ML20207E195

Rev 1 to Comanche Peak Response Team Results Rept Isap: VII.a.7, Housekeeping & Sys Cleanliness

ML20207E195
Person / Time
Site:	Comanche Peak
Issue date:	11/21/1986
From:	Beck J, Ross G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20207E095	List: ML20207E141 ML20207E163 ML20207E184 ML20207E195 TXX-6184, Forwards Revs 1 to Isap:V.A, Insp for Certain Types of Skewed Welds in Nf Supports, ISAP:I.b.2, Flexible Conduit to Cable Separation, ISAP:I.B.1, ... Flexible Conduit Separation & ISAP:VII.a.7, Housekeeping & Sys..
References
NUDOCS 8701020088
Download: ML20207E195 (36)

Text

j-4 COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: VII.a.7

Title:

Housekeeping and System Cleanliness REVISION 1

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73 N J'

/~ //-20 -({h Issue Coordinator Date

--- II!N 96 ReWew Team Leader Date' /

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John T. Beck, Chairman CPRT-SRT Date 8701020088 861219 S pga eDOCK 0500 A

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, f RESULTS REPORT M

'ISAP VII.a.7 Housekeeping and System Cleanliness

. . 1.0; DESCRIPTION OF ISSUE IDENTIFIED BY NRC 1.1 US NRC-TRT Letter January 8, 1985, Issue 9, Housekeeping and System Cleanliness "The TRT_ inspections at CPSES indicated that the facility was well maintained. However, two issues were identified that indicate housekeeping and system cleanliness deficiencies.

A.. The TRT reviewed the August 6, 1984, draft of flush procedure FP-55-08. The purpose of this procedure was to verify the cleanliness of Unit I reactor coolant loops, including the reactor vessel, by means of handwiping, visual inspection, and swipe testing.

Tests to determine surface chloride and fluoride contamination were performed by TUEC systems test engineers and Westinghouse representatives. The TRT notes, however, that FP-55-08 required only two swipe tests cf the reactor vessel--one on the side and one on

' hr- ' the bottom. Inis lim tee number of swipe tests may not provide adequate assurance that the vessel had been

. properly cleaned.

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l B. In rooms 67, 72, and 74 of the Unit 2 Safeguards i Building, the TRT observed that not all snubbers were

-wrapped with protective covering when welding was being i done in close proximity to them. This practice was a ,

violation of Brown & Root procedure CP-CPM-14.1, which 1

, required protection of installed equipment during welding. This condition was immediately corrected when the TRT reported it to TUEC QA management, and an inspection was performed by TUEC to cotract similar conditions in other areas as well."

1.2 NUREG-0797, Supplement 11 (SSER 11), May 1985 Housekeeping Issues (Category SC)

"Two allegations were investigated by the QA/QC Group. The allegation relating to inadequate cleanliness controls during the early stages of construction (AQ-54) was substantiated.

TUEC's QA surveillance inspections reported a substantial number of cleanliness procedure violations, which were subsequently corrected. The other allegation, concerning a supervisor's instructions to disregard some reactor vessel cleanliness control requirements (AQ-65), could not be substantiated.

Rsvision: 1

, Pegs 2 of 36 RESULTS REPORT ISAP VII.a.7 (Cont'd)

1.0 DESCRIPTION

OF ISSUE -(Cont'd)-

The'TRT assessed the current housekeeping system of cleanliness and equipment protection, performed a walkdown surveillance of Units 1 and 2, and reviewed cleanliness control procedures, and found that the overall program for detection and correction of housekeeping deficiencies appeared to be satisfactory.

During the QA/QC Group's assessment, two items were identified that require TUEC's action. The first pertains to the number of swipe tests required by draft procedure FP-55-08 to assure that the. reactor vessel had been adequately cleaned. The second pertained to an observation that not all pipe support snubbers were protected from ongoing construction activity."

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(Paragraph 3.2.7, QA/QC Category SC, Page 0-13) 2.0' ACTION IDENTIFIED BY NRC l~ '

Evaluate the TRT findings and consider the implications of these-findings on construction quality. "... examination of the potential safety implications should include, but not be

-limited to the areas or activities selected by the TRT.

Address the root cause of each finding and its generic implications...

Addrese t.he collective significance of these deficiencies...

- Propose an action plan...that will ensure that such problems do not occur in the future."

3.0 BACKGROUND

Previous NRC-TRT reports have requested specific actions to be takan for deficiencies related to housekeeping and system cleanliness. Specifically, an NRC-TRT letter dated September 18, 1984, addressed NCR closecut for construction debris in the air gap of seismic Category I structures. Action Plan II.c was prepared to resolve that item. An NRC-TRT letter dated November 29, 1984, addressed the possibility of construction debris in the RV shield wall annulus. Action Plan VI.a was prepared to resolve that item.

In addition, NRC-TRT letter, November 29, 1984, Item V.b alleged the possibility of debris in anchor bolt holes, but only requested

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<1 0 Pags 3.of 36 y RESULTS REPORT

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ISAP VII.a.7 '

(Cont'd)

3.0 BACKGROUND

(Cont'd) .

verification of anchor bolt length and replacement or justification if required.- As a result of the NRC-TRT Items, a " critical spaces program" was initiated through ISAP VI.a to assess the impact of construction debris.

1. - An additional discussion of previously identified problems and  !

concerns is presented in Appendix 1.

A preliminary review of the circumstances related to Reactor Coolant System (RCS) flush and cleanliness verification was performed to identify background data related to the issue raised in the NRC-TRT letter dated January 8,~ 1985, Item 9A [See Section 1.1.Al. .This background is aussarized as follows:

- Visual inspection of all four (4) loops, steam generators, reactor coolant pumps, and the reactor vessel and internals was conducted by Startup personnel prior to turnover to Startup. Startup accepted custody on February 18, 1982. t

.O RCS loops were handwiped on several occasions between January, 1982 and July, 1982 following ECCS flushes.-

The RCS was cleaned, visually inspected, and tested for chlorida residue preparatory to cold hydrostatic test. During cold hydro, water samples were taken and analyzed to assure water chemistry specifications were maintained (July 5, 1982 through August 7, 1982). ,

The RCS was cleaned and visually inspected again, preparatory to Hot Functional Test (HFT) (October 1982 through January 1983). During HFT, water samples were taken and analyzed to assure water chemistry specifications were maintained (February through May 1983).

The RCS was periodically filled and drained during testing of other fluid systems.

Cleaning was performed in accordance with Flush Plan FP 55-08 prior to turnover to Operations. Although the flush plan only required chloride residue swipes at two (2) locations, eight (8) swipes were actually taken by test lab technicians. The RCS was turned over to Operations in October, 1984 following final QA acceptance of system cleanliness.

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( '( RESULTS REPORT V .

ISAP VII.a.7 (Cont'd)

3.0 BACKGROUND

(Cont'd)

A preliminary review of protection of components from adjacent welding activities (NRC-TRT letter, January 8, 1985, Item 9B) was not performed, since the NRC-TRT evaluation, as documented in SSER 11, Allegation AQ-54, page 0-159, concluded that " Based on its review of records of QC surveillances for January and February, 1979 and inspection reports for 1981 and 1982 the TRT finds some merit in the allegation relating to inadequate cleanliness controls during the _early stages of construction. The TRT concludes that the cleanliness controls implemented since 1981 indicate that management recognized the cleanliness problem and implemented procedures to correct it."

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4.0 CPRT ACTION PLAN O

4.1 Scope and Methodology This Issue-Specific Action Plan assessed the adequacy of the l()[ housekeeping and system cleanliness program at CPSES.

The following tasks were implemented to achieve this objective:

Reviewed TUGC0 and Brown & Root procedures for establishment of housekeeping and cleanliness measures (including surveillance requirements).

Evaluated implementation of FP 55-08 for Reactor Vessel cleanliness.

Reviewed and evaluated implementation of TUGC0 and Brown & Root Surveillance program by observation of performance of surveillances and review of records.

Reviewed the preliminary results of ISAPs II.c and VI.a for adverse trends related to housekeeping and system cleanliness.

The specific methodology is described below. j 4.1.1 Housekeeping and System Cleanliness procedures were reviewed to determine if the requirements of 10CFR50 l Appendix B and the FSAR are included. Procedural f controls for site and plant surveillance were also reviewed.

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ISAP VII.a.7 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 The TUGC0 flush procedures for verifying cleanliness of the Reactor Coolant Loops, including FP 55-08, as referenced in Item 9A of the NRC-TRT letter dated January 8, 1985, were reviewed to determine the adequacy of swipe testing performed in accordance with the Westinghouse guidelines. Also, the adequacy of the flushing and associated swipe testing performed on the reactor coolant sye, tem was verified. Other Review '.'eem Leaders participated in discussions with TUGC0 and Westinghouse to aid in the determination of the -

adequacy of the ovipe testing performed on the Reattor Coolant System, as well as the procedural requirement for two (2) swipe tests of the 7.eactor Vessel.

4.1.3 Plant areas (warehouses, laydown areas and in-place storage areas), both Unit I and Unit 2, were reviewed for evidence of housekeeping and system cleanlineas problens in conjunction with the TUGC0 surveillance group. The results of these reviews were used to O- determine the effectivaness of the current Hot.sekeeping and System P'.eanliness Program. The reviews checked the following:

Access control to plant areas, Any evidence of damage or detericration to materials and equipment, and Equipment protection from environmental and work induced conditions.

4.1.4 A review of TUGC0 documentation was conducted to establish the effectiveness of the current TUGC0 Housekeeping and System Cleanliness Prcgram. The following documents were reviewed for related housekeeping and system cleanliness concerns:

TUGC0 and Brown & Root aucit reports, surveillance reports, inspection reports, NCRs, CARS, NRC reports and system cleanliness packages.

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. Page 6 of 36 RESULTS REPORT ISAP VII.a.7 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.5 The preliminary results of the following action plans were reviewed for housekeeping and system cleanliness deviations:

Action Plan II.c, Maintenance of Air Gap Between Concrete Structures - relates to construction debris in the air gap.

Action Plan VI.a. Gap Between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall - relates to construction debris in the gap between the RPVRI and the shield wall.

4.1.6 A detailed analysis was conducted on the data from the reviews in paragraphs 4.1.1 through 4.1.5. Data were analyzed to determine if the current Housekeeping and -

System Cleanliness Program meets the requirements of O. tocraso. APPe at > aa the 1 Sin.

4.2 Participants Roles and Responsibilities 4.2.1 TUCCO, CPSES Project 4.2.1.1 TUGC0 assisted in identifying and locating applicable information and documentation to support the Review Team activities.

4.2.1.2 Personnel Mr. D. W. Snow TUGC0 QC Coordinator 4.2.2 CPRT-QA/QC Review Team 4.2.2.1 Scope All actiti t 36 :st identified in 4.2.1 above were tl.e % g; .;Lbility of the QA/QC Review Team.

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ISAP VII.a.7 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.2 Personnel (Prior to March 1, 1986)

Mr. J. L. Hansel QA/QC Review Team i

Leader Mr. S. L. Crawford Issue Coordinator 4.2.2.3 Personnel (Starting March 1,1986)

Mr. J. L. Hansel QA/QC Review Tern Leader Mr. G. W. Ross Issue Coordinator 4.3 Qualifications of Persor.nel All personnel associated with analysio and evaluation of findings were qualified in accordance with the requirements of CPRT Program Plan.

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No irlpections were required during the implementation of this Action Plan; therefore inspection personnel certified in accordance with ANS1 N45.2.6 were not required.

4.4 Procedures Matrices and data sheets were developed as an integral part of the evaluation. No formal procedures were required since no reinspections were performed.

4.5 Standards / Acceptance Criteria Housekeeping and System Cleanliness activities shall be in compliance with 10CFR50, Appendix B, and the associated commitments of CPSES/FSAR. Minimum acceptance criteria abstracted from these documents and from Westinghouse specifications are:

4.5.1 Materials and equipment shall be protected from damage or deterioration during storage.

4.5.2 Implementation of procedure requirements shall be verified through surveillances or audits.

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ISAP VII.a.7 $

(Cont'd) 1 ai 2

4.0 CPRT ACTION PLAN (Cont'd) 4.5.3 Special environmental protection such as inert gas. q L humidity controlled or temperature controlled storage -i Z areas shall be provided for materials and equipment, j m when required. g 4.5.4 Access control to plant and storage areas shall be --a r maintained. 1 0

5 4.5.5 The number of swipe tests performed shall be 3

sufficient to insure that the surfaces have been j"

[ adequately cleaned and meet the chloride and fluoride y limits of acceptance.

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5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS F The CPSES program for housekeeping and system cleanliness is based 1 h upon 10CFR50. Appendix B and the FSAR. Requirements from these ,

documents are presented in Appendix 2. j g Implementation of the specific tasks described in Section 4.1 is $

2 dit. cussed in the following sections. Section 5.1 addresses Section j 4.1.1; Section 5.2 addresses Sections 4.1.3 and 4.1.4; Sections 5.3  ;

E and 5.4 address Section 4.1.2; and Section 5.7 addresses Section 4 i 4.1.5. 4 0

i E 5.1 Procedure Review d

=

E 8 The procedures which describe the current CPSES program for j y housekeeping and system cleanliness controls and surveillance J

$ are shown in Appendix 3. These include B&R construction 2 E procedures and B&R and TUGC0 Construction and Startup/ Turnover 4 E (CST) quality procedures.

[ The B&R construction procedures define measures for 4 9

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housekeeping and cleanliness control which satisfy the program basis requirements shown in Appendix 2. l

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The B&R and TUGC0 CST quality procedures listed in Appendix 3 l adequately address all of the elements of an effective Ti

surveillance program with three minor exceptions. The TUGC0 1 I

[ and B&R quality procedures that define measures for i

, surveillance or monitoring of site activities were reviewed to

, determine their adequacy in addressing the following elements of an effective housekeeping / storage surveillance program: )

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l (Cont'd) 5.0 :IMPLDENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (C:nt'd)

Applicable to all safety-related permanent plant

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equipment, "1 "

Surveillance schedule required and minimum frequency defined, All storage areas defined,

-~ All work areas defined, Surveillance attributes / checklists defined.

Verification of corrective action required for closure.

Report distribution to_ appropriate organizations / management for evaluation and trending defined.

Retention of records as QA Records, Applicable supplemental procedures referenced, r

This listing of surveillance program elements was derived from 10CFR50 Appendix B, and the CPSES FSAR Section 17.

Figure 1 is a matrix that depicts compliance of these n procedures with the surveillance program elements listed.

The following are the minor procedural inadequacies

. Brown & Roor CP-QAP-14.1, Revision 6, provides for Storage Surveillance of twenty-five (25) areas identified by Atta:heent I to the QAP. Surveillances are being i' performed for twenty-nine (29) areas. The areas not shown on Attachment 1 include: Area 26 - Safeguard Building EL 773', Area 27 - Safeguard Building EL 880',

Area 28 - Laydown Area East Reactor Building No. 2, Area 29 - Weld Qualification Training Center (WQTC)

Storage Area.

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ISAP VII.a.7 (Cont'd) 4 l5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

CP-QAP-14.1, Revision 6, paragraph 3.1.b, states that 1

"...a copy of unsat SSR [ Site Surveillance Reports]

shall be given to the Assistant Project Manager for resolution...". A minimum distribution that would assure that surveillance reports are appropriately evaluated and trended should be defined in this procedure.

TUGCO DQP-SG-1, Revision 0, requires that surveillance checklists be prepared based upon the requirements of specifications, procedures, etc.. This appears to be adequate for surveillances other than housekeeping; however, since housekeeping requirements are stated in

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numerous procedures, it is appropriate to define surveillance attributes / criteria in DQP-SG-1 to

; preclude omissions.

As an alternate, a new site housekeeping procedure, consolidating all housekeeping requirements, could be '

developed.

5.2 Discussion of Implementatica of Plant Surveillances Brown & Root

• Two hundred'six (206) B&R Site Surveillance Reports (SSRs) issued between January, 1985 and October, 1985 were reviewed.

. Surveillances were conducted for twenty-nine (29) areas instead of the twenty-five (25) areas identified by CP-QAP-14.1. Attachment 1. These twenty-nine (29) areas included all applicable areas at the time of this site review.

The physical areas have changed somewhat from those shown on Attachment 1 due to site construction. The content and resolution of the 1985 B&R SSRs reviewed indicates that the surveillance program is being effectively implemented. Of the two hundred six (206) SSRs reviewed, eleven (11) identified unsatisfactory conditions which were subsequently corrected and the SSRs closed.

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RESULTS REPORT ISAP VII.a.i (Cont'd)

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' 5.0: IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

TUGC0~

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. 'A new' group of construction surveillance personnel was created at'the direction of the site QC Manager in late 1985. This n group performed surveillances of construction activities. A separate QA group performed surveillances on startup. In July..~1986, the surveillance program became the responsibility of the QA Manager and was implemented by the Surveillance

. Supervisor. Under his direction were a Construction

Surveillance Lead and a Startup/ Turnover Surveillance Lead.

Each of these individuals supervised a group of surveillance

, specialists which performed the actual surveillances. In September, 1986, the responsibility for startup surveillances

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was transferred to TUGCO Operations QA.

The QA/QC Review Team observed the performance of seventeen

(17) surveillances by TUGCO, nine (9) of which identified housekeeping deficiencies. These deficiencies were reported j

_()_- on irs and later verified to have been corrected. Discrepant items were identified, corrective action was verified and

> signed off.by QC as satisfactory, w

At the time of this review, the surveillance program was being implemented through CP-QP-19.0 Revision 4. Twenty-seven (27) surveillance reports from October, 1985 to February, 1986 involving housekeeping and system cleanliness were reviewed to determine program adequacy. The Construction Surveillance group performed twenty (20) housekeeping surveillances and the Startup Turnover Surveillance group performed seven (7) surveillances involving system cleanliness verification.

Eleven (11) surveillances identified deficiencies which were documented on Surveillance Deficiency Reports (SDRs). Four (4) responses to the SDRs listed corrective action and actions to preclude recurrence. The remaining seven (7) SDRs listed corrective actions but did not address actions to preclude recurrence; however, it was noted that the nature of the deficiencies was such that the corrective action alone was sufficient.

From the review of surveillancas performed since the implementation of CP-QP-19.0 Revision 4, it appears that the controls for the housekeeping program are being utilized as outlined in the procedures. The content and resolution of O surveillance reports reviewed indicates that the surveillance program is being effectively implemented. l 1

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ISAP VII.a.7 2

(Cont'd) 5.0 IMPLEMENTATION OF' ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

. Current' implementation of housekeeping, cleanliness and

. surveillance activities is considered adequate to meet the

. procedural requirements and appears to be effective in u . identifying and o5taining resolution of unsatisfactory conditions.

5.3 -Discussion of Reactor Vessel Cleanliness In the NRC-TRT letter dated January 8, 1985, the TRT noted

.that TUGC0 flush procedure FP-55-08 required only two swipe

' tests for chloride and fluoride surface contamination. The letter further stated that "This limited number of swipe tests may not provide adequate assurance that the vessel had been properly cleaned.". The following is an evaluation of the adequacy of the swipe testing performed on the reactor vessel. ,

Westinghouse Cleaning Guidelines

. ; (~Ng During the course of evaluating the adequacy of the swipe 1

\~/7 testing' performed, the QA/QC Review Team noted ambiguities in the Westinghouse (W) cleaning guidelines which could affect the acceptability of swipe test results. As the following

" discussion will show, these ambiguities concern the chloride surface contamination limits to be applied to the inside surfaces of piping systema, vessels, tanks and components.

The chloride acceptance limit is defined with regard to surface. condition (insulated /uninsulated) in one (W) document; and with regard to operating temperature (heated / unheated) in another (W) document. The (W) documents do not distinguish between inside and outside surfaces with regard to chloride surface contamination limits. In response to a request for clarification, (W) has indicated that inside surfaces should

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be considered as unheated (uninsulated). This clarification provides the guidance necessary for TUGC0 to define the chloride surface contamination acceptance limits clearly in procedures.

Westinghouse guidelines for cleaning and flushing are included in the following specifications and procedures:

Process Specification PS 292722, " Cleaning and Packaging Requirements of Equipment for use in the Nuclear Steam Supply System",

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Process Specification PS 597760, " Cleanliness Requirements During Storage, Construction, Erection, l and Startup Activities",

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RESULTS REPORT-(_ J ISAP VII.a.7 (Cont'd) 5.0' IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Process Specification PS 84351 NL, " Determination of

< Surface Chloride and Fluoride Contamination on

' Stainless Steel",

Procedure TBX/TCI-SU-2.1.10,;" Reactor Coolant System Post' Hot Functional Inspection,-Cleaning, and Testing",

. Chemistry Criteria & Specifications Manual, Section 1,

" Water Chemistry Specifications".

Cleanliness classification and associated chloride and fluoride limits for Reactor Coolant System (RCS) components, abstracted from these documents, are presented in Table 1.

Table 1 Cleanliness Classification

1. "'i - _ Inside Outside Reactor Vessel C D RC Piping B B Steam Generators C D Pressurizer B D RV Intsrnals C C Chloride and Fluoride Limits - ag/da n Chloride Fluoride Class B - Insulated /

heated

( )> 150'F) 0.001S 0.0015 Non-insulated /

unheated

( <( 150*F) 0.015 0.0015 Class C - 0.05 0.010 Class D - -

None Specified -

. PS 292722 provides that Class A and B surfaces "shall not

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• exceed the limits for chloride and fluoride contamination as specified in Westinghouse Process Specification 84351 NL", and Class C components "shall meet the same cleanliness

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RESULTS REPORT ISAP VII.a.7 .

(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

.requirementsasspecifiedinClassBexcegttheC1andF1 2

limits shall be .05 mg/dm and .010 mg/dm respectively when  ;

tested per PS 84351 NL." '

. PS 84351 NL states that "The higher. chloride limit on non-insulated surfaces is permitted due to the decreased

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n_ potential for chloride cracking on non-heated surfaces. Since

- temperature has litt1'e effect on fluoride cracking, the fluoride limit is identical for both insulated and non-insulated surfaces.".

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The (W) Water Chemistry Specifications, Revision 2 March, 1977, Table 1-8, " Stainless Steel Surface Contamination" reinforces that the chloride surface contamination limits are based on operating temperature conditions. Although the Water Chemistry Specifications'(WCS) are not referenced by PS 292722, the WCS, Paragraph 1.1. Scope states: " These  ;

f s. specifications are considered mandatory to insure component 1

,)- integrity and efficient plant operation." In addition, Table 1-8 of the WCS references PS 84351 NL as the required specification for the determination of chloride and fluoride surface contamination of stainless steel materials. Table 1-8 provides exactly the same chloride and fluoride contamination limits as PS 84351 NL except that the different chloride limits are referenced to " heated" (2>150*F)and"non-heated" surfaces instead of insulated and non-insulated surfaces.

Neither (W) PS 292722 or PS 84351 NL clearly defines whether the surface contamination limits for interior surfaces should be based on operating temperature conditions or on insulated /uninsulated conditions.

d When this lack of definition and inconsistency of the (W) specifications was identified to TUGC0 by the QA/QC Review Team, the QA/QC Review Team was advised that the decision to consider interior surfaces of piping systems, vessels, tanks and components, including the reactor vessel, as "non-insulated" instead of heated surfaces was a joint decision between TUGC0 and (W) CPSES site personnel. Although the PS 84531 NL discussion of chloride limits in the context of insulated surfaces is appropriate for the exterior surfaces of piping, tanks, vessels and components, it is not clear whether interior surface chloride limits should be based on

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surface condition (i.e., non-insulated) or on operating temperature (as implied by the (W) Water Chemistry Specifications). The reactor vessel operating temperature will exceed 500*F.

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ISAP VII.a.7 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Since neither PS 292722 nor PS 84351 NL clearly stated requirements for interior surfaces, an inquiry to Westinghouse Wster . Reactors Division for clarification of the specification requirements was submitted. The (W) response, WPT-7996, dated August 9, 1985 discussed chloride and fluoride limits by referring to chloride solubilities, reactor coolant system surface-to-volume ratio and chloride cracking test results.

The following points were made in the (W) response: _

Since chlorides are extremely soluble in water solutions, the residence time of any surface chloride would be very short as solution is added to the reactor coolant system and would be removed from the surfaces prior to any heating. Therefore, for purposes of interpreting Process Specification 84351NL - Revision 3, the inside of RCS piping should be considered a "Non-Heated" surface.

The halogen concentration limits for inside surfaces are imposed to prevent contamination of the, fluid added to the reactor system. The chloride and fluoride concentration limits imposed on this fluid are 0.15 ppm (150 ppb).

Based upon estimated surface area and volume, the maximum permissible chloride surface contamination for 8

Class C cleanliness of 0.05 mg/dm would yield a concentration of 3.9 ppb.

Thus if the entire reactor coolant piping was contaminated to the maximum permissible surface 2

chloride of 0.05 mg/dm , it would still not pose a corrosion cracking issue.

- Based on these considerations, the Class B cleanliness classification for reactor coolant piping and fittings in Westinghouse Process Specification 292722 Revision 9 is being modified to a Class C cleanliness classification.

The interior surface of the reactor vessel is specified as Class C by (W) in PS 292722.

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ISAP VII.a.7  !

(Cont'd)-

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

The (W) specification's do not identify a specific number of

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swipe tests'or locations; but state "....The amount of sampling for s'given system or component must be sufficient to insure that the surfaces have been adequately cleaned and meet

+

the chloride and fluoride limits of acceptance....". It should be noted that swipe testing is not the sole means of verifying acceptable chloride and fluoride cleanliness.

.During system filling and flushing, water samples are taken and analyzed to assure water chemistry specification limits are met.- The results of analyses of the water samplas to date have confirmed acceptable concentrations of chlorides and fluorides..

TUGC0 System Cleanliness Plan (FP 55-08)

Flush Plan FP 55-08 was approved August 6, 1984, to verify:

- " Level B cleanliness of the guide tubes for bottom mounted reactor instruments by flushing."

" Level B cleanliness of the reactor coolant loops by handwiping, visual inspection and swipes for chemical analysis."

Although the (W) specification, PS 292722, does not require RV cleanliness to Class B requirements, FP 55-08 does by including the reactor vessel as part of the reactor coolant loops. Paragraph 4.3.1 provides for handwiping, visual inspection and swipe tests to be taken and analyzed by test lab personnel "per their procedure". FP 55-08 does require, as stated by the NRC-TRT letter dated January 8,1985, and by SSER fil, Allegation AQ-54, two (2) swipes, one on the side of the RV and one on the bottom.

Flush Plan FP 55-08 does not define the acceptance limits for chloride and fluoride surface contamination. Nor does it reference the applicable procedures and specifications.

The procedures used by the Test Laboratory for surface chloride and fluoride determination are:

QI-QP-11.1-65 (Surface chlorides)

QI-QP-11.1-66 (Surface Fluorides)

O

Rsvision: 1 Page 17 of 36 y ~s , RESULTS REPORT ISAP VII.a.7

-(Cont'd) 5.0 IMPLDfENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

^

QI-QP-11.1-65 does not reference (H) PS 84351 NL but does include the acceptance limits for Class A, B and C as identified by (y) PS 292722 and PS 84351 NL. QI-QP-11.1-65 also includes the system and component cleanliness classifications of PS 292722 Table III.

Reactor Vessel Cleanliness Swipe Test Results

. Although FP 55-08 required only two (2) swipe tests of the Reactor Vessel, eight (8) swipe tests were actually taken to verify Class B cleanliness of the vessel.

The results of the eight (8) Reactor Vessel swipe tests, evaluated to Class B non-insulated acceptance limits, were:

Location Date Cl Limit Actual P Limit Actual Rx Containment ** 08/27/84 .015 .0013 .0015 .0001

/~N Vessel Bottom

-L)

RV Botton 08/28/84 .015 .0018 .0015 .0000 RV Botton 08/28/84 .015 .0013 .0015 .0001 RV 8' 08/28/84 .015 .0007 .0015 .0000 Rv 25' 08/28/84 .015 .0006 .0015 .0000 08/28/84 .015 RV 25' .0002 .0015 .0000 R7 Rim 08/28/84 .015 .0057 .0015 .0004 RV SG #1 Cold 08/28/84 .015 .0013 .0015 .0000

• • Discussions with Test Lab personnel indicate that the

" Reactor Containment Vessel" is actually the Reactor

' Vessel. QI-QP-11.1-65 and QI-QP-11.1-66 Data Sheets note the " sample was taken prior to final cleaning of the containment vessel."

The results on all samples were well below the limits W) specified specificationfor Class C, the PS 292722 forclassification the interior defined surfaces by of (Ee t

reactor vessel. However, the flush plan required cleanliness

) level B but did not define the limits as " Insulated" (heated, )> 150*F) nor "Non-insulated" (unheated, <,150* F) .

The results on all samples were within the limits for Class B, non-insulated;(but for insulated heated, two 2)150*F) samples exceed the chloride limit surfaces.

/-

3 .

Revision: I s

w Paga 18 of:36 0

RESULTS REPORT Q: ,

ISAP VII.a.7 )

(Cont'd) l i

.5.0 IMPLEMENTATION.0F. ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l i

Susunary - Reactor Vessel Cleanliness l

-Westinghouse specifications PS 292722 and PS 84351 NL do not I clearly establish which chloride contamination limits are l c7 acceptable for Class A and B cleanliness of interior surfaces of heated vessels, components and piping.

The (E) specifications state that the sampling for surface coatsmination must be sufficient to insure that the surfaces are adequately cleaned. 'According to TUGC0 Startup psrsonnel, 7

~the intent of the two (2) swipes required by FP-55-06 was to be a minimum number, with one swipe (minimus) on a vertical surface and one swipe (minimus) on a horizontal surface. The '

actual number and specific location of swipe tests was left to l the discretion of the chemist performing the swipes.  !

Accordingly, Test Lab personnel took swipe tests at eight (8) locations in the reactor vessel as shown above. The QA/QC Review Team considers these eight (8) swipe tests plus water .

chemistry samples to be adequate to demonstrate acceptable cleanliness of the Reactor Vessel.

The results of the August, 1984 swipe tests for the Reactor Vessel were acceptable for Class C cleanliness for interior surfaces required by (3) specification PS 292722.

5.4 Other Flush Plan and' Swipe Test Results Due to the questions raised on the applicable chloride limits for the reactor vessel, an additional selection of flush plans and swipe test results was reviewed. This selection included the results of fourteen (14) swipe tests of the reactor internals and twenty-four (24) swipe tests of reactor coolant piping and steam generator primary sides performed in accordance with FP 55-08; and the results of swipe tests performed in accordance with six (6) other flush plans / travelers.

The review revealed that Flush Plans / Travelers do not define cleanliness classifications consistent with (E) specification PS 292722 and do not clearly state the applicable acceptance limits for chloride and fluoride surface contamination. As a 4

result, Test Lab personnel establish the acceptance limits

against which the test results are evaluated. The acceptance

limits established and the resulting evaluations are not

l. '

consistent relative to insulated (heated) versus non-insulated (unheated) surfaces. Additional details of this review are

} presented in Appendix 4.

k g. .

, Revision: 1

+ Pags 19-of 36

.~ ) - RESULTS REPORT

~

ISAP VII.a.7 (Cont'd) 5.0' IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

A review of the laboratory test reports for the swipe tests performed in accordance with flush plan FP 55-08 revealed that 35% of the tests did not meet the wiped area requirement of 8

,; 20dm as specified in (W) specification 84351 NL, flush plan i FP $5-08 Attachment 1 and QI-QP-11.1-65.

The " cleanness" inspection for flush plan FP 55-08 is i documented on IR 84-1001 which does not reference the flush plan, (W) specifications or STA-612. " Cleanness Control".

Therefore, the acceptance criteria utilized can only be

. inferred. Item 3 of the IR states " Verify an acceptable chemistry report for flourides [ sic] & chlorides has been received for the following areas....". This step is signed off as SAT even though some swipe test areas do not meet the 20dm8 requirement. Per TUGC0 Startup personnel, the Item 3 ,

statement was intended to only verify that a report showing results accepted by the laboratory was received. No verification of the acceptability of the test was intended.

In susmary, Flush Plans and Travelers do not adequately define cleanliness requirements for the Reactor Coolant System in accordance with Westinghouse guidelines or CST procedure CP-SAP-24. They do not reference the Westinghouse specification nor the applicable TUGC0 analytical procedures.

TUGC0 Startup procedures XCP-ME-4 and CP-SAP-24, which define flush plan and system cleanliness requirements, do not address swipe testing.

According to TUGC0 Startup personnel, the B&R QC laboratory has full responsibility for swipe testing. The statement of acceptability on the test report by Test Lab personnel is accepted without question. The TUGC0 analytical procedures do not clearly define acceptance criteria for interior surfaces.

since they reflect the (W) specifications. This results in an inconsistent evaluation of the swipe test samples for acceptability.

Swipe test sampling requirements are not consistently met. QC review of swipe test laboratory reports is unsatisfactory.

Inspection Reports do not identify acceptance criteria nor reference procedures containing them.

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Page 20 of 36 j

,/i RESULTS REPORT

, A)

ISAP VII.a.7 )

(Cont'd) '

l 5.0. IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) )

15.5_ Summary of Results l Procedures The B&R construction procedures establish requirements for I housekeeping and cleanliness that are considered adequate to satisfy the program basis requirements of 10CFR50 Appendix B and the FSAR, if effectively implemented. Since January, 1985

- the B&R quality procedures adequately address all of the elessnes of an effective surveillance program with the exceptica of report distribution to appropriate organisations/ management for evaluation and trending and I definition of all areas subject *a surveillance. l The TUGC0 quality procedure currently in effect, DQP-SG-1, adequately addresses all of the elements of an effective surveillance program, with the minor exception of not defining .

housekeeping surteillance attributes / criteria.

Refer:to Figure 1 for a synopsis of current procedures versus the elements of an effective surveillance program.  ;

P1 1 ant Surveillances Implementation of current TUCCO and B&R procedural requirements is considered adequate and appears to be effective in identifying and obtaining resolution of unsatisfactory conditions.

Reactor Vessel Cleanliness The intent of flush plan FP 55-08 was to require a minimum of '

one (1) swipe on a vertical surface and one (1) swipe on a l horisontal surface. The actual number and location of swipe tests was left to the discretion of Test Lab personnel.

l Although two (2) swipe tests of the Reactor Vessel as required j by FP 55-08 may not have been ".... sufficient to insure that 1 the surfaces may have been adequately cleaned and meet the chloride and fluoride limits of acceptar.co...." (Westinghouse specification PS 8351 NL), the actual number of swipes taken and analysed, eight (8), is considered sufficient to verify ,

the cleanliness of the Reactor Vessel. l LO I

l I

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w

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c Rsvision; 1

-s e Peg 2 21 of 36 y

(~'{

q

+

RESULTS REPORT -

ISAP VII.a.7 '

a. a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AMD DISCUSSION OF RESULTS (Cont'd)

The.results of the August, 1984 swipe tests for the Reactor Vessel were acceptable for Class C cleanliness for interior

surfaces as required by (W) specification PS 292722.

Flush' Plan and Swipe Test Results 55 i

- The cleanliness classes and criteria described by Westinghouse  !

specifications, B&R procedures. TUCCO Startup procedures and TUGC0 Operations procedures, while similar, are not defined to

' a common basis or in'the same terna. This allows for potentially incompatible or at least inconsistent requirements and acceptance criteria from phase to phase (e.g.,

Construction, Startup/ Turnover, Operations).

The' Flush Plans / Travelers reviewed do not adequately define cleanliness requirements and acceptance criteria in the text or through reference to applicable specifications or procedures. The cleanliness classifications used are not

{} l always consistent with the Westinghouse specification.

TUGC0 Startup procedures XCP-ME-4 and CP-SAP-24, which define flush plan and system cleanliness requirements, do not address swipe testing.

Due to inadequate definition of requiremente, swipe test 4

samples are not consistently evaluated to the applicable acceptance criteria. The minimum wips area required by procedure is not always met. QC review of test reports has failed to identify this lack of compliance with procedures.

In spite of the above, all of the sixty (60) swipe test i results reviewed met the minimum chloride and fluoride surface ,

contamination limits intended by Westinghouse. The l inconsistencies noted in the cleanliness classifications defined in flush plans / travelers and in the evaluation of swipe test results have resulted in the application of more i stringent limits than intended by Westinghouse.

The inadequacies identified in the TUGC0 flush plans and the Startup procedures which govern them have been discussed with TUGC0 personnel. Revisions to these procedures are currently being made to address the inadequate areas.

O a

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. Revision: 1 1 4 Page 22 of 36

)

. (; .

M RESULTS REPORT

, V

" ~

ISAP VII.a.7.

~

(Cont'd) )

h

, 5.0 IMPLEMENTATION OF' ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l

~

5.6 '. Compliance with 10CFR50, Appendix B and FSAR Commitments  !

l The current CPSES program for housekeeping activities, ,

including surveillance, complies with 10CFR50, Appendix B and  !

the associated commitments of the CPSES FSAR shown in l Appendix 2. l R .

l The B&R construction procedures establish requirements for storage, housekeeping and system cleanliness which satisfy the program basis requirements. Revever, the B&R and TUGC0 i procedures for surveillance of housekeeping and storage to 1 assure implementation of the established requirements contain minor inadequacies as described in Section 5.1. There were no deviations noted during the implementation of this action plan which were associated with specific hardware items. Therefore no Construction Deviation Reports (DRs) were issued. No QA/QC Program Deviation Reports (FDRs) were issued relative to the housekeeping and surveillance program. However, the current

O,. ce=== P B 1 7e 1 11 < 11 Pir i=*

10CFR50, Appendix B and FSAR couaiteents. TUGC0 flush plans / travelers and the procedures which govern them do not adequately define appropriate acceptance criteria.  !

Accordingly, a QA/QC Program Deviation Report, QA/QC-RT-49, was written to document this deviation. TUGC0 is currently taking action to review and revise the affected procedures.

1 5.7 Trend Analysis  ;

i There were no QA/QC Program Deviation Reports (PDRs) or Construction Deviation Reports (DRs) issued as a result of the review of current housekeeping / surveillance activities. The one PDR written relative to the system cleanliness program l does not constitute a trend. The program deviation described in this PDR is not the result of multiple deviations that would constitute a trend. Therefore, a trend analysis I

relative to the current program is not required.

A review of the results of Action Plan II.c " Maintenance of l Air Gap Between Concrete Structures", did not identify any problems attributable to housekeeping / surveillance practices. ,

, Action Plan II.c concluded that the presence of construction debris in seismic gaps was the result of inadequate 4

construction and inspection procedures for concrete pours.

Action Plan II.c further states that the determination of a more refined root cause will be made by the QOC (QA/QC)

Collective Evaluation group. One such potential root cause is ,

, the failure of the engineering specifications to identify the 1

. critical nature of the seismic gaps.

4

Y 1.

Rsvision: 'l y ' <

Pago 23 of 3'6

'(N y

RESULTS REPORT ISAP VII.a.7 ,

(Cont'd)

. 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

The inspection of critical spaces' required by Action Plan VI.a. " Gap Between Reactor Pressure Vessel Reflective

' Insulation'and the Biological Shield Wall", identified a

-significant amount of construction debris in these areas.

Action Plan VI.a was unable to attribute the debris which had accumulated in critical spaces to any one particular phase of plant construction or to any one organization. As a result, the Action Plan, VII.a.7, Issue Coordinator was requested to evaluate the historical housekeeping surveillance program.

This evaluation shows some evidence of housekeeping and surveillance inadequacies, particularly prior to 1981.

However, the problems identified could not be related to the accumulation of construction debris in critical spaces.

The Deviation Reports and out-of-scope observations generated under ISAP VII.c. were reviewed to identify instances of damage to permanent plant equipment which could be attributable to poor housekeeping / protection of equipment. No instances were identified.

5.8 Root Cause and Generic Implications Analysis In accordance with the CPRT Program Plan, root cause and generic implications evaluations are not required since no deficiencies or adverse trends were identified. However, since the inadequacies found in the TUGC0 procedures governing system cleanliness and flush plans could have implications in other areas, a description of these inadequacies has been transmitted to the QA/QC Review Team Collective Evaluation Group for information and action as appropriate. The QA/QC Review Team concluded that housekeeping practices and housekeeping surveillance activities were not a contributing factor to the accumulation of debris in the seismic gaps and critical spaces which was found through Action Plan II.c and  ;

VI.a.

5.9 Recommended Corrective Action B&R procedure CP-QAP-14.1 should be revised to defitte a minimum distribution for surveillance reports and 'to define all current areas subject to surveillance.

TUGC0 procedure DQP-SG-1 should be revised to define the 1 attributes / criteria to be used for housekeeping surveillance.

?}, ,

( Ravision: 1 p Page 24 of 36 RESULTS REPORT

.ISAP VII.a.7 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

TUGC0 procedures governing system cleanliness and flush plans

.should be revised to provide cleanliness classifications ,

consistent with Westinghouse requirements and to clearly define chloride and fluoride surface contamination limits.

This action is currently in process. The proposed changes have been reviewed by the QA/QC Review Team and are considered to be adequate to resolve this deviation.

6.0 CONCLUSION

S 6.1 Plant Housekeeping and System Cleanliness B&R construction procedures which define housekeeping and cleanliness requirements were adequate to meet FSAR commitments.

Current housekeeping practices and procedures are considered satisfactory and comply with the program basis defined in

~

Appendix 1. This conclusion reflects the results of the observations of TUGC0 surveillances of Unit 1 and 2 areas and facilities (warehouses, lay-down areas, in-place storage, etc.) which verified the fo11 ewing:

Satisfactory access control as appropriate, Absence of evidence of damage to or deterioration of plant materials and equipment,

~

Satisfactory protection of equipment from harmful environmental and work induced conditions.

6.2 Plant and Storage Surveillance Current plant and storage surveillance procedures comply with the program basis defined in Appendix 1 with only minor inadequacies.

The current program is being adequately implemented and is effective in identifying and obtaining resolution of unsatisfactory conditions.

6.3 Reactor Vessel Cleanliness i The actual number of swipes taken, eight (8), was adequate to

-/ verify cleanliness.

ne,--m.,,, e-,v,- ,,, -- , , , - - - -- . , - - - ,---,;--..-,_ , , ,, -

o-L' Rovision: -1

i Pags 25 of 36

<^. RESULTS REPORT v

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ISAP VII.a.7 (Cont'd) 6.0- CONCLUSIONS'(Cont'd)

RV' cleanliness under FP 55-08 was maintained to class B

'although (W) Specification 292722 only required the less stringent Elass C for the internal surfaces.

FP 55-08 is a one-time-only-use procedure for Unit 1; new fps are required to be prepared for any subsequent flushes per procedure XCP-ME-4.

Westinghouse specifications'and TUGC0 procedures do not clearly define chloride and fluoride surface contamination limits for interior surfaces relative to the heated / insulated issue.

I 6.4 Flush Plans and Swipe Test Results Flush plans / travelers do not consistently define cleanliness classifications in accordance with Westinghouse specification PS 292722 and do not identify the acceptance limits for

(~'t chloride and fluoride surface contamination.

V The review of' sixty (60) swipe test results from eight (8)

-flush plans indicates that Westinghouse chloride and fluoride surface contamination limits are being met. As stated in Westinghouse letter WPT-7996, these limits are imposed to prevent contamination of the fluid added to the reactor system and are well below those which would pose a corrosion cracking issue.

7.0 ONGOING ACTIVITIES The following activities, related to the evaluations performed under this ISAP, remain open or to be accomplished:

Westinghouse (W) specification 292722, Revision 9 is to be revised per (W) letter WPT-7996 August 9, 1985, but no schedule for the revision and no commitment to revise (W) ~

specification 84351 NL Revision 3 for clarification of interior surface chloride and fluoride limits have been identified.

However, (W) has provided sufficient guidance through correspondence, etc. to permit TUGC0 to define clearly in procedures, cleanliness requirements which are consistent O with (W) requirements.

_r,---,---y-,---.,,,.m.-m,.,..-,,,.,m.

--,,m-,w-------.--

Rt. vision: 1

..." Page 26 of 36

' RESULTS REPORT ISAP VII.a.7 (Cont'd)-

- 8.0 ACTION TO PRECLUDE RECURRENCE IN THE FUTURE The TUCCO action, currently in process, to review and revise procedures affecting system cleanliness activities will be adequate to preclude recurrence of swipe test problems.

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/' . RESULTS REPORT v -

ISAP VII.a.7 (Cont'd) ,

Figure 1 ISAP Vll. a. 7 Results Report CPSES PROCEDURES

, B&R TUGCO -

SURVEILLANCE PROGRAM ELEMENTS CST CP- CP-QAP QAP DQP-14.1 11.1 SG 1 Applicable to all Perm. Plant Equipment + e +

Schedule Required / Frequency Defined + e +

All storage Areas Defined A C 1 AllWorkAreas Defined A C 1 r) m

\-

Attributes / Checklists Defined Verification of Corrective Action Defined

+

+

e e

D

+

Appropriate Report Distribution Defined B e +

Report Retention as a QA Record . + e +

Supplemental Procedures Referenced + + +

NOTES .

A. Attachment I shows 25 areas,surveillances are performed of 29 areas.

B. Unsatisfactory reports to Ass't. Proj. Manager - No other distribution defined.

C. Inspector to " routinely observe general workmanship" and document unsatisfactory conditions per CP-QAP 14.1 D. - Checklists are required to be prepared based upon procedures and specifications.

1. Not applicable. TUGCO surveillance program is an overview of B & R activities.

Legend :

+ : Adequately Adciessed Letter : Inadequately Addressed

, e : Not Addressed

y s:

Revision: 1 7g Pags 28 of 36

" ,a RESULTS REPORT

.\)

ISAP VII.a.7 (Cont'd)

Appendix 1 4

Discussion of Previously Identified. Problems and Concerns

- USNRC TRT Items

- The following allegations were evaluated by the USNRC TRT and reported in Safety, Evaluation Report, NUREG-0797, Supplements Nos. 9,10, and 11: .

-AP-6: Crowbar dropped in neutron detector well. The TRT r

found that a crowbar was apparently dropped in 1980 or 1981 and was not removed until November, 1983 by flushing. Although the TRT noted that'the accumulation of debris in the reactor cavity was a non-compliance with procedure CP-QP-19.5, the TRT concluded that there was no safety significance and no TUGC0 action was required.

AW-65: Debris in Transfer Tube. Coincident with an evaluation of incomplete welds, which was expressed by

'(y Allegation AW-65, the TRT observed miscellaneous

'-? debris in the transfer tube expansion joint, including a shop rag and a toothbrush-type stainisss steel ,

brush. The TRT found no safety significance to the alleged weld discrepancy, but provided no conclusions or required actions for the construction debris.

'AP-10: A stesa pipe fell off a truck, but did not know if damage occurred [ sic]. The TRT review concurred with a prior Region IV (RIV) investigation that the specific case had no safety significance, since the pipe in question was part of a "non-Q" (non-safety related) system. However, the TRT did note a number of previously identified deviations and violations, which, although not related to piping, did indicate a generic problem with the protection of safety-related mechanical equipment.

- INPO "CPSES Design and Construction Self-Initiated Evaluation Report", October 13, 1982, finding CC.2-1, identified a deficiency in the storage and maintenance of pipe support details in outside laydown areas.

j a

- . . _ . . . _ _ . _ _ ~ _ _ _ _ _ . _ _ _ _ _ . . . . _ _ . . _ . . - - . _ . - . _ . _ _ _ _ _ _ _ . . . . _ . _ _ , . __ _ _ _ _ - - -

zr.

t: .

Rsvision:- 1 Pags 29 of'36

. RESULTS REPORT

. -))

7

~

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ISAP VII.a.7_

(Cont'd)

. Appendix 1 (Cont'd)

'USNRC TRT Items (Cont'd)

IR 50-446/83-12, April 8, 1983, NRC CAT inspection identified violations of 10CFR50 Appendix B, Criterion XIII and KVI related to improper storage control of safety related equipment in outside laydown areas and lack of timely resolution of TUEC audit findings related to maintenance instructions identified during 1979, 1981 and 1982 TUEC audits.

IR 50-445 & 446/79-04, February 27, 1079 and associated notices of violation 445/7904 and 446/7904 identified a violation of 10CFR50 Appendix B, Criterion V related to non-

_ _ compliance with storage maintenance

(}~ requirements fo safety-related equipment.

IR 50-445/83-24 and 50-446/83-15, August 24, 1983 and associated notices of violation 445/8324-02 and'446/8315-02 identified a violation of 10CFR50 Appendix B, Criterion XIII related to failure to prevent deterioration of safety-related equipment in storage.

During the course of their investigation of AP-10, the TRT identified that randon QC surveillance over storage and control of materials in the fabrication shop area was not performed as required. The TRT observed that failure to perform these surveillances was " contrary to the results to be achieved by TUEC corrective action in response to NOV 445/8324-02, 446/8315-02." "The TRT assessment of the current requirements for the protection of mechanical equipment during storage and maintenance and installation found that the r6quirements were adequate and appear to be implemented adequately for piping."

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RESULTS REPORT U ,

ISAP VII.a.7 (Cont'd) >

Appendix 1 (Cont'd)

Internal Items ,

In addition to the inspection and audit items noted by the TRT during evaluation of AP-10, the QA/QC Review Team observed that

. Brown & Root internal audit CP-17, September 16-19, 1980, Audit Deficiency Report ADR CP-17.2, identified numerous supports with rusted threads. The audit team noted that the problem was generic and, although specific items had been reported on B&R NCR-2359 and Surveillance Report S-009, corrective action had not been

_ implemented at the time of the audit. NCR 2359 R1 was closed November 23,'1980, but S-009 was never closed out due to deletion of governing procedure CP-QAP-12.2 on August 25, 1980.

MAC Items f In.1978, Management Analysis Company documented a concern with onsite storage practices:

" Exterior storage practices should be reviewed. The protective coverings of many items are damaged; some reported on monthly surveillance reports have not been corrected.

1.arge temporary structures, such as those over the emergency diesel engines, require wind bracing to prevent further damage. Because of soil chemistry, rain and humidity,.the s current practice of allowing large stainless steel piping to remain uncovered should be reviewed. Sensitised stainless is extremely sensitive to chloride, fluoride and sulphide contamination which with water as a couplant can cause intergranular corrosion and premature failure."

TUGC0 responded to the MAC Report internally by meno July 11, 1978:

"We had previously reviewed the storage practices and have no reason to believe that a probles exists. Various NRC inspectors have also inspected this activity. However, Westinghouse is reviewing this, and their metallurgist will report by July 15."

In summary, numerous concerns, observations, findings and violations have been identified by various internal and external sources relating to housekeeping, cleanliness, storage and surveillance for the period 1978 to 1985. The corrective action cousitaents, and the actions taken to implement and verify them had O not been effective in precluding recurrence of identified deficiencies and violations. The items discussed in this appendix have been transmitted to the Issue Coordinator of Action Plan VII.a.2, Nonconformance and Corrective Action System, for  :

information.

l

.c Rsvision: 1 Pcgo 31 of 36

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(~$ .

RESULTS REPORT L)

ISAP VII.a.7  !

(Cont'd)

Appendix 2 Housekeeping and System Cleanliness Program Basis

'10CFR50 Appendix B Criterion XIII

" Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration. When necessary for particular products, special protective environments, such as inert gas atmosphere, specific '

moisture content levels, and temperature levels, shall be specified and provided."

FSAR, Paragraph 17.1.13

" Contractor procedures for the performance of cleaning, handling, storage, shipping, and preservation of materials and equipment to prevent damage or deterioration are reviewed by TUGC0 or the prime l contractor. The approved procedures become a part, either by inclusion or reference, of the purchase documents issued by these  !

organizations. TUGC0 verifies that adequate provisions for i procedures are included in purchase documents by ongoing rey;ew  !

prior to issuance, by surveillance, or by audits. l At the site, material and equipment are stored in accordance with approved procedures. TUGC0 requires that instructions or guidance for site handling, preservation, storage, and control are prepared and approved prior to arrival of the equipment at the site. These procedures may require that special environmental facilities such as inert gas, humidity controlled, or temperative controlled storage areas be required at the site prior to the receipt of the equipment.

TUCCO performs periodic surveillance and audits of contractors to assure that the specified and approved procedures are being properly implemented."

FSAR, Paragraph 17.1.15 states in part:

" Conditions which render the quality of an item or activity unacceptable or indeterminate will be identified, resolved and closed out. Such conditions are documented on inspection reports, deficiency reports, or nonconformance reports in accordance with O procedures, i .

Rcvision: 1

, P:gs 32 of 36

, 3 RESULTS REPORT

,j' ISAP VII.a.7 (Cont'd)

Appendix 2 (Cont'd)

FSAR. Paragraph 17.1.15 (Cont'd)

Procedures require trending of deficiencies reported on inspection reports, deficiency reports, and nonconformance reports to identify trends adverse to quality. Trend reports are reviewed quarterly by appropriate levels of management to address areas requiring corrective action.

Nonconformance reports and trend reports are reviewed upon issuance by TUGC0 QA for significant conditions adverse to quality or chronically repetitive deficiencies. If such conditions exist, procedures require additional action, as appropriate. This may ,

include issuance of corrective action requests as discussed in Section 17.1.16, ' Corrective Action', or reports to the Nuclear Regulatory Commission."

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. Jage 33'of 36 RESULTS RETORT N ISAP VII.a.7 ,.

(Cont'd) i l t Appendix 3 , ,

\

Current Housekeeping and System Cleanliness Procedures ,

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Brown & Root Construction Procedures CP-CPM 6.9H Rev. 0 02/06/80 " Cleanliness Control" (with DCN fl. 2, 3) g CP-CPM 8.1 Rev. 2 09/25/84 " Receipt, Storage, and Issuance of Items" CP-CPM 10.2 Rev. 2 07/12/83 " Cleaning and Insulating Stainless Steel Pipe and Equipment" (with DCN #1)'

CP-CPM 14.1 Rev. 2 04/05/84 " Guidelines for the Protection of Permanent Plant' Equipment" CP-MCP-10 Rev. 9 07/02/85 " Storage and Storage .

O " t== =c cf " ch =ic 1 Electrical Equipment" a

HEI-8 Rev. 1 07/07/81 "NSSS Cleanliness Control During Coolant Loop Installation" Brown & Root - Quality Procedures CP-QAP-14.1 Rev. 6 01/25/85 " Inspection of Storage and Msintenance of Permanent Plant Equipment" CP-QAP-11.1 Rev. 8 11/20/85 " Fabrication, installation Inspection of ASME Cocponent Supports, class 1, 2 and 3" TUCCO Construction and Startup - Quality Procedures s DQP-SG-1 Rev. 0 07/01/86 "Conservction Startup/

i Turnovet* (CST) Survoillances" DQP-SG-2 Rev. 0 07/01/86 " Training, Qualification and Certification of Surveillance

, Specialists" m um is i - um

s Revision:

Page 34 of 36 RESULTS REPORT ISAP VII.a.7 (Cont'd)

Appendix 4 Review of Other Flush Plans and Swipe Test Results FP 55-08 Reactor Internals and Reactor Coolant Piping Twenty-four (24) swipes of the Reactor Coolant Piping and Steam Generator primary sides (5 in Loop #1, 8 in Loop #2, 6 in Loop #3, 5 in Loop #4) were taken under FP 55-08, all to Class B cleanliness acceptance limits (non-insulated surfaces).

All samples taken for chloride surface contamination under FP 55-08 in August, 1984 were analyzed against .015 mg/dm2 because the interior surfaces were regarded as "non-insulated" surfaces even an, though the operating temperature will exceed 550* F. Approximately ERI 58% of the RC piping samples (14/24) did not meet the Class B surface chloride limits for heated surfaces. None of the Reactor Vessel or Reactor Internals samples exceeded the Class C surface chloride limits, but the Reactor Vessel and Internals were sampled and analyzed under QI-QP-11.1-65 to Class B non-insulated

() (unheated) acceptance criteria. Approximately 25% (2/8) of the RV samples and 57% (8/14) of the Reactor Internals samples did not meet Class B insulated (heated) surface chloride limits.

FP 55-02 Pressurizer (RCRCPR)

PS 292722 requires the Pressurizer (inside) to be cleanliness Class B. FP 55-02, June 2, 1982 required the Pressurizer to be cleaned and verified to cleanliness Level 1. Traveler ME-82-2365-5500, June 15, 1982 provided for verification to cleanliness Class B.

The swipe test data sheets (QI-QP-11.1-65) taken for swipe J-161, June 28, 1982 indicated 2

that the results were originally analyzed to.0015mgC1/dm (insulated / heated) but were later changed to

.015 mg/dm (non-insulated) per a handwritten memo which states that the swipe tests are on interior surfaces and "Therefore common sense dictates these surfaces shall be non-insulated." Two of the four swipa tests exceeded the Class B insulated chloride limits (but did not exceed the non-insulated limits).

FP 55-05B Pressurizer Relief Tank (RCATPR)

PS 292722 requires the Pressurizer Relief Tank interior to be cleanliness Class C. FP 55-05B, October 16, 1982 required the Pressurizer Relief Tanks to be cleaned and verified to cleanliness Level 1. The swipe test data sheets (QI-QP-11.1-65) taken for swipe J-206, October 28, 1982 indicate a non-insulated surface, i

q a

J 1

7 J

E Revision: I  ;

Page 35 of 36

_ j.

x

- RESULTS REPORT ISAP VII.a.7 -- -

(Cont'd) ,

I Appendix 4 . -.

(Cont'd)

'l FP 55-05B Pressurizer Relief Tank (RCATPR) (Cont'd) -Q but provided 2

the actual limits for an insulated surface (.0015 mg d C1/dm ). One swipe exceeded the allowable value for insulated ~['

t surfaces (.0032 mg/dm2 ). The relief tank was reeleaned in the unacceptable area and was retested acceptably. The original test k would not have exceeded non-insulated surface limits. '

d b__ ""

i

. FP 56-09 Recycle Holdup Tank #1 (CSATHT)

• PS 292722 requires the Boron Recycle Holdup Tank interior to be -

cleanliness Class C. FP 56-09 required the Recycle Holdup Tank to '

be verified to cleanliness Class B. The swipe test data sheet r  ; i I

(QI-QP-11.1-65) taken for swipe J-642, dated March 27, 1984, j; indicate a non-insulated surface and the correct chloride limits @

[- 2

(.015 mg/dm ) for a non-insulated surface. The CPSES ESAR, Table 1 K

9.3-8, shows the design temperature of the Boron Recycle Holdup i3 l Q Tanks to be 200*F. The swipe exceeded the allowable value for  : 4-

[ heated surfaces (.0020 mg/dm2 ) but was accepted because the T L, non-insulated surfaco limit was not exceeded. It was noted that a

the Recycle Holdup Tanks are identified by FSAR Figure 9.3-11 (P&ID -1 a 2323-M1-0258) as component 3RATRH instead of CSATHT noted by PS -

292722. See also comments to FP 55-10 below. _

i FP 55-10 Recycle Holdup Tank #2 (BEATRH-02) "

i^

j

PS 292722 does not identify a tank with identification BRATRH; as a Q result, the swipe test data sheets (QI-QP-11.1-65) taken for swipe >

i' J-731, May 18, 1984 did not identify any acceptance limits and made ., ;

g th- remark that the equipment was not listed in (W) specification '!

e92722 Revision 9. As noted in the discussion of FP 56-09 '

above, it appears that the tanks BRATRH (FSAR and P&ID) and CSATHT Li

[' (PS 292722) are the same. FP 55-1(' required the Recycle Hoidup Tank ^

! to be verified to cleanliness Class B. The swipe test results were

[ within the limits provided for insulated (heated) surfaces even though acceptance limits were not ideatified on the data sheets. } -

Traveler ME-82-1699-4900 Cation Bed Demineralizer (C3DMCB) n ";

j PS 292722 required the Cation Bed Demineralizer interior to bc ,j cleanliness Class C. The traveler, dated July 17, ;981 required j E' the derineralizer to be verified to Grade A cleanliness. The swipe g a

test data sheets (QI-QP-11.1-65) taken for swipe J-131 (July 18, 9

i. --

1982) indicate a non-insulated surface. The swipee exceeded the allowable value for heated surfaces (.0064 and .0030) but Hd not a

exceed the non-insulated surface limit. -

r-Revision: 1 3

Page 36 of 36 r-yb RESULTS REPORT ISAP VII.a.7 (Cont'd) l Appendix 4 (Cont'd) y Traveler ME-82-1754-4701 Resin Fill Tank (CSATRF)

PS 292722 requires the Resin Fill Tank interior to be cleanliness Class C. The traveler, October 4,1982 required the Resin Fill Tank to be verified to Grade A cleanliness. The swipe test data sheet (QI-QP-11.1-65) taken for swipe J-198, dated October 13

- 1982, does not indicate the type of service, but provides the '

chloride acceptance limits for heated (insulated) surfaces. This is not consistent with the actions taken for traveler ME-82-1699-4900 discussed above. The swipes met the acceptance requirements for insulated surface chloride contamination limits.

During a discussion of flush plans / travelers, TUGC0 Startup personnel

, stated that swipe test performance and acceptance was the responsibility the of B&R QC Laboratory and was governed by their procedures. Flush i

- plans / travelers, whose content is governed by procedure XCP-ME-4, were

-(w not required to define or reference swipe test acceptance criteria. No 5_) specific quality procedures were identified.

z, TUGC0 Startup' procedure ICP-ME-4, Revision 8 " System Cleanliness  !

Verification" - defines the requirements for the content of flush plans. l It does not address swipe tests, but does state that acceptance criteria  ;

, for visual examination and/or flushing are specified in procedure CP-SAP-24. [

CP-SAP-24, Revision 1 " System Cleanliness Requirements and Control" -

does not specify chloride and fluoride swipe test ecceptance limits nor clearly reference (y) specifications. Attachment B, which delineates the cleanliness classifications of various components / systems, does not

' specifically list the reactor vessel. As a result, the cleanliness classification of the reactor vessel is not defined in accordance with the (j) specifications.

TUGC0 Operations procedure STA-612, Revision 0 " Cleanliness Control" -

defines cleanness classifications and requiremen;s in Attachment 1.

Swipe testing is not addressed. Additionally, STA-612 states that the 77- procedure "...is to be implemented as systems, components and equipment come under custody of the CPSES operating staff.".

g. TUGC0 procedure QI-QP-11.1-65. Revision 4 " Determination of Surface Contamination of Fluorides and Chlorides on Stainless Steel" - defines c~ 3 swipe test sampling and analytical methods and acceptance criteria. The (E) specification PS 292722 is referenced and the acceptance criteria and cleanlinest classifications from PS 292722 and PS 84351 NL are

, included.

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