ML20205Q801

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Affidavit of RG Tolson Re Records & Retrieval Rept.Related Info Encl
ML20205Q801
Person / Time
Site: Comanche Peak, 05000000
Issue date: 06/29/1984
From: Tolson R
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20204J134 List:
References
FOIA-85-59 NUDOCS 8606030310
Download: ML20205Q801 (4)


Text

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' w w ? RED ncSD a UNITED STAT 58 0F AaCULICA NUCLEAR REGULATORY COMKISSICM ,

EEFORE TEE ATCMIC SAF27Y AED LICZLIDG 3 CARD

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In the Matts: of ) Docksy Mos. 50-445 and

) 50-446 TIZAS IMILIT!25 EL3CTRIC CCNPANY, ee 'a1. )

) (Application for

) Operating Licenses)

(Cosanche Peak Stata Electric Station, Units 1 and 2) )

AFFIDAVIT OF RONALD Q. TOLSCli REGARDING R2CCRDS AND R2CCRDS RETRIE7AL RZPORT I,RonaldG.Celson,beingfirstdulysErn,dodepose and state as fclicws: I am employed by TCGC0 at the c = mchs Peak Stasa Electric Station. I have previously t'estified in this proceeding regarding the QA program at Comanche Peak.

A statsmant of ey educational and professional qualificaticas was received into evidence as Applicant's Exhibit 20. As part of my responsibilities as a TUGCC employee I participated in the preparation of ths attached report dated June 29, 1984 and antitled 'Racerds and Records Retriaval." hat report is true and correct to the best of my knowledge, ic. formation and belief.

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Ronald G. Tofion County of Somervell Subscribed and sworn to before State of Texas me this #9 day of June,1984 8606030310 860522 g"."o ./

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p .A UMTED STATES

[8'a na1 NUCLEAR REGULATORY COMMISSION 3 kl1 i wASHINGTo N, D. C, 20555 September 7, 1984 NOTE FOR: HLivermore LShao RBangart The following allegations that fall into your discipline do not appear under any category. Please place in a category or identify why the allegation is not being pursued (i.e., a duplicate of another allegation) and inform the TRT management staff by close of business, Septe=ber 10, 1984.

QA/QC - H. Liver ore AQ-29 4 ?J b'- "

AQ-33 / -L AQ-s4 4 0 L S Lw AQ-133 -- - '~/

AQ-134 h b c_

AQ-135 # .

AQH-16 7 V .:3, In addition, please complete the attached listing for QA/QC including persons assigned and estimated schedule for closure.

Mechanical / Piping - L. Shao/S. Hou AQW-78 AQW-79 AQW-83 Miscellaneous - R. Bangart AM-30 l

3 Thank you.

5 M Annette Vietti Comanche Peak Task Force FCIA-85-59

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QA/QC Allegation Review Categorien Category Est. Handays Allegation Package Assigned Schedule No. Subject to Complete Nos. Prepared to Open Close Remarks 1 Design Process AQ-22 AQ-89, AQ-90,

  • . AQ-106, AQ-119 2 Document Control AQ-3, AQ-4, AQ-8,

. AQ-17, AQ-21 AQ-58, AQ-72, AQ-105, AQ-110, AQ-102, AQ-104, AQ-107,

, AQ-19, AQ-33, AQ-16, AQ-18, AQ-57, AQ-59, AQ-60. AQ-71, AQ-101, AQE-9, AQll-1, AQW-13 3 Itecords AQ-45, AQ-74, AQ-75, AQ-76, AQ-97, AQ-99,

- AQ-Il6, AQ-129, AQW-16 4 Training and Qualifications AQ-23, AQ-24, AQ-26,

/.Q-2ft, AQ-27, AQ-73.

AQ-91, AQ-108 -

5 Construction Installation / Fabric l

. a. Miscellaneous AQ-IS, AQ-47, AQ-7,

, AQ-83, AQ-103, AQ-lli, AQ-49, AQ-131

b. lianagement AQ-25, AQ-69, AQ-117
c. Repair / Rework Halutenatice AQ -43, AQ-98, AQ-88,

. AQ-51, AQ-82, AQ-68, AQ-52, /.Q-96, AQ-130, AW-37

d. Onsite Fabrication AQ-77, AQ-79, AQ-ll5 f .

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y QA/QC Allegation Review Categories (continued) ,

C tegory Est. Handays Allegation Package Assigned Schedule N n. Subject to Complete Hos. Prepared to Open Close , Remarks 5 (cont) Construction Installation /

Fabric ,

e. Document Control AQ-84, AQL100. AQ-123, AQ-125
f. Ilousekeeping AQ-54, AQ-65
g. Travelers AQ-70, AQ-78 ,

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h. UCRs AQ-32, AQ-120, AQ-124, l' AQ-36, AQ-85, AQ-30, .

AQ-31 AQ-34, AQ-87, AQ-95. AQ-80

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1. Materials AQ-12, AQ-13, AQ-14, AQ-40, AQ-41, AQ-5 AQ-53 6 QC Inspection AQ-ll, AQ-35, AQ-37, AQ-86, AQ-114, AQ-42, ,!

AQ-122, AQ-46, AQ-38,  !

AQ-109, AQE-41 l.

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, 7 QA AQ-127, AQ-121, AQ-61, j.

I AQ-6, AQ-126, AQ-9, 1 AQ-20, AQ-il3, AQ-ll2,  ;,

AQ-132  !;

8 As-Builts AQ-44 AQ-50, AQ-55, AQ-128 I

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Miscellincous Allegation Review Categories - Region IV  ;

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Category . Est. Mandays Allegation Package Assigned Schedule Na. Subject to Complete . Nos. Prepared to Open Close Remarks i

1 llearing - 19 issues AM-1 Reclassified to Wessman reclassi-

- AE-51, AE-50, AQ-ill, fled and assigned AP-24, AP-25, AP-26, to TRT teams AP-27 AP-28, AQW-69,

'AQU-71 2 Reactor fuel 1.5 AM-2 Wise 7/23 Reg IV 3 Reactor pressure vessel 1.5 ,AM-3, AM-23 EC&G 8/6 l

4 FSAR error (10.2-11 & 12) 0.5 AM-4 EC&G 8/6 i 5 Radioactive material release 1.0 'AM-5 Wise 7/23

  • Reg IV ,

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6 IIP turbine 2.0 AM-6 EG>G 8/6 7

Pressurizer 3.0 'AM-7

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10 CCW system 2.0 AM-12 Oberg 8/13 Reg IV 11 Pumps - Ilayward Tyler 3.0 AM-13 Ehlershaw 8/9 Reg IV 12 Diesel generator 3.0 AM-14 l EC&G 8/6 13 ielar crane -shimming 3.0 AM-15, AM-16 EC&G 8/6 0

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Miscellaneous Allegation Review Categories - Region IV (Continurd)

Category Est. !!andays ,

Allegation Package Assigned Schedule No. Subject to Complete Nos. Prepared Open Close

'i to Remarks 14 Containment doors 2.0 AM-17 EC&G 8/6

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15 Safeguards tunnel 3.0 AM-18 EG6G 8/6 16 NRC form posting 1.0 AM-19 Wise 7/23 Reg IV 17 Material false statement 'AM 20 to be handled by 01 (plant management to ASLB) 18 Drug Abuse 5.0 AM-21 JKelley 8/27

- Reg IV and ,

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19 HVAC system 4.0 AM-22 E11ershaw 8/9 .

Reg IV t i 20 Damage to upper internals 1.0 .AM-24 Hunnicutt 8/13 Reg IV 21 Polar crane electrical cable 3.0 AM-25 EC&G 8/13 I and crane rotation problems i

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SEP 10 8M4 .'

f:lectrical Allegation Review Categories x*

C tegory Est. Mandays Allegation Package Assigned Schedule No. Subject to Cogplete Nos. Prepared Open Close Remarks to___

J l Electrical Cable ,AQE-7

( part), (AQE- Marini 7/31/84 Terminations 8 part), AQE-12, AE-13, AE-16, AE-18, AE-22 AE-26, AQE-36, (AQE-37 part), (AQE-39 part), (AQE-46 part) 2 Electrical Cable Tray '

(AQE-3 part), (AQE-4 part). Myers 7/31/84 and Conduit Installation AQE-10, AE-14, (AE-24 part), AE-27, AE-29, AE-31, AH-14 3 Electrical Equipment AQE-6, AQE-II, AE-15, Johnson 8/4/84 -

Separatloa jAE-20, (AQE-44 part), and Li  ;

! AQE-49, AE-51, AE-53,

'AQE-54

  • I 4 . Control Room Ceiling AE-17 . Myers 8/10/84 ,

Fixture Supports t

5 E1cetrical NCR Activities AQE-1, AQE-2, AQE-3, Selan 7/30/84 j- AQE-4. AQE-5, (AQE-12 or White i part), AQE-25, (AE-22 and Laudenbach i part), AE-24, (AE-27

part), AQE-33, AQE-34,  ;

AQE-35, (AQE-36 part).

.AQE-37, AQE-38, A0E-40, .

'AQE-41, AQE-42, AQE-45, AQE-47, AQE-48, AE-50 b

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1 Electrical Allegation Review Categories (continued)

I Catsgory Est. Handays Allegation Package Assigned Schedule Ms. Subject to Complete Hos. Prepared to Open Close Remarks o'

.8 6- Electrical QC (AQE-4 part). AQE-6 Selan 7/26/84 Inspector Training / part), AQE-8, (AQE-12 and White Qualifications part) 7 Electrical Cable Installation '(AQE-5 part), AE-19, Marini 7/31/84 AE-28, (AE-29 part),

,AE-30. AE-50, SRT-10 8 Electrical Procedures (AQE-6 part), (AE-18 part), Johnson 8/4/84 i

, (AE-20 part), AQE-23, and Li AQE-32, (AQE-37 part),

AQE-39, AQE-44, AQE-46, AQE-52 ,

9 Electrical Inspection .AQE-7, AQE-43 Selan 8/3/84 Reports Inspection Item Removal Notices, and In-Process Inspections

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.l Test Program Allegation Review Categories SEP 10 PJ84

  • Csteg:ry Est. Mandays Allegation Package Assigned Schedule No. Subject to Complete '

Nos. Prepared to Open C" lose Remarks 1 Hot functional testing 20 AT-1, AT-2, AT-3, Smith 7/20/84 AT-4, AT-5, AT-6 AT-8, AT-17 2 NRC inspection of 10 AT-9, AT-10 AT-11 Benhm 7/20/84 test program / reporting AT-13 3 Unit 2 testing 2 AT-12 Keimig 7/18/84 4 Containment leak testing 2 'AT-7 Mackley 7/20/84 i ,

5 Prerequisite test process 4 ,AT-14 Benhm 8/10/84 ,

! 6 Preoperational test 4 ,AT-15 , AQE-21 Smith 7/10/84 .

procedures .,

7 Hanagement interpretation 2 AT-16 Keimig 8/10/84 of test commitments ,

8 No QA/QC surveillance 2 'AT-18 Mackley 8/10/84 i of testing activities ,

9 4'.

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k-- - - - - - - _ _ _ _ . - - _ - - - - - . _ _ _

SEP 10 AW4 .

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Civil / Structural Allegation Review Categories Category Est. Handays Allegation Package Assigned Schedule No. Subject to Complete Nos. Prepared to Open Close Remarks 1 Inadequate materials 6 AC-16, AC-19, AC-20, Philleo/ 8/17/84 used in conc, rete AC-21, AC-27 Devers 2 Concrete placements 6 AC-22, AC-23 Phillco/ 8/17/84

, Devers 3 Poor weather conditions 7 AC-24, AC-35 Philleo/ 8/I'7/84 placement of concrete Devers l

l l

4 Concrete volds/ cracked / *

'9 AC-25, AC-32, AC-34 Philleo/ 8/31/84 1 crumbled DC-008, DC-009, AC-28 Devers AC-33 5 Miscellaneous concrete to AC-26, AC-31, AC-36 Philleo/ 8/23/84 Devers l

6 Rebar improperly installed / 12 AC-30, AC-37, AC-38, llofmayer/ 8/31/84 or omitted DC-003, AC-39, DC-004 Tapla/

AQC-12, DC-005 Langowski
7 Concrete - Undocumented 7 AQC-10 llofmayer/ 8/17/84 activity / rework Tapia/

Langowski 8 False / wrong documents 9 AQC-1 AQC-2, AQC-3, llofmayer/ 8/17/84 5 AQC-7 Tapia/

i Langowski 9 QC Inspector training 7 AQC-9 llofmayer/ 8/23/84 and qualifications Tapia/

I,angowski 10 Improper testing 6 AQC-4, AQC-5, AQC-6, Phillco/ 8/17/84 AQC-8, AQC-11 Devers e

90

i Civil / Structural Allegation Review Categories (continued) i Cttegory Est. Handays Allegation Package Assigned Schedule N3. Subject to Complete Nos. Prepared to Open Close Remarks 11 Seismic designs / 8 AC-41 llofmayer/ 8/23/84 construction Tapla/

Langowski 12 Concrete construction 6 AC-29 Philleo/ 8/17/84 and deficiencies / tolerances Devers 13 Cracks In concrete pack 6 AC-44 Philleo/ 8/17/84^

beneath the reactor vessel . Devers 14 Control room area 15 AE-17 Ilofmayer/ 8/31/84 deficiences Tapia/

Langowski

, 15 Rebars improperly 10 AC-40, AQC-13, AQC-14, llofmayer/ 8/17/84 drilled AQC-15. AC-18 Tapia/

Langowski 1

16 . Excavation / backfill 8 AQ-64 -

IIofmayer/ 8/17/84 Tapla/

Langowski

, 17 Concrete sampling AQC-45 G

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_________________.._______.___.___a_______m _ _ _ _ T -.t v

6 SEP 10 mg4

!!cchanical and Pit.ing Allegation Review Categories Categcry Est. Handayo Allegation Package Assigned N o. Subject

_ Schedule to Complete Nos. Prepared to Oyen Close Remarks t

1 Welding - incorrect or AW-31, AW-34, AW-35 ECT/CDR 8/31/84 i no procedure AW-38 l 2 Welding - procedure 'AW-36, AW-54, AQW-28, ECT/CDR 8/10/84 adherence AQW-30, AQW-10 r 3 Improper or defective 'AW-52, AW.59, AW-62 ECT/CDR 8/31/84 pipe welds ,

+4 Plug Welds AW-51, AW-55. AW-49 ECT/CDR 8/2/84 5 Weld Designs AW-44 DDit 8/10/84 .i 6 Improper Weld AW-45, AW-46, AW-61 VPF 8/10/84 preparations AW-66 ,

7 Improper veld examination AW-48, AQW-20, AQW-21 VPF 8/27/84

! and testing 'AQW-23 , AQW-77 ,

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8 Weld repairs documentation AW-63 CDR 8/2/84 ,

problems ,

9 Weld rod control AW-56, AQW-24 ECT 7/20/84 5 i

j 10 Damaged pipe AP-5, AP-8, AP-10 HPC 7/20/84 I' 11 Pipe installation .AP-4 AP-9 AP-13 WPC 8/5/84 -

12 Reactor vessel lustallation AP-11 WPC 8/28/84 AP-15, AP-16 on 13 Hepairs and modifications to pipe . AP-7, AP-16 , AP-15 UFC 8/10/84 hold by 01 e

14 Miscellaneous piping problems ,

AP-6 AP-14. AW-47 DDit 8/26/84 e

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6 Mechanical and Piping Allegation Review Categories (continued) >

Catcgory Est. Itandays Allegation Package Assigned Schedule No. Subject to Complete  !!os . Prepared to Open Close Remarks 15 Pipe hanger design probleas . All-5 RJM 8/2/84 16 Intimidatio$itohangerredesign AII-8 RJil 7/30/84 suggestions i 17 Anchor bolt installation problems AB-4, All-5, AB-6, VPF 8/10/84

( All-7 part) , AB-8, AB-9, All-10, AQB-1, AQB-2, AB-14 18 S/G lateral support bolts (AB-7 part), AB-12, SRT-9 VPF 8/31/84 Jmproperly shortened 19 undersized welds and loose nuts AW-68, SRT-8 VPF 8/31/84 e in a llX support ,

j 20 Piping and bolts AQP-2, AQB-3 JilM 8/31/84 l material traceability 21 NCR activities on pipe and hangers AQP-1. AQll-2, AQll-17 RJM 8/10/84 22 7,%

AQP-3, Jillt 8/31/84 t-23 Blank . , ,

t' 24 Improper weldir.g practice AQW-1, AQW-12, AQW-26, RWil 8/10/84 AW-70 25 Incorrect welding documentation AQW-23, AQW-25, AQW-72, RW11 - 8/24/84 AW-67 l

26 Unqualified welders AQW-2, AQW-3, AQW-4 RWil 7/27/84 a4

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!!cchanical and Piping Allegation Heview Categories (continued)

C;tegory Est. Mandays Allegation Package Assigned Schedule No. Subject to Complete 8

/ Hos. Prepared to Open Close Remarks V _

27 D D""P dMags _

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t RWH 7/27/84 9 tMF,f W U 28 - Irzeu_qqqpeg dHc1My '

AQW-6, AQW-7 JilM 8/15/84

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29 Improperly certified AQW-27 JIIM 8/15/84 i l 11guld penetrant material t

8/10/84

  • RWil 30 pp -N*y AQW-15 31 llanger velding problems All-6, AP-18 AP-19, RJM 7/20/84 AP-20, AP-21, AP-22 32 llanger fabrication deficicucles All-3. All-4, All-9, RJM 8/27/84 All-10, All-11, All-20, [

I All-21, All-18 i , l.

33 Ilanger material control 'All-7, All-15. AQW-71, RJM 8/6/84 AQll-22 1 34 Cenputer program AP-24, AP-25 RJM  ;

verification for base plate 35 Computer program AP-26, AP-27, AP-28 RJM verification for piping .

j 36 Piping analysis problems SRT-1, SRT-2. SRT-3 VPF found in RIl report 37 ,SRT-4,fSRT-5,SRT-6, RJtt I

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Mechanical and Piping Allegation Review Categories (continued) l c -

Category Est. !!andays - Allegation Package Assigned Schedule No. Subject to Complete Nos. Prepared to Open Close Remarks 38 Improper installation . All-l l VPF procedures for anchor

. bolts i

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39 Adequacy of small bore AM-29 WPC piping design practice '

t 40 m rW ,

AQP-23 J11M 41 Improper implementation of AQW-8, AQW-9 AQW-29 Jint of random radiograph program . .

l l ' 42 Questionable welds and wcId AQW-33, AQ-32, AQ-41, . ECT/CDR procedures in primary systems ;AP-12 i

43 Poor welding conditions for AW-40. AW-42, AM-ll, ECT/CDR

! spent fuel storage pool liner *AQW-80, AQW-81, AQW-82 44 ', -M4itR*MesMi7dU8.hg AW-39, AU-50, AW-57, DDII rs -- -- .AW-58, AW-64, AQ-53, AQW-22 l 45 Hiscellaneous welding deficiencies AW-43, AW-60 AW-65 DDil

( AQW-73 l * .

l, 46 Improper weld quenching ,AQW-74 RJM technique 47 , ,AQW-75, AQW-76 RJM

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s AQW QA/QC 31 1 4 3 6 45 AW Construction 35 1 1 0 1 38 Conc re t e/ Ret,a r f 15 0 0 0 AQC QA/QC 1 16 AC Construction 28 1 0 0 0 29

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33 0 0 0 0 33 Al intimidatica 23 6 D 0 l 30 AH Hiscellaneous 19 0 0 0 0 19 AD Design of Pipe / Pipe Supports 18 0 0 0 0 18 AV Vendor / Generic 13 5 0 0 la Al lest Program e

'O O O O 7 Independent Assessment Program 7 AA 56 61 12 13 568 Total 426 i

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titlHHE R$ AQ-133 -- AQ-135 Fey to Completion Categoryi 1 - Prior to OL 2 - fuel loaqing ,

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Allf Gall 0NS AND70It iUUi5 fir.Ili0tif5IiiiMARY CROSS Rft./OR COMPLEliott AtttGER-DAIE Rf C[lVf D 1ASK SOURCE THACKlhG CAlftORY l-7 SCHEDULE SOURCE N'l AlifGAIION OR Coldf RN ACI I0t1/S T Altf 5 ANON CONF 10 tin /0Alf SYSIIH NO. tIAD OPfN COMPtElf DOCllMINI PAGF AQ-133 iftectiveness and mana0e- X 1 TRI ment of the exit interview program i

AQ-134 tack of ANI Review of 1RI Construction travelers for 1 year .

AQ-135 Post Construction B. Garde Verification Program GAP Telecon performed in uncon- ,

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AtttCAll0NS AND/OR INM HIGAIIONS St!!V1ARY Cross Rif./0R COMPl[110N AttfGER-DAIE RECElvfD IA5K SOURCf 1 RACKING CAltGORY l-7 SCittDut E SOURCE NO. AttiGATION OR CONCfRN ACI10N/$1AIUS ANON CONTID BN/DAIf SYSilH NO. IfA0 OPIN COMPIfif DOCUMINI PAGF AQW-77 tack of weld inspection Open M 1 AM) 8/8/84 at RHR heat exchanger it/P Cat. 7 IRI 8/23/84 tube supports AQW-78 Incorrect welding docu- Open X 1 A-" 3 8/8/84 mentation of oxygen IRI 8/23/u4 analyser AQW-79 NDE (RI) of bottom of Open M 1 A-4, 8/24/84 drop gate uuides for spent 1RT

, fuel pool not performed ,

to procedures t

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not match drawing H/P Cat. 43 TRI 8/23/84 locationis on floor around Unit I seactor vessel AQW-81 Iloor plate weld Open 1 A-4, 8/24/84 deficiencies at inter- H/P Cat. 43 . INT section of floor plate and wall in fuel trans-

, fer canal aied fuel pool AW-82 Leak chase channel under Open  ! A-4, 6/24/84 floor of spent fuel pool H/P Cat. 43 IRT fuel transfer canal is defective

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CROS5 R[i./0N COMPLE110N Att[G[R-DAll R[C[]v[D "'

SOURCE INACKit4G CAIEGORY l-7 SClil Dul[ SOURCE TASK AtifGAIION OR CONCERN ACil0N/5f Alt!5 ANON CONF 10 DN/0Alf SYS11H NO. IfAD OPIN COMPtETE DOCUMfHI PAGE NO.

Open 1 A-3, 8/21/84 AQW-83 tack of dociumentation on IRI

, i. eld engineering control for teangers to prevet.L under-

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I 3 - Initl41' Criticality 4 - Jero Power festisuj b S - Low Power festing 6 - Power Ascension Testing I 1 i f ull Power e

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Atf(GlI}0NS AidOO5i~iisiSilhliidfiS'5UMMARY CROSS REF./OR COMPLETION AttEGER-DAIE RECEIVED IA5K $0URCE IRACKING CAIEGORY l-7 $CHE DUL E SOURCE i

NO. AttEGAIION OR CONCIRN ACilDf4/51Alu$ ANON 00HilD  !!N/DAlf SYSIIH NO. LEAD OPEN COMPIEIE DOCIRdNI PAGE AQE-54 tadder cable trays do not E lectrical Cat. 3 Disposition of A-47 f quality as acceptable 1/20/84 P. 419 l barriers and thereby the Affidavit P. 10 ,

j minimum separation of I inc h teetween separate trays and conduits located under the trays is not applicable. See also settien 4.11.3.2(2) of G1N Specs. 2323 ES-100 ,

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AliiGAllONS AN07dR iAN 5YlGhil5U$ 5'diNARY CN055 Rif./OR COMPLEIICH ALLEGIR-DAIE RECEIVfD ,

IA5K SOURCE IRACKING cal [ GORY l-7 SClif Dut[ SOURCE l NO. Att(Gall 0N OR CONCERN ACil0WSIAIUS ANON CONF 10 l!N/DAlf $Y511H NO. I f AD . OPIN COMPtEIE DOCUMINI PAGF AQH-22 t ack of liaeujer material Opesi X 1 4T 8/8/84 j

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NUH0ERS AM-30 Key to Compigon Categ<gryl 1 - Prior to OL 2 - tuel ti ding 3 - Initia1' Criticality 4 - Jero Power lesting' i $ - Low Power lesting .I

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IASK i SOURCE INACKlHG CAIEGORY l-7 5Citt DUL E SOURCE ACI 10N/SI Altl5 ANON CONFID HN/DAll SY$lt H M1. IfA0 OPI N COMPtElf DOCt) MINI PACf NO. AlttGAll0N OH CONCIRN AM-30 II.thitual urination on a X 1 A-3 U/21/04 stainless steel pipe in R. Wessmen notes from interview with alleger the Radwaste System i

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AQ QA/QC (GEt4 twat Welding  !

31 1 4 1 6 45 AQW QA/QC 0 38

! AW Construction 35 1 1 1 foncrete/Rebar IS 0 1 0 0 6 22 AQC QA/QC Construction 28 1 0 0 0 29 AC C' Mild h 0 0 0 0 62 AQO QA/QC 62 E!ectrical 19 35 AQE QA/QC 12 2 1 1 AE Cons t ruc t ion 5 5 8 I O 19 l Pipe & Pire Suf'r. ort s (Non W/h) 3 1 0 0 0 4 AQP QA/QC AP Construction 14 5 5 0 0 24

!'*J"O Atti QA/QC 2 2 2 0 1 1 Ah Construction II , 1 3 0 0 15 B._e I t 5 AQB QA/QC 3 0 0 0 0 3

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  • Original Addendum 1 A<htendum 2 Addendum 1 Addendian 4 Addendum 5 _ ictal i

Al Intimidatiota 31 0 0 0 0 33 ,

AM Miscellaneous 23 6 0 0 1 30 AD Design of Fipe/ Pipe Supports 19 0 0 0 0 19 AV Vendar/ Generic 18 0 0 0 0 18 Al Test Program 13 5 0 0 18 AA Independent Assessment Program 7 0 0 0 0 1 Tutal 426 56 61 12 13 8 570 4

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QA/QC (CENfRAL) l j NUMBER $ AQ-136 -- AQ-137 Key to Completion C.stegoryi 1 - Prior to OL 2 - Fuel toading 3 - Initial Criticality 4 - Zero Power Testing 5 - tow Power Testin.;

6 - Power Ascension Testing 4

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t-i (dMANCHf Pt AR ht'Cif AR P%ER FI ANT AltfCATICNS AN!)/0R INVE5VlCATIONS 5tHM4itV CROSS RLF /OR COMPLETION ALLEGER-DATE REC [lvED f TRACKING CATEGORY l-1 SCHIDOtt SOURCE TASK SOURCE '

h0. ALL EGAllON OR CONCERN ACIl0N/STAIUS ANON CONF 10 BN/DAlf SYSIt M f40. LEAD OPik (UMPttiE DOCUMENT PAGE AQ-1 N-5 vault documents are QA/QC Cat. 3 Hatie-f Interview t,eing altered by adding 8/2/E4 Pg. 18 4 welder's or inspector's

/ signatieres to records on dates these persons wasn't onsite (See AQ 77) Telecon w/5. Pfeillips AQ-) fro.3 iab Shop QA/QC Cat. 50

- Fat. of Mtl w/o paper- 09/11/84

' f- ork (gester post dated) Interview with Alleger A-59 on 09/13/94

' - Min of Q & Noe.e Q Mtl

' [ - urauiborized Weld Repairs

- U X ontsalled Weld God (AQ 71)

- Dirette1 to not color (cde atI.

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key to Complet Ian (.iteyry; I - Prior to OL 2 - Fuel tea.timj 3 - Initial Criticality 1

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6 - Pot.er Ascenston Testing 7 - f ull Powr 1

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CON 1 Rot t t 0 COPY COMANCHE FEAK NtiCIEAR POWER PtANT AltEGA110N5 AND/OR INVE _silGA110HS S_UMMARY CROSS k1F./OR COMPLEI!ON ALLEGER-DATE RECEIVED SOURCE TRACKING CATEGORY l-7 SCHEDULE SOURCE TA5n Afil0N/51Alus AFON CONfl0 tin /DATE SYSTEM NO. LEAD OPfN COMPIETE DOCUMENT PAGE tt0. ALLEGATION OR COMCERN AQC-46 Tests required to be C/5 rat. 8 fort Worth Star performed on concrete Telegram dtd. 04/04/79 in mid pour were

  • pencil whipped"

. AQC-47 Cor< rete rejected C/5 Cat. 1 NRC Interview with Alleger Interview on for teing uver specification limit 04/10/79 on time to discharge was placed in ti.e (irculatimj water intake structure AQC-48 Concrete (ylinders C/5 Cat. 10 NPC Interview with in ttie hunt 14t, Alleger Interview on moist room were allowed 04/10/79 in dry C/5 Cat, NRC Interview with AQC-49 Reinforcement was t>

Alleger Interview nn installed upside down .

04/10/79 in a tmildini s. ear ti.e unit e2 contain-ment strutture AQC-50 Rejected " soupy" concrete C/5 Cat. 2 NRC Interview with was pIafeil in a blab in Alleger on 04/0')/19

. tr.e Anmitieiy Building in the sunner of 1976 L

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COMANutt PFAK NUCIEAR POWFR PtANI AtlifdfiliUS Ah076R INVE511GAI10NS SilfNARY CROS$ Rtf./OR COM?ttil0N Alt [GER-DATE R[C[lvfD TASK SOURCt' IRACKING CATEGORY l-7 5CHtDULE SOURCE  :

NO. At t EGAI!ON OR CONCE RN ACTION /SIAIDS ANON CONFlu aATE SYSTIM NO. IfAD GPEN COMPtFTE DOCllMfNT PAGE I t

AQC-$1 An inspector reported C/5 Cat. 8 NRC Interview with results of caldweld Alleger on 04/05/79 tests without actually running the tests during the spring arid sunimer of 1976 if ,

I

UNITEo STAT [S

  • * ..[ .,[ *O'e,%

. ,. NUCLEAR REGlit ATORY C0MMISSION

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ARllNGTON, TLX AS 70011 j,

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In Reply Refer To:

Docket: 50-445/84-16 k p'./ J Texas Utilities Electric Company , IN 0

ATTN: M. D. Spence, President, TUGC0 {

Skyway Tower 400 North Olive Street lock Box 81 Dallas, Texas 75201 Gentlemen: .

This refers to the special inspection of the Unit I reactor containment building conducted by Mr. L. E. Martin and other members of our staf f during the pericd May 14 through June 2C, 1984, of activities authorized by NRC Construction Permit CPPR-126 for the Ccmanche Peak Facility, Unit 1, and to the discussion of our findings with Messrs. J. T. Merritt and A. Vega and other members of your staff at the conclusion of the inspection.

This inspection is the third in a series of planned constructicn cc'.pletion roem/ area inspections. The primary purpose of this inspection was to evaluate the actual as-built status of the reactor containment building as ccmpared to -f-J- f~

the design and inspection documentation. This inspection covered certain g _ p.

construction characteristics, such as, workmp ch 4 ua W no, cipe supports, in< action esdec w v. etc f ich have been the subject of p ;-*i ~ *.e

gh 6 ;- tiot, this inspection was not iatended to achieve total resolution of specific allegations. The NRC inspectors performing this inspection did not p

have any knowledge of specific allegations in the reactor containment building; therefore, the resolution of specific allegations may involve additional Q tien and corre:.tive actions if required. ,

Areas examined during the inspecticn included piping and pipe supports, containment penetrations, HVAC ducts and supports, electrical raceway and s ui:po r ti , safety-related equipment, "as-built" program, QC inspector and welder qualifications, and follewup on one unrescived iten from the :pecial insp:ction of the fuel building. Within these areas, the inspection consisted of selective examination of procedcres and representative records, interviews and discussions with craft and QC personnel, and observations by the inspectors.

The findings are documented in the enclosed inspection report.

Dasing this inepection, it was found that certain of your acti~vities were in violation of f.'RC icquirn.mnts. Conw;uently, you are required to respend to these violations, in writing, in accordr.nce with the provisions of Section 2.701 of the NRC's " Rules of Practice," Part 2, Title 10, Ccde of j F0lA,85-59 l

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t Texas Utilities Electric Ccmpany .

l Federal Regulations. Your response should be based on the specifics contained I in the !!otice of Violation enclosed with this letter.

Your response to Item A of the attached Notice of Violation should address the adequacy of inspection of these cable. tray hangers (CTHs). It is recognized that the as-built conditions of these hangers are adequate for the intended design function and that the engineering analysis indicates that all of these hangers vill be used as they are installed with the exception of CTH 6567; (bevelled washer). Therefore, your recponse to this violation should address

,the corrective action and recurrence controls for the inspection of these cable i tray hangers.

3 In accordance. with 10 CFR 2.790(a), a copy of this letter and the enclosures j will be placed in the NRC Public Document Room unless you notify this office, by telephone, within 10 days of the date of this letter, and submit written i{ application to withhold information contained therein within 30 days of the

] date of this letter. Sych application must be consistent with the requirements j of 2.790(b)(1).

The response directed by this letter and the accompanying Notice is not subject to the clearance procedures of the Office of Management and Budget as required ,

by the paperwork reduction act of 1980, PL 96-511.

l Should you have any questicns concerning this inspection, we will be pleased to l discuss them with you. '

! Sincerely, 4 .

R. L. Sangart, Director Region IV Ccmanche Peak Task Force '

Enclosures:

1. Appendix A - Notice of Viciation
2. Appendix S - NRC Inspection Report 50-445/84-16
CC w/Miclosures
  • l Texas Utilities Electric L -eany Texas Utilities Electric Conpany ATTN: B. R. Clements, Vice ATTN: H. C. Schmidt, Manager President, Nuclear I!uclear Services Skyway Tcwer Skyway Towir

, 400 W rth Olive Street 400 !!crth Olive Street i

! Lock Box 81 Lock Box 81- l Dallas, Texas 75201 Dallas, Texas 75201 l

1 .

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i APPENDIX A

', NOTICE OF VIOLATION '

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l Texas Utilities Electric Company Docket: 50-445/84-16 [

! Comancho Peak Steam Electric Station Construction Permit: CPPR-126  ;

l l j Based on the results of an NRC inspection conducted during the period of '

, Bay 14 through June 20, 1984, and in accordance with the NRC Enforcement  ;

Policy (10 CFR Part 2, Appendix C), 47 FR 8583, dated March 9, 1984, the following violations were identified:

1 A. Failure to Prcoerly Inspect Cable Tray Hangers (CTHs)  ;

i f 10 CFR Part 50,' Appendix B, Criterion X requir'es that the inspection i

) program of activities affecting quality shall be established and con-1 ducted in a manner to verify conformance with the documented instructions, .

5 procedures, and drawings. I i

! Procedure QI-QP-11.10-2, Rev. 27, " Cable Tray Hanger Inspection," f specifies the inspection attributes for inspecting assembly, configur-j

atton, base plate grouting, welding, etc. , for conformance with design
drawings and documents.

1 Contrary to the above:

1. The NRC inspectors identified two cases where three supports shared common clip angle attachments to the concrete wall. CTHs 6503, 6504, i and 6505 shared a common clip angle that was not called for on  !

! Drawing 2323-S-903, Detail D for Case SP4 or on Component Modification j

Card (CMC) 11097. CTHs 6576, 6577, and 6578 shared cor.on clip angles that were not called for on Drawing 2323-S-903, Cetati D for SP4. ,
2. The MC inspectors identified two hangers where the di.wnsions did f not agree with the drawings. CTHs 6632 and 6638 both have installed  !

t dimensions that are more than the 11/4 inch alloaed tolerarce from l those specified in the apprcpria.e design documents. The dia.cnsional  !

errors are specifically documented on Nonconfor
asnce Report f*34-01634 The dimensional errors of the members varied from 7/8 of an inch to

, j 1 1/8 of an inch shorter than those shewn on the FSE-C0159 drawing.

j 4 f The dimensional errors are in the safe direction with regard to the structural integrity of the supports.

3 The NPC inspectors identified two cable tray bcngers that did not i

] M[ r have the weld configuration specified on the design drawir.gs.

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. l CTH 6642 and CTH 6645 both had horizontal welds at the clip ar.jle to support conr.ection and the design drawings specified vertical welds.

4. The NRC inspectors identified five cable tray hangers that had wall / floor connections that did not conform to those specified by the design drawings. CTH 6657 had a bevelled washer that was improperly installed so that it actually decreased the bearing surface between the nut and the clip angle. CTH 5519 did not have 1 inch of grout under base plate as specified on Drawing 2323-5-913, Detail 6.

CTHs 5491, 5498, and 5499 had clip angles that utilized a combination of welding to embed plates and Hilti bolts for the wail or beam attachment for which there was no detail.

The ebove are examples identified by the NRC inspectors where cable tray hangers were installed by the craft to conditions other than those specified by the identified design documents and the QC inspectors failed to identify and dutument these conditions.

This is a Severity Level IV Violation. (Supplement II.D) (445/S416-01)

B. Failure to Previde Controlled Issuance of Design Documents and Chances Thereto 10 CFR Part 50, Appendix B, CritGrion VI, " Document Control," requires that documents, such as instructions, procedures, and drawings, including changes thereto, be controlled and properly distributed to the location where activities affecting quality are conducted. ANSI N45.2.11, Section 7 requires that documented procedurcs be used to control the issuance of design dccuments and changes 'thereto and that these procedures shall assure that documents are properly distributed.

Contrary to the above, it was determined that issuance of design documents and changes thereto were not being controlled by Operations Document Control Center (DCC). Specifically, the actus1 status of design drawings in the centrol rocm, file 003, could not be determined. The list of CMCs and design change authorizations identified by Operations DCC to be applicable did not agree with the Ccnstruction DCC list. In addition, the effective. revision of Drawings 2323-M1-0301 (CP-5), M1-0261 (CP-4), and M1-0262 (CP-4) were not fcund in the centrol room file.

This is a Severity Level V Violation. (Supplee.ent II.E) (445/8416-02) 9 O

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. Pursuant to the provisions of 10 CFR Part 2.201, Texas Utilitics Electric Cerpany, is hereby required to submit to this office, within 30 days of the date of this tiotice, a written statement or explanation in reply, including:

(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full co..plicace will be achieved. Considcration raay be given to extending your response time for good cause shcwn.

Dated:

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. APPENDIX B s i U. S. NUCLCAR REGULATORY CCl*J4ISSION

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i' REGION IV k

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NRC Inspe tion Report: 50-445/84-16 Construction Pernit: CPPR-126 i

j Decket: 50-445 Category: A2 ,

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l Licensce: Tuas Utilities Electric Company j Skyway Tower

! 400 North Olive Street i Lock Box 81 j Dallas, Texas 75201 s

l Facility Name: Comanche Peak Steam Electric Station (CPSES), Unit 1 [

1 j Inspection At: CPSES,*Jnit 1, Glen Rose, Texas ,  ;

i l Inspection Conducted: ffay 14 - June 20, 1984

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i Inspectars sf/Mgs g?J J $k'fYJ'/

L.~E.'itartin, Reactor Ins" .ctor, RIV Task Force ' Ete/

(paragraphs 1, 2, 3, 4, / , 10, 12, and 13) '

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As $T f I C. R. Oberg, Reactor Infhctor, RIV Task Force ate j (paragraphs 4, S, 6, 7, '6, 9 and 11) -

Other j Acccmpanying Persennel: W. R. Bennett, Reactor Inspector, RIV

! M. E. Skcw, Reactor Inspector, RIV 4

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Approved: /b 9'A u q[ _

D. M. Hunnicutt, Team Leader, RIV Task Force

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i Inspection Su::uary Int,metion Conducted May 14-June 20, 1984 (Report 50-445/84-16)

Areas Inspected: Special inspection of construction cor..pletion inside Unit 1 containment building of piping and pipe supports; penetrations; heating, venti-lation, and air conditioning ducts and supports; safety-related equipment; electrical raceway and supports; as-built program; QC inspector / welder qualifi-cations; and followup on one unresolved item from the special inspection of the fuel building. The inspection involved 801 inspector-hours onsite by four NRC inspectors.

Results: Within the eight areas inspected, two violations were identified. One violation was identified in the electrical area pertaining to cable tray hanger inspections (445/841G-01, paragraph 7.b) and one violaticn was identified in the as-built progrca area pertaining to docue.ent control (445/8416-02, paragraph 9.e).

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DETAILS

1. Persons Coiltacted Principal Licensee Contacts .

J. T. Merritt, Assistant Project Coneral Manager .

  • L. F. Fikar, Executive Vice President, Engineering '
  • /
  • J. C. Kuyket.dall, Manage'r Nuclear Operations ,
  • 8. J. Murray, Building Manager J. Kinavy, Assistant Building Manager M. McBay, Engineering Manager
  • L. M. Popplewell, Project Engineering Manager
  • L. M. Bielfeldt, Quality Eng!'ieering Supervisor.
  • W. Executive A'scistant, Office of Project General Manager R. Deatherago,
  • C. Killough, Quali ty Surveillance Supervisor .
  • J. Brackney, Records Supervisor B. C. Scott, QA Supervisor I. Vogelsang, Project Electrical Engineer R. Camp, Start Up Supervisor - '

M. Hudgins, Electrical Test Group R. Calder, Nuclear Engineering Manager M. Strange, Supervising Engineer -

R. R. Wistrand, Administrative Superintendent Other Contractor Contacts R. Langston,' Brown;and Root ('B&R) Insulation Superintendent T. Chandler,,-B&R, QC Inspector S. Perry, B&R, QC Inspector J. Hobbs, B&R, Paper Flow Group B. Edwards, Bahnson, Project Manager D. O'Brien, Bahnson,; Project Manager .

D. Williams,. Chicago Bridge and Iron (C83). QC Supervisor R. Moehler, k'estinghouse, Site Repre~sentatthe J. Foland, Westinghouse, Nuclear Controls Engineer The NRC inspectors also contacted other plant persennel including members of the construction, techlical, quality assurance, and ad:af nistrative staffs.

  • Denotes those attending the exit intervicw on June 20, 1984. ,

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2. Inr.pection Objectives and Scope The objective of this inspection was to evaluate the construction ccmpletion of the Unit I reactor containment building. This objective was accomplished through examination of installed equipment and hardware to ensure that the installation conforms with FSAR commitments and approved design documents as detailed in the inspection packages.

For each of the areas inspected, prepared inspection data sheets were utilized to define the inspection attributes, acceptance criteria, and results. These inspection data sheets are included as an attachment to this report. Also included in tha scope of this inspection were informal discussions with craft and QC personnel and subjective evaluations by the NRC inspectors of their job knowledge.

The areas selected for examination were:

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  • Piping and piping supports including certain instrumentation for six j different piping systems
  • Containment penetrations j
  • HVAC ducts and supports

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  • Electrical raceway / supports, terminations, and electrical separation i
  • Equipment installation and procurement
  • Revies of as-built program
  • Review of QC inspector and welder qualifications

! This inspecticn included followup and closure of unresolved item 445/8323-06 from NRC Inspection Report 50-445/83-23 as documented in paragraph 11 of this report.

The major portion of this inspection was done during the period of May 14 through June 20, 1984, ar,d was bounded by the 860' and above elevations of the reactor containment building. However, a portion of this inspection for the main steam, prnssurizer relief, and reactor coolant systems occurred in January and February l'34. The inspection of these systems coupled with the insp?ction of the other systems docuuented in this report l cover most of the elevations in the reactor containment building for Unit 1,

3. Ststus of Unit 1 Fcsctor Containmant Cuilding T'.o Unit 1 reactor containt. ant buildir.g vos essentially cen plete from the 050' elevation and ebove-. . The major ccnstruction activitics in those arcas involved c1 caning, touch up painting, and insulatinn installation.

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. [)llJJ:1f The following is a sut. mary of the open items as of June 1,1984, from the master data base (MDB) :ystem (punch list) for the Unit i reactor containment building at elevation 860' and above:

s Coatings 26 Craft 25 Engineering 18 Quality 17 Start Up/ Testing 263 ,

f Miscellaneous 35 384 As seen from above, the majority of the open items were in the startup and testing area, with very few construction items remaining open. At the time of this inspection, access controis for this area were in place.

-' There was still considerable construction actitity in the two 1cwor levels of the reactor containment building. A large clean up and coatings effort was underway. The reactor containment building at all elevations will scon be coppiete and access controls will ti in place.

4. Pipino and Pipe Supports
a. Attributes Predetermined attributes for inspection were identified on the specific inspection data sheet. The following listing gives a detailed description of ,these attributes:

(1) Welding - The type and size of welds and their.locatiun and spacing where detailed as specified by the various design documents.

(2) Hardware . Support members and fasteners were proper type and size with proper orientation.

(3) Connections - Ceiling / wall, etc., cennections to attachments per design documents.

(4) Physical Conditions - Dimensions of support members, piping, and their location per design documents.

(5) Attachments - Size of attachment, uciding and/or Hilti bolt / Richmond inserts verified for size, type, thread engagenent, bearing, spacing, and depth.

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. (G) Base Plates - Size per design document and sufficient bearing l surface contact.

(7) Grouting - Used where specified or appropriate.

(8) Clearances - Sufficient space from interferences to allow for specified thermal expansion and movement.

(9) n'orkmanship

- Conforms to generally accepted craft work l practices.

(10) Documentation - Review of installation -and inspection records to [

ensure that these records docum.cnt the as-installed piping and supports and agree with the current approved design information,

b. Reactor Coolant System (RCS) j (1) General - The construction work on the RCS was found to be l essentially cot.:plete. The primary system hydrostatic test and  ;

the hot functional test (HFT) had been completed. The RCS was  !

open and the reactor pressure vessel head was removed. b'crk was being done on the system in the areas of. instrument calibrat'on and fit up of crossover leg restraint spacers. Reflective f.nsulation had been installed. Grouting of various support base plates was being done. Considerable activity in cleaning up spaces and components and the application of protective coatings was also noted.

(2) Inspection Scepe and Inspection Criteria Utilized Inspection of the RCS included a review of selected portions of the follcwing areas:

Foundations Safety Related Structures Safety Related Co.iponents  ;

Instrumentation Portions of mr.racement systems were test:d by examination of docu ents and procedures as they were directly cpplicable to sene of the areas listed atcve. Thrxe ircluded:

Corrective Actions Design Change Control i

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Procurement Maintenance Equipment'. Qualifications The FSAR was reviewed to determine system technical requirements and ifcensee commitments. Applicable drawings and design change authorizations (OCAs) were reviewed. In addition, records'of QC inspections, craft installation records, and other applicable documents were reviewed to determine the specific craft construction and QC inspection requirements. A detailed list of documents reviewed is contained in Attachment 1.

(3) Foundations (a) Foundation for Reactor Coolant Pump (RCP) and Steam En*erator (SG) Supports The documents including applicable drawings relating to the foundations of the RCP and SG supports were reviewed by the NRC inspector. The following information was found to be documented:

Traveler ME81-2154-5500 identified the need for grouting the columns.

Grout Card 186 documented that grouting was authori cd by B&R engineering and performed on December 23, 1981.

Comprehensive strength of the three grout cubes k , averaged 8450 psi (6000 psi required).

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,s 'i ( NThe applicable drawings wore found to differ in one area.

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[ e') Qestinghouse Crawing 1457F29 (Rev. 5) and Traveler ME81-2154-5500 bhth called for approximately S inches of " grout".

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.g ,e Drawing 2323-51-0550, Rev. 4 called for " Class E concrete" to gw 'l 9 be used under the pedestal bases.

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iscussions were hold with TUGC0 civil engineering. The s

/ engineering representative stated that no technical problem h

g xisted since the ccmmercial grout strength excccded the ClasL E concrete strength. The NRC inspector ccncurred p /

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(b) Crossover Leg Horizontal Restraint Anchor Bolts Two types of anchor bolt assemblies were used on the horizontal restraints of the reactor coolant crossover icg.

RA03 and RAS 4 assembly bolts, nuts, and washers were made

from material that conformed to ASTM A-540 requirements.

The anchor plates were made from material that conformed to ASTM A-558, Grade 50 requirements. The assemblies were fabricated off site, shipped to the site, receipt '

/ inspected, and later installed as pat ; of Concrete Placement 101-2812-01 (in blockouts). Subsequently, foundation concrete for the loop 1 crossover restraints was installed (Placements 101-9812-01 and 101-9812-02).

The materials and installation pf the 2 h-inch anchor bolts, RAB-3 (75 inches long) and RAB-4 (S7 inches long) were confirmed by a review of records and verification of code marking on top of anchor bolts. The NRC inspector concluded that the anchor bolts were installed in accordance with the applicable drawings.

(c) Foundations for the Steam Generator and Reactor Coolant Pump Cross Over Leg Restraints The records documenting the placement of foundation concrete for the crecsever leg restraints were examined for Unit 1. Concrete Four Packages 101-9812-002 and -003 were reviewed. Design Mix 129 was used for the placement on June 1, 1978. All 28-day cylinder breaks were verified, by review of compression test reports, to be in excess of 4000 psi as required by Construction Specification 2323-S5-9, Rev. 4. The placements took place on June 1, 1978. Proper curing was performed.

No discrepancies in the documentation were noted. Specific documents reviewed are listed on the inspection data sheets.

(4) Reactor Coolant System Picing Cleaniiness (Cxternal)

Insulation on the RCS piping and major components is the reflective or mirror stainless steel type r:1nufe etured by Di?mond Po.,ar and installed by EOR, Prior to installation of t;,e intuletion cutions, c ! Pes t are t' akn of the rurface of the stainless steel piping in ordar to determine t'e chloride and floorida centcminaticn icycls. FSAR, Section 5.4.3.3.3 stated that prior to rpplication of ther: cal insulation,

')D!irT ia Led 5 austenitic stainless steci surfaces are cicaned and analyzed to

a halogen limit of 0.0015 mg Cic/dm 2 :nd 0.0015 n;g F2/dm*.

The NRC inspector reviewed the program for determining surface contaniination. The procedures contain adequate controls for -

ensuring that the surface of stainless steel does not excoed the * '

designated levels. Inspection travelers were reviewed.

Specific requirements for cleaning and QC inspection were ;

identified. Inspection item removal notices are required when insulation is removed and reinspection for contamination is repeated. The NRC inspector also observed the cleaning and obtaining swipe samples.

No deviations or violations were identified.

(5) Safety-Related Components The NRC* inspector reviewed Traveler ME-78-004-5505 that documented the installation of the RCP casing and supports.

Final adjustr.iont of the column supports was done af ter HFT. The NRC inspectors noted that the columns were grouted. Readings of pump casings level were recorded as required by the traveler.

No discrepancies were noted in documentation. QC. inspections had'bcen accomplished.

(6) Instrumantatien RCS flew tran mitters (1-FT-415, 416, and 414).for loop 1 were selected for inspection. The NRC inspectors examined the runs to determine if identification, routing, sicpe, supports, and valves were installed in accordance with applicable drawings and specifications.

Instrumentation tubing was classified Safety Class 2, Seismic Category I. Wet process lines generally required a sicpe of 1 -inch per foot. Routing and support locations were specified on the installation drawings. Records reviewed (see Attachment 1) agreed with the actual installation of the ir.strument runs. QC inspections had been e.cccmplishad in accordance with hold points specified on each weld data card. QC hold points included cleanliness, fitup, purge, final visual inspection, and dye penetrant exaninations. 1 l

The I.RC ite.;vct or coricit.ded ths.t the flow indireaantation 'for Icep I was installed in .ccord:nce with approved drawings and specifications.

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.. . '[b f (7) Nonconformance Reqorts (NCR)

BLR NCR C705-R1 (7/21/77) identified that 11 RAB-15 anchor bolt assemblies used in crossover leg (vertical) restraints were nonconforming in that jam nuts were welded to the plate washers instead of heavy hex nuts. The assembifes had the jam nuts removed by a lath and grinding from the bolt and the plate washers. The NCR was reviewed and approved by QA on August 8, 1977. On August 1, 1977, TWX-824 requested approval of the repair procedure from Gibbs & Hill (G&H) (New York office).

On August 4, 1977, GTT-1420 documented approval of the repair.

Design Change / Design Deviation Authorization (DC/00A)-65 was issued on August 4, 1977, authorizing the repair.

Inspection and acceptance was to be.done in accordance with ASTM A-540. A QC inspector observed the machining operation and performed a final inspection.

The NCR package was reviewed by the NRC inspector. An inspection report (8/5/77) documented the results of the machine shop operation. Nondestructive Exemination Report (NDER)-1108 documented acceptance of the materials for further use. Verifi-cation of ccrrective action by QC was performed on August 12, 1977.

This NCR was selected for followup due to the special nature of the inspection action requested by the NCR and DC/CDA. All required licensee actions were found to have been ccepleted and appropriately documented.

No deviations or violations were identified,

c. Containent Spray piping and Pipina Supports The NRC inspectors selected 15 supports, 21 nozzles, and approximately 112 linear feet of containment spray piping for inspection. The specific areas inspected are identified on the support / hanger inspection data sheets of Attachment 1 to this report.

These sections were physically walked dcwn and inspected. The NRC inspectors utilized the current cpproved design infcrmation and the latest QC inspection reports to determine adaquacy of installation and accuracy of documentation.

No deviatiens or violaticns *.* ara idantified.

d. Fer.dsd er Picigg g d pip,irg n 3 gprts The HRC inspectors selected 24 mpports nd appror.imately 210 linear feet o,f feeductcr piping for inspection. The specific sections

- obscrved are identified on t he support /hangor inepection data sheets of Attach:.ent 1 to this rrport.

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.j These sections were physically walked down and inspected. The NRC inspectors utilized the current approved design information and the latest QC inspection reports to determine adequacy of installation and accuracy of docun.cntation. .

1 No deviations or violations were identified.

e. Pressurizer and Associated Piping  ;

1 '

(1) Pressurizer Piping Systems and Associated Supports The NRC inspectors inspected 15 pipe supports and approximately 150 feet of piping associated with the pressurizer relief system. All of the supports and piping were installed in accordance with the latest design drawings and the appropriate procedures. This inspection also included a review of the documentation packages including inspection reports, welding '

t document 3 tion, design changes, nonconformance reports and their i closure, material certifications, and construction travelers.

(2) Foundations and Foundation Bolts The NRC inspectors inspected the installaticn of the pressurizer including rigging, pouring of concrete slab, and bolting. Construction Operational Traveler RI 73-009-5503 covered the rigging lifting and setting of the_ pressurizer.

Drawing 2323-51-0SS1, Rev. 6 and the documentation for Cencrete Pour 101-7853-001 covered the location, size, type, securing, and thread protection of the base hold down bolts for the pressurizer. Purch'ase Order 35-1195-6312 and Receiving Inspection Report 03749 for the bolts were reviewed and fcund to be correct.

The NRC inspector verified that the heat number identification (007) was marked on each of the 24 anchor bolts. The bolts were certified to be ASTM A-540, B23, Class 4 material. The anchor bolt assemblies were manufactured by Bostrem-Ecrgen.

The NRC inspectors concluded that-the pressurizer anchor bolt assemblies were of the specified materials and installed in accordance with the drawings and applicable design changes. QC

, inspections and documentation of these activities were appropriate.

The NRC inspector also reviowed the records for Ocsign Mix 133 and Master Euilders Grnut 923 utilizcd in the installatien of the anchor bolts and setting the pressuri:er. The average

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! 28 day stronqth was 4550 psi (design 4000 psi). The concrete 1 pour records for Pour 101-7853-001 were appropriate.

.i j No deviations or violations were identified.

f. Main Steam System Supports and Whip Restraints .

.a The NRC inspectors reviewed four pipe supports'and two pipe whip restraints associated with the main steam system. These cupports and restraints are located above the 860' elevation of containment. The individual supports and restraints are identified on the data sheets in Attachment 1 of this report.

These items were inspected in detail to assure that the supports and restraints as installed conformed with the vendor certified drawings; FSAR, Section 3.6.B; ASME,Section III, Subsection NF; and the associated specifications and procedures. A partial inspection of these supports and restraints was documented in NRC Incpection Report 50-445/34-05 and specifically related to certain allegations. This inspection was a total inspection of the supports and restraints including a review of the documentation.

The NRC inspectors found that the inspected supports and restraints were constructed end inctalled in accordance with the design drawings and procedures. The NRC inspectors also found the document packages for these supports and restraints to contain the portinant documents related to QC inspections, welding, design changes, and procurement.

No violations or deviations were identified in this area of the

, inspection.

5. Penetrations The NRC inspectors examined 3 mechanical penetraticas and 3 electrical penetrations. Dimensions.and locations of all penetrations were found to be in accordance with applicable drawings. Craftsmanship was catisfactory. There was no evidence of insulation cracking on electrical penetration cabling. The NRC inspectors' review of records indicated that installatien and maintenance were in accordance with the acceptance critoria and had been accurately documented, and that leak rate testing had been performed in accordance with the applicable
proce. dure.

No violations or deviaticas ware it'entified in this area of t'.e i.,: r ect i on.

6. !Jc. ;t_'dqd n ti l a t i on , a nd .".f r 'O nd i t i e n i ng Tveenty-five ceirmic duct supports and associated duct seg7.ents of the L' nit 1 centainment ai circulation cnd ccoling system were inspected.

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Specific supports are listed in Attachment 1. All but one of the supports were located on or above the 905' level of containment. The 24 supports are approximately 25% of the total HVAC supports on the

.l 905' level. The 25th support was located on the CGO' level.

The following attributes were utilized during this portion of this inspection.

Duct Supports Duct Segments

  • Location Orientation Dimensions Size itember Size General Configuration Wolding Location Supports for HVAC were examined in two parts. First, the seismic supports as designed and installed by Bahnson and second, the attachment to the containment liner
  • plate, installed by Chicago Bridge and Iron Company (CBI), that held the support in place.

Three of the supports were found to have dimensional discrepancies as

[s V inccrrect member sizes. These supports were examined by Bahnson and submitted to Corporate Consulting and Development Comp'any, Ltd. (CCL) for evaluation. Similar problams had beenyrevjoutly. identified in N/

the CAT Inspection Re;;grt 50-445/83-18 and_ Region IV Inspe_ctio,n_, c b />

Report 50-445/84-10. CCL's report had not included containment HVAC jg supports -in~their evaluatio3 #The weld'Tt7 esses wfF'e-u rneceputed 3 (kl j )M ased o D he "as-installed" condition. The recomputed stresses were

.. found to be within the allo g ble limits as shown below.

,2/

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Maximum Emercency Upset condition g, 3./A{SupportMember , Condition Stress Allowable Stress

/

R8-1-905-10-1G 12,585 psi 21,000 psi RB-1-905-10-4N 16,542 psi 21,000 psi RB-1-905-10-4J 9,137 psi 21,000 psi The results cf the analysis were centained in CCL's letters to Eahnson dated May 22 and May 25, 1984 The analysis confirmed that the installed x HVAC supports were adequate for the expected service requirements.

j Bahnson procedures for " Direct Support Design, Fabrication and l Installation" (DIP-TUSI-003, Rev. 8, 5/4/83) and "Ductwork '

F<.brict.tien reacc. dure" (CIP-TUSI-001, Rev. 30, 7/71/83) .mco reviewed and were found to be apprcpriate and contained sufficient detail and criteria.

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i The second part of the HVAC inspection involved an examination of the attachment assemblics holding the HVAC supports to the containment liner. CBI manufectured and shipped 40G "50-A" attachments to CPSES.

The attachment supports were made of 4" SA 537, Class 2 material, and consisted of 2 pieces joined by a full penetration weld. The base i plate was approximately 6b"x6". The attachment bracket was 6"x3k",

j welded at right angles to the base plate. The base plate was welded 1 to the containment liner by a 3/16" fillet weld around the  ;.

, circumference of the plate. Other attachment brackets of similar

  • ccnfiguration were made of 3/8" plate and welded to the liner plate in a similar fashion.

The NRC inspector concluded that' the materials were as specified on the CBI and C&H drawings. Material traceability was confirned by_a 'N review of receipt inspections, shoo _ releases. and matqrial he.at 7 6Emcer sheets. Attachment welding was inspected by qualiff ed OA

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weldino sucervisors as confirmed by the CBI master checklists. A Bahnson welding s'pecification (BSC-20) was coordinated with TUGC0 to '

conform to base metal SA 537, Class 2 w.31ded to ASTM A-3G material using EE018 filler metal (group F-4). Discussions were held with CBI and Bahnson personnel. Visual examination was made of approximately , C f

25 HVAC attachments. r. I No deviations or violations were identified. 4j.

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7. Electrical --

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This section of the report contains information regarding the inspection of cables ar.d c'able terminaticns, cable trays, conduit runs, and their associated supports.

a. Attributes Predetermined attribates for inspection are identified on the specific inspection data sheet. The following paragraphs give a detailed description of these attributes:

Cable Type - The type of cable used was confirmed by comparison of the cable to cable cor.nection sign-off cards and cable pull cards. The number of cen.(uttccs and color of cables vere specifically verified as part of the inspectien.

Type cnd Site - This pcrisins to the type cr.d size of ccoduit or cable tray including fittings, splices, pull boxes, covers, offrets, a.d fastaners.

  • Trsy ccvers . Installed as required or idcatiff;d as an cpen item.

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  • Grounding - Installed as required on all raceways.

j This grounding is primarily for personnel protection.

  • Craftsmanship.- All fasteners properly installed, raceways

]

! free of sharp edges and burrs, galvinox protection, raceways

free of damage, overall integrity.of raceways, and proper bending of conduit. In addition, note tas made of correctness

. of craft functions such as appropriate and adequate use of, cable ties, crimping of connections, correct and clear identification of the cables, bend radius of cables, surface condition of cable, etc.

  • Identification - Raceway identification and train or channel identification at each end and at the proper intervals in between as specified in IEEE 384.
  • Supports - Proper type and spacing of raceway supports, material size and. dimensions, welding, structural attachments, raceway attachments, location, bolt size, and spacing.
  • Separation (physical / electrical) - Proper separation frcm piping ducting, etc., proper separation between voltage level,
one foot /three feet separation between redundant trains or barriers, and separation frcm possible noise sources for nuclear instrumentation system (NIS) cables. Cable termination racks and
pa.nels were also inspected for internal separation requirements.
Separation criteria for Class IE circuits for CPSES is contained in IEEE 384-1974 (draft). Typical separation details for~ cables and raceways are contained in G&H Drawing 2323-EI-1702-02.

This drawing was based on,the Electrical Erection Specification 2323-ES-100, Section 4.11, " Separation Criteria".

. Additional criteria-for NIS separation is contained on G&H Drawing 2323-EI-0602-03.

  • Color Coding - Safety-related trains are indicated by the color of the outer jacket of the cable as indicated 4

below:

"A" train - orange - 0 Associated "A" train - orange with white stripes "B" train green - G Associated "B" train grecn with white stripes "C" train - black - K - non-Q Instrument Channel I - Red R O

. . _ _. .,_m....... ., -, ..

-1G-Instrument Ch. ann.el II - White W

] Instrum.cnt Channel III - Blue B

-l Instrument Channel IV - Yellow Y Cable trays and conduits are marked with unique identification

', numbers which include a train or color code desigiiation. The use of color code assisted in the determination of acceptable l separation achievement. The cables were checked for consistent and correct color (train) designation.

  • Documentation - review of installation and inspection records to ensure that these records document the as-installed raceway and supports and agree with the current approved design information.

Documentation of the cables was reviewed to determine if the QC inspection record was.(a) clearly identified to the cable involved, (b) legible, (c) corrected, when necessary, by the use of a single line drawn through incorrect entries, and (d) completely filled out, date 1, and signed by authorized QC inspector.

  • Terminations - Inspection of cable terminations included these items to ensure that the cables were consistent with the installation record. Specifically:.

Cable nw. bering and marking at termination points.

Terminations of conductors were properly cricped, terminals were tight, and conductor color and narkings were verified.

b. Electrical Raceway and Raceway Succorts The NRC inspectors selected 1C8 sections of cable tray for inspection. The specific raceway sections inspected are identified on the raceway inspection data sheets of Attachment 1 to this report.

The NRC inspecters physically walked dcwn and inspected 108 cable tray sections, 92 cable cable tray supports, and approximately 924 feet of cable trav. All of the cablo tra's and 77 of the cable 9 "' ay-str;;drE inspected wJri properly instal - , and the docun.catation was in order. The re.:aining 15 cable tray support.s did net have V'" , // W pf w ar__su,a rtina_& cm.ntetion. This refl" cts inad3qvi e insp.:ction.

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f The s'aficiencies wcre subsequ-ntly Mecu::.ented 'c y iGCO,n -~ N '

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. O h .3 5 10 CFR Part 50, Appendix B, Criterion X and the FSAR require the organization performing an activity to verify conformance with accomentcd instructions and drawings for acccmplishing the activity. QI-QP-11.10-2, Rev. 27 of June 19, 1984, specifies inspection requirements for raceway supports including assembly inspection, attachment inspection, verification of bore plates for grouting, and welding inspection.

s In two cases, three supports shared a commen clip angle attached g to the concrete wall. The cable tra,y hangers of Crawing FSE-00159, }

Sheets 6503, 6504, and 6505 specifiy hangers por Drawing 2323-El-0502-S, Detail "F". Detail "F" and Field Sketch /

Electrical (FSE), Sheets 6576, 6577, and 6578 refer to Drawing 2323-S-0904, Octail "5" for additional specifications, which in turn refers to Drawing 2323-S-0903, " Case SP4". SP4 specifies attachment per " Detail 0". Detail O clearly shows a connection for one support to a clip angle and attachment using two bolts. Itwever, to place the hangers with the required 16-inch vertical separation per these FSE sheets and Octail D, there would have been insufficient separation betwoco the Hilti bolts per Table 3 of QI-QP-11.2-3, Rev. 20, dated Mty 8, 1984.

The QC h tors failed to recocnize and document that the supports identified above were not Installed in accordance with

~

approved design drawines.

The cable tray hanger of FSE-00159, Sheet 6538 shows that dimension 22 of Detail "B" of Drawing 2323-El-0502-01-5 should be 3'10 1/6". The allowed tolerance for this specific application is b inch. The actual dimension as-built is 3'9".

This difference is beyond tolerance specifications and was not recognized by the QC nspectors.

The cable tray hanger of FSE-00159, Sheet 6632 shows that dimensions for detail "E" of Drawing 2323-El-0502-01-S should be h t =9'4 k", h2 =5'4 ", and h 3=2'S\". The allowed tolerance for these specific applications is \ inch. .The as-built dimensions are h 2=9 ' 3" , 5 2=5 ' 3" , and ha=2' 7" . This difference is beyond the tolerance specifications and was not identified by the QC l inspectors. _

Cable tray hanger of FSE-00159, Sheet 6657 has a Hilti bolt installed at an angle. The bevelled washer that was inctalled to provide improved bearing contact betwcan the nut and the clip a gle was nisalicnnd. Tha misaliC mnt of the bevel uasher exacerbated the not bearing centact. This was not identified by the QC inspectors.

Tha c ble tray hr.ncer of FSE-00159, Shact 5519 shows a 1-inch grout to imprcve the bearing cf the angle clips per  ;

Drawing 2323-5-0913 Detail "6". Grout was not used and this '

, condition was not. recognized by the QC inspectors. {

1 -

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Cable tray hangers of Sheets, 5491, 5498, and 5499 of FSE-00159

are to be attached to the concrete per flote 1. tiote 1 refers to

, Drawing FSC-00179 for specific requirernents. As-built, these ,

hangers have welded the clip angle at one end to a plate ,-

c.mbedded in the concrete. At the other end, a Hilti bolt is used. FSE-00179 does not provide for this option in 2-bolt -

clips. This substitution was not identified by the QC inspection.  :

Cable tray hangers FSE-00159, Sheet 6642 refers to Detail "A" of Drawing 2323-El-0502-01-S and Sheet 6645 refers to detail "G" for assc=bly details. Both details refer to " Case SP1" of Dr: wing 2323-S-0003 for additional instructions. In all these drawings, the welds where the support joins the clip angle are shown to be 4-inches long in the vertical direction. As-buil t, the welds are horizontal and less than thb 4-inch length required on the vertical edces. This condition was not identified by the QC inspectors.

The licensee's engineers stated, and the !?RC inspectors agreed, that the hangers discussed above are adcquate for use as-built.

Only the bevel washer will be reworked to correct its misalignment. Char.ges were teing prepared to correct the docur.entation for these hangers to reflect the as-built condition. The design docurent or instruction used to install 1 ,

K' cnd inspect the hangers could not be identified.

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The above are exa pies of failure to properly inspec able tray hang ip

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  • We,#). yThis,,ers and toation, verify conformance with apprcved drawings.

M Severity Level IV. (445/8416-01) m

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, { p' c. p9 ct cal Conduit :.nd Conduit Supports

' e t:D.C inspectors physically walked down and inspected 33 conduit Y) '

runs, aoproxiustely 200 conduit supports, totaling approxirnately 1500 linear feet of conduit. The NRC inspectors utilfred the

/ current 2pproved design information and the 14trst QC inspection report to determine the adcquacy of installaticn and accuracy of documentation. The conduits inspected, including sueports and i fixtures, were prcporly installed and accurately docur cr.ted, fio deviations or violattens were identified.

d. fim-trical Sysrations The IRC inspectors ebserved ccyration rce,uire,.ents during the r.:cc,eay er.d conduit in pection. In additien, ccvc.41 *Ours were ycnt walking down the 000' end 005' elevations cf csntatnuant

.r cci fically inspectirig to the i .quirer.. cats of IEEE 334.

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. DTMFT The following list of equipment was opened and inspected for .

separation, terminations, and cleanliness; a Valves Junction Boxes Cabinets MOV 1 HV-6075 JB1C-566G RPI Cabinet A .

MOV 1 HV-6074 -

JB1C-30303 -

RPI Cabinet B MOV 1 IIV-G076 JB1C-3031G Thermocouple JB1C-a385 Ref. Junction-

, JB1C-4420 Box The NRC also. inspected Valve MOV 1Ril-8702 and witnessed the change '

of the torque switch setting required by Traveler MEV 84-0607-5800 and DCA 19537 R-1.

All of the above equipment was preperly terminated, exhibited good craftsmanship, and was properly maintained and clean with the exception of the red position indication (RPI) cab.inets.

The RPI cabinets were not terminated yet. The cables were in the cabinets with the plugs attached, but the drawers and cards were not installed. Th.e plugs were sealed in plastic bags. The RPI cabinets were dirty inside and required cleaning. These cabinets are non Class 1E cabinets, and due to the status of the cabinets, the lack of cleanliness dcas not have safety significance.

The NRC inspector reviewed the procureT.ent testing and installation of the separation blanket raterial utilized at CPSES to meet the barrie'r requirements of Rcgulatory Guide 1.75 and the thercal radiation shield requirements of 10 CFR Part 50, Appendix R. See data sheets in Attschment 1 of this report for the details of this inspection and review.

No deviations or violations were identified in this area.

i

8. Equipment
a. Hydrogen Reco.vbiners The NRC inspectors exanined the maintenance records and installation of the hydrogen racccbiners. Installation, foundation, and anchor bolts were found to be in accordance with the installation drawings.

Type Class "B" storage cas re;uired. Maint m nce records indicated that maintenance had been performed preperly during storage in the wacchoose. In place maintonatice is required every 2 years. It h d not yet bcon perferend because the equipacnt had tcen installed for less than 2 years. l l

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/ The NRC inspectors' review of the precurement pockcce reveale i, out-of-specification voltage roarfiryns for creparator output v'i o

M/d ' M y cc was-inforued and obtainE~d'a modificd quality diktase from 1/cstinghouse stating that voltages were satisfactory. S

, . / d4 / Discussicns with startup and ilostinghouse personnel revealed that f j-'y-}p .

voltcge readings do not affect the operation of tgquipent',' and

,- the equiprnent has succost,fullv_.ccepletedTrcoperational testing.

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The NRC inspector concluded that the cut-of-specification vcitage readings were an isolated event and concurred with the anslyses that y/jddp,< ,u,p l

no safety signific' ce was involved. - '

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/ .{ ,.Equipment Procuren nt Documentatien b -

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k This portion of the inspection was conducted to review the pescurement decur.mntation of three campenents in containtnent. ,

/ The cc ponents selected were:

Hydrogen Rec =biners (505' level) (two each)

!!otor Cperated Blcck Vcivcs pressurf:er relief systet (905' level) (two e.sch)

Air epureted, pressurizer spray valves prcrsurince spr.rf ,

line (9~05' level) (two each)

The inspection cencentrated en the procurem nt specificatiens, '

purchase orders, and receiving inspection repcrts. '

ANSI N45.2.13 was used at th'e aceptsnce cri'.crf k. Specifically, the following attributes were locted for in the documentatian.

  • Secpe of work
  • Technical requirements
  • QA program requirements
  • Right of accass
  • Occunentatich require ents 1
  • Ponconfen.ar.cc requirc%nts )
  • ileview of p,rncurc;.cnt r':cu ents (rqai,- at sgplies)  !

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IJ, .[]ay[ ,7 The NRC inspectcr d6termined that the dvcutent! tion was cvailabic on site. All documentation reviewed was found to be acce.ptable in accordance with the acceptance criteria. Purchase ,

, specifications will be retained under TUGC0 Nucicar Engineering .

(TNE) for configuration control fcr future purchase of replacement units, if required, and purchase of repair a rts.

No deviaticns or violations were identified.

9. As-Built Desir;n Documentation Program I p
a. General _ - A review of the,li'c/ensee's program for verification -

and control of design documents was conducted. Specific drawings cnd dijgsms ,were selected by the manager, nuclear cperation anFTl.pfor updating prior to fuel loading, These ,

drawings and 'otagrams are listed below. THE is in the precess of assuming responsibility for CPSES drawings and specifications as they are verified by the AE, GEH. After design verification, the dra%ings are then issued as "CP " drawings.

The purpose of this partion of the inspection was to determine .

(1) adequacy of procedures governing the generation and ccmpletion of as-built design dccccants (drawings and specifications) and '

(2) the schedule for completion of the as-built drawing dccunientation.

b. Procedures - Precedures gcverning the generation and completion of as-built design dccuments, reviewed by the NRC inspector, are listed in Attachment 1. The procedures caet the applicable requirements of ANSI N45.2, N45.2.11, and !45.2.9. It was verified that CMCs and DCAs affecting GiH design documents.are {'?

~

being reviewed cnd, where indicated, included in the ravised j drawings and specifications. G&H Project Guide 24, " Processing CMCs and DCAs," includes a " Change Verification Checklit,t".

This form is used as e6gineering control for the review of CMCs and DCAs. G1H enginn rina determines if the chance (Cf'C or CC.A) will be incory_ orated into the drawing, and documentsJhdecision on line 6 of this form. When all cutstanding CMCs and DCAs are reviewed and incorporated intu the desf nG decements, TNE plans to issue engincering change notices when system design changes are required.

c. Schedule - The following diagrams and drawings were included in the licensee's schedule:

Mechanical Flow Diagrams (,1-200 cod 300 series)

Electrical One-Line Disgr ms, 3-Line Diacrims, Electrical Wiring and Connection Dirgrcas (El-C01 through El-200 series)

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' Instrument and' Control' Diagrams (til-2200' and 2300;scries)

Instrument Equipment List (MI-2400 scrics) e 4

Instrusent Location Drawings and Tab Shcats (MI-2500 and

  • HI-2G00 series) 5 Safety-Rolated Vender Drawings l Of the 4537 drauings originated by G&H, 4422 had been reissued by TUCCO as of ?.pril 21, 1984.

Drawings that have outstanding design changes at fuel load will be identified in the l'C3 for updating prior to commercial  :

cperation. Additional drawings will be updated af ter ecmmercial  !

cperation. These were identified as follbws: l Electrical Physical Drawings (El-300 through El-800 series)

Electrical Fire Protection Octection Drawings (El-2000 i series) .

Plant Architectpral Crawings (G&H "A" prefix drawings)

Non-Safety Related Vendor Drawings .

Electrical Lighting Orr ings (El-900 scries)

Electrical Materfal List (El-1500 series)

Cceputert:ed Cable anc Raceway Schedule (El-1700) and other misec11anecos (El-1700) ser.ies drawings Instrument Rack Witing Drawings (El-2E00 series) f Instrument Installation Drraings (M1-2100 series)

d. Progr . Conclusiens - The )GC inspection concluded that the pregram

~

far epdating- enf previding as-built design drawings and specifications

  • is adequate and ceots regulatory requirements and FSAR commitments.

e, I plo. mentation - Seven drawings under control of TNE were relected for review to determine if they were being centro 11ed in accordance -

with the g proved precedurcs.

Uhcn salected controlled dr:xings l'r. the control recm were exemined, three'cf the seven, M1-0201, Mi-051 and M1-262, were determined not to be of-the correct versien.

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c' i TUr.C0 document control center (DCC) (Operations) has the responsibility-

for maintaining the control room drcwing file (003) current. TUGC0 CCC had received the aperture cards, date starnped May 22, 1984, for the current revisten of the drawings and was in the prucess of producing copies for dis't'ribution. (Note: The inspection was conducted the afternoon of June 6, 1984; drawings had been updated '

Iay 15, 1984.)

In addition, the NRC inspector reviewed the design change log sheets g (Construction DCC) and DCA log file (TUGC0 DCC) for the selected T

$ drawings. It was found that t'nese two records do not reflect the )

\ same status. Further information regarding this laatter was found in '

l Quality Surveillance Q5R-84-011. The findings result-ad in a g Corrective Action Request (CAR)84-001. This surveillance report stated that ". . . the design change logs for desi0 n drawings and the specification log sheets for design specifications, which are maintained by the Operatiens Document Control Center, do not reflect the w.me document status as that of TUSI Nuclear Engineering.

Due to this condition, the correct status of design drawings and specifications distributed by Operations DCC is indeterminate."

A permanent solution to the deficiency identified in CAR 84-001 was to have been irrplemented by June 1,1964. Implementation was delayed until June 30,1934 (TI!i-840667). The NRC insper: tor

~

found on June 5,19S4, that the control prcblem (as stated ir.

the CAR) still existed. A similar problem with a manual system had been identified in a surveillance conducted in Octcher 1933.

Two aspects of document tontrcl were thus identified: ,

(1) The actual status of design drawings can not be determined. .

This problem had been identified by the licensee in l surveillance reports, and action had been initiated, but -

had not been completed. Control of docur.ents and changes to these documents are required by 10 CFR 50, Appendix S, Criterion VI as well as corrective acticn required by Criterien XVI. The commitment for providing contrciled documents was established in the FSAR, Section 37.2.6. '

(2) Some desien drawings available for use by centrol rcom peysonnel utre out of date. The operations precedure (STA-305) gowarning the control of drawings did not have a '

specific time limit for issuance of revised drawings after.

receipt of aperture cards. Mcwaver, Stsed on the date of drawing revision (5/15/04) cnd " cop 1.: tion" of aperture cards (5/22/S4), updated versions of the drawing could  !

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reasonably be expected to have been provided prior to \.

June 6,1984, the date cf the inspection.

Leick of adequato ,

, measures to ef fectively control the issuance of docu: ents

, affecting quality is a violation of 10 CFR Part 00, .,

Appendix B, Criterion VI.

This is a violation. (445/S416-02)

10. QC Inspector Qualifications #

The NRC inspectors selected eight QC inspectors for verificatien of their iqsjector_ quali'WH ans. The namas selected were chosen from inspection records used in other areas of this repert. The names included two electrical inspectors, three electrical (mechanical) t incpectnes, and three mechanical inspectors.

The varification included checking that qualificaticns were made in accordance with current procederos and that the inspector was indeed quclified at the time selected inspections were perforced. The NRC review fcund one inspector who was not qualified to perform inspection in accordance with QI-QP-11.10-2. The selected inspection was pcRcemed on September 1, 1933, while the inspector did not become

! qualified to perform this inspection until Cece-her 1933. This situatica had already been identified by the licensee in NCR M3-03049 dated l:over ber 15, 1983. Appropriate sction was being ta%cn by the licentce to resolve the NCR. The licensee hac identified all the J, //

in:pections for which the inspector was r.ot qualified, and a rein- q . I','

spection program is caderway. This reinspection is being done on a- g*y g reem-by-rscr. Lasis. ',

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Curing this inspection, the ,':RC inspectors had informal discussions N with QC, engineering, electrical test group, and documentation ,

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persennel to deterc.ine crawings, precedurei,, and jobthe khcwledge day-to-dayard overall familiarity

rechanics of their jobs. with I ,N p c o In all cares, the people were knowledger*alc and professional, , k# gd i

'!o vioht'ons cr tJeviations were identified in this area,

11. 1;11 c3? Tar 3; q i

(Cicsed) Unr:sclved Item (S2.23-05): gA Audits - Formal .udits have bon cw:'uct:d by TOSCO r-cr rding the construce.icn turnover cre pletion Etivities. The NRC inspecter revicwed the follcwing audit reports: .

TCP"CC fuel ?uildirg, Acust 15-26, 1983 1CP-GS f uxiliary and S.ticct ards Cuilding, Cc ' : t e r 31 - lbve. .b e r 15, 1033 l

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i EM h A 1CP-95 fio. 1 Diesel Generator Building, - - r* *2 February 20-24 and ichruary 27-!! arch 2, 1984

{ . . .. . . .

i 1CP-103 Auxiliary Building,!*ay 29 and April 24-I*ay 4, 1984 The audit reports indicate satisfactory impicmentation of the room turnover process. Additional audits have been scheduled. This item is considered closed. '

32. Smmar_y_of Inspection Results This special inspection identified two violations. Only violation 445/0416-01 (cable tray hanger inspection) pertains to the con:truction ccmpletion and roem/ area inspection of the Unit 1 reactor containment pf" building. -

Based en nucber of inspector-hours and the sccp'e and results of this inspection, the liRC inspectors have concluded that the building

, manager concept and the rocm/ area construction ccmpletion program are p' providing adequate centrols fcr the completion of the Unit 1 reactor contair.mant building.

The two violettens identified in this report will be felic'.ted up durir.g a s:.:becquent inspection to ensure appropriata and tinaly corrective action.

13. tur .i n t.c rv i u On June 20, 1024, the l:RC ins;t.ctor and other ...r .5crs of the Region IV staff, including the resident inspectors c.et with the licensee representa-tives as dcccted in par: graph 1 of this repert. The NRC inspector discussed the findings of this report includ'ng the two violations. The licensee representative acknowledged the viclations.

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445 and O[,,

COMPANY, et al. ) 50-446

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(Comanche Peak Steam Electric ) (Application for Statien, Units 1 and 2) ) Operating Licenses)

APPLICANTS' SUPPLEMENT TO MOTICN FOR AUTF.ORIZATION PURSUANT TO 10 C.F.R. 4 50.57(c)

On August 7,'1984, Texas Utilities Electric Ccmpany, et al.

(" Applicants") filed a motion with the Atomic Safety and Licensing Board .C' Licensing Board") requesting that it authorize the NRC Staff to permit Applicants to load fuel and conduct certap.n precritical tests. By Memorandum of August 24, 1984, the Licensing Board requested additional information regarding (1)

QA/CC oversight of contested systems, (2) the status of procedures for the requested activities , (3) calculations of Ke.. ,, and (4) boren concentrations. Applicants response is set forth below and in the attached af fidavits of Antonio Vega, concerning CA/QC oversight, ("Vega Aff3 davit") (Attachment 1); Cavid E. Deviney, concerning complation of procedures, ("Deviney Affidavit")

(Attachment 2); and Edward Alarcon, concerning K e.. ,, and boron,

("Alare:n Affidavit") (Attachment 3).

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4 OA/OC Oversight The Licensing Board requested additional information concerning the adequacy of CA/OC oversight activities on systems that may be called upon to function to protect public health and safety during fuel loading and precritical testing. The Board stated that at least four systems were included in this category, .

3 i.e., (1) boron addition and monitoring equipment, (2) reactor monitoring equipment, (3) fuel leading equipment, and (4) reactor

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protection systems. Specifically, the Board requested " evidence concerning the current status of CA/QC oversight of these systems, i

including evidence that documentation is adequate to assure that unsatisfactory or non-conforming conditions have been corrected and evidence concerning whether or not there are allegations known to the Applicants or Staff about the intimidation of QA/QC personnel who were working on these systems." Licensing Board's "Memorandem (Request for Evidence Relevant to Fuel Loading)"

(August 24, 1984) at 2.

In response to Che Board's request, an evaluation of all plant systems was conducted to determine the . systems that fell into the category specified by the Ecard, as noted above. Ten systems / equipment groupings were~ identified and are listed in

Attachment B to Vega's Affidavit. (See also Alarcon Affidavit at 9-10.) With regard to these systems, a thorough review was conducted of the status of CA/CC oversight to determine if all required inspections had been conducted and verified, as e e

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applicable. This review reflected that QC inspections have been performed on the necessary nachanical, c-lectrical and instrumentation components of th se systens. These inspections f

included in-process inspections, final inspections, as-built verification inspecticns, and Authorized Nuclear Inspector (ANI) inspections, as applicable. Vega Affidsvit at 2.

In addition, an extensive testing p cgram on these systems has been implemented *and will be.ccmple'.ed prior to fuel load, ,

including, as applicable, hydrostatic tests gn pressure retaining systems, prerequisite testing on components to assure proper component functional operability and pre-operational testing to assure proper operation as a system. Precperational testing

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provi[cs assurance that the systems in question will cperate as designed by requiring demonstration of the cacability of_the systems to meet safety-related performance requirements. Vega Affidavit at 3. A summary of the preoperational testing condu .ed for each of the systems in question is set forth in Attachment C to Vega's Affidavit. -

Conditions found to be unsatisfactcry or non-cenforming as a

/ result of the above QA/CC oversight activities have been

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e- dccumented,'.- m w on Non-Conformance Reports, Inspecticn as~ appropriate, W .>

Reports, Test Deficiency Reports or in other prescribed manne.

These methods of documentation assure positive control and ,

tracking of such conditions to preclude inadvertent use of defective materials, components or systems. These unsatisfactory

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or non-conforming items are included in a tracking system which is developed and administered by the TUGCO Start-up organization to assure outstanding items are properly prioritized, assigned and reso1ved in a timely manner. Vega Affidavit at 3.

The Startup Tracking System was reviewed to assess the status

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of ite=s identified as unsatisfactory or non-conforming through the QA/QC oversight of construction and testing activities on the ten systems identified in Attachment B. The review reflected that all such outstanding items are scheduled to be completed prior to fuel load. Vega Affidavit at 3-4.

t In conclusion, based on a thorough review of the QA/QC oversight status of the ten systems / equipment groupings in question, there is a reasonable assurance that with regard to these systems / equipment groupings in- questic: necessary and appropriate QA/QC activities have been conducted, and non-conformances identified by such activities wi: be corrected on a -

schedule to support fuel load and precritical testing activities' in a manner consistent with the health and safety of the public.

Vega Affidavit at 4.

To respond to the Board's second question regarding the status of CA/QC oversight (i.e., "whether or not there are allegations known to Applicants or Staff abo, intimidation of QA/QC personnel who were working on these' systems'), Mr. Vega discussed this issue with appropriate personnel in his QC organizatien, construction and QA/QC for operations, personally 1

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i. s reviewed the cuality Assurance Investigatien Files, and had cognizant individuals review allegations T.ade through the CA Hot-line and allegations transmitted to Applicants by the NRC Staff.

Mr. Vega also instructed Applicants' counsel to review the record compiled on the intimidation issue before the Board. Based upon these discussions and reviews, Mr. Vega is not aware of any specific allegations regarding intimidation of CA/CC personnel related'to any of the ten systems discussad above. Vega Affidavi at 4-5. .

_ ,- Comcletion of CA/CC Procedures The Licensing Board requested evidence "that appropriate CA/QC procedures have been completed for all phases of the activiYles for which a license is sought . . . .

Licensing Board Memorandum at 2.

In response to the Board's request, n review of the status of the procedures to be used for te requested activities was conducted. This review indicates that all such procedores have been prepared, reviewed and are either approved or in the process of being approved; all will be approved and available for use prior to fuel load. Deviney Affidavit at 1. The basic procedures to be used for these activities are the 21 initial startup procedures ("ISU") for fuel 1 . ding and precritical testing listed in Attachment B to the Deviney Affidavit. See also Alarcon Affidavit at 9-10. All but two of these procedures have received final approval. These two procedures, ISU-COSA, Thermal e

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- 6-Expansi'on, and.ISU-009A, Simulated Rod Control System Test, have been prepared and are undergoing final review. They will l:e approved well before fuel load. Deviney Affidavit at 2.

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Other routine. plant procedures may be referenced in or

, provide support for.the ISU procedures and associated activities including System Operatien Procedures, Nuclear Engineering Procedures and Maintenance and Surveillance Procedures. In addition, CC inspection, CA surveillance and QA audit procedures will be used to provide independent and additional assurance that plant activities incl.uding those . related .directly to fuel loading and precritical testing,are properly conducted and documented. .

These additional coordinating / oversight pro 5edures have also been ecmpleted, reviewed and approved and are currently in service.

Deviney Affi avit at 2. '

In conclusion, based'on h complete and thorough review, virtually all 2A/QC procedures relating to fuel load and precritical testing are currently available for use. The remaining few are in the approval cycle and will_be available in time to support fuel load and precritical testi.kg activities.

Calculations Regardince K ..

a:: 3 The Lic nsing Board requested " evidence ~'conceEning the m  ;

maximum K,ff :o be permitted during precritical.tecting and the l K,ff that analysis suggests may be achieved during precritical testing if all control rods were inadvertently removed while the'

,. g : o boron concentration was 2000 ppm . . , . .

Board [Stemorandum at 2.

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The maximum Ke. ,, permitted during precritical testinc is established by Technical Specifications as . 990 during cold shutdown (coolant temperature less than or equal to 200 F) and

.984 at elevated temperatures (greater than 200 F). (It should be noted that as the coolant temperature increases, K,gg decreases.)

Reactivity control requirements during refueline are based on boron concentration. Specifically, in accordance with Technical Specific $ations, the boron concentration must be maintained sufficient to assure that the more restrictive of the following reactivity condition is met: (1) K ,,of .950 or less, or (2) e..

boron concentration of greater than or equal to 2000 ppm. For the initial fuel loading at CPSES, the limit of'2000 ppm boron concen'tration is the more restrictive limit and provides substantial conservatism. Alarcon Affidavit at 2-3.

Using conservative assumptions, the maxi.h.um K,ff expected during precritical testing (either hot or cold) was calculated to be .894. The conditions associated with this calculation are a boron concentration of 2000 ppm, a coolant temperature of 68 F and the most reactive centrol rod bank withdrawn. Alarcon Affidavit at 2-3.

In respohse to the Board's second questien regarding the K,gg.

which may be achieved assuming a 2000 ppm boron concentration and all control rods fully withdrawn, Applicants submit that the likelihood of all control rods being simultaneously withdrawn is virtually nonexistent. In any event, even if all control rods l

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Indeed, conservative calculations reflect that assuming a coolan:

temperature of 68 F and all control rods fully withdrawn, th e' boron concentration could drop to belcw 1390 ppm and K,gg would still be below .990. Alarcon Affidavit 3-4.

Maintaininc Boron Concentration .

The Licensing Board requested evidence "that non-borated water will never be injected into the core, substantially diluting the boron below 2000 ppm" (Scard Memorandum at 2).

Makeup water to'the Reactor Coolant System ("RCS") is provided either from the Chemical and Volume Centrol System

("CVCS") or from the Refueling Water Storage Tank ("RWST"), a large tank normally containing several hundred thousand gallons of borated water. Prior to fuel loading the CVCS and RWST, as well as the RCS are borated to at least 2000 ppm. Alarcon Affidavit at 4-5. -

Immediately prior to commencement of the fuel leading sequence, the RWST is again established and then maintained greater than or equal to 2000 ppm as required by CPSES Technical Specifications.

Also, as required by this test' procedure, the RCS is sampled and analysed for boron concentration at several places to assure uniformity of the 2000 ppm minimum boron concentratien.

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9-In short, prior to fuel loading the boron co.icentration in the RCS, CVCS and RWST will be at least 2000 ppm. Alarcon Affidavit at 5.

The only credible cause of an inadvertent boron dilution would involve the higly unlikely malfunction of ecuipment in the CVCS.1 Administrative and procedural controls have been established effectively to preclude inadvertent injecting of unborated CVCS makeup water into the RCS due to operator error.,

For example, operation of the CVCS is perfo'rmed under the directicn of trained and licensed reactor operators in accordance with procedures which are step-by-step in nature. (With regard to fuel loading, in that the critical valves between the CVCS and RCS are closed and secured in that position, it is virtually impossible for an accidental dilution event to be initiated.)

blarcon Affidavit at 8.

In any event, assuming that such a highly unlikely event wa initiated, numerous manual and automatic actions would assure that the dilution would be detected and mitigated' prior to exceeding a K,ff of 0.990. First, every four hours during refueling and every eight hcurs during precritical testing, samples of the reactor coolant system are taken and analyzed by a chemistry techniciar The results of the analysis are transmitted to the control roor for review by the operators and ISU test engineer on duty. They 1

The CPSES Final Safety Analysis Report Section 15.4.6 addresses the causes and automatic actions associated with an inadvertent boron dilution event. ..

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compare the results of the analysis with the boron cencentration that should be in the system. If there is a discrepar,cy, or if the concentration is below 2000 ppm, all activities which could add positive reactivity are halted and boron concentration is

, restored to at least 2000 ppm. Alarcon Affidavit at 8-9.

In addition, source range monitoring instrumentation in the continuously manned control room has both audio and visual indications of neutr6n flux levels in the core. The audio .

indication is in the form of continuous " clicks" (such as a typical radiation detector) which increase or decrease in frequency based on neutron flux changes in the reactor core. Any, significant change in' boron concentration in the reactor coolant system would result in a substantial and very noticeable change in the clicking" frequency. Further, source range neutron instrumentation level indication is continuously logged on strip chart recorders in the Control Room, so that the ;perator may detect trends, such as changes in source range levels due to boron dilution. Any significant change in boron concentration would again be noticeable. Alarcon Affidavit at 8-9.

In addition, in the virtually impossible event that a dilution- event occurs, is not detected by the periedic sampling, and the controi room operators fail to notice t; increased clicking or increase in neutron flux shown en the strip chart recorders, a safety-related, redundant flux doubling detection system has been provided. If the source range nuclear e

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6 instrumentation detects a doubling of the neu' tron flux in any continuous approximate 10 minute period, an alarm is sounded for the operator and valve movement to terminate the dilution and start boration is automatically initiated. No immediate operator action is required. These automatic actions are carried out to stop any approach to criticality and regain any lost shutdown margin. Alarcon Affidavit at 9.

In conclusion, b'ased on the. foregoing, during fuel loading, and precritical testing, it is a virtual impossibility for a boron dilution event to be initiated and continue until a Ke..

,, of .990 is exceeded. Alarcon Affidavit at 9.

Respec fu y aubmitted, b I mb ,

Nichola, S .! )Reynold s Ma 2o1 M.Iqhilips, Jr.

BI.iOPk LIBr*RMAN , CODK, PURC L '

REYNOLDS 1200 Seventeenth Street, N.W.

Washington, D. C. 20036 (202)857-9817

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Counsel for Applicants September 13, 1984

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' UNITED STATES OF AMERICA *2 i Mp 7 g c. 3 .-

NUCLEAR REGULATORY COMMISSION ~*

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

. TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445-2 and COMPANY, et al. - ) 50-446-2

)

(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)

AFFIDAVIT OF ANTONIO VEGA CONCERNING BOARD OUESTIONS REGARDING OA/CC OVERSIGHT My name is Antonio Vega. My business address is Comanche Peak Steam Electric Station ("CPSES"), P. O. Box 1002, Glen Rose, Texas 76043. I am the Site QA Manager for the design, construction anf startup testing of CPSES. In that capacity, I am responsible for establishing and directing a Quality Assurance /

Quality Control rogram on safety-related activatics to assure that the plant is safe, reliable and in compliance with regulatory requirements. A 'tatement s of my educational and professional qualifications is attached to the affidavit (Attachment A).

The purpose of this Affidavit is to respond to the Licensing Ecard's request for additional information concerning the status of CA/CC oversi St activities on systems that may be called upon to function dur ;g fuel loading and precritical testing to protect public health and saf ety. The Board stated that at least four systems were included in this category, i.e., (1) baron additien and monitoring ecuipment, (2) reactor monitoring equipment, (3)

-s40%-7-case 840913 PDR ADOCK 05000445 G PDR -

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fuel loading equipment, and (41 reactor protection systems.

S,oecifically, the Board requested " evidence concerning the current status of CA/CC oversight of these systems, including evidence that documentation is adequate to assure that unsatisfactory or non-conforming conditions have been corrected and evidence concerning whether or not there are allegations known to the applicants or Staff about the intimidation of QA/QC personnel who were working on these systems." Licensing Board's "

Memorandum (Request fer Evidence Relevant to Fuel Loa ~ ding)" (August 24, 1984) at p. 2.

In 'response to the Board's request, an evaluation of all plant systems was conducted.to determine the systems that fell into th'e category specified by the Board, as noted above. Ten systems / equipment groupings were identified. These systems are listed in Attachment B. With regard to these systems, a thorough eview was conducted to determine if all required inspections had been conducted and verified, as applicable. This review reflected that CC inspections have been performed and documented on the necessary =echanical, electrical and instrumentation conponents of these systems. These inspections include in-process inspections, final inspections- as-built verification inspections, and

uthorized Nuclear Inspector (ANI) inspections, as applicable.

Continuing reinspections will be made as appropriate to preserve the integrity of completed inspections.

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In addition, an extensive testing program on these systems has been implemented and will be completed prior to fuel load, including, as applicable, hydrostatic tests on pressure retaining systems, prerequisite testing on ecmponents to assure proper component functional operability, and preoperational testing to assure proper operation as a system. Preoperational testing provides assurance.that the systems in question will operate as designed by requiring demonstration testing of the capability of the systems to meet safety-related performance requirements. A summary of the preoperational testing for each of the ten systems in question is set forth in Attachment C.

Conditions found to be unsatisfactory or non-conforming as a result of the'above QA/QC oversight activities have been 7

documented, as appropriate, on Non-c'onformance Reports, Inspecticn s

Reports, Tes't-Daficiency-Reports or in other prescribed manners.

These methods of documentation assure positive control and tracking of such . conditions to preclude inadvertent use of defective materials, components or systems. 3hese unsatisfactory or non-conforming items are included in a computerized tracking system which is developed and administe. red by the TUGCo Startup organitation to assure outstanding items are prcperly prioritized, assigned, and resolved in a timely manner.

The Startup tracking system was reviewed to assess the status of items, identified as unsatisfactory or non-conforming through j CA/CC inspecticns or surveillaneds of construction and testing 6

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activities, on the ten systems identified in Attachment B. The review reflected that all such outstanding items are scheduled to be completed prior to fuel load.

In conclusion, based on the ' thorough review of QA/QC

- oversight status described above for the affected systems, I have determined that necessary and appropriate QA/QC activities have been conducted and that ncn-conforming conditions are identified and tracked, as applicable, and are scheduled to be resolved prior ,

to fuel load. Our evaluation reflects that outstanding items will be completed on a schedule to support fuel load and precritical testing activities in a manner which assures the health and safety j of the public.

I" turn now to the Board's second question regarding the status of QA/QC oversight (i.e., whether or not there are allegations about intimidation of QA/QC personnel who were working on these systems). I have discussed this issue with appropriate personnel in my QC organization, construc- ,

tion and QA/QC for operations. I also have personally reviewed the Quality Assurance Investigation Files, and have had cognizant individuals review allegations made through the QA Het-Aine and transmitted to us by the NRC Staff. I also instructed our counsel to review the record compiled on the O

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intimidation issue before the Board. Based on these discussions and reviews, I am not aware of any specific allegation about intimidation of'OA/QC personnel related to any of the systems set forth in Attachment B.

A -

~ ' Antonio Vega NS

(/

County of ./efm h )

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State of Texas )

Subscribed and sworn to befor.e me this May of September, '984.

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Notary Publ .of OS 1

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ATTACEMENT A ANTONIO VEGA; P.E.

STATEMF.NT OF EDUCATIONAL A2O PROFESSICNAL EXPERIENCE POSITION: TUGCo Site Quality Assurance Manager FORMAL EDUCATION: 1961-1967, 3.S. Electrical Engineering, University of Texas EX?ERIENCE:

03/16/34-Present Texas U:ilities Generating Cc:pany (TUGCo), Co=anche Peak S.E.S., Glen Rose, Texas, as TUGCo Site QA Manager. Z11s includes responsibility for establis,hing and directing site QA/QC activities on safety-related ce=ponents and syste s to ensure CPSIS is constructed as a safe, reliable plant, in full cc=pliance with all applicable requiremen:s.

1977-03/15/34 Texas Utilities Generating Ccepany (TUGCc), Dallas, Texas, as Quality Assurance Services Super'.isor, Quality Asaurance Division. Activities include progra: and procedure development, and independent ec=pliance evaluation via surveillance and audit of :afety-related activities perfor=ed by TUGCo, Texas Utilities Services Incorporated (TUSI), the Architect Engineer, the Constructor and safety-related equip =en:

. suppliers.

1973-1977 Texas Utilities Services Ir orpora:ed Dallas, Texas, as quality Assurance Senior Engineer, quality Assurance Division. Activities included involvement in developing the QA progra=, procedures, instructions, and conducting audies' and inspections en TUSI, the Architect Engineer, the Cons uctor, and safety-related equipmen:

suppliers.

1970-1973 Dallas Power & Light Co:pany, Dallas, Texas, Power Plant Design Engineer, Power Plant Divisien, Engineering Department. Activities included conceptual and detail design of power plant pcuer and distribution syste s, protection sys:e=s and ce==unication systens.

Perfor=ed and related constructicn inspecticns.

1967-1970 Dallas ?cuer & Light Ccepany, Dallas, Texas, as Syste: Protec:1cn and Centrels Engineer, System Protection Secti:n, Substation and Trans':is'sien Divisien, Eng'neering Depart:ent. Activities included conceptual and detail desig Of substation, transmission, and switchyard facilities, incl ing pever systems and cc =unicatien systems. Perfor=ed related .cnstructicn inspections.

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ATTACEMEST E SYSTEMS INVOLVING CONTESTED ACTIVITIES 3oren Addition and Monitoring

1. Process Sa:pling System
2. Chemical and Volu=e Control System and

. Refueling Water Storage Tank

3. Reactor Coolant Systen
4. Residual Heat Re= oval Reactor Menitoring -
1. Nuclear Instrucentation t t@r Fuel Loading Equipment
1. Fuel Handling and Vessel Servicing Equipnent
2. Cranes and Hoists Reactor Protection Syste=
1. Reacto: Protection System
2. Analog Control Systec
3. Rod Control Equipment t

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. Pags 1 PREOPERATICNAL TEST SLNS). RIES i .

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! A. PROCESS SAM? LING SYSTEM i

This test de=onstrated the capability of the Process Sa=ple Syste= to provide liquid and gas sa=ples frc= designated syste= sa:ple locatiens, including the Reactor Ccolant Syste=. The test also de=enstrated the prcper operation of the Process Sa:ple Syste= isolation valves, including response to engineered. safety signals within the required ti=e. ,

B. CHEMICAL AND VOLUF:. CONTROL SYSTEM This testing de=enstrated the proper cperational capabilities of all of the various portions ei the Che=1 cal and Volu=e Control Syste=, including 4

let[own, charging, and seal water injection to..=aintain the charging and letdcun flows, the seal water inj ection flow to the Reactor Coolant pu=ps and to provide de inerali:er and filter cleaning of letdevn water, che=ical control, purification, and =akeup of tne Reactor Coolant System, and boren ther=al regeneration 'for boron concentration control of the Reactor Ccelant Syste=,

Alternate flev paths for charging and =iniflow, respense to safety injection signals, e=ergency beration, and redundancy of the beration dilution wete also de=enstrated. Testing also de=enstrated the proper operation cf the Boron Dilution Protection Syste=s to =itigate an inadvertent dilution of the Reactor Coolant Syste=,

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. Pega 2 C. RE.2.CTOR COOLANT SYSTEM .

The testing perfor=ed on the Reactor Coolant Syste: verified the piping syste= integrity and co=ponent ability to function properly at various plant conditions extending frc= static a=bient cenditions to nor=al plant operating te=peratures and pressures. The testing included a syste:

hydrostatic test, safety and relief valve operation and leakage verification, reae:or co'clant pu=p control circuit operability, pressurizer heater and spray valve operation, pressurizer pressure and level centrol systes operabili:y, a'nd integrated plant het functional test, cnd

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=easure=ent of thermal expansion of various systens at nor=al plant 3 operating te=peratures.

J. RESIDUAL EEAT REMOVAL CYSTEM The testing on the Residual Heat Re= oval Syste= de=enstrated cc=penen:

control and interlock functions, including response to engineered safety actuation signals, pu=p hydraulic perfor=ance and syste= hydraulic perfor ance during the heatup and cooldown periods of the Hot Functional Testing.

E. NUCLEAR INSTR"MENTATICN This testing verified tha: the Nuclear Instru=enta:1en Syste= is capable of providing indication of signals, including appropria:c pcwer levels, generating trip functions when trip func: ions are bypassed, blocked, or other than nor=al. Included in the testing on the syste= was verification of the Flux Doubling Circuitry which is an integral part of the 3eren Dilution Protection System.

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Attach =2nt C

,- . Page 3 F. FUEL 'i.ANDLING AND VESSEL SEIVICING EOUIPME';T This testing de=enstrated the proper operation ef hil equip:ent used in fuel handling, access to fuel storage and core loca:1ces, and equipment used to service the reactor vessel, including lif ting of the recctor vessel e

head, reactor vessel internals, stud tensioners and tensicner hoists.

G. FUEL EANDLING EOUIFMD;T CRANES AND E01STS This testing de=enstrated the proper cperation of the cranes used in fuel movecent.

These tests include control and inte:1cck functions, speed and, travel cove =ents and the required load testing. '

E. REACTOR PROTECTION SYSTEM The testing of the Reactor ?:otection System deponstrated the ability of the 'systc= logic to respond properly to varicua plant parameters and previde the correct engineered safety actuatien signal, th4: the engineered safety feature co=ponen:c are directly actuated or sequenced, the prepar operation of the Turbine Runback Controls, the required engineering safety features response ti=c, and that the Technical Specifica:1on

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instrumentation setpoints are properly adjusted. '

I. ANALCG CONTE 0L SYSTD' .

There is no specific test for the Analog Control Systen. The c::penents within the Analog Control Syste: vere tested vi:hin the scope of the specific system preoperational tests.

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J . ROD CONTROL SYSTEM , ,

There is no preoperational test specified for the F.od Centrol System -

because the systen cannot be tested effectively in operational conditiens until fuel is leaded. This system will be tested post-fuel load under the Initial Startup Program.

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