ML20207E034
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| ML20207E034 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/10/1986 |
| From: | Barnes I, Ellershaw L, Hale C, Michaud P, Spessard R, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20207E000 | List: |
| References | |
| 50-445-86-15, 50-446-86-12, NUDOCS 8701020045 | |
| Download: ML20207E034 (31) | |
See also: IR 05000445/1986015
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APPENDIX C
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!:. ::' COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT
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1.v;s U.S. NUCLEAR REGULATORY COMMISSION
gj j . REGION IV ,,
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NRC Inspection Report: Permits:
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50-445/86-15 CPPR-126
::.;p 50-446/86-12
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CPPR-127
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e ? Dockets: 50-445 Category: -A2
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50-446
'fe f. Construction Permit
7 Expiration Dates:
. Unit 1: August 1, 1988
%.j( 7 7? ' Unit 2: August 1, 1987
p- ~ G.[.y A$licant: Texas Utilities Electric Company
1. M Skyway Tower
.F.5 400 North Olive Street Y - 7- Lock Box 81
l'i ,.fi Dallas, Texas 75201 y ( ...u..
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Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 & 2
,f e Inspection At: Glen Rose, Texas
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Inspection Conducted: June 1-30, 1986
Inspectors: ) M#
. L. E. Illershaw, Reactor Inspector, Region IV Dats
CPSES Group
(paragraphs 3.a. 5.a-c, 6.c, and 7.b-e)
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C. J. Ivf}e, Reactor Inspector, Region IV Dat
CPSES4 roup
(paragraphs 2.b-d, 4, 6.b, 6.d, and 8)
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P. C. Wagner, Reactor' Inspector, Region IV
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Date
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CPSES Group
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(paragraphs 2.a. 6.a and 7.a)
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i~ N P. Michaud, Reactor Inspector, Region IV Date 0 -
-(paragraph 3.b)
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:JL Dale (paragraph 5.c)
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T Consultants:- - EG&G
A. Maughan paragraphs 2.a, 6.a, and 7.a)
W. Richins paragraph 6.c)
V. Wenczel paragraph 4)
.
Parameter - J. Birmingham (paragraphs 2.b-c, 6.b and 6.d)
-K.' Graham (paragraphs 3.a. 5.a '7.b, and 7.c)
D. Jew (paragraphs 5.b, 7.d, and-7.e)
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Reviewed By:
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R. -L. Spessard// Deputy Director, Division of Date
Inspection Programs, Office of Inspection
and Enforcement
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IApproved:
-I.
[8%Barnes, Chief, Region IV CPSES Group
/2.da/44
Date
' Inspection Summary
: Inspection Conducted: June 1-30, 1986 (Report 50-445/86-15; 50-446/86-12)
-Areas Inspected: Nonroutine, unannounced inspection of applicant actions on
previous. inspection findings, assessment of overview inspector qualifications,
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assessment of overview inspection program, Comanche Peak Eesponse Team (CPRT)
issue: -specific action plans (ISAPs), overview quality team (0QT) review, and
g -assessment of allegations.
Results: Within the six areas inspected, six violations (absence of procedural
- requirements relative to control of material identification of identical parts
made in'the'onsite fabrication shop, Unit 1 paper flow group issuance of
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control. documents for extended periods, and designation of information to be . , , .
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included on written work requests for items from the onsite fabrication shop,
paragraph 6.d; operations travelers were not being completed as required by
procedures, paragraph 3.b(1); Hilti bolts were not being installed with a "
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torque wrench, parcgraph 3.b(2); modifications were made to NEMA Type 4
enclosures without proper design control measures, paragraph S.b(6); stainless
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Es' teel.'cstti$g'toolswerecontaminatedIwithother.. materials, paragraph 3.b(7);
-^ iand construction made' modifications.without-prior engineering approval,
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y- j paragraph'3.b(11))1andifour deviations (Evaluation Research Corporation (ERC)
. M f failed to,1dentify electrical . inspector certification errors during the Phase I
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" review required:in ISAP No.;.I.d.1, paragraph 6.b; ERC inspectors'did not
f - identify errors during independent inspection of Unit 1 diesel generator
y,t.controlpanel, paragraph 7.a;anlERCoverview: inspector'sexperiencewasnot
7 verified asimeeting. requirements,7 paragraph 4.b;'ERC overview inspectors failed'
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to; identify errors made 1_n an ERC. deviation report (DR) concerning parallelism
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.of pipe clamp' halves, paragraph 5.c, and concerning a pipe clearance violation,
, . . ; paragraph 5.b);were identified.
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DETAILS'
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l'. PersonsiContacted'
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t. , '*J. W.lBeck, Vice' President, Texas Utilities Generating Company (TUGCo) 4* R. Bizzak, tissue Coordina'.or, Comanche. Peak Response Team (CPRT)
.
'D.iBoydston,< Issue CocFdinator, ERC
'*C.'T. Brandt, Quality Engineering.(QE) Supervisor, TUGCo
fe < *R. 'E. - Camp, Project Manager, Unit 1, TUCGo
P. Clark, Overview Inspection Supervisor, ERC
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J.' R. ' Gelzer, Issue Coordinator, ERC
lP.(Halstead, Site Quality Control (QC) Manager, TUGCo
s J. L? Hansel, Quality Assurance (QA)/QC Review Team Leader, ERC
D.EJ.~ Hudson,ECertification Administrator, ERC
_
*0.~Lowe,-Manager,' Mechanical Engineering, TUGCo
b J.~Ma11anda,' Electrical Review Team' Leader, CPRT
'*D. M.' McAfee, Manager, QA, TUGCo
*J; -T.1Merritt, Director of Construction, TUGCo
m ~*L. D! Nace,-Vice President, Engineering & Construction, TUGCo
R. Pearson,' Issue Coordinator, CPRT
G. Ross, Issue Coordinator, ERC
W. Stone, Maintenance Foreman, TUGCo
P. Turi, Issus Coordinator, TERA
**T. G. Tyler, CPRT Program Director, TUGCo
.
C. Vincent, Issue Coordinator,.ERC
M. Wells, Civil / Structural Engineer, TUGCo
R. Wright, Warehouse Supervisor, TUGCo
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:J.lE. Young, Issue Coordinator, ERC
R.~ Zill,'Onsite QA Manager, ERC
* Denotes those persons who attended the exit interview.
The NRC inspectors also contacted other CPRT and applicant employees during
thi3' inspection period.
2. Applicant Actions on Previous Inspection Findings
.a. (Closed) Open Item (445/8511-0-28): Missing penetration assem.ly
identification. The ERC inspection of Verification XV
Package I-E-CABL-045, which was witnessed by the NRC inspector,"g 3
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identified a potential deviation related to cable routing. Because a
p penetration assembly for electrical cable E0121890 was not labeled on
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. both sides of a wall, the ERC inspector was unable to verify that the
cable was routed through the proper assembly. NRC inspector followup
review of the verification package found that subsequent ERC
inspector review of Drawing 2323-El-0507, Revision 2, verified that
the cable was routed through the proper penetration. Therefore, no
deviation was identified. -
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r b. (Closed) Open Item (445/8513-0-03): ERC review of non-ASME
certifications held by ASME inspectors. *
=The issue coordinator for ISAP No. I.d.1 directed that non-ASME
certifications held by ASME. inspectors be reviewed to the same
criteria developed for review of non-ASME inspectors' certifications.
The review of these certifications is complete and has been verified
by the NRC. inspector. Clarification of this requirement and
subsequent action'taken closes this item.
c. (Closed) Open Item (445/8513-0-04): No clear position concerning
acceptability of a TUGCo inspector with a record of passing General
Education Development (GED) test scores, but without a record of a
GED certificate _being issued.
,& .The special evaluation team (SET) has indicated that issuance of a
GED certificate is the formal acknowledgement that test scores
achieved on a GED test are acceptable prorf of high school
equivalency. Therefore, the SET will accepr GED test scores as
. meeting the requirements of Regulatory Guide 1.58, if it is
established that the scores are in fact passing. Passing test scores
should be shown by subsequent issuance of the GED certificate or a
letter from the appropriate authority indicating the test scores are
passing. Since the inspector in question subsequently received a GED
certificate for_these test scores, the SET evaluated his
certification as valid. This clarification of the SET'r position
closes this item.
d. (Closed) Deviation (445/8514-D-01): The ERC records administrator
i did not receive-or provide control of requests for equipment / services
-from TUGCo. Further, unique numbers were not being used in tracking
such requests.
On March 11, 1986, Revision 1 to ERC Procedure CPP-012 was issued to
correct the error that placed control of equipment / service
requests (ESRs) under the QA/QC records administrator. The control
. and trbcking of ESRs was and continues to be the responsibility of
,- the inspection supervisor. The NRC inspector reviewed the system for N tracking ESRs and found that the principal control was provided frum
the individual certification package files and the unique numbers and
tracking logs were used as an aid not required by the primary
control. Accordingly, Revision 1 to CPP-012 deleted the description
of tracking logs and the unique number requirement; however, both
continue to be used. Currently, Procedure CPP-012 is being
implemented as revised and provides the required control of ESRs.
3. Assessment of Allegations ,
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a. 4-86-A-038 (ASME Pipe Hanger Design): It was alleged that the ASME ,
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pipe support design configuration shown on Pipe Support Drawing l
CT-1-014-426-C52R could allow the sharp edge of a structural member
.. to contact piping, which would result in damage to the piping system.
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rThe-NRCl assessment of the allegation ~ revealed that the maximum
horizontal movement of the piping,-in accordance with the latest '
'. ^S ' design. drawing,- was 0.141 inch in the direction of the structural
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memberfand that the existing field clearance between the piping and
the structural member, Item 9 of. Pipe Support CT-1-014-426-C52R, was-
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0.250 inch. :The. existing clearance ~is adequate and does not impair.
-the operational-function of the pipe support or. piping system. The
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subject allegation was.not' substantiated.
7- ~ b. L4-86-A-015 (Electrical Design and Installation): An inspection was
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performed by the NRC staff in response to an allegation-involving 13
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areas of concern. ~These concerns were addressed by an examination of
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l records,' drawings, procedures and specifications, personnel
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,~- ' interviews, and direct physical inspection. A copy of.this
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inspection report will be provided to the alleger.
(1) : Operation Travelers
v [ ilt was'allegedithat operation travelers for conduit and junction
box supports were not signed as work was performed.
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co 4 An operation traveler provides instructions on how to perform a
.. task,'~ identifies required inspection points, and specifies the
H' 46 . documentation required. Section 3.2 of Revision 11 to Brown &
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Root-(B&R) Procedure CP-CPM 6.3, " Preparation, Approval, and
"' , ICo'ntroliof Operation Travelers," requires the initials or
: . signature of.the person completing each operatior,at the
completion of each operation and prior to moving parts or
assemblies.to the next scheduled operation. The alleger stated
that1 travelers were routinely not signed as operations were
- . completed but.were instead signed during a " final walkdown"
performed by craft prior to QC inspection. This " final
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walkdown" could allegedly occur months after the initial
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' installation and in many cases the person signing the traveler
was allegedly not the same person who performed the original
operation.
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- The NRC inspector reviewed more than 50 class 1E conduit
travelers to determine if the operations were signed in a manner
consistent with the requirements of the procedure. A number of
'the selected travelers had the supports for an entire conduit
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run signed by one person on a single day. With eight er more
,' supports on some of these conduit runs, it seemed unlikely one
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person could complete the entire installation in one day.
Examples'of this included conduit runs C23G03594, C23G12372,
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. C22G03862, and C22903719.
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The' NRC: inspector interviewed ~six1 individuals involved in the
; installation of safety-related conduit'and-junction boxx
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-supports,: including one foreman. Each~ individual confirmed that
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s travelers were routinely left unsigned until a final walkdown of
J . ,- M Lan entire conduit run was made and that .the person signing the
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4 : travele~r 'duringlthe final walkdown may not be the.same person
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1 ;- e ;who'did~the original installation. None of these individuals.
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_i could recall any specific instructions given to them to not sign
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travelers las work was-performed. Additionally, each: individual
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1 Estated that~sometimes: travelers were signed as work was
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Jcompleted .an'd-sometimes they were left-blank until a final
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- Installation activities'were witnessed in the Unit 2 reactor
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% building and safeguards building.= The NRC inspector witnessed
, ;<r u . ; travelers being signed both'as work was performed and during a
final walkdown on an installed conduit run, which confirmed a
4 definite lack of consistency.as to when travelers were being
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= signed. The practice of signing for work only'after a final
';,. Dwalkdown may also interfere with the identification or trending
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of, problems with fabrication or construction. The root cause of
. . : a problem may not be identified if.the symptoms are being
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repaired.-
I# ;In: defense of the current practice, QC management pointed out
; that'in'Section 2.1 of CP-CPM 6.3, the signature authority of an
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foperation traveler lies with the construction superintendents or
:their designees. According to QC, the words "or their
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designees" were'added specifically to allow signing of the
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travelers by someone other than the person performing an
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. operation. Also pointed out' was the exception paragraph in
Section~3.2 of.the procedure, which allows operations on a
traveler'to be performed out of sequence, which would allow a
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traveler to be signed any time after an operation is performed.
It'does not appear, however, that the intent of this procedure,
.as written, was to allow the signature of someone other than the
person who actually performs an operation to be affixed at any
time after it has been performed, because paragraph 2 of
Section 3.2 does not permit these actions. The statement in
paragraph 2 of Section 3.2 is explicit with respect to requiring
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the signature or initials of the person completing each
operation at the completion of each operation and prior to
moving parts or assemblies to the next scheduled operation.
Changing the signature authority is not relevant to when a step
; on'a traveler is signed, and the " exception," allowing
operations to be performed out of sequence, does not affect the
requirement for signing each operation at its completion.
In conclusion, the allegation was substantiated by the NRC
inspector and a violation issued (446/8612-V-01).
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[(2)$;Torede' Wrenches 1
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f4 % i - It;was'aNegebthatl torque'wrencheswerenot'always'usedtoset
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/ 'Hilti bolts as Trequired by procedure, and often, an ordinary
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g:n A m j specified torque values.N It,wasLalso alleged that the issue JSw .
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" record cards which accompany each torque wrench were signed "did
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9' snot.use" when torque wrenches were actually.used and that
lj Pt , $ A : instructions were given'to craft persons toisign "did not use." w -
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1y_ V Parag'raph- 321.4.1 of B&R Procedure CEI-20, '_' Installation of
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iHILTI Dr;illed-in Bolts,'? Revision 9, requires the'use of a-
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- -torque wrench to'_setithe bolt at-the time of installation. The.
d u . 'NRC; inspector witnessed Hilti bolts being' installed for a-
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cc a conduit' support using a 6-inch' ratchet wrench with the bolts % % tightened enough to hold the~ supports in place but without
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M- actually setting the bolts by torquing them. No torque wrench
7: Lwas.in the' possession of the craft persons installing the
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i supports of this conduit run. . Interviews conducted with six
i electrical cra_ft persons confirmed that torque wrenches were
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% tseldom:used on the initial installation of Hilti bolts because
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torquing was~ performed _during the final walkdown of a conduit
w# run.
Procedure-CEI-20 specifies only minimum torque values which must
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_ be -achieved in ' order.to properly set the wedges on the Hilti
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~ bolt! These values are based on testing done by Hilti and TUSI
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, specifically: for construction at CPSES. The NRC inspector
iv . , reviewed these test results which demonstrated that with applied
s e torque values nearly twice those minimums specified in CEI-20,
the bolts were still able to withstand loads 150 percent of the
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:specified value. Based on these test results, exceeding the
- minimum torque values specified in CEI-20 would not likely have
any effect on'the bolt's ability to function as designed.
Additionally, although a torque wrench may not have been used to
install Hilti bolts, the wrench that was used has a shorter
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handle-(6-inch ratchet vs. 14-inch torque wrench) resulting in a
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shorter lever arm which would make overtorquing difficult. The
+ consequences of extreme overtorquing would be breaking off the
bolt or pulling it out of the hole.
With regard to the second concern dealing with issue record
cards, B&R Procedure CP-CPM 13.1, " General Calibration
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Procedure," Revision 8, paragraph 3.4.6, provides instructions
that if a torque wrench is checked out and not used, the only
entry required is to record that it was not used.
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, The NRC
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inspector reviewed nearly 500 issue / record cards for torque
wrenches used by electrical craft personnel. Each of these
record cards appeared to be completed and maintained properly.
Approximately one-third of the issue / record cards reviewed had a
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- "did not use" entry. The NRC inspector interviewed four
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individuals to determine if instructions were ever given to sign
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. issue / record cards did_ not use" when, in fact, they had used
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% the wrenches. None of these individuals recalled such
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instructions. All of the persons. interviewed did remark that
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3 occasionally a torque wrench was. checked out and not used, but
%, - the proper notation was entered on the issue / record card. The
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. : supervisor of the calibration-department indicated less than one
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? percent of all torque wrenches were ever found to_be out of
calibration. Since an out of calibration torque wrench is such
'an unlikely occurrence, an unreported use of an
, out-of-calibration torque wrench would be more unlikely.
, In' summary, the NRC substantiated the allegation that torque
. wrenches 1were not always used to install and at times set Hilti
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; bolts as required by B&R Procedure CEI-20. This failure to
comply with procedural requirements is a violation
'(446/8612-V-02). ~ The use of ordinary ratchet wrenches to set
, the bolts does not appear to present a concern with respect to
:over-torque of bolts, since the specified torque values are
minimus' values and a significant margin exists above these
values. The alleger's concern of improper maintenance of torque
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wrench issue / record cards could not be substantiated.
(3)~ Hilti Bolts
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It was alleged that Hilti bolts were installed in contact with
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.rebar in approximately 25% of the installations. During
drilling of holes into concrete for Hilti bolt installation,
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rebar was occasionally exposed in the hole and subsequently the
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Hilti bolt was installed in contact with the rebar.
B&R Procedure CEI-20, Revision 9, covers the installation of
Hilti bolts, and specifies that holes shall not be drilled into
- rebar unless a' proved by the engineers; however, the procedure
1- does not address the case of rebar being exposed in a hole, and
the subsequent installation of a bolt in contact with the
exposed rebar.
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Since the manufacturer's catalogs did not contain any guidance
on this subject, Hilti, Inc., was contacted by the NRC to
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determine the acceptability of such a configuration. A response
j_ received from Hilti, Inc., on June 25, 1986, stated that rebar
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does not create installation problems. If the embedment, skew,
L and minimum torquing requirements are met, all of which are
' verified by QC, there is no problem with Hilti bolts installed
in contact with rebar.
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While the allegation was neither specifically substantiated nor
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refuted, it was concluded that the installation of Hilti bolts
- in contact with rebar does not represent an unacceptable
installation.
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(4)fMateNa1' Traceability
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.It was_ alleged thatIterminal block mounting material in the
- Unit:2 reactor building was'not necessarily of traceable
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A material;as required.' _ Heat numbers were allegedly not .
,% < : transferred when this material was cut up and this materia 1Jwas
< ~M , callegedly salvaged from other areas of the plant when supplies
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'ran short.^
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LThe NRC' inspector: examined purchase orders (P0s) and
ispecifications to determine what this material-was and any
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.- requirements to which it must conform. The material in question
;was Veidauller Assembly Rail,~ Type'TS-32, Catalog No. 1226.0,
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y - . procured under P0s CPF-12897-5land 35-1195-30092. These P0s
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. Lreferenced the B&R' specification for. Class 1E terminal blocks
E - - idated October 19, 1978, and Revision 1 dated August ~22, 1979.
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The alle'ger believed that"all. material placed in the reactor
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but.1 ding must be traceable with heat number, etc. This belief
'is not, however, supported by requlatory requirements. This
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1 material.was procured as~a catalog item and no requirements for
traceability were imposed or required by the B&R specification.
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If the material in question was furnished with heat numbers'on
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it, the , identification markings were beyond the requirements of ,
, . thefspecification. All of this material was purchased under the
; -same requirements per the above P0s and specification.
Therefore,-salvaging this material from one area of the plant
., ,
for. use in another area was of no consequence. ;
-In summary, the allegation was not substantiated since there
14 , -exists no traceability requirement for~ the material in question.
- (5) Protective Coatings
C , It was alleged that Nelson studs, which were reworked or
'
. relocated in the Unit 2 reactor building, were not painted prior
.
to attachment of supports.
'
'
'Gibbs & Hill (G&H) Specification 2323-AS-31, Revision 4,
,
addresses protective coatings in the reactor building.
Sectionl1.16 of this specification states that exposed surfaces
t rendered inaccessible during construction shall not require
field protective coating application. When Nelson studs are
reworked or relocated, it is necessary to remove protective
,
coatings in the area of the studs. If an attachment is then
installed, the portion covered by the attachment becomes
-inaccessible ~(i.e., no longer an exposed surface) and does not
. '
reouire the application of a protective coating; however,
' protective coatings are applied to the remaining exposed areas.
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sBasea'on reviews of records.and. interviews with field personnel,:
f/M u. ~the NRC: inspector found that the rework'or. relocation of Nelson
> >
. F'- y. . studs is notra common occurre'nce. It was also noted that when
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isuch. modifications were necessary, protective coatings were not
e app 1_ied before attachments were made in some~ instances, but:in
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Levery instance protective coatings were applied to exposed areas
safter completion of construction activity.
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iWhile~the' allegation was substantiated, it is concluded that the
L'X7$4 ~
. lack of protective coatings ~on the inaccessible areas described
e above present rd discrepancies or departures from procedural
_
' '
,p :commitaents and requirements.
(6)i NEMA Type'4 Enclosures in Unit 2 Reactor Building
~
,,
'
, .It'was' alleged.that National Electrical Manufacturers-
"
: Association (NEMA) Type'4 enclosures (i.e., junction boxes,
t
c : cable. pull boxes) had been installed without covers attached and
4
V -
: subsequently the covers were lost. Covers from NEMA Type 12
~
enclosures were then' allegedly modified and installed on the
'J -
'
' NEMA Type 4 enclosures.
..
' ~ .'
1 Both'G&H Electrical Erection Specification 2323-ES-100,
. Revision 2, Appendix B,:Section 1.6, and B&R Procedure ECP-19A,
" Installation of Class IE Conduit Raceway Systems," Revision 2,
'
:Section 3.6.1, require NEMA Type 4 enclosures in the reactor
- building. 'According to-NEMA standards, a Type 4 enclosure is
'
,
~
. intended for indoor:or outdoor use to provide a degree of
. protection against windblown dust and rain, splashing water, and
y hose-directed water. A Type 12 enclosure is intended for indoor
.use to provide a degree of protection against dust, falling
'
dirt,,and dripping noncorrosive liquids. Type 4 enclosures must
be tested and evaluated by an external icing test, hosedown
'
' test, and rust resistance test per NEMA standards. Type 12
enclosures must be tested and evaluated by a drip test, dust
test, and rust resistance test per NEMA standards.
NEMA Type 4 enclosures were procured under various P0s with each
requiring, among other things, a Certificate of Compliance from
the vendor certifying the materials conform to the
,
specifications.. These certificates were furnished with the
-
.
equipment.
.
> Field' inspection by the NRC verified that some NEMA Type 12
covers had been modified to fit NEMA Type 4 boxes. This
o" modification apparently occurred in an uncontrolled manner,
without a procedure for the modification and with no test or
certification that the modified enclosures met the requirements
for NEMA Type 4.
,
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' The allegation vas therefore substantiated and constitutes ~a
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. violation'(446/8612-V-03).
P Control of lStainless Steel Conduit-
J
' (7)
.
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.
_It was alleged that stainless; steel flexible conduit was cut-
B , with the.same~ blade that was used on galvanized or carbon steel,
thus impregnating the stainicss steel with impurities.
'
Section 2i20.5 cf b&H Electrical Erection s . Specification 2323-ES-100. Revision 2, states, "Any tool used cn
L stainless steel materials shall net be contaminated witn
particles from other materials." Section 3.6.1 of B&R
,
.. . Procedure CP-CPM-7.3, Revision 1, " General Fcbrication
*
Procedures," requires tools used on stainless steel materials to
be designated for cuch usage and not t.t Le used on carbon steel
materials.
The NRC inspector interviewed six indiviouals invoked in
A conduit installation who confirmed that the same saw was used on
'
stainless steel flex conduit as.on other materials. An
~ inspection of' electrical fabrication areas confirmed that no saw
existed for use on stainless steel exclusively.
The allegers concern was' substantiated and constitutes a
' violation (446/8612-V-04).
(8) Construction Drawings
It was alleged that conduit routing (E2) drawings were not
always used for installation of condait, but rather conduit
numbering (FSE) prints were used. Foremen allegedly instructed
crews to install conduit using FSEeprints kept by the foremen .
rather than obtaining the apprcpriate E2 drawing from the
document control center.
The NRC inspector examined several E2 and FSE drawings. These
drawings are similar, in that the FSE drawings show the general
location of the conduit and provide numbers for conduit and
junction boxes, but no dimensions. The E2 drawings show a
minimum number of dimensions and provide the route a conduit run
should take. The E2 drawings are revised when a change in
E routing is made and are for construction use. The consequence
of using an FSE drawing for construction could be improper
routing of conduit. This is checked for by QC utilizing the
current E2 drawing as well as during design verification by
engineering when a conduit run is complete. These measures are
sufficient to discover improperly routed conduit.
The alleger had stated that the problem was promptly corrected
_ after it was brought to the attention of the project manager.
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- lThe NRC was not able to contact this' individual, but six other
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; persons,-including one' manager, were interviewed. None could
QQr j ' . f - recall .ever.either using FSE drawings for construction or being
md iN Sinstructed,to do so. . The_NRC inspector found no FSE drawings
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, being:used'for construction.
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' w ONRC inspeator findings indicate-that this practice, if it ever
1 occurred inuthe past, is no longer in use.
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$Pm f - 4 /(9)':Trainingi
_ _
_
@ ~1t was alleged that training record sheets for newly hired
"% -- electrical!parsonnel were signed without verification that
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training had actually occurred. New hires were allegedly given
-
. ' copies of procedurer to read without supervision, then the
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-
'; ' foreman would allegedly' sign the " instructor" block on the
- f- ' training record sheet when the employee reported to him, with no
9 <
_ verification that the new employee had acttally read the
procedures. The alleger was concerned that this may be a
_
J, , falsification of training records.
'
'
5 - LSection 2.3.1 of B&R Procedure CP-CPM-2.2, Revision 4, " Training
t. : of Personnel in Procedural Requirements," allows' training to be
'
6'
'
presented by any of three methods; orally by the cupervisor,
,
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copies provided each person to read, or formal classroom
-instruction. :Section 2.5.2 of the same procedure states, in
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- part., "The form shall be signed by the person administering the
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'
training . . . ." The fact that persons reading copies of
!o procedures have no'" instructor" is not addressed.
The NRC inspector. examined training records from 1985 for ten
'
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V individuals in the electrical department. Several training l- record sheets had a foreman's signature entered as instructor ' '
.
when an individual had read copies of procedures as alleged.
* Each record also contained a test for the general area an
j- individual was to work; i.e. , electrical raceway installation, p cable pulling, etc. Formal classroom training in a given
, subject area followed the initial reading of procedures by an
L individual. l- , i Two electrical department instructors and six electrical craft
persons were interviewed. It was determined that the current
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training program includes reading of procedures for familiarity
and then formal classroom presentations on each required subject
~'
for newly hired personnel. Each of the individuals recalled
, reading copies of procedures as new hires before reporting to L
'
their foreman, but none were aware of, or suspected, any
l- falsification of training records. The NRC inspector observed g
-
'
that reading of procedures is now proctored, and foremen no
'
longer sign training record forms. -
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/Aispecific concera of~the alleger was.that'an individual who
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'o for =this individual. show he -failed the initial written' test in
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examinstions,-which suggests that.some comprehension of English
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Another concern was that. newly hired personnel:were not being
itrained in the use of.2323-S2-0910, which is a series of
1 _ > ~ drawings;of-generic'and-specific conduit and junction box
y se supports and accompanying-notes.- Section 2.2.6 of B&R
P
,
Procedure ECP-19A states the' general notes found on these
~
,
; _ drawings are for engineering purposes only and are not
- applicable to construction. Therefore, there was no need to
-
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,
Ltrain craft personnel on the contents of the general notes. The
~N RC inspector found the electrical training program to include a
, ' number of 2323-S2-0910 drawings and instructions on how to read
-
information on these drawings. ,
M
'
In summary, this allegation was not entirely substantiated.
Though not specifically prescribed by procedure, the practice of
, unproctored reading and signing of training records by foremen
is regarded as weak. However, the current electrical department
. training program in effect since mid-1985, includer both
.
-
-proctored reading of procedures by individuals and classroom
- '
instruction. Although some training records with foremen's
signatures as instructor were found, this did not constitute a
~-
falsification. If the foreman had any doubts about an
'
individuals training, it was the responsibility of the foreman,
in accordance with Section 2.6.1 of B&R Procedure CP-CPM-2.2,
Revision 4, to ensure compliance with training requirements.
'
(10) QC Inspection of Conduit Runs
It was alleged that QC inspectors would sometimes use a craft
" ,
..
" helper" to perform inspections in hard to reach areas. It was
also alleged that craft persons performed rework during QC
I
,
-
inspections rather than QC noting a nonconforming condition on
, an inspection repurt.
"
The NRC inspector, during review of operation travelers in
Section (1) above, noted a number of inspection reports which
identified nonconforming items. There appeared to be no obvious
, lack of QC identifying and documenting nonconformances during
inspections.
1 Six individuals'from the electrical department were interviewed
i to determine the extent of their involvement during QC i ,
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ex { f . inspections and their perceptions and knowledge of QC activities R< and responsibilities. A craft " helper":'usually' accompanies a QC fn inspector.to assist in locating specific items to be inspected.
Each'of-these-individuals stated that QC inspectors always
personally verify items on inspections, regardless of where or
'
. Swhat it'is. Additionally, no person interviewed recalled ever
, performing rework-during QC inspections. All persons
interviewed were' aware of basic QC responsibilities and
- ; <- generally perceived the QC~ organization to perform' independently
and as required.
:In conclusion, nothing was discovered by the NRC inspector which
suggested improper conduct by QC or craft during inspections,
. and the allegation therefore, was not substantiated.
(11) Departure from Desian Drawings
1
'It was alleged that craft _ personnel changed conduit support
u
.'.
: types and locations without prior approval from engineering.
Engineering was allegedly notified after the fact via a Request
For. Information/ Clarification (RFIC). The alleger further
'
stated these-changes would then be incorporated on a revised
t . 4 isometric drawing without an engineering evaluation. Specific
"
' areas of concern were:
'
.
(a). Junction Box JB-244G support base plate was allegedly
'
changed from 3/4" to 1" thickness without engineering
' ~
authorization and not in accordance witn the support
-
: drawing. Additionally, welding was allegedly performed on
this support while cables were pulled inside the junction
(
,
box. The cables were allegedly pulled out of the box after
the work had been performed.
(b) Conduit C24K12074, a 3-inch diameter conduit, was to have
-
been reduced to a 2-inch diameter at panel CP2-PSMEPS-04
per an engineering answer to an RFIC. A foreman allegedly
ignored this engineering decision and ran 3" conduit into
the panel which resulted in a modification to a piece of
vendor supplied equipment and a violation of electrical
separation criteria.
Departures frcm cesign drawings are addressed in B&R
Procedure CP-CPM 4.1, Revision 0, " Construction Requests for
' Engineering Design Changes," which states that work activities
must be suspended when design documents cannot be complied with.
A design change must then be requested from engineering (an RFIC
form is commonly used for this) and work may resume after
receipt of the approved design change document.
'"
The NRC inspector examined approximately 50 RFIC files from 1985
to determine the type of requests made to engineering from
*
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craft. 'A number of these contained statements which indicate
: craft had made changes before initiating an RFIC to request a
i ;
,
design change from engineering. Examples are:
' ~
I" . RFIC No. 963'(February 7,.1985): "Need iso revised;
supports no._1 & 3 are.CSM-6C and No. 6 has 3/8-inch
-
HKB's."'
.
'
. RFIC No.~970 (February 8, 1905): " Support No. 4 is a
CSM-7J on the iso, actual is CSM-12C."
. RFIC No. 1415-(March 13, 1985): " Craft requests iso
revision to.show changes in support materials and
dimensions."
. '
. RFIC No. 1509 (March 19, 1985): " Conduit had to be
re-routed. Iso needs to be revised to show changes made in
the field."
The operation ~ traveler and support drawings were obtained for
4
Junction Box JB-244G. From these documents and a physical
' inspection of the arrangement, the NRC inspector determined the
baseplate thickness had been' changed with no apparent
engineering involvement. The installed baseplate is 1" thick,
-which was shown on Revision 3 of the support drawing dated
January 6, 1986. However, the 1" thick baseplate was welded on
November 6 and 7, 1985, and the support drawing in effect at
that time (Revision 2 dated November 1, 1985) called for a 3/4"
thick' plate.
A review of QC inspection reports showed approximately half the
cables were removed from Junction Box JB-244G on October 29,
1985, and the remainder removed on November 6, 1985. Welding
was performed on the baseplate, which is located approximately
12" above the junction box, on November 6 and 7, 1985. All
cables were replaced on November 7, 1985. Because of the
overlap of cable pulling and welding on the same' day, it is not
possible to conclusively prove that the operations occurred in
the order assumed by using sound engineering and construction
practices. However, a physical inspection by the NRC inspector
showed no indication of any type of damage to the cables and
*'
aprovided no reason to assume that cables were in the junction
box during welding.
In summary, sufficient evidence was found to substantiate the
allegation that changes have been made to condui" and junction
box support types and locations without prior engineering
approval and without the cppropriate design documents. This
failure to comply with B&R Procedure CP-CPM 4.1, Revision 0, is
a violation (446/8612-V-05).
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- Al'thdugh notia safety-related item, the NRC inspector followed
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-
up:on the allegation concerning conduit C24K12074 termination.
LThe NRC inspector learned that a:2" hole had been cut into
.
ipanel CP2-PSMEPS-04 and when craft attempted to run the 3"
~e n conduit, engineering was contacted for a resolution. The
ni engineer' initially specified reducing the conduit to 2" at the
: - -
panel; however,-the number of cables involved required a 3"
-condui_t'and craft supervision was informed verbally to aisregard
the initia1' engineering resolution and insta11'the 3" conduit as
'
: originally specified.- This did not constitute a violation of
engineering'or design documents, since the initial
~
recommendation was wrong and engineering remained involved in
its resolution.. The NRC inspector checked the separation
1 '
requirements of the actual installation and found no separation
-
. problems on this conduit.
'
. The alleger's concern as to whether changes requested by craft
are evaluated by engineering, was based on the perception that
changes made in the field were simply accepted without any
;
'
engineering evaluaticn and incorporated onto the isometric
'
: drawings. Section 2.3 of TUGCo Procedure TNE-FVM-CS-002,
Revision 1, " Design Control of Electrical Conduit Raceways,"
, requires any revision of.these isometric drawings to be design
. fverified. Design verification, per Section 2.7 of the above
.
procedure, occurs after-QC has satisfactorily inspected the
installation and consists of calculation preparation and
checking and approving of drawings. The formal evaluation thus
n ' occurs after all changes affecting a conduit run are complete,
L including incorporation of the changes on isometric drawings.
'The. allegation was therefore not substantiated.
(12) RCP Motor Junction Boxes
'
It was alleged that covers had been left off the junction boxes
on the Unit 2 reactor coolant pump motors which allowed dust and
moisture inside the pumps and may have damaged some electrical
insulation.
The NRC inspector found all four of the Unit 2 covers in
,
. question to be in place. Covers were removed from two of the
L junction boxes for inspection. The interior had dust
throughout, but no damage to any electrical insulation was
observed. The bus bars going into the motor were sealed at the
-
rear of the junction box, so there is no path for dust or
moisture into the motor. The cables carrying power into the
- f, junction box have not been terminated, so more work is to be
performed inside the junction box before cleaning and closing
,
the box.
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,i ;In' conclusion,-while the' covers'may_have been left off at some
_ 1 point,(such:an action'did not'_ violate;any requirements.and
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kmvm 1 1(13) Electrical Separation-
'
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; ;Threel speiific' areas!of: concern werh alleged to have electrical
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separation violations... Separation criteria are defined.in
.
Of i 1 ' Section 4.11 of G&H Electrical Erection -
gpyg y- ~ ; ; _
Specification 2323-ES-100,~ Revision 2.
e> ,m ~
.
~
TConduit C24812521 was alleged tofhave been routed such that'it'
f 'vi_olated separation requirements. This conduit is located in
W % ~' the' Unit 2 reactorLbuilding at elevations 830 feet and 860 feet.
Il '
- The;NRC inspector; walked down this conduit run and found no
electrical-separation problems.
~
j . . _
.
,,
>
m Conduit C24K12074 was alleged to;have been routed such that it
. '
violated separation requirements. This conduit is a Unit 2
instrumentation conduit and is consafety-related. However, the
>
NRC; inspector walked down this conduit and found no electrical-
lf * r'
,
'
-separation problems.
'
' ~"
:ConduitlC23810279, located in the Unit 2 safeguards building was
.
- ..allaged to violate separation requirements. The safety-related
: , -Train A conduit was in fact located less than three feet above a
-safety-related Train B cable tray and, therefore, violated
~
p ,
-
, ~ separation requirements. This fact had been identified and
,
. documented by QC on Inspection Report (IR) 2-0075337 dated
.- , -October.19, 1985, and both the conduit and cable tray had been
+ . tagged =by QC.
'
,
Inis_ummary, one of:the examples.provided by the alleger did
@i < '
present a violation of electrical separation requirements;
,'
however, this had been identified by QC. No violation of NRC
7
'
requirements was found.
4'
4. . Assessmant of ERC's Overview Inspector Qualifications and Verifications
a
. The purpose of~this NRC inspection was to determine whether ERC overview
, .
'
"-
inspectors were qualified and certified in accordance with the procedure
governing the certification ~of inspectors, CPP-003, Revision 3, dated
~
December 10/ 1985, " Indoctrination Training and Certification of
,' Personnel." Ten overview inspector training, qualification, and
,
. ' certification files were reviewed for conformance to CPP-003 and the
referenced requirements. Of the ten files reviewed, two were inactive.
n. Elements covered in this review were certification policy and
applicability, determination of inspector capability, certification, and
m records.
.
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a'.i #C ertification-Policy'and Applicability
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'QA/qcreviewteampersonnelconductinginspections, examinations,
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and/or tests shall,fas' required; (1) be' certified in accordance with
d W. s , 3:the applicable. requirements of NRC' Regulatory Guide 1.58, Revision 1,
.g "A S1980~, which. endorses ANSI.N45.2.6, 1978,'" Qualifications of
r ~ 1" j ' Inspection,' Examination, and: Testing Personnel for Nuclear Power
Q' c , Plants";c(2) complete prescribed training and testing; and
& ((3) provide evidence of. demonstrated proficiency'as required by
R 7- CPP-003.~
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.No violations or deviations ~were-identified.
_
'
Determination of Inspector Capability-
~
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jg, ~ % Ncap' abilities / of'a candidate for certification are required to be
. initially ~deteruined by evaluation and verification of the
'
' '
. candidate's education,-experience, indoctrination, training, and
s- ,- = confirmation of objectivity.
' ~
'
; Procedurally,"the. education and applicable experience of 0A/0C review
T.- ' _ ' ~
: team personnel implementing QA/QC ISAPs is to be verified in a timely
( x ; manner. :For ERC direct hires, either. letters are prepared or
.
' telephone-interviews conducted to verify education and experierce.
'
.
_
'
. Returned letters and memoranda of telephone interviews are used to
: '/ s document. verification results.' In the case of individuals obtained
.. '
from' suppliers of contract support personnel, rather than direct
.
J -hire, the supplier is required to verify education and experience and
M '
,
, furnish supporting documentation of verification results. Both ERC
and~ vendor supplied verfication results.are transfered to an ERC
Education / Experience Verification Summary form. Of the ten files
'
, ' evaluated,:three contained verifications by Stone & Webster (S&W), an
'
approved supplier. The ERC audit used to approve S&W was reviewed
< and found to'be acceptable.
E _
. -
"
The review team leader reviews and approves the Education / Experience
"
i Verification Summaries as final assurance that the candidates meet
-the applicable requirements of Attachment 6.4 of CPP-003. NRC review
4
-
'of these files disclosed tnat one inspector's verified experience did
[ '
, not conform to the prescribed requirements of Attachment 6.4. This
failure to properly verify the experiance of an inspector is a
s
1
deviation (445/8615-D-01).
The QA/QC review team personnel implementing QA/QC ISAPs are required
'
to be given timely indoctrination in the responsibilities and
i objectives of the CPRT. All ten files contained documented evidence
of timely indoctrination.
.
.
. The type and scope of training provided to inspectors are determined
,
by the individual's supervisor. Additional training to pass ._ .
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; certification. testing'isLalso determined by the-QC supervisor.
Os s. . -Training is comprised of assigned reading, class. room training,.
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;land/or_on-the-jobtraining'(0JT).
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(Eacl(inspectorisassignedalistofrequiredreadingmaterial.
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Depending on job assigneent, the supervisor determines _what
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Ladditional: reading material.is required; e.g,, plans, procedures,
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. . instructions, and reports. Completed assigned reading lists were
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, : contained in-the' files rewlowed. _
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EachiNspectsr,inc1udingothermembersoftheQA/QCteam,is
Jrequired.to complete a CPRT Objectivity Questionnaire.- This
~
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_
iquestionnaire'is used to identify any conflicts of interest which
, -
could; affect the inspector's objectivity in the-performance of work
-
~ assignments. .All reviewed questionnaires were completed and no
fM, . conflicts were noted.
' '
'
'
,
-
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-c.'- Certification'
'a ,,
: Level II inspectors'are certified by ERC Level III inspectors or the
- '
.
-QA/QC inspection supervisor. = Level III inspectors are certified by
the ERC QA-manager. . Prerequisites 'to certification are successful
f
'
4 . completion'of required training and testing and the assessment of
L.f . m personnel capabilities (education and experience). It should be
sa
,
-
,-
noted that'the 0QT raised a concern to the senior review team (SRT)
c ..
'
-
regarding ERC's practice of certifying inspection personnel prior to
' ,
fcompletion of personnel education / experience verification. The NRC
J' w-
:will follow the SRT's resolution of this issue as'an open item
.
, (445/8615-0-02).
6. : d. . Records-
h
'
'
Thel indoctrination, training, and certification files reviewed were
,. found to contain, as applicable, the records and documentation
-
, ' required by CPP-003. Records were stored in a secured file cabinet
n 'with' limited access, and were readily retrievable.
,
.
;
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, :No. violations or deviations were identified.
. Summary:
1 Records and documents reviewed for the indoctrination, training, testing,
: ?and' certification of overview inspectors were found to be developed,
: processed,_and_ completed in accordance with requirements. The exception
,
'noted was a deviation regarding the one occurrence of using unrelated
'
experience to certify an overview inspector. The practice of certifying
. inspectors prior to verificatten of previous education / experience has been
u . presented by the 0QT to the SRT for resolution. This issue will be
l.' tracked as an open item. No other violations or deviations were
'
, identified in this area of; inspection. _.
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15.: Overview Inspection
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' NRC inspectors have inspected a total of 22 overview verification
packages. The following 11 packages were inspecteo durihg this report
period:
27-I-M-L6CO-129
'33-I-M-MEIN-003
33-I-M-MEIN-034
*44-I-M-MEIN-035 ,
34-I-M-MEIN-065
29-I-M-MEIN-073
34-I-M-SBCO-004 s
12 I-M-SBC0-078 '
_
25-I-S-PS7N-079
20-I-S-PS7N-095 -
23-I-S-PS7N-149 '-
*The initial ERC reinspection was identified as unacceptable by the ERC
overview inspector.
NRC inspectors identified the following conditions:
a. 44-I-M-MEIN-035: The NRC inspector identified an anchor bolt with a
1/4" gap between the nut and the bearing surface. Subsequent NRC
. review of the overview inspection package revealed that the ERC
overview inspector had issued a DR for this condition.
b. 12-I-M-SBC0-078: During an NRC inspection, one instance of a pipa
.to pipe clearance violation of Section 5.2.U.2 of QI-026, Revision 3,
was identified. However, the initial ERC reinspection as well as the
overview inspection failed to identify this condition. The details
of the NRC inspector findings and the separation violation are
discussed in paragraph 7.d. This inspection perfonnance is considered
a deviation (445/8615-D-03).
c. 20-I-S-PS7N-095: A DR was issued by the initial ERC inspector for
unsatisfactory pipe clamp halves' parallelism. Attachment 6.1 of
.QI-037. Revision 1, specifies acceptance criteria and states, in
part, 'S dimensions on the same side of the clamp at points 1, 2, and
3 shall be within 1/16" of each other . . . ." Measurements are
recorded for each side of the clamp (S1 and S2) on Attachment 6.1 of
the verification package.
Measurements for S1 recorded by the initial ERC inspector showed a
difference between points 1 and 3 of 1/8", which is 1/16" out of
tolerance. Similarly, measurements recorded for S2 showed a
difference between points 1 and 3 of 5/32", which is 3/32" out of
tolerance. However, the ou.t-of-tolerance values recorded on DR
No. I-S-PS7N-095-DR1 were 1732" and 1/16", respectively. The DR
incorrectly identified the degree of the out-of-tolerance values, and
.
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*
1
22
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the overview inspection failed to identify and resolve these
y discrepancies. This inspection performance is considered a deviation [ (445/8615-D-04).
6. CPRT ISAPs (Excluding ISAP No. VII.c)
,
a. Inspection Reports on Butt Splices (ISAP No. I.a.2)
r. ) Inspection of Cabinets which contain No Butt Splices (NRC
(1)
Reference No. 01.a.02.07)
- The NRC performed inspections of five of the 38 cabinets,
previously inspected by ERC, that were not supposed to contain
'
butt splices. The following Unit 1 control room and cable
spreading room cabinets were inspected:
Cabinet No. Drawing No. & Revision
CPI-ECPRCR-11 2323-El-0179, Revision 3
CPI-ECPRCR-16 2323-El-0080-07, Revision CP-1
2323-El-0080-08, Revision CP-1
CP1-ECPRCR-18 2323-El-0166, Revision CP-7
CP1-ECPRTC-11 2323-El-0172-11, Revision CP-2
CPX-ECPRTC-02 2323-El-0172-52, Revision CP-5
Cable bundles were opened for these inspections and no butt
splices were found. This inspection completes NRC review of
ISAP activity number RT-01.a.02.07.
No violation's or deviations were identified,
b. QC Inspector qualifications (ISAP I.d.1)
(1) SET Evaluation of ASME and non-ASME Inspector Qualifications
(NRC Refer'nce No. 01.d.01.03)
During this report period, the NRC inspector reviewed 10% of the
non-ASME inspector qualification files against the ERC Phase II
summary sheets and attached information from TUGCo. The files
were selected to include inspectors who had been identified
during previous NRC inspections to have had deficient
documentation. Also selected, were files identified in Phase I
of the ISAP to have had a large number of deficiencies in
documentation.
The files were reviewed for level of verified education and
experience, sufficient 0JT hours or justified waiver, acceptable
examination results, completion of required reading and
y training, completed training outlines, acceptable eye
.
examinations, timeliness of recertifications, and overall
~
quality of documentation including appropriate signature
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review team:was found for all'of the above attributes except for
~
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two items.--The NRC inspector noted'that some of the electrical
._ inspectors certifications had lapsed before being reissued. This
>
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- -
: lapse' varied in length from~a few' days to over a week. In all
fcases;noted, subsequent recertification was made. The ERC.
~' i ~ review had'not evaluated the lapses in certification for-these
= inspectors. .The NRC inspector additionally found that an
*
..
- ' , . electrical inspector's recertification to CP-QP-11.3 had failed
-
_
'
'to11dentify'the specific activities or restrictions included in
(the recertification. ERC's failure to' identify these
"
.
'
Ladministrative-errors'is a deviation'(445/8615-D-05;
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>
,4 .446/8612-D-06).
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/These administrative errors.were brought to the attention of the
. s
quality, training. supervisor and have been corrected. The
.. , quality training supervisor stated he had previously initiated a
-
-
review of the TUGCo non-ASME file for certification lapses and
4 <
, that the review was ongoing.
'
-
~ ic. Maintenance of' Air Gap-Between Concrete Structures (ISAP No. II.c)
- JThe following activities for ISAP No. II.c were reviewed by the NRC
.
inspector during this' report period:
...
:(1) Reins?ect and Assess As-Built Condition (NRC Reference No.
"
'02.c A1.00)
'
#
' Nonconforming conditions have'been identified by TUGCo during
,
'
reinspection and removal of. debris from the seismic air gaps.
TUGCo.Nonconformance Report (NCR) C-85-1017785 addresses cracks
o fin the exterior east wal1~~of the fuel building at the
.: intersection of line CF and the Unit 1 reactor building near
'
860' elevation. The cracks were discovered during removal of
concrete in the air gap and were subsequently examined by the
^ ^
' NRC inspector. An evaluation by TUGCo including " Interviews
Associated with NCR C-85-101778S," indicates that the cracks may
have occurred during~ pressure testing of the Unit 1 containment
due to' relative displacement between the two buildings. The air
. gap was bridged at this location by concrete approximately 6" in
depth resulting in stresses in the fuel building wall. The
exterior wall at this location was repaired and TUGCo performed
inspections of other locations where the combination of pressure
testing for the Unit 1 containment and concrete bridging in the
air gaps could have resulted in wall damage. No additional
damage was identified.
Additional nonconforming conditions identified by TUGCo during
gap inspection and debris removal included: (1) small voids and
, ,
honeycombing in the concrete; (2) irregular concrete surfaces;
, ,
(3) metal flashing, wood and other debris in construction
'
.
24
~ joints; (4) localized areas with exposed rebar; and b _(5) improperly installed water stops. The NRC inspector T physically examined several of the nonconforming conditions
addressed by TUGCo NCRs C-86-102432, C-86-101455, C-86-101767
/ and C-86-201602. In addition, the following TUGCo NCRs related
'
to the.above conditions were reviewed by the NRC inspector:
,
C-85-100458 C-85-101778
1 C-85-100459 C-86-101455
C-85-100460 C-86-101767
, .C-85-100461 C-86-102432
C-85-100462 C-86-201600
M-85-100463 C-86-201601
C-85-100467 C-86-201602
'
C-85-100520
The significance of these nonconforming conditions will be
evaluated and documented by TUGCo in the NCR dispositions.
(2) Removal of Debris or Rotofoam (NRC Reference No. 02.c.02.00)
) j The NRC inspector witnessed ongoing cleaning and repair ' activities for the seismic air gap during this report period.
The NRC inspector also observed the use of a new high pr. essure
water jet system recently purchased by TUGCo.
(3) Analyze Final As-Built Condition (NRC Reference No. 02.c.03.00)
!
The NRC inspector reviewed the following G&H calculatio. , during
this report period: -
.
LIS-100C, Set 3, Revision 0, Effect of Elastic Joint Filler
Between Containment and Safeguards Building, Unit-1, During
'
a Seismic Event. l
.
LIS-100C, Set 17, Revision 3, Minimum Required Gap Between
the Secondary Walls and Floors Above Them.
The methodology and assumptions used were compared against the
design commitments contained in Section 3.8 of the Comanche Peak
FSAR. Numerical calculations were spot checked. .
!
NRC inspections were not performed on other activities during this
report period.
No NRC violations or deviations were identified.
d. Onsite Fabrication (ISAP No. VII.b.1)
._
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During this report period, an unanno'gunced inspection of activities of
the onsite fabrication shop was condu'ted c to assess compliance with
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T / control,4 fabrication; QC.., inspection land; specific NRC Technical.
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lReviewTeam;(TRT)Tconcerns;on thread verification.-
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:-NRC, inspection of(document'controlswasilimited to use of controlled
Mjxpf M idrawings'and material; requisitions L(MR).c. The NRC inspection .of 50 - ~
N M s ; is, Unit?1 controlled drawings, issued on an extended basis'to the
wgF 1 ' Vfabrication shop ffound them to be current to the latest. revision and
a,7
,
. : complete.with 'all applicable design changes. .The Unit 1 paper flow -
.'_ q7 . "M, % 3 group -(PF6),f responsibleifor maintaining these drawings, did not have ,
La procedure: detailing how:this.. activity was:being accomplished. The-
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, gfailure)to h'veLprocedural a controlsifor this' activity is.a violation
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Review ~of Unit'2 procedures showed that the'. Unit 2 PFG had procedures
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Ltoicontrolfthe Unit 2 drawings issued on an extended basis.
.
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]#, ? ' ' During inspection of the fabrication _ process, the shop foreman was % - W .s 4 . < ,
g ['6- xinterviewed and/Tound. knowledgeable of the shop procedures and-the
activities they ccitrolled. -He'was also familiar with the applicable
-
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.
s %' m -lQC procedures dnd required-QC' inspections. He was not. familiar with
*- f ithe procedures which provided document control.. While shop foremen
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.
.are not; responsible for this activity, knowledge of document control i
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pFocedures appears desirable in this area of supervision.
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ae i~ _. LDrawings for both' units wereIninspected
^
for notations added to the i
5 _ , S. idrawings in penci1~or ink. all cases,'these. notations were found ,
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'A ot have been added by.the craft or the foremancas reminders to
" facilitate fabrication rather than as design modifications'.
, , ~, -
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^ (The^ NRC inspector witnessed a QC inspector-properly transferring heat ,
"
4 numbers and. material identity for a steel .bar being cut into :
4*L / sections; The absence of. thread verification activity precluded NRC
- " - *' witness during this inspection. Based on interviews of personnel, '
"
-
' '
'both craft and.QC were found to be aware o 'f thread verification,
X _
'
requirements.' ,
s: The--fabrication shop identifies fabricated components by stamping
7
,
them with a " Mark Number." QC inspections of.each item are ~
documented on an_IR. To provide traceability to the specific item
[
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N inspected, the = inspection repert number tis stamped on the item when
F ,
inspection is complete. However, no procedural requirement exists to
. . control- this activity. This lack of procedural controls is
consideredaviolation(445/8615-V-07;446/8612-V-07). .
-
L
,, , NRC review of field generated written requests for fabricated items
<
-found that written requests did not always indicate: whether the
item to be fabricated is Q gr non-Q; ASME or non-ASME; its location;
_'
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- its intended use; or if temporary or permanent status. This
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information is required to assure that proper QC inspections are
L ,,< " performed and material traceability is maintained. Additionally, the
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{for.this activity does not describe what information is required.
'}^'%- mThis lack of ' procedural' controls-is considered a violation
-
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s' . ..(445/8615-V-08; 446/8612-V-08).
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, M7.z ~ISAP'No.iVII.c- E #
,
,
,' ia.' - 4 Electrical. Equipment
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Status of ERC Activity.
4 . ,
N , :ERC ah's' completed 83 reinspections and 83 documentation review
. packages-of sampled electrical equipment as of June 30, 1986. ,
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. Status of NRC Inspection Activity , l
'
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-NRC inspectors have, as'of June 30,.1986, witnessed 11 reinspections,
b, '
'
iperformed independent reviews.of 10 documentation packages and
* *
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performed 6-independent.reinspections of sampled electrical-
*
-
iequipment. .The:following three independent reinspactions of sampled
f e h' .
-
' Unit:1 ele'ctrical equipment'were-performed in this report period:
..
[ = Verification.
'
System Equipment.
' Package Mc. No. 7
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'
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I-E-EEIN-051- Train A CP1-ECPRTC-41
pn . Termination
- n, Rack
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.
.
:I-E-EEIN-075 Train A 1DG-01A
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-
Emergency
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Diesel
L Generator p , L" I-E-EEIN-083 Residual ILCS-5668
Heat
- -
Removal .
$' -
During the above independent inspections, the following
,;J conditions were identified:
'
I-E-EEIN-051: The location of this rack was not as shown on the
drawings. This condition had been identified by ERC and
j ,
DR I-E-EEIN-051-01 was written.
Disposition of the above finding is an open item
-(445/8615-0-09).
'
I-E-EEIN-075: The following three items were observed during
this inspection:
. . , , . . . .
.
_ _ - _ _ _ _
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27
,
, -
1
(1)' The wiring to the interior cabinet light had two PIES -
-
splices installed;
'
-
(2) A jam nut was loose on one of the six, in floor, mounting
bolts; and-
-(3) Relays R12A and R12B were installed, but not shown on
Component Layout Drawing 52383, sheet 2.
' ~
Items (2)'and (3) were not identified by the ERC inspectors and
'were within the scope of QI-010. Failure to identify these
,l-
,
, conditions is a deviation (445/8615-D-10). l
[ No -other violations or deviations were identified.
b. Inspection of Non-Pressure Boundary Welds for a Supplementary
Evaluation of Visual Welding Inspection Techniques
Status of'CPRT Activity
6 CPRT inspection is now complete for this activity. Sixty-two
p randomly selected samples of weld joints obtained from ISAP
Nos.-VII.b.3 and VII.c populations have been inspected. The -
F following two samples were inspected before removal of coatings
during,this report period:
l Verification Equipment- System * Unit No. [ Package No. Tag No.
I-S-NPBW-103 . 2323-MI-0760 HVAC Common (1)
I-S-NPBW-122 RC-2-078-901-C47W RC 2
'
'
~ The following 17 second phase inspections, after removal of coating,
b. . p
were performed during this report period:
.
Verification Equipment Tag No. System * Unit No.
Package No.
'
' 'I-S-NPBW-045 1-TE-S400 N/A 1
I-S-NPBW-110 CT-1-047-007-C92R CT 1
, '
I-S-NPBW-120 CP-X-VAFNCB-06 HVAC Common (1)
I-S-NPBW-083 CC-1-EC-007-013-3 CC 1
o I-S-NPBW-115 FW-1-019-902-C57W FW 1
. I-S-NPBW-101 CC-1-228-007-C53R CC 1
I-S-NPBW-049 FW-1-015-901-557W FW 1
I-S-NPBW-116 SF-X-034-020-F43K SF Common (1)
I-S-NPBW-107 CT-1-008-001-S22S CT 1
I-S-NPBW-112 CT-1-097-402-C52R CT 1
I-S-NPBW-119 CS-1-078-013-C42S CS 1
I-S-NPBW-104 CC-1-RB-033-007-3 CC 1
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I-S-NPBW-122 RC-2-078-901-C47W RC 2
I-S-NPBW-087 CC-1-EC-006-005-3 CC 1
I-S-NPBW-103 2323-MI-0760 HVAC Common (1)
I-S-NPBW-113 MS-002-903/905-C77W MS Common (1)
I-S-NPBW-043 CP2-MEFT1F-01 structural 2
*CT - Containment Spray; HVAC -' Heating, Ventilation, Air-
Conditioning; CC - Component Cooling Water; FW - Steam Generator
Feedwater; SF - Fuel Pool, Cooling and Clean-up; MS - Main Steam; RC
- Reactor Coolant; CS - Chemical and Volume Control
Status of NRC Inspection Activity
The NRC inspector has witnessed 100% of the inspections performed on
welding in the coated and uncoated condition.
No NRC violations or deviations were identified during this report
period.
c. Mechanical Equipment Installation
Status of CPRT Activity
...--
Reinspection of 125 mechanical equipment installation items from the
combined random and engineered sample has been completed. A total of
193 deviations have been identified. Of these, 96 have been
evaluatsd and 70 have been determined to be valid.
Documentation review has been completed for 83 of the 86 combined
..
,. random and engineered sample verification packages. A total of 26
deviations have been identified. Of these, nine have been evaluated
and none were found to be valid.
.
Status of NRC Inspection Activity
<
.
The NRC inspector has, to date, independently inspected six
mechanical equipment installation ite.as including the following five
: packages during this report period:
s Verification Equipment Tag No. System * Unit
Package No.
I-M-MEIN-003 CPI-CCVBST CC 1
I-M-MEIN-034 TCX-TRDMTH DD Common (1)
I-M-MEIN-065 CPI-00ATDT-02 DG 1
I-M-MEIN-073 CPI-MEATAR-03 DG 1
I-M-MEIN-035 CPI-CHCICE-06 H/AC 1
*CC - Component Cooling Water; DD - Demineralized and Reactor Make-up
Water; DG - Diesel Generator and Auxiliary; HVAC-Heating,
Ventilation, Air Conditioning
.
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JDdrin thabiidependent inspection .of[V'erifi.ca'tiion
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%Jf~ y ; l?foundation Package I-M .NEIN-035,
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1 anchor bolt: nutthe was NRC.. inspector
not bearing load identified
and thatthat a 1/4" an gap equipment l
is "~ '
M existed.between the anchor' nut'and the load bearing: mating surface. ' !
?4 w w l Subsequent;NRC' review of-ERC overview inspection documentation
revealed that aniERC overview inspector identified the deviating
_
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A w condition and that'a' DR had been-issued. The disposition of. this ~ " [ h". W sfindingeis fan lopenlitem (445/8615-0-11);
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yV , . ,j ;No'NRC2 viol'ations:o'r deviations"were identified. ^ : rL . .. ..
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d. - Small: Bore Piping Configuration
_,' 1 ~- -
? M JM^f 1 -
- -
-
-
[ Status 'of *CPRT 'Acti$ity -
, fg ERCIhas] completed 98 reinspections of small bore piping.
. ' C ", ;fconfigurations out ofLthe-planned random and engineered sample size
t
j :of-99.' -The' combined sample size, previously 88, was increased in
-
order! to: (1)-~ include:pipingconfigurationsfromthediesel
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; : generator a'ssembly which were inadvertently left out of the. initial
^
j- ; population,t(2) include some. Unit 2 piping which ERC initially .
, m* ' thought:did not have N-5 certification, and (3) add packages to
# _
' ensure'that the attribute' dealing with orientation met the sampling
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_
-
y- criteria of, Appendix D of the CPRT Program Plan,
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gf lSikty-seven validLDRs -have been identified and issued.
"
i Sta'tusofNRC!Inspectibn' Activity
. - w:
-
To date, the'NRC inspector has witnessed seven ERC reinspections and
- performed four independent inspections. The following NRC independent
11nspections occurred during this reporting period:
,
'
.
4
4 Verification ~ Drawing No. System * Unit No.
- '
'
. Package No.
'
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LI-M-SBCO-004- .BRP-CH-1-AB-023 CH 1
1 1-M-SECO-078 BRP-CH-1-SB-014 CH 1
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*CH. - Ventilated chilled water system.
H[
"
During the independent inspection of Verification
- Package.I-M-SBC0-078, the NRC inspector identified an instance where
F 2 .
the separation criteria of paragraph 5.2.6.2 of QI-026 was not met
u,
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-
and documentation justifying this condition could not be located. ' A
.
minimum clearance of 1" must exist between two pipes, including
insulation, when the operating temperature of both lines is below
y .
-200 F. Inadequate pipe clearance occurred just east nf wall C-S and
involved two 1 1/2" lines; one just above and one just below the
L inspected line. Attribute 1.f on the checklist for this verification p package regarding separation was accepted and did not identify this
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condition as a deviation. The failure of the ERC inspector (and the
-
-overview inspector as discussed in paragraph 5;b.) to identify this
.
. condition-is a~ deviation-(445/8615-D-03).
'e . Large Bore Piping Configuration
'
Status'of CPRT Activity-
ERC has' completed 90 reinspections of large bore piping
configurations out of the planned random and engineered sample of 97.
The combined sample s;ze, previously 85, was increased in order to:
* ..
(1) include piping configurations from the diesel generator assembly
-
which were inadvertently left out of the initial population,
'(2) include some Unit 2 piping which ERC initially thought did not
have N-5 certification,.and (3) add packages to ensure that the
attribute dealing with orientation met the sampling criteria of
Appendix D of the CPRT Program Plan.
A Fifty-five valid DRs have been identified and issued.
Status of NRC Inspection Activity
To date, the NRC inspector has witnessed seven ERC reinspections and
performed five independent inspections. The following independent
inspection occurred during this reporting period:
Verification Drawing No. System * Unit No.
Package No.
I-M-LBCO-129 BRP-FW-1-RB-008A FW 1
~
*FW - Feedwater System
No NRC violations or deviations were identified.
8. Overview Quality Team (0QT) Review
During this reporting period, Region IV personnel, assisted by personnel
+: from IE Quality Assurance Branch and NRR, inspected the relationship of
the 0QT with the SRT and the current status of the 0QT program. The SRT
and 0QT personnel described this program and the interfaces and advised
that a documented response to NRR's request for information dated June 9,
1986, was in preparation. This response, as described, would include an
0QT schedule, a revision to the 0QT program, and a more detailed
description of the 0QT scope. Further inspections in this area will occur
after the additional information is submitted.
, - - - . - . -. . -.- - .. . -- .- .-_ - - - .- = _ -
. _ _ _ _
_ _ _ _ _ _ _ _ _ - _ - _ _ - ..
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3
31
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' 9. . Exit' Interview
h! 2.. , E - An exit interview was' conducted on July 9, 1986, with the applicant
representatives denoted in paragraph 1 of this appendix. During this
{c1 ( , "#" . intervior, the NRC inspectors summarized the scope and findings of the g: { inspection. The applicant acknowledged the findings. ( . [- e I. L h I~ p g < I<
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._ _ _ _ _ _ _ _ _ _ _
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