ML20199G432
| ML20199G432 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, 05000000 |
| Issue date: | 02/04/1985 |
| From: | Tang R NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| To: | Livermore H NRC |
| Shared Package | |
| ML20197J178 | List:
|
| References | |
| FOIA-85-59 NUDOCS 8606250225 | |
| Download: ML20199G432 (17) | |
Text
'o UNITED STATES
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[.' g NUCLEAR REGULATORY COMMISSION f WASHINGTON, D. C. 20555 74 f
- February 4, 1985
.tiOTE T0: Herbert Livermore Group Leader, QA/QC g,
I M FROM: R. C. Tang, Comanche Peak TRT
SUBJECT:
COMMENTS BY TRT CONSULTANT TED WORKINGER ON DRAFT QA/QC SSERS, CATEGORY 8 - AS BUILTS The following comments are submitted for consideration with respect to preparing the final SSERs for QA/QC.
A0-44 and 128 ~
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No comments. .(,, .p.p.,! j U . , ? < t ,1
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A0-50 We do not have a copy of this SSER.
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g A0-55 and 78 i> a:$[M d
No comments.
A0-135 (Draft 5 - 1/14/85)
Attached is a marked-up copy of AQ-135, which contains the authors mark-up in black and our suggestions in red ink. For the most part, these ccmments are editorial in nature.
On pages 4 and 5, of Section 4, this SSER discusses a finding of inconsistency regarding the levels of unsatisfactory attributes documented in inspection reports, which in some cases resulted in an NCR, a.nd in other cases did not.
This issue is also addressed in the last paragraph on page 12, Section 5, wherei_n it is stated: This finding has generic implications for TUEC's entire inspection and corrective action programs for the design and construction of CPSES.
We suggest that additional sentences are required to clarify the significance of this finding and to place it in perspective.
SSER QA/QC Category 50 discusses a number of issues related to the issuance and dispositions of NCRs. The TRT in its assessment of AQ-36 noted that procedure CP-QP-16.0, "Nonconformance," Rev. 14, defined a nonconformance as "a deficiency in characteristic, documentation, or procedures, which renders the quality of an item unacceptable or indeterminate." TRT also noted that because this definition is so all-encompassing, it may have been difficult to determine when an NCR was required and when a CMC or DCA was adequate.
8606250225 860611 PDR FOIA GARDE 85-59 PDR
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Herbert Livermore -2.
SSER QA/QC Category 6, AQ-35, discusses a related issue concerning when an IR results in a DCA, CMC or NCR, i.e. B&R procedure CP-QAP-16.1, " Control of
, Nonconforming Items," and TUGC0 procedure CP-QP-18.0, " Inspection Reports."
The TRT also located two interoffice memoranda that stated that only items that could not be resolved with an IR, DCA or CMC were to be written as NCRs.
Although QC inspectors had difficulties deciding between alternative methods for correcting an unsatisfactory item in an Ik, which resulted in administrative inconsistencies relevant to the issuance of NCRs, we question whether this has significant, broad, generic implications relevant to TUEC's entire inspection and corrective action programs. Accordingly, additional sentences are suggested, which narrow the scope of this finding and place its significance into perspective.
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. CP8C - AQ-135 Rev. 1 - 2/1/85
- SSER
- 1. Allegation Category: QA/QC, Category 8
- 2. Allegation Number: AQ-135
- 3. Characterization: It is alleged that the post-construction serification program (PCVP) was conducted in such a manner that it failed to adequately process the results of quality control (QC) inspections as It is alleged that the scope and
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required by 10 CFR 50, Appendix B.
depth of the program were inadequate, that reviews of identified -
deficiencies were inadequate,'and that management of program results was 5
inadequate. ,
'The PCVP was alleged to be: (1) a " blitz inspection" consisting of an
" instant review and an instant fix," (2) of narrow scope, encompassing only a few cable trays, (3) an inspection program'with no requirement to identify problems which were fixed on-the-spot, and (4) a program that was stopped prematurely in February 1984.
The alleger maintained that the PCVP was a " violation of law" that lacked ~
~
data on engineering review of identified problems and a method of tracking and trending deficiencies.
The alleger asserted that the PCVP was "out of control" and that the facility constructor, Brown and Root, Inc. (B&R), was " turning over a mass" to the owner, Texas Utilities Electric Company (TUEC).
4 4 ,. , .~e ... -. . . . - - . , .-
- 4. Assessment of Safety Sicnificance: The implied safety significance of this allegation is that an inadoquately managed and supervised inspection program may: (1) fail to identify and correct actual quality-related probl, ems; (2) fail to ensure timely and effective correction of identified problems; and (3) fail to analyze quality-related problems for fundamental, underlying causes and for adverse trends with generic implications. If this allegation were substantiated, the quality conditions of portions of the facility would be indetenninate.
The TRT Technical Review Team (TRT) found that in FSAR Section 8.1.4.3, TUEC coninitted to implementing Institute of Electrical and Electronics
' Engineers, Inc. (IEEE) standard 336-1971, " Installation, Inspection, and .
' ~
Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations." Section 6 of this standard requires that post-construction verification consisting of the inspection of installed equipment and systems be conducted. This requirement states that installed equipment and systems shall be inspected to verify the following: (1) that equipment and materials have not sustained damage during installation, (2) that good and proper workmanship has prevailed, (3) that the installation has been made in accordance with specified re,quirements, (4) that all nonconforming items have been satisfactorily resolved, (5) that appropriate protective measures are applied for lay-up after installation, and (6) that all .
temporary conditions such as jumpers, bypass lines, and temporary set .
points have been clearly identified so that subsequent restoration can be ascertained prior to placing the items in service.
The TRT found through interviews with the managers, supervisors, and inspection personnel associated with the PCVP that TUEC chose to implement IEEE-336 with a series of post-construction inspections of instrumentation, electrical equipment, and raceway. These post-construction inspections followed in-process and final inspections and were made prior to a plant area being turned over to the startup testing organization. Therefore, the post-construction inspections reexamined previously inspected equipment and raceway.
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TUEC's written descript~ ion of the PCVP was contained exclusivelf in administrative.and implementing procedures. The TRT found no higher-tiered post-construction inspection plan to describe the s. cope, control,.and management of the PCVP. The TRT reviewed these procedures as a part of its c"mination of this allegation.
TUEC managers and supervisors involved in the PCVP indicated to tne TRT that other post-construction inspection activities were conducted in a similar manner, i.e., they occurred after final inspection. These other activities included: (1) the American Society of Mechanical Engineer's (ASME) N-5 certification program conducted by B&R, (2) post-constructior.
inspections of Hilti anchor bolt separation, and (3) post-construction -
verification of baseplates, grouting, and Richmond inserts.
',, TUEC managers also indicated that startup testing personnel made
- sdditional room and system walkdowns prior to testing, as did plant
- operations . personnel prior to TUEC's fomal acceptance of these rooms and systems. These walkdowns were not considered to be inspections, and were not necessarily conducted by personnel certified as inspectors in
, accordance with American National Standards Institute (ANSI)/ASME i
N45.2.6-1978; however, these.walkdowns served to identify and control the correction of any remaining identifiable deficiencies.
l The TRT concentrated its review on those pcst-construction inspections -
implementing IEEE-336 and on the final walkdown and acceptance by TUEC plant operations.
4 Based on its review of TUEC's written description of the PCVP, the TRT found two principal programmatic weaknesses. These were: (1) lack of a program plan for :.he PCVP, and (2) lack of writ +.en guic'ance on the type or level of deficiency which required issuance of a nonconformance report
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(NCR).
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. The fir't weakness found in the PCVP was not a violation of regulatory requirements, since TUEC complied with IEEE-336 by implementing procedures QI-QP-11.3-40, " Class IE Electrical Post-Construction l Verification," and QI-QP-11.8-14, " Instrumentation System Turnover."
Nonetheless, this weakness indicated the lack of a management program to define the scope of the post-construction verification program. The lack of a program plan could have lead to the perception of inadequate scope, as maintained by the aT1eger.
The second weakness'in the PCVP did not constitute a regulatory violation, but was considered to be significant by the TRT and to have e,.lateA 4.
broad generic implications cad involved a lack of defined thresholds for -
triggering corrective actions. In ascending order, the corrective action systems available to TUEC personnel as a part of the PCVP and other inspection activities ~ at CPSES were: (1) line items on punchlists, deficiency reports (DRs), and deficiency lists (DLs), which were attached to inspection reports (irs); (2) unsatisfactory irs, (3) NCRs; (4) corrective action reports and corrective action requests (CARS); and (5) reports submitted to the NRC in accordance with IQ CFR 21 and 10 CFR 50.55(e).
During the review of TUEC's PCVP, the TRT found no guidance other than general definitions of how to initiate a higher-tiered corrective action -
I system for an identified problem. In particular, the TRT found no -
guidance concerning the types or levels of unsatisfactory IR attributes that required generation of an NCR.
During interviews with PCVP personnel, the TRT found a nearly universal understanding that an NCR was required for those deficiencies for which '
an engineering evaluation was necessary. In addition, most personnel interviewed stated that an NCR was initiated for those deficiencies that
//., ,-
could not be corrected using normal craft procedures. Thcac wcc.::pt: and only miminal guidance for NCR initiation 'were contained in TUEC procedures, CP-QP-16.0 and CP-QP-18.0.
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A further indication of the lack of effectiveness of some of TUEC's procedures on nonconformances appeared in an error in Revision 20 to CP-QP-18.0. Section 3.2 of this procedure described the processing of irs. The third paragraph of Revision 20 to this procedure, issued August 9, 1984, stated:
When all unsatisfactory conditions have been corrected and reinspected and accepted, or when an NCR or superseding IR has been prepared for the unsatisfactory condition (s) per approved procedures / instruction, the QC Inspector shall Block 16). The closed IR shall then be forwarded to the PPRV by the IR clerk. -
Evidently, some portion of the first sentence was missing from line 4.
6 The TRT noted this error on October 2, 1984, and discussed it with TUEC management, who confirmed the error. They also noted that the same error had be'en present in Revision 19. Such an error in a procedure was not surprising; however, its uncorrected existence th ough t two revisions issued two months apart caused doubts regarding the usefulness of this procedure among the personne.1 who generated and processed irs.
The TRT reviewed TUEC's program for trending nonconformances which were .
generated as a result of the PCVP. The trending program was described in -
CP-QP-15.7 and CP-QP-17.0, and the results were documented in quarterly trending reports issued by TUEC's site QA organization. The TRT found that the description of analytical considerations of the trending program was weak in that the procedures listed above failed to include: (1)a discussion of data normalization to account for the effects of varying construction or inspection activities, (2) guidance on the characterization of nonconformances, (3) me,thods for determining fundamental underlying causes of nonconformances, and (4) guidance for using the trend analysis results'to initiate CARS.
9
i The allegation that the PCVP was not trended was incorrect; however, the quality and uses of this trending were weak. The TRT found that the
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. quarterly trend reports contained little more than gross statistical categorizations of different types of deficiencies in the form of tables and bar graphs. The TRT did not find analytical descriptions of the data i
. or discussions of any determination of the root causes o.f significant nonconforming conditions; however, the quarterly trend reports ,did contain a tabulation of deficiencies identified by the PCVP.
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{ A typical categorization contained in the fourth quarter 1983 trend I report identified a total of 1168 deficiencies (through the PCVP) with the following breakdown: .
Work Incomplete /Not per Requirements 778 Procedure Violation (Upgraded to NCR) 0 3 Poor Workmanship / Improper Hardware 8 Bend Radius Violations O Color Code /ID Violations 288
- Continuity Check /Megger Failure 0 Damaged Equipment / Cables 94 Raceway Unacceptable for Pull 0 Hilti Bolt Violation /No Sealant - 0 The TRT examined TUEC's prog, ram for final acceptance of systems and areas by plant operations. This program was described in STA-802 and was designed to take place after all final QC inspections and all post- ,
construction verification were completed, and following testing by the i .
startup organization. The program included a review of master data base items, a review of test results and outstanding deficiencies, a verification of the accuracy and adequacy of drawings needed to support operations, and system and area walkdowns.
Walkdowns were conducted by operators, instrument and control tschnicians, electrical and mechanical maintenance personnel, radiation protection personnel, and plant engineers from the plant operations organization. TUEC personnel stated that walkdowns were not intended to serve as a final construction QC inspection, but were intended to take advantage of the perspective of plant operations personnel to identify l
y . . -- .. - . - . - . . . - . . . .
those items requiring' resolution as a part of TUEC's final 3cceptance of the facility. Items identified during the STA-802 walkdowns included hardware condition problems, problems with equipment access for operability and maintainability, and potential problems from a radiation protection standpoint. Items identified as a result of the STA-802 program were documented, tracked, corrected, and reviewed by managers and supervisors. The TRT found that the STA-802 program went beyond regulatory rcquirements and was an effective inechanism for ensuring the operability of the facility prior to fuel load.
To evaluate the effectiveness of the PCVP and to determine the merits of the allegation, the TRT reviewed: (1) 22 irs associated with the PCVP;
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(2)attachmentstotheIRs,includingpunchlists, post-construction .
deficiency reports and lists, electrical equipment punchlists, 'and deficiency reports; (3) selected NCRs; (4) quarterly trending reports for 1983 and 1984; and (5) CARS written during 1983 and 1984.
As a result of its review of the PCVP documentation, the TRT observed that irs were sometimes generated later than the attach'ed DRs, punchlists and other attachments. Two examples of irs with this characteristic were numbered PCV-1-0028616 and PCV-1-0016954. TUEC personnel stated that during the early stages of the PCVP, irs were not always initiated at the start of a post- construction inspection for a particular room. In some cases irs were generated after completion of a room inspection; in .
others, irs had not been generated for a particular room. In the latter -
instances, the post-construction inspection was repeated for those rooms.
TUEC's practice at the time of the TRT review was to initiate an IR at the start of the inspection. In all cases examined by the TRT, irs were closed after all unsatisfactory attributes had been corrected anc satisfactorily reinspected by QC.
Because the unsatisfactory IR was the administrative vehicle for 1 racking correction., reinspection, and closecut of identified deficiencies, the lack of timely generation of IRp lends credence to the allegation that the PCVP discrepancies were not always tracked. However, the TRT review indicated that TUEC strengthened the program to include timely initiation
a
, 4 of irs. Furthermore, in November 1983, TUEC shifted tracking
- responsibilities for unsatisfactory irs to the Paper Flow Group (PFG),
A TRT review of the PFG administrative control system showed that the PFG was not only tracking unsatisfactory irs, but was also tracking the correction, reinspection, and closecut of individual deficiencies using the computerized master data base (MDB). The TRT determined that the MDB was an effective management tool that was updated continually.
The TRT observed that there was no documented QC supervisory review of irs and attachments. The TRT found that the IR form did not contain blanks for a QC lead inspector or supervisor to document his or her .
review with a signature and date. In some cases, individual supervisors documented a review by signing in an open space at the bottom of the IR 3 form. TUEC's IR procedure, CP-QP-18.0, did not describe supervisory review of irs.
The TRT found that during the 19 revisions to QI-QP-11.3-40, 8 different DR and punchlist forms were promulgated to list the individual deficiencies and to serve as attachments to an IR. None of the forms attached to the various versions of the procedure contained blanks for signatures or dates to denote a QC supervisory review. However, some of the printed DR forms used by TUEC did contain blanks for QC superv'sory .
review. The TRT determined through a review of records that these -
signature blanks were not always used. Procedure CP-QP-18.0 did r ot address QC supervisory review of irs; however, TUEC QC supervisors stated that they reviewed the irs and attachments as part of their nor'aal practice.
The TRT considered TUEC's lack of a formal mechanism to document QC supervisory review to be a weakness that became more significant when coupled with the lack of guidance on the level of a deficiency that would require initiating an NCR.
_ _ _ i....___ - - -
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The TRT observed the lack of a consistent administrative control system to ensure that.all required attachments were 'part of a given IR. During a review of TUEC's written program, the TRT found no description.of a method which ensured that all required punchlists and DRs remained attached to an IR. Some individual inspection groups sequentially numbered each attachment and denoted the total number of attachments on
- the IR, but other irs reviewed by the TRT contained several attachments, each labled "page 1 of 1," with no indication of the total number of DR l or punchlist pages. TUEC supervisors stated that the responsibility for completeness of an IR package rested with the inspector generating the IR. TUEC's later practice of entering individual deficiencies into the MDB tended to mitigate the adverse consequences of this weakness. -
The TRT observed an inconsistency between the post-construction
, deficiency report (PCDR) and electric equipment deficiency report (EEDR).
Revision 19 to QI-QP-11.3-40 included both an attached PCDR form with a blank for a QC reinspection signature and date and an attached EEDR fom withou't such a blank. The PCDR was used to document raceway deficiencies, and the EEDR was used to document el.ectrical equipment deficiencies. The TRT was unable to determine any reason for this inconsistency. .
TheTRJfoundthatNCRsgeneratedduringapost-constructioninspection .
were not always listed on the IR. Such NCRs were listed with the -
t particular deficiency on the DR or punchlist, but these were not cross-referenced to the appropriate block (block 15) on the IR. This cross-reference was a specific procedural requirement of QI-QP-11.3-40, Revision 18; however, not one of the 22 irs reviewed by the TRT included this cross-refererice. -
The TRT also found that some DR forms were.used that were not described in an approved procedure. Three of the irs examined by the TRT had foms attached entitled " Post-Construdtion Verification Deficiency Report" (emphasis added) that were not included with any of the 19 revisions to QI-QP-11.3-40.
4
In addition, the TRT found that inappropriate attributes were listed on an IR and an incorrect DR was used. IR E-1-0015374 listed attributes'
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j applicable to cables and raceway which were marked as unsatisfactory.
l The attached DRs were intended for raceway, but described deficiencies associated with a single piece of electrical equipment (an emergency l light fixture) rather than those associated with raceway.
l l
The TRT noted that there were unexplained line-outs on a DR. Twenty-six i -
deficiencies on IR PCV-1-0034919 were lined-out and no indication of the reason for the line-out was provided. The TRT could not determine whether the items had been incorrectly recorded, if entries had been duplicated, or if there was some other plausible reasdn. .
7 Individually, these weaknesses found by the TRT have little safety significance; however, collectively, they point to a program that, although subject to management review and evaluation, suffered from a lack of administrative precision. The TRT considered the following weaknesses to be far more significant, particularly when coupled with the progrannatic weakness regarding the lack of guidance for initiation of NCRs.
The TRT reviewed deficiencies listed on irs and found a number similar deficiencie'sfor which an NCR was initiated in some cases, but not in .
others. Examples of these deficiencies are as follows: .
i cables not properly trained into a motor control center lack of torquing of limit switch cover fasteners
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lack of color coding on conduit and junction boxes missing identification l
- broken flexible conduit i .
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.- The TRT also found some deficiencies listed which appeared to require an engineering evaluation or repair or rework using other than normal construction procedures. However, these were not listed with an NCR
/ number. Examples of such deficiencies are as follows:
rusted terminal points tw'isted lugs broken' terminal blocks I-
- a bent' transformer top j
- corrosion in a cable tray 6
- 5. Conclusion and Staff Positions: The TRT found much of this allegation to .
be without basis. THE PCVP was not a " blitz inspection" consisiting of an
" instant review and an instant fix" that was stopped prematurely in 1984.
Rather, the PCVP was an. ongoing program beginning in 1982 and continuing for Unit 1 in October 1984. (The PCVP for Unit 2 had not yet begun.)
The TRT could find no evidence that the PCVP failed to document problems
, which 'were identified by QC but were corrected- by the craft persennel on-the-spot. The PCVP was not limited in scope to "only a few cable
- trays"; however, the alleger's perception of a limited program is understandable due to the lack of a program plan for the PCVP and due to the limited regulatory basis contained in IEEE-336.
Contrary to the allegation, TUEC's PCVP was not "a violation of law," .
namely the Atomic Energy Act of 1954, as amended. In fact, the PCVP met TUEC's regulatory commitments to IEEE-336. The PCVP included tracking and trending of all identified deficiencies including line items en DRs and punchlists, unsatisfactory irs, NCRs, and CARS. However, the TRT did find TUEC's trending program to be weak.
The alleger's assertion that the PCVP lacked an engineering review of identified. problems was essentially correct, since only NCRs and separation violations received dngineering review. The vast majority of 3 deficiencies identified during the PCVP were minor and inappropriate for '
engineeringreview,forexample,chippedpaintandicosecabinet fasteners.
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The alleger's description of the PCVP being " cut of centrol" and E&R
" turning over a mess" to TUEC was exaggerated. Hcwever, the TRT did find
. that the PCVP suffered frc= a number of administrative weaknesses that collectively detracted frc= a smooth running program. Based on its review of the PCVP and related programs, the TRT did not find that S&R -
was " turning over a mess" to TUEC. On the contrary, TUEC's final acceptance by plant operations appears to have been thorough',
well-managed, and effectively implemented. The final acceptance program, ,
- which followed the PCVP and testing, was specifically designed :: prevent
. TUEC's acceptance of "a mess."
In summary, the TRT concludes that the PCVP meets the requirements of .
IEEE-336. Most aspects of the allegation were not. substantiated, had no safety significance, nor any generic implications. However, the allegation of inadequate review of identified deficiencies led the TRT. to
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detenaine a significant prcgrammatic weakness involving the lack cf guidance on the level of deficiency needed to initiate an ftCR. This ckd finding has generic implications for TUEC's entire inspection and 3
,, 7 corrective action programs for the design and construction of CFSES. MM Review of this allegation also led the TRT to conclude that TUEC's program for trending nonconf.ormances was weak.
- 6. Actions Recuired: TUEC shall review its corrective action systers and .
develop written guidance describing the thresholds of deficiencies and .
nonconformances that trigger increasingly higher tiers of corrective action. ,
TUEC shall refine and further develop its trending program to include
- descriptions of data normalization, trend analysis, rect cause ceter-mination, corrective acticn, tracking, and close-out.
- 8. Attachments: tione.
___.~ 1 _
____...a e' -
- 9. Reference Documents:
" Electric Power." -
- 2. Texas Utilities Generating Company (TUGCO-TUEC's operating division and wholly owned subsidiary) Quality Assurance Procedure CP-QP-15.0, Revision 4 " Tagging System."
- 3. CP-QP-15.7, Revision 2, " Tracking of Audit Reports / Corrective Action Reports."
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- 4. CP-QP-16.0, Revisions 12 and 14, "Nonconformances."
- 5. CP-QP-17.0, Revision 4, " Corrective Action."
- 6. CP-QP-18.0, Revision 20, " Inspection Report."
- 7. QI-QP-3-29, Revision 16, " Electrical Separation."
- 8. QI-QP-3-29.1, Revision ,16, " Verify Electrical Separation."
- 9. TUGC0 Quality Assurance Instruction QI-QP-11.3-40, Revisions 0 .
through 19, " Class 1E Electrical Post-Construction Verification." -
- 10. QI-QP-11.8-14, Revision 3. " Instrumentation System Turnover."
- 11. TUGC0 Startup Administrative Procedure CP-SAP-3, Revision 12,
" Custody Transfer of Station Components."
- 12. CP-SAP,-16, Revision 8, " Test Deficiency and Nanconformance Reporting."
i
- 13. CP-SAP-20, Revision 2, " Guidelines for System Walkdown Inspections."
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- 14. CPSES Station Administrative Procedure STA-802, Revision 2, " Final Acceptance of Station Systems, Structures and Equipment."
- 10. This statement prepared by:
C. Haughney, Date TRT Technical Reviewer Reviewed by:
H. Livermore, Date Group Leader *
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Approved by: -
V. Noonan, Date Project Director s .
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OUTGOING TRANSMISSION SERVICE REQUEST
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