid DRs were generated as a result of the above reinspections.
ERC has also completed 68 document reviews of these packages, with 9
valid DRs being issued to date.
1
)
a
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Status of NRC Inspection Activity
The NRC inspector performed document reviews of the following
packages during this report period:
Verification
Package No. Drawing No. Flange No. Unit No. * System
R-M-PB0M-34 BRP-SI-1-RB-048 1 1 SI .
R-M-PB0M-46 BRF-CH-1-SB-021 3 1 CH
- SI - Safety Injection System, CH - Ventilated Chilled Water System
During the above document reviews, it was noted that ERC had
identified the following as subject to evaluation as a potential
deviation:
R-M-PB0M-046: No heat number, lot number, or color code for the
studs were recorded on the construction operation traveler.
Dispositions of the above findings are an open item (445/8518-0-16).
No NRC violations or deviations were identified.
f. Inspection of Non-Pressure Boundary Welds for a Supplementary
Evaluation of Visual Welding Inspection Techniques
Status of CPRT Activity
The purpose of this inspection activity is to provide information
that will supplement the conclusions previously reached concerning
visual reinspection of nonpressure boundary coated welds. Randomly
selected samples of previously ...spected and accepted safety-related
nonpressure boundary welds obtained from ISAP Nos. VII.b.3,
ISAP VII.b.5, and ISAP VII.c are being inspected in accordance with
the applicable code, before and after removal of coatings.
Status of NRC Insnection Activity
The NRC inspector has reviewed QI-062, Revision 0, " Evaluation of
Non-Pressure Boundary Welds for a Supplementary Evaluation of Visual
Inspection Techniques," and witnessed, to date, the following 11 ERC
reinspections of coated welds:
/
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Verification Unit
Pkg. No. Equipment Tag No. System No.
I-S-NPBW-021 VA-X-005-702-A73R HVAC Common (1)
I-S-NPBW-035 AF-1-043-001-Y43R Auxiliary Feedwater 1
I-S-NPBW-053 CS-1-241-010-A42R Chemical / Volume Control 1
I-S-NPBW-048 CS-1-058-701-A42R Chemical / Volume Control 1
I-S-NPBW-007 D0-1-DG009A-004-3 Diesel Oil 1
I-S-NPBW-063 AF-1-001-021-Y33K Auxiliary Feedwater 1
I-S-NPBQ-059 MS-1-RB-010A-013-2 Main Steam 1
I-S-NPBW-042 P-18/CMK-D22(SG) Structural Steel 1
I-S-NPBW-075 SW-1-007-700-J035 Service Water 1
I-S-NPBW-030 SI-1-104-001-C425 Safety Injection 1
I-S-NPBW-023 CS-1-SB-053B-008-2 Chemical / Volume Control 1
At this time, no welds have had paint removed, which is required for
implementation of the second phase of the inspection. While witnessing
ERC's performance of weld inspections, the ERC inspector identified
that a fillet weld attaching item 1 to item 2 of pipe support
CS-1-SB-053B-008-2 was 1/16-inch undersize for 25% of the joint length,
and that two fillet welds attaching item 29 of pipe support
SI-1-104-001-C425 to existing pipe support SI-1-051-008-C42R were each
approximately 1 inch underlength.
The NRC inspector's review of documentation associated with these
supports revealed that they had previously been inspected by ERC as
required by ISAP No. VII.c, "Small Bore Pipe Supports," and "Large Bore
Pipe Supports Non-Rigid." The documentation further revealed that ERC
failed to identify the undersize and underlength welds during the
previous reinspections, as required by Revision 0 to QI-019 and QI-029.
The failure to identify discrepant weld conditions is an NRC deviation
(445/8518-D-17).
g. Large Bore Pipe Supports - Non-Rigid
Status of CPRT Activity
ERC has completed 75 reinspections of non-rigid large bore pipe
supports out of the combined random and engineered sample size of 82.
A total of 268 deviations have been currently identified of which, to
date, 210 have been determined to be valid. Documentation review of
80 original installation packages has been completed, resulting in the
identification of 8 valid deviations. ERC is reviewing the valid
deviations for safety significance.
Status of NRC Inspection Activity
The NRC inspector did not witness or perform independent inspections
during this report period.
No NRC violations or deviations were identified.
a
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h. Large Bore Pipe Supports - Rigid
Status of CPRT Activity
Reinspection /ve'.'ification of the combined random and engineered sample
consisting of 89 pipe support installations by ERC has been completed.
A total of 180 DRs have been issued, 129 of which have been determined
to be valid while the remaining 51 are being evaluated. Seven
previously validated DRs were voided as a result of ERC's safety
significance evaluation establishing from evaluation of field
conditions that the DRs were, in fact, invalid.
Documentation review of original installation packages by ERC has been
completed. A total of 150 DRs have been issued, 4 of which have been
determined to be valid, while the remaining 146 are being evaluated.
ERC has determined that 79 of the total valid deviations (reinspection
and documentation) are not safety significant while the remainder are
being evaluated for safety significance.
Status of NRC Inspection Activity
To date, six independent inspections of pipe support installations
have been performed, with the following inspection being performed
during this report period:
!
! Verification Pkg. No. Pipe Support Mark No. System Unit No.
I-S-LBSR-009 SW-1-004-015-A33R Service Water 1
No NRC violations or deviations were identified.
i. Reinspection of Containment Liner and Tank Stainless Steel Liner
Status of CPRT Activity
Reinspection of the combined sample of 91 containment liner and tank
stainless steel liner packages is 100% complete. Eighty-two valid
deviations have been identified during physical reinspection. Document !
review of the 91 packages is also 100% complete with 28 valid
deviations identified. Valid deviations are being reviewed for. safety
significance. i
Status of NRC Inspection Activity
I
There was no NRC inspection activity during this report period.
l
j. Structural Steel i
Status of CPRT Activity
Reinspection of the 107 structural steel packages in the combined first
and second samples is approximately 16 percent complete. Twenty-seven
__ __ ___ _
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valid deviations have been identified. -QI-046, Revision 0, for
documentation review has been issued; however, review activities have
not yet been initiated.
Status of NRC Inspection Activity
.
(1) The NRC inspector has, to date, witnessed nine reinspections
representing approximately 8 percent of the combined first and
second samples. The following two ERC reinspections were
witnessed by the NRC inspector during this report period:
Verification Package No. Equipment No. Building Unit No.
I-S-STEL-117 MEDC0 Mk No.D2 Reactor 1
I-S-STEL-236 MEDC0 Mk No.C7 Reactor 1
(2) During the above reinspections, the ERC inspector identified the
following condition as subject to evaluation as a potential
deviation:
I-S-STEL-117: Bolt material was rejected due to incorrect
marking.
Disposition of the above finding is an open item (445/8518-0-18).
No NRC violations or deviations were identified.
k. Concrete Placement
Status of CPRT Activity
Reinspection of the combined first and second samples consisting of
97 concrete placement packages is approximately 70% complete.
Twenty-six valid deviations have been identified relating primarily
to unfilled holes, voids, and debris in the concrete surface.
Documentation review procedures have not yet been issued.
Status of NRC Inspection Activity
,
(1) The NRC inspector has, to date, witnessed 14 reinspections l
representing approximately 14 percent of the combined first and i
second samples. The following two ERC reinspections were
witnessed by the NRC inspector during this report period: 1
l
Verification Package No. Concrete Placement No. Building Unit No. I
I-S-CONC-080 IRCN-CPC-002-9792-008 Auxiliary Common
I-S-CONC-130 IRCN-CPC-002-6873-003 . Auxiliary Common
i
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s
%
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(2) During the above witnessed reinspections, the ERC inspector
identified the following condition as subject to evaluation as a
potential deviation
I-S-CONC-080: Anchor bolt projection was out of tolerance.
Disposition of the above finding is an open item (445/8518-0-19).
No NRC violations or deviations were identified.
(3) The NRC inspector has, to date, independently inspected six
concrete placements representing approximately 6% of the
combined first and second samples. The following concrete
placement was independently inspected during this report period:
Verification Package No. Concrete Placement No. Building Unit No.
I-S-CONC-019 IRCN-CPC-205-9810-034 Diesel 2
Generator
No NRC violations or deviations were identified.
1. Small Bore Pipe Supports
Status of CPRT Activity
Reinspection of small bore pipe supports is 100% complete with 76
supports reinspected. Eighty-three DRs have been issued with
fifty-nine valid deviations identified to date. Clarification of
embedment requirements has resulted in a reduction in the number of
valid deviations from the 67 reported in NRC Inspection Report
50-445/85-16; 50-446/85-13. These deviations relate primarily to
Hilti bolt embedment, bolt hole spacing and edge distance in base
plates, and pipe clearances. Documentation review of the 76 supports
is also 100 percent complete with 31 valid deviations identified.
Status of NRC Inspection Activity l
(1) The NRC inspector has witnessed seven reinspections representing
approxinately 9 percent of the combined first and second samples.
The following ERC reinspection was witnessed by the NRC inspector
during this report period:
Verification Package No. Pipe Support No. * System Unit No.
I-S-SBPS-284 CH-2-AB-008B-002-3 CH 2
- CH - Ventilated Chilled Water System
No deficiencies were noted by ERC or NRC inspectors with respect
to this verification package.
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e l
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(2) The NRC inspector independently inspected during this report
period the following five small bore pipe supports representing
approximately 7% of the first and second samples:
Verification Package No. Pipe Support No. * System Unit No.
I-S-SBPS-051 GH-X-AB-051-004-3 GH Common
I-S-SBPS-067 CH-1-SB-004-013-3 CH 1
I-S-SBPS-003 CH-1-SB-014-002-3 CH 1
I-S-SBPS-254 CS-1-111-703-C425 CS 1
I-S-SBPS-017 CC-1-EC-006-005-3 CC 1
- CC - Component Cooling Water System
CH - Ventilated Chilled Water System
CS - Chemical and Volume Control System
GH - Gaseous Waste Processing System
No NRC violations or deviations were identified.
m. Pipe Whip Restraints
Status of CPRT Activity
ERC has completed 47 reinspections of pipe whip restraints out of the
planned combined random and engineered sample size of 110. Nineteen
valid DRs have been identified.
Status of NRC Inspection Activity
(1) The NRC inspector has witnessed five ERC reinspections, to date,
of which the following occurred during this report period:
Verification Package No. ' Support Identification * System Unit No.
I-S-PWRE-536 MS-1-12-903-T57W MS 1
- MS - Main Steam System
No deficiencies were noted by ERC or NRC inspectors with respect
to this verification package.
(2) The NRC inspector performed the following two independent
inspections during this report period:
Verification Package No. Support Identification * System Unit No.
I-S-PWRE-528 FW-2-019-912-C47W FW 2-
I-S-PWRE-545 SI-0590 F30 SI 1
- FW - Steam Generator Feedwater System
SI - Safety Injection System
6
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During the prior ERC reinspections, the following condition was
identified as subject to evaluation as a potential deviation:
I-S-PWRE-528: Location of the bumper on the baseplate was out of
tolerance from what was shown on the drawing.
Disposition of this finding is an open item (446/8515-0-03).
No NRC violations or deviations were identified,
n. Instrument Pipe / Tube Supports
Status of CPRT Activity
ERC has completed 83 reinsp6ctions of instrument pipe / tube supports
out of the combined random and engineering sample size of 102. Three
hundred and ninety-eight DRs have currently been issued. One hundred
and forty-two DRs have been validated from a total of one hundred and
seventy reviewed by the population engineer.
One document review has been performed by ERC, with one valid DR being
issued.
Status of NRC Inspection Activity
(1) The NRC inspector has performed, to date, a total of five
independent inspections of which the following occurred during
this report period:
Verification Packaoe No. Instrument Tag No. * System Unit No.
I-S-INSP-023 1-PI-978 SI 1
- SI - Safety Injection System
(2) During the prior ERC reinspection of this verification package,
the following cor.ditions were identified as subject to evaluation
as potential deviations:
Baseplate die stamp was not visible through the paint and the
fillet weld between the baseplate and the structural tubing was
undersized by 1/16 inch.
Dispositions of the above findings are an open item (445/8518-0-20).
(3) The NRC inspector noted during independent inspection with
respect to support 0230, that the bolt on the Unistrut clamp was
not torqued to the value specified by attribute 4.7 in QI-055.
Signoff by the ERC inspector of this attribute as being acceptable .
is an NRC deviation (445/8518-D-21). l
O
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Upon review of the ERC inspection checklists for Verification
Package No. I-S-INSP-023, it was noted that supports 023A and
023C had been marked as "N/A" with respect to attribute 4.5.
This attribute deals with the use of spring nuts. Independent
inspection showed, however, that spring nuts were used on these
two supports for a bolted connection. The failure to inspect
attribute 4.5 is an NRC deviation (445/8518-D-22).
o. Documentation Review of Fill and Backfill Placement
Status of CPRT Activity
Documentation review of the sample of 180 fill and backfill placements
is approximately 66 percent complete. A total of 317 deviations have
been identified and are being evaluated for validity. No physical
reinspections are planned.
Initially, two populations were identified: (1) 719 placement packages
for the safe shutdown impoundment (SSI) dam for the period April 21,
1976, to April 29, 1977; and (2) 101 placement packages associated
with other fill and backfill activity. Sixty sample packages were
randomly selected from each population by ERC. TUGCo identified the
packages for each population. An additional 219 packages were
discovered during the document review process that should have been
included in the second population. The original 101 packages in the
second population are TUCGo inspection reports subsequent to July 12,
1978. The 219 additional packages are B&R inspection checklists for
the period August 18, 1977, to July 12, 1978. An additional 60 packages
were randomly selected from this third population, increasing the
total number of fill and backfill packages from 120 to 180.
Status of NRC Inspection Activity
To date, no independent NRC inspections of documentation have been
performed.
p. Field Fabricated Tanks
Status of CPRT Activity
Reinspection / verification of field fabricated tank installation has
been completed. A total of 14 DRs have been issued of which 8 have
been determined to be valid. Documentation review of original i
installation packages by ERC has been completed with a total of 46 DRs )
issued, none of which have currently been reviewed by the population
engineer for validity.
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Status of NRC Inspection Activity
Planned NRC physical inspections were documented in NRC Inspection
Report 50-445/85-16; 50-446/85-13.
No NRC violations or deviations were identified.
q. Large Bore Piping Configuration
Status of CPRT Activity
ERC has completed 75 reinspections of large bore piping configuration
out of the combined random and engineered. sample size of 82. The
sample size has decreased from 99 to 82 due to the random selection of
common verification packages in both.the random and engineered sample.
Forty-one valid DRs have been identified.
Status of NRC Inspection Activity
(1) The NRC inspector has witnessed, to date, seven ERC reinspections
of which the following occurred during this inspection period:
Verification Package No. Drawing No. * System Unit No.
I-M-LBCO-091 BRP-CS-2-AB-035 CS .2
I-M-LBCO-092 BRP-MS-1-BB-002 MS 1
I-M-LBC0-127 BRP-CC-1-AB-008 CC 1
- CS - Chemical and Volume Control System
MS - Main Steam System
CC - Component Cooling Water System
(2) During the above reinspections, ERC identified the following
conditions as subject to evaluation as potential deviations:
(a) I-M-LBCO-127: Valve did not have an id'entification tag or a
flow direction tag.
(b) I-M-LBCO-091: Clearances between the pipe and other pipes
and supports did not meet the required dimensions. ,
Dispositions of the above findings are open items (445/8518-0-23 and l
446/8515-0-04).
No NRC violations or deviations were identified.
r. Small Bore Piping Configuration
,
Status of CPRT Activity- l
ERC has completed 73 reinspections of small bore piping configurations
out of the combined random and engineered sample size of 88. The
_ . . _ . - __- . . _ - _ _ _ . - _ . . _ . _ _ . . . - _
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combined sample size was reduced from a previous figure of 95 to 88,
because of the random selection of common verification packages in
both the random and engineered samples. Thirty-four valid DRs have
been identified.
Status of NRC Inspection Activity
(1) The NRC' inspector has, to date, witnessed seven ERC reinspections
of which the following occurred during this~ inspection period:
Verification Package No. Drawing No. * System Unit No.
,
I-M-SBC0-083 BRP-MS-1-RB-021 MS 1
- MS - Main Steam System
(2) During the above reinspection, ERC identified the following
condition as subject to evaluation as a potential deviation:
Required clearances were not met between: (a) the pipe and an
adjacent pipe, and (b) the pipe and an adjacent hanger. '
1
Dispositions of the above findings are an open item (445/8518-0-24).
i
,
No NRC violations or deviations were identified.
'
(3) The NRC inspector performed the following independent inspection
during this inspection period:
Verification Package No. Drawing No. * System Unit No.
I-M-SBC0-022 BRP-CH-X-AB-055- CH Common
- *GH - Gaseous Waste Processing System
On the above verification package, ERC identified during their
reinspection the following condition as subject to evaluation as
a potential deviation:
Required clearances between the pipe and adjacent pipes were not
met.
Disposition of the above finding is an open item (445/8518-0-25).
While performing the above independent reinspections, the NRC
inspector observed that a socket welded coupling, with a specific ,
> location shown on the piping isometric drawing, was covered with i
I insulation. Consequently, verification of this linear dimension l
,
'
could not be performed. However, attribute 1.d which deals with '
linear pipe dimensions shown on the piping isometric drawing was
signed off as acceptable.
,
-- - ,-- . e .,,,..-+g.-m.,,,e . ,,mw,.- -g, --m-m--m-, . .-n--,----~nv- ---- --.n. - - , - - - - - ,-
-
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This incorrect designation of acceptability is an NRC deviation
(445/8518-D-26).
Upon review of the ERC inspection checklist for Verification
Package No. I-M-SBCO-22, it was noted that N/A was inserted by
the population engineer for attribute 1.1, Mechanical Joint
Location. This attribute dealt with bolted flanges being
dimensionally located in accordance with the piping isometric
drawing. Independent inspection revealed, however, the presence
of four bolted flange connections.
The failure of the engineer to designate applicability of mechanical
joints is an NRC deviation (445/8518-D-04).
It was additionally noted that the ERC. inspector failed to
identify the engineer's error during reinspection of this sample
item.
'
7. Exit Interview
An exit interview was conducted on January 7, 1986, with the applicant
representatives denoted in paragraph 1 of this appendix. Dur.ng this
interview, the NRC inspectors summarized the. scope and findings of the
inspection. The applicant acknowledged the findings.