ML20199G420

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Partially Withheld Comments by Technical Review Team Consultant T Workinger on Draft Qa/Qc Ssers,Category 5 Re Repair,Rework & Maint
ML20199G420
Person / Time
Site: Comanche Peak, 05000000
Issue date: 01/29/1985
From: Tang R
NRC
To: Livermore H
NRC
Shared Package
ML20197J178 List: ... further results
References
FOIA-85-59 NUDOCS 8606250220
Download: ML20199G420 (11)
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Note to: Herbert Livermore Group Leader QA/Q ,f,f From: R.C. Tang

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Subject:

Comments by TRT Consultant Ted Workinger on .

. Draft QA/QC SSERs, Category 5

. The following comments are submitted for consideration with respect to preparing the final SSERs for QA/QC. These comments address the content and statements in the SSERs, rather than editorial corrections. Note that these comments pertain to draft copies of QA/QC SSERs that were sent to me in mid-December.

SA. Repair, Rework and Maintenance All of the draft SSERs in Category SA were reviewed and we have only two minor comments as follow:

A0-43, 47 and 51 (Rev. 2 - 10/24/84)

The last sentence of Section 5, on page 5, makes a cross reference to Mechanical and Piping, Category 4. A more specific reference should be added in the final SSER.

7 AQ-52 (Draft 2 - 10/12/84) i It is suggested that the last item in Section 5, on page 5, be changed as I indicated in the marked-up copy of the SSER. g 8606250220 860611

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PDR FOIA GARDE 85-59 PDR a

1 58. Onsite Fabrication We have no comments relevant to AQ-77 and AQ-79.

AQ-138 [S m l

It is suggested that the last paragraph of Section 6, on page 18, be deleted.

The treble hook on a thirty-foot stainless steel chain is not related to the i emergency Icw-fuel-limit switch nor the diesel fuel storage system. It is speculated that someone had the fron fab shop make this item, possibly, for

-their pers~onal use.

y' SC. Housekeeping AQ-54 and 65 No comments i 5D. Nonconformance Reports, A0-30, et al (Draft 7 - 10/8/84)

1. This is a long SSER. To assist the reader,-it is suggested that the format consist of sub-sections, i.e. , 4.1 A0-30 and A0-31, *
  • 4.15 i

'AQ-120.

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2. The last d g = , at the top of page 17, states, "
  • however, the issuance of that many NRCs would seem to warrant the preparation of a corrective action request, but none was available."' The author meant none was prepared.

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3. On page 23, Section 6, Actions Required. Rather than allude to items noted in AQ-34 and AQ-36, statement "a". should say specifically what actions are required. This comment also applies to statement "b.(3)" in the next paragraph. -
4. On page 24, Section 7, Potential Violations. Item b. appears to be related to the incident regarding ANIS not reviewing CSTPs, MRSS, and WDCs between February 1980 and March 1981, which is addressed in QA/QC Category 2, AQ-134. Since corrective action had been taken, AQ-134 did not find any actions required or note any potential violations. What are we alluding to here?

SE. Materials We have no comments relevant to AQ-12, 13, 14, and 115, AQ-41 and AQ-53 A0-5 (Rev. 1 - 10/11/84)  ;

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1. Section 4, page 2, discusses the corrective actions that were taken in response to ASME surveys in October 1981 and January 1982. It is not clear what explicit, additional, actions TUEC must take to respond to Section 6, Actions Required. d.MtIe.ef 50#8-d 2.

\el. 0 On page 4, Section 7, Potential Violations. The date at the end of the statement, " - - - as identified by ASME survey of October 1984.", is wrong. It should be 1981. & CAAJ. b ',

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A0-40 (Rev. 1 - 10/9/84)

Regarding the fourth sentence, of the second paragraph, of Section 4, on page 1, "Over the years . . . paints of different colors . . . where depleted.",'it i is not clear whether TUEC ran out of paint or colors. We believe the author meant colors. - N e

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Some of the above comments are reflected in the attached markedrayT6Fies of ti. w J~~ -

the relevant SSERs from QA/QC Category 5.

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2. S-47: Work perfcrmed on system without inspection item removal notice (IRN).
3. S-50: Rework of items completed prior to disposition approval.
5. Conclusion and Staff Positions: Based on their review of applicable documentation, the TRT concludes that all aspects of the allegations can be substantiated. However, identified unauthor.ized rework and welding, are documented with NCRs. The TRT did not identify any significant breakdown in the quality control program, although isolated preblems did occur. The safety significance of the allegations relating to undocumented repair welds is addressed in Mechanical and Piping Category 4.

In a meeting with the alleger on December 10, 1984, the TRT presented the results of the assessment of allegation AQ-43 and the TRT's conclusion.

A brief discussion ensued. There were no major items of disagreement, and no new concerns or allegations were identified. Q g f my m-swkALuvuase s m QQ w p

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8. Attachments: None.
9. Reference Documents:
1. 676 NCRs dated between March 1976 and August 1984.
2. Permanent Equicment Transfer Forms (PETS) No. 4 through No.1665.
3. CP-SAP-6, Revision 9.
4. CP-CPM-12.2.
5. AQ-43: GAP 2.206 Petition, dated March 19, 1984 and A-1 s:stement.
6. AQ-47: GAP Petition, dated March 19, 1984.
7. AQ-51: A-14 Testimony pp. 1, 4, 5, 10, 14, 16, 26-2S and Q-4-34-001.
8. Components - CP1-CCEXCC-07 S/N 290950 thru S/N 290959 S/N 12120 CPI - SWAP 5W-01 & 02 CF2 - SWAFSW-01 & 02

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. 10-12-84'* Draft 2 sser format /CP2

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1. Allegation. Group: QA/QC SA, Repair, Rework, Maintenance. ,

, 2. Allegation. Number: AQ-52

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! 3. Characterization: It. .is alleged -that site, personnel, interchanged J.t parts of unidentified. diaphragm valves during. site disassembly /

reassembly operations. It is believed that part traceability to the ,

5 .ves was lost und the valves operability is questionable.

4. As .ssment of Safety Significance: The implied safety significance of this allegation is that installed valves may have interchanged parts not designed to withstand the service pressure and temperature of the system in which they are installed and, therefore, may fail to func-tion during system operation. .

l ~$((TRTreviewedfourprocedureswhichwereineffectpriortoJune8, i ~

l  %)53, governing the assembly / disassembly of ASMI valves. The TRT found no specific procedural requirements to assure valves parts were not lost / interchanged following disassembly. Some mechanical i

equipment valve 'MEV) travellers did contain specific steps to package l

I and tag components following disassembly to insure that traceability l

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1 were documented in nonconformance reports, recent problems associated with maintaining control of qnntiry certified valve components

- indicates.the problem still exists in spite of many corrective action steps taken over the pcst years.

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5. Conclusion and Staf f Positions: Based on the infornation obtained during field inspections, document review, and interviews with Quality 7

Control, engineering and craf t personnel, the TET concludes that the Nalve asse=bly/ disassembly process has resulted in components. being e lo'st/ misplaced or interchanged. It is. the staff position that f ailure 55 of the corrective action system to adequately address this recurring problem has safety significance du A Llim .g m.ma relating de-

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otential gauling or even valve f ailure if valve bonnets from similar valve of different pressure ratings are mixed.

6. Actions Required: TUEC shall accomplish the following actions prior to fuel load:

Identify those similar diaphram valves s h dif fering pressure 1.

ratings that had potential for bonnet interchange, in the following systems:

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Revision 1 - 10/11/84 AQ-5/SSER/ CP2A

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. SSER

1. Allegation Group: QA/QC Categury No. SE 2.' Allegation Number: AQ-5
3. Characterization: It is alleged that lack of material traceability for safety-related materials and components has occurred.
4. Assessment of Safety Significance: The implied safety significance of '

this allegation is that if Texas Utilities Electric Company (TUEC) f ailed .

to maintain material traceability for safety-related materials and hard-I ware components, defective material may be installed that will not perform .

its intended safety function. h The NRC Technical Review Team (TRT) reviewed the Brown & Root (B&R) '

Quality Assurance Manual, Section 8.0,. dated May 17, 1978. Paragraph 8.2 of the manua1 requires that if material with material traceability identi-

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{ fication is cut into more than one piece, the identification (or heat num- ."

bers) shall be transferred, before cutting, to the other pieces. A QC inspector shall then verify that heat numbers have been transferred. Sec-tion 8.0 of the B&R manual, dated August 14, 1981, continued to require i

verification of heat numbers by a QC inspector prior to subdividing material. Quality Instruction QI-QAP-11.1.28, Revision 25, required QC verification of material heat numbers prior to subdividing and also required that this heat number remain distinguishable until the fabrication i

and instaliation of component supports were accepted by QC.

! During an ASME Boiler and Pressure Vessel Code survey at Comanche Peak l Steam Electric Station (CPSES) or October 12 - 14, 1981, the ASME survey I

team determined that B&R did not verify the transfer of material identi-fication! The ASME survey team also determined that control of material salvaged from vendor-supplied components was inadequate. As a result,

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g\ significant changes to the QA program were made prior to a resurvey by the t

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.. Based on review of records and interviews with craf t, ' inspection, and engineering personnel, the TRT determined that since the identification and correction of the deficichcies reported by the ASME survey team, clarification of the QA program for material control has been maintained and has been handled in accordance with TUEC's accepted QA procedure CP-QAP-8.5, " Reclassification of Code Material," Rev. 4.

5. Conclusion and Staff Positions: Based on its review, the TRT concludes that the allegation that TUEC failed to maintain material traceability for safety-related material and numerous hardware components was substantiated.

TUEC did have procedures for material traceability, as required by 10 CFR 50, Appendix B, Criterion VIII; however, TUEC had not followed these procedures.

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A partial breakdown in the QA program did occur, as documented in NCRs M-3033 and M-3258; and although corrective act. ions were taken and were

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- documented in accordance with TUEC QA procedure CP-QAP-8.5, TUEC failed to l report the breakdown to the NRC per 10 CFR 50.55(e) requirements; The TRT notes is that the allegation itself has neither safety significance nor

-generic"irr.plications, in that the condition ha7 s'ince been corrected.

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6. Actions Recuired: Prior to fuel load, TUEC shall review their1 reporting system to assure that the causes for failing to report construction

- deficiencies has been corrected.

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8. Attachments: None. -

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9. Reference Documents: ,
1. Procedure CP-QAP-S.5.
2. E&R Manual, Section S.O
3. Item 5 of A-2 letter to U. 5. Department of Labor, dated March 7, 1984.
4. Pages 26 thrcugh 34 cf A-2 interview.
5. Special Inspection Services :(SIS) reports 367A, and 367.
6. Interof fice Memorandum (IM) 26, 407, SIS 367-E; IM 26,159 SIS 369, SIS 369-B, IM 26, 729.

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. .- Revision 1 - U -A

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SSER AQ-40/ CPI V

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1. Allegation Grouo: 0A/QC Category No. 5E e

j 2. . Allegation Number: AQ-40 l

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3. Characterization: It is alleged that heat numbers were obtained inappro-priately in the field for materials used in safety-related applications.

a l 4. Assessment of Safety Significance: The implied safety significance of l this allegation is that the acceptability of work performed with unknown N f heat numbers would be questionable and the quality of the installed. *

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! materials would be ind'eterminate, g

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.In assessing this allegation, the Technical . Review Team (TRT) reviewed the Brown & Root (B&R) quality assurance manual and procedures addressing (

material traceability and interviewed inspection personnel. The TRT could I

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find 310. evidence that material heat numbers were being assigned in the -

field, with the exception of color-coded material. Texas Utilities l

Electric Company (TUEC) used a color coding system to maintain heat number I trac'aability for tubing material. Over the years of the plant construc-tion, paints of different colors compatible with nuclear stainless steel j tubing were depleted. TUEC then, assessed the feasibility of using the

( same colors for different material requiring traceability. The engineering personnel made the decision to use green to identify tubing for heat number M7632, even though green had previously been used to denote tubing heat number 402095. The Comanche Peak Steam Electric Station (CPSES) quality assurance (QA) manager had extensive material testing conducted on M7632 to assure its conformance to specification and its intended use. This testing would have prevented the use of any defective material.

CPSES Engineering acknowledged the fact that if either heat number 402095

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or M7632 was identified later as defective, both heats of material would-

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