ML20199L020
| ML20199L020 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/04/1986 |
| From: | Barnes I, Ellershaw L, Hale C, Andrea Johnson, Will Smith, Wagner P, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20199K948 | List: |
| References | |
| 50-445-85-16-01, 50-445-85-16-1, 50-446-85-13, NUDOCS 8604100278 | |
| Download: ML20199L020 (34) | |
See also: IR 05000445/1985016
Text
.
APPENDIX D
COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
,
NRC Inspection Report:
50-445/85-16
Permits: CPPR-126
50-446/85-13
CPPR-127
Category: A2
Dockets:
50-445
e
50-446
Applicant: Texas Utilities Electric Company (TUEC)
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas
75201
Facility Name: Comanche Peak Steam Electric Station (CPSES). Units 1 & 2
Inspection At: Glen Rose, Texas
Inspection Conducted: November 1-30, 1985
Inspectors:
e
d
Y / 76
L' E. Ellershaw, Reactor Inspector, Region IV
Dalfe /
CPSES Group
(paragraphs 1, 5, 6.g - 6.h, 6.k. 7.f - 7.t)
3htf86
W. F. Smith, Resident Reactor Inspector (RRI)
Date
Region IV CPSES Group
(paragraphs 1, 6.c - 6.f)
ck$t s
+/Wh6
[ C. J. Hale, Reactor Inspector, Region IV
Date
CPSES Group
(paragraphs 1, 2, 3, 4, 6.b, 6.1 - 6.j)
_
&Oh$
?
G
.
.
2
9 C.uk e
ahus6
P. C. Wagner, ReactTr Inspector, Region IV
Date
CPSES Group
d
,
(paragraphs 1, 6.a. 7.a - 7.e)
Sm
B/&/P&
p A. R. Johnson, Reactor Inspector, Region IV
Date
CPSES Group
Consultants: EG&G - R. Bonnenberg, J. Dale, L. Jones, A. Maughan, W. Richins,
R. VanderBeek
Parameter - J. Birmingham, D. Brown, J. Gibson, K. Graham,
D. Jew
Reviewed By:
%
w4//J%
I. Barnes, Group Leader, Region IV CPSES
Date
Group
//hj/C
Approved:
'
T. F. Westerman, Chief, Region IV CPSES Group
Date
Inspection Summary
Inspection Conducted: November 1-30, 1985 (Report 50-445/85-16; 50-446/85-13)
Areas Inspected: Nonroutine, unannounced inspection of applicant actions on
previous inspection findings, Hilti bolt inspections, and Comanche Peak Response
Team (CPRT) issue - specific action plans (ISAPs). The inspection involved
2008 inspector-hours onsite by 6 NRC inspectors and 11 consultants. A summary
of NRR and IE audit / inspection activities is provided in paragraph 4 of this
appendix.
i
Results: Within the three areas inspected, four violations (unacceptable design
basis for grouting Richmond inserts, paragraph 5; failure of QC inspectors to
detect undersize welds, paragraph 6.k; failure to verify confomance to procedure
requirements for Hilti bolt installation, paragraph 6.k; QC inspector acceptance
of an HVAC duct system exhibiting damage and an unacceptable gasket gap, para-
graph 7.k) and three deviations (failure to comply with approved instructions in
'
performance of reinspections, paragraphs 7.a. 7.b
7.e. 7.1, 7.1, 7.n, and 7.q;
inadequate quality instruction (QI) for liner measurements, paragraph 7.1;
inadequate review of reinspection documentation, paragraph 7.n) were identified.
.
'
.
3
DETAILS
1.
Persons Contacted
- S. R. Ali, TUGCo Staff Engineer, TUGCo Nuclear Engineering (TNE)
W. Bailey, ERC Supervisor, QA/QC Reinspection Engineering
- C. T. Brandt, TUGCo Quality Engineering Supervisor
- D. W. Braswell, TUGCo Engineering Superintendent, Plant Operations
C. I. Browne, Project Manager, R. L. Cloud & Associates, Inc.
-
(RLCA)
R. Brown, ERC Lead Civil / Structural Engineer
- R. E. Camp, Assistant Project General Manager, Ur.it 1 (Impell
Corp.)
J. Cardoza, TUGCo System Engineer
J. D. Christensen, ERC Deputy QA/QC Review Team Leader
- D. E. Deviney, TUGCo Operations QA Supervisor
J. Finneran, TUGCo Lead Pipe Support Engineer
- S. M. Franks, Special Projects and Technical Support Lead (Impell
Corp.)
E. L. Gastenel, TUGCo System Test Engineer
- P. Halstead, TUGCo Site QC Manager
- J. L. Hansel, ERC QA/QC Review Team Leader
J. Honekamp, TERA TRT Issues Manager
- C. R. Hooten, TUGCo Project Supervisor, THE Civil
- R. A Jones, TUGCo Manager, Plant Operations
D. M. McAfee, TUGCo QA Manager
G. M. McGrath, TUGCo Licensing / Compliance Supervisor
- J. T. Merritt, TUGCo Assistant Project General Manager, Unit 2
- C. K. Moehlman, TUGCo Project Mechanical Engineer
- A. A. Patterson, ERC Reinspection Engineering Supervisor
- F. L. Powers, TUGCo Unit 1 Building Manager
C. M. Puffer, TUGCo System Test Engineer
- G. R. Purdy, Brown & Root (B&R) QA Manager
J. G. Red, TUGCo Technical Support Supervisor
- R. B. Seidel, TUGCo Operations Superintendent
- J. C. Smith, TUGCo Operations QA
C. Spinks, ERC Inspection Supervisor
- J. Streeter, TUGCo Executive Assistant to Executive Vice President
P. Streeter, TERA Senior Mechanical Engineer
P. Turi, TEPA Issue Coordinator
- W. I. Vogelsang, TUGCo Coordinator, Electrical and Instrumentation
and Controls
- C. H. Welch, TUGCo QC Services Supervisor
- D. W. Westbrook, TUGCo Project Control Supervisor, Pipe Support
Engineering
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.
.
.
4
2.
Applicant Actions on Previous Inspections Findings
(Closed) Unresolved Item (445/8514-U-19):
Certification to QI-QP-11.8-7
could not be located for a TUGCo inspector who performed original inspec-
tion with respect to instrumentation installation Verification Package
No. R-E-ININ-060. Additional documentation was located by the applicant
i
during this report period which resolved the question concerning the TUGCo
'
inspector's certification to QI-QP-11.8-7.
3.
CPRT Program
The applicant's responses to the detailed NRC staff coments on the CPRT
Program Plan, Revision 2, were forwarded to NRR by TUGCo letter of
November 22, 1985. This submittal included a preliminary copy of the
umbrella QA program; i.e., CPRT Third-Party Quality Assurance Program.
4.
NRR and IE Audit / Inspection Activities
a.
NRR: A site inspection was performed on November 5 and 20, 1985, of
the Stone and Webster (SWEC) walkdown. An audit was performed at
Ebasco, New York, on November 8, 1985, to review specifications and
design documents related to cable tray / conduit supports. A site audit
was performed on November 11, 1985, of the construction adequacy
program as it relates to the SWEC piping and pipe support effort. A
CCL test of conduit supports and components was observed at Charlotte,
North Carolina, on November 13, 1985.
A site inspection was performed
with Region IV participation during November 18-22, 1985, of as-built
drawings for Unit 1 cable tray supports. An audit of homogeneity of
design activities was performed at TERA, Bethesda, Maryland, on
November 4-6 and 12-13, 1985. An audit was performed on November 25,
1985, at SWEC, New York, with respect to nonseismic piping effects on
seismic design piping.
b.
IE:
Inspection activity which was performed, in part, in November 1985
Es previously documented in NRC Inspection Report 50-445/85-14;
50-446/85-11.
Copies of reports for these activities will be placed in the Public
Document Room upon completion. The results of the Unit 1 cable tray
support inspection performed by NRR and Region IV will be documented in a
Region IV inspection report.
5.
Hilti Bolt Inspection
An independent measurement inspection was performed by NRC Region I
personnel during September 9-19, 1985, which was documented by Appendix F
of NRC Inspection Report 50-445/85-13; 50-446/85-09. This inspection
included examination of 124 installed Hilti anchor bolts with respect to
'
.
5
embedment depth, bolt spacing and length, and diameter of individual bolts.
One bolt was identified by ultrasonic examination (UT) during this inspec-
tion as appearing to be underlength.
Separate subsequent reexaminations by
applicant and Region IV personnel confirmed that the questioned bolt was,
in fact, of the correct length. Applicant personnel noted, however, during
their verification activity that six other Hilti bolts used in the support
installation were identified by their marking (i.e., star stamp) as being a
Super-Hilti type, although the drawing required use of only a regular Hilti
type. UT by applicant personnel of these bolts identified that the bolts
were misidentified, in that they were established to actually be regular
Hilti bolts.
As a result, nonconformance report (NCR) M-18708 was initiated on
September 26, 1985, in order to properly document and correct this
condition. Concurrently, corrective action report (CAR) 058 was initiated
,
in order to:
(a) identify Super-Hilti design required installation loca-
'
tions which were installed prior to March 1982, and (b) to perform UT on a
randomly selected sample of 60 supports. March 1982 was the date on
which application of the star stamp, designating Super-Hilti type bolts,
became a QC controlled operation.
The CAR further stated that any identi-
fied deviations from design would be cause for expansion of the sample to
100% of all Super-Hilti installations made prior to March 1982.
Because of the potential for installation of misidentified regular Hilti
bolts rather than the design required Super-Hilti bolts, NRC Region IV
initiated an independent inspection. A total of 64 ASME component
supports, which were located inside containment and containing 247 anchor-
bolts, were selected for UT. Of the 247 anchor bolts examined, 246 were
identified with the star-stamp marking. All of these were verified to be
of the Super-Hilti type.
UT of the one unmarked anchor bolt revealed that this bolt was not a Hilti.
The original construction / installation documentation package was reviewed
in order to assess the condition. The package did not reflect usage of
anything other than the required Hilti bolt. Discussions with applicant
personnel resulted in their review and subsequent identification of
Component Modification Cards (CMCs) which had been misfiled. The CMCs
revealed that a Richmond insert had been substituted for a Super-Hilti
bolt. Further investigation revealed that Design Change Authorization
(DCA) 10633 dated July 20, 1981, had been issued which allowed the use of a
shorter Super-Hilti than what was originally called for; i.e.,11 inches.
This apparently was the result of an interference.
The 11-inch Super-Hilti was installed between July 20, 1981, and August 24,
1981. Subsequently, DCA 13349 dated May 17, 1982, was issued allowing the
replacement of i.he Super-Hilti with a Richmond insert. An associated
Concrete Chipping Request (CCR) dated May 24, 1982, indicated that the
Super-Hilti had pulled out.
Required calculations to support the modifica-
tion were performed on June 19, 1982. The CCR provides the following
instruction: " Chip out concrete 5 inches dia. x 8 inches deep for 1 inch
Richmond insert." A handwritten note on the CCR states, " Complete 5-26-82."
An inspection report (IR) No. IRC-7542 dated February 10, 1983, attests
that all grouting pre-placemeat, placement, and inspection attributes were
satisfactory.
0
6
During the NRC inspector's review of the above documentation, it was noted
that DCA 13349 failed to provide instructions or procedures for the accomp-
lishment of the modification activity.
It was further noted that the
calculations failed to consider the shear capacity of the grout-concrete
interface.
These conditions constitute a violation of Criterion III of Appendix B to
,
10 CFR Part 50 (445/8516-V-08).
s
6.
CPRT 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 II actions for ISAP No. I.a.2 have been completed and Phase III
reinspections are in progress.
The splices involved in the reinspec-
tions are environmental butt splices, and uninsulated splices covered
with heat shrink tubing.
The applicant has completed the reinspection
of 38 of the 76 cables listed in NCR E-85-1006305, Revision 1.
Status of NRC Inspection Activity
The review of CPRT ISAP Nos. I.a.2 and I.a.3 has been completed and
the review of the Phase III program is in progress.
A review of the
results of 10 cable reinspections, Work Orders C850003404 and 3441,
showed that the following NCRs were generated:
NCR No.
Item (s) Identified
E85-101532
One conductor was twisted and the cable
bend radius was violated.
E85-101533
Butt splice " shims" were not installed
as had been indicated on a previous IR.
E85-101534
The flexible conduit had a cut in the
outer jacket.
E85-101535, Revision 1
Two torminal blocks were broken.
E85-101536, Revision 1
Butt splice " shims" were not installed
as had been previously indicated in an
IR and the heat shrink tubing was not
installed in accordance with the
manufacturer's instructions.
E85-1016575
The heat shrink tubing was not installed
per the manufacturer's instructions.
E85-101762
Seven terminal blocks were cracked or
broken.
..
.
(
_
-
-
.
7
NRC inspectors witnessed reinspections of cables E0119863A, E0119865A,
E0100821Z, E0100822Z, and EG100861Z.
During inspections of cables
E0119863A and E0119865A, it was noted that the length of the conduits
between the end device and the associated junction box was longer than
allowed by Drawing 2323-EI-1701, Revision 11.
This is an unresolved
item pending completion of review of the applicability of the drawing
detail to the installation (445/8516-U-09).
No NRC violations or deviations were identified.
b.
QC Inspector Qualifications (ISAP No. I.d.1)
Status of CPRT Activity
The Special Evaluation Team (SET) is evaluating information received
in TUGCo memorandum TUQ 3426. This memorandum was a response to the
SET evaluation of historical electrical and all current non-ASME
inspectors' qualifications.
If this additional information is
determined to not establish the qualifications for the inspectors, a
letter detailing the specific area of inadequacy is sent to the QC
manager requesting additional response.
Discrepancies not resolved
advance the inspector to Phase III of ISAP No
I.d.1 for reinspection.
Reinspection activity for the seventh inspector placed into Phase III
of ISAP No. I.d.1 has been completed and the results report is in
preparation.
Reinspection activity for an A5ME-related inspector
identified for Phase III has not begun and is awaiting inspection
packages from B&R.
Status of NRC Inspection Activity
The NRC inspector reinspected 33 conductor terminations as part of a
continuing check on the adequacy of ERC reinspection effort conducted
for Phase III of ISAP No. I.d.1.
The NRC reinspection results were
in agreement with those obtained by ERC. The SET transmittal and
TUGCo response pertaining to qualification status of non-ASME
inspectors has been reviewed.
Further SET evaluations will be
monitored as they are made.
No NRC violations or deviations were identified.
c.
Hot Functional Testing Data Packages (ISAP No. III.a.1)
In order to maintain a correlation between areas inspected and the
applicable sections of the ISAP, this inspection report will address
each area using the ISAP paragraph number assigned by the applicant.
During the inspection period of August 1-31, 1985 (see Appendix E of
InspectionReport'50-445/85-11), paragraphs 4 1.1 thru 4.1.6 were
followup inspected, and paragraph 4.1.7 was started but not completed.
During the inspection period of September 1-30, 1985 (see Appendix E
of NRC Inspection Report 50-445/85-13), paragraphs 4.1.7 and 4.1.8
'
.
8
were comple
ing this inspection period, the remaining
paragraphs i.
i No. III.a.1 were followup inspected as indicated
below:
4.1.9
In accordance with the sampling plan guidelines established
by the applicant for the remaining 139 completed preopera-
tional test data packages, the applicant committed to sample
60 items comprising test deficiency reports (TDRs), test
procedure deviations (TPDs), and FSAR commitments to
demonstrate the capability of systems to function as
designed.
These items were reevaluated utilizing the
attributes in Attachment 1 of ISAP No. III.a.1.
A followup
inspection was conducted by the NRC inspector to ensure both
that the results of reevaluations were consistent with the
guidelines delineated in Attachment 1, and that the
dispositions were consistent with regulatory requirements.
The NRC inspector sampled 20% of the list of items identi-
fied by the applicant. This sampling consisted of seven
TPDs, three Tuus, and two FSAR commitments.
No NRC violations or deviations were identified.
4.1.10
The applicant committed to incorporate the guidelines of
ISAP No. III.a.1, Attachment 1, into the applicable startup
administrative procedures to assure that the concerns
expressed by the NRC Technical Review Team (TRT) would be
addressed in a consistent manner during future test results
reviews.
The NRC inspector reviewed the Startup Administra-
tion Procedures Manual and verified that the above guidelines
were incorporated into Revision 6 of CP-SAP-11, " Review,
Approval and Retention of Test Results," dated July 8, 1985.
In addition, the applicant incorporated an improved method
of Joint Test Group (JTG) reviews. The procedure now
requires all JTG members to document their review comments
and submit them to TUGC0 Startup for resolution.
The
resolutions are then to be documented and redistributed to
all of the JTG members, so that each has an opportunity to
evaluate the resolution to all comments before approving the
data package.
The NRC inspector questioned whether or not
the comments and resolutions would become a permanent part
of the JTG-approved data packages.
The response was that
the intent of Section 4.2.1.5 of CP-SAP-11, which describes
supporting documentation requirements for data packages, is
to include the JTG comments and resolutions.
4.1.11
The applicant committed to determine the root cause(s) and
evaluate the potential for generic implications related to
the issues and findings in ISAP No. III.a.1.
When asked by
the NRC inspector to produce evidence that this had been
done, the applicant indicated that the final results report
would contain the information, but it had not been completed
yet. As such, this shall be tracked as an open item
(50-445/8516-0-10).
,-
'
.
9
Followup inspection of ISAP No. III.a.1 is completed pending closure
of the above open item and those items identified in Appendix E of
NRC Inspection Reports 50-445/85-11;50-446/85-06 and 50-445/85-13;
50-446/85-09; i.e., unresolved item 445/8511-U-02 and open items
445/8511-0-02, 445/8511-0-03, 445/8513-0-07, and 445/8513-0-08.
No NRC violations or deviations were identified.
d.
JTG Approval of Test Data (ISAP No. III.a.2)
During the 1984 TRT inspection of testing programs, the NRC inspector
noted that if a preoperational test is deferred into the Initial
Startup (ISU) program, which commences after_ initial fueling, the
completed results data would be reviewed by the Station Operations
Review Committee (SORC) in lieu of the JTG. The version of the FSAR
in effect at the time of the inspection did not provide for this shift
in review responsibility; i.e., the FSAR stated that the JTG is
responsible for reviewing preoperational test data. Deferring,this
testing to another time frame, or incorporating the deferred
preoperational tests in ISU procedures, did not in itself relieve the
JTG of this responsibility.
The action required by Supplement to Safety Evaluation Report (SSER)
No. 7 and accordingly the commitment in.ISAP No. III.a.2 was to revise
the FSAR. During the followup inspection, the NRC inspector verified
that the FSAR had been revised (see Amendment 54,'Section 14.2) to.
clarify the division of responsibility between the JTG and the SORC.
The FSAR now supports station procedures which prescribe the method of
deferral of preoperational tests from the preoperational test program,
which is the responsibility of the JTG, to the ISU program, which is
the responsibility of the SORC, a similarly qualified group. _ This
issue is closed.
~
No NRC violations or deviations were identified,
e.
Technical Specifications for Deferred Tests (ISAP No. III.a.3)
During the TRT inspection of test programs in the preoperational test
area, the NRC Operations resident inspectors expressed concern that
the orderly progress of ISU testing may be hampered by Technical
Specification (TS) limiting conditions for operation, due to the
nature and extent of the preoperational tests which had been deferred.-
In order to achieve the plant conditions (i.e., hot plant at normal
pressure and temperature) to conduct the deferred preoperational
' tests, the TS requires some of the systems being tested to be operable.:
However, operability cannot be verified until preoperational' testing
is completed. Since then, the applicant conducted another hot' testing
'
.
10
,
sequence in November and December 1984, at which time most of the
deferred tests were completed.
In a letter dated January 24, 1985,
the NRC closed this issue and thus the concern did not appear in
SSER No. 7.
~
There is no followup inspection required. This item is closed.
f.
Preoperational Testing (ISAP No. III.d)
'
During the TRT inspection of the preoperational testing program,
conclusions were reached indicating that none of the related allega-
tions and findings had either safety significance or generic implica-
tions, except that past document control system problems may have
affected the testing program.
Details of these conclusions and
findings are in SSER No. 7.
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
impacts 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 did not adversely affect the testing program.
In the ISAP, this is 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.
4.1.2
Detailed record reviews to determine the effect of Document
Control Center (DCC) problems on the testing program.
4.1.3
Determinationofrootcause(s)andevaluationofthe
potential for generic implications.
The NRC followup inspection of actions taken in accordance
with this ISAP commenced with 4.1.1 during this inspection
period and will continue during subsequent periods.
For
the sake of clarity and tracking, the ISAP No. III.d
paragraph numbers are indicated below.
4.1.1.1
The applicant comitted to revise CP-SAP-21, " Conduct of
Testing," to include instructions for STEs to review test
procedures approximately two weeks prior to the scheduled
test date to help facilitate timely updates and thus
eliminate last-minute complex reviews. The NRC inspector
verified Section 4.9.3 of CP-SAP-21 (Revision 3) as having
this requirement as of January 11, 1985.
- -
- -
.
11
4.1.1.2
The applicant committed to instruct STEs on the new
requirements of CP-SAP-21.
This was verified to be complete
by the NRC followup inspector by review of documented
evidence that the training had been completed by January 14,
1985.
Sections 4.1.1.3 and 4.1.1.4 of ISAP No. III.d involve a review
of the CPSES document control program and interviews of STEs to
help assess the adequacy of existing procedures and methods.
When the NRC followup inspector attempted to review related
documentation, there were only a few rough, hand written notes
showing evidence of STE interviews, but no results or actions
from the review and interviews were available.
The applicant
,
explained that the final results report would address this,
'
therefore this part of the followup will be conducted later.
For tracking purposes, this is an open item (445/8516-0-11).
No NRC violations or deviations were identified.
g.
Plug Welds (ISAP No. V.d)
Status of CPRT Activity
Reinspection of the new random sample of 57 ASME Code,Section III
supports by ERC has been completed.
No unauthorized plug welds were
identified.
This new random sample was required as a result of the
.
NRC identifying that the original sample of supports included
f
unauthorized non-ASME Code,Section III supports.
Status of NRC Inspection Activity
'
(1) The NRC inspector has witnessed a total of 13 ERC reinspections
from the new random sample, of which the following 5 were
performed during this report period:
Component Support No.
Unit No.
SF-X-002-021-F43S
Common
SI-2-105-404-052K
2
CC-2-204-421-C53R
2
CC-1-065-007-533R
1
MS-2-RB-004-2
2
4
During the above reinspections, ERC did not identify any
conditions to the NRC inspector as subject to evaluation as
potential deviations.
The NRC inspector also witnessed the
macroetching of four component support base plates which
exhibited indications that suggested the possible existence of
plug welds.
Two of these base plates were identified during the
October inspection period.
The macroetching confirmed that plug
welds did not exist.
No NRC violations or deviations were identified.
i
'
.
12
(2) A total of four independent inspections has been conducted by
the NRC inspector, of which the following three occurred during
this report period:
Component Support No.
Unit No.
CS-2-AB-067-013-3
2
CC-2-050-700-A43K
2
CS-2-564-701-A33R
2
No NRC violations or deviations were identified.
(3) Documentation packages for the 13 reinspected and 4 independently
inspected supports were reviewed.
No discrepancies or missing
documents were identified.
No NRC violations or deviations were identified,
b.
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 results report is being reviewed by CPRT.
Status of NRC Inspection Activity
The preservice inspection documentation; i.e., UT and magnetic
particle examination reports are currently being reviewed.
In
addition, the results of the four UTs performed on the highest
stressed areas of loops 1 and 4 will be reviewed.
No NRC violations or deviations were identified.
i.
Nonconformance and Corrective Action Systems (ISAP No. VII.a.2)
Status of CPRT Activity
A review of current and historical procedures that controlled the
processing and documenting of deficiencies has been completed.
This
review was made to determine if programmatic deficiencies existed in
these procedures.
Sub populations of nonconformances have been
selected from the various systems used to document deficiencies.
These sub populations were based on-type of documentation, method of
processing, and time of occurrence in plant construction.
Addition-
ally, ASME and non-ASME related deficiencies were divided.
Random
samples have been generated for each sub population.
Review of the documentation is complete for approximately 360 NCRs.
Review of the remaining sub populations is ongoing.
If programmatic
deficiencies are found, root cause and generic implication will be
determined.
s
.
13
Status of NRC Inspection Activity
Checklists used by ERC to evaluate nonconformances were reviewed by
the NRC inspector.
It was noted that no evaluation of the dispositions
for adequacy was made on the checklists.
This omission may be resolved
by an ERC proposed review of dispositions for technical adequacy.
This is an open item (445/8516-0-12, 446/8513-0-08).
No NRC violations or deviations were identified.
j.
Audit Program and Auditor Qualifications (ISAP No. VII.a.4)
Status of CPRT Activity
The draft of the results report for this ISAP has been written and is
undergoing review and revision.
Status of NRC Inspection Activity
The NRC inspector reviewed background data for verification during a
future NRC audit of the corporate audit files.
No NRC violations or deviations were identified.
'
k.
Pipe Support Inspections (ISAP No. VII,b.3)
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
Reinspection / Documentation Review Plan."
(1) Room 77N Pipe Supports
Reinspection of the 178 pipe supports in Room 77N, identified as
being nonconforming by TRT, has been completed. Of the 238 devi-
ations identified, 234 have been evaluated with 229 determined to
be valid.
(2) TRT Issues - 42 Pipe Supports
Of the 42 pipe supports identified by TRT as being nonconforming,
17 have been reinspected by ERC.
Physical reinspections _ are
being accomplished using QI-058, Revision 0.
Twenty-six
deviations have been issued with 22 processed as being valid.
_
'
.
14
.
Status of NRC Inspection Activity
(1) Room 77N Pipe Supports
(a) The NRC inspector has reviewed QI-037, Revision 0.
To date,
seven reinspections have been witnessed.
The following
seven independent inspections were performed by the NRC
inspector during this report period:
Verification Package No.
Support No.
Unit No.
I-S-PS7N-190
SI-1-039-044-S42R
1
I-S-PS7N-031
CC-1-131-010-S43R
1
I-S-PS7N-038
CC-1-155-011-S43R
1
I-S-PS7N-039
CC-1-155-012-543R
1
I-S-PS7N-095
CS-1-158-033-542R
1-
I-S-PS7N-129
PS-1-SB-006-004-2
1
I-S-PS7N-143
SI-1-SB-043-008-2
1
(b) During the above independent inspections, the NRC inspector
identified the following conditions:
I-S-PS7N-031:
The welds joining a wide flange (item 8) to
a plate (item 9) consisted of a fillet weld on both sides
of the wide flange of approximately 22 inches in length.
Approximately 20 inches of the welds were undersize by a
minimum of 1/16 inch with respect to the 1/4-inch _ fillet
required by Drawing CC-1-131-010-543R, Revision 4, and a
consecutive 2-inch segment was 1/8-inch undersize.
The
vertical welds on the outside of the wide flange joining two
plates (items 9 and 10) were also undersize by a minimum of
1/16 inch for more than 25% of the weld length.
Paragraphs 5.1.2 and 5.3 of B&R Procedure CP-NDEP-200 require-
plate and piping welds to be inspected'for size.
Review of
the applicable operation traveler, CC-1-131.010-S43R, and
associated weld data cards showed that the welds had been
previously inspected and accepted.
As a result of this
condition being identified, B&R-initiated NCR XI-708.
The failure to identify undersize welds is'a violation
(445/8516-V-13).
I-S-PS7N-190:
The NRC inspector measured a center-to-center
spacing of 10 1/2 inches.between a 1 1/4-inch Hilti bolt and
a 1-inch Hilti bolt on adjacent fixtures of support
SI-1-039-044-542R.
It was ascertained that this installation
had been inspected and accepted on December 21, 1981.
'However, review of Attachment l'in Revision 7 of B&R-
Procedure CEI-20 revealed that a minimum center-to-center-
spacing of 11 1/4 inches is required between 1 1/4-inch and
i
1-inch Hilti bolts.
This procedure further stated that this
~ inimum spacing applies to Hilti bolts detailed on separate
'
m
!
-_
_ - - - _ -
.
. - .
--. .
.,.
. -
- . .
. . .
-
._
'
.
15
.
adjacent fixtures and that violation of_ minimum spacing must
be approved by issuance of design change documents by the
applicable Comanche Peak Project Engineering design groups.
There was no evidence of any design change documents
approving this minimum spacing violation.
This failure to verify conformance to procedure requirements
,
is a violation (445/8516-V-14).
<
'
(2) TRT Issues - 42 Pipe Supports
(a) The NRC inspector reviewed QI-058, Revision 0, and QI-061,
Revision 0.
To date, three reinspections have been
witnessed with the following two performed during this
inspection period:
Verification Package No.
Support No.
Unit No.
I-S-PS42-25
CT-1-013-011-S22R
1
I-S-PS42-41
RH-1-020-003-522K
1
(b) During the above reinspections, ERC identified the following
conditions to the NRC inspector as subject to evaluation as
potential deviations:
I-S-PS42-25:
(i) No lock nuts were present on clamp balts,
and (ii) location of bolt hole in relation to base plate
edge was incorrect.
I-S-PS42-41:
(i) Paint was observed on a spherical hearing,
and (ii) material was incorrectly identified.
Dispositions of the above findings are open items
,
(445/8516-0-15 and 445/8516-0-16).
No NRC violations or deviations were identified.
(c) The following five independent inspections were performed by
the NRC inspector during this report period:
Verification Package No.
Equipment No.
Unit No.
I-S-PS42-06
AF-1-035-029-S33A
1
I-S-PS42-024
CT-1-013-010-522K
l'
I-S-PS42-034
RC-1-052-016-C41K
1
I-S-PS42-033
RC-1-035-700-C41R
1
I-S-PS42-08
AF-1-059-003-S33R
1
(d) During the above independent inspections, the NRC inspector.
identified the following conditions:
_
_
_
.
1
16
I-S-PS42-06: The NRC inspector observed that three 1 1/4-inch
Hilti kwik bolts (from a total of eight), that were used to
attach two base plates of support AF-1-035-029-S33A to the
wall, had been installed through an embed plate.
It was
noted that this ir.stallation was inspected and accepted on
IR No. 15042 dated March 30, 1981.
B&R construction Procedure CEI-20, applicable to this
installation, was reviewed. Attachment 3 of CEI-20 allows
Hilti bolts to be placed as close as practical to the edge
of an embedded plate, without damaging the plate, as long as
there are no attachments to the plate within a minimum of
12 inches on both sides of the proposed Hilti bolt location.
Subsequent to this report period, applicant personnel
showed the NRC inspector that insertion of Hilti kwik
bolts through the embed plate had been authorized by DCA.
The adequacy of the engineering basis for the DCA is
considered an unresolved item pending NRC review (445/8516-
U-55).
7.
ISAP No. VII.c
a.
Electrical Cable
Status of_ CPRT Activity
>
ERC has completed 87 reinspections and 88 documentation reviews of
sampled electrical cable as of November 25, 1985.
Status of NRC Inspection Activity
(1) NRC inspectors have, as of November 25, 1985, witnessed 21 ERC
reinspections and performed independent reviews of 10 documenta-
tion packages. The following three independent reinspections of
sampled electrical cable were performed in this report period:
Verification Package No.
Cable No.
Unit No.
I-E-CABL-014
ER140509Z
1
I-E-CABL-063
E9123380
1
I-E-CABL-102
EG139517
1
(2) During the above independent reinspections, the following
condition was identified:
-
I-E-CABL-102:
Reinspection revealed that ERC inspectors did not
identify the disagreement of the physical routing with the cable
and raceway schedule, as required by Section 5.6 of QI-014,
Revision 0, dated July 18, 1985. The cable physically routes
into tray T13GCCP80 and then tray T13GCCP81. The cable schedule
routes this cable into T13GCCP81 and then T13GCCP80. This is an
NRCdeviation(445/8516-D-17).
.
_
-
.
17
..
i
b.
Cable Trays
j
Status of CPRT Activity
ERC has completed 89 reinspections and 83 documentation reviews of
sampled cable trays as of November 25, 1985.
Status of NRC Inspection Activity
i
(1) NRC inspectors have,'as of November 25,19C, witnessed 11 ERC
reinspections, performed independent reviews of 7 documentation
packages, and performed 6 independent ieinspections of sampled
cable trays. The following independent reinspection was
performed in this report period:
,
Verification Package No.
Cable Tray No.
Unit No.
I-E-CATY-077
T14BREC28
1
(2) During the above independent reinspection, the NRC inspector
identified that F.RC inspectors did not identify a missing bolt
and locking device on the splice plate joining tray section
',
T14BREC28 to T14BREC27 as required by Section 5.3.6 of QI-016,
Revision 1.
This is an NRC deviation (445/8516-D-18).
c.
Electrical Conduit
Status of CPRT Activity
ERC has completed 80 reinspections and 80 documentation reviews of
sampled electrical conduit as of November 25, 1985.
Status of NRC Inspection Activity
(1) NRC inspectors have, as of November 25, 1985, witnessed 14 ERC
reinspections, performed independent reviews of 15 documentation
'
packages and performed 5 independent reinspections of sampled
electrical conduit.
(2) The following two independent reinspections of sampled electrical
conduit were performed in this report period:
Verification Package No.
Conduit No.
Unit No.
I-E-CDUT-036
C12909546
1
I-E-CDUT-048
C16WO9519
1
No NRC violations or deviations were identified.
'
,
-
.
.
,
.
..
-.
.
-
'
.
18
4
(3) The following documentation review was performed for an
electrical separation inspection in this report perfod:
,
Conduit No.
Room No.
Un_it No.
C12G03270
100
1
During the above review, it was identified that the electrical
inspector who signed the " Electrical Separation Punchlist" and
" Electrical Separation Deficiency Report," which were attached
to IR E-1-0013528, had been certified for "All QI-QP11.3" as a
level II inspector, despite having failed the written examination
for QI-QP-11.3-29.
This condition was ascertained to have been
previously identified by the TUGC0 Audit Group (TAG) cnd is being
evaluated by SET. Thi's is an open item pending review of the SET
9
evaluationandaction(445/8516-0-19).
No NRC violations or deviations were identified.
,
d.
Electrical Equipmegt Installation
l
Status of CPRT Activity
ERC has completed 59 reinspections and 20 documentation review packages
of sampled electrical equipment installations as of November 25, 1985.
,
Status of NRC Inspection Activity
(1) NRC inspectors have, as of November 25, 1985, witnessed 11 ERC
reinspections, perforned independent reviews of 10 documentation
packages and performed 3 independent reinspections of sampled
electrical equipment ir.stallations.
.
,
I
(2) The following ERC reinspection of sampled electrical equipment
installation was witnessed during this report period:
,
Verification Package No.
Equipment No.
Unit _No.
'
I-E-EEIN-062
1E35
1
During the above reinspection, ERC identified the following
i
condition as subject to evaluation as a potential deviation:
Nuts on the studs for the penetration were not engaged flush with
!
top of stud threads.
,
Disposition of the above finding is an open item (445/8516-0-20).
No NRC violations or deviations were identified.
.
I
,
.
.
. .
.
. -
.
.
.
'
.<
1
19
(3) The following independent 'teinspections of electrical equipment
installations were parformed during this rep 6rt period:
Verification, Package Na.
Equipment No.
Unit No.
I-E-EEIN+050
CPX-ELDPEC-06
1
I-E-EEIN-055
CPI-ELOPEC-10
1
No NRC violations or deviations were identified.
-
'.
(4) Independent documentati4n reviews were performed of nine
verification packages during this . report period.
The results of
these reviews are open items per. ding comparison with ERC findings
when they become available (445/8516-0-11 through 445/8516-0-29),
e.
Instrumentation Equipment _ Installation
Status of CPRT Activity
ERC has completed 80 reinspections and 97 documentation reviews of
!
sampled instrumentation equipment installations as of November :25,1985.
Status of NRC Insnection Activity
.
(1) NRC fr.spectors nave, as of November 25, 1985, witnessed eight ERC
reinspections, performed independent reviews of five documentation
packages and performed six ir, dependent reinspections of sampled
instrumentation equipment installations.
,
(2) Of the six Independent NRC inspections performed, to date, the
'
"
following four occurred during this report period:
Verification _ Package No._
Eguipment No.
Unit No.
I-E-ININ-051
1- LT-932
.1
I-E-ININ-041
1-LT-930
1
I-E-ININ-049
1-FT-425
1
1-E-ININ-059
1-PT-124
1
During the above reirspections, the following conditions were
identified by the NRC inspector:
I-E-ININ 051:
The ERC inspector failed to identify and inspect
the required mininum bend radius for Bend No. 5.
This berd was
accessible for inspection.
I-E-ININ-041:
Bend No. 5 which was identified by the ERC
inspector as being inaccessible for measurement was found to be
accessible and inspectable.
!
l
.
-
,
..
.
_.
'
.
20
'
.
.
1-E-lNIN 059:
'(a) A swagelck fitting rear support C-24-04-51 was
observed to be touching the wall, thus violating the air gap
requirement; and (b) an air gap violation was identified between
'
tee tubing arid the wall penetration at the inside face of the
excess letdesn heat exchanger orifice room.
I-E-ININ 049:
(a) Installation identification tag for the low
pressure root valve was incorrectly marked with respect to
appitchble instrument identity, i.e., the tag on val e 1-RC-80618
which was assctiated with 01strument 1-FTe425, showed instrument
1-FT-424; (b) less than the required 1/84f nch air gap existed
between the high pressure sensing line and a steel member adjacent
'
to the isolation valve location; and (c) a loose bolt was observed
at the lov pressur6 sensing line flange attachment to the
differential pressure type instrument.
The above failures to inspect required attributes and identify
non-onfor' ming conditions constitute a deviation (445/8516-D-20h
00 ring the abote inspection, the ERC inspector additionally noted
that tags on immediat'ely adjacent lay pressure root valves were
also incorrectly marltd with retpect to applicable instrument
identity.
Tlie tag on valve 1-8C-80598, which was associated with
-
instrument 1-FT-424, showad instrument 1-FT-426.
The tag on
'
valve 1-RC-8060B, which was associated with instrumsnt 1-FT*426,
'
showed instrumeht 1-FT-425.
~
,
(3) irdependept documentation reviers were performed on three
'
verification packages during this report period,
The l'esults of
these rev$ews are open itehis pending comparison with ERC firdings
when they becone available (445/85M-0*31 through 445/8516'0-33).
f-
pipi.ig Syr*.em Bolted Joir.ts/.Materialp
Statys of CFET Activity
ERC has completed 72 reinspectlons of piping system bolted
joints / materials as of November 23,19Q5, from a total random aird
engineered sample size of 73.
Seyeo valid deviation repoFts (DRs)
were g'anerated as a result cf the above reinspections.
ERC has also cQmpleted 65 docm.ent revien on these packages.
Eight
valid ors have been generated as a result of the above documentation
reviews.
Status of NRC Inspection Acti_vity
i
(1) The NRC inspector has performed five independent inspections, to
date, of which the following occurred during this report period:
j
Verification Package No.
Drawing No,
Flange No.
UMt
-1
I-M-PBOM-035
BRP-D0-2-0G-056
5
?
i
No NRC violations or deviaticns were ident.ified.
+
.
.
.
.
.-..
'
.
21
(2) The NRC inspector performed independent document reviews of the
following packages during this report period:
Verification Package No.
Drawing No.
Flange No.
Unit
R-M-PBOM-018
BRP-SW-1-SB-003
1
1
R-M-PB0M-031
BRP-CS-1-AB-001
1
1
R-M-PB0M-042
BRP-SI-1-SB-012
1
1
No NRC violations or deviations were identified.
(3) The following independent NRC inspections were performed during
September 1985, but were not specifically identified in NRC
Inspection Report 50-445/85-13; 50-446/85-09:
Verification Package No.
Drawing No.
Flange No.
Unit
I-M-PBOM-003
BRP-CC-1-RB-038
4
1
I-H-PB0M-054
BRP-CC-1-RB-056
1
1
No NRC violations or deviations were identified,
g.
Small_ Bore Piping and Instrumentation Tube Welds / Material
Status of CPRT Activity
Reinspection of a random sample of 60 small bore pipe and
instrumentation tube welds and material from Units 1, 2, and common is
in progress.
To date, 45 small bore piping welds have been rein wected
by ERC. No deviations havo been identified.
Status of NRC Inspection Activity
To date, the NRC inspector has witnessed seven reinspections performed.
by ERC, none of which occurred during this report period.
The
following two independent inspections were conducted in this report
period:
Verification Package No.
Pipe and Weld No__._
Unit No.
I-M-SBWM-004
WP-X-073-151R3, 3
Common
I-M-SBWM-005
MS-1-221-1303-2, 16
1
No NRC violations or deviations were identified.
h.
Large Bore Piping Welds / Material
Status of CPRT Activity
Visual reinspection of a random sample of 60 ASME Code,Section III
large bore piping welds hnd material from Units 1 and 2 is in progress.
-
-
-
-
.
.
._.
. _ -
.
._
'
,
22
To date, 45 large bore piping welds have been reinspected with one
deviation being identified. The deviattor,was evaluatcd as being
valid; however, it was determined to r.ot have safety significance.
Status of NRC Inspection Activity
To date, the NRC it.spectcr has w'itnessed eight reinspections by ERC,
none of which occurred during this report period. Tne following
independent inspection was conducted in this report period:
Verification Package No.
Pipe & Weld No.
Unit No.
,
I-M-LBWM-073
CS-X-010-151R3, ISA
Comon
No NRC violations or deviations were identift.ed.
1.
Large Bore _ pipe Supports - Rigid
Status of CP_RT Activity
j
Reinspection / verification of pipe support installations by ERC is in
' rocess with approximately 96% of the population sar.ple completed. A
p
,
total of 164 deviations have been identified of which 136, to date,
'
have been determined to be valid. ERC has determined that 70 of the
-
valid DRs are not safety significant, while the reminder are currently
being reviewed for safety significance.
Status of NRC Inspection Activity
(1) To date, five ERC reinspections have been witnessed to assure
compliance with QI-027, with the following being witnessed
'
during this report period:
'
Verification Package No.
Pipa Support No.
Unit _No.
.
!
j
I-S-LBSR-217
CC-1-197-008-C52R
1
'
During the reinspection, ERC identified the following to the NRC
'
inspector as subject to evaluation as potential deviations:
(a) clearances between the pipe -and the support were out-of-
tolerance, (b) undersize welds were present, and (c) component
n: ember lengths were not shown or) the design drawing.
Dispositionsoftheabovefindingsareanopenitem(445/2516-0-24).
No NRC violations or deviations were identified.
i
.
E-
..
-
.
-
'
.
23
(2) Five independent inspections of pipe support installations have
been performed, with the following three inspections performed
during this report period:
Verification Package No.
Pipe Support No.
Unit No.
I-S-LBSR-006
CC-1-146-008-S43R
1
I-S-LBSR-013
DD-1-016-016-S33R
1
I-S-LBSR-041
CC-1-126-702-F43R
1
,
During independent review of ERC Verification Package
No. I-S-LBSR-041 and the original installation documentation
package for pipe support Mark No. CC-1-126-702-F43R, a deviation
,
from commitment (445/8516-D-35) was identified. Section 5.6.1.A
'
of QI-027, Revision 0, states, " Verify welds are located as shown
on design drawings. Record any welds that are in addition to
those specified on the drawings (attachment 6.6)."
ERC did not
identify or document the existence of two additional field welds
which were not specified on the drawings, but were identified by
the issuance of " Vendor Supplied Component Modification Records"
that documented the performance of field welding.
,
J.
Large Bore Pipe Supports - Non-Rigid
Status of CPRT Activity
Reinspection / verification of pipe support installations by ERC is in
process with approximately 83% of the population sample completed. A
total of 234 ceviations have been identified of which 187, to date,
have been determined to be valid.
ERC has detennined that 72 of the
,
valid DRs are not safety significant, while the remainder are currently
.
being reviewed for safety significance.
,
Status of NRC Inspection Activity
(1) To date, six ERC reinspections of pipe support installations
have been witnessed to assure compliance with QI-029, with the
'
following being witnessed during this report period:
Verification Package No.
Pipe Support No.
Unit No.
I-S-LBSN-043
MS-1-150-033-C52K
1
1-S-LBSN-240
CC-1-040-019-E33S
1
(2) During the above reinspections, ERC identified the following
conditions to the NRC inspector as subject to evaluation as
potential deviations:
I-S-LBSN-043:
(a) Component member length and location were
out-of-tolerance, (b) locking devices were missing, (c) spherical
,
.
-e.
-
m
. _
..
.-.
-
.-
- ..
i
.
,
24
I
bearing gap was out-of-tolerance, (d) safety lockwire on snubber
capscrew was broken, (e) paint.was present on spherical bearings,
(f) welder identification was not visible on pressure boundary
r
welds,and(g)snubberinterferencewithinsulationwasobserved.
I-S-LBSN-240:
(a) Component member identification was incorrect,
(b) bill of material items were not within fabrication tolerances,
(c) component member location was out-of-tolerance, (d) shear lug
to pipe clamp clearances were out-of-tolerance, (e) pipe clamp
bolts did not have full thread engagement, (f) locking devices
were missing, and (g) one Hilti bolt violated requirements for
perpendicularity,
Dispositions of the above findings are open items (445/8516-0-36
l
and 445/8516-0-37).
!
No NRC violations or deviations were identified.
(3) To date, five independent inspections of pipe support
installations have been perfomed. During this report period,
the following inspection was performed to assess the adequacy of
i
ERC reinspections:
i
Verification Package No.
Pipe Support No.
Unit No.
1
j
I-S-LBSN-003
SI-1-008-003-S42S
1
This effort revealed that ERC had perfomed the reinspection in
accordance with the requirements of QI-029.
No NRC violations or deviations were identified.
i
k.
HVAC Duct Supports
4
Status of CFRT Activity
~
A total of 89 HVAC duct supports were randomly selected from a
population of 2580 supports representing Units 1, 2, and common. To
i
date, ERC has reinspected 55 supports and initiated 142 DRs, primarily
in the areas of undersize welds and configuration discrepancies. Of
l
the 142 DRs,106 have, to date, been established as being valid.
'
Status of NRC Inspection Activity
(1) To date, the No.C inspector has witnessed seven ERC reinspections,
I
with the following four being performed during this report period:
(
Verification Package No.
Duct Support No.
Unit No.-
!
l
I-S-HVDS-029
SG-785-1H-RIF
1
[
I-S-HVDS-089
CB-810-IN-2BB
1
I-S-HVDS-103
CB-810-1N-2BD
1
r
l
I-S-HVDS-109
CB-854-2N-C30/C30-1
2
i
.
. . _ . -
-_
_,
_
-
,
,
.
.
25
(2) During the above reinspections, ERC identified the following
conditions to the NRC inspector as subject to evaluation as
potential deviations:
I-S-HVDS-029:
(a) Weld symbols and weld locations were incorrect,
(b) welds were undersized, and (c) a Hilti Kwik Bolt violated
required embedment length.
l
I-S-HVDS-089:
(a) Member dimensions were incorrect, (b) welding
configuration was incorrect, (c) weld sizes were incorrect,
(d) incomplete fusion was noted in welds, and (e) weld undercut
4
was observed.
~
I-S-HVDS-103:
(a) Dimension violations, (b) duct dimension was
incorrect, (c) incorrect orientation was observed, (d) welds were
'
undersized, and (e) an unsatisfactory weld profile was noted.
I-S-HVDS-109:
(a) Weld location was_ incorrect, (b) welds were
undersize, (c) welding was not performed per weld symbol, and
(d) minimum thread engagement was unsatisfactory.
Subsequent to the inspection, DRs were initiated for the above
conditions.
Dispositions of the abc/e findings are open items (445/8516-0-38
through 445/8516-0-40 and 446/8513-0-09).
(3) During the witnessing of ERC's reinspection of support
CB-854-2N-C30/C30-1, the NRC inspector observed what appeared to
be significant damage to Flange Nos.-17 and 18 of Battery Room
Ventilation Exhaust Duct System EMD-3.
This observed condition
was not an attribute being reinspected by ERC at this time, and
was therefore not identified.
Further examination revealed that
this condition most likely was caused during installation, in
that the bolted flanges were force bent upwards approximately 30
degrees in order to preclude interference with an adjacent
concrete wall.
The force bending created a gasket gap of 1/4 inch
in the trough of the bend which is in excess of the maximum
'
allowable gap of 5/32 inch. A sealant type material was used to
fill in the excessive gap.
Review of the original installation
and inspection documentation revealed that this field modification
was neither reported nor documented on a Bahnson Installation
Interference Report or a Bahnson Deficiency & Disposition Report.
Further, the Bahnson QC IR dated April 1, 1983, which required
ductwork inspection for visual damage, reported that joints 1
through 18 of Duct System BRVE-EMD-3 had been inspected and
accepted. This failure to document field modifications and
identify nonconforming conditions is a violation (446/8513-V-10).
'
1
.-
.
_
_ _
d
'
.
'
26
.
~
(4) The NRC inspector conducted the-following five independent
~.
inspections during this inspection period:
VerificationiPackage No.
Duct Suppor.t No.
Unit No.
I-S-HVDS-010
AB-886-1L-WP2
1
I-S-HVDS-066
SG-773-2H-WP5
2
I-S-HVDS-057
SG-852-1J-1E
1
I-S-HVDS-065
CB-830-2N-1CV
-2
I-S-HVDS-122
DG-810-2K-PS1
2
i
No NRC violations or deviations were identified.
1.
Reinspection of Containment Liner and Tank Stainless Steel Liner
Status of CPRT Activity
~
A tank stainless steel liner was 100% reinspected representing 29 weld
seam packages.
Sixty-two weld seams were randomly selected from
Units 1 and 2 containment liners incloding both dome and cylindrical
liners.
ERC reinspections and document revie'ws are 100% complete.
However, changes to QI-031, Revision 0,.are contemplated and may
require additional reinspection.
Eighty-two valid deviations have been identified by ERC which are
currently being reviewed for safety significance.
Status of NRC Inspection Activity
.
(1) The NRC inspector had previously witnessed 9 reinspections
representing approximately 10% of the random sample of 91.
The
NRC inspector independently reinspected the following three
containment liner and tank stainless steel liner weld seams
during this report period
Verification Package No.
Joint No.
Unit No.
-
I-S-LINR-08
8D
1
3
I-S-LINR-12
P88
-
2
I-S-LINR-61
PS2
2
/
(2) During the independent reinspections, the NRC inspector noted the
following conditions:
I-S-LINR-61:
Excessive reinforcement up to 7/32 inch was
identified for approximately 80% of the weld length.
This weld
seam is between the 3/8-inch cylindrical liner plate and a pipe
penetration with a 3 to 1 taper.
QI-031, Revision 0, does not
provide specific instructions for the measuring of reinforcement
,
of welds connecting a tapered item to a uniform thickness item.
However, Section 5.1. A3c states, .in p' art, " Verify that the height
4.
-
.
,
27
of the reinforcement on each face of the seam does not exceed
3/32-inch." All NRC measurements were taken from the liner plate
to the center of the weld seam.
The ERC inspector accepted this
attribute without comment or obtaining special instructions.
This is an NRC deviation (446/8513-D-11).
I-S-LINR-08:
The NRC inspector rejected attribute A.1.d of the
checklist regarding contour measured from a 10-foot straight edge.
Section 5.1.Al of QI-031, Revision 0, states, in part, with
respect to attribute A.1.d, "The following local contour devia-
tions are to be verified: . . . A maximum of 3/4 inch deviation
from a 10 foot straight edge placed in the vertical direction
between the horizontal weld seams." The NRC inspector measured a
1 1/4-inch deviation from the straight edge. The liner plate-in
this location is apparently somewhat convex near the center of a
vertical cross section.
The NRC inspector measured the 1 1/4-inch
deviation by placing the 10-foot straight edge in contact with
the liner plate for approximately the top 30% of the vertical
cross section and measuring at the bottom of the cross section
just above the lower horizontal weld seam.
The ERC inspector
stated that he measured the deviation from the 10-foot straight
edge by placing the straight edge in contact with the greatest
inward vertical deviation and adjusting the position of the
straight edge until equal maximum deviations exist for the upper
and lower portion of the vertical cross section.
The ERC
inspector measured a maximum deviation of 3/4 inch using this
method and accepted the attribute.
Values of measurements
'
obtained by these methods are not precise and in this case varied
by as much as a factor of two.
QI-031, Revision 0, fails to
provide concise instructions for the measuring of this attribute,
This is an NRC deviation (445/8516-D-41).
,
I-S-LINR-08, -12, and -61:
It was noted with respect to the base
material local contour attributes for cylindrical liner verifica-
tion packages that the ERC inspector had entered "N/A" (not
applicable) and " dome only" on the checklists.
Section 5.1.A.1
in Revision 0 of QI-031 states, in part, "The following local
contour deviations are to be verified:
A maximum of 1-inch gap
between the cylindrical liner or dome shell plate and a 6 feet
long template curved to the required radius . . . ." Thus, the
local contour attribute is applicable and does apply to the
cylindrical liner.
The failure to inspect the required attribute
is an NRC deviation (445/8516-D-42).
The NRC inspector noted that attribute A.1.b was not applicable.
Paragraph 5.1.A.1 of QI-031, Revision 0, states, in part, with
respect to attribute A.1.b, "The following local contour
deviations are to be verified:
. . . A maximum 1 1/2-inch gap
when the 6 feet long template is placed across 'the dome weld
l
seams when measuring horizontally or vertically." Therefore,
l
attribute A.1.b applies only to the dome weld seams.
Review of
the completed checklists revealed that the ERC inspector had
!
_-
_ -
__
._.
.
._
_
. . _ _
__
_ _ _ . . _ .
__
_
.
I
28
4
accepted this attribute for these three verification packages
which are weld seams on the cylindrical _ liner. The.NRC inspector
'
then reviewed the ERC Description Memorandum QA/QC-RT-293 which
lists Gibbs and Hill (G&H) Containment Liner Specification
2323-SS-14, Revision 4, dated January 10, 1979, as a reference
for developing QI-031 Revision 0.
Paragraph 8.2.2.1.2.b in G&H
Specification 2323-SS-14, Revision 4, states, in part, "The -
i
following deviations are acceptable: . . . A 1 1/2 inch gap when
the template above is placed across one or more welded seams,"
and applies to both the cylindrical liner and the dome liner.
This conflict between the G&H specification and attribute A.1.b
.of QI-031, Revision 0, is an NRC deviation (445/8516-D-41).
i
m.
Structural Steel
!
Status of CPRT Activity
$
Reinspection of the first random sample of 60 structural steel members
is approximately 25% complete.
Twenty-five valid deviations have been
identified. The second sample, which is related to safe shutdown
l
systems, has not yet been selected.- Documentation review procedures
!
have not been issued.
Status of NRC Inspection Activity
(1) Seven reinspections have been partially witnessed (welding
-
inspection is not complete), representing approximately 12% of
the first random sample. The following four ERC reinspections
were witnessed by the NRC inspector during this report period:
.
Verification Package No.
Equipment No.
Unit'No.
I-S-STEL-059
AFCO-MK-F180-1-RB
1-
I-S-STEL-007
liK-12
1
,
I-S-STEL-066
DCA 16019 MK-10
Common
I-S-STEL-010
AFC0-C70-3-SA
1-
I
(2) During the above reinspections, ERC identified the following
conditions to the NRC inspector as subject to evaluation as
potential deviations:-
[
I-S-STEL-059:
Numerous attributes _were rejected including bolt
hole coverage and edge distance, bolt size, and weld location..
'
-Paint removal was requested to allow for adequate surface
inspection of the weld
4
-
I-S-STEL-007: An extra bolt hole, not identified in the field
- '
performed alterations, was~noted.
Bolt contact was also. rejected.
~
,
. Verification Package No. I-S-STEL-007 involves the reinspection
i
i
of a sump screen in the Unit 1 reactor building. The screen is a
~
vendor assembled frame bolted to a -structural steel framework.
-
!
The screen is-included in_the ERC Population Description under
.
.
. -
. -
_
-.
-
.
29
" Vendor assembled frames and bents," but is not actually a
- structural member. The validity of the structural steel
population is being evaluated.
I-S-STEL-066:
Hilti bolt size and field installed associated
details (size of components) were rejected.
I-S-STEL-010:
Numerous attributes were rejected including bolt
spacing, configuration and edge distance, connection orientation
and location, limit of alterations, and location of member.
This
package is a monorail support member that is installed at an
angle of approximately 60 degrees between the monorail and the
support member. The drawings indicate an installation angle of
90 degrees.
Dispositions of the above findings are open items (445/8516-0-43
through 445/8516-0-46).
No NRC violations or deviations were identified.
n.
Concrete Placement
Status of CPRT Activity
Reinspection of the first random sample of 60 concrete placement
packages is approximately 98% complete.
Reinspection of the second
sample related to safe shutdown systems is approximately 40% complete.
Thirty-one deviations have been identified related primarily to
unfilled holes, voids, and debris in the concrete surface.
Of the
28 deviations which have been evaluated, 25 were identified as valid.
These are currently being reviewed for safety significance.
,
Documentation review procedures have not yet been issued.
Status of NRC Inspection Activity
'
(1) The NRC inspector has witnessed a total of 12 reinspections' to
date. The following three ERC reinspections were witnessed by
the NRC inspector during this report period:
Verification Package No.
Concrete Placement No.
Unit No.
I-S-CONC-079
IRCN-CPC-201-4822-007
2
I-S-CONC-076
IRCN-CPC-201-6885-010
2
I-S-CONC-069
IRCN-CPC-101-8805-001
1
(2) During the above reinspections, ERC identified the following
conditions to the NRC inspector as subject to evaluation _as.
,
potential deviations:
I-S-CONC-079: The locations and sizes of installed concrete
cast-in place Richmond inserts were out-of-tolerance.
Embedded
plates were installed too close to cast-in place inserts.
'
.
30
I-S-CONC-076:
The locations of installed concrete cast-in place
Richmond inserts were out-of-tolerance.
Dispositions of the above findings are open items (446/8513-0-12
and 446/8513-0-13).
No NRC violations or deviations were identified.
(3) The NRC inspector independently reinspected the following five
concrrte placements during this report period, representing
approximately 5% of the first and second samples:
Verification Package No.
Concrete Placement
Unit No.
I-S-CONC-017
IRCN-CPC-003-4860-023
Common
I-S-CONC-003
IRCN-CPC-002-5852-025
Common
I-S-CONC-016
IRCN-CPC-205-6810-010
2
I-S-CONC-015
IRCN-CPC-002-4790-040
Common
I-S-CONC-057
IRCN-CPC-002-E852-370
Common
(4) During the above independent reinspections, the NRC inspector
identified the following conditions:
I-S-CONC-015:
During review of the ERC inspection checklist
subsequent to the NRC inspection, the NRC inspector observed that
attribute 3.A of the checklist (surface inspection of walls, etc.)
was not signed off.
Therefore, it could not be established
whether or not ERC had performed the required reinspection of
this attribute.
Section 5.2.4 of ERC Procedure CPP-009,
Revision 1, requires the lead inspector (Level III) and the lead
discipline engineer to ". . . ensure that reinspection /
documentation review results are clear, accurate, and complete."
The incomplete checklist for Verification Package No. I-S-CONC-015
had been approved by both the lead inspector and the lead
discipline engineer.
This is an NRC deviation (445/8516-D-47).
I-S-CONC-057:
The NRC inspector identified dirt in the
construction joint and a void with a depth of at least 11/2
inches.
The void and dirt were not identified by the ERC
inspector.
Further review of the inspection checklist revealed
that the ERC inspector had entered "N/A" (not accessible) and
" coated" with respect to attribute 3.A.
Section 5.3.A of QI-043,
Revision 1, states with respect to concrete surface inspection,
" Inspect all accessible surfaces for honeycombing and voids.
(Inaccessible surfaces are those cast against earth, backfilled,
or coated)." The NRC inspector observed the concrete placement
associated with this verification package and found that it was
not coated on any surface and was accessible.
This is an NRC
deviation (445/8516-D-48).
.
31
o.
Small Bore Pipe Supports
Status of CPRT Activity
Reinspection of the first and second samples of small bore pipe
supports is approximately 97% complete.
A total of 67 valid deviations
have been identified related primarily to Hilti bolt embedment, hole
spacing and edge distance in base plates, and pipe clearances.
Documentation review is approximately 99% complete with 31 valid
deviations identified.
Status of NRC Inspection Activity
Six reinspections were previously witnessed by the NRC inspector.
There was no NRC inspection activity during this report period.
p.
Pipe Whip Restraints
Status of CPRT Activity
ERC has completed 28 reinspections of pipe whip restraints out of the
planned sample size of 110.
Nine valid ors have been identified.
Status of NRC Inspection Activity
(1) The NRC inspector has witnessed four ERC reinspections, to date,
of which the following occurred during this report period:
Verification Package No.
Support Identification Unit No.
I-S-PWRE-057
-M40-S1-0588
1
I-S-PWRE-053
FW-1-018-906-C67W
1
(2) During the above reinspections, ERC identified the following
conditions to the NRC inspector as subject to evaluation as
potential deviations:
I-S-PWRE-053:
(a) Gaps existed between the plate and the top of
the washer (0.164 inches) and between the bottom of the washer
and the nut (0.140 inches) on the upper right anchor bolt of the
reactor side plate, (b) a gap of 0.122 inches existed between the
washer and the top of the nut on the middle left anchor bolt on
the reactor side plate, and (c) the capture plate on the reactor
side was 1/16 inch out of location from drawing requirements.
Dispositions of the above findings are an open item
(445/8516-0-49).
No NRC violations or deviations were identified.
.
.
-
sr
_
_ _ _ _ _
-
.
32
q.
Instrument Pipe / Tube Supports
Status of CPRT Activity
ERC has completed 46 out of the planned 102 reinspections of
instrument pipe / tube supports. Twenty-eight DRs have been validated
from a current total of 29 that have been reviewed by the population
engineer. Two hundred and sixty-three deviations have not yet been
reviewed for validity.
Status of NRC Inspection Activity
The NRC inspector has performed, to date, four independent inspections
of which the following occurred during this report period:
Verification Package No.
Instrument Tag No.
Unit No.
I-S-INSP-010
1-PI-4770
1
I-S-INSP-033
1-LT-462
1
While performing the above independent reinspections, it was observed
and noted with respect to support 33A, that the serrated grooves on
the spring nuts did not align with the channel clamping ridge as
required by attribute 4.5 of QI-055.
However, the ERC inspector
signed off the attribute as being acceptable. This is an NRC
deviation (445/8516-D-50).
r.
Category I Conduit Supports
Status of CPRT Activity
A total of 110 Category I conduit supports were randomly selected from
a population of 5500. The number of supports inspected, to date, is 71.
Physical reinspections are being accomplished using QI-053, Revision 0,
and are approximately 64% complete.
Nineteen deviations have been
identified and are being reviewed t,y ERC for validity and safety
significance. Two have been processed and were found to be not valid.
'
Status of NRC Inspection Activity
(1) The NRC inspector reviewed QI-053, Revision 0, and QI-054,
Revision 0, and witnessed the following three reinspections
during this report period:
Verification Package No.
Equipment No.
Unit No.
I-S-COSP-046
C03609956-04
1
I-S-COSP-073
C-140-06419-01
1
I-S-COSP-071
C-14W-13102-05
1
(2) During the reinspections, ERC identified the following conditions
to the NRC inspector as subject to evaluation as potential
deviations:
_
,, s
,
33
I-S-COSP-046:
A 3/8-inch Hilti, on south end, had a 1/8-inch gap
'
between unistrut and wall.
I-S-COSP-071:
(a) Plate size was incorrect, and (b) a nut was
. bottomed out on Hilti bolt threads.
Dispositions of the above findings are open items (445/8516-0-51
and 445/8516-0-52).
No NRC violations or deviations were identified.
s.
Documentation Review of Fill and Backfill Placement
Status of CPRT Activity
Documentation review of the sample of 120 fill and backfill placements
is approximately 92% complete.
A total of 254 deviations have been
identified and are being evaluated for validity.
No physical
reinspections are planned.
Status of NRC Inspection Activity
The NRC inspector reviewed Revision 3 of QI-057.
No independent
document reviews have yet been performed.
No NRC violations or deviations were identified.
t.
Field Fabricated Tanks
Status of CPRT Activity
The population consists of eight tanks which were fabricated on site,
four of which are inaccessible.
Reinspection by ERC is in process
and is approximately 60% complete.
A total of 54 deviations have
been identified which are being reviewed by ERC for validity and
safety significance.
a
Status of NRC Inspection Activity
(1) The NRC inspector reviewed QI-041 for accuracy and adequacy, and
witnessed 10% of the ERC reinspection effort on the following
four tanks:
l
Verification Package No.
Unit No.
I-M-FFTA-01
Common (1)
l
!
I-M-FFTA-02
Common (1)
I-M-FFTA-03
Common (1)
I-M-FFTA-04
Common (1)
,
1
l
. . .
.
, . . -
34
(2) During the above reinspections, ERC identified the following
conditions to the NRC inspector as subject to evaluation as
potential deviations:
I-M-FFTA-01:
(a) A stitch weld was used where a full length
weld is required, (b) weld size was indeterminate on lap joints,
(c) a 3/8-inch fillet weld was specified on 1/4-inch thick
material, (d) Bill of Material item 6 to 11 fillet weld had an
'
insufficient weld throat size,.(e) seismic restralit gussets had
!
insufficient weld throat size, and (f) anchor bolt ring chairs
had undersize welds.
I-M-FFTA-02:
(a) A stitch weld was used where a full length weld
,
'
is required, (b) weld size was indeterminate on lap joints,
(c) undersize fillet weld was present at nozzle locations No. 1
and 15, (d) Bill of Material item 11 to tank shell had an
undersize fillet weld, (d) Bill of Material item 11 to item 6
fillet weld had an undersize throat, (f)-fillet welding on the
davit bracket was undersize, and (g) anchor bolt ring chairs had
undersize welds.
Dispositions of the above findings are open items (445/8516-0-53
and 445/8516-0-54).
No NRC violations or deviations were identified.
,
(3) Due to the small population, the NRC inspector performed
independent inspections of approximately 15% of the defined
{
attributes on the four accessible tanks.
This effort revealed
that reinspections were performed in accordance with the
1
requirements of QI-041.
No NRC violations or deviations were identified.
8.
Exit Interview
An exit interview was conducted on Dec0nber 4,1985, with the applicant
representatives denoted in paragraph 1 of this appendix. During this
interview, the NRC inspectors summarized the scope and findings of the
inspection.
The applicant acknowledged the findings.
1
1
1
(
f
i
i
l
,
-