ML20212C981
| ML20212C981 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/27/1987 |
| From: | Wooldridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2649 OL, NUDOCS 8703040036 | |
| Download: ML20212C981 (53) | |
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WTED CORRESPONDENQt; WORSII AM, FORSYTIIE, S AM PELS ;& dYOOLDRIDGE THIRTY Two MUNORED,2OOI BRYAN TowENi '
M.D.SAMPCLS JOE A wCRSHAM ROBERT A. WOOLDRIDGE DALLAS, T EXAS 75201 iest-es7e NEtk D. ANDERSON *
$ ENCER C. RELVEA RONALD M. MANSON TE LEPHO N E (214) 979 - 0 MAR -2 P3 :23 Or COUNSEL J. DAN SOMANNAN JOS. IRION WORSM AM TR AvsS E. VAN DER POOL EARL A. FORSYTM E JUDsT M M. JOHNSON ReCM ARD L. ADAMS g f,l[ -
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TE LECOPIER;(214) 8 80- 0011
- JOMN w. McREYNOLDS ORANCW THOMAS F. LILLARD ROBER? n. wtSE .
TIMOTHY A. M AC M ROSERT M. F#LLMORE WM STE PH E N BOYD MARM R.WASEM CMR*STOP*.E R R. MILTE N B ERG ER ROeERY P O Lsv t e
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- "L E February 27,1987 NANCYE L. BETHUREM CECELIA J. BRUNER JOE A. DAvs$
E RaC M PEtERSON WALTER w. wM6f C Peter 3. Bloch, Esquire Dr. Kenneth A. McCollom Chairman Administrative Judge Atomic Safety and Licensing Board 1107 West Knapp U.S. Nuclear Regulatory Commission Stillwater, Oklahoma 74075 Washington, D.C. 20555 Dr. Walter H. Jordan Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory 831 West Outer Drive P. O. Box X, Building 3500 Oak Ridge, Tennessee 37330 Oak Ridge, Tennessee 37330 Re: Texas Utilities Electric Company, et at (Comanche Peak Steam Electric Station, Units 1 & 2); Docket Nos. 50 445 and 50-446 - 8b
Dear Administrative Judges:
Applicants have this date delivered to Mr. Vincent S. Noonan the following SRT approved Results Reports:
III.S Conduct of the CILRT VII.b.1 Onsite Fabrication These reports should be placed in sequence behind the tabs " Testing" for III.b and "QA/QC" for VII.b.1 in the results reports binders previously transmitted. Also enclosed is a revised Table of Contents reflecting the issuance of these reports. As with all previous Results Reports issued to date, this material is not being offered into evidence at this time and is provided for information only.
8703040036 B70227 Respectf Ily submitted,,
- j Robert A. Wooldridge l
RAW /k!w Enclosures Bp3 l cc: Service List I
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TABLE OF CONTENTS (L-~s>.
COLLECTIVE SIGNIFICANCE REPORT
- Later -
COLLECTIVE EVALUATION REPORTS
- Later -
RESULTS REPORTS Electrical I.a.1 Heat-Shrinkable Cable Insulation Sleeves -
Revision 1 I.a.3 Butt-Splice Qualification - Revision 1 I.a.4 Agreement Between Drawings and Field Terminations
- Revision 2 I.a.5 NCR's on Vendor Installed Amp Terminal Lugs
- Revision 1
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I.b.1 Flexible Conduit to Flexible Conduit Separation
- Revision 1 I.b.2 Flexible Conduit to Cable Separation - Revision 1 1.b.3 Conduit to Cable Tray Separation - Revision 1 I.b.4 Barrier Removal - Revision 1 Civil / Structural II.b Concrete Compression Strength - Revision 1 II.c Maintenance of Air Gap Between Concrete Structures
- Revision 1 Testino III.a.2 JTG Approval of Test Data - Revision 0 III.a.3 Technical Specification for Deferred Tests
- Revision 0 III.a.4 Traceability of Test Equipment - Revision 0 0
n-
- s TABLE OF CONTENTS (cont.)
Testino (cont.)
III.b Conduct of the CILRT - Revision 0 III.d Preoperational Testing - Revision 1 Mechanical V.a Inspection for Certain Types of Skewed Welds in.NF Supports - Revision 1 V.c Design Consideration for Piping Systems Between Seismic Category I and Non-Seismic Category I Buildings - Revision 1 V.d Plug Welds - Revision 1 V.e Installation of Main Steam Pipes - Revision 1 0A/0C I.d.2 Guidelines for Administration of QC Inspector Test
- Revision 1 I.d.3 Craft Personnel Training - Revision 1 VII.a.3 Document Control - Revision 1 VII.a.4 Audit Program and Auditor Qualification -
Revision 1 VII.a.5 Periodic Review of QA Program - Revision 1 VII.a.6 Exit Interviews - Revision 1 VII.a.7 Housekeeping and System Cleanliness - Revision 1 VII.a.8 Fuel Pool Liner Documentation - Revision 1 VII.b.1 Onsite Fabrication - Revision 1 VII.b.2 Valve Disassembly - Revision 1 DSAPs
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COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: III.b
Title:
Conduct of the CILRT REVISION O lO i
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I sue Coordinator 2-/9-87 Date Q _ - _ - , 2-I9-87 Roview Team Leader Date
&. 1- 2/% 3 0l John W(/ Beck, Chairman CPRT-SRT Date O
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Revision: 0 m Page 1 of 8
(} RESULTS REPORT U
ISAP III.b Containment Integrated Leak Rate Test (CILRT)
1.0 DESCRIPTION
OF ISSUE The NRC-TRT described this issue in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-14 Item 3.2.3, " Findings for Test Program Issues," as follows:
The Group [TRT] found no safety significance for the allegations in TP Category 3 (Containment Integrated Leak Rate Testing), but concluded that a generic problem could exist because when the CILRT leakage rate was calculated by a method different from that which was committed to in the FSAR, the FSAR had not been amended to reflect that change. The TRT questioned the TUEC procedure for documenting and identifying FSAR deviations to the NRC. . . .
2.0 ACTION IDENTIFIED BY NRC The action identified by the NRC-TRT in the CPSES Safety Evaluation O Report, Supplement No. 7 at Page J-17, Item 4.2.2, " Containment Integrated Leak Rate Testing (CILRT)," as being necessary to resolve this issue is as follows:
TUEC has identified deviations from FSAR commitments related to the CILRT. TUEC shall identify all other deviations from FSAR commitments which were not previously identified to NRC.
3.0 BACKGROUND
During the NRC-TRT investigation of an allegation concerning the conduct of the CILRT, the NRC-TRT reviewed the CILRT test data package. Two discrepancies involving test methodology were identified that suggested the possibility of a generic problem
( concerning test program commitments in the FSAR. The two i
discrepancies concerned the method of calculation of leakage rate and the physical configuration of the containment system during testing. The NRC-TRT forwarded these items to NRC-NRR for evaluation, and the resolution of them is documented in CPSES l Safety Evaluation Report, Supplement No. 7 at Page J-18 as follows:
l I
This title corresponds to the specific heading of the paragraph that identified this issue in the NRC letter dated September 18, O. 1984 and does not accurately reflect the scope of the review. The review considers FSAR commitments associated with preoperational testing.
I, Ravision: 0 g Pags 2 of 8 RESULTS REPORT
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ISAP III.b (Cont'd)
3.0 BACKGROUND
(Cont'd)
TUEC was also required in the September 18, 1984, letter to
" justify to NRC the conduct of preoperational CILRT (Type A Test) with penetrations isolated and leakage rate calculation in accordance with ANSI /ANS 56.8 rather than ANSI N45.4-1972" and to " identify to NRC any other differences in the conduct of the CILRT as a result of using ANSI /ANS 56.8 rather than ANSI N45.4-1972." These issues have been resolved (see page J-83); accordingly, the actions are no longer required.
In addition to the CILRT data package, the NRC-TRT reviewed fifteen of the twenty-two preoperational test data packages associated with hot functional testing. These reviews were also addressed in the CPSES Safety Evaluation Report, Supplement No. 7. No additional FSAR deviations were reported by the NRC-TRT.
The preoperational test program is conducted in accordance with written administrative control procedures and test procedures. The administrative procedures are reviewed by the Lead Startup Engineer and the Manager, Operations Quality Assurance. These procedures are approved by the Manager, Startup. The test procedures are reviewed and approved by a Joint Test Group (JTG),
the membership of which reflects the CPSES design, testing, and operating organizations, as well as the NSSS supplier. The administrative procedures establish the methods for preparation, review, approval, conduct, and results review of each test procedure. Test procedures are prepared and executed by the Startup organization, which also prepares the test data packages for subsequent review and approval by the JTG.
i Shortly after receipt of an NRC letter dated September 18, 1984, in
! which the findings of the NRC-TRT were initially reported, the JTG initiated a reevaluation of the preoperational test data packages l it had previously approved. This reevaluation effort was performed in accordance with Startup* Administrative Procedure CP-SAP-11, e i
" Review, Approval and Retention of Test Results," augmented by i additional criteria approved by the JTC. The scope of the reevaluation included the three hot functional test data packages in which the NRC-TRT expressed a concern regarding test objectives; the seven hot functional test data packages that were not reviewed l by the NRC-TRT; and a sample of the remaining 139 preoperational l test data packages that had been approved by the JTG as of i September 17, 1984 The sample consisted of twenty test data packages considered by the JTG to be the most safety-significant.
The JTG completed its reevaluation in April 1985. One reevaluation criterion, among others, was to reverify FSAR commitment compliance as it applied to each of the test data packages. The JTG did not identify any additionci undocumented deviations from FSAR commitments.
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RESULTS REPORT (A)
ISAP III.b (Cont'd)
3.0 BACKGROUND
(Cont'd)
In Revision 3 and previous revisions to ISAP III.b, " Containment Integrated Leak Rate Test," the approach to the FSAR commitment compliance review was to examine additional FSAR sections if discrepancies were noted in the test program commitments. This Action Plan examines the test program related commitments. FSAR compliance considerations related to the design and construction of CPSES are being conducted under the Design Adequacy and Quality of Construction Programs described in Appendix A and B, respectively, to the CPRT Program Plan.
4.0 CPRT ACTION PLAN The objective of this Action Plan was to provide reasonable assurance that the preoperational testing program has been, and is being, conducted in accordance with commitments made in the FSAR.
4.1 Scope and Methodology Q The following tasks were implemented to achieve the objective:
4.1.1 Startup Administrative Procedures The administrative process by which the Startup organization identifies and reports FSAR commitment deviations was reviewed.
4.1.2 FSAR Commitments The CPRT reviewed preoperational testing commitments presented in Table 14.2-2, "Preoperational Tests -
Summaries," of Section 14.2, " Initial Test Program."
The relevant preoperational test data packages were reviewed to determine if commitments in the FSAR had been met. The review was based on a sampling program discusced in Section 4.4, " Sampling Program."
4.2 Participants' Roles and Responsibilities The CPRT Testing Program Review Team Leader, Mr. J. E.
Rushwick, was responsible for the reviews and evaluations described in Sections 4.1.1 and 4.1.2. The Startup Special Projects Supervisor, Mr. G. M. McGrath, provided assistance with the sampling. program.
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4.0 CPRT ACTION PLAN (Cont'd) 4.3 Qualifications of Personnel The CPRT Testing Programs Review Team Leader met the qualifications as described by the CPRT Program Plan. The Review Team Leader (RTL) was responsible for ensuring that other personnel providing assistance in the conduct of the Action Plan were appropriately qualified.
4.4 Sampling Program Commitments pertaining to the preoperational testing program are discussed in various sections of the FSAR. These commitments are shown in summary form in FSAR Table 14.2-2, "Preoperational Tests Summaries."
^
Since previous reviews by the JTG and NRC-TRT had not led to the identification of any additional deviations from FSAR consiements..the RTL elected to examine compliance with FSAR commitments via a random sampling program, as a means to determine if a generic problem existed. The population of FSAR commitments examined consisted of the 254 specific tests listed in the Test Methods section of FSAR Table 14.2-2.
Recognizing the FSAR commitment deviation identified by the NRC-TRT as an item in the population of interest, the minimum sample size necessary to achieve the basic objective of Appendix D "CPRT Sampling Policy, Applications and !
Guidelines," of the CPRT Program Plan, was ninety-five items.
4.5 Acceptance criteria 4.5.1 Startup Administrative Procedures
! The Startup Administrative Procedures were acceptable if measures were established to assure the 6 identification and reporting of FSAR commitment l deviations.
, 4.5.2 FSAR Commitments l
l Each preoperational testing-related FSAR commitment j sampled was set, or if not, the reason had been documented and reported to the NRC.
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} RESULTS REPORT
{G ISAP III.b (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The following presents the results of the review of the Startup organization's administrative procedures as they relate to FSAR commitment adherence, and the results of a review of a random sample of FSAR commitments for compliance.
5.1 Startup Administrative Procedures The Startup organization's Startup Administrative Procedures (SAP) were reviewed. The following procedures were identified as establishing requirements pertinent to the issue of FSAR commitment adherence prior to the NRC-TRT review:
CP-SAP-2, "Startup Program Organization and Responsibilities," delegates responsibility for FSAR commitment compliance during test procedure preparation, review, and approval to the Startup and TU Engineering organizations. The Manager of Startup is specifically identified as being responsible for O assuring that all preoperational testing is identified and performed according to the requirements of the FSAR.
CP-SAP-7, " Format and Content of Test Instructions /
Procedures," provides guidelines for preparing each section of a test procedure. The test procedure preparer is directed to use appropriate references in j the FSAR when establishing the objective of a test procedure. References used in preparing a test procedure are required to be identified.
1 CP-SAP-8, " Review, Approval and Revision of Test Instructions / Procedures," directs the test procedure i reviewers to an attachment that provides guidance for the JTG review. The attachment directs the reviewers to assure that the stated acceptance criteria are consistent with FSAR commitments.
A review of the evolution of the above-noted procedures was conducted. It was determined that the need to address FSAR testing-related commitments had been recognized since the inception of the CPSES Startup Program. The findings described above with respect to the current revision of SAP Nos. 2, 7 and 8 are equally valid for all of the preceding revisions as far back as late 1979. The first Unit 1 preoperational test was started in July 1982.
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, Peg 2 6 of 8 O RESULTS REPORT V ISAP III.b (Cont'd) 5.0 IMPL MENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
It should also be noted that subsequent to hot functional testing, the JTG recognized that some preoperational testing comitments described in the FSAR would not be met. These commitments related to performing tests at normal operating temperatures and pressure. At that time, the next heatup was scheduled in the interval between fuel loading and criticality. A program of deferred preoperational testing was organized. The program consisted of evaluating preoperational test commitments, evaluating the consequences of deferring preoperational tests with the requirements of the Technical Specifications, and, where necessary, seeking approval of NRC-NRR. This program was in place and operating prior to the NRC-TRT review. (See Results Reports for issues III.a.2, "JTG Approval of Test Data." and III.a.3, " Technical Specifications for Deferred Tests.")
The following additional SAPS were modified subsequent to the NRC-TRT review to include explicit reference to FSAR cosaitments:
CP-SAP-11. " Review, Approval and Retention of Test
! Results," provides guidance in an attachment for the
! JTG's use during its review of test data packages. One i
criterion is that the " test satisfied applicable FSAR couaiements."
, CP-SAP-12 " Deviations to Instructions / Procedures,"
l requires that Test Procedure Deviations (TPD) that I change the intent of a test procedure be evaluated by l the Startup organization's Technical Support /Startup Special Projects (TS/ SSP) Group for FSAR testing i
couaitments compliance and approved at the next JTG aceting. The SAP defines a " change of intent" as a procedure deviation that " includes changes to the test objective, acceptance criteria or the test methods which prevents verification of the test objective or acceptance criteria or FSAR conunitments." All TPDs become an integral part of the test data packages subsequently reviewed and approved by the JTG.
CP-SAP-14 " Design /FSAR/ Technical Specification Change Request Processing," requires that FSAR changes, among other changes, be tracked as to the status of each change, and provides instructions for initiating O changes to the FSAR.
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[~'N RESULTS REPORT
() ISAP III.b (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Preoperational testing generally occurred prior to NRC-TRT review. Although the Startup organization did not have a specific written administrative procedure for processing an FSAR change until after the NRC-TRTs review, the practice was for Startup to complete a standard FSAR Change Request form.
This form was generally available throughout Startup's facilities, as well as those of Operations and Engineering.
The RTL reviewed approximately one-hundred FSAR Change Requests submitted by the Startup group using this form.
These forms were available in a TS/ SSP historical file. The purpose of this review was to determine the types of changes that Startup was requesting, and the depth of detail in which they were reviewing the FSAR prior to the revision of CP-SAP-14. The majority of these changes were requested during test procedure development, and consisted of necessary clarifications due to design changes or of corrections due to inconsistencies between FSAR sections. The changes requested by the Startup organization were found to be very detailed in C') nature, indicating that a thorough review of the FSAR had been performed as it relates to testing activities.
5.2 FSAR Commitment Compliance Review As described in Section 4.4, ninety-five preoperational testing-related FSAR commitments were randomly selected and evaluated for compliance. In each case, the FSAR commitment was found to have been met as evidenced by supporting documentation in the associated test data package. No i deviations were found, and no adverse trends were identified.
5.3 Root Cause and Generic Implications No testing deficiency'was identified through the implementation of this Action Plan. Accordingly, no root cause and generic implications analyses were required. With respect to the FSAR deviation identified by the NRC-TRT, the RTL found no evidence to substantiate the existence of a generic problem.
6.0 CONCLUSION
S Based on its review of established administrative procedures and O practices, and the results of the sampling program conducted to provide a statistical measure of commitment compliance, the RTL
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6.0 CONCLUSION
S (Cont'd) concluded that there is reasonable assurance that the preoperational test program has been, and is being, conducted in accordance with the connaitments presented in the FSAR.
7.0 ONGOING ACTIVITIES There are no ongoing activities.
8.0 ACTIONS TO PRECLUDE OCCURRENCE IN THE FUTURE No actions to preclude occurrence in the future were required.
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4 COMANCHE PEAK RESPONSE TEAM !
RESULTS REPORT i
f ISAP: VII.b.1
Title:
Onsite Fabrication REVISION 1 i
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I db.0 Issue Coordinator 1-/1-87 Date #
_. -A h b/&$1 Re ~Isan Leader ~ N Datsf /
JohnLW. Beck, Chairman CPRT-SRT Date 1 /t[f 7 i
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/ 'i RESULTS REPORT
\j ISAP VII.b.1 Onsite Fabrication
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC 1.1 USNRC-TRT Letter January 8, 1985. Issue 8. Onsite Fabrication "The TRT findings regarding onsite fabrication shop activities indicated that:
A. The scrap and salvage pile in the fabrication (fab) shop laydown yard was not identified and did not have restricted access.
B. Material requisitions prepared in the fab shop did not comply with the applicable procedure.
C. The fab shop foremen were not familiar with procedures that controlled the work under their responsibility.
D. Fabrication and installation procedures did not include p information to ensure that Brown & Root fabricated gj threads conformed to design specifications or to an applicable standard.
E. Indetermimte bulk materials that accumulated as a result of site cleanup operations were mingled with -
controlled safety and non-safety material in the fab shop laydown yard.
F. Site surveillance of material storage was not documented.
C. Work in the fab shop was performed in response to memos and sketches inste.id of hanger packages, travelers, and controlled drawings."
2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT firdings 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..."
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" Address the collective significance of these deficiencies..."
" Propose an action plat....that will ensure that such problems do not occur in the future."
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RESULTS REPORT ISAP VII.b.1 (Cont'd)
3.0 BACKGROUND
This Action Plan provided for an assissment of onsite fabrication activities, in general, whether performed in the fabrication shop or other plant areas.
CPSES Safety Evaluation Report Supplement No. 11 (SSER 11), May 1985. Appendix 0, Allegation AQ-138 (pages 0-145 to 0-153) discussed fabrication shop activities under QA/QC Category 5B, Onsite Fabrication. Specifically, Allegation AQ-138 consists of twelve (12) elements:
- 1. Personnel asked to perform work without knowledge of paperwork. (Substantiated)
- 2. Paperwork illegal due to post dating. (Unable to substantiate)
- 3. Non-safety material mixed with safety-related material. (Not substantiated) d
- 4. Personnel directed not to mark indeterminate material as scrap. (Not substantiated)
- 5. Electrical and iron fab shop material consolidated and mixed.
(Not substantiated)
- 6. Electrical personnel used undocumented material. (Unable to
, substantiate)
- 8. Undocumented weld repairs made on base metal. (Unable to substantiate)
- 9. Threaded rod cut without QC verification of heat numbers.
(Not substantiated)
- 10. Arc cut done too close to cut line. (Unable to substantiate)
- 11. Beam clips may have been cracked during bending. (Not substantiated)
- 12. Chain and triple hook fabricated without regard to procedures.
(Unable to substantiate)
NOTE: The statements shown in parentheses above are NRC conclusions.
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U RESULTS REPORT ISAP VII.b.1 (Cont'd)
3.0 BACKGROUND
(Cont'd)
SSER 11, Appendix P (Page P-14) lists seven (7) concerns relative to Allegation AQ-138. Four (4) of these concerns are a reiteration of ones stated in AQ-138. The remaining three (3) , listed below, are the result of the TRT investigation of AQ-138.
- 1. Material requisitions did not comply with procedures.
- 2. Random QC surveillance of storage areas not performed.
- 3. Unused material not returned to warehouse.
A preliminary investigation by the QA/QC Review Team indicated that except for the fuel pool liner fabrication effort, only a small amount of safety-related work was performed in the onsite fabrication shop prior to January 1980. The work activities performed at the onsite fabrication shop ranged from simple cutting of material through the fabrication or modification of complex A items that involved fit-up, welding, and machining operations.
() Because of modifications, the fabrication of components often occurs periodically throughout the installation and checkout phases of an item. Consequently, a documentation package for a completed assembly sometimes includes inspection data entries covering a time span of five (5) years or more. The program of procedural controls for onsite fabrication activities has evolved with time as a result of corrective actions to problems identified by both internal and external sources.
Fabrication and inspection records for work performed are not maintained on file in the fabrication shop. Locating the trail of work performed in the shop required utilization of the shop's hanger request and memoranda files. These files provided a trail for evaluating the records of the work performed (drawing, procedure, inspection, installation and acceptance) as recorded in the item documentation packages. The documentation packages j identified through the use of the shop's files include records of fabrication activities performed in the shop and within the plant during installation. These packages are maintained and available for review either in the TUCCO records vault or the Brown & Root permanent plant records vault (PPRV) for completed items and in the interim records vault (IRV) for items in-process, b) e l
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Rcvioicn: 1 Page 4 of 40 x RESULTS REPORT ISAP VII.b.1 (Cont'd)
3.0 BACKGROUND
(Cont'd)
Based upon the preliminary investiga' t ion, it was determined that a directed approach for selecting sample items for review would provide a more effective means to assess a representative cross-section of activities over time than would a random sample selection process. The use of a directed approach ensured that the selection of items that involved significant iron shop fabrication activities included items fabricated during the time period involved with the TRT investigations, i.e., July a September 1984.
Coupled with an indepth survey of current fabrication shop activities, the directed approach also enabled assessment of the evolving program of procedural controls with time and an evaluation of the ef fectiveness of corrective actions taken for the problems identified by internal and external sources.
4.0 CPRT ACTION PLAN 4.1 Scope and Methodology O This Issue-Specific Action Plan assessed the adequacy of the procedural control of onsite fabrication activities at CPSES.
These activities include fabrication in the onsite fabrication shop as well as fabrication-type activities performed within the plant during installation. Action Plan VII.a.8, " Fuel Pool Liner Documentation", identified a large number of documentation discrepancies resulting from failure to implement procedures and the lack of definitive procedural direction. Due to the potential for the existence of similar discrepancies in other areas / work activities,'the scope of Action Plan VII.b.1 was expanded to encompass onsite fabrication activities in general. The evaluation considered the evolution of procedural controls with time and includes an assessment of the current program.
This action plan consisted of two separate areas of evaluations a) Concerns that were evaluated by review of safety-related fabrication document packages:
Material requisitions not properly completed.
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Fabricated thr6ad conformance.
Fabrication / inspection accomplished without full knowledge / utilization of correct paperwork e.g., drawings, travelers and procedures.
Fabrication using undocumented material.
Fabrication involving unauthorized / improperly documented repairs.
b) Concerns that were evaluated by physical survey and by review of procedures, survey, surveillance and audit records to identify trends and corrective action effectiveness:
e -
Shop Foremen familiarity with procedures.
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Control of nonconforming hardware, indeterminate material and scrap and salvage areas.
Segregation of safety, non-safety and bulk material.
Surveillance of asterial storage.
The specific methodology is described below.
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' Applicable material storage, fabrication, and inspection procedures in effect for both ASME and non-ASME safety-related work in onsite fabrication areas were identified and reviewed.
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The procedural adequacy with respect to controls for material traceability, fabrication processes and ites acceptability was evaluated for compliance with the applicable requirements of 10CFR50 Appendix B and the FSAR.
Categories of both ASME and non-ASME safety-related fabricated I items were selected for review in a manner that provided for l
an evaluation of a reasonable cross-section of onsite
' fabrication shop activities for the time period 1980 through December 1985. Three (3) ASME Code and six (6) non-ASME Code sample items were also selected from the 1978 and 1979 time O. period, f
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V ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
ASME Item Selection -
Because fabrication and inspection records are not maintained in the fabrication shop, the shop's hanger request and memoranda files were reviewed to select the ASME Code items for evaluation. The files contained information for identifying items that represented significant fabrication activities, both in the shop and within the plant, during selected time periods, e.g., the time of the TRT's investigations, July - September 1984.
Fabrication shop activities consist of the following groups of work activities:
a) Cutting of material and material identification transfer.
b) Fitup and welding.
/^s b c) Machining, threading, bending, and other forming activities.
The fabricated / modified items under the jurisdiction of ASME Code requirements that were selected for review represented at least two (2) of the above groups of work activities. Where practical, based upon the above groups of work activities, three (3) sample items per calendar quarter were selected over the 1980 through 1985 time period. Three (3) sample items were also drawn from the 1978 and 1979 time period for a total of seventy-three (73) items.
Non-ASME Item Selection The documentation packages for eighteen (18) items not subject to ASME Code requirements (cable tray hangers) were also evaluated. The non-ASME sample items were selected by reviewing a data base printout that contained a listing of cable tray hangers and their fabrication completion dates.
Fabrication activities associated with cable tray hangers and structural steel comprise essentially all of the safety-related work performed by the fabrication shop. The only structural steel items evaluated were those fabricated or modified as a task operation incidental to completion of a o component support assembly. Other structural steel items were
( I not evaluated independently because of their lack of complexity, i.e.. review team inability to identify individual
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RESULTS REPORT ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) structural steel items that inv'lved o a significant number of fabrication shop processing operations. The QA/QC Review Team concluded that a review of structural steel items would not provide information, relative to the fabrication shop, different than the ASME and non-ASME sample items. The structural steel population within Action Plan VII.c evaluated the fabrication / installation of structural steel since these activities took place primarily within the plant.
Review Activities The completed documentation packages for the selected sample items were reviewed for adequacy of material identification, applicable drawings and procedures used, and fabrication and inspection sign-offs. Deviations identified during the review were documented and processed in accordance with CPRT procedures. When necessary to confirm or resolve the-deviation and aid in the safety significance evaluation, the O hardware was examined in place.
An indepth survey of current fabrication shop activities was also performed. This three-part survey was implemented to determine the adequacy and implementation of present procedural controls and to resolve or confirm the NRC-TRT investigation concerns that could not be assessed by review of documentation alone, e.g., shop forenen familiarity with procedures and singling of controlled safety and non-safety material.
Storage and surveillance procedures and records were reviewed, under Action Plan VII.a.7, " Housekeeping and System
, Cleanliness", for adequacy of requirements, identification of trends, and effectiveness of corrective action. Information I from the VII,s.7 evaluation was evaluated for applicability to
! the issues addressed in this Action Plan.
'.i
, A detailed analysis on the data from the above l reviews was conducted to determine the adequacy of onsite 3
fabrication activities in meeting the applicable requirements of 10CFR50 Appendix B and the FSAR.
t i Deviations identified were documented on either a Construction Deviation Report (DR) or on a QA/QC Program Deviation Report
] (PDR) and evaluated in accordance with CPRT progran j- requirements.
I I
Rsvicion: 1 Pcge 8 of 40 RESULTS REPORT Oi ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Deviations related to material traceability were documented on Deviation Reports and were transmitted to the Action Plan VII.a.1 Issue Coordinator for evaluation and action as appropriate.
4.2 Participant's Roles and Responsibilities The organizations and personnel that participated in this effort are described below with their respective scopes of work.
4.2.1 TUCCO CPSES Project 4.2.1.1 Scope Assisted the QA/QC Review Team in the identification and provision of specifications, drawings, procedures O and other documentation necessary for the execution of this action-plan.
Assisted in determining the type of items fabricated or modified onsite in the fabrication shop and/or other plant areas.
Processed NCRs that were generated due to this action plan.
4.2.1.2 Personnel Mr. C. R. Hooton Project Coordinator
, (TNE)
Mr. D. W. Snow TUCCO QC Coordinator 4.2.2 CPRT QA/0C Review Tema 4.2.2.1 Scope The QA/QC Review Teau was rt .ponsible for O evaluating the adequacy of completed inspection records (documentation packages) for the selected sample items.
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ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.2 Personnel (prior to March 1, 1986)
Mr. John Hansel QA/QC Review Team Leader Mr. S. L. Crawford Issue Coordinator 4.2.2.3 Personnel (starting March 1, 1986)
Mr. J. L. Hansel QA/QC Review Team Leader Mr. G. W. Ross Issue Coordinator 4.3 Qualifications of Personnel There were no tests or inspections required during the implementation of this action plan; therefore, inspection personnal certified in accordance with ANSI N45.2.6 were not required Participants were qualified to the requirements of the CPRT Program Plan.
4.4 Procedures Matrices, checklists and data sheets were developed as an integral part of the evaluation. No formal procedures were prepared because no reinspections were performed.
4.5 Standards / Acceptance Criteria Acceptance criteria were based on the requirements of 10CFR50 Appendix B, FSAR commitments, applicable codes and standards and a review of shop fabrication procedures, QC inspection procedures, drawings and sketches.
Fabrication work activities were considered acceptable if all required documents:
a) were present and correctly identified the drawings and process procedures used, b) identified the inspection criteria and O c) provided authorized inspection sign-offs attesting to the adequacy of the items and documentation.
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,e~T RESULTS REPORT
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ISAP VII.b.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Population Identification
- The types of activities performed in the fabrication shop were reviewed to identify populations of work for which the documentation could be evaluated for implementation of this Action Plan. The documentation for safety-related component support assemblies was determined to be the most applicable for evaluation because these assemblies typically require a considerable amount of onsite fabrication / modification of piece parts and represent a major portion of the work performed in the onsite fabrication shop, i.e., fitup, welding, assembly, and inspection.
Documentation packages related to pipe hanger assemblies were identified to represent ASME Code fabrication activities and packages related to cable tray hangers were identified to represent the non-ASME safety-related activities.
(~') 5.2 Sample Selection
\J A sample of seventy-three (73) assemblies, subject to ASME Code, was selected primarily by reviewing the hanger request and memoranda files located in the CPSES onsite fabrication ihop. Each of the selected items represented fabrication / modification effort involving at least two (2) of the following groups of work activities:
a) Cutting of material and material identification transfer, b) Fit-up and welding, c) Machining, threading, bending, and other forming activities, i
Of the seventy-three (73) ASME sample items reviewed, the selection included approximately three (3) per calendar quarter over the period January 1981 through December 1985.
Fifteen (15) samples were selected for 1981. Because of the limited pipe hanger installation effort prior to 1981, only
' two (2) samples were reviewed for 1978, one (1) for 1979 and seven (7) for 1980. The samples for 1978 and 1979 were selected from the Action Plan VII.c populations because of the
(s limited hanger request and memoranda files maintained by the
('~' ) fabrication shop for the 1978 and 1980 time-frame. The samples for 1980 were selected by reviewing a number of
1 Rsvision: 1 Peg 2 11 of 40
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t RESULTS REPORT ISAP VII,b.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) documentation packages in the Permanent Plant Records Vault (PPRV) and selecting those that represented a significant number of fabrication activities during that year.
The non-ASME sample items were selected by review of a data base printout maintained in the PPRV. The printout contained a listing of the cable tray hangers in numerical order and also identified the inspection records, including their dates of sign-off, that were included in the documentation packages.
Based upon the inspection sign-off dates, a total of eighteen (18) non-Code, safety-related cable tray hanger documentation packages was selected [three (3) per year from 1978 through i 1983).
5.3 Procedure Requirements The historical files for the construction and inspection
[)
V procedures used for the work activities being evaluated were initially subjected to a general "overall requirements" review based upon the requirements of 10CFR50, Appendix B and FSAR commitments.
The review of inspection procedures included an evaluation of the evolution / maturation of procedural controls with time.
t The criteria listed below were utilized for evaluating the I procedures:
Title with issue or effective date.
- Listing of all applicable references.
Complete purpose and scope.
Responsibility for implementation.
Identification of personnel qualification requirements.
Instructions (detailed instructions including delineation of required inspection points).
i -
Acceptance criteria for all inspected attributes.
I i A -
Processing of nonconforming attributes.
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,M RESULTS REPORT ISAP VII.b.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Documentation requirements. (i.e., How to fill out documents or otherwise record data or document the acceptance of an attribute inspected.)
Review and processing of records.
Referenced, and clearly defined use of attachments.
The results of the review are documented on checklists that are included in the Action Plan working file. (Reference 9.1]
A listing of the procedures reviewed is presented in Attachment 1 to this report. Brown & Root construction procedures provided the criteria used by craft for fabrication and installation activities both in the fabrication shop and within the plant. Inspection activities associated with component supports subject to ASME Code requirements were also governed by B&R procedures. TUGC0 procedures governed the inspection activities associated with non-ASME code sample items.
Following review of the historical procedures, a separate indepth evaluation was performed relative to the adequacy of the current construction and inspection procedures for the ASME Code (pipe hanger) and non-ASME Code (cable tray hanger) component supports. This evaluation was performed as a part of the indepth survey of current fabrication shop activities (discussed in Section 5.5 of this report) and utilized checklist criteria prepared specifically for that survey l (Reference 9.2).
1 Procedures Evaluation Rasults As reflected in Attachment 1, inspection requirements and i accept / reject criteria for component supports were provided in a large number and variety of procedures. Many of these i
provided overlapping and differently stated requirements and criteria; most underwent many modifications during the 1978 to l 1985 time period. For example, QI-QAP-11.1-20, (issue date I
' January 3, 1980) was revised seven (7) times in 1980. As indicated in Attachment 2, QI-QAP-11.1-28, (issue date September 8, 1980) has been revised thirty-four (34) times and currently references twenty-one (21) different forms / documents with applicability to component support documentation packages, compared to only seven (7) required by earlier versions. Subsidiary procedures have similarly undergone j numerous revisions.
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Rsvision: 1 Psgs 13 of 40 fq RESULTS REPORT
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ISAP VII.b.1 (Cont'd) 5.0 IMPLhMENTATIONOFACTIONPLANANDDISCUSSIONCFRESULTS(Cont In evaluating the results of the procedure reviews, the relative significance of the above criteria was considered.
Although inadequacies were identified in both the historical and current construction procedures, they were judged to be minor and would not adversely impact the performance of activities governed by the procedure.
Inadequacies were also identified in both the historical and current inspection procedures. Most of the inadequacies were minor and would not adversely impact the performance of inspection activities. However, many of the inspection procedures failed to provide adequate instructions for documenting the results of inspections. As a result, the documentation packages for component supports may not contain objective evidence that all required inspections have been performed and accepted. The documentation package review i
discussed in Section 5.4 confirms that this is the case.
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The following are examples of the inadequacies identified in the primary governing inspection procedure employed by Brown &
Root for the ASME Code sample items (QI-QAP 11.1-28).
c Paragraph 3.4.3, Nopa 2 requires inspection verification of welder qualification and verification i of weld filler material data between the WFML and the l WDC, (Weld filler material log and Wald Data Card). No inspection instructions or provisions are included, i
however, for recording the inspection results.
The procedure does not address inspection nor does it provide criteria for the inspection of onsite fabricated U-bolts. (Although TUGC0 inspection instruction QI-QP-11.14-1 addresses such inspection for their,non-ASME hardware, Brown & Root has no comparable procedures). The documentation packages assembled by Brown & Root contain no objective evidence for the inspection of U-bolts fabricated onsite.
Paragraph 3.7.3 provides criteria for use by inspectors for verification of concrete anchor bolts length identification and die stamping. However, no j instructions or provisions are included relative to i
documenting these inspections.
() -
Paragraph 3.4.4.7 addresses inspection requirements relative to " weep hole" verification; however, no instructions or provisions have been included for documenting the results of this inspection.
R. vision: 1 Psg2 14 of 40 RESULTS REPORT ISAP VII.b.1 (Cont'd) ,
5.0 IMPLDfENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
In addition, both the Brown & Root and TUGC0 procedures reflect inadequate compliance with the applicable B&R and TUGC0 internal requirements for the preparation, content and structure of procedures. (Reference B&R CP-QAP-6.1 and CP-CPM-6.1; TUGCO CP-QP-6.0) For example, CP-QAP-6.1 requires that the reference section shall list the codes, standards, procedures, etc., that are referenced in the text. Procedure QI-QAP-11.1-28. Revision 34 does not list the supporting procedures that are referenced in the text.
An evaluation conclusion is that the historical individual procedures lack procedural integration, i.e., the precedence / hierarchy of procedures is not clearly delineated within the procedures or by a " hierarchy of procedures" document. Many of the individual procedures lack full references to other applicable procedures, attachments and inspection forms. Such references are necessary for ensuring the recording and compilation of consistently adequate inspection documentation.
The identified inadequacies described in the paragraphs above have been transmitted to the QA/QC Collective Evaluation Group for use in conjunction with their overview of the TUGC0 program for updating specifications, procedures and drawings
, as discussed in Section 7.0 of this report.
It should be understood that the procedure review did not evaluate the technical adequacy to ascertain the completeness of the overall inspection program or to determine the adequacy of the stated acceptance criteria or construction i
requirements. Such a detailed technical adequacy review is not within the scope of this Action Plan. The results of the Action Plan VII.c evaluation of the quality of construction I indicate that technically inadequate construction and l inspection procedures are the root cause or a contributing cause of some of the construction deficiencies and adverse trends identified by the VII.c reinspections/ documentation reviews. See the Action Plan VII.c Results Report for the details of these findings.
5.4 Documentation Package Review The inspection requirements information resulting from the p review of Brown & Root and TUCCO inspection procedures was used in developing a checklist for evaluating the onsite I
l fabrication activities. This infor:ation, in conjunction with
Rsvisiont 1
'Pago 15 of 40 n'
g RESULTS REPORT ISAP VII.b.1
- (Cont'd) 5.0 IMPLEMENTATION OF /7 TION PLAN AND DISCUSSION OF RESULTS (Cont'd) i
- information from the applicable' requirements of 10CFR50, Appendix B, ANSI N45.2; ASME Section III; Gibbs & Hill specifications 2323-MS-46A, ES-100, SS-16B and SS-17; and the j commitments in Chapter 17 of the FSAR, provided criteria for -
assessing the adequacy of the documentation.
! The documentation packages for the sample items were reviewed
} in accordance with the checklist. Where the package included references to other documentation such as receiving inspection records (RIR), inspection reports (IR) and nonconformance
- reports (NCR) filed elsewhere, that documentation was also reviewed.
To perf'orm the assessment of Brown & Root and TUGC0 compliance to procedural controls, it was necessary to review, extract i and record information from a large number of forms and inspection record sheets such as Material Identification Logs (MIL), Hanger Inspection Reports (HIR), Weld Filler Material l Logs (WFML), Component Modification Cards _(CMC),
Vendor-Supplied Component Modification Records (VSCMR), and 1 Nondestructive Examination Reports (NDE). The types of review l data extracted from these inspection forms and records are j reflected on the individual checklists and data sheets
! compiled for each of the documentation packages evaluated.
{ The individual checklists and data sheets have been retained ,
i and are included in the Action Plan working file. [ Reference l 9.3]
1 ,
i Review of the documentation packages identified numerous
- deviations that can be placed into either of two (2)
{ categories - general or specific. General deviations are those that were prevalent in a substantial number of sample ;
items and reflect deviations of a procedural or QA program -
- nature. General deviations were documented on Program l Deviation Report,s (PDRs). Specific deviations are those
! associated with specific component support assemblies or items ,
! and concern missing data, undocumented traceability of ,
- material, indeterminate inspector certifications or welder
! qualifications, etc.. The specific deviations were documented
{ on Construction Deviation Reports (DRs). Descriptions of both l I
the general and specific deviations identified during the
! implementation of this Action Plan are included in Attachments
, 3 and 4 to this report. Summaries of these deviations are provided later in this section.
I l . ,
Revision: 1 Page 16 of 40 RESULTS REPORT
{aT ISAP VII.b.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The matrix in Attachment 5 to this report presents a summary of the numbers and types of deviations found in each of the sample items. The deviations are tabulated by attributes that correlate to the more detailed attribute criteria provided in the Action Plan checklist developed specifically for review of the sample items.
During the records review, no attempt was made to evaluate the significance of the individual deviations, i.e., obvious transposition errors were documented and counted as heavily as were errors of omission. Following the Action Plan documentation review, however, each of the specific deviations was evaluated and classified as to its potential effect on the hardware. A listing of the specific deviations and definitions of the assigned classifications of
" insignificant", " notable", and "significant" are given in Attachment 4. It should be noted that the definitions and f- s usage of these classifications are unique to the deviations
() identified by this Action Plan.
The number of discrepant / questionable data points varied from none in six (6) of the sample packages to as many as twelve (12) in one sample package. In general, about two (2) discrepant / questionable data point entries were found in typical sample items.
The number of inspection points varies from sample item to sample item depending on hardware complexity, procedural maturity and hardware rework. Also, because of the sample selection criteria employed, the Action Plan sample items likely involved "above average" amounts of onsite fabrication and fabrication-related activities.
In order to provide a perspectiva. of the number of errors versus the number of opportunities for error, a review of a typical sample documentation package from each of four (4) time periods was made. This review, while not comprehensive, indicates that the number of opportunities for error varied from forty-nine (49) in the earlier time period to four
,j L
hundred thirty-four (434) in the later time period, while the number of errors remained relatively constant at about two per package.
, The ratio of the number of data point deviations versus the number of opportunities for error found in the documentation packages declined, in general, for the ASME Code assemblies fabricated / modified during the latter years covered by-this
Revision: 1 Page 17 of 40
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-(y RESULTS REPORT ISAP VII.b.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) evaluation. The decline in devlations (despite the increasing number of opportunities for making data entry errors because of added requirements), is most likely attributable to experience gained with. applicable hardware items and procedures.
Review of Related Records Welder Qualification The qualification status of all welders who performed the onsite welding recorded in the sample item documentation packages was reviewed to verify qualification in applicable weld processes on the dates identified for the welding activities. The review was limited to verifying that the correct qualification codes for the applicable weld processes were recorded (g -
\'
)
on the weekly Welder Qualification Matrix (WQM) for the dates identified. The use of the Welder Qualification Matrix was considered acceptable based on the ISAP VII.a.8 Issue Coordinator's evaluation of its accuracy.
No discrepancies related to welder qualification were identified during the evaluation of the seventy-three (73) sample items subject to ASME Code requirements.
However, appropriate welder qualification records could not be located for several of the welders of record who performed welding activities on eight (8) of the non-ASME Code cable tray hanger sample items. A Construction Deviation Report (DR) was written to document the questionable welder qualification status ,
relative to the identified sample items. (Reference DR No. R-VII.b.1-EGEN-DR31.]
Inspectors and NDE Personnel Certification The certification status of all QC inspectors who had performed or signed off inspections on the sampled records (repair records, hanger inspection reports, material identification logs, NDE reports, etc.) was .
reviewed by reference to personnel certification files.
A comparison was made to determine if the personnel had been certified in appropriate disciplines / procedures IN prior to performing inspections or examination i \s- activities.
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As reflected in Attachme'n: 5 to this report, a total of forty-four (44) of the documentation packages contained records of inspections performed / recorded by individuals for whom evidence of proper certification could not be located.
Construction Deviation Reports were initiated to document the questionable certification status of the inspectors for whom evidence of appropriate certification could not be located. These DRs have been reviewed and validated by the ISAP I.d.1 Issue Coordinator, in accordance with QA/QC Review Team procedures.
The I.d.1 evaluation of the inspectors identified on these DRs has indicated that the qualifications of five (5) inspectors were questionable. Four (4) of these
~~) five (5) had previously been identified as requiring g ,j Phase III evaluation through ISAP I.d.l. Their work has been evaluated under Phase III of the I.d.1 Action Plan and was found to be acceptable. The work of the remaining individual will also be evaluated under Phase III of ISAP I.d.1. The results will be reported through the Collective Evaluation of the Construction QA/QC Program.
Summary of General Deviations The general deviations identified during evaluation of the documentation packages involved a lack of thorough procedural definition of the inspections required and/or inadequate documentation of the inspections performed. These general deviations were documented on QA/QC Program Deviation Report No. 38 for the ASME Code sample items (B&R responsibility) and I
on QA/QC Program Deviation Report No. 39 for the non-ASME
, sample items (TUGC0 responsibility). The general deviations j identified during this evaluation are described in Attachment 3 to this report. The most important general deviation concerns the lack of objective evidence relative to inspection of threading and bending operations. Such operations were performed during onsite fabrication of U-bolts used for component supports subject to ASME Code requirements. The
! remaining general deviations identified in the documentation O- packages and described in Attachment 3, while not acceptable w-from a QA record standpoint, have a low potential to adversely impact the adequacy of the hardware. A summary of these general deviations is provided below:
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i e""$ RESULT 3 REPORT
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ISAP VII.b.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
No. of Psckages Exhibiting Description of Deviation the Deviation a .- No evidence that inspections were 78 performed, e.g., site threading /
bending, Hilti bolt die stamping.
- b. Inadequate / inconsistent information, 14 i e.g., references, material identifi-cation data.
- c. Insufficient data / missing records, 84 e.g., missing data entries, lack of information relative to inspector identification, type of observations,
,<, results.
-I d. Illegible records, improper data 20 corractions, incomplete identification of records to items.
Summary of Specific Deviations The specific deviations are listed in Attachment 4 to thin report and are classified as " insignificant", " notable" or "significant" relative to their potential effect on the hardware. Definition of these classifications is given in Attachment 4. It should be noted that several of the sample item documentation packages contained multiple deviations that fall into separate classifications or levels of significance. The specific deviations were documented on a total of thirty-two (32) Construction Deviation Reports, which were processed in accordance with CPRT procedures. When necessary to confirm or resolve the deviation and aid in the safety significance evaluation, the hardware was examined in place. The following is a summary of the data presented in Attachment 4:
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. Page 20 of 40
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[a RESULTS REPORT ISAP VII,b.1 (Cont'd) 5.0 IMPL_ !ENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
NOTE: Some DRs identify problems with multiple sample items, 1
therefore, there is not a direct correlation between the number of DRs and number of deviating sample items.
Category Number of Number of Number of Number of of Deviating Insignificant Notable Significant
-Deviation Sample Items Deviations Deviations Deviations
- Traceability 31 10 20 5 Questionable Inspector Certifications 44 0 44 0 Welder l Qualification 8 0 0 8
( Missing
) Documentation 1 1 0 0 Documentation Conflict 2 1 1 0 In view of the number of deviations identified during this Action Plan evaluation, an evaluation was performed relative to the adequacy of the procedures and practices employed during the current QA review of inspection records prior to placing them in the vault as permanent plant quality records.
Although excellent procedures have been established for this effort, e.g., CP-QAP-12.1, it was noted that the procedures were not being consistently implemented. Attachment 3 to CP-QAP-12.1 provides a comprehensive checklist for assuring consistency and completeness of documentation packages. The evaluation revealed, however, that not all of the reviewers utilized the checklist. Although the reviewers have been provided with training in the procedure, it was found that the reviewers were not consistent in its interpretation nor in the utilization of ancillary review tools, e.g., heat number logs.
The material traceability deviations have been provided to the Action Plan VII.a.1 Issue Coordinator for evaluation and action as appropriate.
(
Revision: 1 Page 21 of 40 RESULTS REPORT ISAP VII,b.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The results of this particular evaluation and the substance of the findings were discussed thoroughly in meetings with cognizant Brown & Root supervisory representatives.
Commitments were made that additional training and supervisory overview would be provided for the documentation package review activities. Implementation _of these commitments will preclude recurrence of the substantial number and types of documentation deviations identified during the Action Plan evaluations.
1 Two out-of-scope observation reports were initiated during this review. The first report concerns the probability that some of the hanger saddles installed on safety-related pipe were processed by a vendor who was not on the Approved Suppliers List during the timeframe in which this processing occurred. This item was documented as an out-of-scope observation because the information was found during review of
's a Receiving Inspection Report (RIR) not applicable to hardware in the sample documentation package undergoing review. The second out-of-scope observation concerns the lack of inspection criteria for component support snubber and low friction bearing plate installations, which was noted in early revisions of QI-QAP-11.1-28. Evaluation indicates that the present procedure provides adequate instructions relative to these installations. Inspection criteria were added by Revision 4 of the procedure (12/8/80). Snubber installation appears to have started in early 1981. This out-of-scope report was initiated to determine the significance, if any, of this omission in the inspection procedure during the early timeframe of component support installations.
Both of these out-of-scope observations have been forwarded to the QA/QC Review Team Hardware Collective Evaluation Engineer for processing in accordance with CPRT procedures. In addition, the first report was also transmitted to the Issue Coordinator for Action Plan VII.a.9, Receipt and Storage of Purchased Material and Equipment, for information and action as appropriate.
5.5 Results of Indepth Survey of Currently. Ongoing Fgbricat16n Shop Activities In order to evaluate the issues / concerns identified by NRC Oi letter January 8, 1985, Issue 8, Onsite Fabrication and CPSES Safety Evaluation Report Supplement No. 11, an indepth survey ;
of present fabrication shop activities at CPSES was performed.
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RESULTS REPORT ISAP VII.b.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The survey of current fabrication shop activities consisted of three (3) parts:
Evaluation of current shop and inspection procedures versus applicable 10CFR50 Appendix B criteria, Verification of the implementation of defined procedural controls, and
- Evaluation of current fabrication shop activities relative to the specific elements of the External Issues identified in the 0;NRC Letter, January 8, 1985, Issue 8 and SSER 11 Appendices O and P (see Sections 1.0 and 3.0 above).
The checklist developed for the survey defines the specific critoria and elements evaluated / verified. [ Reference 9.2]
,(~'
N -
The overall results of the survey indicated that the Brown &
Root implementation of the defined procedural controls currently applicable to fabrication shop activities was very good. The applicable construction procedures were posted on a large display board in the fabrication shop. Supervision and craft personnel were knowledgeable of these procedures. No procedural implementation defici4cties or documentation discrepancies were identified during the survey of current fabrication shop activities and the review of in-process documentation in the shop.
l An indepth evaluation of the current Brown & Root and TUGC0 procedures for controlling the onsite fabrication and inspection activities revealed only minor inadequacies.
Except for a lack of sufficient detail for inspection and documentation of onsite threading and bending activities, the ccaposite of these procedurcs meets the requirements of 10CFR50, Appendix B and FSAR commitments. As previously discussed in Section 5.3 of this report, however, several of the procedures are not in full compliance with the Brown &
Root and TUGC0 internal requirements for the structure and content of procedures.
The evaluation of current activities relative to the identified exterr.al issues revealed that the currently O, -
implemented controls effectively address these issues. There were no discrepancies noted relative to any of the identified external issues /concerne.
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M ISAP VII,b.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.6 Compliance With 10CFR50, Appendix B and FSAR Commitments The discrepancies identified through implementation of this Action Plan reflect a number of failures to comply fully with the applicable criteria of 10CFR50, Appendix B, and FSAR Commitments. Based on the reviews performed, the historical documentation of onsite fabrication activities fails to consistently provide:
- a. Details necessary to permit complete confirmation of acceptable inspection activities,
- b. Documented acceptance of item or activity by authorized personnel,
- c. Completely legible, accurate records of work accomplished.
() d. Identification of the person (s) recording the data and approving the inspection results.
- e. Materials traceability information.
The PDRs identify discrepancies in documentation packages that represent activities performed in the past. With the exception of the procedural inadequacies discussed in Section 5.3 of this report, the current program provides adequate control of onsite fabrication activities.
Although the PDRs document a number of past failures to implement FSAR commitments consistently, it is concluded that corrective action can be accomplished without the need for a substantive revision of the current program. The evaluation effort recommended in Paragraph 5.9 is not considered to be extensive.
The QA/QC Program Deviations were evaluated to determine if '
the PDRs should be classified as QA/QC Program Deficiencies.
In acccrdance with the CPRT Program Plan, Appendix E, a QA/QC Prcgram Deficiency is defined as a deviation meeting one or more of the following criteria:
Inadequacy of a QA/QC program element such that substantive revision of the program or other corrective s.s/ action is required to bring it into compliance with the regulatory requirements, FSAR commitments or other licensing commitments; or
I s Rsvision: 1 Page 24 of 40
( RESULTS REPORT ISAP VII.b.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Extensive evaluation would be required to determine the effect on the quality of construction.
Based on the above definition, the deviations documented on the PDRs do not meet the criteria for classification as QA/QC Program Deficiency. Therefore, the deviations described in the Program Deviation Reports are not considered to be QA/QC Program Deficiencies.
5.7 Trend Analysis Documentation deviations were found to be present in sixty-seven (67) of the seventy-three (73) "ASME Code" documentation packages and in each of the eighteen (18) non-ASME item documentation packages reviewed during
,. implementation of this Action Plan. This was determined to constitute a trend and an analysis was performed in accordance with Appendix E of the CPRT Program Plan. [ Reference 9.4]
The deviations identified during this evaluation involved three types of errors: 1) clerical errors and omissions such as dates, drawing and procedure revision numbers, etc.; 2) questionable inspector certifications and welder qualifications (non-ASME); and 3) inadequate data / documentation to establish material traceability and no evidence of inspection of site fabrication of U-bolts or j
marking of Hilti bolts (ASME only).
The number of deviations in each of these three categories i (see Attachment 5) make it likely that similar deviations exist in the remainder of the component support documentation packages. Consequently, an evaluation of the potential for safety significance was made. In the first category 1
(Attributes 1-5, Attachment 5), the deviations are not acceptable from a QA records standpoint, but are insignificant with regard to potential for adverse impact on the hardware.
4 Similar deviations in the remainder of the population would also be insignificant with respect to hardware impact.
- In the second category (Attributes 6 & 7 Attachment 5),
instances of questionable inspector certifications have been I
referred to the Action Plan I.d.1 Issue Coordinator for
- () evaluation. The results of this evaluation and corrective action if required, w111 be reported in the Collective Evaluation report. The deviations for welder qualification in the non-ASME sample items have all been evaluated to be
' Revision: 1 l Page 25 of 40
/ -
RESULTS REPORT '
1 ISAP VII.b.1
- (Cont'd) ,
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 1
, insignificant with respect to impact on hardware. In each l
case, alternate documentation was available to verify qualification. Action Plan VII.c also identified instances of questionable welder qualifications that were resolved threugh the use of alternate documentation. Therefore, it is probable thdt alternate documentation for welder qualification would I j exist for similar deviations in the remainder of the population.
- In the third category (Attributes 8, 9, & 10, Attachment 5),
each deviation was considered to be either notable or significant relative to a potential adverse impact on the hardware. However, each was subsequently determined to have
! no safety-significant effect on the hardware. In the case of
^
site-fabricated U-bolts, the acceptability of U-bolts was said by B&R QC to be verified as part of the final installation inspection. However, this is not stated in the procedure nor j
separately documented. Observation of bending and threading operations in the fabrication shop indicates that craft applied controls provide a high degree of confidence that
' U-bolts are acceptable. Additionally, there were no deviations involving site-fabricated U-bolts identified by the Action Plan VII.c reinspections. Consequently, it is considered that the lack of specific inspection / documentation for site-fabricated U-bolts is unlikely to have a ,
safety-significant effect on the hardware.
- In the case of Hilti bolts, the procedure requires verification of " star stamp" marking of Super Kwik type Hilti bolts; but no provision is made for documenting this verification. As a result of an NRC inspection. TUGC0 has initiated Corrective Action Requests (CARS) 58 and 74 to verify the correct marking and usage of Hilti Super Kwik bolts. The QA/QC Review Team considers this item to be adequately addressed by these CARS.
I In the cases of material traceability problems, field i
observation or the location of missing /alterna'-ive l documentation confirmed that acceptable material was used. In
- each case the deviation was determined to have no l safety-significant hardware effect on the sample items. This
- indicates that similar deviations in the remainder of the population would also have no safety-significant hardware
!, effect. However, insufficient data is available to allow a final conclusion. Therefore, the deviations and information
- regarding material traceability problems have been referred to
r
% Rsvision: 1 Page 26 of 40
( RESULTS REPORT ISAP VII.b.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) the Issue Coordinator of Action Plan VII.a.1, " Material Traceability", for information and action as appropriate. An evaluation of the potential for safety-significant hardware impact of material traceability deviations will be made by that Action Plan.
Based on the above, the QA/QC Review Team concluded that the deviations identified in onsite fabrication records do not constitute an " adverse trend" as defined by Section 5 of Appendix E of the CPRT Program Plan. Therefore, root cause and generic implication analyses were not performed.
5.8 Root Cause and Generic Implications In accordance with the CPRT Program Plan, root cause and generic implications evaluations are not required since no deficiencies or adverse trends were identified.
( Conclusions relative to the deviations identified by this Action Plan and the findings of Action Plan VII.c will be made through the Collective Evaluation of the Construction QA/QC Program and the Collective Evaluation of the Quality of Construction.
5.9 Recommended Corrective Action The Engineer should perform an analysis to confirm the acceptability of the safety-related component support installations. Based on the substantial number of deviations identified, the status of the documentation is indicative of a deviation from specification requirements. The analysis should be made with specific emphasis on the effect of inadequate inspection and material traceability documentation.
t The deviations identified during the implementation of this Action Plan were determined to have no safety-significant hardware effect. However, Action Plan VII.c identified several deviations within component support sample items that were determined to be construction deficiencies. Accordingly, the Engineer should consider the deviations identified by both of these Action Plans in performing the above analysis to confirm the acceptability of safety-related component supports.
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l RESULTS REPORT ISAP VII.b.1 (Cont'd)
6.0 CONCLUSION
S i
The implementation of this Action PI'an evaluated each of the
' NRC-TRT findings regarding past onsite fabrication shop activities and the NRC conclusions thereto. An indepth survey and evale .<nt of present activities relative to the identified issues / concerns revealed no discrepancies. Although inadequacies relatable to the l
NRC-TRT' findings and other external source issues were identified in the historical procedures and the QC records evaluated, it was concluded that currently implemented controls in the fabrication
, shop effectively address these issues and concerns.
Because Action Plan VII.a.8, Fuel Pool Liner Documentation, identified a large number of documentation deviations resulting from failure to implement procedures and the lack of definitive procedural direction, this Action Plan was expanded to evaluate onsite fabrication activities, in general, whether performed in the fabrication shop or other plant areas. Although deviations similar to those identified by Action Plan VII.a.8 were identified in the sample packages that were evaluated, determinations were made that i
O none of the deviations resulted in a safety-significant effect on the hardware represented by these documentation packages.
The fabrication shop is under the direction of Brown & Root.
Construction and inspection activities in the fabrication shop and other plant areas are governed by Brown & Root and TUGC0 procedures which have evolved over the seven year time period encompassed by this review. The review of procedures, forms and documentation packages indicates that the construction methodology and details i
were understood. However, the applicable inspection requirements were conveyed in numerous procedures that provide overlapping and l
differently stated requirements and criteria. These procedures were frequently changed, and implementation of the procedures was inadequately supervised.
The above factors # coupled with a lack of detailed guidance within individual procedures (relative to data entries, cross-references to other applicable procedures, etc.), contributed to inconsistency and gaps in the documentation of inspection results. In turn, the lack of appropriate supervisory overview and timely QA monitoring of the inspection records resulted in the placement of unsatisfactory QA documentation in the permanent plant records.
Thirty-two (32) Deviation Reports and two (2) QA/QC Program Deviation Reports were issued to document the deviations identified O through implementation of this Action Plan. Most of these deviations were identified in the historical documentation packages. These deviations confirm the NRC-TRT findings concerning l
Rsvision: 1 Page 20 of 40 RESULTS REPORT (J'
ISAP VII.b.1 (Cont'd)
6.0 CONCLUSION
S (Cont'd) past procedural inadequacies and implementation problems relative to management and inspection controls of onsite fabrication activities. The deviations described in these reports have been evaluated and determined to have no safety-significant hardware effect on the component support systems.
As described above under the summary of general deviations, Brown &
Root and TUGC0 procedures have been established for ensuring the adequacy of inspection records in completed documentation packages.
Effective implementation of these procedures will assure that complete and acceptable documentation packages are maintained for safety-related component supports.
7.0 ONGOING ACTIVITIES TUCCO is presently implementing a Hardware Validation Program for pipe supports and a Field Verification / Design Adequacy Verification l
Os Program for cable tray supports. These programs are applicable to Unit I and Common areas; and appear to be adequate to demonstrate the acceptability of the hardware. The documentation resulting from these programs will resolve the documentation deviations, with the exception of material traceability deviations. The material l traceability deviations identified during this evaluation have been
- referred to the Action Plan VII.a.1 Issue Coordinator for l
information and evaluation. TUGC0 is presently developing a Specification, Procedure, and Drawing Update Program that should, when effectively implemented, resolve the identified procedural inadequacies. The deviations and corrective action recommendations relative to the procedural inadequacies identified during this evaluation have been coordinated with the Collective Evaluation Group for integration into their overview of this update task effort.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE Fabrication, installation and inspection of the component support and other safety-related systems is still in process. Brown & Root and TUCCO implementation of documentation review procedures, as .
previously discussed under " Summary of Specific Deviations", will l preclude recurrence of the number and types of documentation
! deviations identified during the Action Plan evaluation.
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, Page 29 of 40 i .
i RESULTS REPORT I ISAP VII.b.1 (Cont'd) i
9.0 REFERENCES
i 9.1 ISAP VII.b.1, File #3 Procedures Review
! 9.2 ISAP VII.b.1, File #4E Survey Checklist 9.3 ISAP VII.b.1, File #4B Record Review l 9.4 ISAP VII.b.1, File f*B Trend Analysis a
4 2
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, Rsvision: 1 Page 30 of 40 RESULTS REPORT
{a')
ISAP VII.b.1 (Cont'd)
Attachment 1 Procedures Reviewed During the Implementation of ISAP VII.b.1 CP-CPM-6.9 General Piping Procedure Appendix 6.9B Welding Filler Material Control Appendix 6.9C Material Identification Appendix 6.9D Welding and Related Processes Appendix 6.9E Pipe Fabrication and Installation Appendix 6.9G Documentation for ASME Welding, Fabrication and Installation Activities Appendix 6.9H Cleanliness Control
/~'s Appendix 6.91 Pressure Testing U CP-CPM-7.3 General Fabrication Procedure CP-CPM-7. 3B Fabrication of ASME Component Supports CP-CPM-7.3D Welding and Related Processes CP-CPM-9.10 Component Support Installation CEI-20 Installation of Hilti Drilled-In Bolts CP-NDEP-200 Visual Inspection Structural Weldments CP-QAP-8.1 Receiving Inspection CP-QAF-8.5 Reclassification of Code Material CP-QAP-12.1 Mech. Component Installation Verification N-5 Certification CP-QAP-16.1 Control of Nonconforming Items I QI-QAP-10.1-20 Component Support Inspection
\~- Criteria
R visient 1 Page 31 of 40 RESULTS REPORT ISAP VII,b.1 (Cont'd)
Attachment 1 (Cont'd)
QI-QAP-10.2-4B Ultrasonic Examination of Hilti Bolts QI-QAP-11.1-5 ASME Section III Traceability
, Requirements QI-QAP-11.1-20 Component Support Inspection Criteria QI-QAP-11.1-26 Pipe Fabrication and Equipment Installation Inspections QI-QAP-11.1-28 Installation Inspections of ASME Component Supports, Class 1, 2, & 3 QI-QAP-11.1-28A Installation Inspections of ASME Class 1, 2, and 3 Snubbers QI-QAP-11.2-28 Fabrication and Installation Inspection of Safety Class Component Supports QI-QP-11.0-15 Verification of Base Plates for Grouting QI-QP-11.3-2 Cable Tray and Conduit Hanger Inspection QI-QP-11.10-2 Cable Tray Hanger Inspection QI-QP-11.14-4 Control of Material Traceability for Site Fabricated Structural / Miscellaneous Steel 4
QI-QP-11.21-1 Requirements for Visual Wald Inspection QI-QP-16.0-5 Reporting of Base Metal Defects CP-QP-15.0 Tagging System CP-QP-16.0 Nonconformances CP-QP-18.0 Inspection Report
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. Page 32 of 40 RESULTS REPORT ISAP VII.b.1 (Cont'd)
Attachment 2 QI-QAP-11.1-28 Revision History 1
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., Page 33 of 40
[ RESULTS REPORT ISAP VII.b.1 (Cont'd)
Attachment 2 (Cont'd)
Document code for table on previous page.
A. - Material Identification Log.
B. - Hanger inspection Report.
C. - Weld Filler Material Log.
D. - Weld Data Card.
E. - Multiple Weld Data Card.
F. - Component Modification Card.
G. - Nondestructive Examination Reports.
H. - NF-1/NF-2 Forms.
b I. - Material Requests.
J. - Vendor Supplied Component Modification Record.
K. - Inspected Item Removal Notice.
L. - Structural Assembly Verification Card.
M. - Manufactures Record Sheet.
N. - Construction Operations Traveler.
O. - Repair Process Sheet.
P. - Vendor Certified Drawing / Design Reviewed Drawing.
Q. - Component Support Drawings.
R. - Typical Inspection Drawings.
- S. - Vendor Supplied Code Date Report.
l T. - Vendor Supplied Material Report.
U. - Certified Material Test Report / Certificate of Conformance.
Rsvision: 1 Page 34 of 40 (N) RESULTS REPORT ISAP VII.b.1 (Cont'd)
Attachment 3 General Deviations PDRs 38 and 39 address deviations of a procedural or QA Program nature that were common to a substantial number of the QA records of the ASME Code and non.-ASME safety-related sample items. PDR 38 documents the general deviations of this nature identified in the ASME Code QA records (Brown & Root responsibility) and PDR 39 addresses those identified in the non-ASME sample records (TUGC0 responsibility).
The PDRs both provide examples, as summarized below, of identified deviations from the requirements of: a) 10CFR50 Appendix B, Criterion XVII, Quality Assurance Records " Sufficient Records shall be maintained to furnish evidence of activities affecting quality," and b)
ANSI N45.2.9-1974, Paragraph 2.3.1 "...such quality assurance records shall be legible, completely filled out and identifiable to the item...".
/ -
Of the ninety-one (91) documentation packages evaluated,
\ seventy-eight (78) lacked objective (verifiable) evidence that certain detailed fabrication operations were independently inspected by QC as required by applicable code, specification, or procedure. Although inspection requirements had been established for most of the operations in question, provisions / instructions for documenting the results of these inspections were either inadequate or lacking.
Fourteen (14) of the sample item documentation packages contained inspection records with inadequate / inconsistent information, e.g.,
i inspection records referenced by a data entry or necessary to amplify information relative to a data entry were not available in the permanent plant records, data necessary for establishing or re-establishing matarials traceability were available only in records maintained in personally held employee files, etc..
Eighty-four (84) documentation packages were found to have missing records; improperly completed data entries; inspection records that lacked sufficient information to establish inspector or data recorder identification, type of observation, applicable procedure and/or revision level; and/or lacked sufficient information to identify the inspection results clearly.
l Twenty (20) of the inspection record packages contained illegible ps inspection records or data point entries, records that did not list the date of inspection, reflected improper corrections or lacked sufficient information to identify the action taken for nonconformances.
l _ _ _ _
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, Page 35 of 40 RESULTS REPORT ISAP VII.b.1 (Cont'd)
Attachment 4 Specific Deviations Potential Effect DR Number Description of Deviation On Hardware R-VII b.1-16-DR-01 Traceability of a BOM (Bill Insignificant of Material) item is in question due to documentation inconsistencies.
R-VII.b.1-01-DR-02 Traceability for items listed Notable on a Manufacturing Record Sheet is listed as "N/A", (with a cross-reference to an inspection report).
R-VII.b.1-04-DR-03 Traceability of a BOM item to a Insignificant specific heat number is in
-<s question. (Three possible heat
_) numbers, all traceable, are identified).
R-VII.b.1-05-DR-04 Traceability to a specific heat Insignificant number is not possible. Two heat numbers, both traceable, are identified.
R-VII.b.1-05-DR-05 No traceability for BOM item 10. Significant R-VII,b.1-12-DR-06 Heat number discrepancy between Insignificant two documents.
R-VII.b.1-14-DR-07 No traceability to the MIC number Notable l listed for the snubber barrel
' installed on this assembly.
R-VII.b.1-17-DR-08 No traceability to the heat Insignificant i
number listed for tube steel installed on this assembly.
R-VII.b.1-18-DR-09 No traceability to the MIC Notable number listed for BOM item j Number 7 for this assembly.
3
)
.- ._ _ _ - _ _ _ _ _ _ _ _ ~ . _. _ - _ ._ . .. ._
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l RESULTS REPORT ISAP VII.b.1 (Cont'd)
Attachment 4 (Cont'd) t Potential Effect DR Number Description of Deviation On Hardware R-VII.b.1-19-DR-10 Traceability for BOM items Notable in question due to documentation 3
inconsistencies.
R-VII.b.1-19-DR-11 Traceability for eye rod in Notable question due to documentation 4
inconsistencies.
4 R-VII.b.1-24-DR-12 No traceability for U bolt Insignificant installed on this assembly.
R-VII.b.1-32-DR-13 No traceability for BOM item Significant 24 (eye rod).
R-VII.b.1-40-DR-14 Traceability for BOM item 17 Notable
- s in question due to documentation inconsistencies.
R-VII.b.1-42-DR-15 No traceability for BOM items Significant 17 and 12.
- R-VII-b.1-43-DR-16 No traceability for BOM item 10. Significant i
R-VII.b.1-45-DR-17 No traceability for BOM item 7. Notable R-VII.b.1-48-DR-18 Traceability for BOM item I is Insignificant in question.
l R-VII.b.1-53-DR-19 Traceability for BOM items 19, 22 Insignificant and 28 in question due to
' documentation inconsistencies.
R-VII.b.1-61-DR-21 No traceability for BOM item 3. Insignificant R-VII.b.1-73-DR-23 Certifications do not reference Insignificant the code class of material for BOM item 1. (Heat number is available and traceable).
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, Page 37 of 40
( RESULTS REPORT ISAP VII,b.1 (Cont'd)
Attachment 4 (Cont'd)
Potential Effect DR Number Description of Deviation On Hardware R-VII.b.1-02-DR-24 Design documents conflict with Notable
, "as-built" shim sizes; inspection documents which accepted these shims are also in conflict.
R-VII.b.1-15-DR-25 No traceability for BOM item 27. Significant R-VII.b.1-45-DR-26 Traceability for BOM item 16 is Insignificant in question due to identification of two heat numbers (both traceable).
, R-VII.b.1-41-DR-28 No traceability for BOM item 19 Notable i
s due to failure to record data,
) R-VII.b.1-45-DR-29 Traceability for BOM item 7 is Notable in question.
R-VII.b.1-EGEN-DR-30 Material traceability information Notable
). is inadequate for eleven (11) cable tray hanger assemblies.
R-VII.b.1-EGEN-DR-31 Welder qualification records not significant available for welders of record for eight (8) cable tray hanger assemblies.
R-VII.b.1-EGEN-DR-32 Inspector certification records Notable not available for dates certain inspections were performed on
' cable tray hanger assemblies.
R-VII . b .1-GEN-DR-33 Inspector certification records Notable and not available for dates certain R-VII,b.1-48-DR-34 inspections performed on ASME Code pipe hanger assemblies.
R-VII.b.1-30-DR-01 Missing records in pipe hanger Insignificant documentation package. Records
() do not reflect that hanger has been voided and is no longer installed.
Rsvision: 1 Page 38 of 40 RESULTS REPORT ISAP VII.b.1 (Cont'd)
Attachment 4 (Cont'd)
Definition of Classifications:
Insignificant: Deviations that are primarily obvious documentation errors with a negligible potential to adversely affect the acceptability of the hardware. Example: Material not traceable to a specific heat number but is traceable to one of three heat numbers, all of which are acceptable material.
Notable: Deviations that have a moderate potential to adversely i
affect the acceptability of the hardware. Example:
Lack of traceability of components salvaged from t
previously accepted vendor-supplied supports.
Significant: Deviations that make the acceptability of the hardware l
indeterminate without additional evaluation. Example:
Lack of traceability of bulk materials such as plate, tube steel, etc..
(These classifications are unique to the deviations identified by this Action Plan.)
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/
l RESULTS REPORT ISAP VII.b.1 (Cont'd)
Attachment 5 Attribute Deviation
- Matrices ISAP VII.b.l. Results Report - Attachment #5 Sheet 1 of 2 Attribute deviation frequency peryearfor ASME Code samples 1 2A 28 2C 2D 3A 38 3C 3D 3E 3F 3G 4 5 6 7 8 9 10 Total 1978-1980 3 0 0 0 1 0 1 1 2 2 0 10 2 0 4 0 4 0 5 35 1981 6 0 1 0 2 0 1 1 1 1 1 11 4 7 0 9 9 64 1 10 1982 2 0 0 0 0 0 0 0 0 0 0 4 2 0 9 0 1 8 5 31 1983 3 0 3 0 1 0 1 0 1 1 1 3 1 0 5 0 8 6 7 41 1984 1 1 1 0 0 0 1 0 0 1 0 3 1 0 1 0 1 2 8 21 1985 1 0 0 0 0 0 0 0 0 1 1 3 0 2 3 0 1 5 6 23 Total 16 1 5 0 4 0 4 2 4 6 3 34 10 2 29 0 24 31 40 215 Attributes :
1
-Is the procedurally required documentation for operations performed present ?
2A - Are all required entries legible ?
28 - Are all entries completed appropriately ?
2C - Are all operations signed offin correct sequence ?
- 2D - Are all corrections / changes properly performed and annotated ?
- 3. -Do allinspection recordsidentify ?
A -ltemsinspected.
B -Date ofinspection.
C -inspector.
D -Type of observation.
E -Results or acceptability.
F - Actions for nonconformances.
G - Drawing, Specification, Procedures and revision levels.
- 4. - Are all entries on related documents consistent ?
- 5. - Are all required inspections complete and acceptable ?
- 6. -Inspector Certifications.
- 7. -Welder Qualifications.
- 8. - Material Tr aceability.
i
- 9. -Site fabrication of threads and bending operations.
- 10. -Marking of Hilti s. '
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RESULTS REPORT ISAP VII.b.1 (Cont'd)
Attachment 5 (Cont'd) .
ISAP VII.b.1 Results Report - Attachment #5 Sheet 2 of 2 Attribute deviation frequency per year for non - ASME samples Sample years 1 2A 28 2C 2D 3A 3B 3C 30 3E 3F 3G 4 5 6 7 8 Total w
1978 0 0 1 0 0 0 0 0 0 1 0 3 2 3 2 1 2 15 1979 1 0 0 0 0 0 0 0 0 0 0 3 2 0 3 1 2 12 1980 0 0 0 0 0 0 0 0 0 0 1 3 1 1 3 0 0 9 l 1981 0 0 0 0' O O O O O O O 3 0 0 3 2 1 9 1982 1 0 0 0 1 0 0 0 0 0 0 3 0 2 1 0 3 11 1983 0 0 0 0 0 0 1 0 0 0 0 3 0 2 1 3 3 13 Total 2 0 1 0 1 0 1 0 0 2 0 18 5 5 15 8 11 69
(' T Attributes :
1 -is the procedurally required documentation for operations performed present ?
2A - Are all required entries legible ?
28 - Are all entries completed appropriately ?
2C - Are all operations signed offin correct sequence ?
2D - Are all corrections / changes properly performed and annotated ?
- 3. -Do allinspection recordsidentify ?
A -ltemsinspected.
B -Date ofinspection.
C -inspector.
D -Type of observation.
E -Resultsoracceptability.
F - Actions for nonconformances.
G - Drawing, Specification, Procedures and revision levels.
- 4. - Are all entries on related documents consistent ?
- 5. - Are all required inspections complete and acceptable ?
- 6. -Inspectorcertifications.
- 7. -WelderQualifications.
- 8. -MaterialTraceability.
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