ML20206E812
| ML20206E812 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/01/1987 |
| From: | Barnes I, Ellershaw L, Hale C, Spessard R, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20206E792 | List: |
| References | |
| 50-445-86-26, 50-446-86-22, NUDOCS 8704130746 | |
| Download: ML20206E812 (43) | |
See also: IR 05000445/1986026
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APPENDIX C
COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-445/86-26 Permits: CPPR-126
50-446/86-22 CPPR-127
Dockets: 50-445 Category: A2
50-446
Construction Permit
Expiration Dates:
Unit 1: August 1, 1988
Unit 2: August 1, 1987
Applicant: Texas Utilities Electric Company
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas 75201
Facility Name: Comanche Peak Steam Electric Station (CPSES),
Units 1 & 2
Inspection At: Glen Rose, Texas
Inspection Conducte September 1 through October 31, 1986
Inspectors: UO
LI E. Ellershaw, Reactor Inspector, Region IV (Tate
CPSES Group
(paragraphs 2.b, 2.1, 3.c, 4.a-k, 5.c, and 6)
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C. J. Halg4 Reactor Inspector, Region IV Date
CPSES Group
(paragraphs 2.y, 3.a-b, 3.d-e, and 5.a)
9. C bMA
P. C. Wagner, ReactorjInspector, Region IV
Jlsi /67
Date
CPSES Group
(paragraphs 2.a-x, 2.z-al, and 5.a-b)
8704130746 870402 5
DR ADOCK 0500
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Consultants: EG&G - J. Dale (paragraphs 2.b, 4.j, 4.k and 5.c)
A. Maughan (paragraphs 2.a-x, 2.z-al, and 5.a)
W. Richins (paragraphs 2.b, 3.c, 4.a-c, and 5.a)
V. Wenczel (paragraph 5.a)
Parameter - J. Birmingham (paragraphs 2.y, 3.a-b, and 3.d-e)
K. Graham (paragraphs 2.b, 2.1, 4.e-f, 4.h-1,
dnd 6)
D. Jew (paragraphs 2.1, 4.d, 4.g 5.a. and 6)
Reviewed By: .
rtd e 87 7
R. L. Spessard,'p/puty Director, Division -
Date
of Inspection Programs, Office of
Inspection and Enforcement
Approved: W N/M7
1. Barnes, Chief, Region IV CPSES Group Date
Inspection Summary
Inspection Conducted September 1 through October 31, 1986 (Report 50-445/86-26;
50-446/86-22)
Areas Inspected: Nonroutine, unannounced inspection of applicant actions on
previous inspection findings, Comanche Peak Response Team (CPRT) Issue-Specific
Action Plans (ISAPs), and assessment of allegations.
Results: Within the three areas inspected, four violations (cable pulling
ropes were left in Unit I conduits and cable trays, paragraph 2.h; a log
documenting potentially nonconforming items was discarded without the items
being dispositioned, paragraph 5.a; potentially nonconforming items being
documented on request for inspection forms are not being effectively tracked or
accounted
improperlyfor, paragraph
certified, 5.a; and4.k.)
paragraph Bahnson Service
and five Company
deviations t {an EvaluationBSC) welders w
Research Corporation (ERC) inspector failed to write an out-of-scope memorandum
documenting a potentially nonconforming condition, paragraph 2.h; ERC's craft
training procedure review failed to identify the lack of a BSC personnel
retraining requirement and thus did not recommend procedure improvement,
paragraph 3.b; substantive changes to an ISAP were made and implemented prior
to approval by the Senior Review Team, paragraph 3 b; ERC engineering failed to
identify all the HVAC activities and attributes to be included in review and
inspection checklists, paragraph 4.j; and ERC inspections in the HVAC area were
based on documents different than those used for the inspection of record,
paragraph 4.k) were identified.
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DETAILS
1. Persons Contacted
S. Ali, Engineering Assurance Systems Manager, Texas Utilities
Generating Company (TUGCo) Nuclear Engineering (TNE)
J. Audas, Senior Licensing Engineer, TUGCo
- R. P. Baker, Regulatory Compliance Manager, TUGCo-
- J. L. Barker, Engineering Assurance Manager, TUGCo
- C. T. Brandt, Quality Engineering (QE) Supervisor, TUGCo
- T. Braudt, Senior Engineer, TUGCo
- R. E. Camp, Project Manager, Unit 1, TUGCo
- R. Deatherage, Director, Engineering Administration, TUGCo
. J. V. Everett, Project Manager, Impell Corporation
- P. E. Halstead, Site Quality Control (QC) Manager, TUGCo
- J. Hicks, Licensing Engineer, TUGCo
R. Hooton, Civil / Structural Engineering Manager, TNE
R. Iotti, Project General Manager, EBASCO
M. Keathley, Lead Electrical QC Inspector, Evaluation Research
Corporation (ERC)
- J. Krechting, Director of Engineering, TUGCo
J. C. Kuykendall, Vice President, TUGCo
- D. McAfee, Manager, Quality Assurance (QA), TUGCo
J. Ma11anda, Electrical Review Team Leader, CPRT
S. Martinovich, Principal Engineer, Gibbs & Hill
- J. T. Merritt, Jr. , Assistant Project General Manager, TUGCo
C. K. Moehlman, Project Mechanical Engineer, TUGCo
- L. D. Nace, Vice President, TUGCo
E. Odar, Project Engineering Manager, EBASCO
A. A. Patterson, Reinspection Engineering Supervisor, ERC
F. L. Powers, Assistant Unit 1 Project Manager, TUGCo
P. Passalugo, Equipment Qualification Engineer, Impell
- D. M. Reynerson, Project Manager, Unit 2, TUGCo
B. Shair, Lead Electrical Engineer, ERC
R. Shetty, Engineering Supervisor, EBASCO
- M. R. Steelman, CPRT, TUGCo
P. Stevens, Electrical Engineer Manager, THE
- J. F. Streetar, Director, QA, TUGCo
M. Strehlow, Conduit Engineering-Field Program Manager, EBASC0
T. G. Tyler, CPRT Program Director, TUGCo
The NRC inspectors also interviewed other CPRT and applicant employees
during this inspection period.
- Denote:, personnel present at the October 9,1986, exit interview.
- Denotes personnel present at the November 12, 1986, exit interview.
- Denotes personnel present at both of the above exit interviews.
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2. Applicant Actions on Previous Inspection Findings
a. (Closed) Unresolved Item (445/8511-U-01): Unclear requirements in
EC Quality Instructions (QIs). Tnis item dealt with the lack of
clarity with respect to inspection requirements contained in two QIs.
QI-008 contained unclear requirements with respect to channel
separation, fire stops and seals, and certain attachment criteria.
QI-014 contained unclear instructions regarding inspection of cables
that were not accessible for their full length.
The unclear requirements and instructions were suitably resolved with
the issuance of Revision 2 of QI-008 on September 9, 1985, and
Revision 1 of QI-014 on February 19, 1986, respectively.
In addition, the NRC inspectors reviewed the 73 other QIs that had
been issued as of September 30, 1976, for clarity of instructions and
requirements. No other similar concerns were identified; therefore,
this item is closed.
However, it should be noted that an unresolved item (445/8622-U-15;
446/8620-U-06) pertaining to instructions not being provided in
QI-070 for weld size inspection when the edge of tubing fittings had
either been consumed by welding or subjected to grinding, has been
identified in NRC Inspection Report 50-445/86-22; 50-446/86-20.
b. (Closed) Deviation (445/8513-D-02): Verification package
preparation. This item pertained to incomplete and incorrect
preparation of verification packages by ERC population engineers. In
response to this deviation, the applicant proposed the following
corrective actions: (1) retrain the population engineers in package
preparation per Comanche Peak Project Procedure (CPP)-008
requirements, (2) review and revise as needed all QIs used for
ISAPs VII.c and VII.b.3, (3) perform a reinspection of a sample of
verification packages which were complete, (4) form an overview
(surveillance) inspection group to perform independent inspections of
a sample of completed inspection packages to assess past and future
inspector performance, and (5) form an engineering assurance group to
review completed verification packages and verify that they are
properly prepared. The NRC inspector verified the above proposed
corrective actions have been implemented by a review of:
(1) Corrective Action Report (CAR)-016, (2) appropriate procedures,
(3) overview inspection log books and a sample of inspection
packages, and (4) organization records.
c. (Closed) Open Item (445/8513-0-24): Loose conduit fittings. Further
NRC inspector review of the loose conduit fittings discovered by ERC
inspection of Verification Package I-E-CDUT-044 showed that
nonconformance report (NCR) E85-101342 had been dispositioned to
tighten the connections. The NRC inspector verified that this work
had been accomplished.
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d. (Closed) Open Item (445/8513-0-26): Missing plug and loose. retaining
screw. Further NRC inspector review of the out-of-scope conditions
found by ERC inspection of Verification Package I-E-CDUT-027 showed
NCR E85-101439 had been dispositioned and closed. The disposition
stated that the plug was properly installed (it was difficult to see
without close inspection) and that the retaining screw was stripped
and needed to be replaced. The NRC inspector verified.the existence
of the plug and that the screw had been replaced.
e. (Closed) Open Item (445/8513-0-33): ERC identified missing
identification tags. Further review by the NRC inspector of this
item found that the NCR number in NRC Inspection Report 50-445/8601;
50-446/8601, Appendix E, was incorrectly stated as E85-1001289 when
it should have been E85-101289. NCR E85-101289 has been
dispositioned to require new identification tags to be fabricated and
installed on the electrical conductor seal assemblies (ECSAs). NRC
inspection verified that the NCR rework had been completed.
f. (Closed) Open Item (445/8513-0-35): ERC identified missing conduit
identification (ID) digit. Further review by the NRC inspector of
this item revealed that, in addition to NCR E85-101289 which was
written for this item, NCR E85-101440 was also written. Both of
these NCRs had been dispositioned to require ID correction and were
closed. The NRC inspector performed a reinspection and verified that
the conduit ID had been corrected.
g. (Closed) Open Item (445/8513-0-36): ERC identified illegible conduit
markings. Further NRC inspector review of this item revealed that
NCR E85-101442 had been dispositioned and closed. The NRC inspector
performed a reinspection and verified that the NCR required rework
had been completed.
h. (Closed) Open Item (445/8513-0-37): Flexible conduit fittings and
Valve 1-8875A. This ERC identified item pertained to: (1) the
flexible conduits at penetration 1E66 did not have protective sleeve
inserts installed; (2) conduit C12018896 contained a nylon pull rope;
and (3) a loose electrical attachment for Valve 1-8875A. Further
review by the NRC revealed that TUGCo reinspected the flexible
conduits and found the sleeves to be installed. On this basis,
item (1) above is closed. The loose electrical attachment was found
by NRC reinspection to be properly installed; therefore, item (3) is
closed. The rope in the conduit was identified by both the ERC
inspector and the NRC inspector witnessing this reinspection as an
out-of scope deficiency. Follow-up by the NRC inspector found that
the ERC inspector had failed to document this out-of-scope deficiency
as required by Procedure CPP-020. Item (2) is closed; however, the
failure by ERC to document this deficiency is a deviation
(445/8626-0-01).
Further review and inspection by the NRC inspector during this report
period found that conduit C12018896 still contained the pull rope.
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In addition, during a tour of the 832' level of the auxiliary
building on September 11, 1986, the NRC inspector observed a pull
rope in safety-related Train A, cable tray T130ACG57. This cable
tray had the thermolag covering removed for hanger inspections. The
TUGCo post construction inspection Procedure QI-QP-11.3-40 required
the inspector to verify that all cable pulling aids had been removed
from the raceway. For both of these raceways, a post construction
inspection had been performed. The failure of the project inspectors
to identify that the ropes had not been removed is a violation
(445/8626-V-02).
The applicant issued NCR E86-103883 for the rope in the conduit on
September 4,1986, and NCR E86-103981 for the rope in the cable tray
on September 12, 1986.
i. (0 pen) Violation (445/8513-V-01): Incomplete and missing conduit
ids. This item pertained to through-the wall conduit sleeves (TWS)
and through-the-floor conduit sleeves (TFS) which were marked with
incorrect identification numbers or had no identification markings
applied. In response to this violation, the applicant proposed the
following corrective actions: (1) correct the identification marking
for the sleeves identified in the Notice of Violation (N0V) as having
incorrect or incomplete identification; (2) perform walkdowns of all
power and nonpower TWS and TFS; (3) perform a review and comparison
between the requirements in Specification ES-100, Drawing
2323-El-1701, design change authorization (DCA)-21,464, and
installation and inspection procedures for TWS and TFS; (4) train
personnel to procedure and drawing requirements; and (5) perform
surveillance inspections to assess effectiveness of training.
The NRC inspector performed a reinspection for action (1) and
verified the sleeve identifications had been corrected. The NRC
inspector review verified that ES-100 and Drawing 2323-El-1701 have
been revised to reflect DCA-21,464 and that the training records
indicated that involved personnel have been trained to the revised
procedures; therefore, actions (3) and (4) are complete. This item
remains open pending the applicants completion of actions (2)
and (5).
j. (Closed) Deviation (445/8514-D-02): Document & tion review of
attributes. This item pertained to the lack of inaccessible or
nonrecreatable attributes in document review procedures as required
by ISAP VII.c. In response to this deviation, the applicant proposed
the following corrective actions: (1) revise ISAP VII.c to state
that document reviews will only be used for nonrecreatable attributes
where 60 occurrences of the attribute were not accessible from the
population as a whole, and (2) inspect additional samples from the
population for those attributes which were inaccessible in preceding
inspections. These additional samples were selected until 60 samples
of each attribute had been inspected. The NRC inspector reviewed the
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ERC files and verified that ISAP VII.c had been revised and that
additional. samples were inspected for the inaccessible attributes.
k. (Closed) Deviation (445/8514-D-03): Inspector failed to follow
procedure. This item pertained to an ERC inspector who failed to
follow the. instructions in document review Procedure QI-009. In
response to this deviation, the applicant proposed to retrain the
inspector in the requirements of Procedure QI-009 and reinspect 25%
of the inspector's completed packages to evaluate his performance.
The NRC inspector reviewed the ERC training records and verification
packages and verified the proposed actions have been implemented.
1. (Closed) Deviation (445/8514-D-04): Inspectors failed to follow
procedures. This item pertained to reinspections for instrumentation
supports (INSP), large bore pipe supports (LBSR) and
instrumentation (ININ) where the ERC inspectors failed to follow
procedure instructions. In response to this deviation, the applicant
proposed the following corrective actions: (1) reinspect 25% of the
INSP and LBSR packages completed by the two identified ERC inspectors
and evaluate the results of these reinspections; (2) revise QI-012 to
allow inspectors to indicate inaccessible bends; (3) hold a general
training session for inspectors on spring nut inspections; and
(4) revise and reissue all ININ verification packages for
reinspection. The NRC inspector verified that the above actions had
been implemented through a review of a sample of ERC verification
package inspection reports (irs), procedures, and training records.
As a result of the reinspection performed for action (1), use of one
inspector was discontinued and 100% of the inspections performed by
that inspector were reinspected. _The other ERC inspector was
retrained in the applicable procedure requirements,
m. (0 pen) Open Item (445/8514-0-07): Comparison of NRC and ERC results
from document reviews for cables. Further review was performed for
five ERC cable document review packages with the following findings:
R-E-CABL-004: NCR E85-102052 had been dispositioned and closed. The
NRC inspector reviewed the NCR and verified it had been properly
dispositioned. This document review package is ccmplete and closed.
R-E-CABL-011: A comparison of ERC document review results with the
NRC results was completed with no adverse findings.
R-E-CABL-026: The two deviation reports (ors) identified with this
package have been invalidated. The NRC inspector reviewed the DRs
and verified that they had been properly dispositioned.
R-E-CABL-028: The DR identified with this package was invalidated.
The NRC inspector reviewed the DR and verified it had been properly
dispositioned.
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R-E-CABL-035: One of the two DRs written for this package was
invalidated, the other was validated. NCR E86-101208 was written for
the valid DR. The NRC inspector reviewed the invalid DR and verified
it had been properly dispositioned.
This item will remain open pending NRC review of the disposition of
the NCR for Verification Package R-E-CABL-035.
n. (Closed) Open Item (445/8514-0-08): Cable tray splice plates. This
item pertained to ERC and NRC identified conditions of unused holes
next to splice plate bolts in tray T13GDCX60 and loose splice plate
nuts in tray T13GDCS50. Further NRC inspector review and
reinspection verified that the rework for these two cable trays has
been completed.
o. (Closed) Open Item (445/8514-0-10): Document reviews for conduits.
Comparison of NRC review results to the ERC review results for six
conduit document review packages was completed. Comparison of ERC
results for Review Packages R-E-CDUT-027, R-E-COUT-044, and
R-E-CDUT-050, with the NRC results was completed with no deviations
or violations being identified. Review Packages R-E-CDUT-035,
R-E-CDUT-065, and R-E-CDUT-066, which did not originally reference
Procedure QI-QP-11.3-4, were re-reviewed by ERC using the revised
QI-009 procedure. The NRC review of these packages was completed
with no deviations or violations identified.
p. (0 pen) Open Item (445/8514-0-13): Instrument tubing slope and
location. This item pertained to the ERC identification of tubing
for pressure instrument 1-PIS-4251 not meeting the slope requirements
and the instrument not being located as shown on
Drawing 2323-M1-2613. NCRs 186-100058 (slope requirements) and
186-100699 (location requirements) have been written for these
deficiencies. This item remains open pending disposition of the
NCRs.
q. (0 pen) Open Item (445/8514-0-14): ERC identified tubing line with
reverse slope. Further review by the NRC inspector of the reverse
slope of the tubing for pressure instrument 1-PT-4520 revealed that
NCR 186-102023 had been written. This item remains open pending
disposition of the NCR.
r. (Closed) Open Item (445/8514-0-17): ERC identified damaged conduit.
Further review by the NRC inspector revealed that NCR E85-101596 had
been written, dispositioned and closed for the damaged conduit. The
disposition called for the conduit to be replaced. The NRC inspector
performed a reinspection and verified that the conduit had been
replaced.
s. (Closed) Unresolved Item (445/8514-U-16): Cable damage due to cable
grips. This item pertained to potential electrical cable damage
resulting from installation practices used for cable support grips.
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The NRC inspector reviewed the responses by the cable manufacturers
to the TUGCo request for evaluation of the CPSES installation
practices for cable grips, letters numbered VBR-19,469 and
VBR-19,470, and verified that the installation practices used by
TUGCo are in agreement with the recommended installation instructions
of the cable manufacturers.
t. (Closed) Unresolved Item (445/8514-U-18): Incomplete document
review. This item pertained to construction operation travelers that
were not reviewed by ERC as part of Verification Package
R-E-CDUT-064. Further review by the NRC inspector found that this
verification package was revised by ERC to include these construction
travelers. An NRC inspector comparison of the revised results to the
NRC results was completed with no violations or deviations being
identified.
u. (0 pen) Violation (445/8514-V-04): Inspector not certified. This
item pertained to an applicant inspector who performed inspections
while not certified to the involved procedure. In response-to this
violation, the applicant proposed the following corrective actions:
(1) issue NCR E85-101639 for this violation; (2) review 800
inspection reports completed by 163 QC inspectors that were issued in
the last 6 months; and (3) issue a weekly QC inspector certification
list to supervisors. The NRC inspector reviewed the applicant review
reports from action (2). The applicant found no other instances of
an inspector. signing an inspection report while not certified. The
NRC inspector also reviewed the weekly certification list and
verified that a sample of the inspectors were certified. This item
remains open pending disposition and closure of the NCR for
action (1),
v. (Closed) Deviation (445/8516-D-17): Incorrect cable routing. This
item pertained to an ERC inspector who failed to identify that a
cable routing did not agree with the cable and raceway schedule. In
response to this deviation, the applicant proposed the following
corrective actions: (1) discuss the deviation thoroughly with the
inspector; (2) have the overview inspection group perform a
historical review of inspections for this attribute by the inspector;
and (3) write a OR for this deficiency. The NRC inspector reviewed
the ERC records and verified that: (1) the training records indicate
that the deviation was discussed with the inspector; (2) overview
inspections had been performed; and (3) a DR for this deficiency had
been issued.
w. (Closed) Deviation (445/8516-0-18): Incomplete cable tray
configuration. This item pertained to an ERC inspector who failed to
identify a missing nut and locking device on a cable tray splice
plate. In response to this deviation, the applicant proposed the
following corrective actions: (1) discuss deviation thoroughly with
the inspector; and (2) write a DR and revise the verification package
for this deficiency. The NRC inspector verified that: (1) the
. . _ . _ . .
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deviation was discussed with the inspector; (2) DR I-E-CATY-077-DR02
had been written; and (3) Verification. Package I-E-CATY-077 had been
revised. Implementation of the overview inspection program was
i verified, as discussed in paragraph 2.b above.
3 x. (0 pen) Deviation (445/8516-D-30): Improper instrumentation
inspections. This item pertained to incorrect instrumentation
inspections by various ERC inspectors and the lack of procedure
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clarity. In response to this deviation, the applicant proposed the
following corrective actions: (1) reinspect the various items
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, identified and revise the verification packages by writing required
DRs and out-of-scope observation memos; (2) revise instrumentation
] inspection Procedure QI-012; (3) perform a 100% reinspection of ININ
packages after QI-012 had been revised; and (4) prior to fuel load of
Unit 1, TUGCo will perform a reinspection of all system valve tags.
population and QI-012 verified that the above actions have been
implemented and completed except for item (4). This item remains
,
, open pending completion of the valve tag reinspection.
! y. (Closed) Open Item (445/8516-0-19): ERC Special Evaluation Team
! actions regarding TUGCo inspector who had failed test. A review of
the certification of the TUGCo QC inspector who failed the
examination for QI-QP-11.3-29, but was certified to all QI-QP-11.3
! procedures, has been completed by ERC. NRC inspector review of the
l' ERC report on this inspector indicated that: (1) this inspector
performed no QI-QP-11.3-29 inspections after taking the test; (2) the
error in certification was discovered by TUGCo and the inspector's
certifications were revised to exclude authorization to perform
QI-QP-11.3-29 inspections; and (3) this inspector's performance will
be evaluated in the ISAP I.d.1, Phase III, program.
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z. (Closed) Open Items (445/8516-0-21 through 445/8516-0-29): Document
reviews. Comparison of the results of NRC documentation reviews to
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the results of the ERC reviews for the following nine electrical
- equipment verification packages has been completed.
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Open Item Verification Equipment l
- Package
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445/8516-0-21 R-E-EEIN-003 ECSA-1-HV-4725-1,
2, & 3
445/8516-0-22 R-E-EEIN-012 ECSA-1-HV-4172-1,
j 2, & 3
- 445/8516-0-23 R-E-EEIN-024 IE66
445/8516-0-24 R-E-EEIN-029 ECSA-1-85128
445/8516-0-25 R-E-EEIN-039 ECSA-1 ,iV-5561
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445/8516-0-26 R-E-EEIN-042 ECSA-1-8511B
445/8516-0-27 R-E-EEIN-045 1E15
445/8516-0-28 R-E-EEIN-052 ECSA-1-HV-4169
445/8516-0-29 R-E-EEIN-059 CP1-ECDPEC12
No violations or deviations were identified.
aa. (Closed) Deviation (445/8518-D-14): Inspector failed to follow
procedure. This item pertained to a reinspection for instrumentation
not being performed in accordance with instructions. In response to
this deviation, the applicant proposed the following corrective
actions: (1) write a DR and an out-of-scope observation memorandum
for the deficiencies identified by NRC inspectors, (2) revise the
verification package, and (3) perform a 100% reinspection of
instrumentation packages. The NRC inspector verified that: (1) a DR
and memorandum had been written, (2) the verification package had
been revised, and (3) a 100% reinspection of the instrumentation
packages had been completed.
ab. (Closed) Unresolved Item (445/8518-U-13): Instrumentation procedure.
This item pertained to potential tubing damage and loose gland nuts
not being addressed in ERC Procedure 01-012. Further review by the
NRC inspector revealed that the ERC procedure was based on the TUGCo
and the Brown and Root (B&R) instrumentation installation procedures.
The above two items were not included in these installation
procedures, but were included in the TUGCo pressure testing and post
construction procedures. The ERC procedure, therefore, adequately
included all of the steps needed for instrumentation tubing
installation,
ac. (0 pen) Violation (445/8518-V-01): Incorrect conduit lengths per
drawing. This item pertained to two conduits for solenoid valves
associated with valves 1-HV-4631A and 1-HV-4631B that are longer than
Drawing 2323-El-1701 requirements. In response to this violation,
the applicant proposed the following corrective actions: (1) issue
NCR E86-102718 for valves 1-HV-4631A and 1-HV-4631B; (2) perform
plant walkdowns to identify any deviations from the requirements of
Drawing 2323-El-1701, Detail 18, as part of CAR-63; (3) revise
Procedure QI-QP-11.3-28 to include instructions for Drawing
2323-E-1701, Detail 18, requirements; and (4) train QC inspectors to
the revised procedure. The NRC inspector has verified, through a
review of QI-QP-11.3-28 and training records, that actions (3)
and (4) have been implemented and are complete. This item remains
open pending completion of applicant actions required by (1)
and (2) above.
ad. (0 pen) Violation (445/8518-V-11): This item pertained to incorrect
and missing identification markings on the thermal lag installed on
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cable trays and conduits. In response to this violation, the
applicant proposed the following corrective actions: (1) issue NCRs
for the items identified in the NOV; (2) reinspect and rework as
required all thermal lag installed in Unit 1; and (3) train craft
personnel to the requirements of Procedure CP-CPM-10.3 prior to
thermal lag installation. The NRC inspector verified that NCRs
E86-103146, E86-103147, E86-103148, and E86-103149 have been issued
for action (1). This item remains open pending completion of
applicant actions.
ae. (0 pen) Violation (445/8518-V-15): Failure to perform engineering
walkdown. This item pertained to a failure by applicant engineering
organizations to perform a walkdown of instrumentation tubing
installations as required by DCA-13,023. In response to this
violation, the applicant proposed the following corrective actions:
(1) revise DCA-13,023 to prohibit instrument tubing contact with
galvanized surfaces, and (2) perform a walkdown of instrument tubing
to identify any nonconforming conditions to the revised DCA-13,023.
The NRC inspector verified that the DCA had been revised and issued,
and that an engineering walkdown will be performed as part of the
work for Significant Deficiency Analysis Report (SDAR)-8616. This
item remains open pending completion of the walkdown.
af. (Closed) Open Item (445/8601-0-15): Comparison of ERC and NRC
inspection results. This item pertained to the comparison of the NRC
inspection results with ERC inspection results for Verification
Package I-E-CDUT-111. The NRC inspector comparison of the results
has been completed with no violations or deviations being identified.
ag. (0 pen) Open Item (445/8603-0-07): Lack of tubing color coding
identified by ERC during an NRC witnessed reinspection. This item
pertained to tubing which did not have the required longitudinal
color coding. Further review by the NRC inspector revealed that DR
I-E-ININ-30R-DR01 and NCR 186-101787 have been written for this item.
This item remains open pending disposition of the NCR.
ah. (Closed) Open Item (445/8603-0-08): Flange material traceability
identified by ERC during an NRC witnessed reinspection. This item
pertained to lack of information included in the verification package
to verify flange material identification and traceability. Further
review by the NRC inspector revealed that the flange was shipped by
the vendor as part of the instrument for which traceability is
available.
,
'
al. (0 pen) Open Item (445/8603-0-09): Lack of required air gap
identified by ERC during an NRC witnessed reinspection. This item
l pertained to four air gaps around the tubing which were less than
i required. Further review by the NRC inspector revealed that DR
I-E-ININ-030R-DR02 and NCR 186-101787 have been written for this
item. This item remains open pending disposition of the NCR.
1
i
i
13
aj. (Closed) Open Item (445/8603-0-10): Flange material traceability
problem identified by ERC during an NRC witnessed reinspection. This
item pertained to lack of information included in the verification
package to verify flange material identification and traceability.
Further review by the NRC inspector revealed that the flange was
shipped by the vendor as part of the instrument and that
identification and traceability are available through the vendor.
ak. (0 pen) Open Item (445/8603-0-11): Lack of required air gap
identified by ERC during an NRC witnessed reinspection. This item
pertained to an air gap around the instrument tubing which was less
than required. Further review by the NRC inspector revealed that
DR I-E-ININ-034R-0R02 and NCR 186-101786 have been written for this
item. This item remains open pending disposition of the NCR.
al. (0 pen) Open Item (445/8603-0-12): Lack of required air gap
identified by ERC during an NRC witnessed reinspection. This item
pertained to two air gaps around instrument tubing which were less
than required. Further review by the NRC inspector revealed that
DR I-E-ININ-046R-DR01 and NCR 186-101745 have been written for this
item. This item remains open pending disposition of the NCR.
3. CPRT ISAPs (Excluding ISAP VII.c)
a. Guidelines for Administration of QC Inspector Tests (ISAP I.d.2)
During this report period, ISAP activities identified by NRC
Reference 01.d.02.04 were inspected as follows:
Qualifications of Personnel (NRC Reference 01.d.02.04)
The NRC inspector reported the qualifications of the Special
Evaluation Team in NRC Inspection Report 50-445/86-01; 50-446/86-01.
ERC has utilized additional personnel for implementation of this
ISAP. The qualifications of the additional personnel performing
evaluations were inspected and were found to meet the requirements of
the CPRT Program Plan and the specific requirements in Section 4.3 of
this ISAP. This inspection was accomplished by review of the resumes
and the objectivity questionnaires on file in the ERC personnel
files.
No violations or deviations were identified during this inspection.
Since the results report for this action plan has been issued and no
additional personnel will be assigned, NRC inspection of this
reference area is complete.
- - ._ - .-_- -- - - . - - . .-- . .- -
,
l-
,
l 14
i
i- b. Craft Personnel Training (ISAP I.d.3) [
During this report period, ISAP activities identified by NRC
Reference 01.d.03.01 and the ISAP results report were inspected as
'
follows:
I
i Procedural Review (NRC Reference 01.d.03.01)
i
- In order to assess the current BAR and BSC craft training programs,
i ERC reviewed procedures: QCI-CPSES-013. Revision 4. " Indoctrination
and Training of Personnel (BSC)"; and CP-CPM-2.2, Revision 4
j " Training of Personnel in Procedural Rcquirements (B&R)."
d
The NRC inspector determined that the ERC reviews of these procedures '
- did not meet the intent of ISAP paragraph 4.1.2 in that the ERC
- review failed to identify a deficiency in the BSC training procedure.
i The NRC inspector evaluated the training procedures of B&R and BSC ;
- against the requirements of ANSI N45.2, 1971, and the guidelines on .
{ training given by Section D of the Gray Book, " Guidance on Quality !
'
- Assurance During Design and Procurement Phase of Nuclear Power
Plants." The NRC inspector determined that the BSC training program i
(as documented in Procedure QCI-CPSES-013, Revision 4) did not ,
provide, as necessary, the suitable maintenance of craft proficiency '
,
as the craft fabrication / installation instructions were cianged. ,
j
- ERC's failure to comply with the requirements of ISAP paragraph 4.1.2 +
j isadeviation(445/8626-D-03;446/8622-D-01). ;
,
No violations or deviations were noted for the B&R proc? dure review.
,
ISAP I.d.3 Results Report
f -During this report period, the CFRT issued the I.d.3 results report.
i
i The NRC inspector determined, during review of the results report and i
i the working files, that ERC had deviated from its Procedure CPP-024, l
l " Issue Specific Action Plan Revisions" by implementing substantive
I changes to the action plan prior to obtaining Senior Review Team .
l approval. For example, the Special Evaluation Team's effort was '
i transferred to the QA/QC Review Team and the issue coordinator was
j changed (445/8626-D-04;446/8622-D-02). l
1
] c. Maintenance of Air Gap Between Concrete Structures (ISAP II.c) j
!
The following activities for ISAP II.c were reviewed by the NRC j
j inspector during this report period:
!
! Removal of Debris or Rotofoam (NRC Reference 02.c.02.00)
!
l'
During activities to break up and remove debris from the seismic air
gap, parent concrete broke free from the safeguard Unit 2 wall
i adjacent to the Unit 2 reactor building near 862' elevation. The
i
i t
! l
!
- - . - . - - _ - - . - _-
__
15
L !
, e
piece of dislodged concrete is approximately 6' in length, 1.5' in i
width, and 4". deep. The damaged and dislodged concrete was
'
L
,
discovered during inspection of the gap using,a remote video camera
l following gap cleaning nearby. This condition was not apparent in
L video recordings taken prior to the gap cleaning activities. The
!
dislodged concrete was removed and the damaged safeguard Unit 2 wall
is being assessed. NCR C-86-202323 dated September 19, 1986,
l addressed this condition.
,
The NRC inspector was notified of the damaged wall by project
l personnel approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.after the discovery and examined the
i dislodged concrete visually using remote video equipment. The NRC ,
inspector also examined video tapes taken prior to the gap cleaning l
activities as well. as the dislodged concrete after renoval from the :
,
gap. The NRC inspector will review the disposition of this NCR in a ;
l subsequentinspectionreportperiod(446/8622-0-03). l
l NRC inspections' were not performed on other activities during this
report period,
'
o No violations or deviations were identified.
l
d. Nonconformance and Corre..tive Action Systems (ISAP VII.a.2) i
)
During this report period NRC inspections were conducted for the ;
activities identified by NRC Reference 07.a.02.11.
Review Implementation of 10 CFR 50.55(e) Reporting -
(NRC Reference 07.a.02.11)
ToassesstheERCreviewofTUGCo10CFRPart50.55(e) reporting,the
NRC inspector evaluated the ERC checklists used for the review and i
inspected a sample of the completed ERC reviews. The checklists were
determined to properly reflect the requirements found in TUGCo .
. ProceduresCP-QP-16.1,NEOCS-1,andin10CFRPart50.55(e).
!
ERC reviewed 61 TUGCo SDARs for compliance with these procedures and
regulatory requirements. The NRC inspector inspected six of these
SDARs to verify whether ERC had properly implemented its review. The 1
SDARs inspected were: CP-79-08. CP-80-10, CP-82-07 CP-83-03, i
The NRC inspection of these SDARs was performed utilizing the ERC
t'
checklists. The results of the NRC inspections were then compared to ;
the ERC results. No differences from the ERC results were noted for
the checklist attributes. l
!
!
!
^
_ _ _ _ _ _ _ _ . -_ _ _ . _ _ _ _ _ _ _ _ _ _ - _ _ _________ ___________________ _-_ . _ -- _ _ _
16
Based on the checklists reflecting the procedural and regulatory
requirements and the results of the NRC inspection agreeing with the
results of the ERC inspection, this item has been properly
implemented.
During NRC review of the above SDARs, the NRC inspector reviewed
documentation (not required to be reviewed in the ERC effort on
SDARs) which identified that six installed Hilti Kwik bolts had been
modified in an unauthorized manner. The length designator stamped on
the end of five of these bolts had been modified such that the
indicated lengths of these bolts were longer than the actual lengths.
The specific conditions of the bolts were: Five bolts with a length
designator of 7" were actually 51" long; one bolt with a length
designation of 7" was actually 11" long. These unauthorized
modifications were found during a Hilti bolt reinspection program
which was a part of SDAR CP-80-10. SDAR-CP-80-10 addressed
modifications to Hilti Kwik bolts in which the length and the holding
ability of the bolts were changed by craft cutting off the mandrel
portion of a Hilti Kwik bolt and grinding a new mandrel on the
shortened stud, or craft cutting off the bottom mandrel of a
double-mandrelled Super Hilti Kwik bolt and installing the resultant
shorter bolt.
The Hilti bolt with modified length designations were not reported as
part of SDAR CP-80-10. Documentation concerning whether these Hilti
bolts were properly evaluated and whether the safety implications of
the nonconformances (modifications to the length designators) were
determined, could not be provided for NRC evaluation during this
report period. This is an unresolved item (445/8626-U-05;
446/8622-U-04).
e. Fuel Pool Liner Documentation (ISAP VII.a.8)
During this report period, the activities identified by NRC
Reference 07.a.08.01, and the qualifications of ISAP personnel were
inspected as follows.
Identify Inspection and Test Requirements from Document Reviews
(NRC Reference 07.a 08.01)
The NRC inspector inspected the notes from the ERC review of
documents related to fuel pool liner erection and inspection. These
notes showed that ERC personnel had reviewed the engineering
specification, the construction procedure, the nondestructive
examination (NDE) procedures, applicable weld processes, and the
inspection procedure. From their review ERC generated a data sheet
listing the applicable inspection and test requirements. To assess
the implementation of the ERC document review, the NRC inspector
compared ERC data sheets to the above fuel pool liner documentation
and to ten completed construction travelers for the fuel pool liner.
The NRC inspector found that the data sheet listed requirements for
!
17
i
l the areas of welding, inspection, NDE Nelson studs, and records.
l Items that required verification by ERC on the data sheet were the
welders identification, the weld procedure used, weld filler material
used, the QC inspectors identification QC hold / witness points,
required civil data, and NDE procedures used. Other information such I
as inspection report numbers, weld repair process sheets, NDE
requests NDE reports, and NCR numbers were verified if applicable.
The NRC inspector determined by reviewing the data sheet and
comparing against the specifications and procedures that the
inspection and test requirements were identified by ERC properly.
I
No violations or deviations were identified.
'
No further NRC inspection is planned for this reference area.
Qualification of Personnel
The qualifications of personnel for this ISAP were first reported in
NRC Inspection Report 50-445/86-01; 50-446/86-01. The qualifications
of additional and replacement personnel were verified by the NRC
inspector to meet the CPRT Program requirements. This was
accomplished by review of the resumes and statements of objectivity
maintained in the ERC personnel file. This action plan is nearly
complete. No violations or deviations were identified and no further
NRC inspection of this reference area is planned.
4. ISAP VII.c
a. Documentation Review of Cement Grout
Status of CPRT Activity
Documentation review of cement grout placements is complete with 121
packages reviewed. A total of 125 valid deviations have been
identified and evaluated for safety significance. No
safety-significant deviations were identified.
Status of NRC Inspection Activity ,
The NRC inspector performed documentation reviews of the following
five cement grout packages:
Verification Cement Grout Unit
Package P_lacement
R-S-GRTC-010 IRC-4591 1
R-S-GRTC-027 IRC-4870 1
R-S-GRTC-054 IR2-35005 2
R-S-GRTC-078 IRC-5542 Common
R-S-GRTC-083 IRC-1324 1
No violations or deviations were identified.
18
b. Documentation Review of Epoxy Grout
Status of CPRT Activity
Documentation review of epoxy grout placements is complete with 90
packages reviewed. Thirty-two valid deviations have been identified
and evaluated for safety significance. No safety-significant
deviatiori, were identified.
Status of NRC Inspection Activity
The NRC inspector performed documentation reviews of the following
five epoxy grout packages:
Verification Epoxy Grout Unit
Package Placement
R-S-GRTE-003 IRC-7333 Comon
R-S-GRTE-011 IRC-7149 Comon
R-S-GRTE-029 IRC-6322 1
R-S-GRTE-043 IRC-8683 Comon
R-S-GRTE-067 IRC-3983 Coman
No violations or deviations were identified,
c. Reinspection of Concrete Placement
Status of CPRT Activity
Reinspection and documentation review of concrete placement packages
is complete. Forty-three valid deviations for reinspection and 100
valid deviation, for documentation review have been issued. A total
,
of 133 deviations have been evaluated for safety significance. No
safety-significant deviations have been identified to date.
Status of NRC Inspection Activity
! The NRC inspector performed documentation reviews of the following
five concrete placement packages:
Verification Concrete Placenent Unit
Package
l R-S-CONC-015 IRCN-CPC-002-4790-040 Comon
R-5-CONC-023 IRCN-CPC-002 M852-082 Comon
R-S-CONC-040 IRCN-CPC-105-6831-014 I
l R-S-CONC-087 IRCN-CPC-101-5805-026 1
R-S-CONC-103 IRCN-CPC-002-6873-003 Comon
No violations or deviations were identified.
_ -. _-_ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ - - _ - - _ ___ - _
0
i 19
. L
l
I
, d. _!_nstrument Pipe / Tube Supports
_
j Status of CPRT Activity
1
ERC has completed all reinspections of instrument pipe / tube supports
4
from the planned random and engineered sample of 129. Five hundred ,
and three valid DRs have been identified and issued. The sample size :
- was increated from a previously reported figure of 111. The purpose
<
for tha increase was to ensure that the proper number of each
- attribute had been reinspected.
- ERC has completed all documentation reviews of instrument pipe / tube
supports from the sample size of 111. Sixty-six valid DRs have been
'
1
identified and issued.
Status of NRC Inspection Activity l
} (1) To date, the NRC inspector has witnessed four reinspections. I
performed eight hardware inspections and conducted five i
documentation reviews.
(2) The following hardware inspection was perfor1ned by the NRC l
inspector during this inspection period:
Verification Instrument Tag System * Unit
j Package
l I-INSP-012 1-FT-4558 CC 1
- CC - Component Cooling Water System
j No violations or deviations were identified. j
(3) The following five documentation reviews were performed by the j
NRC inspector during this inspection period: j
l
! Verification Instrument Tag System * Unit l
j Package
j R-S-INSP-010 1-PT-4775-1 CT 1 !
'
R-S-INSP-012 1-FT-4558 CC 1 !
R-S-INSP-033 1-LT-462 RC 1 !
R-5-INSP-107 1-PT-2326-C MS 1
!
- R-S-INSP-126 1-PT-2328-A MS 1
l
- i
i * CT - Contairment Spray System ;
{ CC - Component Cooling Water System l
'
j
- MS - Main Steam System
1
l No violations or deviations were identified.
t
,
,
20
e. Large Bare Supports - Rigid
Status of CPRT Activity
ERC has completed 134 reinspections and 89 documentation reviews of
the planned random and engineered sample of large bore supports -
rigid. One hundred sixty-nine valid deviations have been issued by
ERC.
Status of NRC Inspection Activity
(1) To date, the NRC inspector has witnessed five reinspections and
performed six hardware inspections.
(2) The NRC inspector performed the following five documentation
reviews in this period:
Verification Pipe Support System * Unit .
Package
R-S-LBSR-005 CT-1-054-429-C42R CT 1
R-S-LBSR-011 DD-1-012-709-A33R DD 1
R-S-LBSR-020 SI-1-106-014-C52R SI 1
R-S-LBSR-021 SW-1-173-710-Y33R SW 1
R-S-LBSR-064 CC-1-134-704-E63R CC 1
DD - Demineralized and Reactor Makeup Water
SI - Safety Injection
CC - Component Cooling
No violations or deviations were identified.
f. Large Bore Supports - Nonrigid
Status of CPRT Activity
ERC has completed 92 reinspections and 82 documentation reviews of ,
the planned randem and engineered sample of large bore supports -
nonrigid. Two hundred fourteen valid deviations have been issued by
ERC.
Status of NRC Inspection Activity
(1) To date, the NRC inspector has Witnessed six reinspections and
performed five hardware inspections.
(2) The NRC inspector performed the following five documentation
reviews in this inspection period:
l
L
l
21
i
Verification Pipe Support System * Unit
Package
R-S-LBSN-008 CC-1-008-026-A335 CC 1
R-S-LBSN-015 RC-1-164-003-C81K RC 1
R-S-LBSN-020 CS-1-001-039-C42K CS 1
R-S-LBSN-034 MS-1-074-004-CE2K MS 1
R-S-LBSN-061 CC-1-323-724-A43K CC 1
- CC - Component Cooling
RC - Reactor Coolant
CS - Chemical and Volume Control
MS - Main Steam
No violations or deviations were identified,
g. Pipe Whip Restraints
l
Status of CPRT Activity
ERC has completed all reinspections of pipe whip restraints from the
planned random and engineered sample of 143. Two hundred and
seventy-seven valid DRs have been identified and issued. The sample
size was increased from a previously reaorted figure of 110. The
purpose of the increase was to ensure t1at the proper number of each
attribute had been reinspected.
ERCcompletedalldocumentreviewsofpipewhiprestrair$t: from the
sample size of 139. Fifty-seven valid DRs have been identified and
issued.
Status of NRC Inspection Activity
(1) To date, the NRC inspector has witnessed five reinspections,
performed six hardware inspections, and conducted five
documentation reviews. The following four hardware inspections
were performed by the NRC inspector during this inspection
period:
Verification Support Identification System * Unit
Package
I-S-PWRE-062 CS-1-087-912-A47W CS 1
I-S-PWRE-521 FW-2-017-904-C57W FW 2
1-5-PWRE-527 FW-2-019-911-C57W FW 2
1-S-PWRE-541 FW-2-020-907-C47W FW 2
- CS - Chemical Volun,e and Control System
FW - Steam Generator Feedwater System
No violations or deviations were identified.
.
22
(2) The following five document reviews were perforwed by the NRC
inspector during this inspection period:
Verification Support Identification System * Unit
Package
R-S-PWRE-057 FW-1-018-906-C67W FW 1
R-S-PWRE-062 CS-1-087-912-A47W CS 1
R-S-PWRE-521 FW-2-017-904-C57W FW 2
R-S-PWRE-527 FW-2-019-911-C57W FW 2
R-S-PWRE-541 FW-2-020-907-C47W FW 2
- FW - Steam Generator Feedwater System
CS - Chemical Volume and Control System
No violations or deviations were identified.
h. Tubing Welds / Materials
Status of CPRT Activity
ERC has completed all reinspections and documentation reviews of
tubing welds / materials from the planned random and engineered sample
of 100 and 98, respectively. Twenty valid deviations have been
issued by ERC.
Status of NRC Inspection Activity
(1) To date, the NRC inspector has witnessed three reinspections and
performed four hardware inspections.
(2) The NRC inspector performed the following five documentation
reviews in this inspection period:
Verification Drawing System * Unit
Package
R-M-TUWM-002 FSI-1-500 MS 1
R-M-TUWM-008 FSI-1-601-01 RC 1
R-M-TUWM-024 FSI-00043-17 NI 1
R-M-TUWM-034 FSI-00043-56 NI 1
R-M-TUWM-036 FSI-00043-54 NI 1
- MS - Main Steam
RC - Reactor Coolant
NI - Nuclear Instrumentation
No violations or deviations were identified.
l
l
23
1. Mechanical Equipment Installation
Status of CPRT Activity
ERC has completed all 170 reinspections and 84 documentation reviews
of the planned random and engineered sample of mechanical equipment
installations. Two hundred and twenty-one valid deviations have been
issued by ERC.
Status of NRC Inspection Activity
(1) To date, the NRC inspector has performed six hardware
inspections.
(2) The NRC inspector performed the following five documentation
reviews in this inspection period:
Verification Equipment Tag System * Unit
Package
R-M-MEIN-009 CP1-AFAPMD-01 AF 1
R-M-MEIN-019 CPI-CCAHHX-02 CC 1
R-M-MEIN-035 CP1-CHCICE-06 CH 1
R-M-MEIN-107 TBX-CSAPPD-01 CS 1
R-M-MEIN-263 CP1-VAAUSE-11 VA 1
- CC - Component Cooling
CH - Ventilated Chilled Water
CS - Chemical and Volume Control
VA - Heating, Ventilation, and Air Conditioning
No violations or deviations were identified.
j. Reinspection of HVAC Ducts and Plenums
Status of CPRT Activity
ERC has completed all 110 reinspections of HVAC ducts and plenues in
the random and engineered samples. A total of 176 valid deviations
were identified by ERC.
Status of NRC Inspection Activity
The NRC inspector previously witnessed eight ERC reinspections and
performed hardware inspections and documentation reviews on the
following three verification packages during this report period:
24
Verification Duct Unit
Package
! I-M-DUPL-045 EMD-1-8 Common
I-M-DUPL-046 RMD-1-37 Common
I-M-DUPL-051 EMD-1-6 Common
!
!
Paragraph 4.3.3 of ISAP VII.c. states, in part. "For each population,
attributes which have safety significance will be determined . . . .
Justification for not including attributes in the reinspection or
I documentation review checklists which have been identified as
l nonsafety-significant will be documented and retained as records in
the ISAP file. For each safety-significant attribute identified,
detailed instructions for the verification of the attribute,
including definitive accept / reject criteria, will be
established . . . ."
During review of BSC's HVAC duct and plenum procedures, the NRC
inspector noted certain work activities and attributes which were not
identified by ERC engineering during development of the QIs (QI-039
- and -040) associated with the reinspection and documentation review
l of HVAC ducts and plenums and their applicable inspection and
documentation review checklists. Work activities and attributes not
addressed consisted of such items as:
l (1) Welded nuts on the interior of seismic volume extractors.
l (2) S and J crimps used for attaching various accessories such as
grills, registers, and associated sealant material.
The failure to identify these activities / attributes precluded
determination of safety significance and the failure to provide
justification for not including nonsafety-significant attributes in
the applicable reinspection or documentation review checklists is a
deviation (445/8626-D-06). No violations or deviations were
i identified with respect to performance of the inspections and
l documentation reviews.
k. HVAC Duct Supports
Status of CPRT Activit.y
ERC has completed all 183 reinspections of the HVAC Duct Support
random and engineered sample. A total of 371 valid deviations were
identified by ERC.
Status of NRC Inspection Activity
(1) The NRC inspector has previously witnessed seven ERC
reinspections and separately inspected six verification
packages.
_
25
(2) The NRC inspector performed inspections and documentation
reviews on the following six verification packages during this
report period:
Verification Drawing Unit Location *
Package
I-S-HVDS-003 CB-830-IN-1X 1 CB
I-S-HVDS-023 CB-830-IN-1R 1 CB
I-S-HVDS-046 CB-830-IN-1AL. 1 CB
I-S-HVDS-117 CB-830-IN-1AQ 1 CB
I-S-HVDS-118 CB-830-IN-C5 1 CB
I-S-HVDS-060 SG-790-IH-28 1 SG
~
- CB - Control building-
SG - Safeguard building
The following information was inadvertently omitted from NRC
Inspection Report 50-445/8607; 50-446/8605. BSC provided ERC with a
population list which was to have contained all final QC inspected
and accepted Unit 2 HVAC duct supports. A population list was also
presented to the NRC inspector for use in selecting inspection
samples. Subsequent to selecting 15 supports for inspection, the NRC
inspector requested BSC to provide the inspection records for those
supports. BSC informed the NRC inspector that these supports had not
been final QC inspected and they should not have been listed. This
raised a question with respect to the validity of the list presented
to ERC.
Follow-up of this information, in conjunction with the six
inspections and documentation review activity, revealed the following
conditions. Section 2.0 in Revision 1 of QI-035 and QI-036 requires
that reinspection and documentation review be performed on only those
duct supports which have been installed and final QC accepted by BSC.
Section 5.0 in QI-036 requires the initiation of a DR for any
applicable HVAC duct / support attribute identified as not having been
inspected by BSC.
In deviation from the above, the following conditions were
identified:
(1) The documentation review verification packages issued to ERC
inspectors for Unit I and common HVAC duct supports contained
BSC detail drawings which were supposed to represent the
installed and final QC accepted supports, and the applicable BSC
inspection reports.
(2) The NRC inspector identified that the BSC inspection reports
were dated as many as five years prior to the initial issue of
the detail drawings.
26
1
(3) There was no evidence of inspections performed by BSC QC to
verify the duct support configuration to the detail drawing.
(4) It was further determined that BSC QC used typical drawings for
their . inspections. These drawings can be dissimilar to the
detail drawings provided to ERC. As a result, the ability of
ERC to identify attributes not inspected by BSC was affected;
thus initiation of all required DRs was precluded
(445/8626-D-07).
During review of BSC inspection records, the NRC inspector recorded
the names of eight BSC welders in order to examine their performance
qualification records. Review of BSC's procedures applicable to
welders' qualifications (DFP-TUSI-001, Revision 8, and DFP-TUSI-003,
Revision 7) identified that all welders performing work on duct
supports and seismic support systems shall be qualified in accordance
with Section IX of the ASME Code.
Paragraph QW-301.2 in Section IX of the 1977, 1980, and 1983 editions
of the ASME Code states, in part, "Each manufacturer or contractor
shall qualify each welder or welding operator for each welding
process to be used in production welding . . . ." QW-301.4 states,
in part, "Information regarding the essential variables and the test
results obtained by each welder . . . shall be recorded on a Record
of Performance Qualification Tests."
The NRC inspector identified a violation with respect to position
limitations and qualified material thickness ranges, in that BSC's
welder performance qualification records dated May 1979 June 1981,
and March 1983, certified their welders as being qualified in more
positions and material thickness ranges than allowed by the reported
number of test results (445/8626-V-08; 446/8622-V-05).
5. Assessment of Allegations
a. 4-86-A-50: Civil Engineering Concern Related to Safety Related
Electrical Systems
An alleger expressed several concerns to the NRC involving site
activities and observations in the civil / structural area relative to
safety-related electrical systems. The following paragraphs
characterize these allegations and provide the NRC's assessments and
conclusions.
(1) It was alleged that several cases existed at Comanche Peak in
which a common hanger or support was used for redundant trains
of safety-related electrical systems, while the Final Safety
Analysis Report (FSAR) requires that such trains be kept
separate. It was also alleged that another individual had
.
identified the use of common hangers or supports for redundant
'
safety-related Trains A and B to the Comanche Peak Safeteam as a
._ .
. - . - - - . . - _ . .- - - . - - . . - - . . - . .- .__.- .
q- ,
.
.s 27
-concern, but no response was given to the individual regarding
the resolution of the concern. The general location where
'
comon hangers or supports were used was identified as being in
'
the northeast corner of the control room.
In assessing the described concerns, the NRC inspector:
(1) determined FSAR comitments regarding the support and
separation of redundant Class IE (safety-related) electrical
systems; (2) verified TUGCo's method of supporting and
separating Trafns A and B to conform to FSAR comitments; and
(3) examined hos the common hanger or support concern reported
to the Safeteam was resolved.
- Sections 3.10B.3, 7.0, and 8.0 of the FSAR prescribe the
requirements for the independence of redundant Class IE systems.
TUGCo has comitted to using seismic Category I hangers or
supports for Trains A and B.- The FSAR does not prohibit
Trains A and B from being installed on a comon hanger or
-
support, provided train sepcration criteria are not violated.
There hangers and support's were designed such that if the
. safe-shutdown earthqucke occurs, electrical power,
' instrumentation, and control wiring in the cable trays will
. remain functional for Trains; A and B. These hangers and supports
are attached to walls and floors of seismically designed
buildings. Section 8.0 of the FSAR requires that Class 1E
cables be routed in such a manner that any single failure in one
tran?'does not cause a failure in another train. Preserystion
of the independence of redundant electrical circuits is accomplished
by raceway separation criteria. For example, in the cable
spreading area and control room, a minimum separation of one
foot horizontal and three feet vertical is required to be
maintained between redundant raceways (cable trays and conduits).
Separation of redundant cable trays was inspected by the NRC
inspector in the control room and cable spreading area for
compliance to FSAR separation requirements. In examining the
control room's northeast corner (identified by the alleger) for
comon supports of Trains A and B, the NRC inspector found that
no redundant trains in cable trays or conduits were installed in
that area of the control room. Train A and B cables were found
to be routed below the control room in the cable spread area
prior to entering the control room. 'In the cable spread area,
Train A and B cable trays were found to be supported on a comon
support; however, tray separation was in accordance with
prescribed requirements.
A common support location area for Train A and B cable trays was
selected to verify that required seismic analysis had been
performed. The location for Train A was spread room location K1
(elevation 814' 8"), and Train B was location P1
. ._ -__. -. . , _ - --
. . . .. . _ _ _ _ . ._ _
28
(elevation 818' 2"). NRC review of the K1 and P1 support beam
documentation, including calculations, confirmed that seismic
analyses were performed as required and met design requirements. -
'
.
The NRC inspector reviewed the Safeteam's assessment of.the
concern that Train A and B conduits having a common support
could result in a compromise of safe plant shutdown capability.
Based on the review of the FSAR, site procedures, examination of
installed hardware, and interviews with site personnel, the
Safeteam determined that common support for Trains A and B was
permissible; however, the Safeteam was unable to report its
findings to the concerned individual, who chose to remain
anonymous.
,
'
In sumary, the portion of the allegation that redundant
safety-related electrical systems (Trains A and B) were
supported by comon hangers or supports was substantiated;
however, trains were kept separate and a violation of FSAR
requirements did not occur. Review of FSAR comitments disclosed
common support of redundant trains is permissible provided train
separation is such that any single failure in one train does not
cause a failure in another train. Based on NRC field inspections
of cable tray separation and the verification of comon support
, seismic analysis, it was determined that the sampled redundant
train installations conformed to FSAR comitments.
The issue that the Safeteam did not provide feed back to the
individual who expressed a concern about comon support of
Trains A and B was substantiated; however, the reason feedback
was not given was that the individual chose to remain anonymous.
(2) It was alleged that safety-related cable trays were overloaded,
and added fire wrap or thermolag contributed to further
overloading. The cable spread room was identified as the
location where this overloading was occurring.
In assessing this allegation the NRC inspector: (1) determined
the criteria used for cable tray weight loading; (2) evaluated
l the method used by TUGCo to control tray weight; and
'
(3) inspected the cable spread room for potential overloading. '
Table 3.9-1 of Gibbs & Hill (G&H) Specification 2323-ES-19,
- dated November 22, 1976, prescribes the design load2 for cable
, tray weight of 35 pounds (1bs.) per square foot (ft ).
!_ Section 8.3.3.1 by the FSAR establishes cable tray fill criteria
to accomodate this design load as follows:
"
. . . generally limit the sumation of the cross-sectional
areas of control and power cables to a maximum of 40 and 30
percent, respectively, of the usable cross-section [ area] ;
- of the tray. However, percentages may be exceeded provided
! the following conditions are satisfied:
i
7 . , - .. - - , - , _ - - - . - , - - , - . . - - , , - - . - - . , - , - - - - , - , - -
_ _ _ _ . ._ _ . . _ _ _
l
l
29
1) Cables do not extend above the side rails of the cable
tray.
~
2) For power cables - thermal rating of the cable is not
exceeded.
3) Cable tray support design is adequate."
Based on interviews with site electrical and civil personnel,
two types of overloading of cable trays have been considered:
(1)thethermalimpactofexceedingcabletraypercentfill;and
(2) exceeding the design cable tray load considering the
combined weights of the tray, cables, and fire barrier material.
The FSAR 40% fill criteria limit for control cables was
established using the National Electric Code fill requirements
from Article 318-8(d), " Cable Tray." The FSAR 30% fill criteria
limit on power cables was based on percent fill calculations
performed by G&H. In determining the thermal-impact on percent
tray fill for power cable such factors as ampacity, cable size,
and ambient temperature were considered. TUGCo has committed t6
use Insulated Power Cable Engineers Association - National
>
Electric Manufactures Association standards publication,
! IPCEA P-54-440, "Ampacities, Cables in Open-Top Cable Trays" for
determining heat generation rates for power cable and determining
j necessary derating factors. Using IPCEA P-54-440, an acceptable
percent tray fill, based on thermal consideration, was calculated
to be 39.26%. The G8H 30% fill criteria limit for power cables
was to provide additional margin.
,
,
Since the foregoing calculations for determining thermal loads
were based on open cable trays, TUGCo performed tests to
!' ~ determine the additional thermal effect when fire barrier
material (thermolag or fire blanket) was used to enclose the
cable tray.
The NRC inspector reviewed these test reports and noted the
'-
following conditions: (1) thermolag testing was conducted using
a dry film thickness of .500"; however, the thermolag
installation Procedure CP-CPM-10.3, Revision 9, permits a film
j thickness of .500" with a tolerance of
'
permissible thickness of .750"; and (2)plus 50% fortesting
qualification a maximum
'
for both thermolag and the fire blanket material was performed
at an ambient temperature of 40"C; however, the G&H cable
derating calculations (G&H Procedure E-2323-VII, " Cable Sizing
Calculations") were based on a 50 C ambient temperature. NRC
l inspector's review of additional infonnation, some of which was
not available until shortly after the end of this report period,
- disclosed
- (1) the fire protection rating of the thermolag was
based on a minimum thickness of 0.500" and the cable derating
calculations were based on a maximum thickness of 0.750", and
,
- -. - _- .. - -. _ ,. - - - - - - -
. . _ . .. . . - _ __ __ __ __
.
..
30 -
.
(2) the acceptance criteria for electrical cable derating were
-based on a maximum conductor temperature of 90 C regardless of
the initial ambient temperature. Therefore, the NRC inspector
found the thermal effects on electrical cable from the addition
'
of fire barrier material to be acceptable.-
Control of thermal and weight loads by percent cable tray fill
is governed by a computerizad report developed by G8H,
2323-El-1700, " Electrical Raceway Schedule." This computer
program performs several functions, including selecting the
shortest path for cable routing between two points, and
monitoring cable tray fill to assure fill does not exceed design
criteria limits. Should tray fill approach maximum design
,
limits, the computer locks out the shortest path and selects the
next available shortest route between two points. A pull card
is generated then for the craftsmen to install the cable. The
, pull card contains beginning and ending points of the cable
route, type of cable to be pulled, length of run, number of
cables, drawing reference number, and other pertinent
- information to pull the cable. QC inspectors witness and
-
inspect pull activity to verify work performed conforms to the
applicable installation procedures and pull card requirements.
Procedure TNE-DC-10, Revisions 1 and 2, " Design Verification of
Computer Programs," requires the design verification of computer
programs which are originated, developed, modified and/or used !
> by TNE for computational purposes to determine the design,
installation, performance, or operation of Class I or II,
equipment, systems or structures at CPSES. The purpose of the
design verification of Electrical Raceway Schedule Program (s)
,
was to demonstrate the validity of obtained results in
conforming to established design criteria. The NRC inspector
- reviewed the computer program verification documentation that !
confirmed G&H had design verified the original program and
, subsequent modifications to the program.
To determine if cable tray overfilling was occurring in the
spread room as alleged, the NRC inspector reviewed a sample of
19 Train A and B cable tray segments. The location of these
cable tray segments was between columns B and D and column
lines 2.9 and 5, which included the area identified by the
alleger. Inspection included the NRC inspector's physical
examination of the tray fill, verifying the control being
provided by the raceway schedule computer program, and reviewing
the documented tray weight for compliance with the design basis
, of 35 lbs./ft2 The types of cables found in this area of the
spread room were control and instrumentation and no fire barrier
material was used.
.
.
1
, . _ . . . _ . . . . . . . . . _ , . - , . _ . _ , _ , , . . . - , - , . . , . . - - - _ . _ _ , _ _ _ _ _ , _ - . , . , ,,, . . _ _ , - , , . . . , , - - . . , . , ,_,-----,-_w..,. -.y ---_.
- . . . . - _ _ -
a
, 31
4
(a) Overloading by Exceeding Percent Fill
The 19 segments examined in the spread room were reviewed
on the Electrical Raceway Schedule for compliance to the
40% area fill criteria. Several. segments were found to be
greater than 40% (by 2% to 9%), but no cables were observed
to be above the tray side rails, which is prohibited by
FSAR requirements. Those segments exceeding 40% were found
to be locked out by the computer for further cable routing.
An additional sample of documentation for approximately 740
Unit I control and instrumentation. cable tray segments were
.
reviewed to identify segments that exceeded the 40% fill
i
criteria. Segments which were approaching 40% were noted
with a warning message in the raceway schedule and segments
, exceeding 40% were locked out to prevent further use. From.
2 this additional ssmple, several tray segment fill limits
were exceeded by 2% to 7%. In every case where the fill
criteria was exceeded, additional analyses had been
performed, either confirming the weight limit had not been
, exceeded, or the support system was modified to accommodate
the additional weight load.
A further documentation sample of approximately 700 Unit 1
'
power cable tray segments was reviewed to identify segments
that may exceed the 30% fill criteria. Only one instance
of overfilling was identified which was 32%. The NRC
inspector's physical examination of this tray segment
disclosed the tray was not covered by fire barrier
material. -Based on the calculated power cable fill limit
(normal) of 39.26% and verifying the 35 lbs/ft2 was not
violated, this instance of exceeding 30% fill did not
4
violate FSAR cable tray fill requirements.
(b) Overloading Cable Trays from Use of Thermolag
, The NRC inspector reviewed TNE Procedure CP-El-4.0-49,
Revision 1, " Evaluation of Thermolag (TSI) Fire Barrier on
Class 1 Electrical Raceways," which established methods for
evaluation of the structural adequacy for the Class IE
i electrical raceways (cable-trays and conduits) with the
addition of fire barrier material. The evaluation
'
considered the weight of cables plus the weight of the tray
.
with the thermolag, which collectively was not to exceed
l the design load of 35 lbs/fte,
The NRC inspector reviewed the evaluations of 149 cable
'
trays with thermolag installed in the auxiliary, electrical
control, and safeguards buildings. Of the 149 evaluations,
18 cable tray weights exceeded the design load limit of
35 lbs/fte and required additional analysis. The NRC
l
- . - , - . .- .- - . - - - _ .- -. . - . -- _
. . - . - = - - - - - . . - ._
32
inspector reviewed in detail 9 of these 18 analyses and 6
were found to contain either errors or raise questions
concerning the methodology used in performing the analyses.
Since TUGCo has retained two outside contractors (EBASCO
and IMPELL) to perform a design verification of all Unit 1
Unit 2, and common cable tray supports, the NRC inspector
4
obtained and reviewed for adequacy the new analysis of one
of the overloaded cable trays in question. TUGCo has
a? designated these analyses as the analyses of record. The
NRC inspector's evaluation found that these analyses are
4 based completely on the as-built configuration of the
supports and trays. The NRC inspection of the analyses for
"
three of the supports, associated with one of these trays,
did not identify any errors or questions in methodology.
i
(c) Possible Overloading from the Use of Fire Blankets
TUGCo has installed separation barrier and radiant energy
shield material (thermal wrap) on Unit 1 cable raceways
(cable trays and conduit). The original design
- verification of cable raceways did not consider the
additional weight of thennal wrap on raceway supports in
,
design weight limit evaluations. Upon recognizing that
thermal wrap had not been considered for overloading, TUGCo
ve'rbally reported this issue to the NRC on August 27, 1985,
as a potentially reportable item under the provisions of
. 10 CFR 50.55(e). The possible overloading by use of fire
'
blankets is being evaluated under the CPRT Program Plan,
DSAP VIII, " Civil / Structural Discipline Specific Action
Plan."
! In conclusion, the overloading of cable trays with respect to
cable fill was not substantiated. The overloading of cable
trays by the additional weight of fire barrier material did
occur, but in every-case reviewed, the required reanalysis was
,
performed and support modifications were made if required. In
! addition, TUGCo has initiated a reverification of design for all
i Unit 1 Unit 2, and common electrical supports using, as a
minimum, the actual cable tray fill and fire protection material
'
l
weights (thermolag and fire blanket). The reverification of
design, which will become the design and analysis of record, is
- _ being accomplished under the CPRT Civil / Structural Design
l- Specific Action Plan (DSAP) VIII, Attachment 2, "CPSES Project
l
Activities for Cable Tray Supports."
' (3) Procedure Control and Training
,
The alleger was concerned that the field engineers' procedures
l manuals were not being properly maintained. For example,
j manuals were missing procedures or procedures were added without
,
i
.,v . - - - . ,-- , - , - - . - . .-w .,,.---ec. < - + m,--- -.---,,,,,*w, ,% --
c-.- - - - -----e----e,---, --w- --.g
. .- - -. . _
-- . ~ .- -
33
1
4
,. removal of the superseded procedure. According to the alleger,
during February and March 1986, a problem with manual control
was identified which resulted in manuals being recalled (removed
from the manual holders). The alleger believed the lack of
manual control was an indication of falsification of records
because field engineers were required to sign a document
, attesting that the engineer had received, read, and understood
the updated procedures and had removed the old procedure from
the assigned manual. In addition, the alleger believed the
official training given while at Comanche Peak was only
- superficial.
Based on information provided by the alleger and interviews with
site personnel, the NRC inspector determined that the site
procedures manual referred to by the alleger was the ThE
Procedures Manual. The field engineers mentioned were TNE civil
engineers from the Unit 1 Task Force engineering group which
functioned from January 1984 through April 1986. The Unit 1
Task Force was dissolved in April-May 1986.
The NRC's approach to assessing this allegation was
(a) determine how TNE controlled the procedures manuals issued
to TNE personnel, and (b) evaluate TNE's personnel
. indoctrination / training program.
-
(a) THE Procedural Control
Procedural control is governed by TNE Procedure TNE-AD-3,
" Preparation of Procedures and Instructions." For this
assessment, Revision 7 was used to determine compliance to
, procedural requirements. Revision 7 was in effect from
i
December 1985 through August 1986. The time period of the
! allegation was February and March 1986. THE-AD-3 required
l that control of procedures was to be maintained by
assigning a unique manual number to each control copy
- recipient. The use of a table of contents reflecting the
current revision'of each procedure in the manual was an aid
in assuring manuals were current. Each complete manual or
single procedure issued for insertion into manuals was
transmitted to controlled copy holders via a memorandum.
All issues were accompanied by a revised table of contents
and each assigned manual holder was required to acknowledge
this receipt by signing an acknowledgement form attached to
the transmittal memorandum and returning the
acknowledgement form to TNE files. If the acknowledgement
form was not received within 30 days, the manual was
subject to being decontrolled. TNE files maintained a list
of controlled copy manual holders which varied from 320 to
350.
4
. - , . - _ , - _ .. __ _., _ _ - _ _ _ _ _ _ -_,..,__..--_.___,.___,m-- - _ . . - _ _ . _ . , ___ _ _ - -. _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _
. - . . -. . ..
$
34
-
No manuals were found to be decontrolled during January
through April 1986 because of either failure to keep
,
manuals current, or because TNE files had received late
acknowledgement forms. During September 1986, two manuals
were decontrolled by TNE files as.a result of manual
holders not returning acknowledgements per TNE-AD-3
- requirements, well after the time period of this
allegation.
i
To determine if transmittal memorandums were signed and
returned in accordance with TNE-AD-3, the returned
acknowledgement forms were reviewed by the NRC inspector
, for the months of January, February, March, and April 1986.
! All civil engineering manual holder acknowledgements were
found to have been returned within the prescribed time
limit of 30 days, or when the 30 day limitation was
exceeded, upon notification, the manual holder returned
- their acknowledgement forms.
.
On February 12-17, 1986, and March 3-11, 1986, TNE
2 conducted a self initiated internal surveillance of
l- Procedure TNE-AD-3, Revision 7. The purpose of the
); surveillance was to verify that controlled manuals
contained the current table of contents, the _ proper
procedures, and that the acknowledgement forms from the
- controlled manual holders had been submitted. Observations
from this surveillance of 35 manuals were: (1) manuals
were not being maintained current (5 and 6 revisions behind
thecurrentissue);(2)deletedorsu
were found to be in some manuals; (3)perseded procedures
procedures were
missing from some manuals; and (4) the return of
acknowledgement forms exceeded the 30 day requirement in
some cases.
During the performance of the THE surveillance, actions
were taken to correct the observed problems which included
bringing the 35 manuals inspected into conformance with
TNE-AD-3. A copy of the surveillance report (TNE-86-01)
was distributed to TNE managers recommending manual holders
- update manuals as new or revised procedures were received.
On March 24-27, 1986, TUGCo Dallas QA performed a scheduled
audit (TCP-86-10) of TNE's records and document control
function. Part of the audit focused on THE procedural
control. Eighteen TNE procedure manuals ,
were audited against the latest revision of the table of .
contents. The results of the audit were that 10 of the 18
manuals were not current with the table of contents. l
Deficiencies observed included: (1) procedures missing, i
(2)revisedproceduresnotinserted,and(3) deleted
procedures not removed,
r
i
I
- - _ . _ _ _ _ _. _ _ _ _ . . _ _ _ _ _ _ , _ _ _ _ _ _ . _ _ _ _ ,__ _______._________w
. . . .. . . - - . . . - - ._ . - - - .
4
,
l
35
l
TNE's corrective action for this audit was to:-(1) update
and verify the completeness of the controlled manuals
listed as deficient in TCP-86-10; (2) review all remaining
controlled manuals for completeness to the latest table of
contents; and (3) issue a memorandum to all manual holders
to remind them of their responsibility to maintain manuals
to the latest table of contents and that manual
completeness would be verified during future surveillances.
After bringing all manuals up-to-date TNE performed a
~ surveillance of a sample of 15 manuals on July 17 and 18,
, 1986. All manuals were found to conform to the
a
requirements of TNE-AD-3 requirements. TUGCo's QA audit
group, during a followup audit, verified TNE's corrective
action was satisfactorily implemented and completed as
j ,
scheduled. The audit finding was i:losed on July 21, 1986. .
TNE transferred responsibility of manual distribution and
maintenance to the site document control program (DCP-3,
"CPSES Document Control Program") effective October 13,
1986. The decision was based on site document control
, having a more effective mechanism to issue and maintain
l procedure manuals than TNE. Under DCP-3, the Document
-
Control Center (DDC) satellite personnel will physically
insert in each controlled manual any updated or new TNE
. procedures and delete any old procedures.
With respect to recall of procedure manuals because of
problems identified with manual control, the NRC inspector
was unable to substantiate such an event. Based on site
personnel interviews and the review of audits,
surveillances, corrective actions, and TNE file records, no
'
manuals were recalled for problems with manual control
i- during the time frame of this allegation. The number of
!
manual holders was reduced from approximately 310 to 253
during April 1986. The cause for the reduction, according
to TNE, was the elimination of the Unit 1 Task Force and the
,
restriction by TNE management of manual holders to leads
and higher supervision. The alleger may have viewed this
,
reduction in the number of manual holders in April 1986 as
l a recall of manuals because of problems identified with TNE
- manuals during February and March 1986; however, this does
'
not appear to be the case.
The concern regarding the lack of THE procedure manual
l-
control was evidence that amounted to falsification
i of records, was assessed. The. alleger stated that
l- acknowledgement form TNE-AD-2.2 (from Procedure TNE-AD-2,
!- " Personnel Indoctrination and Training") signed by the
manual holder attested to the removal of superseded or
deleted procedures and that the manual holder had read and
,
understood the changes. The alleger assumed that if such
l
l
[
_ - - _ _ _ - _ __ _ _ __ _ ____ _ . _ _ _ . _ _ _ _ _ _ _ _ - _ _
, . . - - - - -. - -. - - ..
.
4.
36
was the case, any manuals found in noncompliance would
amount to falsification of form TNE-AD-2.2 by the
respective manual holder.
Form THE-AD-2.2 contained the following statement, "I
acknowledge having received, read, and understood . . . the
.
Procedures / Instructions transmitted per this Memo." This
form then was signed, dated, and returned to THE files.
This fonn 'had no statement concerning the removal of the
- old procedure or the insertion of the new procedure.
- Accordingly, the' problems associated with manual control
were not evidence of falsification of records with respect
to signing the acknowledgement form, nor was there any
other evidence that these forms were' falsified. -
(b)- TNE Training Program
Regarding the concern that official training given to TNE i
civil field engineering personnel was superficial. the NRC
'
, inspector reviewed TNE's personnel training / indoctrination
program as described in Procedure TNE-AD-2, Revision 4.
Indoctrination / training consists'of a combination of
required reading, classroom instruction, and as required
L on-the-job training relative to experience in the practical
implementation of established procedures. The standard
reading list for all THE personnel included 10 CFR Part 50,
,
Appendix B; TUGCo/TUSI CPSES QA Plan; TNE Procedures
',
Manual; and selected sections of the FSAR. On a
case-by-case basis, each individual's supervisor specifies
required reading in addition to the standard list.
'
Completed initial indoctrination is documented on fonn
TNE-AD-2.1, "TUGCo Nuclear Engineering Indoctrination
- Program." Deviation from the standard reading list is
required to be justified and documented.
Fourteen civil field engineering personnel
' indoctrination / training files were reviewed. The NRC
inspector found all initial indoctrination was completed
' and maintenance of proficiency in procedures was
' accomplished by completing reading assignments. Since TNE
is an engineering organization, training is primarily
accomplished via reading assignments. In reviewing
'
training sessions conducted during January, February,
March, and April 1986 (not related to civil field
,
engineering), the NRC inspector noted that the following
types of classroom training sessions were also given.
n Three were for procedural changes and two for specific
i subject matter; i.e., containment analysis and power
-
operated control valves. Outlines of subject matter
- presented and attendance records were documented in the
! files. Some sessions exceeded three hours in length. ,
i
!
-_ _ . .- .,_ _ _ ~ _ . - . _ _ _ . _ . . _ _ _ _ _ . _ _ . _ _ _ . . _ _ _ . _ _ _ _ . . . _ . _ _ _ . . _ _ _ _ . _ . . _ _ _ _ _ _ . --
~37
,
Based on review of personnel indoctrination / training
-
records and classroom training files, the NRC inspector
determined THE had established a training program that was .
more than superficial and in accordance with established '
procedures.
In conclusion, the allegation that controlled TNE procedures
manuals were not properly maintained was substantiated. Both
TNE internal surveillance personnel and TUGCo QA auditors
identified problems with TNE manual control as alleged; however,
corrective action was taken. Responsibility for procedure
distribution and maintenance has been transferred to DCC who has
a suitable mechanism to assure manual control. With respect to
the allegations that: (1) manuals were recalled (withdrawn from
manual holders) because of problems identified with manual
control, (2) completion of the procedures receipt
acknowledgement form when procedures were not inserted / deleted
from the manuals was falsification of records, and (3) official
training received by TNE personnel was superficial; these
allegations were not substantiated.
(4) " Problem Log" Destroyed
It was alleged that a " problem log" which was established to be
used by field engineering to record safety-related concerns
between July 1985 through mid-May 1986 was discarded before
identified problems were evaluated for impact on hardware.
The NRC's approach to assessing this allegation was to first
determine if such a problem log existed. If such a log did
exist, determine the function and purpose of the log and the
types of problems that were recorded. Finally, if the log was
determined to be destroyed, ascertain if problems were otherwise
identified and suitably resolved.
From information provided by the alleger and interviews with
three site personnel, the NRC inspector determined the area of
concern was the Unit 1 Task Force, civil conduit walkdown field
engineers. The function of the conduit field engineers was to
create as-built isometric drawings (IS0s) of Unit 2
safety-related conduit systems installed in Unit I and common
areas. The IS0s were drawn based on field verification of the
as-built condition of installed conduit. These IS0s typically
depicted conduit origin and destination. points, lengths and
configurations,supportdetails(typesandlocation),and
miscellaneous electrical fittings. The field verified conduits
were of completed installations which had been accepted by QC in
accordance with Procedure 2323-S-0910. " Conduit Routing and
Support Package for Unit 1," for design and acceptance criteria.
The problem log did exist and was initiated by the field civil
engineering supervisor to record any observations that were
. - _ - - . _ _ _ _ _
38
outside of the scope of the walkdown effort that could be
potentially nonconforming conditions. The intention was to turn
the log over to QC at the end of the walkdown activities, to
determine if the identified out-of-scope observations were
actually nonconforming conditions. If so, QC would report such
conditions on an NCR for appropriate dispositioning.
Entries to the problem log would have covered the time interval
of August 1985 through April 1986, as actual walkdowns occurred
. in August, September, and October 1985 and March through April
1986. In April 1986, the walkdown program by the Unit 1 Task
Force was discontinued. This activity was started again under a
new program conducted by EBASCO and described in the CPRT
civil / structural design specific action plan DSAP VIII,
Attachment 3 "CPSES Project for Conduit Supports." The current
procedure governing conduit field verification (walkdowns) is
TNE-FVM-CS-014. Revision 3. "As-built Field Verification Method
- Design Control of Electrical Conduit Raceways for Unit 2
Installation in Unit 1 and Common Areas, Class 1."
When EBASCO became responsible for the new design verification
program for Unit 2 conduit, the old verification program was
discarded, including the walkdown data and the created IS0s.
Apparently, in mid-May 1986, the " problem log" was discarded
without having the identified concerns / problems evaluated for
nonconforming conditions. To the best knowledge of the
individual in charge of the log, the log contained about half of
a page of entries, perhaps 10 to 15 concerns / problems. This
individual also stated that those concerns / problems identified
under the old program were the type of items that would be
considered under the new program (TNE-FVM-CS-014). Two other
individuals that had knowledge of this problem log were still
on-site and were separately interviewed by the NRC inspector.
Each individual's recollection was consistent with that of the
individual in charge of the log. Discarding of the problem log
bypassed the site nonconformance reporting mechanism. This
action is in violation of Criterion XV of 10 CFR Part 50,
Appendix B (446/8622-V-06).
1 Based on inspection of TNE-FVM-CS-014, Revision 3 (particularly
paragraphs 2.2, 6, and 13.3), the NRC inspector determined the
following concerning the current program. A process has been
established to identify out-of-scope concerns / problems to be
evaluated for potentially nonconforming conditions. These
problems are required to be documented on a Request for
Inspection (RFI) form. The original is kept in the RFI log book
and c copy included in the applicable ISO work package. Based
on interviews of EBASCO personnel, at the conclusion of the
walkdown program copies of the RFI forms will be transmitted to
THE Engineering Assurance for further evaluation and processing.
.-
.
.
'
39
f
No mechanism appears to be established that describes or
controls the tracking and accountability of RFIs (126 to date)
to assure that identified items are evaluated and suitably
- dispositioned. The absence of such controls has been identified
as a violation (446/8622-V-07).
In summary, the allegation that the problem log used by the
Unit 1 Task Force civil field engineers to record out-of-scope
concerns / problems was discarded before the items identified were
evaluated or dispositioned was substantiated. A new Unit 2 and
common conduit field verification program was established by
TUGCo. Under the new program, all previous work (walkdowns and
createdIS0s)wasdiscardedandtheworkstartedover. The new
program provides for potentially nonconforming conditions to be
identified, but lacks detail as to tracking identified conditions
to assure appropriate evaluation and dispositioning. These
conditions have been identified as a violation.
b. 4-86-A-013: Alleged Improper NCR Disposition
A concern was raised that certain NCRs, related to Unit 2 electrical
cable installations, were being improperly dispositioned; NCRs
E85-201562, E86-200113, and E86-200195 were cited as examples. The
NRC inspector reviewed these NCRs and other. germane documents, in
4-
'
addition to performing physical inspections, in an effort to
determine the adequacy of the dispositioning of these NCRs.
i
NCR E85-201562
A concern over nonconcentric' outer jacket insulation on electric
cable from two cable reels was raised in this NCR on November 16,
1985. The original disposition indicated that the outer jacket is
for protection of the cable during shipping, storage and
installation; therefore, exact centering of the conductors was not
required and the project could "use-as-is" this cable.
This disposition was supported in a revision to the NCR (Revision 2,
approved August 25,1986) which provided additional information. The
revised disposition concluded that the nonconcentric outer jacket was
acceptable based on: (1) evaluations conducted by the electrical
cable manufacturer of representative samples of cable from the actual
cable types at the CPSES, and (2) testing conducted by the cable
manufacturer in 1979 on electrical cable with thin wall thickness of
the outer jacket. The cable manufacturer's report (contained in
"
Rockbestos Company letter VBR-19,608, dated June 10,1986) stated
that an average jacket wall thickness of 50% of the specified
thickness and spot minimums as low as 40% of the specified thickness
"will have no detrimental effect upon the ability of the cable jacket
to perform its intended protective function."
1
J
t
!
. - ._ . _ - , _ _ _ . . _ _ . _ , . - . _ . . . , _ . _ _ . _ _ . - _ . . . _ , . , . . _ . _. __ .._.-
y
40
The NRC inspector also ieviewed the receiving inspection report file
for both cable reels involved in this NCR. It was found that the
specified minimum and average wall thickness were listed as 0.036"
and 0.045" respectively for both reels and that the actual
measurements were 0.039" and 0.049" for cable reel W-166-1,
and 0.038" and 0.050" for cable reel W-266-1. The actual thickness
was, therefore, greater than the specified minimums. Based on the
aoove NRC_ inspector findings, this portion of the allegation was not
substantiated. However, the NRC inspector noted that the original
NCR disposition was not as complete as the Revision 2 disposition in
explaining how the decision to "use-as-is" was detennined.
,
NCR E86-200113 ,
A concern over the connection of the electrical wiring to a motor
operated valve (MOV) was raised in this NCR dated January 15, 1986.
The concern addressed the bend radius of the electrical cable and the
inability to inspect the cable for either color coding or possible
insulation damage. The disposition indicated that the wiring
conditions were acceptable and to "use-as-is" the installation.
The basis for the above determination, as presented on the original
disposition of the NCR dated January 27, 1986, and Revision 1 of the
NCR dated February 12. 1986, was as follows: (1) the bend radius was
measured as 0.797" in IR 2-0081174 on January 31, 1986 (this radius
is greater than the minimum requirement); (2) the cable color code
was verified by review of the original installation IR; and (3) no
cable jacket damage was observed by QC inspection of the cable
exposed inside the MOV connection box.
,
In order to verify the acceptability of the NCR's disposition, the
! NRC inspector had the M0V connection box opened and performed a
physical inspection of the internal wiring. The NRC inspector noted
- that the outer jacket was removed back inside the flexible conduit
for approximately 2", determined that the bend radius was acceptable
for the 3, single, !6 conductors inside the MOV box and also
, determined that the conductor insulation exposed inside the MOV box
i
was not damaged. The NRC inspector was also able to verify that the
cable jacket was the correct orange color and that the conductor
l insulation exposed inside the flexible conduit was not damaged by
lifting up on the conductors while viewing down into the flexible
conduit.
Based on the above observations, the NRC inspector determined that
this portion of the allegation was not substantiated. However, the
NCR did not, by itself, contain a sufficient explanation for the NRC
inspector to conclude that the "use-as-is" disposition was acceptable;
visual inspection was required to reach this conclusion.
__ . . - _ _ . - _. --- -
_ - . . - _ - _ __ _ _ _ _ _ _ . _ _ , . , - . . _ _
r
41
NCR-E86-200195
A concern over cable slack being removed without QC present to
monitor for possible cable damage was raised in this NCR on
January 20, 1986. The disposition indicated that, since the raceway
was properly prepared for cable installation, removal of slack would
not damage the cable; therefore, "use-as-is."
The NRC inspector could not agree that the basis for the "use-as-is"
disposition provided in the NCR was acceptable. Therefore, the NRC
inspector physically checked the condition of the cables inside the
junction boxes (JBs) and the cable tray mentioned in the NCR. The
results of this inspection were: (1) JB 2C-4910, the electrical cables
were found to be free of damage and to have adequate slack, and in
addition, a cable support grip was installed in the vertical conduit
that exits the bottom of the JB; (2) JB 2C-1920, the cables were found
to be free of damage and to contain adequate slack; and (3) cable
tray T230RCJ06, the cables were found to be free of damage and were
properly coiled and protected while awaiting termination to the
containment electrical penetration device.
The NRC could not substantiate whether or not QC was present when
the cable slack was removed. However, based on the above NRC
inspector observations, even if this did occur, there was no adverse
effect on the quality of the cable installation.
Although the allegation was not substantiated, the NRC inspector
noted that, in each of the above examples, additional information was
required in order for him to conclude, by inspection and
documentation review, that the NCR disposition was acceptable. The
lack of a clear explanation on how the NCR disposition was determined
could have contributed to the alleger's concern.
The NRC inspector discussed the concern of incomplete explanations
for NCR dispositions with applicant QE personnel. The inspector was
informed that TUGCo became aware that the NCR dispositions may not
always be as explanatory as would be desirable and that steps were
being taken to correct this situation. The first step included a
redispositioning of selected NCRs in accordance with CAR-062, dated
March 4, 1986. The NRC was informed by letter dated October 20,
1986, that the applicant had implemented a program to review
, additional NCRs. This review program encompasses a technical review
of all previously closed NCRs with " void," " repair," or "use-as-is"
dispositions and is planned to be completed by June 30, 1987. In
addition, a new corporate procedure (NE0 3.05) is being finalized to
provide more specific guidcnce on the processing of NCRs. The NRC
inspector will evaluate the results of the above actions when they
are implemented. This is an open item (445/8626-0-09; 446/8622-0-08).
!
l No violations or deviations were identified.
!
,
I
42
c. 4-86-A-056: Alleged Improper Weld
It was alleged that a foreman had directed a welder to make a weld on
a cable tray support without removing existing paint. The support in
question was reported to be located in the Unit 2 electrical room at
elevation 852'. The weld was alleged to'have been made in
approximately May 1986.
The cable tray supports are vendor supplied and are fabricated using
ASTM A-36 structural steel and Type E7018 coated electrodes.
Subsequent to fabrication, the supports are coated with a phenolic
modified epoxy. Normally, any welding performed on-site would be
associated with the installation of the support. However, during
TUGCo's inspection of Unit 2 cable tray supports which was initiated
in approximately August 1985 and is about 65% complete, it was
determined that, in some cases, additional members were required;
e.g., bracing.
The addition of bracing was generally acccmplished by welding. Since
the supports had already been coated, removal of the coating would be
required prior to welding. If the coating had not been removed prior
to welding, conditions which would normally be expected to occur, and
which would be visible in the weld, are gross porosity, inclusions,
and areas of nonfusion.
The NRC requested the alleger to assist in identifying the specific
cable tray support. This request was denied. Thus, without having
necessary specificity, the NRC inspector selected a sample of 35
cable tray supports based on the specified room (Unit 2 electrical
room) and location (elevation 852'), and the fact that they exhibited
welds made subsequent to installation. The NRC inspector performed a
visual examination of the welds. The inspected welds were all
deposited as a result of the identified need for added bracing.
These welds had not yet been coated; thus, were in the as deposited
condition. The NRC inspector observed none of the conditions which
would have been expected if welding over paint had occurred.
Further, it was observed that paint had been removed as bare metal
was visible beyond the toe of each weld leg.
There was no evidence of welds having been made over paint.
Therefore, this allegation was not substantiated.
. . . - -- - _ _ . . . ~ . - . - . . -
43
6. - Overview Inspection
NRC inspectors have inspected, to date, a total of 45 overview
<-
verification packages. . The following six packages were inspected during
this report period:
4
18-I-S-INSP-012
46-I-S-PWRE-541
2-I-S-PWRE-527
46-I-S-PWRE-521
'
18-I-S-PWRE-521
14-R-S-LBSN-015
No violations or deviations were identified.
7. Exit Interview
Exit interviews were conducted October 9 and November 12, 1986, with the
applicant's representatives identified in paragraph 1 of this appendix.
During these interviews, the NRC inspectors summarized the scope and
findings of the inspection. The applicant acknowledged the findings.
.
.
1
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