ML20205D213
| ML20205D213 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/16/1987 |
| From: | Barnes I, Ellershaw L, Hale C, Spessard R, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20205C998 | List: |
| References | |
| 50-445-86-22, 50-446-86-20, NUDOCS 8703300350 | |
| Download: ML20205D213 (49) | |
See also: IR 05000445/1986022
Text
APPENDIX C
COMMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-445/86-22 Permits: CPPR-126
50-446/86-20 CPPR-127. -
Dockets: 50-445 Category: A2
50-446
Licensee: Texas Utilities Electric Company Construction Permit:
Expiration Dates:
Unit 1: August 1, 1988
Unit 2: August 1, 1987
Applicant: Texas Utilities Electric Company
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, July 1 through August 31, 1986
[
Inspectors: C b
Lf E. Ellershaw, Reactor Inspector, Region IV
M
/
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Q(ite
CPSES Group
(paragraphs 2.n, 2.v-z, 3, 4.d-e, 4.1-j,,and
5.c-k)
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C. J. IQ1p, Reactor Inspector, Region IV
CPSES Group
das/v7
Date
(paragraphs 2.a, 2.m. 2.0, 4.b-c,-4.f-h,
6.a, 7, 8, and 9)
?{0330035007fO$45
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$ $=__ "
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[ P. C. Wagner, Reactor. Inspector, Region IV Date
CPSES Group
'(paragraphs 2.b.-1, 2.p-u, 4.a. 5.a-b, and 6.b)
Consultants: 'EG8G - J. Dale (paragraphs 2.z, 3, 4.j, and 5.j)
A. Maughan-(paragraphs 2.b-1, 2.p-u, and 5.a)
- W. Richins (paragraphs 2.n, 2.v-y, 4.d, 5.e)
V. Wenczel (paragraphs 8 and 9)
Parameter - J. Birmingham (paragraphs 4.b-c, 4.f-h, and 7)
K. Graham (paragraphs 4.e, 5.c-d, 5.f 5.1 and 5.k) '
D. Jew (paragraphs 4.1, and 5.g-h)
Reviewed by: - .
.
4WM
Spessard~,/ Deputy Director, Division of
e8
Date
7
R. L'.
Inspection Pr'ograms, Office of Inspection
and Enforcement
Approved: 8w UNM~/
I. Barnes, Chief, Region IV CPSES Group Date
<
Inspection Summary
Inspection Conducted: July 1 through August 31, 19E6 (Report 50-445/86-22;
30-446/86-20)
Areas Inspected: Nonroutine, unannounced inspection of applicant actions on 1
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previous inspection findings; employee protection posting; assessment of
d11egations; Comanche Peak Response Team (CPRT) issue-specific action
plans (ISAPs); CPRT central and working files; ERC overview inspection program;
and procurement, receiving, and storage.
Results: Within the seven areas inspected, four violations (stainless steel
and carbon steel were stored in outside areas with improper protective end
coverings, paragraph 6.a; records of heat treatment were not available for disc ,
inserts and spares for main steam safety valves, nor was it apparent that ;
proper source and receipt ins
nonconformance reports (NCRs)pections were performed,
dealing with installed paragraph
valve bonnets were 4.g;
incorrectly dispositioned, paragraph 4.1; and a correct assessment was not
provided regarding adequacy of design with respect to square groove welds in
HVAC duct supports, paragraph 2.z) and six deviations (objectivity forms and
evaluations had not been completed for certain members of the CPRT staff,
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paragraph 2.a; and Evaluation Research Corporation (ERC) documentation package
review failed to identify four inspectors and two welders involved in the
package being reviewed, paragraph 4.h; ERC overview inspection failed to
identify deviating conditions and unsatisfactory decisions made by the initial
ERC inspector, paragraph 5.g; ERC identified eight deviations on a pump but
did not tag the pump, paragraph 5.c; diaphragm valves were purchased to an
earlier version of the ASME Code than that committed in the Final Safety
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Analysis Report (FSAR), paragraph 4.i; and ERC engineering did not identify all
safety significant attributes on the inspection checklist for mechanical
equipment installation, paragraph 5.c) were identified.
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DETAILS
1. Persons Contacted
- J. W. Audas, Senior Licensing Engineer, Texas Utilities
Generating Company, (TUGCo)
- J. L. Barker, Engineering Assurance Manager, TUGCo
L. B. Barker, Executive Assistant, TUGCo
- R. T. Bentley, Technical Assistant, CPRT
- C. T. Brandt, Quality Engineering Supervisor, TUGCo
- R. E. Camp, Project General Manager, Unit 1, TUGCo
- W. G. Counsil, Executive Vice President, TUGCo
B. DuBois, Quality Assurance (QA) Manager, TERA
P. E. Halstead, Site Quality Control (QC) Manager, TUGCo
M. Keathley, Lead Electrical QC Inspector, ERC
- J. Krechting, Director of Engineering, TUGCo
- J. C. Kuykendall, Vice President, TUGCo
- J. Mallanda, Electrical Review Team Leader, CPRT
- J. T. Merritt, Jr. , Director of Construction, TUGCo
C. K. Moehlman, Project Mechanical Engineer, TUGCo
- L. D. Nace, Vice President, TUGCo
0. Nevins, Training Coordinator, TERA
A. A. Patterson, Reinspection Engineering Supervisor, ERC
- F. L. Powers, Assistant Unit 1 Project Manager, TUGCo
P. Pussalugo, Equipment Qualification Engineer, TUGCo
F. Schafer, Systems Engineering Manager, TERA
B. Shair, Lead Electrical Engineer, ERC
P. Stevens, Electrical Engineer, TUGCo
- J. F. Streeter, Director of QA, TUGCo
T. G. Tyler, CPRT Program Director, TUGCo
R. F. Wright, Manager, Warehouse and Material Control, TUGCo
The NRC inspectors also interviewed other CPRT and applicant employees
during this inspection period.
- Denotes personnel present at the August 7, 1986, exit interview.
- Denotes personnel present at the September 5, 1986, exit
interview.
- Denotes personnel present at both of the above exit interviews.
2. Applicant Action on Previous Inspection Findings
a. (Closed) Deviation (445/8511-0-02): An issue coordinator that had
been previously involved with CPSES activities had not been
identified to the NRC, r.or had the CPRT provided justification .
regarding his objectivity as required by Section VII of the CPRT
Program Plan.
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Revision 3 to the CPRT Program Plan deleted the commitment from
Section VII to identify and provide justification to the NRC when
third party personnel were found to have had prior CPSES involvement.
By letter to the NRC dated April 1, 1986, (Counsil to Johnson), it
was further committed that all CPRT personnel would complete
objectivity questionnaires (Attachment 7 of the CPRT Program Plan).
When completed questionnaires identified prior CPSES involvement or
association of an individual, further evaluation was required by the
Senior Review Team (SRT) for Review Team Leaders (RTLs) and by the
RTL for their assigned personnel. In such cases, evaluation forms
were to be completed documenting the basis for the SRT or RTL
conclusions concerning the objectivity of such an individual. These
objectivity and evaluation forms were to be completed by the end of
April 1986.
The NRC inspector verified the implementation of these revised
commitments by: (1) a review of a sample of the ERC and TERA files
on objectivity of personnel (the TERA records were in Bethesda,
Maryland, and QA branch personnel from the Office of Inspection and
Enforcement conducted this review); (2) review of all the objectivity
records of the testing and electrical personnel; and (3) review of a
sample of the files of the SRT and their support staff. The
objectivity questionnaires and their evaluations by the appropriate
authority were found to be in compliance with the revised commitments
with the following exceptions.
The technical support staff (two individuals) of the CPRT Program
Director had not completed objectivity questionnaires nor had the
personnel on the records review committee. The CPRT Program Director
did not believe the revised commitment applied to these individuals;
however, the commitment states that these documents had been
completed for the SRT, RTL, and support staff. Further, a commitment
was made to document an evaluation of the objectivity forms for all
CPRT personnel by April 1986; however, such an evaluation was not
made for the CPRT Program Director and the TERA RTL evaluation was
not completed until July 17, 1986. These findings represent a
deviation from commitment (445/8622-D-01; 446/8620-0-01).
b. (Closed) Open Item (445/8511-0-01): Incorrect electrical pull box
location. Further NRC review established that the ERC determination
of incorrect box location was based on a drawing which was for
guidance only and did not contain mandatory location requirements.
The NRC inspector verified that the box had been properly installed
and met all of the required quality procedure checklist items.
c. .(Closed) Open Item (445/8511-0-09): Sharp cable trap edges and cable
. jacket damage. Further NRC review found that NRC Inspection Report
50-445/86-01;-50-446/86-01 had incorrectly associated NCR E85-100831
, with this open item. The correct NCR (i.e., E85-100844) was found to
have been dispositioned and closed. The disposition stated that
since the sharp edges were not inside the cable tray but were on the
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tray's lip, above the cable jacket, the conditions were acceptable.
The NRC inspector performed a reinspection of the cable tray and
-found that the NCR had been properly dispositioned.
d. (Closed) Open Item (445/8511-0-11: Loose splice plate bolt.. Further
NRC review found NCR E85-100988 had been dispositioned and closed.
The disposition stated that the nut was jammed and could neither be
tightened or removed. The condition was determined to be acceptable
since Design Change Authorization (DCA) 3883, Revision 2, requires
only six bolts per plate and there are'eight bolts in this plate.
.The NRC inspector performed a reinspection of the splice plate for
this NCR and found that the NCR had been properly dispositioned.
e. (Closed)'Open Item (445/8511-0-21): Missing fire seals. The
findings that fire stop sealing material was not present in the
conduit stubs which entered a control room panel was evaluated during
a review of the ERC deviation report (DR). A review of the
applicable project requirements by the NRC inspector showed that the
seal material can be installed in either end of the conduit and an
inspection revealed that it was installed in the opposite end of
these conduits.
f. (Closed) Open Item (445/8511-0-22): Improper electrical separation.
The condition of conduit C13016035 ending just under tray T130CCQ64
instead of ending 10" above the tray was identified during a
witnessed ERC. inspection. Further review by the NRC showed that
Drawing 2323-El-1702, Note Sc, allowed this type of installation
provided 2" of slack was maintained. Reinspection by the NRC of the
installation found it to be acceptable.
g. (Closed) Open Item (445/8511-0-23): Group of cables bearing on
single cable, Further review by the NRC found NCR E85-101047X had
been dispositioned and closed. The disposition stated that the
indentation of the cable outer jacket was minor and would not affect
conductor performance. The NRC inspector performed a reinspection of
the cable and found that the NCR had been properly dispositioned.
h. '(0 pen) Open Item (445/8511-0-24): Lack of cable slack. This item
pertained to a lack of the required 2" of cable slack at the cable
tray (T130 SCC 65) to conduit (C13015570) transition for cable E0106091.
Further' review by the NRC inspector showed NCR E85-101211SX had been
written for this deficiency. This item remains open pending
disposition of the NCR.
i. (0 pen) Open Item (445/8511-0-31): Cable with cut outer jacket. This
item pertained to a two conductor cable with a cut outer jacket which
_w as located at the floor penetration for motor control center (MCC)
'
IEB1-1. Further review by the NRC showed NCR E85-101048X had been
written for this finding. This item remains open pending disposition
of-the NCR.
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j. (0 pen) Open Item (445/8511-0-32): Incorrect tray to conduit
separation. This item pertained to less than the required 1" of
separation between a cable tray (T030 SCC 68) and a lighting conduit.
Further review by the NRC showed NCR E85-100180S had been written for
this finding. This item remains open pending disposition of the NCR.
k. (Closed) Open Item (445/8511-0-38): This item pertained to the lack
of CPRT quality instructions governing ISAP I.a.5 activities.
Further review by the NRC of the required tasks, redispositioning of
NCRs and obtaining a vendor analysis report, showed that the
activities were already governed by acceptable existing site
procedures.
1. (Closed) Violation (445/8511-V-01): Inspector failed to write NCR.
During an NRC witnessed reinspection, a TUGCo QC inspector failed to
document nonconforming conditions and process an NCR in a prompt
manner relative to out-of-scope ERC inspection findings. The
inspector involved was retrained to Procedure CP-QP-16-0,
"Nonconformances," on September 16, 1985. For the nonconforming
conditions identified, TUGCo has issued NCR E85-100993X. In addition
to the above actions, ERC Procedure CPP-020, "Out-of-Scope
Observations," Revision 0, was issued on August 23, 1985, to provide
a procedure to third party inspectors to follow in documenting
out-of scope observations.
m. (Closed) Open Item (445/8511-0-37): Prior to the development of_the
design adequacy procedures (DAPs), TERA personnel used informal work
instructions to control their activities.
The DAPs manual was issued in October 1985. This manual is fully
developed, presently containing 23 procedures. NRC inspectors from
the QA branch in the Office of Inspection and Enforcement have
inspected the adequacy and implementation of these procedures at
TERA's office in Bethesda, Maryland, and Berkeley, California. The
results of these inspections are documented in NRC Inspection Reports
50-445/86-17; 50-446/86-14 and 50-445/86-19; 50-446/86-16.
NRC personnel involved in these inspections observed that very little
work was performed by TERA prior to March 1986 that would have
required these procedures being in place. Therefore, the DAP manual
was issued before substantive TERA work was conducted,
n. (Closed) Deviation (446/8513-D-11): This deviation addressed field
reinspection of a containment liner package that included weld seams
between materials of unequal thickness. Change Notice 001 to QI-031,
Revision 2, provided guidelines for measuring reinforcement of welds
using a contour gauge for weld seams between materials of unequal
thickness. Approximately 38 containment liner packages were
reinspected. Two new DRs were issued, ten were superseded, and six
were invalidated. The NRC inspector inspected containment liner
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Verification Package I-S-LINR-061 using Change Notice 001 to QI-031,
Revision 2, and found the weld reinforcement to be acceptable. A
sample offthe results of the additional reinspections by ERC for weld
rein'forcement was reviewed by the NRC inspector. The committed
corrective actions were found by the NRC inspector to have been
., correctly implemented.
o. .(Closed) Open . Item (445/8513-0-01): TERA identified a potentially
-reportable condition on August 27, 1985. This open item was
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initiated in order to track its disposition.
.
. t Discrepancy / Issue Resolution Report (DIR) D-0004 was initiated by
' TERA on August 27, 1985, concerning the evaluation of an air gap
deviation using methodology in apparent conflict with FSAR
commitments. "On July 26, 1985, a significant deficiency analysis
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report was,issu'ed (CP85-27) and the NRC was notified that the matter
< - was potentially' reportable under paragraph 50.55(e) of 10 CFR
Part 50. On December 17, 1985, this item was determined to be
reportable and a report was submitted to the NRC. This matter is
included in the CPRT's assessment under ISAP II.c, which the NRC is
monitoring on a continuing basis. Accordingly, this item is closed.
p. (Closed) Open Item (445/8513-0-25): Conduit separation and loose
fittings. This item pertained to two loose conduit couplings and
separation between two conduits being less than the required 1".
These conditions were identified during a witnessed ERC inspection
and were additionally addressed in NRC Inspection Report
50-445/86-01; 50-446/86-01. NRC review during this report period
found that NCR E85-101496SX had been dispositioned and closed. The
disposition of the NCR required the couplings to be tightened and the
conduits reworked to meet the 1" requirement. The NRC performed an
inspection of the conduits and found the reworked condition
acceptable.
q. (Closed) Open Item (445/8513-0-28): Incorrect tray node
identification. This item pertained to a tray section identification
tag not located as shown on Drawing 2323-El-0500-16. Further NRC
review of Drawing 2323-El-0500-16 found that note 1 is used only to
identify the location of the tray segment, not its identification.
Review of TUGCo Instruction QI-QP-11.3-24, " Class IE Cable Tray
Raceway Inspections," by the NRC inspector found that the tray
identification tag was properly installed,
r. (0 pen) Open Item (445/8513-0-38): Misaligned torque indicators.
This item pertained to anti-torque indicators on flexible hose
connections which were misaligned. Further NRC review found that
DR-I-E-ININ-005-DR01 and NCR 185-101251SX had been written for this
condition. This item remains open pending disposition of the NCR.
s. (0 pen) Open Item (445/8513-0-39): Loose lighting switch box. This
item pertained to a lighting circuit switch box which was loose.
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Further NRC review found that NCR E86-101053X had been written for
this condition. This item remains open pending disposition of the
.NCR.
., t. :(0 pen) Open Item'(445/8514-0-03): Cable routing and conduit
. . identification. The conditions of incorrect routing for cable
EG113538 and two through-wall conduit sleeves with the same
identification number were noted during a witnessed ERC inspection.
-Review of ERC Verification Package I-E-CABL-078 by the NRC inspector
showed that DR I-E-CAB-078-DR01 and NCR E85-101382SX had been written
for these conditions. This item remains open pending disposition of
the NCR.
u. (Closed) Open Item (445/8514-0-11): Incomplete procedure. The
condition that an ERC procedure (QI-009) did not reference the
specific procedures for plant Class IE lighting conduits was resolved
by the initiation of a new population for lighting circuits. The new
population covered all aspects of the plant lighting circuits,
including the conduits, and resulted in the removal of lighting
circuits from the other populations; i.e., conduit, cables,
equipment. Therefore, the new population eliminated the need to
incorporate lighting conduit procedures in the conduit inspection
procedures.
v. (Closed) Deviation (445/8516-D-41): This deviatica
addressed: (1) an inconsistency regarding measurement of liner
contour between ERC QI-031, Revision 0, for containment liner
reinspection and Gibbs & Hill (G&H) Containment Liner
Specification 2323-S5-14, Revision 4; and (2) a failure to provide
comprehensive instructions for reinspection of containment liner
contour using a 10' straight edge.
The committed corrective action involved the revision of the
applicable paragraphs in QI-031. ERC conducted a review of each QI
for clarity and discussed changes to QI-031 with the ERC inspectors.
QI-031 was revised and Revision 1 was issued on January 15, 1986. A
review of inspection packages completed prior to this date was
conducted by the NRC inspector. The committed corrective actions
have been made to determine if any package was inappropriately marked
"N/A" for Attribute A.1.b. In addition, ERC determined that previous
inspections using the 10' straight edge (Attribute A.1.d) were
correctly performed.
The NRC inspector reviewed the changes made to QI-031 to assure
consistency with G&H Specification 2323-55-14 and that adequate
instructions were provided for the measurement of containment liner
contour. The NRC inspector also discussed with the ERC population
engineer and inspectors, the methods used for inspection of these
attributes prior to January 15, 1986. The NRC inspector reviewed an
additional ten containment liner reinspection packages and determined
that the original ERC reinspection conformed to Attributes A.1.b. and
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A.1.d of QI-031, Revision 1. The committed corrective actions were
verified to have been implemented,
w. (Closed) Deviation (445/8516-D-42): -This deviation addressed field
reinspections of containment liner packages by ERC that were not
performed in accordance with approved instructions. The ERC
inspector entered "N/A" for not applicable and " dome only" in the
remarks column for Attribute A.1.a on the checklists for three
containment liner packages. These verification packages involved the
cylindrical liner and Attribute A.1.a did, in fact, apply.
The committed corrective actions involved the revision of ERC QI-031
and a review of reinspection packages. In addition to the 3 noted
verification packages, 14 other packages initially reinspected by the
same ERC inspector were identified as having "N/A" and " dome only"
entered for Attribute A.1.a. These packages were reinspected for
Attribute A.1.a and two new DRs were issued regarding liner contour.
The NRC. inspector has reviewed the corrections made to QI-031, the
results of the ERC reinspection of Verification Packages I-S-LINR-08,
I-S-LINR-12, and I-S-LINR-61, and three of the additional packages
reinspected by ERC for Attribute A.1.a. The committed corrective
actions have been verified by the NRC to have been implemented.
x. (Closed) Deviation (445/8516-D-47): This deviation addressed the
completeness and accuracy of an ERC checklist for a concrete
placement reinspection. Attribute 3. A of the completed checklist for
Verification Package I-S-CONC-015 was neither accepted nor rejected;
i.e., not signed off, and actual reinspection for this attribute
could not be verified. The checklist was approved and signed by both
the lead inspector and the lead discipline engineer.
The committed corrective actions were the reinspection of this
verification package for Attribute 3.A. and ERC management meetings
'with all ERC inspectors and leads to emphasize the importance of
providing complete and accurate information. The overview inspection
program has also been implemented to reinspect a sample of each
inspector's work. The NRC inspector reviewed ERC's reinspection of
Verification Package I-S-CONC-015 and established from record review
that training meetings were held with ERC inspectors and' leads. A
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review of the overview inspection program is ongoing. The committed
corrective actions have been implemented.
y. (Closed) Deviation (445/8516-D-48): [ Note: This deviation was
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incorrectly identified as 445/8516-D-47 in the Notice of Deviation, !
NRC Inspection Report 50-445/85-16; 50-446/85-13. Appendix 0 of that
report torrectly identified the deviation as 445/8516-D-48]. This
deviation ^ addressed field reinspection of a concrete placement
,
package by ERC that was not performed in accordance with approved
instructions. The ERC inspector entered "N/A" for not applicable and
" coated" in the remarks column for Attribute 3.A on the checklist for
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Verification Package I-S-CONC-057. A subsequent NRC inspection,
however, identified that the surface was not coated.
The committed corrective actions involved discussions with the
inspector and a historical review of the inspector's activity by the
ERC overview inspection program. No additional errors were -
identified. The ERC inspector stated that reinspection was made on a
blockout immediately adjacent to the designated blockout. The NRC
inspector has reinspected Verification Package I-S-CONC-057, verified
ERC's reinspection of the correct blockout, and reviewed the results
of the ERC overview inspection program. The committed corrective
actions have been implemented.
z. (Closed) Unresolved Item (446/8602-U-12): It was not apparent that
inspection of square groove weld penetration conditions had been
considered in the Corporate Consulting & Development Company, Ltd.
(CCL) reanalysis of HVAC supports.
Further review of this item identified Memorandum No. BSC-2156, which
references Section 6.2 of Revision 8 to Bahnson Service Company (BSC)
Procedure DFP-TUSI-003 and states, "The following shall be considered
a part of the subject procedure: All groove welds on the seismic
duct hanger detail drawings shall be shown as square groove welds.
Unless otherwise stated the weld shall be considered partial
penetration. No size will be shown. Per the attached test results a
penetration of not less than 1/8" (0.125") is achieved. These tests
results with coupons are retained in DCC."
This 1/8" penetration has been used in CCL's reanalysis of HVAC
supports in Unit 2. However, the available documentation for the
original test program did not assure that the test results were fully
representative of minimum penetration conditions that could occur
during field welding; i.e., the position used to weld the samples was
not recorded and etching was performed on weld sample ends rather
than on sections cut from samples. Further, the tests coupons were
not retained in the Document Control Center (DCC) and could not be
located.
Additional welded samples were prepared and sections macroetched,
with the NRC inspector witnessing the activities. The samples were
welded with a 3/32" electrode in the vertical position using BSC
Welding Procedure Specification BSC-20. Macroetching of sections
revealed a maximum partial penetration of 0.047", which is 0.078"
less than the claimed penetration used for reanalysis.
The unresolved item is closed and replaced by a violation, as a
result of the original test program documentation and witnessed
macroetch activities failing to provide an appropriate test basis for
assumptions used in the design analysis (446/8620-V-02).
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Employee Protection Posting
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[ Paragraph (e) in 10 CFR Part 50.7, " Employee Protection," requires the
j applicant to post Form NRC-3 " Notice to Employees" on its premises.
Posting must be at locations sufficient to permit employees to observe a
copy on the way to or from their place of work.
As-a. result of recent relocations and modifications to entrances and
! exits, the NRC inspector performed an inspection to determine if TUGCo
was in compliance with the above requirements. The inspection revealed
that TUGCo was in. compliance in that Form NRC-3 had been conspicuously
posted at all entrances and exits to the job site, and at various
i. locations within Units 1 and 2.
No violations or deviations were identified.
,
4. CPRT ISAPs (Excluding ISAP VII.c)
a. Butt Splice Qualification ISAP I.a.3
The NRC inspector participated, with representatives of NRR and the
applicant, in an inspection of selected Unit 1 panels known to
i contain the AMP splices that are the-subject of this ISAP. The
, panels-(i.e., control room relay panel CR-03, cable spreading room
'
. termination cabinets TC 41 and TC 42, and auxiliary building MCC
- CEB 4-1) were inspected to familiarize the NRR representative with
the type.of installations and configurations in which the splices ~are
4 installed.
During this inspection, the NRC inspector noted wrappings of
electrical tape on a conductor in control room panel CP1-ECPRCR-03.
i
- The green conductor of cable E0112530 was subsequently identified as
having had its insulation repaired and inspected by Maintenance
Action Request (MAR) 85-0757 as implemented by Operation Traveler
4
EE85-11348-2203.
No violations or deviations were identified.
b. QC Inspector Qualifications (ISAP I.d.1)
i During this report period, the activities identified by NRC Reference
No 01.d.01.04 were inspected as follows:
'
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Phase III Sample Selection and Reinspection (NRC Reference No.
01.d.01.04)
- The NRC inspector reviewed four reinspection matrices approved by the
ERC Discipline Level III inspector. These matrices were used to
evaluate the performance of those inspectors placed into Phase III
due to documentation difficulties with their qualifications. The
reinspection matrices were for TUGCo Instructions QI-QP-11.2-1,
a-
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Revision 16, " Installation of Drilled-in Hilti Bolts"; QI-QP-11.14-8,-
Revisions 1 and 2, " Verification of Installation of Richmond Insert
Bolts"; QI-QP-11.0-15. The NRC inspector verified that the
'
reinspection matrices identified the inspection procedures and
4
' . designated the' inspection attributes as recreatable/nonrecreatable
s and subjective / objective as defined in ERC QI-005, " Evaluation of
- Inspector Performance."
~
The NRC inspector witnessed the ERC Phase III reinspection of TUGCo
" Inspection Reports (irs) 2-0010162 and 2-0020136. Subsequent NRC
review of,the completed ERC reinspection matrices for these two irs
found-them to be complete and to properly reflect the actual field
conditions.
No violations or deviations were noted during this inspection.
c. Craft Personnel Training (ISAP I.d.3)
During this report period, the ISAP activities identified by NRC
Reference Nos. 01.d.03.02, 01.d.03.03, 01.d.03.04, 01.d.03.05,
01.d.03.06, and 01.d.03.07 were inspected as follows:
Interview Personnel (NRC Reference No 01.d.03.02)
The NRC inspector reviewed the documentation from the interviews of
site personnel conducted by ERC. Thirty-seven interviews of
personnel were conducted, with the selection of personnel interviewed
ranging'from general superintendents to craft journeymen and helpers.
The NRC inspection was performed to determine if the attributes
listed in Section 4.1.2 of the ISAP were included.- Since no
established list of questions was utilized in the ERC interviews, the
NRC inspector reviewed the interviews to assure that each attribute
was included. It was found that the interviews in total did address
each attribute, although not every attribute was applicable or
addressed in each interview; e.g., attributes applicable to
management were only addressed in the management interviews.
From review of interviews, the NRC inspector determined that specific
areas of NRC Technical Review Team (TRT) concern, such as knowledge
of criteria used for lifting of heavy loads and installation of
electrical supports were addressed in interviews of the
representative craft personnel.
Separate NRC interviews of personnel are planned to be conducted
during a subsequent inspection.
No violations or deviations were noted.
-14-
'
. Observe Training and Field Activitics (NRC Reference No. 01.d.03.03) I
- - 1
-
- : The NRC inspector reviewed the records of ERC's observations of
>
training and field activities. These records showed that one class
- *
each of mock up training, classroom training, and procedural training )
'
were observed. The lesson plan for each class was reviewed by the
. . NRC inspector. The ERC observations were found by the NRC inspector j
,
to be in agreement with the lesson plans. The records of field 1
activities observed showed that 11 field activities were observed '
which included installation of Hilti bolts and pipe hanger rework in
-
the mechanical discipline, cable termination and pulling in the
electrical discipline and installation of a duct and a duct hanger
for HVAC. The field observations lists were noted by the NRC
inspectcr to contain attributes that would be found in the applicable
procedures, but did not give either a direct reference to the procedure
in most cases, or provide specific evidence of craft compliance with
these attributes. The ERC observers were determined by the NRC
. inspector from file review to have previously reviewed the craft
procedures to familiarize themselves with the craft activities to be
observed. The NRC inspector verified that the listed procedures were
applicable to the field activities observed. Additional assessment
of the adequacy of field activity observations will be made during a
subsequent NRC inspection.
No violations or deviations were identified during this inspection.
Recommendations for Improvement and Evaluation of Changes (NRC
Reference Nos. 01.d.03.04 and 01.d.03.05)
The NRC inspector verified performance of the following ERC
activities by inspection of documents in the working files for this
ISAP.
ERC addressed through implementation of this ISAP the specific TRT
concerns for conduit supports, lifting of heavy loads, and the
general concern of craft training. ERC found by interviews of
electrical personnel and observation of a conduit support
installation that craft were aware of necessary documents of
installation, but did not always recall the formal name of the
documents. ERC found by review of the training procedure, interviews
of rigging personnel, training records, and a field observation that
training related to lifting of heavy loads was adequate. ERC also
found as a result of interviews, procedure review, and field
observations that the training programs of Brown & Root (B&R) and BSC
craft personnel were adequate and therefore recommendations for
improvement or evaluation of changes were not applicable.
The NRC inspector inspected the current training procedure of B&R and
found that it met the requirements of ANSI N45.2, 1971, and the
guidelines on training given by Section D of the Gray Book, " Guidance
on Quality Assurance During Design and Procurement Phase of Nuclear
-15-
Power Plants." The NRC inspector verified a portion of the training
records listed in the ERC working files by reviewing the signed
attendance sheets in the TUGCo training files. The NRC inspector
inspected the lesson plans for the training classes that were
monitored by ERC and found that the lesson plans support the ERC
observations of mockup, classroom, and procedural training adequacy.
The ERC review of Corrective Action Requests (CARS) related to craft
training was inspected by the NRC inspector.
A sample of the CARS reviewed by ERC was inspected in detail. These
CARS were found by the NRC inspector to support ERC's determination
that most craft training related CARS pertained to documentatiei,
administrative, and clerical deficiencies rather than craft training
program or implementation deficiencies. NRC inspection of the BSC
training program will be reported in a subsequent inspection report.
No violations or deviations were identified.
Qualification of Personnel (NRC Reference No. 01.d.03.06)
The NRC inspector verified the qualification of personnel associated
with the evaluation of this ISAP. The resumes and objectivity
questionnaires from the personnel files were; reviewed and found to
meet the requirements of the CPRT Program Plan.
No violations or deviations were noted during this inspection. No
further NRC inspection is planned for this reference area.
Root Cause Determined from VII.c Results (NRC Reference
No. 01.d.03.07)
The results report for ISAP I.d.3 was approved by the SRT on
August 27, 1986. No program deviations or deficiencies were
identified by ERC; therefore, root cause and generic implication
analyses were determined by ERC to be not applicable. NRC evaluation
of this determination will be reported when inspection of I.d.3
activities is completed. Craft training may be determined to be the
root cause of construction deficiencies or adverse trends found
'
during implementation of other ISAPs, including VII.c. If this
'
occurs, the Collective Evaluation Group is responsible for evaluation
of' that determination. NRC inspection of the Collective Evaluation
Group. activities for this ISAP reference area (01.d.03.07) will be
,,
< reported when the collective evaluation is completed.
, , ,
t
Noitolationsordeviationswerenotedduringthisinspection .
.
4
2
%.
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d. Maintenance of Air Gap Between Concrete Structures (ISAP II.c)
The following activities for ISAP II.c were reviewed by the NRC
inspector during this report period:
Reinspect and Assess As-Built Condition (NRC Reference No. 02.c.01.00)
The NRC inspector reviewed Unit 1 and Unit 2 work in progress on
single wall, secondary wall, and basemat gap initial clean out and
inspection. These activities are complete for single wall gaps. The
initial clean out of foam to allow for. gap inspection has started for
secondary wall gaps with approximately 70% of the work complete. The
initial clean out of foam and inspection of the as-built condition
has also started for gaps associated with the basemat.
Initial clean out and inspection of double wall gaps is essentially
complete with the exception of several areas at or near the basemat
that are not accessible through existing access points. Two
blockouts, approximately 6' x 6', have been cut through the auxiliary
building walls to provide access to the gaps between the auxiliary
and safeguards buildings for both Units 1 and 2 at the 790' level.
Five additional blockouts are planned.
No violations or deviations were identified.
Removal of Debris or Rotofoam (NRC Reference No. 02.c.02.00)
The NRC inspector witnessed ongoing cleaning and repair activities of
air gaps between structures in Units 1 and 2 during this report
period. These activities included use of a high pressure water jet
system, concrete removal from single walled gaps, grinding of
concrete in secondary wall gaps to increase the gap dimensions, and
removal of debris through the blockouts discussed above.
NRC inspections were not performed on other activities during this
report period.
No violations or deviations were identified,
e. Plug Welds (ISAP V.d)
The following activities for ISAP V.d were reviewed by the NRC
inspector during this report period:
Determine Effects of Plug Welds on Quality of Supports (NRC Reference
No. 05.d.09.03)
A concern relative to the effect of plug welds on the quality of
supports is the influence on weld properties of the slag removal
method used during welding. To address this concern, a program was
established by the CPRT in which 3/4" diameter plug welds were made
-17-
in 3/8" thick predrilled plates. Three welders were randomly
selected from a list of all welders qualified to make plug welds.
Each welder was provided with eight test plates and instructed to
make plug welds and remove slag with a chipping hammer and wire brush
on the first four test plates, and a grinding tool on the remaining
four test plates. Each of the 24 test plates was radiographed per
AWS 01.1. Three test plates were selected from each slag removal
process used by each welder (i.e., 18 plates) and tensile test
coupons were prepared and tested per ASTM E8.
The two remaining coupons prepared by each of the the three welders
were sectioned, polished, and acid etched for macroscopic testing.
The NRC inspector will review all test results and associated
documentation during a subsequent report period.
No other activities in this ISAP were inspected during this report
period.
No violations or deviations were identified.
f. Periodic Review of the QA Program (ISAP VII.a.5)
During this report period, the ISAP activities identified by NRC
Reference Nos. 07.a.05.01 and 07.a.05.02 were inspected as follows:
Develop Criteria for Review of the QA Program (NRC Reference
No. 07.a.05.01)
ERC considered information obtainr>d from INP0 and guidance from the
USNRC Standard Review Plan in developing the review criteria to
assess the current management review of the QA program. The review
criteria specified that a policy statement of management objectives
for the QA program be published and that specific details be
developed to assure management's review of progress in meeting those
objectives. In addition, the review criteria required management
review of: current QA status reports, including any deficiencies
from all departments; trend analysis reports; audit reports; notices
and bulletins from external sources; construction progress reports;
and other typical sources. The ERC review criteria further specified
that the methods should be detailed by which management would:
respond to reported information; track deficiencies and assure that
followup and closecut is performed; and provide for an annual review
of management's actions in meeting the published objectives. The NRC
inspector verified that the applicable elements of the USNRC Standard
Review Plan were incorporated in the ERC review criteria. The NRC
inspector determined that the ERC review criteria would provide an
adequate basis to perform an evaluation of management review of the
QA program required in paragraph 4.1.2.4 of the ISAP.
!
-18-
ERC's development of review criteria is complete. No violations or
deviations were identified and no further NRC inspection is planned
for this reference area.
Evaluation of the Current QA Program Review Versus the Developed
Criteria (NRC Reference No. 07.a.05.02)
The NRC inspector reviewed the ERC issue coordinator's evaluation of
the current QA program review. The ERC evaluation reviewed Policy
Statement No.2, Revision 0, issued by the Executive Vice President
for Nuclear Engineering and Operations (NE0). This policy statement
details the QA program objectives and defines the responsibilities of
the Director of QA and the organizational vice presidents. The
policy specifies that the vice presidents shall meet periodically to
assess the status and adequacy of the QA program and at least
annually provide a written assessment of the QA program to the
Executive Vice President, NE0. The Executive Vice President, NE0, is
responsible to assure that an annual independent assessment of the
TUGCo QA program is performed. NE0 Procedure 2.20, Revision 1,
" Senior Management QA Overview Program," details the methods by which
the objectives of the policy statement are to be implemented. The
issue coordinator reviewed NE0 2.20, Revision 1, and attended the
first two meetings of the Senior Management Quality Assurance
Overview Committee. The notes and recommendations of the issue
coordinator and the minutes of the overview committee meetings were
reviewed by the NRC inspector. The results of this review showed
that the issue coordinator had evaluated the meetings against the
objectives of Policy Statement No. 2 and the ERC developed criteria.
NRC's review of these notes and Revision 1 of NE0 2.20 showed that
recommendations of the issue coordinator had been incorporated.
No violations or deviations were identified and no further NRC
inspection is planned for this reference area.
g. Receipt and Storage of Purchased Material and Equipment (ISAP VII.a.9)
Receipt Inspection Report (RIR) 13686 was inspected by the NRC as a
sample of the implementation of ISAP VII.a.9. During this
inspection, a disc insert for main steam safety valve CP2-2MS-021 and
two spare disc inserts were found not to have required records of
heat treatment available in the documentation package. The NRC
inspector noted that implementation of ISAP VII.a.9, Revision 0,
would not have identified the deficiency. For this and other
reasons, ISAP VII.a.9 is undergoing revision. The failure to have
heat treatment records for the indicated disc inserts is a violation
(445/8622-V-02; 446/8620-V-03).
.
-19-
[ ,
, h. 'Onsite~ Fabrication (ISAP VII.b.1)
m
~'
During this report period, the ISAP activities identified by NRC
,
.
, Reference Nos. 07.b.01.01 and 07.b.01.03 were inspected as follows:
Review and Evaluate Procedures for Onsite Fabrication (NRC Reference
.
No. 07.b.01.01)
The NRC inspected the review performed by ERC of material storage,
fabrication, and inspection procedures applicable to both ASME and
non-ASME onsite fabrication. The ERC review listed the attributes
necessary for control of material traceability, fabrication
processes, and item inspection for acceptability. The ERC review
then identified where the attributes existed in the historical and
the current procedures. NRC inspection of the attributes found them
to reflect the requirements of 10 CFR Part 50, Appendix B,
Criteria VIII and XIII; ANSI N45.2; and the Comanche Peak FSAR. The
NRC inspector selected several of the attributes for inspection and
verified that the attributes were included in the procedures for the
times specified (historical and current) by the ERC review.
No violations or deviations were noted in this area and no further
NRC inspection is planned for the reference item.
Review Fabrication Packages (NRC Reference No. 07.b.01.03)
The ERC sample selection and review of ASME-related fabrication
packages were inspected by the NRC inspector. ERC reviews of
non-ASME packages are near completion and will be inspected and
reported when complete. The 73 ASME-related package reviews were
inspected for overall completeness and adherence to the guidelines of
the ISAP and the review checklists. The following nine ERC package
reviews were selected for inspection in detail:
CC-1-195-015-C42R SI-1-101-011-C41R
CH-1-206-703-E23R RH-1-063-010-S22R
SI-1-031-033-Y32K RH-2-006-408-C42R
PS-2-R8-011-003-2 SW-1-102-086-543R
CT-1-031-015-C82K
These package reviews were compared to the hanger packages and other
applicable documents to determine their completeness and accuracy.
NRC inspection showed that eight of the nine package reviews were
complete and accurate for all review criteria, such as welder or
inspector qualifications, all required inspections complete, required
documentation complete and legible, documentation consistent and in
proper sequence, and traceability requirements met. One package was
noted to have failed to record four inspectors and two welders. This
. deficiency was corrected at the time of discovery and all reviews
performed by the responsible document reviewer were repeated. NRC
-20-
inspection of the repeated reviews found them to be satisfactory.
This deficiency has been identified as a deviation (445/8622-D-03;
446/8620-D-04).
No other violations or deviations were noted.
i. Valve Disassembly (ISAP VII.b.2)
Review Construction and QC Procedures to Determine if They Provide
Adequate Controls of Materials During Disassembly / Reassembly (NRC
Reference No. 07.b.02.03)
NRC Inspection Report 50-445/86-07; 50-446/86-05, documented in
Deviation 445/8607-D-26 the failure of CPRT to identify that B&R did
not have an implementing procedure in existence for a portion of 1983
to control the disassembly / reassembly of valves. The CPRT
investigated to determine the reason (s) for not having a procedure in
effect for the five month time span and what effect it had on the
valve di'sassembly/ reassembly process. The CPRT's response is
documented in a memorandum dated May 23, 1986, from Counsil to
Noonan.
Based on review of the above memorandum, the NRC inspector concurs
with the CPRT finding that with the appropriate portions of QA
Procedure QI-QAP-11-1.26, Revisions 9 thru 12, still in effect, and
the use of an operation traveler similar in format and content to
those utilized prior to the procedural omission, adequate control of
valve disassembly / reassembly existed during this time frame. This
activity is complete.
No violations or deviations were identified.
Perform an Analysis to Determine the Safety Consequences of
Improperly Assembled Valves (NRC Reference No. 07.b.02.04)
An analysis was performed by CPRT to determine the safety
consequences and failure modes of improperly assembled generic
valves. Generic valves are those which required disassembly of all
valves of that type and included ITT Grinnell diaphragm valves and
Borg-Warner check valves.
All possible combinations of reassembling generic valve bodies and
bonnets of the same size and type were evaluated in this analysis.
CPRT concluded that improper reassembly could possibly result in a
loss of valve function for Borg-Warner check valves. For ITT
Grinnell diaphragm valves, it was determined that improper reassembly
would result in ASME Code violations, but not a loss of valve
function. The NRC inspector reviewed this analysis for validity and
completeness, factoring into the review ASME Code requirements and
information received from the valve vendors. However, a satisfactory
response is required with respect to a previously identified
-21-
unresolved item (445/8607-U-28) before a final evaluation of this
ISAP element can be made. This unresolved item deals with the lack
of consideration in the results report, after stating there was a
potential for switching ASME and non-ASME bonnets, of the
significance of differences in QA requirements for non-ASME and ASME .
Code bonnets.
No violations or deviations were identified.
Additional NRC Findings
As a result of DRs identifying the lack of traceability between the
installed bonnet and the vendor supplied NPV-1 form for Valve Tag
Nos. 1-7046 and XSF-179, NCRs were issued by B&R. NCRs M-23175N,
Revision 1, and M-23178N were initiated on February 25, 1986, and
were dispositioned and closed out by TUGCo on July 15, 1986. To
assess the applicant's review of these nonconformances, the NRC
inspector reviewed the NCR dispositions.
The dispositions stated that documentation, except for hydrostatic
testing, was received from the vendor indicating that the bonnet
material met all applicable requirements of ASME Section II and
Section III, ND-2000. The dispositions, however, stated that an
acceptable bonnet hydrostatic test was performed during the
system / subsystem hydrostatic test, as allowed by the ASME Code. In
order to reconcile the fact that the valve bonnet heat numbers did
not correspond with those specified on the vendor's Nuclear
Valves / Heat Code Identification, the dispositions stated that the
bonnets shall be considered as replacement parts and documented as
such on an NIS-2 form, which is an Owner's Report for Repair and
Replacement.
. As a result of this review, the NRC inspector identified the
following:
(1) The disposition was incorrect with respect to an acceptable
bonnet hydrostatic test being performed during the system /
subsystem hydrostatic test. When a diaphragm valve is
hydrostatic tested as a complete assembly, the diaphragm
isolates the bonnet from any hydrostatic pressures, Therefore,
there is still no evidence of the required hydrostatic test
having been properly performed. This incorrect disposition of
the NCRs is a violation (445/8622-V-04).
_
(2) The NRC questions the validity of utilizing an NIS-2 form to
document as-installed components. This matter is an unresolved
item pending the applicant providing the NRC with adequate bases
for using the NIS-2 forms (445/8622-U-05).
(3) Table 3.2-1 in Section 3 of Amendment 56 to the CPSES FSAR
requires that Class 2 and 3 valves shall meet the requirements
l
-
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of the 1974 Edition of Section III of the ASME Code.
Westinghouse P0 546-CCA-191000-XN, which deals with Class 2 and
3 valves, specifies, however, the applicable Code requirement to
be Section III, 1971 Edition, Summer 1972 Addenda. Receipt of
valves in accordance with this criteria is evidenced by the
NPV-1 form for Valve Tag No. 1-7046 which states, "The material,
design, construction, and workmanship complies with ASME Code,
Section III, Class 3, 1971 Edition, Summer 1972 Addenda." The
failure to comply with FSAR commitments is a deviation
(445/8622-D-06).
J. Pipe Support Inspections (ISAP VII.b.3)
(1) Status of CPRT Activity
The reinspections being performed under ISAP 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 VII.c.
~ Room 77N Pipe Supports
Reinspection of the 178 pipe supports identified as being
nonconforming by TRT has been completed. Of the 252 deviations
identified, 248 have been evaluated to date, with 99 determined
to be valid.
~
TRT Issues - 42 Pipe Supports
Of the 42 pipe supports identified by TRT as being nonconform-
ing, 40 have been reinspected. Of the 103 deviations
identified, 99 have been evaluated to date, with 67 determined
to be valid.
(2) Status of NRC Inspection Activity
Room 77N Pipe Supports
To date, a total of 9 ERC reinspections have been witnessed and
16 NRC inspections of ERC verification packages have been
performed. Eight of the 16 NRC inspections were performed in
conjunction with the NRC inspection of the ERC overview
inspection program.
As a result of a previously identified deviation (445/8607-D-13)
pertaining to improper acceptance of a spherical bearing gap
measurement by an ERC inspector, ERC determined that six
verification packages which had been previously inspected by
3
-23-
that ERC inspector would be reinspected. The six reinspected
packages are:
'
I-S-LBSN-048 I-S-LBSR-009 I-S-SBPS-033
I-S-PS7N-001 I-S-PS7N-135 I-S-PS7N-145
The reinspections of the spherical bearing gaps were witnessed
by the NRC inspector, and resulted in the identification of
out-of-scope observations pertaining to paint on the spherical
bearings for packages I-S-PS7N-001, I-S-PS7N-135, and
I-S-PS7N-145.
Disposition of these out-of-scope observations is an open item
(445/8622-0-07).
TRT Issues - 42 Pipe Supports
There were no NRC inspections performed in this area during this
report period.
No NRC inspections were performed in other ISAP VII.b.3
activities.
5. ISAP VII.c
a. Electrical Equipment
Status of CPRT Activity
ERC has completed 98 reinspections and 98 documentation review
packages of sampled electrical equipment as of August 31, 1986.
Status of NRC Inspection Activity
The status of NRC inspection activity remains unchanged for the ERC
population sample from the previous inspection report; i.e., the NRC
inspectors have witnessed 11 ERC reinspections, performed separate
reviews of 10 documentation packages, and performed 6 separate
inspections of sampled electrical equipment. The NRC inspectors
did, however, perform the following inspection during this report
period of electrical equipment which was not included in the ERC
population sample:
(1) The NRC inspectors performed an inspection of the four
safety-related refrigeration units to verify proper
installation. The inspections included observations that:
(a) components were properly installed and identified as
indicated on the latest design documents, (b) supports and
attachments were properly mounted and secured, (c) protective
coatings were as specified, (d) electrical separation and
, l
.__ . _ . .
,_ .
.
'
- b -24-
-
-
< 4
L -
,
'
independence were maintained, and (e) provisions related to
,
'
,
. environmental qualification of the components were maintained.
- -
The ;following refrigeration units cool the safety chilled water
'
>3
system l(SCW) which provides cooling water to various engineered
,
e
safety. features (ESF) components' room coolers:
~
. Equipment No. System Unit
. .
'
'
CP1-CHCICE-05 SCW 1
CP1-CHCICE-06 SCW 1
CP2-CHCICE-05 SCW 2
CP2-CHCICE-06 SCW 2
During the above inspections, the following conditions, which
appeared to deviate from CPSES electrical erection specification
requirements, were identified.
'
CP1-05
'
(a) Bolts on the compressor discharge flange were not installed
as shown on Drawing 376-09121E;
j (b) . Paint on the underside of the compressor was peeling;
(c) Some of the devices inside the control panel had wires
terminated using slide-on, tab type connectors;
(d) A number of wires inside the control panel had a short bend
radius;
(e) A number of connectors had two conductors crimped inside
one connector's barrel;
,
(f) Fitting No. OPG, inside the control panel, was leaking oil
, onto relay SG and its associated wiring, which had resulted
in damage to the insulation of one of the wires;
(g) The flexible conduit for switch PRV had the outer jacket
split and falling off; and
(h) Cap type, inline splice connectors were used to terminate
instruments and limit switches.
l CP1-06
This unit had the same conditions as identified in (a), (c),
'
(d), (e), (f), and (h) above for CP1-05, and:
(a) Some splices used to terminate instruments and limit
switches were made using Thomas and Betts (T&B) RC-6
L
!
1
I.
_ .- _ _ _ . _ . _ _ _ - . _ . - _ _ _ _ _ _ _ __-
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connectors, which are usually only used for lighting
circuits; and >
(b) A cap type, inline splice was installed on a wire in the
control panel.
CP2-05
This' unit had the same conditions as identified in (a), (c),
(d), (e), (f), and (h) for CP1-05.
CP2-06
This unit had the same conditions as identified in (a), (c),
(d), (e), (f), and (h) for CP1-05 and one of the auxiliary oil'
pump motor leads was also terminated using a wire nut.
The above findings are an unresolved item pending the completion
of an NRC review of the applicable requirements for these pieces
of equipment (445/8622-U-08; 446/8620-U-05).
(2) In addition to the above inspection efforts, the NRC inspector
noted, during a tour of the Unit 1 cable spreading room, feeder
cable splices and a cable jacket repair inside distribution
panel CPX-ECDPEC-02. The cover had been removed from this
panel, as well as another N nel, to facilitate some plant
modifications; the. cable il question (EG205704) was, however,-
unaffected by those modifications.
The NRC inspector noted that the outer jacket of one of the two
conductors of cable EG205704 had been repaired by wrappings of
electrical tape and that both conductors had been reduced in
size from AWG 4/0 to AWG #2 through the use of reduction 4
splices. A review of the applicable records showed:
(a) The damage to the cable jacket.had been reported in NCR
E84-01095, was repaired and the results recorded in
>,.
IR E-1-0036473.
..
.
,
~
(b) The reduction splices were installed in accordance with
. 4
- . construction operation traveler EE83-3520-2-02CT. The
,
reduction consisted of installing a terminal lug of the
i , 'properisize on each of the conductors and then bolting the
- "
..l'ugs,of one of the 4/0 and one of the #2 together. These
. ,
connections were then covered with heat shrinkable tubing
- , ; insulation.
_
-
e,
i
. 'The conductor size reduction was necessary for connection
,
'.,- to.the c_ircuit breaker in the panel. Since the circuit
= breaker was rated for 100 amperes, and a review of the
applicable plant drawing (2323-El-1701) showed the smaller
-26-
(#2 AWG) conductor was rated for 116 amperes, sufficient
current carrying capability was maintained by the
reduction.
No violations or deviations were identified.
b. Documentation Review of NIS Cable Terminations
Status of CPRT Activity
ERC completed the review of the 60 sampled nuclear instrumentation
system (NIS) cable termination verification packages prior to
August 31, 1986.
~
Because the attributes affecting these connectors
are not inspectable without completely reworking the connectors, no
physical inspections were required. ERC is continuing the evaluation
of the deviations which were noted during the documentation reviews.
Status of NRC Inspection Activity
(1) Procedures Review
The NRC inspector initiated the review of this population during
this report period. A review of the procedure which was
utilized by ERC (QI-074, Revision 0, dated March 10, 1986,
" Documentation Review of NIS Cable Terminations /R-E-NIST")
showed that it required checking five attributes. The ERC
reviewer was required to verify that: (a) all attributes on the
IR for the connector were indicated to be satisfactory, (b) all
IR attributes for insulation and resistance measuring were
satisfactory, (c) all IR attributes for the coupling of the
connector were satisfactory, (d) all IR attributes for soldered
connections were satisfactory, and (e) the QC inspector who
verified the above four connection attributes was certified to
the applicable procedure. The NRC inspector also reviewed the
latest revision of the QC installation inspection procedure for
NIS connectors, QI-QP-11.3-43, Revision 20, dated February 18,
1986, " Verify Testing and Installation of NIS Triaxial Cable
-Connectors."
(2) CPRT Records Review
'
Ten of the completed ERC verification packages were selected at
random and reviewed by the NRC inspector. A total of 9 DRs were
'
noted to have been written by the ERC inspectors for findings
made during their documentation reviews of these 10 packages.
Each package consisted of one NIS connector. Of the nine DRs,
four were written because the heat shrink tubing (HST) had not
been installed over the completed connection. A subsequent
review of the applicable requirements by ERC showed that HST
need only be applied to those NIS connectors at the containment
penetrations and at the detector wells. Since all of the
.
-27-
connectors in question were equipment connections, HST was not
required. One DR was written because the test date was not
included in the package; however, the data sheet was-
subsequently located. Another DR was written because the "0"
ring seal-between connector halves had not been installed;
however, the connector in question was, a spare connector which
'
was covered with HST and not mated with another connector half. ;
A seventh DR was written because a procedure step for insulation
and resistance measurements had been marked "N/A"; however,
since the connector was not a penetration connection, these
4
measurements were not required. The remaining two DRs were
written because.other steps in the procedure had been marked
"NA." Further review determined that the steps marked "NA" were
not required for the particular application. ERC, therefore,
determined that all of the nine DRs were invalid.
. The NRC inspector questioned the appropriateness of some of the
above determinations with CPRT personnel and the applicant
personnel responsible for the preparation and implementation of
the QC' procedure. The inspector was informed that all
connectors located inside the containment were covered with HST;
- the invalidated DRs on this subject were for connectors located
outside the containment. In addition, the entire length of the
cable run, excluding active devices, was subjected to an
, insulation and resistance measurement test after final
installation. The NRC inspector found no reason to disagree
with the above determinations.
(3) TUGCo Documentation Review
The NRC inspector performed reviews of TUGCo documentation for
the following four verification packages for Unit 1 NIS cables:
' Verification Cable No.
Package No.
1
R-E-NIST-002 EW-140610
R-E-NIST-003 EY-140308
-
R-E-NIST-004 ER-140490Z
R-E-NIST-008 EW-140601
The results of the NRC inspector's review, which included
verification of the QC inspector's certification, were
compared to the ERC review findings with no differences
being identified.
-
No violations or deviations were identified.
.
4
.,. . . . - _ - , - , - . - - - . - - - ....---..._-,v
-
.----_-....,.-,-.v---__ . _ , _ , ~ . - - - - . , . . , , . - , , . - - .
. - _ _ _ _.
Y
4
-28-
,t
, c.' Mechanical Equipment Installation
, -
- Status of CPRT' Activity
,'EkCIbascomhleted168reinspectionsofmechanicalequipment
4
,
'
, installation items from a total _ random and engineered sample size of
' '
'
s 171.~ Two!hundred~and fifteen valid DRs were issued as a result of
.the above reinspections.
<'
v ERC has comos'eted all documentation reviews of the total sample of 84
~
documentation review packages. Two valid DRs have been issued.
.
Status ,of NRC Inspection' Activity
4
To date, the NRC inspector has performed nine inspections of sample
items previously inspected by ERC, of which the following three
inspections occurrgd during this report period:
Verification Equipment Tag No. System * Unit
Package No.
I-M-MEIN-107 TBX-CSAPPD-01 CS Common (1)
- I-M-MEIN-019 CP1-CCAHHX-02 CC 1
I-M-MEIN-263 CP1-VAAUSE-11 VA 1
i CS - Chemical and Volume Control;
CC - Component Cooling Water;
VA - Containment Ventilation
The NRC inspector identified that ERC engineering, during their
review of historical data pertaining to Verification Package
I-M-MEIN-017, failed to provide ERC inspectors with accept / reject
criteria for the following work activities described by construction
- operation travelers (C0Ts)
(1) COT ME78-101-4901 identified the use of Richmond inserts for
equipment anchoring. No inspection instruction were provided to
verify adequacy of stud bolt thread engagement.
(2) COT ME83-1532-4900 identified torquing requirements for Cylinder
Head Cover No.9. No inspection instructions were provided to
verify satisfactory performance of the torquing operation.
, (3) COT ME78-101-4901 identified a requirement to install the oil
cooler and its associated piping. No inspection instructions 1
were provided to verify satisfactory performance of the work
activities required for installation.
Subsequent to the NRC inspection, ERC engineering issued inspection
instructions to resolve (2) and (3) above. The failure to include
1
m, . - - - _ * , - , _ , . ,. c- , -r .- . - - - - - - - - - - - - -- - - - , - -
-29-
the preceding work activities in the scope of the reinspection effort
is a deviation (445/3622-D-09).
As a result of the additional inspection activities performed by ERC
inspection personnel with respect to (2) and (3) above, eight
deviations pertaining to nonconforming torque and coupling / alignment
specifications were identified. However, NRC subsequent inspection
revealed that the equipment was not tagged to identify the
nonconforming conditions as required by ERC Procedure CPP-010. This
failure to tag the nonconforming equipment is a deviation
(445/8622-D-10).
d. Pipe Welds / Materials
Status of CPRT Activity
The Pipe Welds / Material (PIWM) population was created by combining
two previous populations referred to as Large Bore Pipe
Welds / Material and Small Bore Piping and Instrument Tubing / Piping
Welds / Material. In addition, tubing welds were excitded and placed
in their own population, and mechanical equipment pressure boundary
welds were added as PIWM welds. The PIWM population was then
categorized into two subsets: Large Bore Pipe Welds / Material (LBWM)
subset and Small Bore Pipe Welds / Material (SEWM) subset. This
categorization has been done for the purpose of utilizing the
existing inspection QIs and corresponding verification packages.
ERC has completed all of the planned random and engineered sample of
180 reinspection packages and the 182 documentation review packages.
Of the five valid DRs which were issued, four have been evaluated, to
date, and determined to be nonsafety significant.
Status of NRC Inspection Activity
(1) To date, the NRC inspector has witnessed 15 ERC reinspections
and performed 6 separate inspections of ERC verification
packages, of which the following three separate inspections were
performed during this report period:
Verification Drawing No. Weld No. System * Unit
Package No.
I-M-SBWM-029 BRP-MS-2-RB-044 WE-15 MS 2
I-M-LBWM-054 BRP-BR-2-SB-014 WE-7 BR 2
I-M-LBWM-038 BRP-MS-2-SB-056 FW-3A MS 2
MS - Main Steam; BR - Boron Recycling
No violations or deviations were identified.
-30-
(2) The NRC inspector performed a documentation review of the
following four ERC population samples:
Verification Drawing No. Weld System * Unit
Package No. No.
R-M-PIWM-174 BRP-BR-2-SB-014 WE-7 BR 2
R-M-PIWM-046 BRP-MS-2-RB-044 WE-15 MS 2
R-M-PIWM-110 BRP-MS-2-SB-056 FW-3A MS 2
R-M-PIWM-2004 TNE-12-2107-04-8-01-1Q2 FW-14 CS 2
BR - Borco lecycling; MS - Main Steam; CS - Chemical and
Volume Control
No violations or deviations were identified.
e. Equipment Supports
Status of CPRT Activity
ERC reinspection of equipment supports is complete with 70 support
packages reinspected and 128 DRs issued. Eighty-nine DRs have been
determined to be valid. Documentation review is also complete with
225 DRs issued. No safety significant deviations have been
'
identi fied.-
Status of NRC Inspection Activity
(1) Two ERC equipment support inspections were witnessed by the NRC
inspector during March 1986. The discussion of the following
witnessed inspections was inadvertently left out of NRC
Inspection Report 50-445/86-03; 50-446/86-02:
Verification Equipment No. Building * Unit
Package No.
.
I-S-EQSP-002 CP2-EPBCED-03 AB Common
I-S-EQSP-_010 CP2-ECDPED-01 CR Common
- '
AB - Auxiliary Building, CR - Control Room
~
'
During the above reinspections, ERC identified the following
,
'
e conditions to the NRC inspector as subject to evaluatio,n' as ,
'
potential' deviations:
, 'I-S-EQSP-002: A channel was incorrectly located by 1/4" and a
'
weld length was undersized for 1 3/4".
- . _ .
~
I-S-EQSP-010: The support location was not in accordance with
the installation drawing. The gap between the panel and the -
r
,
-31-
concrete wall exceeded the allowable of 1/2". In addition, a
Hilti bolt spacing violation was identified.
Dispositions of the above findings are open items (445/8622-0-11 I
and 445/8622-0-12).
(2) The following seven equipment supports were separately
reinspected during this report period:
Verification Equipmert No. Building * Unit
Package No.
I-S-EQSP-008 CP1-VAFNAV-32 DG 1
I-S-EQSP-023 CP2-ELDPEC-04 DG 2
I-5-EQSP-027 CP2-VAFNAV-27 DG 2
I-S-EQSP-038 ILCS5691A DG 1
I-S-EQSP-045 ILCS5803 AB 1
I-S-EQSP-049 CPX-EPTRET-04 CR Common
I-S-EQSP-052 CP2-ELDPEC-14 CR Common
DG - Diesel Generator, AB - Auxiliary Building,
CR - Control Room
The above seven equipment supports had been previously inspected
by the ERC 01. The initial ERC reinspection of Verification
Package I-S-EQSP-023 was evaluated as unacceptable by the
ERC OI. The initial ERC inspector rejected Attribute 6F(i)
because nuts and washers were not installed on two Hilti bolts.
Note 10 of DCA 3273 states, "If Hilti violations occur between
existing Hilti Kwik bolts and new added Hiltis, remove nut
- permanently from existing Hilti Kwik bolts." Note 5 of DCA
~20659 states that the Hilti bolts inside the panel are not
necessary. The OI determined that a DR should not have been
issued. Upon evaluation of this finding by the overview
supervisor, a decision was made to accept the initial ERC
inspector's DR, since the identity of the new versus existing
.
.Hilti bolts could not be determined. Thus, Note 5 of DCA 20659
- ~ was.not applied.
..
The initial ERC reinspection of Verification
-
.
,- Package I-S-EQSP-052 was evaluated as unacceptable by the
4 '# #.
. *
- -
'ERC oil Two additional DRs were issued. Attribute 3,
% ,
. configuration, was rejected by the ERC OI. The bottom of the
,
"~ '
-, panel was 5/8" from the wall whereas DCA 14811 allowed 1/2"
4, *
-
maximum. Attribute 6F(ii), anchor bolt nut engagement and
bearing, was also rejected by the ERC 01. One Hilti bolt was
' '
' installed without a required washer.
.
J
J
_ _ _
. ._ . . . .
" '
,
e
-32-
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t' is
ERC Overview inspection results agreed with the initial ERC
reinspections for the remaining five packages listed above.
No violations or deviations were identified.
,
f. Fuel Pool Liner '
Status of CPRT Activity
.ERC has completed 62 reinspeitians of the fuel pool liner from a.
population sample size of 627 Ten valid DRs were issued as a result.
of the above reinspections. '
ERC has completed 100 documentation reviews from a total sample size
of 100. -Forty-four valid DRs have been issued as a result of the ,
above documentation reviews. i'
Status of NRC Inspection Activity
(1) The NRC inspector witnessed the following ERC inspection during
December 1985, the discussion of which was inadvertently omitted
from NRC Inspection Re' port 50-445/85-18; 50-446/85-15:
"N.
'
Verification' Weld Unit
I.D. No.
'
Package No.
. I-S-FPLR-163 -1161 1
No deviating conditions were identified during this inspection.'
.
'...
' (2) To date,'the NRC~ inspector has performed the following
'
f inspections of ERCsinspected packages:
\
"4 '
'-
'
Verification Weld Unit
.. Package No. I.D. No.
I-S-FPLR-004 969 2
I-S-FPLR-111 1748 1
I-S-FPLR-029 1052 Common (1)
I-S-FPLR-072 1049 2
4
I-S-FPLR-058 1015 Common (1) x
-(
i No violations or deviations were identified. '
,
g. Small Bore Piping Configuration
,
'
,
Status of CPRT Activity ,
, ERC has completed all reinspections of small bore piping
'
s . configurations from the planned random and engineered sample of 99.
Seventy-nine valid DRs have been identified and issued.
1
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,
-33-
.
- ~
- Status of NRC Inspection Activity
-
3 .-
< (1) To date, the'NRC inspector has witnessed seven ERC reinspections
and performed seven separate inspection of ERC inspected
-e , ,
,
- '
packages, of which the following three separate inspections
T
..
-
occurred-during this report period:
'
~ Verification Drawing No. Unit
'
,
, , System *~
- -
Package No.
-
.,
'I-M-SBC0-023 BRP-GH-X-AB-068 GH Common
c I-M-SBC0-097 BRP-RC-1-RB-039 RC 1
s <" < I-M-SBC0-121 BRP-RH-1-SB-011 RH 1
Y. .
GH - Gaseous Waste Processing System;
RC - Reactor Coolant System; RH - Residual
Heat Removal System
(2) With respect to Verification Package I-M-SBCO-121, the OI
identified that in the northwest corner of Room No. 67, the
inspected line and the floor grating angle iron did not meet the
separation criteria of Section 5.2 of QI-026. The deviation was
not identified by the original ERC inspector. Disposition of
the above item is an open item (445/8622-0-13).
(3) During the inspection of Verification Package I-M-SBCO-121, the.
NRC inspector identified two instances where the separation
criteria of paragraph 5.2.6.2 in QI-026 was violated. QI-026
requires that for pipes operating at 200 degrees Fahrenheit or
greater, a minimum of 1", including insulation, shall be
maintained between the pipe and hangers. Attribute 1.f
(separation) of the ERC reinspection checklist for this
verification package was accepted by the ERC inspector. The
subsequent overview inspection failed to identify the deviating
conditions; thus resulting in a failure to identify
unsatisfactory decisions made by the ERC inspector. These
failures constitute a deviation (445/8622-D-14).
These conditions existed between a vertical run of pipe (5' 7
1/2" west of wall D-S and 3' 4" south of wall 5-S at elevation
789'6") and structural tubing of pipe support RH-1-025-004-522R,
and at elevation 791' 2" with the snubber rear bracket of Pipe
Support No. RH-2-013-008-S32K.
h. Large Bore Piping Configuration
Status of CPRT Activity
ERC has completed all reinspections of large bore piping
configurations from the planned random and engineered sample of 98.
Sixty-three valid DRs have been identified and issued.
- - . _ . --. -. -
. - _ , . _- . - _ , _ _ - - , -
~
, .
,
'
, -
'
. -34-
'
_
n
~ ,
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. - g= m
, ,
7
-
, , Status of NRC Inspection Activity
-- 1 ! <
'
.
, ,
To date, the NRC' inspector has witnessed seven ERC reinspections and
-
performed seven separate inspections of ERC inspected packages, of
L , , 3, . - x .which the following separate inspections occurred during this report
_
period:
'
'
. .
'
,
.,
Verification Drawing No. System * Unit
_
Package No. -
I-M-LBCO-087 BRP-CT-1-RB-020.
~
CT 1.
I-M-LBCO-025 CRP-CC-1-RB-057 CC 1
.
CT - Containment Spray; CC - Component Cooling Water
N'o violations or deviations were identified,
i. Reinspection of Tubing Welds / Materials
Status of CPRT Activity
ERC has completed all reinspections of tubing welds / materials from
the total random and engineered sample of 99. Seventeen valid DRs
were issued as a result of the above reinspections.
ERC has also completed all documentation reviews from the sample of
'
98 packages. Fourteen valid DRs have been generated as a result of
the above documentation review.
Status of NRC Inspection Activity
Review of this population identified that documentation of NRC
inspection activity had been deferred pending attempted resolution of
questions concerning the adequacy of instruction to. inspectors in
QI-070, Revision 1. The questions, which are somewhat judgmental in
nature, are described in paragraph (3) below.
(1) The NRC inspector has, to date, witnessed tae following three
inspections:
'
Verification Drawing No. System * Unit
Package No.
I-M-TUWM-024 FSI-00043-17 NI 1
!
I-M-TUWM-034 FSI-00043-56 NI 1
I-M-TUWM-036 FSI-00043-54 NI 1
i
NI - Nuclear Instrumentation
!
-35-
During these inspections, no deviating conditions were
identified by the ERC inspector. No violations or deviations
were identified by the NRC inspector.
(2) The NRC inspector has, to date, performed the following four
separate inspections of ERC inspected packages:
Verification Drawing No. System * Unit
Package No.
.I-M-TUWM-002 FSI-1-500 MS 1
I-M-TUWM-008 FSI-1-601-01 RC 1
I-M-TUWM-016 FSI-1-601-01 RC 1
I-M-TUWM-025 FSI-1-528 RC 1
MS - Main Stream; RC - Reactor Coolant
No violations or deviations were identified.
(3) The NRC inspector questioned ERC engineering concerning the
adequacy of QI-070, Revision 1, relative to instructions not
being provided for weld size inspection when the edge of tubing
fittings had either been consumed by welding or subjected to
grinding. An additional related question was asked concerning
the QI not requiring verification of socket weld fitting sizes.
In the NRC inspector's judgement, fitting size verification
would have permitted more accurate assessment of weld size when
the edge of the fitting was not identifiable. In attempting a
suitably resolve these questions, TUGCo Quality Engineering was
contacted relative to original inspection criteria used for weld
acceptance. TUGCo Quality Engineering-issued NCRs M-86-103363
(for Unit 1) and M-86-201978 (for Unit 2) to obtain suitable
resolution of these questions. This subject is considered
unresolved pending disposition of the NCRs and NRC review
(445/8622-U-15; 446/8620-U-06).
j. Category I Conduit Supports *
Status ~of CPRT Activity
Reinspection of Category I Conduit supports is complete with 161
support packages reinspected. A total of 80 valid deviations were
' identified. Documentation review is also complete with 160 packages
, reviewed. . A total of 186 valid deviations were identified.
~
-36-
Status of NRC Inspection Activity
i
The NRC inspector has, to date, performed the following eight i
separate inspections of ERC inspected packages, all of which occurred !
during this report period: ' 1
Verification Support No. Unit
Package No.
I-S-COSP-071 C14W-13102-05 1
I-S-COSP 073 C140-06419-01 1
I-S-COSP7046 C03G09956-04 1
I-S-COSP-003 EAB9-5 1
I-S-COSP-017 ESB2-21 1
I-S-COSP-024 ESB8-6 1
I-S-COSP-042 C12G-16958-08 1
I-S-COSP-009 C146-20047-01 1
No violations or deviations were identified,
k. Inspection of Nonpressure Boundary Welds for a Supplementary
Evaluation of Visual Welding Inspection Techniques
Status of CPRT Activity
All inspection activity is complete.
Status of NRC Inspection Activity
.
(1) All inspection activity is complete.
(2) The NRC inspector witnessed the following inspection during
March 1986 which was documented in NRC Inspection
Report 50-445/86-03; 50-446/86-02:
Verification Equipment System * Unit
Package No. Tag No.
I-S-NPBW-004 FW-1-017-908-C77W FW 1
- FW - Steam Generator Feedwater System
An open item was identified during the inspection; however, its
discussion was inadvertently left out of the NRC inspection
report. The following is a discussion of that open item.
During the second phase inspection (after removal of coating),
the NRC inspector identified what appeared to be an unacceptable
weld surface condition; i.e., not suitable for nondestructive
examination (NDE). This open item was resolved by the
performance of a magnetic particle examination (MT) of the weld
- - _ . - .
-37-
by a Brown & Root (B&R) Level III NDE examiner on June 30, 1986,-
using NDE Procedure QI-QAP 10.2-2, Revision 4. The result of
the MT was documented on MT Report.No, 22583, and showed that
the weld surface. condition was suitable for NDE. No rejectable
indications were observed.
No violations or deviations were identified.
6. Assessment of Allegations
a. AQ-148 (4-85-A-15), AQ-155, and AQ-157 (4-85-A-30): It was alleged
that the construction start-up/ turnover surveillance (CSTS) group
performed a QA surveillance of the warehouse and bulk material
storage (laydown) areas and found deficiencies. The QC group had
performed a similar surveillance in the same areas, yet the QC
surveillance did not detect or record any deficiencies (AQ-148 and
AQ-157). Although the QC group had reported the iron fabrication
shop (fab shop) had satisfactorily implemented corrective action for
previously identified deficiencies, CSTS surveillances found that the
same type deficiencies continued. Also, the QC surveillances of the
fab shop did not detect or record the continuing deficiencies
.(AQ-155).
These three allegations were assessed in common since they concern
departures from procedural requirements pertaining to surveillances
of the segregation, protection, and storage of bulk materials.
The NRC inspector reviewed the CSTS QA Surveillance Report 85-002
dated January 14, 1985, for the fab shop and found that the report
identified several deficiencies regarding material storage and one
deficiency that QC surveillances required by procedures were not
documented. The CSTS record package contained documentation of
satisfactory corrective action that was implemented by CAR 039 dated
January 16, 1985, which addressed surveillances not being documented.
The NRC inspector reviewed CSTS QA surveillance reports through
April 1985. These reports identified deficiencies in the warehouse
areas that related to maintenance records for stored in place items;
however, no deficiencies similar to those previously identified in
the fab snop were noted. The CSTS record packages contained
documentation'of the satisfactory implementation of corrective action
of the maintenance record deficiencies noted. A walkdown inspection
by the NRC inspector did not identify any continuing deficiencies or
deficiencies similar to previous findings in the fab shop.
The allegers referred to a QC surveillance of the warehouse area
which did not identify any deficiencies; however, a CSTS QA
surveillance of the same area conducted one day later found uncapped
pipe and deteriorated tape on pipe ends. The NRC inspector found
that a QC surveillance report of bulk material storage outside
Warehouse C was performed on April 30, 1985. On the following day,
May 1, 1985, the CSTS QA surveillance group performed a random
-
)
-
-38-
~
(unscheduled, not utilizing a prepared QA checklist) surveillance of
the same area. The random surveillance resulted in the issuance of
surveillance deficiency reports concerning pipe end caps missing or
damaged. The deficient items were corrected and the deficiency
' reports closed.
The NRC inspector considered further the differences in the results
of the April 30 survey, which was satisfactory, and the May 1 survey
which identified the deficiencies. Based on interviews with
personnel involved and review of documentation, it was determined
that the April 30 survey was a visual only inspection of the stored
condition of the items in the laydown yard. The May 1 survey was a
hands on inspection of protective coverings which identified
deficiencies that would not necessarily be identified during a visual
only inspection. This difference in inspection technique could
account for the different survey results.
In discussions with the manager, Warehouse and Material Control, the
NRC inspector found that warehouse and receiving QC personnel conduct
weekly and monthly surveillances of all storage areas. While the
requirement for these surveillances are not clearly documented in
procedures, the surveillance results are documented for each area
inspected, a result of implementation of CAR-039. In addition,
periodic surveys and audits are conducted by personnel from the CSTS
group and the Dallas-based QA audit group. The NRC inspector
reviewed the results of the following surveillances and audits of the
pipe laydown area outside Warehouse C.
(1) Weekly surveillances are conducted in 28 areas by warehouse
personnel. Three of the weekly surveillances conducted in
June 1986 were reviewed and no unsatisfactory conditions were
noted in the areas outside Warehouse C.
(2) Monthly surveillances are conducted in 14 areas by receiving QC
personnel. The January through June surveillance reports were
reviewed. The February report identified seven items not stored
properly in areas outside Warehouse C, which were subsequently
corrected. All other reports found conditions satisfactory in
this same area.
(3) CSTS Report No.86-170, conducted the end of March 1986, was
reviewed. This survey of warehousing included the pipe laydown
areas outside Warehouse C. Checklist item #4, based on
CP-CPM-8.1, Revision 3, was to verify piping and components were
capped and protected. This item was documented as satisfactory.
(4) The Dallas QA group conducted an audit (TCP-86-08) of the
warehousing at the site, including the laydown areas outside
Warehouse C, during the weeks of March 3-17, 1986. No
unsatisfactory conditions were noted in the audit report
concerning outside pipe storage.
Y
-39-
.
.f
-
4
The NRC; inspector discussed the above findings with both the
, CSTS surveillance inspector and the Dallas QA auditor. Each
confirmed that the outside pipe storage areas were in compliance
.
'
with requirements during their inspections. This is potentially
accurate since the monthly surveillance conducted February 28,
1986, had identified seven nonconforming items which had been
corrected. Further, no audits or surveillances since the end of
. February had identified nonconforming conditions in the outside
pipe storage areas.
'
On July 10, 1986, accompanied by the manager, Warehouse and v
Material Control, the NRC inspector conducted an inspection of
outside storage at Warehouse C, including pipe storage. Four
pieces of stainless steel pipe were found with damaged or
deteriorated end covers, which is a violation of Procedure
MCP-10, Revision 9, " Storage and Storage Maintenance of
Mechanical and Electrical Equipment." The manager, Warehouse
and Material Control, initiated immediate corrective action.
The NRC inspector found several pieces of carbon steel pipe with
end caps in place. When asked why, the manager, Warehouse and
Material Control, stated that when carbon steel pipe is received
with end caps in place they were not required to remove them.
This also is contrary to MCP-10 which states, in part, " Carbon
steel piping material or structural tubing shall not be capped."
These conditions are considered a violation (445/8622-V-16;
446/8620-V-07).
Based on the assessment of these allegations, the NRC inspector
substantiated that the weekly and perhaps the monthly
surveillances were not completely effective in identifying
storage deficiencies nor in preventing identified deficiencies
from recurring. The NRC findings above and those identified in
paragraph 7.c of this report are indicative that the alleged
ineffectiveness of the surveillances continues to exist. The
NRC findings concerning material stored outside was the only
example of receiving deficiencies that was identified that is
indicative of ineffective preventive measures, while several
examples of effective preventive measures, such as CAR-039, were
noted.
b. 4-86-A-026: Improper Drilling on Cable Trays
An allegation was made to the NRC inspectors that craft personnel bad
drilled holes through solid bottom cable trays while electrical
cables were installed. The holes were drilled so that cable ties
could be installed in the bottom of the tray to hold the electrical
cables in proper separation positions, The concern was that the
drilling through the tray could cause damage to the electrical
cable (s).
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An NRC inspector identified a similar concern in NRC Inspection
Report 50-445/86-14; 50-446/86-11, in that holes were being drilled
through cable trays (paragraph 10.d). The failure of the applicant
to control the drilling of holes through cable trays containing
electrical cables was determined to be a violation of Criterion V of
Appendix B to 10 CFR Part 50 (445/8614-V-03; 446/8611-V-10).
Therefore, this allegation has been substantiated and the NRC will
follow the corrective actions proposed by the applicant in response
to the above violation.
7. Procurement, Receiving, and Storage
During this report period, an inspection of TUGCo procurement, receiving,
and onsite storage activities was made by the NRC inspector. The
activities of subcontractors that perform safety-related procurement were
also inspected. Review of safety-related contracts revealed that BSC is
the only subcontractor currently performing onsite safety-related
procurement.
a. TUGCo Onsite Procurement
Onsite procurement is the responsibility of TUGCo as committed in the
FSAR and the TUGCo/TUSI QA Manual. Details of organization are in
TUGCo Procedure CP-SP-1, Revision 0. A review of the site
procurement procedures found that they include the requirements of
ANSI N45.2.13 (1986).
To verify TUGCo implementation of onsite procurement requirements,
the NRC inspector selected 10 safety related P0s issued in the last
6 months for inspection. The P0sselected were: (1) CPF-12901-S,
(2) CPF-12913-S, (3) CPF-12971-S, (4) CPF-13022-S, (5) CPF-13114-S,
(6) CPF-13141-S, (7) CPF-13172-S, (8( CPF-13210-5, (9) CPF-13257-5,
(10) CPF-13313-S. For all of the P0s, the purchasing documents
specified and imposed the applicable technical requirements; i.e.,
codes and standards.
The NRC inspector' verified that the P0s were placed with suppliers
from the approved suppliers list or that the items were purchased
'
commercial grade and the required engineering evaluations performed.
The adequacy of the vendor surveillance program was previously
inspected and reported in NRC Inspection Report 50-445/86-03;
50-446/86-02. As a further review, 10 vendors were selected and a
verification made that a current audit or evaluation had been
perfdrmed. Two of these audits were reviewed in depth.
Audit TBBC-3/T of BBC Brown Boveri, Inc., was performed by Gilbert
Commonwealth for TUGCo, an approved supplier for conducting these
audits. The Gilbert Commonwealth auditor utilized the Nuclear
Supplier Quality Assurance System Evaluation Checklist developed by
the Coordinating Agency for Supplier Evaluation. Audit TWH-34 of
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Westinghouse Nuclear Components Division was performed by the TUGCo
Dall,3 audit group utilizing their own prepared checklist. Both
vendors QA programs were evaluated as acceptable.
No violations or deviations were found in this area of the
inspection.
b. TUGCo Receipt Inspection
The system for conducting receipt inspection was examined for
procedural compliance. Procedures utilized were:
. CP-QP-8-0, Revision 5, " Receiving Inspection"
. CP-QP-8-0-2, Revision 1, " Receiving Inspection Instruction"
. CP-QP-2-1, Revision 21, " Training of Inspection Personnel"
. QI-QAP-2.1-5, Revision 9, " Training and Certification of
Mechanical Inspection Personnel."
The qualifications of six receipt inspectors were inspected and found
to be proper with appropriate supporting documentation in the
qualification file.
The area used for receipt inspection provided controlled access, a
clean and protected inspection area, a hold area for nonconforming
material, calibrated measuring equipment in current calibration, and
an area with controlled temperature and humidity available for
receipt inspection of environmentally sensitive material.
Eleven RIRs and supplemental data were inspected to determine if the
requirements of the receiving procedures and purchasing
specification were met. The RIRs selected were #27448, #26274,
- 27699, #27737, #27738, #27698, #27650. #27672, #27857, #27735, and
- 27734. The receiving requirements were met for all of these RIRs
and no violations or deviations were identified.
c. TUGCo Storage
The site storage and laydown areas were inspected for compliance to
.
B&R Procedure MCP-10, Revision 9, " Storage and Storage Maintenance of
Mechanical and Electrical Equipment." Areas inspected were
Warehouse's A and B, Welders Qualification Training Center (WQTC),
the Pipe Fabrication Shop, Millwrights Shop, and the pipe, steel, and
electrical laydown areas. Also, items " stored inplace" inside Unit 2
reactor building were inspected. The following areas of
noncompliance were noted: two level transmitters " stored inplace"
were not protected from overhead grinding activity; electrical cable
in cable trays in Unit 2 were not properly protected from nearby
welding activity; stainless steel tubing with the ends not capped or
capped with tape in degraded condition was found outside in the area
behind the WQTC and the layout area north of Warehouse C. Violations
for the unprotected level transmitters and electrical cable was
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reported in NRC Inspection Report 50-445/86-15; 50-446/86-12. The
improperly capped tubing was identified as a violation
(445/8622-V-16; 446/8620-V-07) in paragraph 6.a of this report during
the assessment of an allegation.
The NRC inspector reviewed Procedures CP-QAP-14-1, Revision 6,
" Inspection of Storage and Maintenance of Permanent Plant Equipment";
CP-QP-19.0, Revision 4, " Construction, Start-up/ Turnover (CST)
Surveillances"; and MCP-10. These procedures describe storage levels
and inspection requirements for storage and maintenance. The
procedures meet the requirement of ANSI-N45.2.2, Sections 2.7 and
6.1.2 for storage levels, and Section 6.4.1, for inspection
requirements.
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No other violations or ceviations were noted in this area of
inspection.
d. Subcontractor Onsite Safety-Related Procurement Activity
To determine the procurement, receipt, and storage requirements for
BSC, the NRC inspector reviewed the terms of the BSC contract with
TUGCo. The contract imposed the requirements of 10 CFR Part 50,
Appendix B; ANSI N45.2, 1971; and ASME,Section III, 1977. The
following BSC procedures for procurement, receipt, and storage of
.- , safety-related materials were reviewed to determine if they
incorporated these requirements:
'
Procedure Title
QFP-4.003-CP1 Procurement of Material and Service from
General Contractor /0wner
QFP-4.002-CP1 Procurement of Welding and Brazing Material
QFP-4.001-CP1 Procurement Document Control for Nuclear
Projects
QFP-7.002-CP1 Receiving and Storage
QFP-8.001-CP1 Identification and Control of Materials,
Parts, and Components
QCI-CPSES-004 Receiving Inspection and Identification
Procedure
These procedures were found to adequately incorporate the above
standards and requirements for procurement, receipt, and storage
activities.
BSC P0s 1769, 1776, and 1864 and BSC RIRs 511 and 517 were compared
with the criteria of the procurement and receipt inspection
. _ _.
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procedures. -They were found to have been developed and processed in
accordance with these procedures.
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The NRC inspected the inside and outside storage areas as well as the
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weld rod room and oven area. These areas were found to be in
. compliance with the storage procedures and suitable for the type of
material stored. Inspection of recent surveillance reports for these
areas found that surveillances were being performed to the specified
frequency'and that the area surveillance forms were completed
including notation of deficiencies.
The approved vendors list was reviewed to determine if a current
audit or-evaluation had been performed for each vendor. This review ,
found all vendors listed to be in compliance or to have been removed
from the approved vendors list.
The qualifications and certification files of all receipt inspectors
were reviewed. These were found to be in accordance with the
requirements of ANSI-N45.2 and the BSC procedure for inspector
qualification.
No violations or deviations were identified during this area of
inspection.
8. CPRT-Central and Working Files
The purpose of this inspection was to verify that the CPRT central and
working files have been established, maintained, and controlled in
accordance with the requirements of Policy and Guideline (PAG) PAG-02,
Revisions 0 and 1, " Policy on Assembly of CPRT Program Central and Working
Files,: and PAG-11, Revision 0, " Policy for Controlling Access to the CPRT
File and Closed Working Files."
PAG-02 describes: (a) documents to be included in the CPRT central files;
(b) accountability mechanisms; (c) specific requirements for content
organization, and format of ISAP working files; and (d) the criteria used
by the'results report and working file review committee (RRRC) in their
review of completed working files and results reports for compliance to
ISAP requirements. PAG-11 describes the measures used to control access
to CPRT files. PAG-02 and PAG-11 are implementing documents for CPRT
Program Plan,Section III.J, "CPRT Program Records," and Appendix G,
Attachment 4, " Verification of Issue-Specific Action Plan Working Files."
It should be noted that PAG-02, Revision 0, and PAG-11, Revision 0, were
not issued until May 22, 1986, and July 30, 1986, respectively. Work
accomplished prior to issuance of PAG-02 and PAG-11 was inspected for
compliance using the requirements in the CPRT Program Plan,Section III.J,
and Appendix G, Attachment 4.
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a.' Organization of Central Files
The description of the central file contents and file index is
provided in PAG-02, paragraph 2 and Attachment 6.6. To verify
implementation of the PAG-02 requirements, the file index and file
contents log of each file was examined for compliance with
requirements. In cases where files were too large for 100%
inspection, sampling was used to verify file content. For example,
of the ten closed ISAP working files, seven were 100% inspected and
three were sampled.
The results of this inspection verified that file indexes, content
logs, and file contents were consistent with requirements. The only
exception was the CPRT Program Director's personnel file which did
not contain the required objectivity questionnaire / evaluation
documentation. This matter has been identified as a deviation in
paragraph 2.a of this appendix.
b. Control of Documentation / Files
Accountability of a file is accomplished by matching documentation
listed on the content file log against those documents in the file.
Procedurally, documents or document packages contained in the file
are required to be identified with the file number and the content
log sequential number. PAG-02, Revision 1, requires working file
documents or the contents of documentation packages to be
sequentially page-numbered. This allows for accountability and/or
recompiling should pages be mixed after or during reproduction, file
transmittal, or other use. The central file is in the process of
numbering pages of working files processed prior to PAG-02,
Revision 1. With the exception of working files, the pages of
documents, such as action plans, results reports, CPRT program plan,
etc., were always numbered.
PAG-11 requires controlled access to the file cabinets containing the
files. Files are locked when not in use. With the exception of the
working files, files may be removed from the central file room by
using check out cards to account for the documents.
The NRC inspected checkout cards, access methods to file cabinets,
the practice used to review working files in the central file room,
and documentation accountability. The practices used were found to
conform to PAG-02 and PAG-11 requirements.
c. Verification of ISAP Working Files
Appendix G, Attachment 4 of the CFRT Program Plan describes the
requirements, responsibility, and criteria for the review and
verification of working file by the RRRC. This review occurs after
the ISAP has been completed and prior to the results report (RR)
being submitted to the SRT for review and approval. The purpose of
_____ ______________
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this review / verification is to determine: (1) the contents of the
working file is complete and organized to be consistent with the
requirements of the CPRT Program Plan, and (2) the work reported and
conclusions reached in the RR are supported by information contained
in the working files.
Prior to May 22, 1986, the RRRC performed review activities using
checklists individually developed from Appendix G, Attachment 4. The
checklists -listed criteria to be used in verifying consittency
between the ISAP, working files, and RR. Results of th's
review / verification were documented on the checklist w{th actions
required. After actions required were completed by the responsible
issue coordinator, the RRRC conclusions resulting from the review and
verification were documented in a working file verification report.
The verification report was then submitted with the RR to the SRT for
their review. Of the seven working files reviewed using Appendix G
checklist, six were found in the backup file, but there was no
commitment to retain the checklist. In each case, the working file
verification report was in the file to document the performance of
the RRRC review and the conclusions reached. Retention of the
working file verification report is a requirement.
The three working files processed by the RRRC using PAG-02,
Revision 0, were found to comply to stated requirements of PAG-02 and
l Appendix G. Found in the backup files were detailed checklists
- listing criteria to perform reviews, actions required, closure of
actions required, and the completed RRRC report submitted to the SRT.
The NRC inspector witnessed a portion of in process review of I.d.3
by the RRRC and found it to comply with PAG-02, Revision 1,
requirements. A checklist was used to document review results and
actions required.
In summary, the NRC inspector determined that the CPRT had established
measures to develop and maintain the CPRT central files. Procedures
governing the central file activities have been suitably implemented with
one observed exception concerning the objectivity questionnaire missing
from the CPRT Program Director's personnel file noted above. Other files
appear to contain the required documentation. Accour,tability and access
to files were controlled per procedural requirement.
I
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With respect to the results report and working files review performed by
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the RRRC, their reviews were found to conform to the applicable
requirements and guidelines. The inspected documentation confirmed the
performance of reviews and that conclusions reached were reported to the
SRT as required.
Based upon a review of central files and supporting documentation, for
i
RRRC activities, it appears that PAG-02, Revision 0 and 1, and PAG-11,
Revision 0, have been adequately implemented.
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9. ERC Overview Inspection Program
The purpose of this inspection was to verify that the ERC overview
inspection program, as delineated in ERC-QA-28, Revision 3, " Performance
of Overview Inspections," was being implemented in accordance with
requirements. According to ERC personnel, the objectives of the overview
inspection program are: (a) to measure the effectiveness of ERC
inspectors performing third party reinspection / documentation review
activities, and (b) to determine the adequacy of QIs in directing
inspection activities. To achieve these objectives, the OIs duplicate the
initial reinspection or documentation review, then by comparing these
results with the initial reinspection / documentation review identify any
inconsistencies. Inconsistencies are then evaluated for validity and
resolution including required actions to prevent recurrence.
The NRC inspector developed a checklist detailing requirements identified
in ERC-QA-28, Revision 3, and compared a sample of overview inspection
verification packages (VPs) against the checklist to determine if the VPs
were developed and processed in accordance with ERC-QA-28 requirements.
Of the ten certified Ols, seven had performed the majority of the overview
inspections. The sample of overview VPs was selected to contain at least
one or more packages from each of the seven most active OIs. It was noted
that, in some cases, more than one OI participated in a single overview
inspection. This inspection was structured to evaluate the following
topics: sample selection, determination of accessibility, preparation of
overview VPs, completion of overview checklists, comparison of results
with the initial reinspection, completion of overview inspection report
and verification and followup of actions required,
a. Sample Selection
VPs documenting the results of initial reinspection / documentation
reviews were randomly selected for overview inspection. Based on the
type of reinspection activity, the sampling technique is described in
ERC-QA-28 for the selection of VPs for overview inspection. The NRC
sample selected for inspection was 16 out of a total of 51 ERC
inspectors. The number of inspectors sampled were by discipline:
six piping; five-mechanical, three-electrical, and two-civil. The
NRC review of this sample included: the overview inspection program
selection methods and use of random tables, calculations, and
selection results. Based on documentation reviewed, the sample
selection used in the overview inspection program conformed to
procedural requirements,
b. Determination of Accessibility !
The O! was required to confirm that any necessary equipment / services
to perform overview inspections are in place and that the sample is ,
accessible. This practice was found to be documented. If the
equipment / services was not available or the sample inaccessible, such
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was documented in the sample selection log and another accessible
-sample chosen in accordance with procedures.
t
, c. Preparation of Overview VPs
l
l The overview VP is prepared by ERC and duplicates the initial VP used
! by the ERC inspector. Upon receipt, the 01 supervisor is responsible
to verify that the overview VP is complete and accurate prior to
assignment to an 01. Based on the NRC inspector's review of 17
overview VPs, it was determined that the OI supervisor had verified
the completeness and accuracy of VPs. The contents of the packages
l were found to agree with the contents form which lists all the
- documents that comprise the overview VP; e.g., inspection drawings,
, supplemental inspection instructions, and inspection checklist.
d. Completion of Checklists and VP Contents Form
i In the review of overview inspection checklists, it was found that
l
some checklists were not processed in accordance with ERC-QA-28
, requir'ements. Noted errors were: corrections not initialed and
dated; absence of required entries; no justification or explanation
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for "N/A" (not applicable) entries; supplemental checklist not signed
. by OI; and added documents to the VP were not entered on the VP
contents form. These type errors were also identified by ERC during
>
' audit ERC-86-03, June 16-20, 1986. Corrective action responding to
these findings was to conduct an independent review of historical
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VPs. A detailed checklist was developed to identify errors in
checklists and content forms. ERC was in the process of conducting
.this historical review of VPs during the NRC inspection. The NRC
- , insp'ector' examined 12 historical review results. VP checklist and
content form' errors that were identified were being corrected. VPs
processed after' completion of this corrective action would be subject
to independent reviews to assure completion errors are being
identified'and corrected,
e. Comparison of Overview Inspection Results vs Initial Reinspection
Results
,
Procedurally, a comparison is required to be made between the
overview inspection packages and the initial reinspection / document
review package to identify inconsistencies. Those inconsistencies
confirmed as being valid are reported in the overview inspection
i report for required action. During the NRC's comparison of the
l packages, it was found that not all inconsistencies were identified
l by the 01. Examples of inconsistencies were: inspection checklists 7
'
reflect disagreement between ERC inspectors and Ols, but the overview
i inspection report did not identify the disagreement; the ERC
l
inspector or 01 accepted an attribute and the other inspector would
enter N/A; and items not inspected by overview were inspected by the
initial ERC inspectors. These types of inconsistencies were also
identified in audit ERC-86-03. Corrective action taken was to also
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address these type errors in the historical review of overview VPs.
. During the NRC's' inspection of the 12 historical reviews, it was
_
. found that the inconsistency errors were being addressed and when
indicated, inspector retraining was conducted.
f. Overview Inspection Reports
Seventeen overview inspection reports were examined. The results
from overview inspections were found to be documented on the reports
per procedural requirements. Information in overview inspection
reports included: accept / reject criteria; the observed deviating
condition; and action required with a completion schedule. Typical
corrective action included: inspector retraining, reinspection of
identified inconsistency, revising OIs or the combination thereof.
The overview inspection reports were reviewed and approved by the OI
supervisor and transmitted by memo to the responsible ERC personnel
for action.
g. Followup and Verification of Actions Required
ERC-QA-28 delineates steps for the verification of actions required.
Of the 17 VPs reviewed, 11 contained overview inspection reports
requiring actions to correct identified inconsistencies. One
overview inspection report contained an error in that the required
corrective action had not been verified. This type error was to be
addressed in the historical review being performed by overview
personnel as a result of a finding in audit ERC-86-03. To assure the
historical review was effective and would identify this type of
error, the NRC witnessed the historical review of the overview
inspection report. The error was identified during the historical
review.
To date, 104 overview inspection reports required corrective action.
Seventy-nine related to findings against reinspection inspectors
(inspector effectiveness), and 25 related to ERC engineering
(inadequacy of QIs). Inspector deficiencies identified in overview
inspection reports are trended for corrective action to prevent
recurrence. When engineering deficiencies are identified, the
appropriate QI is revised as necessary, and previously completed work
per the affected QI is assessed for impact.
As of July 28, 1986, 46 open overview inspection reports requiring
corrective action were from 8 to 175 days past the scheduled closure
date. Audit ERC-86-03 identified the overdue reports as untimely
corrective action. In response to this audit finding, ERC
established a tracking system to monitor the status of overview
inspection reports and their progress.
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. 10.~ Exit Interview
Exit interviews were conducted on August 7,1986, and September 5,1986,
with the applicant's representatives identified in paragraph 1 of this
appendix. During-these interviews, the NRC inspectors summarized the
scope and findings of the inspection. The applicant acknowledged the
findings.