ML20212P837
| ML20212P837 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/26/1986 |
| From: | Barnes I, Ellershaw L, Hale C, Will Smith, Tapia J, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20212P745 | List: |
| References | |
| 50-445-86-01-02, 50-445-86-1-2, 50-446-86-01, 50-446-86-1, NUDOCS 8609030306 | |
| Download: ML20212P837 (104) | |
See also: IR 05000445/1986001
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APPENDIX E
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COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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,.NRC'InspectionReporE:, 50-445/86-01
cps:
CPPR-126
50-446/86-01
CPPR-127
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Dockets:
50-445
Category:
A2
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50-446~"
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Licensee: . Texas Utilities Electric Company
Skyway Tower
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400 North Olive Street
. : Lock Box 81
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Dallas, Texas 75201
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Facility Name:
Comanche $ Peak Steam Electric Station (CPSES), Units 1 and 2
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Inspection At:
Glen Rose, Texas
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Inspection Conducted:
January 1 - 31, 1986
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Inspectors:
1
LY E. Ellershaw, Reactor Inspector, Region IV
Date /
CPSES Group
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(paragraphs 1, 5, 8.b, 8.d-8.e, 9.e-9.m)
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C. J. Hal y Rdactor Inspector, Region IV
Date
CPSES Group
(paragraphs 1, 3.a
4, 6, 8.b)
Y $<%
8/M/%
[ W. F. Smith, Resident Reactor Inspector (RRI)
Date
Region IV CPSES Group
'(paragraphs 1, 8.c)
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P.C. Wagner,ReactorIngector,RegionIV
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CPSES Group
(paragraphs 1, 3.b, 8.a, 9.a-9.d)
6lLif S(o
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I. Tapih, R6ac
Inspector,. Region IV
Date
ragraphs 1, 7, 8.d.(4))
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Consultants:
EG&G - J. Dale (paragraphs 1, 5, 8.b(13), 8 e.(7))
A. Maughan (par *agroplis 1, 3.b(1) - 3.b(28), 8.a(2) -
8.a(3),9.b)
W. Richins (paragraphs 1, 8.d(2) - 8.d(3), 8.d(5), 8.e(2),
8.e(6), 9.f - 9.g)
R. Vanderbeek (paragraphs 1, 3.b(34) - 3.b(37), 8.a(6),
8.a(8), 8.e(1), 8.e(4), 9.a)
V. Wenczel (paragraphs 1, 6.a - 6.g)
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Parameter - J. Birmingham (paragraphs 1, 8.b(1) - 8.b(11))
J. Gibson (paragraphs 1, 3.b(5), 3.b(29) - 3.b(34),
3.b(38) - 3.b(39), 8.a(1), 8.a(4)'- 8.a(5), 9.c - 9.d)
K. Graham (paragraphs 1, 8.b(14), 9.k - 9.1)
D. Jew (paragraphs 1, 8.b(12), 8.d(1), 8.e(3), 8.e(5), 9.e,
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9.h - 9.j)
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Teledyne - J. Malo.nson (paragraphs 1, 6.h - 6.j)
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Approved:
ASec-r+>
P/26/N
'I. Barnes, Chief, Region IV CPSES Group
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Inspection Sammary
Inspection Condected:
January 1-31, 1986 (Report 50-445/86-01; 50-446/86-01)
Areas Inspected:
Ncaroutine, unannounced inspection of applicant actions on
previous inspection f'. ridings, inspection process control, applicant processing
of ERC inspection findings, assessment of allegations, pipe support
modifications, and Comanche Peak Response Team (CPRT) issue
specific action
plans (ISAPs).
A sunimary of NRR and IE audit / inspection activities is provided
in paragraph 2'of this appendix.
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Results:
Within the six areas inspected, two violations (nonconforming
conditions not identified in accordance with QA program requirements,
paragraphs 4 and 5; failure to perform field testing of cable reels,
paragraph 9.a) and two deviations (failure to comply with approved instructions
in performance of inspections, and inadequate engineering review during
preparation of an inspection checklist, paragraph 9.j.) were identified.
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DETAILS
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1.
Persons Contacted
J. Adams, ERC Supervisor, Safety Significance Evaluation Group
S. R. Ali, TV3Co QA Staff Engineer, TUGCo Nuclear Engineering (TNE)
J. Arros, TERA Civil / Structural Issue Coordinator
W. Baker, Brown & Root (B&R) Project Welding Engineer
G. Benfer, Site QA Manager, Bahnson Services Co.
G. Bennetsen, B&R Quality Engineer (QE)
L. Bast, TUGCo Corrective Actions Supervisor
T. Birdwell, B&R Paper Flow Group
T. Blixt, BLR QE
D. Boydston, ERC Issue Coordinator
- C. T. Brandt, TUGCo QE Supervisor (Ebasco)
C. I. Browne, Project Manager, R. L. Cloud & Associates
- R. E. Camp, Assistant Project General Manager, Unit 1 (Impell Corp.)
J. D. Christenson, ERC Deputy QA/QC Review Team Leader
A. Contieu, TUGCo Training Coordinator- Non ASME
S. L. Crawford, ERC Issue Coordinator
M. Curland, ERC Special Evaluation Team (SET)
R. Curtis, TUGCo Senior Tech., Operations QA
- D. E. Deviney, TUGCo Operations QA Supervisor
M. Evans, TUGCo Operations Machine Shop Foreman
J. Finneran, TUGCo Lead Pipe Support Engineer
J. R. Galzer, ERC Issue Coordinator
- P. E. Halstead, TUGCo Site QC Manager
- J.
L. Hansel, ERC QA/QC Review Team Leader
R. Haskovec, TUGCo Licensing
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J. Hayworth, B&R ASME Inspector Training Coordinator
D. Hicks, TUGCo QC Supervisor
J. R. Honekamp, TRT Issues Manager, TERA ,
P,. Hooton, TUGCo Project Civil Engineer
D. J. Hudson, ERC Certification Administrator
A. Lancaster, TUGCo QA Surveillance Supervisor
P. Leyendecker, TUGCo QC Surveillance Supervisor
J. B. Leutwyler, B&R Electrical QC Supervisor
J. Mallanda, CPRT Electrical Review Team Leader
J. Maxwell, TUGCo Operations QC Supervisor
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R. Melton, TERA Documentation Coordinator
- J. T. Merritt, TUGCo Assistant Project General Manager
C. K. Mcehlman, TUGCo Project Mechanical Engine'er
M. Obert, ERC Issue Coordinator
C. Osborn, B&R Permanent Plant Records Vault (PPRV) Supervisor
G. W. Parry, QA Surveillance Supervisor
B. Parr, Authorized Nuclear Inservice Inspector, Hartford Steam Boiler
A. A. Patterson, ERC Reinspection Engineering Supervisor
G. R. Purdy, B&R QA Manager
G. W. Ross, ERC Onsite QA Representative
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D. Sampson, B&R Receiving Inspection Supervisor
J. C. Smith, TUGCo Operations QA
C. Spinks, ERC Inspection Supervisor
D. Snow, B&R QA/QC Coordinator
P. Stevens,-TNE Electrical Engineer
J. F. Streeter, TUGCo Assistant to Executive Vice President
A. 3mithy, B&R Interim Records Vault Supervisor
J. Sutton, ERC SET
K. Thomton, B&R Warehousing Supervisor
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'P. Turi, TERA Issue Coordinator
T. G. Tyler, TUGCo CPRT Program Director
W. I. Vogelsang, TUGCo Coordinator, Electrical and Instrumentation and
Controls
J. Wehlein, EBASCO Section XI Surveillances"
C. H. Welch, TUGCo QC Services Supervisor
- J. R. Wells, TUGCo Director, QA
.J. E. Young, ERC Issue Coordinator
- Denotes those persons who attended the exit interview.
The NRC inspectors also contacted other CPRT and applicant employees
during this inspection period.
2.
NRR and IE Audit / Inspection Activities
a.
NRR:
ANCO cable tray testing was observed at Culver City,
California, on January 8-9, 1986.
A site technical review was
performed on January 16, 1986, with respect to allegations in the
mechanical and structural areas.
A site audit was performed on
January 17, 1986, of activities being performed in the review of
heating, ventilation, and air conditioning (HVAC) supports.
An audit
was performed on January 21, 1986, at R. L. Cloud Associates,
Berkeley, California, with respect to the random calculation overview
approach on EBASCO and Impell activities in the cable tray and
conduit support effort.
Impell was audited at Concord, California,
on January 22, 1986, with respect to activities in the safeguards
building cable tray and conduit support effort.
An audit was
performed on January 27, 1986, at Stone and Webster, New York City,
New York, with respect to status of piping analysis special technical
issues,
b.
IE:
A site inspection was performed on January 16-17, 1986, relative
to TERA implementation of design adequacy procedure DAP-21 and for
the purpose of planning IE inspection of the process.
The report for the January-17, 1986, site audit of HVAC supports review
activities will be included in a future Region IV inspection report;
i.e.,
NRC Inspection Report 50-445/86-03; 50-446/86-02.
Copies of reports for
the other activities will be placed in the Public Document Room upon
completion.
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3.
Applicant Actions on Previous Inspection Findings
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a.
QA/QC:
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(Closed) Deviation (445/8511-0-01):
Side bars were not being used to
identify all changes to ERC procedures and instructions.
The NRC inspector verified that Procedure CPP-001 was revised as -
committed.
Records indicate that training relative to the revised
procedure was conducted October 24, 1985, with appropriate lead
personnel in attendance.
The NRC inspector selected four recently
revised procedures for review to verify the_ effectiveness of the
preventive measures.
No noncompliance with the revised procedure was
identified.
This item is closed.
b.
Electrical:
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(1) (0 pen) Open Item (445/8511-0-06): .Further review of this open
item pertaining to a loose grounding strap bolt showed that
Deviation Report (DR) I-E-CATY-004-DR01 and Nonconformance
Report (NCR) E85-101318SX were written for the deficiency.
This
item will remain open pending disposition of the NCR.
(2) (0 pen) Open Item (445/8511-0-07):
Further review of this open
item pertaining to a tray T140CDJ17 which had two 1-inch
openings in it's solid bottom showed that DR I-E-CATY-004-DR02
and NCR E85-101318SX were written for the deficiency.
This tray
is only 2 feet 9 inches above T13GCCM08.
This item will remain
open pending disposition of the NCR.
(3) (Closed) Open Item (445/8511-0-08):
Further review of this open
item pertaining to Drawing El-712-11, Revision 7, which showed
the tray elevation as 819 feet while the actual elevation is
817 feet, indicated that the drawing was for reference of
approximate location only.
Actual installation is performed per
Drawing El-712-01 which shows the elevation at 817 feet.
This
item is closed.
(4) (0 pen) Open Item (445/8511-0-09):
This item was incorrectly
associated as being part of cable tray package 047.
DR I-E-CATY-024-DR01 and NCRs E85-100844SX and E85-100831 were
written for the deficiency pertaining to sharp edges in
tray T130RCJ28 and jacket damage to a seven conductor 600 vult
cable.
This item will remain open pending disposition of the
NCRs.
(5) (0 pen) Open Item (445/8511-0-11):
This item pertained to a
loose bolt on a splice plate.
DR I-E-CATY-036-DR01 and
NCR E85-100988X were written for this deficiency.
This item
will remain open pending disposition of the NCR.
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(6) (Closed) Open Item (445/8511-0-12):
This item pertained to a
welded splice plate which had two of eight required bolts
missing.
Design Change Authorization (DCA) No. 4178,
Revision 29, dated July 7, 1985, required the two bolts be
removed when the splice plate was welded to the cable tray.
This item was incorrectly associated with cable tray
package 047.
This item is closed.
(7) (Closed) Open Item (445/8511-0-13):
This item pertained to a
pipe (FD-1-880-21A) clearance less than the required 6 inches
from cable trays.
Further review determined that the pipe is a
floor drain pipe and that only a 1-inch clearance need be
maintained instead of the 6-inch clearance from cable trays
required for safety-related pipes.
This pipe meets this
separation criteria.
This item is closed.
(8) (0 pen) Open Item (445/8511-0-14): This item pertained to the
following four findings:
(a) torn fire blanket material on
conduit C14B11217 - NCR E85-1013405 has been written for this
damage; (b) damaged fire blanket material on conduits C15W11119,
C15W16160 and C15W11989 - NCRs E86-100003S, E86-100004S, and
E86-100005S have been written; (c) the fire blanket material on
conduits C15W11119 and C15W11989 was touching f~ree air cables -
NCRs E86-100004S and E86-1000055 have been written; (d) damaged
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fire blanket material on conduits C14G19934 and C14G19936 (this
material is located at tray sections T13GCCM92 and T13GCCM79 in
the Lower Cable Spreading Room). TUGCo has written
NCRs E86-100006S and E86-100007S.
These items will remain open
pending disposition of the NCRs.
(9) (0 pen) Open Item (445/8511-0-16):
This iten, pertained to a
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conduit to tray transition separation distance of only
6 1/2 inches.
DR I-E-CDUT-066-DR01 and NCR E85-100363SX have-
been written for this deficiency. This item will remain open
pending disposition of the NCR.
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(10) (0 pen) Open Item (445/8511-0-17): _This item pertained to a
separation deficiency where a conduit was only 1 inch from
cable tray T14KCCL23.
DR I-E-CDUT-064-DR02 and NCR E85-101622SX
were written for this deficiency.
This item'will remain open
pending disposition of the NCR.
(11) (0 pen) Open Item (445/8511-0-18):
This item pertained to fire
blanket material on conduit C13016037, which had a separation
of less than 1 inch to cable trays T13KCCT22 and T13KCCV18.
OR I-E-CDUT-064-DR02 and NCR E85-101622SX were written for this
deficiency.
This item will remain open pending disposition of
the NCR.
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'(12) (Closed) Open Item (445/8511-0-19):
This item pertains to a
termination panel, CP1-ECPRCR-15, which had no fire seal in the
end of a conduit in the control room, DR I-E-CDUT-064-DR01 was
written for this deficiency but was invalidated by ERC because
fire stop/ seal material was found to be installed in the other
end of the conduit in the Lower Cable Soreading Room.
This item
is closed.
(13) (Closed) Open Item (445/8511-0-20T:
This item pertained to
cables apparently lacking 2 inches of slack when coming out of
the conduit stubs (which are thermal-lagged) at Motor Control
ERC memo QA/QC-RT-466 dated
September 5, 1985, has provided the ERC inspectors with a method
of determining the slack for thermal-lagged cables.
Thermal
lagging of free air cables is controlled by
Procedure CP-CPM-10.3.
Based on this information, this item is
closed.
(14) (0 pen) Open Item (445/8511-0-25):
This item pertained to a wall
sleeve, TWS-020, not being shown on cable routing schedule,
2323-El-1700.
DR I-E-CABL-045-DR02 and NCR E85-101209SX were
written for this deficiency.
This item will remain open pending
disposition of the NCR.
(15) (0 pen) Open Item (445/8511-0-26):
This item pertained to a
cable lacking the required 2 inches of slack at the conduit to
cable tray (C13011615 to T130CCQ22) transition.
DR I-E-CABL-045-DR01 and NCR E85-101138SX were written for this
deficiency.
This item will rer.1ain open pending disposition of
the NCR.
(16) (0 pen) Open Item (445/8511-0-27):
This item pertained to a
cable lacking 2 inches of slack at the C13003316.to-T130CCQ45
transition.
DR I-E-CABL-045-DR01 and NCR E85-101138SX were
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written for this deficiency.
This item will remain open pending
disposition of the NCR.
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(17) (Closed) Open Item (445/8511-0-29):
This item' pertained to wire
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terminations not being properly identified on
Drawing 2323-El-0035, Sheet 38.
Supplemental instructions in
ERC Quality Instruction (QI) QI-014 were written to verify the
termination points by checking the position of'the _ limit switch
contacts before and during operation.
Position of the switch is
checked by measuring continuity.
This item is closed.
(18) (Closed) Open Item (445/8511-0-30):
This item pertained to wire
terminations not being properly identified on
Drawing 2323-El-0035, Sheet 37.
Supplemental instructions in
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QI-014 were written to' verify the termination points by checking
the position of limit switch contacts before and during
operation.
Position of the switch is checked by measuring
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continuity.
This item is closed.
(19) (0 pen) Open Item (445/8513-0-23): This item pertained to the
following three findings:
(a) a three piece fitting that was
not hand-tight.
DR I-E-CDUT-027-DR02 and NCR E85-101344SX have
been written for this deficiency; (b) less than 1 inch
separation between conduit ESB6-5, tray T13KECH, and
conduit C14013763.
DR I-E-CDUT-027-DR03 and NCR E85-101344SX
have been written for this deficiency; (c) a conduit size which
was 1 inch when it should have been 3/4 inch.
Electrical
Erection Specification 2323-ES-100, Revision 2, dated
October 15, 1980, Section 4.8.2 states for lighting, "All
metallic conduits shall be rigid galvanized steel and 3/4-inch
minimum unless otherwise noted on the drawings."
In the same
specification, Section 4.4.2 states, in part, ". . . In order to
facilitate construction conduit of the rext larger
size . . . may be substituted'for reasons such as the smaller
sized conduit is not in stock." Based on this information,
finding (c) is closed. . Findings (a) and (b), above, will remain
open pending the disposition of the NCRs.
(20) (0 pen) Open Item (445/8513-0-26):
This item. pertained to the
following two findings:
(a) an outlet box with a 3-inch stub
.that was not sealed as required; and (b) an outlet box which had
two cover retaining screws that were stripped.
NCR E85-101439SX
has been written for these deficiencies.
This item will remain
open pending disposition of the NCR.
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(21) (0 pen) Open Item (445/8513-0-30):
This item pertained.to
electrical conductor seal assemblies (ECSAs) which were longer
than shown by the drawings and the supplemental instructions.
DR I-E-EEIN-052-DR01 and NCR E85-101288SX were written for this
deficiency.
This item will remain open pending disposition of
the NCR.
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(22) (0 pen) Open Item (445/8513-0-31):
This item pertained to the
following two findings:
(a) ECSA-1-HV-5561 was longer than
shown by the drawings and the supplemental instructions.
DR I-E-EEIN-039-DR01 and NCR E85-101259SX were written for this
deficiency; and (b) ECSA-1-HV-5561 associated had a bend radius
under the required minimum of 5 inches.
DR I-E-EEIN-039-DR02
and NRC E85-101259SX were written for this deficiency.
These
findings will remain open pending disposition of the NCRs.
(23) (0 pen) Open Item (445/8513-0-32):
This item pertained to the
following two findings:
(a) ECSA-1-HV-4725-3 had a fitting
that was not hand-tight.
DR I-E-EEIN-003-DR01 and
NCR E85-101268SX were written for this deficiency; and (b) three
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ECSAs (1-HV-4725-1,
-2, and -3) were longer than shown by the
drawings and the supplemental instructions.
DR I-E-EEIN-003-DR02 and NCR E85-101268SX were written for thic
deficiency.
These findings will remain open pending. disposition
of the NCRs.
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(24) (0 pen) Open Item (445/8513-0-33):
This item pertained to the -
following two findings:
(a) flexible conduits.C1388908-2 and -3
had bend radii under the allowed minimum of 5 inches.
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DR I-E-EEIN-001-DR01 was writt en for this deficiency,'but was
invalidated by ERC because the flexible conduit run is not
considered part of the ECSA installation; and (b) two ECSA
assemblies were missing their identification tags.
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DR I-E-EEIN-001-DR02 and NCR E85-10012895X were written for this
deficiency.
This item will remain open pending disposition of
the NCR.
(25) (0 pen) Open Item (445/8513-0-34):
This item pertained to the
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following three findings:
(a) a three piece coupling on
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ECSA-1-HV-4172-2 was not hand-tight.
DR I-E-EEIN-012-DR01 and
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NCR E85-1012695X were written for this deficiency; (b) three
ECSAs (1-HV-4172-1, 2, and 3) were longer than shown by the
drawings and the supplemental instructions.
DR I-E-EEIN-012-DR02 and NCR E85-101269SX were written for this
deficiency; and (c) two ECSAs (1-HV-4172-2 and 3) had bend radii
under 5 inches.
DR I-E-EEIN-012-DR03 and NCR E85-101269SX were
written for this deficiency.
This item will remain open pending
disposition of the NCRs.
(26) (0 pen) Open Item (445/8513-0-35):
This item pertained to a
solenoid valve's flexible conduit which had a missing digit on
its identification tag.
DR I-E-EEIN-001-DR02 and
NCR E85-1012895X were written for this deficiency.
This item
will remain open pending disposition of the NCR.
(27) (0 pen) Open Item (445/8513-0-36): This item pertained to
conduits from junction box JB1C-2450 to ECSA-1-HV-4725-1 and 3
s
which had identification markings that were illegible.
NCR E85-101442SX has been written for this deficiency.
This
item will remain open pending disposition of the NCR.
(28) (0 pen) Open Item (445/8518-0-09):
This item pertained to
banding on fire blanket material for conduit C13G08248 which
was not installed within 2 inches from the end of the blanket.
DR I-E-CABL-026-DR03 and NCR E85-101155SX were written for this
deficiency.
This item will remain open pending disposition of
the NCR.
(29) (Closed) Open Item (445/8511-0-10):
This item was incorrectly
associated as being a finding of cable tray package 047.
The
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finding, related to holes in the cable tray, has1 een resolved
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tthrough the review of DCA No. 4178, Revisionc29,Idated July'24,
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1985.
This item is closed.
(30).(0 pen) Open' Item (445/8514-0-08):- During October 1985, theLNRC
inspector performed-an independent inspection of, Unit No. 1
,
- cable tray T13GDCX60, Verification Package No.e I-E-CATY-167.
A
review of ERC inspection reports revealed agreement'.between
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observations, and validated ERC DRLI-E-CATY-167-DR1.iqThe NRC c ~
inspector.also observed that cable tray T13G0CX50;had'. loose nuts
at the east splice plate connection.
This observation was
outside of the defined-inspection scope.' (;
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This item will remain open pending theJNRC review of the I-
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applicant's disposition.
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(31) (0 pen) Open Item (445/8514-0-10): .During October 1985, the NRC'
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inspector performed an independent documentation review offthe
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following six Unit 1 electrical conduits:
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Verification
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Package No.
Conduit No.
System
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R-E-CDUT-027
ESB6-5
Lighting
R-E-CDUT-035
C12G03270
N/A
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R-E-CDUT-044
ECB3-29
Lighting
R-E-CDUT-050
ECB1-16
Lighting
R-E-CDUT-065
C13G08606
N/A
R-E-CDUT-066-
C12G04985
N/A
Comparison of NRC findings to ERC finding is as follows:
(a) Verification Package Nos. R-E-CDUT-027, R-E-CDUT-044, and
j
R-E-CDUT-050 have been included in the new population for-
Lighting (LITG).
A repeat review will be performed in
i
accordance with QI-071.
(b) Review ~of Verification Packages R-E-CDUT-025, R-E-CDUT-065,
and R-E-CDUT-066 by the NRC inspector identified that
!
QI-009 does not list QI-QP-11.3-4, the inspection procedure
'
.in effect'at the time of the conduit inspection, against'
which inspector certifications are to be reviewed.
ERC has
identified this same condition, and has not been able to-
complete processing of the review results.
This item will
remain open pending NRC review of the applicant's
[
resolution of this finding.
L
(32) (Closed) Open Item (446/8511-0-12):
During October 1985, the
<
NRC inspector performed an independent inspection of cable
.
.
tray T23GECX18, ERC Verification Package No. I-E-CATY-241, Unit
i;
i
s
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-12-
No. 2.
The NRC inspector identified abandoned holes on both
sides of the tray near one of the splice plates.
The NRC inspector reviewed ERC inspection documentation for this
cable tray and verified that DR I-E-CATY-241-DR1 identified the
condition observed by the NRC inspector, and also documented
that the ERC inspector had identified a sharp edge where the
tray sections join together.
ERC has invalidated the DR based on the fact that the holes are
acceptable per DCA No. 4178, Revision 29, and that the tray
configuration is such that the sharp edge does not present a
cable hazard.
(33) (CloseJ) Unresolved Item (445/8514-U-17):
Accomplishment of
conduit separation inspections.
During independent conduit
inspections and documentation reviews performed by the NRC
inspector during October 1985, it was observed that TUGCo
inspection procedures did not contain provisions for inspection
of electrical separation.
The NRC inspector was informed that
inspection for electrical separation was performed in
conjunction'with room / area turn-over per QI-QP-11.3-29, instead
of at the time of the' installation inspection.
During January 1986, the NRC inspector reviewed building
turn-over files in the Permanent Plant Records Vault (PPRV) for
16 rooms / areas.
These records represented inspections for
various elevations in the Reactor Containment, Safeguards,
Diesel Generator, Control, and Auxiliary buildings of Unit
No . 1.
With the exception of the Cable Spreading Room
(No. 133), all of the packages reviewed contained Inspection
Reports and supporting documentation, indicating: inspection for
electrical separation in accordance with QI-QP-11.3-29.
Documentation for the cable sprea' ding room was-located'in the
Unit No. 1 Paper Flow Group (PFG) files.
With the exception of
the cable spreading room, all of the Inspection Reports were
closed indicating completion and acceptance of any required
rework.
This review of documentation resolves the initial concern over
~
the lack of electrical separation attributes in conduit
installation inspection procedures.
The NRC inspector was informed that open inspection items
pertain, for the most part, to areas where separation barrier
material (SBM) is required, or to abandoned holes in the
siderails of cable trays.
No action is being taken with regard
to SBM problem areas due to a May 16, 1985, memorandum
prohibiting the installation of SBM, based on NCR E-85-1001805.
-13-
No action is being taken on the remainder of the separation
problem areas, including holes in the cable tray siderails,
pending receipt of further direction from TUGCo Nuclear
Engineering (TNE).
Through discussions with.the electrical QC inspection
supervisor, the NRC inspector was informed that the
approximately 300 to 500 separation problem areas were the
result of a reinspection initiated by QC in early 1985.
The
initial concern was the effectiveness of the cable tray as a
barrier with abandoned holes present in the siderail.
The
effort was terminated because of the amount of ongoing rework,
and a question as to the tignificance of the abandoned holes.
The electrical QC inspection supervisor informed the NRC
inspector that another room / area inspection by QC inspectors,
for electrical separation, would be required subsequent to
completion of rework activities.
Discussions with TNE indicated that a testing and evaluation
program has been initiated to justify the relaxation of
electrical separation requirements.
The NRC inspector was
informed that the results of the testing and evaluation program
should be available during April 1986.
The issue of inspection for electrical separation is an open
. item pending the NRC review of the applicant's
disposition / action pertaining to SBN installation, abandoned
holes in cable tray siderails, the engineering testing and
evaluation report, and the room / area separation inspection
program (445/8601-0-11).
-
(34) (0 pen) Open Item (445/8514-0-07):
Independent documentation
review of 10 verification packages comprising 22 cables.
Comparison of the results of NRC documentation reviews to the
results of the ERC reviews for the following,10 Unit.1
electrical cable verification packages ha's been. completed:
Verification
Package No.
System
Cable No.
R-E-CABL-004
Safety Injection (SI)
Ed123625Z,
'
R-E-CABL-011
Lighting
-
ESB2-13
R-E-CABL-026
Chilled Water
EG111199
R-E-CABL-028
Control Room HVAC
E0015951D
R-E-CABL-035
Instrument Air
EG112939
,
R-E-CABL-042
EG123834
R-E-CABL-054
E0100440
R-E-CABL-078
Diesel Generator'HVAC
EG113538
R-E-CABL-086
Chemical & Volume Control
E0121816Z
R-E-CAB L-089
EG123639Z
>
.
.
-14-
Results of these comparisons are as follows:
R-E-CAB L-004:
A valid DR was issued by the ERC inspector
pertaining to an engineer failing to date his signoff of a
, cable pull card for identifying that the raceway was ready for
cable pulling.
NCR E-85-102052SX has been initiated for this
item.
R-E-CABL-011:
This package was moved to a new population for
lighting cable.
Rereview will be performed in-accordance with
QI-071.
R-E-CABL-026:
This package has been superceded by cable
package R-E-CABL-108 as a result of CPRT's determination that
an inadequate number of random digits were used in the initial
sample selections for the cable populations.
There were two DRs
identified by ERC during their review, which if validated, will
be submitted to TUGCo for processing into a NCR.
R-E-CABL-028:
This package has been superceded by cable
package R-E-CABL-109 for the same reason as R-E-CABL-026.
There was one OR identified by ERC during their review, which if
validated, will be submitted to TUGCo for processing into a NCR.
R-E-CABL-035:
This package has been superceded by cable
package R-E-CABL-110 for the same reason as R-E-CABL-026.
There were two DRs identified by ERC during their review, which
if validated, will be submitted to TUGCo for processing into
NCRs.
The above findings will remain open pending review of the final
disposition.
The comparison of the remaining verification
package resulted in no additional findings and these packages
are considered closed.
4
(35) (0 pen) Open Item (445/8514-0-04):
Further inspection of cable
routing deviating from the cable schedule (i.e., a cable was
routed through conduit C13G06325 instead of C13G06324) showed
that NCR E85-101756SX has been issued to address the finding.
This item will remain open pending disposition of the NCR.
(36) (0 pen) Open Item (445/8514-0-05):
Further inspection of this
open item, pertaining to a 2-inch slack requirement for. cables
and requirement to identify conduit sleeves, showed that two
NCRs were issued to address these concerns.
NCR E-85-101141SX
addressed the 2-inch slack requirement and NCR-E-85-101928SX
addressed the identification requirement.
This item will remain
open pending disposition of the NCRs.
. .
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. - . .
.-
- . - .
. . .
--
-.
-
E
-
-15-
(37) (Closed) Open Item (445/8514-0-06):
Further inspection of this
open item, pertaining to conduit size being 1 1/2 inch as
compared to the 2 inches referenced on the cable and conduit
schedule 2323-El-1700, showed that this item was addressed by
TUGCo letter TU0-3355.
No NCR was issued for this out-of-scope
item based on TUGCo's disposition per the above letter that
s
cable and conduit schedule 2323-El-1700 is not used to determine
conduit size but rather, the~ field physical
Drawing 2323-El-500-03, which specifies the conduit C13008544 is
to be 1 1/2 inches.
(38) (0 pen) Open Item (445/8513-0-24):
Further inspection of this
open item, pertaining to loose locknuts and bushing on
conduit CB3-24-29 and C83-29, showed that the two DRs were
validated and NCR E85-101342SX has been issued.
This item will
remain open pending disposition of the NCR.
(39) (0 pen) Open Item (445/8513-0-25):
Further inspection of this
open item, pertaining to loose couplings and conduit
separation, showed that the two DRs were validated and
NCR E85-101496SX has been issued to address the two DRs.
This
item will remain open pending disposition of the NCR.
4.
Inspection Process Control
The NRC inspector initiated an inspection of the Reliability Assessment
Program that will be completed in a subsequent report.
However, an
uncontrolled use of three part memos was found being used to document
potentially nonconforming conditions that were in areas outside the
process inspection control lots.
Further review of the use of these
three part memos resulted in the following findings:
(a) an informal log
was used to track these memos, but there was no assurance that all memos
were entered on the log; (b) several of the memos on the log could not be
located, thus disposition of the problems could not be assured; and
(c) with few exceptions, no NCRs were written to document / correct the
items on the memos.
These activities are in noncompliance with TUGCo
procedures including CP-QP-16.0 that requires immediate action leading to
an NCR when identifying a deficiency in characteristic, documentation, or
procedure which renders the quality of an item unacceptable or
indeterminate.
This failure to comply with procedures is identified as a
violation (445/8601-V-12; 446/8601-V-03).
5.
Applicant's Processing of ERC Inspection Findings
The NRC inspector conducted a review of the TUGCo QA/QC Coordinator's
files in order to assure that NCRs were being initiated as a result of
ERC issued and validated DRs, and to assess the processing of the NCRs.
The following procedures, applicable to the NCR program, were reviewed:
o
CPSES Station Administration Manual Procedure STA-405, " Control of
Nonconforming Materials," Revision 9, dated November 11, 1985
-16-
o
CPSES Station Administration Manual Procedure No. STA-406,
" Corrective Action," Revision 2, dated February 11, 1983
TUGCoProcedureCP-QP-16.0,"Nonconformance,"Rehision19, dated
~
o
October 16, 1985
o
TUGCo Procedure CP-QP-16.3, " Processing CPRT Deviation
Reports /0bservation Notices," Revision 1, dated August 28, 1985
o
TUGCo Procedure QI-QP-17.0-1, " Preparation and Distribution of Trend- .
Reports," Revision 1, dated January 10, 1986
o
B&R Procedure CP-QAP-16.1, " Control of Nonconforming Items,"'
Revision 25, dated August 17, 1985
m
g
o
B&R Procedure N61-1, " Program For Repair or Replacement of Mechanical
Components Accepted by the Owner," Revision 4, dated December 10,
1985, through Change Notice No. 1, dated January 2, 1986.
During this inspection effort, the NRC inspector identified' conditions
which were contrary to the requirements of the procedures.
Paragraph 3.2
in Procedure CP-QP-16.3 states, in part, ". . . All DRs will require the
'
generation of an NCR."
Review of the records revealed numerous instances
'
where the TUGCo QA/QC Coordinator had incorrectly invalidated DRs issued
by ERC, thus resulting in a failure to generate NCRs.
Further, the DR log
showed that Deficiency Notifications (DNs) were improperly used in lieu of
NCRs.
Rework or repairs were performed as a result of these DNs.
DNs, as
addressed in paragraph 8.0 of Procedure N61-1, are to be used for
documenting deficiencies identified during repair or replacement of
mechanical components previously accepted by TUGCo.
A nonconformance, as defined by Procedures CP-QP-16.0 and CP-QAP-16.1, is
a deficiency in characteristic, documentation, or procedure which renders
'
the quality of an item baacceptable or indeterminate.
Both procedures
required that nonconforming conditions be reported on NCRs.
,
Procedure CP-QP-16.3 addresses ERC's responsibility for generating
Observation Notices which are used for documenting out-of scope
observations, and their subsequent transmittal to the QA/QC Coordinator.
Further, paragraph 3.2 states, "The QA/QC Coordinator shall evaluate the
condition (s) identified on the Observation Notice to determine if a NCR
is to be issued." The NRC inspector observed over 100 Observation Notices
~
in which conditions were determined to be nonconforming, as evidenced by
subsequent rewor k or repair.
However, the QA/QC Coordinator had not
issued NCRs.
It was further noted that, in some cases, DNs had been
improperly initiated in order to effect the rework or repair.
Procedures CP-QP-16.0 and CP-QAP-16.1 require nonconforming items to be
identified by the use of signs, barriers, or hold tags.
However,
observation of numerous items identified on NCRs as being nonconformances,
revealed no evidence of signs, barriers, or hold tags.
4
-
-
- - - .
-
n
-
--
,
,.:-...-
- _ . -
- , , . - . .
-17-
Paragraph 3.5 in Procedure QI-QP-17.0-1 states, in part, "The Trend
Analysis report shall be issued monthly and contain Potentially Adverse
Trends . . . ." Paragraph 3.4.1.1 states that potentially adverse trends
are based on the relationship of the number of NCRs initiated in the
current reporting period to the preceding three month average.
The NRC inspector has identified that NCRs have not been initiated as
required.
As a result, the validity of potentially adverse trends
contained in the Trend Analysis Report is brought into question.
Failure to comply with the applicable requirements of the procedures is a
violation (445/8601-V-12; 446/8601-V-03).
6.
Assessment of Allegations
a.
AQ-145 (4-85-A-15) and AQ-153 (4-85-A-30):
It was alleged that the
Construction Startup/ Turnover Surveillance (CSTS) group:
(1) had
not trended their surveillance results from April 1983 to April 1985;
'
and (2) were being required to look at less, as a result of reduction
in staff from 10 to 4 people, without corresponding reduction in work
load (AQ-145).
It was also alleged that CSTS group management
created a difficult environment for their personnel to work in which
caused pressures that affected work output (AQ-153).
,
(1) AQ-145(1) - The program for trend analysis to identify
conditions adverse to quality was previously assessed by the
NRC.
This assessment was documented in NUREG-0797, Supplement
No. 11.
The substance of this current alleCation was considered
by the NRC in Appendix P of Supplement No. 11.
The NRC found
that deficiency reports, NCRs and CSTS reports, which identified
discrepant conditions were not trended periodically, as
prescribed by the FSAR for identification of adverse quality
trends.
The applicant responded to three NRC findings i Appen' dix C to
the CPRT Program Plan, ISAP No. VII.a.2.
This ISAP committed,
among other things, to (a) review.the trend analysis program
implemented on site versus FSAR commitments, and (b) to identify
any programmatic weaknesses which require correction with
^
respect to the work remaining on Unit 2 and the operations QA
program.
The NRC is currently inspecting the implementation of the
applicant's commitments.
(2) AQ 145(2) - The CSTS Oroup was found by the NRC inspector
through interview and reviewing organizational charts, to have
been comprised up to mid-1984 of two types of surveillance
technicians; i.e., construction and startup/ turnover (SU/TO).
The construction surveillance technicians were performing
hardware walkdown inspections to verify that hardware conformed
..
-
-
_
.- -
.
-
.- -.
.-
-18-
to drawings, procedures, and specifications governing work being
inspected.
SU/TO surveillance technicians monitored
preoperational testing activities for conformance to
procedure / programmatic requirements.
The CSTS group staff was
reduced from 10 to 4 people as identified during the summer of
1984.
The reduction in staffing resulted from completion of
specified Unit I room walkdowns in mid-1984 by the construction
technician section of the CSTS group. Accordingly, the group
was reduced (during the summer of 1984) consistent with handling
the remaining activities.
This reduction did not directly
affect the SU/TO surveillance technicians.
The procedure governing the surveillance program was reviewed.
Procedure CP-QP-19.6, Revisions 0 to 7,
" Surveillance of
Construction and Startup/ Turnover Activities," indicated that
the surveillance program for the construction, turnover, and
startup phases progressively evolved from a general program to a
more specific and structured program.
Between May 15, 1984, and August 9, 1984, three significant
revisions were made to CF-QP-19.6 as a result of experiences
learned through performed surveillances.
For example, room
walkdowns yielded numerous findings which were documented in
large surveillance reports.
Contained in the reports were minor
discrepancies, hardware nonconformances, and procedural
deviations.
Tracking and resolving these problems was found to
be an unwieldy process when compared to existing site mechanisms
such as NCRs for hardware nonconformances and deficient reports
for procedural / programmatic deviations.
NCRs and deficiency
reports were more suited to processing and resolving identified
problems than the surveillance reporting mechanism.' To address
the above condition, on July 31, 1984, an office memo (TUQ-2260)
was issued to more clearly identify what methods should be used
to identify and resolve findings resulting from surveillances.
Some of the subjects covered by the memo included correction of
minor items using the rework process, basis for documenting
.
discrepant items on an NCR, and a description of when to use the
!
CSTS deficiency reporting system.
These policies were included
l
in CP-QP-19.6, Revision 7, dated August 9, 1984.
Based on
!
review of procedures governing CSTS activities, there was no.
indication of a reduction of surveillance' requirements.
The-
revisions to CP-QP-19.6 and issuance of TUQ-2260 during the.tirr.e
period when the reduction in the group occurred could be viewed
l
as restricting the latitude and requirements for performing
surveillances.
i
With respect to adversely restricting surveillances ("look at
less"), the NRC inspector reviewed the log of performed
I
surveillances.
It appeared that the surveillances performed
after the reduction in personnel covered similar subjects to
those performed in the prior period.
A sample of Dallas
I
-19-
surveillance reports (DSRs), including DSRs identified by the
al. leger, was reviewed to determine if the scope, magnitude,
reporting requirements, and resolution to findings showed any
evidence of restriction of surveillance activities following the
reduction in personnel.
No changes were noted and DSRs appeared
to be resolved in a timely manner.
Dispositioning was with the
concurrence of the cognizant surveillance technician.
(3) AQ-153 - It was alleged that a difficult environment for their
personnel to work in was created by CSTS group management which
generated pressures that adversely affected work / output.
Since
the time frame and substance of the allegation appeared to be
similar to AQ-145(2), these allegations were assessed
simultaneously.
The information obtained from reviewing
procedures governing CSTS activities, published surveillance
reports and resolution to findings, organizational charts, and
office memos regarding CSTS activities is listed below.
From May to August 1984, three significant changes were made to
the procedure (CP-QP-19.6) directing CSTS activities.
An
office memo TUQ-2260 was written by the CSTS supervisor to
clarify policy regarding the identification and reporting of
surveillance findings.
The substance of the memo could be
interpreted as signifying that management was disenchanted with
the group's performance; however, no memos were found that were
written for disciplinary actions or personnel performance
problems.
The group was reduced in size from 10 to 4 due to
work realignment.
During 1984 and 1985, the lead position in
the group was changed three times and the supervisor's position
twice.
In September 1985, the CSTS surveillance program was
totally revised including the methods of reporting and resolving
findings.
The revision was to meet the changing role,of CSTS in
the site QC function.
Because of the numerous changes in policies, procedures, and
personnel described above, the alleger's expressed concern is
understandable.
The working environment appears to have been.
consistent with the nature of the changing work activities at
the site and did not appear to be systematic and intentionally
created by CSTS management to place pressure on the surveillance
technicians.
Based on review of the surveillance schedules and
published reports, it did not appear that the above described
onvironment abnormally affected work output.
In conclusion, the allegation AQ-145(1) that results from CSTS
reports and findings were not trended from April 1983 to
April 1985 was substantiated during an earlier TRT assessment.
The applicant has initiated corrective and preventative
measures, which the NRC is continuing to inspect.
In AQ-145(2),
it was identified that CSTS was reduced to a manpower level of
4; however, it was neither substantiated that the reduction
-20-
adversely affected surveillance performance, nor that the work
load was the same as before the reduction.
The concern (AQ-153)
that the CSTS management created a difficult working environment
which adversely affected work output was not substantiated.
b.
AQ-150 (4-85-A-30):
It was alleged that operations pl_ ant personnel
were unfamiliar with the operations QA orga'nization,' its site
personnel, and its function.
<'
,
s
Theinformationpresentedby'heallegerwasgeneralfinnAntureand
t
identified that operations personnel were. unaware ofis (1) the
quality organization's objectives, personnel, and functions, and-
.
(2) the mechanism to identify and report observed discrepancies and
concerns.
These concerns question the effectiveness'of employee
indoctrination and training regarding thi role ofiQA in thei
operations phase.
The approach to resolving this allegation.was to-
assess TUGCo's general employee training program relative to QA and
to interview a sample of employees to determine if they were
knowledgeable about the QA role at the site.
In reviewing the FSAR, it was found that Section 13.2 commits to
general station training.
Procedure TRA-101 is the implementing
station procedure for the general employee training (GET) program.
The objective of the procedure was to assure that all employees (and
-others) who have unescorted access to the protected area of the
station will receive training commensurate with their
responsibilities.
Among other things, one of the principal areas of
GET is the QA program and its role at the site. GET is given to new
hires with an annual refresher to assure that all individuals
maintain competency in the safe operation and maintenance of the
facility.
The GET program was implemented in February 1983.
The NRC inspector reviewed the GET indoctrination lesson plan and
notes given to TUGCo employees and other attendees.
The lesson plan
contained the following items:
(1) QA introduction, (2) definition
of selected QA terms, (3) discussion of legal requirements,
(4) organization structure, (5) hierarchy of documents, and
(6) problem identification and reporting.
QA indoctrination is
followed by an examination,'which has a minimum passing grade of 70%
for the following subjects:
o
Goal of the QA program (quality is the responsibility of
everyone)
o
Definitions of QA terms; e.g. , quality, QA, QC, hold point,
audit, safety related, deficiency, nonconformance, and quality
related
o
Relationship of 10 CFR Part 50, Appendix B, to the QA program at
CPSES and the NRC's responsiblity in monitoring the QA program
,
..
-21-
o
Stop work authority
o
Purpose of procedures, employee's responsibilities to use
procedures, and how to handle inadequate / incorrect procedures
o
Methods and individual (s) responsible for reporting deficiencies
and nonconformances and the employee option of talking to the
NRC
,
o
Purpose of hold tag, and how/who may remove' hold tags
~
,
o
Identification of selected examples of-deficiencies'and
nonconformances
,
,
,
For further reference, each student is given a.GET booklet which'
covers each of the above subjects in detail.
~
Training files were reviewed to verify implementation of. training
procedures.
It was observed that for each employee'and others, the
type of training received was entered into a computer data base ~and
backed up by a hard copy file.
The actual training session file
contained attendance records (with student signatures), examination
grades, and subject matter covered.
NRC, B&R, and other personnel
receiving GET training have files similar to'TUGCo employees.
The
only difference being that non-TUGCo employee training is based on a
need to know, rather than on a utility requirement.
1
~
To determine if site personnel were cognizant of the role of QA, its
organizational structure, its function, and methods used to report
nonconformances, as presented in GET, site operations personnel were
t
interviewed.
The sample included personnel from the administrative
function, engineering department, maintenance and operations
personnel, and QA/QC individuals.
It was observed that employees
were knowledgeable about the QA/QC goals and organization at the
site, what individuals should be contacted to identify and report
discrepant / nonconforming conditions, and the mechanism used to
document deficiencies /nonconformances.
In conclusion, the allegation that operations personnel were
unfamiliar with the operations QA organization, its site personnel,
and its function was not substantiated.
Since the GET program was
not implemented until February 1983, the alleged conditions could
have possibly existed to some degree in the past.
c.
AQ-144 (4-85-A-29) and AQ 152 (4-85-A-30)
It was alleged that TUGCo attempted to dictate what the authorized
nuclear inservice inspector (ANII) would review / inspect by bypassing
his prework review of maintenance action reques
(MAR) work packages
(AQ-152), one such MAR included an undersized barger weld (AQ-144).
_ . _ -
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_ . - - - - - - . .
_ _ . - - _ - - _ _ .
.
.-.
-22-
These allegations concerned plant systems which have been completed
and accepted under the ASME Code Section III construction program and
have been turned over to TUGCo operations.
Any subsequent repair or
replacement activities are accomplished and controlled undar the
operations ASME Section XI QA program.
The impact of bypassing the
ANII's prework review (intended to establish required hold points for
repair activities only) questions the credibility of the applicant's
ASME Section XI repair and replacement program.
The ASME Code does
not require ANII prework review of replacement activities.
To determine if the ANII was bypassed in the prework review of MAR
work packages, all the "NIS-2 Owner's Reports for Repairs or
Replacements" were reviewed, consisting of approximately 150
packages.
For ASME Code repairs and replacements required in MAR
work packages, completion of the NIS-2 report form by the owner and
tha ANII certifies that all the applicable code requirements have
been meet and the required inspections have been performed.
The
NIS-2 report packages were obtained from the TUGCo operations vault
and reviewed for completeness and evidence of ANII prework review.
The packages were found to be complete.
In two of only four packages
involving weld size increases, the date of the ANII review was later
than the approval to start work date indicating possible bypassing of
the ANII's prework review.
In checking the ANII's daily inspection
log, it was found that these two packages had bypassed ANII prework
review.
When these packages initially were in the field, prior to
start of work, a QC inspector discovered the absence of required ANII
hold points and stopped work from continuing.
The packages were then
returned to the ANII for prework review and reissued to the field for
work.
An inspection report (No. 85-2) was issued by the ANII that
identified this bypassing as an implementation deficiency of
procedure MDA-303, Revision 0.
The applicant's~ response was to
reinstruct / retrain personnel involved in the review of repair and
replicement work packages to assure that ANII prework reviews were
provided for, when required.
Attached to this response was the
documentation attesting to completion of the training.
In discussing
this occurrence with the ANII, he stated that he was not aware of any
other instance of bypassing.
Further, the record' review by the ANII-
associated with the issuance of all NIS-2 reports would have
discovered any previous bypassing of the ANII.
In summary, although
two identified instances of bypassing were found to have occurred, no
other such occurances were found in a complete review of the relevant
MARS.
Moreover, the two instances were correctly identified by QC,
and corrective action to prevent reoccurrence was implemented.
For repair activities, the ASME Code requires the ANII to perform
prework documentation reviews (to establish desired hold points) and
perform inprocess inspections as necessary.
For replacement
activities, ANII prework review and inprocess inspection
participation is not a requirement.
The ANII is only required to
verify (by way of documentation review) that the applicable ASME Code
requirements have been met and required inspections performed.
Since
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the alleger was not part of the operations personnel, he may have
perceived the lack of ANII participation during inprocess replacement
activities as bypassing the ANII review.
Although not required,
since June of 1985 the ANII has been involved in at least 30 percent
of Section XI replacement inprocess work activities by performing
prework reviews and establishing hold points and performing
inspections.
In conclusion, the general allegation that TUGCo attempted to dictate
what the ANII would review / inspect by bypassing his prework review of
Section XI repair and replacement work packages was not
substantiated.
ANII inprocess involvement for Section XI replacement
activities is not required by the ASME Code, thus bypassing the
ANII's prework review for replacement MARS would not have been a
requirement.
The ANII inprocess involvement for Section XI repair
MAR work packages is required by the ASME Code and is being
accomplished.
The instances where the ANII was bypassed on repair
MARS appears to have been an isolated occurrence that was identified
and corrected when it occured.
d.
AQ-149 (4-85-A-15):
It was alleged that operations QA surveillance
report findings were being suppressed or severely changed.
In assessing the allegation, the NRC inspector reviewed backup files
of quality surveillance reports from 1983 through 1985.
The purpose
of the review was to determine if the contents of draft findings were
changed or altered prior to final publication.
Copies of drafts were
found either in the official backup files or in the personal files of
individuals performing surveillance activities.
Comparison of-drafts
to final reports disclosed editorial (grammar and spelling) changes.
One draft contained redundant subjective comments which were not
included in the final report.
No suppression of findings or
alteration of content was observed.
Six of nine current and one former QA surveillance individuals were
interviewed.
None of the individuals interviewed believed that they
were pressured to suppress findings, and all indicated that they had
sufficient independence in writing surveillance findings.
As a
practice, changes to drafts were discussed between the surveillance
personnel and their supervision prior to changes being made.
One
individual acknowledged that at times his reports contained
subjective comments which he agreed to delete.
In conclusion, the allegation that surveillance findings were
suppressed or changed between initial drafts and final report
publication was not substantiated.
This conclusion is consistent
with similar assessments made by the NRC, in particular the NRC's
assessment of AQ-132 as presented in NUREG 0797, Supplement No. 11.
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e.
AQ-155 (4-85-A-33):
It was alleged that maintenance procedures in
the operations area were not consistent with commitments to ANSI
standards and Regulatory Guides, and operations procedures had
similar problems.
In assessing the allegation, the NRC inspector reviewed TUGCo
procedures, policies, and FSAR commitments addressing the control of
operational phase procedures and instructions.
Documents reviewed included STA-201, Revision 12 " Preparation,
Responsibility and Content of Station Manuals"; STA-202, Revision 13,
" Preparation, Review, Approval and Revision of Station Procedures";
STA-209, Revision 4, " Preparation, Review, Approval, and Revision of
Station Instructions"; STA-401, Revision 10, " Station Operations
Review Committee"; QAI-008, Revision 0, " Review of Procedures,
Instructions, and Plans"; quality program policy as stated in the
Operations Administrative Control and Quality Assurance Plan (OAC&QAP),
Sections 13.1, 13.2, 13.3, and 13.4; and FSAR, Chapter 17.2.
These
documents were consistent with 10 CFR Part 50, Appendix B.
Section 17.2.5 of the FSAR requires that activities affecting the
quality of safety-related components be prescribed by and
accomplished in accordance with documented instructions and
procedures.
The implementing policy document establishing
instruction and procedures control for the operations phase is the
CPSES OAC&QAP.
The supervisor or superintendent that has cognizance over a specific
safety-related activity is responsible for the development and
approval of instructions / procedures prescribing the activity.
Administrative procedures and instructions are to be reviewed and
approved prior to performance of the activity.
The cognizant
supervisor is responsible for assuring that the activity is performed
in accordance with the procedures and instructions.
The development,
review, and use of instructions and procedures is to be monitored by
the operations QA supervisor as part of the station quality
surveillance program.
These commitments appear to be consistent with
the provisions of Regulatory Guide 1.33 and ANSI 18.7-1976/ANS-3.2.
Section 13 of the OAC&QAP delineates the requirements regarding the
content of various types of procedures and instructions.
These
requirements provide for the inclusion, as necessary, of items such
as purpose, references, prerequisites, precautions, limitations,
step-by-step instructions, acceptance criteria, and check-off lists.
Station manuals contain administrative procedures which describe
activities and reference implementing instructions.
As appropriate,
the procedures for an activity may themselves contain the necessary
instructions.
Implementing instructions may be contained in the
cognizant activity manual with associated administrative procedures,
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or may be in a separate station manual. Typically',' manuals cover
station administration, engineering, operations, maintenance, and
station refueling.
To verify implementation of the operations procedural control
program, a' sample of procedures / instruction governing and directing
maintenance, engineering, quality, and operations-activities was-
~
reviewed.
It was observed that the pro,cedures/ instructions were
,
prepared, reviewed, revised and distributed in accordance^with FSAR
commitments. All procedures / instructions which are safety-related
were reviewed by quality.
This review was' performed and documented
using the QA department procedure / instruction reviek sheet'-
(Attachment 1 to QAI-008).
Each procedure / instruction was; reviewed <
to determine if it adequately addressed the applicable' requirements
of the FSAR; associated specification (design and/or technical
>
specification, as applicable); Regulatory Guides; other site
procedures, instructions, and plans; nuclear industry standards
'
(i.e., ANSI N18.7-1976); OAC&QAP; and any other related documents;
i.e., NUREG, NRC Bulletin, Information Notice, and Circular.
To ascertain if the allegation was time dependent, the operations
quality surveillance reports which appraised procedural control for
operations and maintenance were reviewed.
Three such reports were
Quality Surveillance Reports QAR 85-001, QSR-003, and QSR-006.
These surveillances were conducted from October 14, 1984, to
January 24, 1985. Approximately 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> were spent providing
24-hour coverage by the operations QA staff during the performance of
these surveillances.
During the surveillance review of maintenance procedures, two
deficiency reports were written against several maintenance
surveillance test procedures for not complying with the OAC&QAP, ANSI
N18.7Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.7" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., NUREG/CR-1369 and STA-702 requirements.
The NRC inspector
reviewed the deficiency reports and noted that resolutions were
timely and approved by the surveillance technician who initiated the
deficiency report.
No deficiency reports were written, however,
against operations procedures for not complying with the FSAR,
OAC&QAP, or NRC requirements.
Several deficiency reports were
written concerning procedural implementation and use.
The overall
summary from the surveillance reports was that the operations QA
program, including procedural control, was satisfactory.
The
identified deficiencies principally related to the station's
implementation of specific requirements.
Based on the NRC's assessment of the operation procedures / instruction
control programs, the allegation that maintenance and operations
procedures were not consistent with commitments to ANSI and
Reguistory Guides could not be substantiated.
However, from reviews
of past operations QA surveillance reports, minor deficiencies in
maintenance procedures not complying with ANSI and Regulatory Guides
requirennts have been identified, but none were identified against
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operations procedures.
It is possible that in the past there was
some substance to the allegation.
Currently, the
procedural / instruction control program appears consistent with
requirements.
f.
AQ-167 (4-85-A-18):
It was alleged that a B&R inspector performed
inspections of ASME activities for which he was qualified but not
certified, and subsequently his certification was predated by
. management.
A review of the B&R ASME procedures was i:onducted to determine if
procedurally it was permissable to (1) predate inspector
~
certifications or (2) perform inspections between qualification
testing and certification issuance, as alleged.
It was found that
neither of these two activities was permitted by procedure.
The
interval between qualification testing and certification issuance is
normally used by the certifying Level III to determine if the
candidate has met all certification prerequisites. '
^
A selected sample of B&R ASME inspector qualification and training
files (obtained from the permanent plant' records vault) were reviewed
for predating of certifications.
The certifications, including those
of the inspector alleged to have been improperly used, did not
disclose any predating or other irregularities (e.g. , white-outs or
undocumented changes to record content), which would appear to have
been falsification of records.
With respect to inspectors performing inspections between
qualification testing and certification issuance, a sample of
certification dates versus qualification testing dates were compared
with completed inspection records.
The time period selected was from
May 1982 to July 1984, the time frame of the allegation.
The
interval between testing and certification was found to vary from 1
to 67 days; the average being 8.4 days.
Inspection records (traveler
packages) were searched to identify all inspections performed by each
inspector in the sample, beginning with the time of qualification
testing to 6 or 8 months after certification.
The expansion of the
interval beyond certification issuance was to account for any time
lag that may have been associated with traveler package closecut.
In
every case, the NRC found inspectors were certified prior to the
performance of inspections.
In summary, the NRC did not find evidence of predating of B&R
inspector qualifications.
Certifications reviewed did not have any
apparent indications of falsification, neither were any instances
observed of inspectors performing inspections during the interval
between qualification testing and the issuance of certification.
Accordingly, this allegation was not substantiated.
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g.
AQ-146 (4-85-A-15), AQ-151 (4-85-A-30), AQ-160 (4-85-A-31), and
AQ-164 (4-85-A-32):
It was alleged that plant operations management does not accept
deficiency report and surveillance findings identified by the
Construction Startup/ Turnover Surveillance (CSTS) group on operations
activities.
Examples identified were:
(1) a CSTS inspector found
inconsistent or ineffective implementation of procedures, but
operations did not provide feed back, thus CSTS had no knowledge of
any action taken (AQ-164); (2) operations had an uncooperative and
unresponsive attitude towards CSTS findings (AQ-146); and
(3) Surveillance Deficiency Report (SDR 84-12) involving operations
procedures, identified an adverse trend that did not appear to have
been acted upon by either operations or QA management (AQ-151 and
AQ-160).
The substance of the current allegations were considered by the NRC
in Appendix 0 of NUREG-0797, Supplement 11 during the assessment of
Allegation AQ-112.
Under most circumstances, allegation (s)
previously assessed by the NRC would be relied upon without further
assessment; however, because these issues were identified by several
different individuals, the NRC r'ected to reassess these specific
issues.
The roastessment also was to assure that the previous
assessment had addressed all relevant aspects of these issues.
The basis for AQ-146 and AQ-164 was what the CSTS group perceived as
a failure to follow procedures by the operations personnel.
Instances cited by the CSTS group were first reported to the
operations plant manager for action to prevent recurrence in TUGCo
Interoffice Memorandum (memo) No. DQA-84164, dated June 27, 1984.
By
July 6, 1984, the CSTS upgraded its findings and observations to an
SDR (84-012) which required a formal response within 7 calendar days.
The SDR's description of the reported deficiency was, " Review of Test
Deficiency Reports and observations during preoperational. tests has '
revealed an adverse trend in the area of operations and compliance to
sound operational principles, procedures and instructions.
Ref:
DQA 84164, SWA 20563, and attached TDR's (2822' 3075, and 3061)."
,
AQ-151 and AQ-160 deals with the processing and resolution of
SDR 84-012.
In a July 10, 1984, joint meeting with CSTS and operations personnel,
as documented in memo DQA-84182 to operations from the CSTS
supervisor, it was acknowledged that since " . . . the problem areas
identified in the above CSTS-SDRs (which included DQA-84164 and
SDR 84-012) had been identified by your staff and were being
investigated, no reply to this office is required." Nonetheless,
operations QA responded to the CSTS concerns in memo QIM-84116, dated
October 1, 1984.
Based on the information provided in QIM-84116, the NRC inspector
verified that the CSTS concerns expressed in DQA-84164 and SDR 84-012
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,had indeed been identified by operations QA personnel before being
-identified by the CSTS personnel.
QIM-84116 also provided the
' resolution of the CSTS concerns or the justification why no action
was required. The NRC inspector evaluated the disposition of the
CSTS concerns by operations QA and found them appropriate.
The allegation that' plant operations management did not accept
findings. identified by.the CSTS group could not be substantiated,
either in earlier or current NRC inspections.
Operations personnel
were found to respond to CSTS findings, observatior.s, and SDRs in a
cooperative and responsive manner.
Also, CSTS had knowledge of-
actions taken by operations with respect to'the. specific CSTS
findings in this allegation.
h.
AQ-158-(4-85-A-31):
It was alleged that there was no documentation
(records) for.surveillances in the construction areas for 1983
through mid-1984. Although surveillances or surveillance programs
are not an NRC regulatory requirement, TUGCo is committed to
surveillances by Section 17.1.1.1.1 of.the CPSES FSAR which states:
- The Quality Assurance Division is. responsible for the development,
"
implementation, and surveillance of the TUGCo Quality Assurance
program for design and construction.
This. responsibility extends
into all project activities including engineering, design,
procurement, and construction."
The NRC inspector interviewed _the QA and QC surveillance supervisors
and found that the allegation pertained to surveillance activity
performed by QA personnel who reported to the TUGCo. site QA
supervi sor.'
The surveillances were conducted in accordance with
TUGCo Procedure CP-QP-19.6, " Monitoring of Construction and
Installation Activities."' Revisions 2, 3, and 4 of the procedure
.
were applicable for the time frame'of the allegation.
For
clarification of the terminology,. monitoring versus surveillance,
although the procedure:is entitled monitoring, the activity is
commonly referred to as surveillance.
'
,
TUGCo Procedure CP-QP-19.6 stated that its purpose was 'to outline the -
method used to monitor quality related a6tivities to assurel ,
compliance to approved instructions, p'rocedures'and/or drawings
'
implementing the requirements of the B&R QA manual (QAM)l'and the
TUGCo CPSES QA plan. The procedure further states,," Construction ~<-
monitoring shall be performed by assigned personnel usini dstalled
checklists prepared from the B&R QAM and implementing procedures.
'
Assigned personnel shall verify complianca of the delineated
activities through observation of work activities, discussions with
'
cognizant personnel, and review of objective. evidence.
The results
,
I.
of the monitoring activities shall be documenteo on the checklist for'
l
subsequent review by the TUGCo Site QA. Supervisor'or his designee."
i
Additionally, the procedure addresses reporting and followup,'the "
frequency of monitoring, corrective action trends, and files.
i
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The NRC inspector found that the non-ASME surveillance schedule for
1983 (Ref: office memorandum TUQ-1491 dated December 8, 1982) called
for 12 surveillances and designated the activity to be covered. The
NRC inspector's review of the surveillance record documentation found
that 19 surveillances were performed. However, only the scheduled
January surveillance was conducted in accordance with the schedule
for the activity specified.
Four of the other scheduled activities
were accomplished, but not in the month scheduled. The seven
surveillances conducted in February, April, July, August October,
November, and December were not those required by the schedule. The
departures from schedule were discussed with the QA supervisor who
explained that the schedule had been revised; however, he could not
produce a copy of the revision for the NRC inspector to review.
The NRC inspector reviewed the surveillance records for 1983 and
found that the checklists revealed that some of the surveillances
covered only a review of procedures. Since the stated purpose of
Procedure CP-QP-19.6 is to monitor construction and installation by
observations of work activities, discussions with cognizant personnel
and review of objective evidence, the NRC inspector found that those
surveillances consisting only of a procedure review did not comply
with the monitoring procedure. Some of the surveillance records
contained duplicate checklists which were marked to identify that one
was used for procedure review and the other used for verification of
implementation. Although the implementation checklist implied that
work activity was observed, and the lists were checked " SAT" or
"UNSAT", the construction / installation activity observed and the
objective evidence reviewed by those doing the surveillance were not
identified in the surveillance records.
In the review of the
surveillance records and discussions with the QA supervisor, the NRC
inspector found that the emphasis of the surveillance program appears
to have been on procedure reviews rather than observations of
construction / installation work activities and review of objective
evidence for those activities, which were the methods described in
the procedure.
During the NRC review of these surveillance records, several
anomalies were noted that included:
(1)checklistattributeswere
not checked, or were crossed out without explanation; (2) checklists
did not identify the person who completed the list; (3) some
checklists in the record file were not accompanied by the
surveillance report; and (4) there was no evidence that surveillance
reports were reviewed by the site QA supervisor. These conditions,
which are procedural noncompliances, reflect poor practice and are
indicative of ineffective implementation of the surveillance program.
The current surveillance program is conducted under the
responsibility of a surveillance supervisor and the structure of the
organization divides the surveillances into four separate well
defined tasks which cover: documentation, inspection, startup/ turnover
and construction.
New program procedures have been prepared
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a'nd issued and more controls imposed for performing, reporting.
- evaluation, and for trending the results of the surveillances.
In summary, this allegation has been substantiated in part, in that
surveillances were conducted but they were poorly documented.
In the
1983 timeframe, numerous departures from procedures were identified;
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however, this problem appears to have been recognized by the
,
-
applicant in that the site surveillance program has since been
reorganized and restructured. The currsnt surveillance program,
which appears to be an improvement over the program in place in 1983,
is scheduled for NRC ir.spection during the next report period.
.
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i.
AQ-154 (4-85-A-30):- It was alleged that a Section XI QA surveillance
'
>
supervisor incorrectly changed a procedure in order to disposition
1
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deficiencies that were reported in a deficiency surveillance
report (DSR).
.
The NRC assessment of the allegation found that TUGCo QA surveillance
i
report DSR-85-013 dated February 28, 1985, reported a deficiency that
one work authorization per Section XI program (WASP) form did not
identify the applicable drawing number and that seven WASP forms,
'
although the _ drawing number was identified, did not indicate the
1
drawing revision. The omission of the drawing and/or revision number
!
!
was contrary to Section 3.2 of Procedure CP-XI-4.8, Revision 1,
" Preparation, Review, Control and Distribution of ASME Section XI TNE
)
De. sign Drawings."
Disposition of the cited deficiency was documented in TNE office
memo TSG-8762 dated April 1, 1985, to the QA surveillance supervisor.
The TNE disposition was to correct the deficient WASP forms by adding
the necessary drawing and revision numbers as well as a proposed
revision of Procedure CP-XI-4.8 eliminating the requirement for a
drawing revision number. The TNE proposed revision of
Procedure CP-XI-4.8 did not provide any justification for deletion of
the drawing revision numbers required on the WASP form other than to
prevent recurrence of the deficiency. The surveillance package also
contained documentation that the QA surveillance supervisor accepted
the THE disposition and reouested the formal revision to the
.
procedure. The NRC inspector found that the revised procedure
deleted the words " Revision Numbers" from Section 3.2.
1
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The alleger had stated that the QA surveillance specialist that
4
perfomed the surveillance, and was responsible for closure of the
deficiency after the corrective action was addressed, disagreed with
,
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the QA supervisor's acceptance of the corrective action because there
could be a later problem. The NRC inspector interviewed the QA
>
<
supervisor, but was unable to ascertain what the potential problem
!
was that concerned the surveillance specialist.
In further
discussion with the NRC inspector, the QA supervisor explained that
his basis for' revising the procedure in accordance with the TNE
disposition was justified by the fact that the work package that
!
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-31-
contains the WASP form also contains the actual drawings.
In
addition to the WASP form and applicable drawings, a package
inventory card is included in each work package that lists the
package contents, including drawing numbers and revisions, as
required by Procedure CP-CPM-7.1A, Revision 2, "Ducumentation Package
Preparation."
To verify the process described by the QA supervisor and the
implementation of Procedure CP-CPM-7.1A, the NRC inspector reviewed
the contents of 21 completed WASP work packages taken from the
interim records vault.
In every package, copies of the applicable
drawings were included, each package invertory card correctly listed
the contents of the package including drawing numbers and revisions,
and in all but three packages the WASP form included the drawing
revision number even though no longer required by Procedure CP-XI-4.8.
Therefore, the identification and control of these documents are
being maintained.
While the alleged actions did occur, the deletion of the revision
requirement on the WASP form from the procedure as corrective and
preventive actions does not appear to have been improper or
incorrect. The control of documents is still maintained through the
package inventory card in each package and the existence of the
drawing itself in each package.
J.
AQ-147 (4-85-A-30):
It was alleged that a TUSCo report to the NRC
may be misleading because it presented surveillance data concerning
welding supervisors' knowledge of procedural requirements which
occurred after the training had been conducted.
The NRC inspector reviewed TUGCo QA surveillance report DSR 85-004
dated January 18, 1985, which was referred to by the alleger, and
interviewed the QA surveillance supervisor, a QA technician in the
surveillance group, and the project welding engineer to obtain some
of the details necessary for this assessment.
The document review and interviews revealed that the surveillance was
performed as part of TUGCo's corrective action in response to
concerns which were raised as a result of an NRC site inspection tour
on January 10, 1985. This concern stated that it appeared that two
craft weiding supervisors lacked sufficient understanding of welding
procedure requirements, principally the control of weld filler
materials.
On January 11, 1985, a QA surveillance of craft supervisors was
initiated to determine the supervisors' knowledge of procedural
requirements. During the process of developing the methodology to
implement the surveillance, the QA supervisor instructed the QA
surveillance technician to develop a number of questions that would
be asked (verbally) of the supervisors. The questions were derived
from procedure CP-CPM-6.9B, " Weld Filler Material Control." The QA
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surveillance group's evaluation of the accuracy of the craft
supervisor's answers to the questions would reveal the need for and
the extent of training for craft supervisors.
The surveillance was interrupted by management because a training
session had been scheduled for craft supervision on January 12, 1985,
making the surveillance unnecessary.
The NRC inspector verified
recorded evidence that procedure training and testing was conducted
as follows on January 12, 1985:
All craft supervisors - CP-CPM-6.98, " Weld Filler Material
Control"
Structural, Iron Workers and Millwright Supervisors - WES-29,
'" Welding Specification for Field Fabrication and Erection of
Structural Steel"
Fabrication Shop and Component Supports Supervisors -
CP-CPM-9.10 " Fabrication of ASME Related Component Supports"
Piping Supervisors - CP-CPM-6.9D, " Welding and Related
Processes."
On January 15, 1985 (after the training session), a surveillance was
conducted using the questionnaire developed on Jantary 11, to assess
the effectiveness of the January 12 training.
The surveillance
report stated that there were no QA concerns pertaining to the
supervisor's knowledge of the procedural aspects in the control of
weld filler material.
The NRC inspector compared the above actitns and their sequence with
the information contained in a January 15 1985, TUGCo letter to the
NRC.
The letter presented an accurate saquence of events and a brief
but correct description of actions taken.
One statement in the
letter could be viewed as misleading ("It appears that two. craft
welding supervisors lacked sufficient understanding of welding
procedure requirements."); however, this' statement refers to the
supervisors interviewed by the NRC during the site tour on
January 10.
This report goes on to clearly state that the training
of all supervisors was conducted on January 12, 1985, and that a
surveillance was being conducted to assess the effectiveness of the
training.
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The inspection finds that the TUGCo report of actions regarding the
training of craft supervisors adequately and accurately responded to
the NRC's concern.
Accordingly, the allegation was not
substantiated.
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7.
Pipe Support Modifications
Modifications to pipe supports resulting from design reviews by Stone &
Webster Engineering Corp. were addressed during this inspection.
Specific
attributes covered included control of design changes, work traveler
generation, and adequacy of modification implementation.
Pipe supports-
were evaluated to identify any probable potential for shifting or moving
into a position other than the position assumed in the piping stress
analysis.
Supports found to exhibit such probable potential behavior are
by procedure, either removed or modified to eliminate the probable
potential instability.
Definitions, examples, and corrective action for
identified supports are provided in Procedure CPPP-7, Revision 1,
Attachment 4-9, " Procedure for Identification and Correcting of Potential
Unstable Configurations." This procedure along with TUGC0 Nuclear
Engineering (TNE) Instructions TNE-AD-4-5, Revision 1, " Control of Unit 1
Pipe Support Drawings," and TNE-DC-21-1, Revision 1, " Preparation of Field
Design Changes for Pipe Support (s)," were reviewed by the NRC inspector.
The TNE instructions reviewed provide the programmatic control of design
changes for Units 1 and 2, respectively.
The NRC inspector verified that
all pipe support modifications are required to be reviewed by the
responsible pipe support engineer against the design information provided
in the pipe stress analysis to assure that the modifications do not affect
the original pipe stress analysis inputs.
This requirement is contained
in Project Procedure CPPP-9, Revision 1, " Pipe Stress / Support As-Built
Procedure."
The NRC inspector selected the following design change packages (DCPs) for
inspection of implementation of the reviewed programmatic requirements:
DCP NO.
SUPPORT NO.85-065
CT-1-039-008-C42R
85-122
CC-1-226-004-C53R
85-011
SI-1-102-007-041R-
85-047
CC-1-211-003-C53R
85-043
SW-1-129-736-A43R
85-038
FW-1-D17-707-C72K
85-048
CC-1-217-012-C53S85-107
CC-1-234-016-C53R
85-009
MS-1-SB-056-003-3
85-022
CC-1-204-003-C53R
The design calculations for DCPs85-011 and 85-047.were reviewed.~ The
work orders, travelers, inspection reports, material identification-log,
weld filler material log, and multiple weld data cards were reviewed for
items85-065 and 85-122. With the exception of DCPs85-011 and 85 047,
all'DCPs listed were inspected to verify that the supports subject to
engineering modifications were identified on the revisions to the pipe
support drawings.
,
'
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The following supports were addressed in Unit 2 for verification of
conformance to the design change control requirements:
a.
CT-2-053-402-C625
b.
CT-2-053-444-C62K
c.
FW-2-096-435-C62R
d.
CC-X-908-703-E23K
c.
CC-X-909-703-E23R
The design calculations for items b and c above were reviewed.
The
inspection reports, multiple weld data cards, and weld filler material log
for all items were reviewed.
Items d and e above were inspected as
installed to verify conformance to the engineering drawings and QC
inspection reports.
The results of the inspection performed by the NRC inspector indicated
correct implementation of the programmatic design control requirements and
conformance with applicable design criteria.
No NRC violations or deviations were identified.
8.
CPRT ISAPs (Excluding ISAP No. VII.c)
a.
Electrical
(1) Heat Shrinkable Cable Insulation Sleeves (ISAP No. I . a.1)
This ISAP arose from the NRC Technical Review Team (TRT)
identification that craft and inspection personnel lacked
familiarity with procedural requirements governing the
installation, inspection, and documentation of heat shrinkable
cable insulation sleeves.
To correct this situation and assess
plant status, the ISAP identified the following activities:
Activity
ISAP
NRC
Paragraph No.
Reference No.
Revise Construction Procedure EEI-8
4.1.1
01.a.01.01
EEI-8
Revise Inspection Procedure
4.1.1
01.a.01.02
QI-QP-11.3-28
Revise Inspection Forms
4.1.1
01.a.01.03
Train Craft Personnel
4.1.1
01.a.01.04
Train / Certify Inspection
4.1.1
01.a.01.05
Personnel
Identify Required Sleeve Locations
4.1.2.1
01.a.01.06
Establish Sampling Plan / Select
4.1.2.2
01.a.01.07
Review Inspection Reports (I.R.s)
4.1.2.2
01.a.01.09
Visual Hardware Inspection
4.1.2.2
01.a 01.10
Inspection 7 Cables /26 Equip.
4.1.3
01.a.01.11
Items
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_
Review I.R.s for 7 Cables /26 Equip.
4.1.3
,'
01.a.01.12
Issue Non-Conformance Reports
4.1.4-
'01.a.01.08
Establish Root Causes/ Implications /
4.1.4
01.a.01.13
~ Safety
Identify Corrective Action
4.1.4.
01.a.01.14
,
The above identified activities have reportedly been completed
by CPRT.
However, the final results report has not yet"been
,
issued and assembly and review of-the working files have not yet
been completed.
,
Final NRC evaluation of the activities will ~be-initiated upon -
CPRT completion and review of.the working files for this. ISAP
and issue of the results report.
,
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(2)
Inspection Reports on Butt Splices (ISAP No. I.a.2)
The applicant's response to the TRT inspections nd evaluation
of butt-splice installations is contained in ISAP Nos. I'.a.2 and
I.a.3.
The TRT's inspection findings evaluation and required
applicant actions are specified in NUREG-0797, Supplement.No. 7,
pages J-28 through J-31.
The scope of ISAP No.I.a.2 includes all butt-spliced Class IE
essantial and associated cables which are spliced with the AMP
preeinsulated butt-splice connectors.
This ISAP is divided into
three phases, with the objectives being to assure that the
splices are identified on drawings and are properly installed.
The program proposed by the applicant in response to the TRT
concerns requires the following activities to be performed:
IdAP
NRC
Activity
Paragraph No.
Reference No.
Phase I
Review Inspection Reports
4.1.1
01.a.02.01
on Butt Splices
Phase II
Drawings and Design Change
4.1.2
01.a.02.02
Reviews
Inspection of Cables for
4.1.2
01.a.02.03
As-Built Condition
Doc. Review of I.R.s for
4.1.2
01.a.02.04
Cables Inspected in
01.a.02.03
Revise Drawings to Match
4.1.2
01.a.02.05
As-Found Condition
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Replacement of Rejected
4.1.2
01.a.02.06
Splices
Pullout Test and Radiograph
4.1.2
01.a 02.07
Replaced Splices
Inspection of Cabinets
4.1.2
'
01.a.02.08
'
Which Contain No Spliced
Cables
Inspection of Adjacent
4.1.2
01.a.02.09
Splices in Same Wire
Bundle
Phase III
Ident. of Spliced Cables
4.1.3
01.a.02.10
not Inspected in
01.a.02.03
Inspecticn of Cables
4.1.3
01.a.02.11
s
Identified in 01.a.02.10
NCRs Issued for Cables
4.1.3
01.a.02.12
Identified in 01.a.02.10
CPRT Overview of TUGC0 Insp.
4.1.3
01.a.02.13
Performed for 01.a.02.11
General
Root Cause and Corrective
4.1.4
01.a.02.14
Action
Training of Third Party
4.3
01.a.02.15
Inspectors
Inspectors Certified to
4.3
01.a.02.16
Personnel Meet CPRT Quali-
4.3
01.a.02.17
fications and Objectivity
Requirements
The NRC inspectors have reviewed selected information from the
CPRT working files to assess the status of this ISAP.
The
results of the Phase II inspections were reported in previous
inspection reports, as have the results of those Phase III
inspections witnessed by the NRC inspectors.
Final NRC
inspector evaluation of the above activity items will be
addressed as the actions, and related files, are completed and
upon issue of the results report.
(3) Butt-Solice Qualification (ISAP No. I.a.3)
The objectives of this ISAP are to develop adequate procedures
to assure that continuity checks are performed on all circuits
in which splices are installed and that splices are staggered or
. -
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t
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4
r
' separated.
A review of the qualifications of AMP pre-insulated
environmental seal splices will be made to assure'that it is-
"
. qualified for.its expected service.
The program proposed by the
applicant in response to the TRT concerns requires the.
following:
s
,.
'
ISAP
NRC-
Activity
Paragraph No.
Reference No.
Revise Procedure EEI-8
4.1.1
01.a.03.01
Revise Procedure
4.1.1
01.a.03.02
Q0-QP-11.3-28
Train Crafts to Revised
4.1.2
01~.a.03.03
Procedures
Train and Certify Inspectors
4.1.2
01'a.03.04
.
,
i-
to Revised Procedures
Repair of Adjacent-Splices
4.1.3
01.a.03.05
in Same Wire Bundle
Prepare Data Qualification
4.1.4
.01.a.03.06'
Package
,
Third Party Engineering.
4.1.4
01.a.03.07
Review of Data
"
Qualification Package
Replacement of Unqualified
4.1.4
01.1.03.08
.
Splices
_~
!~
Root Cause and Corrective
4.1.5
01.a.03.09
- -
Action
'
,
'
NRC inspector review of the CPRT working files indicated that
.
revision evaluation is pending the, completion of'the required
'
actions, assembly and review of files, and issuance of the
i
results report.
!
.
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(4) Agreement Between Drawings and Field Terminations (ISAP No. I'.a.4)
'
ThisISAParosefromaTRTinsp'e~ctionof'380 cables,*6Iofwhich
'
I
were not terminated in accordance with. current-drawings.
The.
.
l
-ISAP involves reinspection of essential class,'IE conductors
(-
which interface with the alternate shutdown panel and inc10 des
'
'
the following activities:
!
ISAP'
NRC-
Activity
Paragraph-No.-
. Reference-No.
i.
.
.
'
l
Establish Sampling Plan
4.1.1
01.a.04.01
.
Perform Physical
4.5.1-
01.a.04.02-
l
. Reinspection
Reconcile Differences
4.6
01.a.04.03
i
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t
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.
.
.
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Determine Root Cause and
4.1.2
01.a.04.04
Corrective Action
^
ERC has reportedly completed _the reinspection activities
identified in this ISAP.
Final NRC evaluation is pending completion of the assembly and
review of the working files, and issuance of the results report.
(5) NCRs on Vendor Installed AMP Terminal Luos (ISAP No. I.a.5)
'endor installed AMP ring-torque terminal lugs in the Unit 1
V
6.9 KV switchgear cubicles were bent and/or twisted between the
ring-torque and barrel.
The NCRs which documented the.
conditions were determined by the TRT to be improperly
dispositioned,.in that the. full scope of the identified problems
were not addressed and the "use-as-is" dispositions were not
.
adequately justified.
In order to resolve the TRT concerns, the
-applicant was required to reevaluate and redisposition all NCRs
related to lugs.
,
The program proposed by the applicant, as set forth in
ISAP No. I.a.5, Revision 4, dated January 24, 1986, consists of
.the following activities:
ISAP
NRC-
Activity
Paragraph No.
Reference No.
Disposition of
4.1.1
1.a.05.01
Nonconformance
Vendor Analysis
4.1.2
1.a.05.02
Use of Results
4.1.3
1.a.05.~03
Related Activities
4.1.4
1.a'.05.04
'
The NRC inspector reviewed the CPRT working files"to evaluate
s
the status of these activities.
The results of this review are-
as follows:
(._
Disposition of Non-Conformance (NRC Reference-No.' 1.a.05.01)
,
..
The TUGCo Comanche Peak Project has redispositioned all of'the
original NCRs.on bent and twisted ring-torque terminals
'
.
(NCRs E-84-01066 through E-84-01081).
The redispositio'n,was in'
the form of two revisions to the applicable NCR;.the,first on
January 5, 1985, and the second on May 17, 19857 The'second
.-
revision addressed the use of twisted ring torque terminal ~-lugs
based on an AMP Engineering Evaluation ' Report 'which was attached .
~
to the NCR.
'
,
.
j
ReviewoftheNCRsbytheNRCinspector'confirmedihattheNCRs'
!
had undergone this redispositioning.
CPRT Electrical Review
team approval of the final disposition of'the NCRs had not,
1
however, been completed.
.
,, ,
~._,..y.
,
,_.,,,..-..,.,y-.-..
-
--
,_-,,,,.,-.,,..._,-.,,_~,_,-.,,,e.-
- . ,
,.m,
,,
,.c~
.
-39-
Vendor Analysis (NRC Reference No. 1.a.05.02)
As discussed above, the NRC inspector verified that an
engineering evaluation had been provided by the terminal lug
vendor, AMP.
The CPRT had not, however, as of the end of this
report period, formally accepted the completeness and adequacy
of this evaluation.
(6) Flexible Conduit to Fiexible Conduit Separation (ISAP No. I.b.1)
The separation between certain safety-related and non
safety-related flexible conduits inside control room panels was
not maintained in accordance with design requirements.
In order
to resolve NRC concerns, the applicant was required to correct
each violation of the separation criteria, or demonstrate the
acceptability of the conduit as a barrier.
The program proposed by the applicant to demonstrate the
acceptability of the conduit and its separation consists of the
following 10 activities:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Analysis of Circuits
4.1.1
1.b.01.01
Testing as a Short-Circuit
4.1.2
1.b.01.02
Current Barrier
~
'
Testing as an Overload Barrier 4.1.2
1.b.01.03
Test Procedures for the Above
4.1.2
1.b.01.04
Tests
Third Party Inspections
4.1'.3.2
1.b.01.05
.TUGC0 Inspections
4.1.3.2
1.b.01.06
Revision of Unit 2 Procedures
4.1. 4 -
1.b.01.07
Examinations of Other Panels
4.1.5
1.b. 01.03
'
Correction of Unit 1
- 4.1. 7
1.b.01.09
'
Deficiencies
3
.
.
,
Root Cause Determination
.4.1. 7
1.b.01.010
'
- _.
Analysis of Circuits (NRC Reference No. 1.b.01.01).
.
The analyses to verify that the existin'g separation is. adequate
are being conducted by Gibbs and Hill.
Earlier analyses did not
contain sufficient detail to be considered acceptable'to the
CPRT.
The newer analyses will also include information from the
'
testing program to verify that the Sevicair conduit is an
adequate barrier.
_
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,
Testing as a Short' Circuit Barrier, Testing as an Overload
Barrier, Test Procedures for the Above Tests (NRC Reference
,
'Nos. 1.D.01.02.-l.b.01.04)
-
The physical tests have been conducted as a two part program.
The first-test was designed to determine the adequacy of the
Servicair flexible conduit to provide a path-for a short circuit
'
'
current without damage to cables in adjacent or touching
conduits. 1This test was conducted-in.accordance with
Procedure I.b.1-001, "SERVICA.IR Short Circuit" Test."..Thie second
test was designed to determine the ability,.of the conduit'to act
as an effective barrier between, exposed. cables ^and adjacent or
,
touching conduit.
Procedure I.b.1-001, " Cable /SERVICAIR Heat;
Transfer Test," was written for this test.
The results.of these
-
tests are being evaluated.
-
.
ThirdPartyInspections(NRCReferenceNo.l'.b.01.05)
i
The third party QC inspectors have completed their'inspe'ctions
of the Unit 1 main control boards and two of the common ve'rtical
panels.
A draft tabulation of.these inspection results
'
indicates approximately 265 examples of improper conduit
L
separation or barrier installation.
These findings were
'
transmitted to the applicant for disposition.
Some of the
findings were, however, determined to be invalid by TUCGo
,
personnel, based on reinspections they performed using the
separation criteria being proposed rather than the original
Gibbs and Hill criteria.
l
The other reinspections, required by the applicant due to
revised separation attributes, have been completed, but the
reports have not been reviewed by the CPRT or NRC.
The
,
examination of the other panels for the presence of Servicair
.
conduit was initially completed, but the CPRT identified some
problems with the program which will necessitate some
reinspections.
.
The results of the analyses, test, and reinspections' are to be
-
!
factored into corrective actions.
For Unit 1, the problems
identified are being corrected through NCR dispositioning.
For-
Unit 2, the applicable drawing details were revised by a DCA and
,
the procedures were revised.
Th6 determination of a root cause
i -
and corrective action will be evaluated at the conclusion of the.
program.
,:
(7) Flexible Conduit to Cable Separation (ISAP No. I.b.2)
The separation between the Servicair flexible conduit and
certain safety-related and non safety-related cables inside
{
control room panels was not maintained in accordance with
i-
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7
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_._ . _ .-..-,..._.
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,-
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original design requirements.
The program described in
ISAP I.b.1 incorporates all of the provisions necessary to
resolve this concern; therefore, ne additional requirements are
included in this ISAP.
(NRC Reference No. 1.b.02.01).
(8) Conduit to Cable Tray Separation (ISAP No. I.b.3)~
An analysis of the one-inch separation criteria between rigid
conduits and cable trays, contained in the Gibbs and Hill
electrical erection specifications,.had not been presented to
the NRC.
An analysis substantiating the acceptability of this
criteria is-required to be submitted to the NRC prior..to fuel
load.
As described in Section 4.1 of this ISAP, its objective is to.
substantiate the acceptability of the separation criteria.
Gibbs and Hill is to compile the criteria which,=after CPRT-
review, will be transmitted by the applicant to the NRC.
(NRC
Reference No. 1.b.03.01)
~
A CPRT review of the available information determined that
additional analyses were required.
These additional analyses
-
are being performed by Gibbs and Hill.
(9) Barrier Removal (ISAP Ho. I. b'.4)
The minimum separation of redundant class IE field wiring and
instrumentation was not maintained in accordance with design
requirements.
In order to resolve these TRT concerns, the
applicant was required to take corrective action to ensure that
the required minimum separation is maintained either by distance
'
or by an acceptable barrier.
The program proposed by the
,
applicant, as set forth in ISAP No. I.b.4, Revision 4, dated
January 24, 1986, consists of the following activities:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Rework
4.1.1
1.b.04.01
Maintenance Procedures
4.1.2
1.b.04.02
Revision
Use of Results
4.1.3
1.b.04.03
The NRC inspector reviewed the CPRT working files to determine
the status of these activities.
Rework (NRC Reference No. 1.b.04.01)
NCR E-84-100524 was issued on October 9, 1984, to replace a
separation barrier between redundant electric train cables
within Unit 1 Control Room Panel CB-09.
The barrier was
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-.
-42-
replaced and the NCR was closed on October 19, 1984.
Physical
inspection of CB-09, by the NRC inspector, confirmed that the
barrier material had been' replaced.
Another NCR (E-84-100526) was issued on October 9, 1984, to
. retrain cable AG139390, located in CB-03, to meet the 1-inch
inspection criterion required by drawing 2323-31-1702-02, detail
61C. Work was completed and the NCR was closed October 19,
1984.
NRC inspection of control panel CB-03 confirmed that the field
cable had been retrained and a 1-inch minimum separation was
established.
No other NCRs had been issued.
Maintenance Procedures Revision (NRC Reference No. 1.b.04.02)
The-two procedures identified by the NRC inspector as being
associated with the ISAP activities are:
(1) I&C Maintenance-
Program Procedure No. INC-101, Revision 4, dated July 19, 1985;
and (2) Equipment Qualification Procedure No. MDA-107,
Revision 0, dated December 11, 1985. The first procedure was
revised to specify that maintenance of barriers and train
separation shall require explicit instructions via a
safety-related work order.
The second procedure was newly-
written to address equipment qualification and specifies the
control to be used for separation and fire barriers.
NRC inspector's review of these procedures found them to be
acceptable.
The Review Team Leader (RTL) had not, as.of the end
of this report period, documented the results of the review
team's evaluation of these procedures.
b.
QA/QC
(1) QC Inspection Qualifications (ISAP No.~ I.d.1)
,
,
This ISAP is a response to the -TRT identification of;a' lack of
supportive documentation in the training and certification files
regarding QC inspector qualifications.
Specific activities of
the action plan are delineated in the following t'able:
-
.
.
ISAP
NRC
Activity
Paragraph No.
Reference No.
TUGC0 Audit Group (TAG)
4.1.1.1
1.d.1.01
Review of Non-ASME Files
,
4.1.1.2
1.d.1.02
._
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3
Special Evaluation Team
4.1.2
1.d.1.03
(SET) Evaluation of ASME
and Non ASME Inspector
Qualifications
Phase III Sample Selection
4.1.3
1.d.1.04
and Reinspection
Qualification of Personnel
4.3
1.d.1.05
Evaluation of Results
4.6.3 & 4.6.4
1.d.1.06
TAG (NRC Reference No. 1.d.1.01)
This activity was initially reported in NRC Inspection
Report 50-445/85-13; 50-446/85-09.
The NRC inspector reviewed
the checklist used in the TAG review of non-ASME inspectors and
ascertained that it included the guidelines in ANSI N.45.2.6
(1978); Regulatory Guide 1.58, Revision 1; and TUGCo site
inspection procedures.
The NRC verification that this activity
meets the requirements in paragraph 4.1.1 of this ISAP is
complete.
ERC ASME (NRC Reference No. 1.d.1.02)
This activity is complete except for review of non-ASME
certifications held by ASME inspectors (0 pen Item 445/8513-0-03).
NRC inspection of this activity was previously reported in NRC
Inspection Report 50-445/85-13; 50-446/85-09.
Open
Item 445/8513-0-04 from the same report was written concerning
the adequacy of GED test scores without the accompanying diploma.
These two items remain open.
The requirements derived from ERC review of certifying /
qualifying procedures for ASME inspections were formatted into
matrix form which was used during ERC review of ASME inspector
qualifications.
The matrix parallels the requirements of
ANSI N45.2.6 (1978) and Regulatory Guide 1.58, Revision 1.
The
ERC review was documented in an ERC memo to the I.d.1 file. As
previously reported, the NRC inspector insp.ected'10% of the ERC
review of ASME inspector files.
-
,
NRC inspection of this activity (paragraph 4.1.1.2) is complete
except for Open Items 445/8513-0-03 and 445/8513-0-04.
.
+
.
SET on ASME and Non-ASME (NRC Reference No. 1.d.1.03),
,
NRC inspection of this activity was initially 'eported in NRC
r
Inspection Report 50-445/85-13; 50-446/85-09.
The SET evaluated
ASME and non-ASME inspectors whose qualifications were
questioned by TAG or ERC evaluations.
The SET evaluation was
performed using the criteria in paragraph 4.1.2 and
Attachments 1 and 2 of this ISAP.
Results of the SET review
. _ ,
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,
were documented on certification summary sheets.
The NRC
inspector reviewed 10% of.the complete certification summaries
by comparing the summary data to data in.each inspector's
qualification / certification file.
The NRC. inspector found that
the SET evaluations identified the inspectors whose
,
1
qualifications files did not meet requirements.
TUGCo will'be
contacted to ascertain if additional information is available.
NRC' inspection will continue as additional summary sheets are
completed.
$
_ Phase'III Sample Selection and Reinspection (NRC Reference
No. 1.d.1.04)
E
This activity was initially reported in NRC Inspection
Report 50-445/85-13; 50-446/85-09.
The NRC. inspector witnessed
10% of. Phase III reinspections to. verify that they were
+
conducted in accordance with'the requirements of the ISAP.
An
additional 5% of Phase III reinspections have been independently
verified by the NRC inspector. 'All reinspections were performed
j-
to the original inspection procedure by a Level'.II.TUGCo
inspector with a 100% overview by a-Level II ERC inspector.-
-
Deficiencies were documented on NCRs.
The reinspection samples were prepared by TUGCo.
NRC inspection
^
.
showed that these were the first 90 days of recreatable and
4
is
accessible inspections, with a minimum of 50 inspections.
If
'
50 inspections were not made in.the first 90 days, additional
sequential inspections were added'until 50 inspections or 100%
of the inspector's work was reinspected.
[
ERC personnel reviewed 20% of the inspections designated non-
!. .
recreatable by TUGCo to determine if the' inspections were
i
non-recreatble.
The NRC inspector. duplicated-25% of_the ERC
reviews and found that these inspect. ions _were.not recreatable
due to rework subsequent to the original,. inspection. -
a:
,
,.
.
, r ' -
.ERC reinspections were documented in a matrix approved by an ERC >
Level III inspector.
This matrix documentsithe. inspection
'
. attribute as accessible, recreatable, objective, subjective, and-
-
the acceptability of the attribute per.the' original' inspection ~
requirements.
The definitions of " inaccessible" and "not
recreatable were as given in Appendix B~ of the CPRT Program
Plan and further defined for Phase III of this ISAPiin ERC
l
QI-005.
NRC inspection of this activity will continue as
further Phase-III reinspections are performed.
-
l
Qualifications of Personnel (NRC Reference No'. 1.d.1.05)
The TAG personnel performing the independent assessment of
non-ASME inspectors in Phase I were verified to meet the
!
,
5
9
.
-
, . _ . - .
,
_,. -.
, . _ . . , _ _ _ _ , . _ . _ . _ . _ , _ . - . . . - . _ _ , _ - . - - - . . _ . . _
.
.
~
.
J
g
r.
- . ,
-45-
. "
,
requirements of DQI-QA-2.1, " Qualification of Audit. Personnel,"
during NRC inspection of the Dallas QA audit files.
The ERC personnel performing the review of-ASME inspectors, the
Issue Coordinator, and the RTL were found to meet the
requirements of the CPRT Program Plan by NRC review of their
resumes and objectivity questionnaires.
The same personnel
worked on ISAP Nos. I.d.2 and I.d.3 and met the qualification
requirements for those ISAPs.
-
Third party'and TUGCo inspectors were verified to meet the
requirements of ANSI N45.2.6 and Regulatory Guide 1.58 by review
of the certification files for all inspectors performing
reinspections in Phase III.
- SET personnel were verified-to meet the specific requirements of-
ISAP Nos. I.d.1, I.d.2, and I.d.3 by review of their objectivity
questionnaires and resumes in ERC personnel files. 'All three
members met requirements.
'
NRC inspection of this item is complete. - If additional
- -
personnel are to be utilized,- their qualifications will be
verified'per the CPRT Program Plan.
!
'
(2) Guidelines for Administration of QC Inspection Tests (ISAP No. I.d.2)
This ISAP is in response to the TRT identification of a lack of
guidelines and procedural requirements for testing and
certifying QC inspectors.
Specific activities of the ISAP are
delineated in the following table:
ISAP
NRC
. Activity
Paragraph No.
Reference No.
SET Review of Procedures and
4.1.1
1.d.2.01
I
and Recommended Changes
!
TUEC Evaluation of Recommen-
4.1.2
1.d.2.02
'
datiens and Revision of
Instructions
SET Evaluate Effectiveness of
4.1.3
1.d.2.03
Revisions
Qualifications of Personnel
4.3.
1.d.2.04
l
SET Review of Procedures (NRC Reference No. 1.d.2.01)
The SET is comprised of individuals independent'of the,CPSES
I
inspector / certification progra.a.
Their. qualifications and ^
objectivity were verified by NRC' review of their objectivity-
- i
.
1
L
'
-
_
-46-
questionnaires and resumes from the ERC personnel files.
These
-
documents showed that the qualifications required by the ISAP
were met.
The SET review of training procedurer, was initially reported in
NRC Inspection Report 50-445/85-13; 50-446/85-09.
SET review of Procedures CP-QP-2.1, " Training of Inspection
Personnel," and QI-QP-2.1-23, " Training / Certification Records
Processing," is complete.
The results of the SET review have~
been inspected by the NRC to verify that the review criteria
considered FSAR commitments and the requirements of
paragraph 4.1.1 of this ISAP.
This activity was accomplished by
NRC inspection of-SET's review notes and SET recommendations
transmitted to TUGCo.
NRC inspection of this item is complete.
Evaluation of Recommendations and Revisions of Instructions (NRC
Reference No. 1.d.2.02)
,
The NRC inspector verified through review of available data and
interview of cognizant personnel that the TUGCo review of SET
recommendations has been completed.
Procedures and/or
instructions have been revised to incorporate the SET
reconmendations.
The RTL's agreement with tne adequacy of the
revised procedures has been documented for the initial
recommendations and procedure revisions.
If further SET
recommendations are made, they will be monitored by the NRC
inspector.
Evaluation of the Effectiveness of Procedure Revisions (NRC
Ea ference No. 1. d. 2. 03)-
The NRC inspector reviewed inspector qualification deficiencies
identified by the SET for certifications made since the
procedures for training / certification were revised to
incorporate SET recommendations.
TUGCo response resolved some
of the SET identified deficiencies, but in one case.NRC follow
up resulted in the identification of a violation (445/8518-V-03;
445/8515-V-02) regarding an incorrect discipline Level III
certifying an inspector and failure to record bases for
on-the-job training waivers.
SET monitoring of inspection certificat. ions and recertifications
is planned to continue to provide input for the evaluation of.
effectivity of training / certification procedure revis' ions.
This
monitoring occurs during the SET' Phase III reviews in
ISD No. I.d.1,
NRC inspection of_this activity ccntinues.
(3) Craft Personnel Training (ISAP No. I.d.3)
_.
'
This ISAP, which was originally part of ISAP No. I.d.2, is a
response to the TRT determination that craft perfonnel training
}
-47-
may have been inadequate and needed to be evaluated. Specific
activities of this ISAP are delineated in the following table:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Procedural Review
4.1.2.1
1.d.3.01
Interview Personnel
4.1.2.2
1.d.3.02
Observe Training and Field
4.1.2.3
1.d.3.03
Activities
Recommendations for Improvement
4.1.3
1.d.3.04
Evaluation of Changes
4.2.2.1
1.d.3.05
Qualification of Personnel
4.3
1.d.3.06
Root Cause Determined
4.6
1.d.3.07
from VII.c Results
There was no NRC inspection activity on th,is ISAP during this
report period.
(4) Material Traceability (ISAP No. VII.a.1)
This ISAP is a response to a TRT concern that control of
material traceability had been inadequate and needed to be
evaluated. The specific activities of this ISAP are delineated
in the following table:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Assure Ongoing VII.c Provides
4.1.2.1
7.a.1.01
Input
Evaluate Procedures For
4.1.2.2
7.a.1.02
Material Control
Evaluate Actions Relative to
4.1.2.3
7.a.1.03
1981 ASME Survey
Assure Actions On All
4.1.2.4
7.a.1.04
SER Findings
Assure VII.b.1 and VII.b.3
4.1.2.5
7.a.1.05
Results are Considered
Incorporate Input From VII.c
4.1.2.6
7.a.1.06
Assess Compliance with
4.1.2.7
7.a.1.07
Commitments
There was no NRC inspection activity on this ISAP during this
report period.
(5) Nonconformance and Corrective Action Systems (ISAP No. VII.a.2.)
This ISAP is a response to the TRT identification of
irregularities in the nonconformance and deficiency reporting
i
L
-48-
system.
Specific activities of the action plan are delineated
in the following table:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Identify Systems / Methods for
4.1.1.1
7.a.2.01
Recording Nonconformances
Review Samples of NCR Processing
4.1.1.2
7.a.2.02
Evaluate TRT & SSER Findings
4.1.1.3
7.a.2.03
on NCRs
Report Hardware Concerns and
4.1.1.4
7.a.2.04
Input to CA, etc.
Review CAR Procedures
4.1.2.1.
7.a.2.05
Sample CAR Implementation
4.1.2.2'
7.a.2.06
Review Trend Analysis Vs. FSAR
4.1.2.3
7.a.2.07
Evaluate TRT & SSER Findings
4.1.2.4
7.a.2.08
on CAR and Trending
Report Hardware Concerns and
4.l.2.5
7.a.2.09
'
Input to 55(e) Reporting
Evaluate Reporting Procedures
4.1.3.1
7.a.2.10
Review Implementation of 55(e)
4.1.3.2
.7.a.2.11
..
Reporting
Expand Review if Deficiencies
4.1.3.3
- 7.a.2.12
are Noted
TERA Technical Review of NCRs
4.2.3.1
E7.a.2.13
+
Identification of Site Methods for Recording Nonconformances-
(NRC Reference No. 7.a.2.01)
,
This activity is currently incomplete.
By a search of~
procedures, ERC identified the site methods used for recording
nonconformances.
The procedures searched were the current B&R
construction series (CP-QAM-XXX), current and historical TUGCo
quality series (CP-QP-XXX), and the current B&R quality series
(CP-QAP-XXX).
The NRC inspector reviewed the compiled notes and
data sheets resulting from the ERC review and compared them to
the identified procedures.
The results of the NRC review were
in agreement with the results of the ERC review, in that
proceduralized methods for recording nonconformances were
identified. The methods identified in the ERC search were,
NCRs, field deficiency reports, inspection reports (I.R.s),
receipt I.R.s, weld data cards for supports, and weld data cards
for piping.
Other methods may be identified during
implementation of this ISAP.
Review of NCR Processing (NRC Reference No. 7.a.2.02)
This activity is not complete.
Populations for five methods
identified for recording nonconformances have been defined by-
. - ,
-
_
_
.
.
~
.
-49-
ERC.
The five methods are NCRs, field deficiency reports,
I.R.s, weld data cards for supports, and weld data cards for
piping.
The NCRs for TUGCo and B&R have been divided into six groupings.
These groupings were primarily based on. chronology, but also
separated ASME related NCRs from non-ASME'related NCRs.
The NRC
inspector reviewed the data for division of the NCR population
and for subsequent generation of random samples.
This showed
the NCR groupings and sample selection to be in accordance with
the requirements of paragraph 4.1.1.2 of this ISAP.
This
resulted in samples of 60 NCRs taken from each of the six NCR
groups.
The NRC inspector reviewed the draft results of the ERC review
of the FSAR and TUGCo QA program.
The draft results were
utilized in the development of ERC's checklist for NCR review.
NRC inspection of the checklist found it incorporated QA program
requirements and the attributes listed in paragraph 4.1.1.2 of
this ISAP.
ERC's evaluations of the six NCR groups were inspected by the
NRC duplicating 10% from each of the six groups.
The NRC
inspection results found the ERC evaluation to be satisfactory.
NRC inspection of the remaining nonconformance populations used
to document nonconforming conditions is ongoing and will be
reported in subsequent reports.
Review of CAR Procedures (NRC Reference No. 7.a.2.05)
The NRC inspector inspected ERC's checklist prepared for
evaluation of TUGCo and B&R corrective action procedures.
This
inspection showed that the elements of paragraph 4.1.2.1 of this
ISAP were incorporated in the checklist.
The data sheets
resulting from the ERC evaluation were inspected to verify that
they addressed the elements of the checklist.
This inspection
found the checklist elements had been addressed and that the
data sheets accurately reflected the corrective action
procedures.
ERC's evaluation of the accumulated data will be
inspected when it is complete.
Implementation of Corrective Action System (NRC Reference
No. 7.a.2.06)
The ERC checklist to be used for review of CARS was inspected by
the NRC inspector.
This inspection found the criteria of
paragraph 4.1.221 of this ISAP and data gained from the
nonconformance system review were incorporated"in'the checklist.
.
y--
.w--
,--- - --
,,r-
9
y
-,
i-,
.
-50-
,.
The population of CARS to be evaluated has been identified by
ERC to be all closed TUGCo and B&R CARS. ERC's evaluation of
these CARS is ongoing.
NRC inspection of this activity will be
reported in a subsequent report.
(6) Document Control (ISAP No. VII.a.3.)
This ISAP is a response to TRT concerns over historical problems
in the area of document and record control.
Specific activities
of the ISAP are delineated in the following table:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Identify Other ISAPs
4.1.2.1
7.a.3.01
Verifying Document Control
Evaluate III.d. & VIfTc
4.1.2.2
7.a.3.02
'
Document Control Deficiencies
Determination of Corrective
4.1.2.3
7.a.3.03
Action
Procedure Evaluation
4.5
7.a.3.04
Action on Adverse
4.6
7.a.3.05
Trends / Deficiencies-
,
There was no NRC inspection activity on this ISAP during this
report period.
(7) Audit Program and Auditor Qualification (ISAP No. VII.a.4)
NRC concerns about the adequacy of the TUGCo QA audit program
and qualifications of the QA auditors were described in
NUREG 0797, Supplement No. 11.
ISAP No. VII.a.4 is intended to
evaluate the adequacy of the TUGCo QA auditors and audit
program. Specific activities are delineated in the following
table:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Review All Procedures and
4.1.2.1
7.a.4.01
Program Revisions of Audit
Program
Effectiveness Evaluation Based on
4.1.2.2
7.a.4.02
Implementation Documents
..
._
__.
=
.-
-51-
Resolve Identified Program
4.1.2.3
7.a.4.03
Deficiencies
Evaluate Audition Qualifications
4.1.2.4
7.a.4.04
and Staffing
The results report for this ISAP has been submitted to the
Results Report Review Committee.
The NRC inspector has audited
files of the Dallas QA Audit Group and reviewed documentation in
the ISAP working file.
Implementation of the ISAP was verified
as follows:
Review of Current and Historical Procedures for the QA -
J
,
Audit Program (NRC Reference No. 7.a.4.01)
The issue coordinator for this.ISAP.has completed the review of
the CPSES PSAR/FSAR (Appendix 1A.(N) and 1A(B)),' Chapter 17.1;
TUGCo' Corporate Quality Assurance' Program manual, CPSES Pro' ject
Quality Assurance Plan (Design & Construction); and'Dallis
,
Quality Procedures / Instructions manual.
The review and ,
'
evaluation of these procedures and their revisi6ns~will be
-
.
documented in the results report.
The issue coordinator's
evaluation of the degree to which the written program, conforms
to commitment is based on this review'of. procedures.
For each of the above procedures', the NRC inspector reviewed the
ERC checklists and data sheets.
These are maintained in the
ISAP's working file. This review verified the completeness and
compliance of the issue coordinator's review to the ISAP
requirements.
Specifically, procedural implementation of
Amendment No. 2 of the PSAR and Amendment No. 52 of the FSAR
were verified.
Amendment No. 2 of the PSAR shows TUSI utilizing
the ANSI N45.2 series in the development of the QA program and
plan.
Amendment No. 52 of the FSAR endorses the guidance of
Regulatory Guide 1.144 for scheduling of external audits.
No
further NRC inspection is planned for this item.
(8) Periodic Review of QA Program (ISAP No. VII.a.5)
This ISAP is a response to findings by the TRT and RIV as
reported in NRC Inspection Report 445/8432; 446/8411 that TUGCo
management failed to periodically review the adequacy of their
QA program.
The specific activities of the ISAP are delineated
in the following table:
,
ISAP
NRC
,
Activity
Paragraph No.
Reference No.
Develop Criteria for Assessment
4.1.2.3
7.a.5.01
Evaluate Current Program
4.1.2.4
7.a.5.02
There was no NRC inspection activity on this ISAP during this
report period.
,
_
_ _ . _ _ _ _ - -
-
. - - - .
. -
.
-52-
'
(9) Housekeeping and System Cleanliness (ISAP No. VII.a.7.)
As a result of two issues identified by the TRT, this ISAP was
developed to assess the adequacy of the housekeeping and system
cleanliness programs at CPSES.
The specific activities of the
ISAP are listed in the following table:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Review Results of II.a, V.b & VI.a.
4.1.2.1
7.a.7,01
Review Procedures for Housekeeping
4.1.2.2
7.a.7.02
and Surveillance
Review of Flush and Swipe
4.1.2.3
7.a.7,03
Procedures
Review of Plant Areas
4.1.2.5
7.a.7.04
Review of Documentation on
4.1.2.5
7.a.7.05
Housekeeping
Analysis of All Data
4.1.2.6
7.a.7.06
Review Housekeeping and Surve' sance Procedures
(NRC Reference No. 7.a.7.02)
The NRC inspector reviewed ERC notes and data sheets resulting
from the ERC review of procedures controlling housekeeping,
plant and site surveillances, and system cleanliness.
This data
was compared against the controlling procedures; the
requirements of Criterion XIII of 10 CFR Part 50, Appendix B;
and FSAR requirements to verify the ERC evaluation of procedural
controls.
The ERC evaluation is not final; however, the ERC
data was found to properly reflect the procedural requirements.
Review of Flush Procedures (NRC Reference No. 7.a.7.03)
l
-
The NRC inspector reviewed the notes and data compiled from
'
ERC's revision of flush procedures.
The NRC inspector checked
this information against the applicable procedures and flush
plan documents reviewed including Westinghouse' Specifications
PS 292722 on cleanliness requirements for the NSSS, PS 597760 on
cleanliness maintenance, PS 84351 NL on chloride and fluoride
levels for stainless steel surfaces; Westinghouse startup
Procedure TBX/TCX-SU-1.2.1.10 on post hot functional cleaning of
the reactor coolant system; TUGCo flush plan FP-55-08 on reactor
l
l
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coolant system (Unit 1); and startup Procedure CP-SAP-24 for
component cleanliness levels.
The ERC evaluation is not final,
but this NRC review found the ERC notes and data a're supported
by the procedures referenced.
Review of Plant Areas (NRC Reference No. 7.a.7.04)
Plant surveillances conducted by the site construction
surveillance group were overviewed by ERC. This activity was
initially reported in NRC Inspection Report 50-445/85-14;
50-446/85-11.
NRC inspection is ongoing for ERC reviews of
plant survey documentation.
Qualifications of Personnel
The NRC inspector verified the qualificatians of ERC personnel
performing analyses on evaluations for the ISAP.
The individual
resumes and objectivity questionnaires were reviewed and
evaluated as meeting the requirements of the CPRT Program Plan.
Certified inspectors were not required in the performance of the
ISAP.
Unless additional personnel are utilized, no further NRC
inspection activity is planned in this area.
(10) Fuel Pool Liner Documentation (ISAP No. VII.a.8.)
This ISAP is a response to the TRT identification of
irregularities in fuel pool travelers.
NUREG'0797,
Supplement Nos. 10 and 11, provided additional information on
the adequacy of fuel pool liner welds.
Specific activities of
the ISAP are delineated in the following table:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Identify Inspection & Test
4.1.2.1
7.a.8.01
Requirements From Documentation
Review
Select Sample From All Liner Welds
4.1.2.2
=7.a.8.02
Verify Required and Proper
~ 4.1.2.3
7.a 8.03
Inspection of Sample
j
Identify Inspection and Test Requirements from Document
Reviews (NRC Reference No. 7.a.8.01)
-_
This activity is not complete.
The results of NRC inspection.of
this activity will be documented in a subsequent report.-
s
,
N.
+
-
1.
-54-
Identify Fuel Pool Liner Weld Population and Select a Sample
of Fuel Pool Liner Welds (NRC Reference No. 7.a.08.02)
A list of all spent fuel pool, transfer canal, and cask loading
pit travelers used during erection of the fuel liner and
associated components has been compiled.
Composition of this
list has been verified by the NRC inspector reviewing the list
itself, checking the-traveler files, and interviewing the ERC
personnel responsible for its compilation.
This review showed
that the weld travelers for each of the above parts of the fuel
pool liner were included.
This compilation resulted in a fuel
pool liner population of 2,610 weld travelers.
Each has been
assigned a unique sequential number. A sample of this
population has been selected using the guidance given in
Appendix D of the CPRT Program Plan.
This has been verified
through review of the population list, the random number list,
and the correlation matrix.
For this ISAP, a random list of 300
weld travelers was generated, of which 60 were used.
Verify Required and Proper Inspection of Sample (NRC Reference
No. 7.a.8.03)
The ERC data sheets for each of the 60 weld traveler samples
have been reviewed by the NRC inspector.
Eight of the data
sheets were selected for comparison to the weld packages and
other verification sources against the standards and criteria
defined in paragraph 4.5 of this ISAP.
Specifically, the data
sheets were checked to verify proper recording of weld number,
weld process, welder I.D. and qualification, and inspector 1.0.
and certification. Welder's qualifications were checked by
review of the welder's personnel file.
Inspector's
certifications were checked by review of the inspector's
personnel file.
For the eight selected packages, the NRC
inspector checked a total of 19 welder qualifications and 19
inspector certifications.
The results of the NRC review were in
agreement with those of the ERC review.
The issue coordinator has written DRs for deficiencies in some
of the weld traveler packages, including some where the required
inspections appear not to have been performed.
.
Qualification of Personnel
.
Qualification of personnel for this ISAP was verified for'
objectivity and training.
These were.found to be acceptable by
review of the ERC personnel file and an ERC reply to deviation
445/8511-0-02.
No inspectors requiring certification are
planned to be used for this ISAP.
No further NRC inspection is
planned for this item.
-55-
(11) Onsite Fabrication (ISAP No. VII.b.1.)
This ISAP resulted from several TRT findings of fabrication shop
inadequacies which are identified in NUREG-0797, Suppler, ant
No. 11 and USNRC letter dated January 8, 1985. Specific
activities of this ISAP are delineated in the following table:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Review and Evaluate Procefures
4.1.2.1
7.b.1.01
for Onsite Fabrication
Identify and Select Sample from
4.1.2.2 &
7.b.1.02
ASME and non-ASME Fabrications
4.1.2.3
Review Fabrication Packages
4.1.2.4
7.b.1.03
Hardward Reinspection of
4.1.2.4
7.b.1.04
Fabrication Package Discrepancies
Review Storage and Surveillance
4.1.2.5
7.b.1.05
Procedures and Records for
Adequacy
Review VII.a.1 Deviations for
4.1.2.6
7.b.1.06
Reinspection
Analyze Data for Fabrication
4.1.2.7
7.b.1.07
Compliance
Provide Input to ISAP VII.a.1.
4.1.2.8
7.b.1.08
Notify TUGCo of Hardware Deviations
4.1.2.9
7.b.1.09
Report Programmatic Implications
4.1.2.10
7.b.1.10
and Issues to Other ISAPs
There was no NRC inspection activity on this ISAP during this
report period.
(12) Valve Disassembly (ISAP No. VII.b.2)
The TRT found that installation of certain butt-welded valves in
>
three systems required removal of the valve bonnets and
internals prior to welding to protect temperature-sensitive
i,
parts. The three systems involved were the spent fuel cooling
and cleaning system, the boron recycle system, and the chemical
and volume control system. This installation process was poorly
ccntrolled in that disassembled parts were piled in uncontrolled
-56-
areas, resulting in lost, damaged, or interchanged parts.
This
practice created the potential for interchanging valve bonnets
and internal parts having different pressure and temperature
ratings.
The program proposed by the applicant, as set forth in ISAP
No. VII.b.2, devision 1, dated January 24, 1986,. consists of the
,
following activities:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Identify Population of Valves
4.1.1
07.b.02._01
Which Have Been Disassembled
Develop List of Valves in the
4.'1.1
07.b.02.02
._
Three Systems Identified by the
TRT
.
Review Construction and QC
4.1.2
07.b.02.03'
Procedures to Determine if They
Provide Adequate Controls of
Materials During Disassembly /
Reassembly
Perform an Analysis to Determine
4.1.3
07.b.02.04.
Safety Consequences of Improperly
Assembled Valves
Reinspection of a Sample of the
4.1.4
07.b.02.05
Valves Listed in ISAP Paragraph
No. 4.1.11
Inspection Procedure for Re-
4.1.5
07.b.02.06
inspection of Valves, Identified
in ISAP Paragraph No. 4.1.1,
will be Predicated on Review of
-
Vendor Drawings, Procedures and
Documentation Packages
Preparation of Results Report
07.b.02.07
As of this reporting period, NRC inspection activities for the
items referenced above are as follows:
Identify Population of Valves Which Have Been Disassembled (NRC
Reference No. 07.b.02.01)
Valves which must be disassembled after installation have been
identified by the CPRT.
The identification of these valves has
.
.
-.
. - - - ,
-57-
been reviewed by the NRC inspector.
Refer to NRC Inspection
Report 50-445/85-13; 50-446/85-09.
This activity is complete.
No NRC violations or deviations were identified.
Develop List of Valves in the Three Systems Identified
by the TRT (NRC Reference No. 07.b.02.02)
From the list developed in 07.b.02.01 above, a list of valves in
the spent-fuel cooling and cleaning, boron recycle, and the
chemical and volume control systems that. require disassembly was
developed.
Subsequent NRC review confirmed this list.
Refer'to
NRC Inspection Report 50-445/85-13; 50-446/85-09. This activity
is complete.
.
No NRC violations or deviations were identified.
Reinspection of a Sample of the Valves Listed in ISAP
Paragraph No. 4.1.1 (NRC Reference No. 07.b.02.05)
Two samples of valves consisting of a random sample and an
engineered sample were reinspected by the CPRT.
The two sample'
sizes and selection were in accordance with ERC Procedure
CPP-006.
These two combined samples consist of 101 reinspection
packages.
The NRC inspector verified this. activity by
witnessing eight of the reinspections and performing seven
independent inspections.
Refer to NRC Inspection Reports
50-445/85-11, 50-446/85-06; 50-445/85-13, 50-446/85-09; and
50-445/85-14, 50-446/85-11.
This activity is complete.
No NRC violations or deviations were identified.
Inspection Procedure Predicated on Review of Vendor Drawings,
Procedures, and Documentation Packages in Order to Perform
Reinspections (NRC Reference No. 07.b.02.06)
Prior to the re#iisktctions being pe~rformed, the packages had to
be assembled h c*t r to define reinspection activities. When
the NRC iraps 29r
tnessed or performed inspection activities,
the inspection p.s"4ge was also reviewed for adequacy and
completion.
Refer to NRC Inspection Reports discussed in
07.b.02.05 above. This activity is complete.
No NRC violations or deviations were identified.
No NRC inspection has been performed, to date, in the other
defined activities.
i
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(13)PipeSupportInspections(ISAPNo.VII.b.3)
The TRT conducted a series of inspections encompassing as built
safety-related pipe support installations. These inspections
were of completed systems or components that had been previously
inspected and accepted by applicant QC as meeting the respective
construction and installation requirements. Of the 42 pipe
supports inspected, 37 were randomly selected and 5 originated
from an alleger's list.
Forty-six deficiencies ~were identified
-in the supports inspected. There were six specific deficient
items identified by the TRT that required further evaluation.
The TRT concern is that the items may have a high rate of
.
occurrence throughout plant safety-related systems.
The program proposed by the applicant as set forth in ISAP
No. VII.b.3, Revision 1, dated January 24, 1986, consists of the
-
following activities:
ISAP
NRC
Activity
Paragraph No. Reference No.
Verify TRT Identified Dis-
4.1.1
07.b.03.01
crepancies
Develop Reinspection Checklists 4.1.1.1
07.b.03.02
for TRT Identified Discrepancies
Prepare Reinspection Packages
4.1.1.2
07.b 03.03
4
Perform Reinspection of Hardware
4.1.1.3
07.b.03.04
Conipare Inspection Results and
4.1.1.4
07.b.03.05
,
l'
Identify Differences
Reinspect Random Sample in
4.1.2
07.b.03.06
i
Accordance with ISAP VII.c.
Identify VII.c. Pipe Support
4.1.2.1
07.b.03.07
Populations Representative of
the TRT Samples
,
Include all Attributes and
4.1.2.2
07.b.03.08
L
Instructions Required to Verify
l
TRT Identified Discrepancies in
!
the VII.c Inspection Checklists
Review VII.c. Inspection Results
4.1.2.3
07.b.03.09
,
l
for Pipe Supports and Identify
l
Valid Discrepancies
!
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-59-
Evaluate Valid Discrepancies for
4.1.3.1
07.b.03.10
Safety Significance in Accordance
with Appendix E of the CPRT
Program Plan
Perform Trend Analysis for all
4.1.3.2
07.b.03.11
Valid Deviations
This Action Plan is to be Conducted
4.1.4
07.b.03.12
in Accordance with Existing
Procedures and Inspectors Are to
be Qualified to Applicable
Procedures and ANSI N45.2.6.
Additional Procedures to be
4.1.4.4
07.b.03.13
Developed as Required.
Determine Root Cause, Generic
4.1.4.5
07.b.03.14
Implications and Programmatic
Concerns for any Construction
Deficiencies and Adverse Trends
As of this reporting period NRC inspection activities are as
follows:
Develop Reinspection Checklists for TRT Identified Discrepancies
(NRC Reference No. 07.b.03.01)
QIs and their reinspection checklists were developed for the
reinspection of TRT identified discrepancies; i.e., QI-059 and
-061 for the TRT 42 pipe supports, and QI-037 and -038 for the
TRT Room 77N pipe supports. This activity is complete.
Prepare Reinspection Packages (NRC Reference No. 07.b.03.03)
The TRT inspection results were utilized in the selection and
preparation of inspection packages in the TRT Room 77N and TRT
42 pipe supports. This activity is complete.
Include All Attributes and Instructions Required to Verify TRT
Identified Discre)ancies in the VII.c. Checklists (NRC
Reference No. 07.).03.08)
All valid attributes relative to the ISAP No. VII.b.3
discrepancies were identified and utilized in the development of
the ISAP VII.c pipe support inspections. The procedures and
checklists are contained in QI-027, QI-028, QI-29, and QI-030.
This activity is complete.
The NRC inspector has performed the following inspections as of
the end of this reporting period:
l
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-60-
(a) Room 77N Pipe Supports
The NRC inspector has reviewed ERC QI-037, Revision 0.
To
date, seven reinspections have been witnessed, of which the
following two occurred during this report period:
Verification
Package No.
Support No.
- System
Unit No.
1-S-PS7N-097
CS-1-158-036-542R
1
1-S-PS7N-080
-CS-1-074-042-542R
1
- CS - Chemical and Volume Control System
No NRC violations or deviations were identified.
(b) TRT Issues - 42 Pipe Supports
The NRC inspector has reviewed ERC QI-058, Revision 0.
To
date, three reinspections have been witnessed, none of
l
which occurred during this report period. Six independent
inspections have been conducted, with the following one
being performed during this report period:
Verification
Package No.
Support No.
- System
Unit No.
_
I-S-PS42-021
CT-1-005-004-S22K
1
- CT - Containment Spray System
The following conditions were identified by the NRC
inspector during this independent inspection. The NRC
inspector observed a broken lockwire on the snubber adapter
assembly. This lockwire was identified as an out-of-scope
observation per the ERC inspector's notes in the inspection
package. Paragraph 6 on page 34 of the Attachment 6.17 to
QI-058 states, "In those cases where attachment bolts
,
,
!-
between forward bracket assembly and snubber assembly are
I
safety wired by the verdor, QCI shall verify the following
conditions exist:
1
Bolts are tight.
2
Lockwire is not damaged.
3
Lockwire is crimped.
Prior to installation, if any (,f the above conditions are
unsatisfactory, the bolts shall be retorqued and the new
lockwire shall be installed."
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Attribute 5.3.1 of the inspection checklist required the
ERC inspector to verify that all threaded fasteners, except
SA-193 and SA-325 bolting materials and Hilti bolts were
provided with locking devices. This attribute was accepted
by the ERC inspector, despite the recorded observation of a
broken lockwire. Acceptance of this attribute is a
deviation (445/8601-D-13).
(14) Hilti Anchor Bolt Installation (ISAP No. VII.b.4)
The TRT inspected Hilti anchor bolt installation on pipe
supports and electrical raceway supports to the requirements of
QI-QP-11.2-1, and identified the following types of deficiencies
during its inspection:
(a) Minimum effective embedment criteria were not met for
certain installed Hilti Kwick bolts.
(b) Anchor bolt torque was not verified.
(c) Hilti bolts were not marked in accordance with procedure
requirements.
(d) Hilti bolt lengths were not verifiable.
(e) Base plate bolt holes violated minimum edge distance.
(f) Hilti bolt skewed more than the allowable 6*.
The program proposed by the applicant, as set forth in ISAP
No. VII.B.4, Revision 1, dated January 24, 1986, consists of the
following activities:
ISAP
NRC
Activity
Paragraph No.
Reference No.
'
Review Specifications / Procedures
4.1.1
07.b.04.01
and Identify Safety-Significant
!
Attributes
l
'
Review Action Plan VII.c to Assure
4.1.2
07.b.04.02
Inclusion of Safety-Significant
Attributes
Review Specifications, Procedures,
4.1.3
07.b.04.03
QC Inspections, and Training
Procedures and Records to
Determine Comonality
Obtain results from Action
4.1.4
07.b.04.04
Plan VII.c Inspections
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- - -
-
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Assure That Sample Size, Chosen
4.1.5
07.b.04.05
from Action Plan VII.c, is
Adequate
Perform Reinspections in Accordance
4.1.6
07.b.04.06
With Action Plan Vii.c
Torque Verification Program
4.1.7
07.b.04.07
Determine Programmatic Implications
4.1.8
07.b.04.08
As of this reporting period, NRC inspections for the activities
referenced above are as follows:
Obtain Results From Action Plan VII.c Inspections (NRC Reference
No. 07.b.04.04)
Reinspection / verification and documentation reviews for populations
contained in ISAP VII.c are currently in process. Results of NRC
inspection activities are contained in NRC Inspection Reports
50-445/85-13, 50-446/85-09; 50-445/85-14, 50-446/85-11; 50-445/85-16,
50-446/85-13; and 50-445/85-18, 50-446/85-15.
There was no NRC inspection activity or other activities in this ISAP
during this report period.
c.
Test Programs (ISAP No. III Series)
There was no followup inspection activity in the Test Programs ISAPs
during this inspection period.
Since most of the inspections in this
area have been completed, it is anticipated that followup inspections
for the Test Programs actions will resume upon issuance of the next
revision of ISAP No. III, which is currently targeted for March 1,
1986.
The current status of followup inspections on Test Programs ISAPs is as
follows:
III.a.1
Hot Functional Testing Data Packages:
Complete with seven
inspection findings and one possible enforcement action.
See NRC Inspection Reports 445/85-11, 85-13, and 85-16.
III.a.2
JTG Approval of Test Data:
Complete. See NRC Inspection
Report 445/85-16.
III.a.3. Technical Specifications for Deferred Tests:
Complete.
See NRC Inspection Report 445/85-16.
III.a.4
Traceability of Test Equipment:
Started, but not yet
documented in an inspection report.
.
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-63-
,
III.b
Conduct of the CILRT: Not started.
III.c
Prerequisite Testing: Not started.
III.d
Preoperational Testing: Completed ISAP III.d.4.1.1.1
through 4.1.2.6 with seven inspection findings including
two deviations. See NRC Inspection Reports 445/85-16 and
445/85-18.
~
None of the final results reports, as approved by the Senior Review
Team (SRT), have been reviewed. Completions listed above are subject to
reinspection upon issuance of a revised ISAP.
d.
' Civil / Structural
(1) Electrical Conduit Supports (ISAP No. I.c)
The TRT examined the nonsafety-related conduit support
installation in selected seismic Category I areas of the plant.
The support installation for nonsafety-related conduits less
than or equal to 2. inches was inconsistent with seismic
requirements and no evidence could be found that substantiated
the adequacy of the installation for nonsafety-related conduit
of any size. According to Regulatory Guide 1.29 and FSAR
Section 3.7B.2.8, the Seismic Category II and non-seismic items
should be designed in such a way that their failure would not
adversely affect the function of safety-related components or
cause injury to plant personnel.
The program proposed by the applicant, as set forth in ISAP
No. I.c, Revision 3, dated January 24, 1986, consists of the
following activities:
(a) Demonstrate That All Nonsafety-Related Conduits and
Supports Satisfy Regulatory and FSAR Provisions:
ISAP
NRC
Activity
Paragraph No. Reference No.
Evaluate Interaction of Train C
4.1.1
01.c.01.00
,
!
Conduit Greater Than 2 Inches in
Diameter in Seismic Cat. I
Buildings with Safety-Related
Conduits
!
!
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__
._ _
_
.
.
.
_ _
__
_
.
.
.
.
-64-
.
(b) Verify Nonsafety-Related Conduit Less Than or Equal To 2
Inches in Diameter Satisfy Applicable Design Requirements
ISAP
NRC
Activity
Paragraph No.
Reference No.
Selection of the Random and
4.1.2.1
01.c.02.00
Engineered Samples of Train C
Conduit with Diameter Less Than
or Equal to 2 Inches
Field Verification of the Samples
4.1.2.2
01.c.03.00
of the Train C Conduit 2 Inches
-
or Less in Diameter Per Procedure
Seismic Analysis and Acceptance
4.1.2.3
01.c.04.00
Criteria of Two Samples
Damage Analysis Where Sample Runs
4.1.2.4
01.c.05.00
are Considered for Interaction
with Safety-Related Targets
Population Acceptance Criteria
4.1.2.5
01.c.06.00
Where Interactions are Evaluated
and Accepted / Rejected
Issuance of Results Report
01.C.07.00
As of this reporting period, inspection activities for the items
referenced above are as follows:
Evaluate Interaction of Train C Conduit Greater Than 2
Inches in Diameter in Seismic Cat. I Building With Safety-
Related Conduit (NRC Reference No. 01.c.01.00)
The CPSES Damage Study Program evaluated all Train C conduit
greater than 2 inches in diameter in seismic Cat I areas. The
CPRT evaluation of the adequacy of this program will be
contained in ISAP II.d. Therefore a separate evaluation of this
conduit is not required in ISAP No. I.c.
Selection of the Random and Engineered Samples of Train C
Conduit With Diameters Less Than or Equal to 2 Inches
(NRC Reference No. 01.c.02.00)
The CPRT has identified 126 conduit runs in the random sample
and 131 conduit runs in the engineered sample. The NRC
inspector has reviewed the procedures for selection of the two
samples to assure compliance with the CPRT program plan.
.
.-
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. - .
. _ _ _ _ _ ___.
-65-
Verification of the two samples has also been completed.
Refer
to NRC Inspection Reports 50-445/85-13, 50-446/85-09;
50-445/85-14, 50-446-85-11.
There was no NRC inspection activity on this ISAP during this
report period.
(2) Reinforcing Steel in the Reactor Cavity (ISAP No. II.a)
This ISAP addresses the documented occurrence of the omission of
some reinforcing steel from a reactor cavity concrete placement
in Unit 1.
The primary objective is to assess the design
adequacy of the as-built condition. The program proposed by the
applicant as set forth in ISAP No. II.a. Revision 3, dated
January 24, 1986, consists of the following activities:
ISAP
NRC
Activity
Paragraph No. Reference No.
Analysis of As-Built Reactor Cavity
4.1
02.a.01.00
Wall
Review Circumstances Leading to
4.1
02.a.02.00
Provision for and Deletion of
Subject Rebar
Review Rebar Omissions Documented in
4.1
02.a.03.00
Project NCRs
Review Sample of Pour Cards for use
4.1
02.a.04.00
of Current Design Documents
Review Engineering Field Interface
4.1
02.a.05.00
of Major Embedments
Review Design Change Procedures and
4.1
02.a.06.00
Their Effectiveness Regarding
Implementation
Review of Results for Generic
4.1
02.a.07.00
Applications
The CPRT has informed the NRC inspector that the actions
committed to by ISAP No.-II.a are essentially complete; however,
an additional commitment has been added. The actual existence
of reinforcement steel will be physically verified in a sample
of locations. The scope and other details of this added
commitment is currently being addressed by CPRT.
.
- - .
_
_ _ _ _ _
.
.
5
-66-
Analysis of As-Built Reactor Cavity Wall (NRC Reference
4
No. 02.a.01.00)
An analysis of the as-built condition of the Unit I reactor
cavity by Gibbs & Hill was previously reviewed by the NRC
inspector (see NRC Report 50-445/85-11;50-446/85-06).
There was no NRC inspection activity on this ISAP during this
report period.
(3) Maintenance of Air Gap Between Concrete Structures (ISAP No. II.c)
"
This ISAP addresses the seismic gap required by the FSAR for
separation of seismic category I buildings to prevent
interaction during a seismic event. The program proposed by the
applicant as set forth in ISAP No. IIc, Revision 3 dated
January 24, 1986, consists of the following activities:
,
ISAP
NRC
Activity
Paragraph No. Reference No.
Reinspect and Assess As-Built
4.1
02.c.01.00
Condition
,
Removal of Debris or Rotofoam
4.1
02.c.02.00
Analyze Final As-Built Condition
4.1
02.c.03.00
Documentation of Final As-Built
4.1
02.c.04.00
Condition
Revision of Engineering Calculations
4.1
02.c.05.00
l
to Reflect Final As-Built Condition
Review Procedures for Gap Maintenance
4.1
02.c.06.00
!
Determine Generic Implications
4.1
02.c.07.00
Assess Sequence of Events Leading to
4.1
02.c.08.00
Existing Condition
.
Evaluate Need to Update the FSAR
4.1
02.c.09.00
Reinspect and Assess As-Built Condition (NRC Reference
- .
No. 02.c.01.00)
1
Inspection of the as-built condition of the double-walled *
building sep6iration gaps is complete.
Debris was located and
l
identified using visual examination, long probes, and remote
i
video cameras. Drawings were prepared showing the location,
,
,
- - _
. .. -
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.--
- - - . .
. - .
-
.-
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-
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_ . .
_
._
_
_
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__ ..
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-67-
l
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identification, and a conservative estimate of the extent of the
debris. Video tapes are also available.
Inspection activities
and results were witnessed and reviewed by Southwest Research
Institute (SWRI), a third-party organization.
Inspection of the single-walled * building separation gaps is
also complete. Debris was located using visual examination and
probes. Remote video cameras were generally not used for
single-walled gap inspection.
Inspection activities and results
were witnessed and reviewed by SWRI.
'
The NRC inspector has independently reinspected a portion of the
double-walled gap between the Fuel and Auxiliary Building (A-F
wall) at elevation 810 foot and has also witnessed and reviewed
inspection of both single and double-walled gaps. This
inspection included review of video taping techniques and
results as well as drawings showing the location of debris.
Removal of Debris or Rotofoam (NRC Reference No. 02.c.02.00)
i
ProtoPower has the general contract for gap cleaning. Most work
to date on double-walled gaps has been concentrated along the
,
j
LA-AF wall between the Fuel and Auxiliary Buildings.
Gap cleaning for this double-walled gap is generally complete
down to elevation 810'6".
Below that level, existing rotofoam
may be left in place if the Gibbs & Hill calculation indicates
that rotofoam is allowed. The rotofoam will be drilled at
intervals below elevation 810'6" to show that no concrete is in
,
~
the gap. Some concrete does exist in the gap above this
3
elevation. This concrete will be removed by EverFab under
subcontract to ProtoPower using diamond impregnated cable.
Double-walled gaps will be completely reinspected using the same
techniques employed for the initial inspection.
,
Cleaning and repairing of single-walled gaps is nearly complete.
Debris has been removed and gaps have been widened to conform
with the Gibbs & Hill analysis.
i
i
The NRC inspector has witnessed the cleaning and repairing of
both single and double-walled gaps on numerous occasions. This
'
includes witnessing the use of various tools for debris removal
and review of the overall' progress.
Analyze Final As-Built Condition (NRC Reference No. 02.c.03.00)
Gibbs & Hill has completed analysis of minimum gap requirements
for single and double-walled gaps including the reactor building
internal to external structure gaps. TERA is reviewing this
analysis for adequacy.
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-68-
Review Procedures for Gap Maintenance (NRC Reference No. 02.c.06.00)
Initially, TUGCo Instruction QI-QP-11.0-3, Revision 6, dated
,
April 22, 1985, entitled, " Concrete or Mortar Placement
Inspection," was used for building gap inspection and
maintenance.
Revision 7 dated October 8, 1985, was issued to
include reactor building (Units 1 and 2) internal structure to
external structure.
Revision 8 of this instruction is scheduled
to be issued by early February 1986 and will extend inspection
down to the base mat.
Previous revisions specify a lowest
applicable elevation for each identified building separation
gap, generally 790 or 810 foot elevation.
The NRC inspector has reviewed these procedures.
No NRC inspections have occurred of other ISAP No. II.c
activities.
No NRC violations or deviations have been identified to date.
- Double and single-walled gaps are defined in ISAP No. II.c as:
Double-walled building separation gaps are separation gaps
between two buildings which have a solid wall (except for
openings from one building to the other) on each building face
for full height of a specific separation gap. Single-walled
building separation gaps are separation gaps between two
buildings in which one building has a solid wall (except for
openings) for full height of a specific gap and the opposite
building provides gap walls only by slab, beam, column, or wall
ends.
(4) Seismic Design of Control Room Ceiling Elements (ISAP No. II.d.)
The primary objective of this ISAP is to assure th'at all
elements of the control room ceiling satisfy, the seismic
interaction provisions of Regulatory Guide 1.29 and FSAR
Section 3.78.2.8.
The control room ceiling has been redesigned
and is currently being replaced.
The program proposed by the applicant, as set forth in ISAP
No. II.d., Revision 3, dated January 24, 1986, consists of.the
following activities:
ISAP
NRC
Activity
Paragraph No.,
Reference No.
Design of New Control Room
4.1.1.1
02.d.01.00
Ceiling Structure and Components
to he Reviewed
L
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Installation of New Control Room
4.1.1.1
02.d.02.00
Ceiling Structure and Components
Review of Process for Evaluating
4.1.1.2
02.d.03.00
'
Potential Seismic Interaction
Damage Study Verification for
4.1.3.2
02.d.04.00
Architectural Features
Review Procedures and Methods
4.1.3.3
02.d.05.00
for Damage Study
Review Criteria and Acceptability
4.1.3.4
02.d.06.00
of Category II Interaction-
Review Criteria for Evaluation
4.1.3.6
02.d.07.00
of Consequences for Interactions
Review Implementation of
4.1.3.7
02.d.08.00
Damage Study
Comparative Damage Assessment
4.1.3.8
02.d.09.00
in Selected Rooms
As of this reporting period, inspection activities for the items
referenced above are as follows:
Design of New Control Room Ceiling Structure and Components
to be Reviewed (NRC Reference No. 02.d.01.00)
Gibbs & Hill, Inc. has completed the seismic design of the new
ceiling structure.
Design requirements are. delineated in
Gibbs & Hill Design Procedure 09.3, " Control Ro'om Ceiling,"
Revision 1.
The NRC inspector reviewed-this procedure and found
it in accordance with NRC Regulatory Guide 1.29, Revision 3,
" Seismic Design Classification"; FSAR Section 3.78.2.8,
" Interaction of Non-category I Structures with Seismic
Category I Structures"; FSAR Section 3.78.3.5, "Use of
Equivalent Static Load Method of Analysis"; and FSAR
Section 3.8.4, "Other Seismic Category I Structures." Results
,
of the third party review of design calculations performed by.
TERA were reviewed during this inspection. ' Answers'and
i
clarifications to questions generated by TERA were. reviewed.
The NRC inspector also reviewed portions of the following Gibbs
l
& Hill calculations:
i
'
Calculation No. SAB-271C, Set 1, " Control Room Ceiling-Secondary
Frame Support (Louvered Panel Supports)"
Calculation No. SAB-171C, Set 2, " Control Room Ceiling
(Stage I-Main Frame Support)"
.
.
-70-
Calculation No. SAB-171C, Set 3, " Control Room
Ceiling-Reevaluation of Concrete Floor at Elevation-854-4"
Calculation No. SAB-171C, Set-4, " Control Room Ceiling (Main
Frame Support)"
Calculation No. DAB-20, Set-1 and Set-2, " Dynamic Analysis of
Control Room Ceiling"
-
Installation of New Control Room Ceiling Structure and
Components (NRC Reference No. 02.d.02.00)
B&R has removed the original ceiling and commenced the
installation of the new ceiling.
The main' structural steel
frame has been installed.
Verification of_the' adequacy of-the
-
installed main structural steel framing was addressed during
this inspection by measuring the as-built Hilti bolt locations' ,
for ceiling support base plates on beams 68,.71,177'and 79.
The
design and installation of the inspected Hilti bolts was found
to be correct and in accordance with the requirements of Gibbs &
Hill Specification 2323-SS-30, Revision 2, " Structural
Embedment" and Brown & Root Procedure 35-1195-CEI-20,
" Installation of Hilti Drilled-In Bolts."
.
,
Quality control inspection and documentation of the Hilti bolt
installation conformed to the requirements'of TUGCo
Procedure CP-QP-11.2, Revision 9, " Inspection of Concrete Anchor
Bolt Installation."
Review of Process For Evaluating Seismic Interaction
(NRC Reference No. 02.d.03.00)
The process for evaluating potential seismic interactions among
components above the new control room ceiling has been reviewed
by the third party.
However, the cognizant engineer and the
results of his evaluation were not available onsite during this
inspection period.
NRC inspections were not performed on other activities
identified above during this report period.
No NRC violations or deviations were identified.
(5) Rebar in the Fuel Handling Building (ISAP No. II.e)
This ISAP addresses the alleged instance of unauthorized cutting
of rebar in the Fuel Handling Building.
The program proposed by
the applicant as set forth in ISAP No. II.e, Revision 3, dated
January 24, 1986, consists of the following activities:
t
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ISAP
NRC
Activity
Paragraph No.
Reference No.
Analysis of As-Built Condition
4.1
02.e.01.00
Assuming Cut Rebar
Review Controls Governing Rebar
4.1
02.e.02.00
Cutting
Review of All Cases Where Rebar
4.1
02.e.03.00
Cutting was Requested
Assess Work of Construction Crew
4.1
02.e.04.00
Review Pipe Supports with Shear Lugs
4.1
02.e.05.00
Installed by Core Drilling
The CPRT has informed the NRC inspector that the actions
committed to by ISAP No. II.e are essentially complete.
Additional rebar cutting requests have been identified delaying
the issuance of the final results report.
.
Analysis of As-Built Condition Assuming Cut Rebar-
(NRC Reference No. 02.e.01.00)
An analysis of the effects of cutting two layers of rebar
associated with the installation of the trolley process aisle
rails in the Fuel Handling Building was completed by Gibbs &
Hill and reviewed by TERA.
Ultrasonic testing was carried out
by SWRI.
These activities were previously reviewed by the NRC
inspector (see NRC Report 50-445/85-11,50-44U85-06).
No NRC inspections have occurred in other ISAP No. II.e
activities,
e.
Mechanical
(1) Inspection for Certain Types of Skewed Welds in_
NF Supports (ISAP No. V.a)
B&R procedures for welds in pipe supports designed to
Subsection NF in Section III of the ASME Code contained no
fillet weld inspection criteria for certain types of skewed
This lack of inspection criteria and lack of
verification of proper inspection procedures is a violation of
ASME Code for NF supports committed to by TUEC in FSAR
Section 5.2.1 and Criterion X7 in Appendix B of 10 CFR 50.
The program proposed by the applicant, as set forth in
Revision 2 of the ISAP, to demonstrate the adequacy of the
corrective actions consists of the following activities:
.___.
_.
-72-
ISAP
NRC
Activity
Paragraph No.
Reference No.
Chronology of Inspection Methods
4.1.1
05.a.01.00
o Develop Chronology of
05.a.01.01
Inspection Methods
o Chronology to Identify
05.a.01.02
Methods, Inspection Documents
Required, Revisions to
Procedures not Superseded by
'
Subsequent Inspection
Inspection Procedures
4.1.2
05.a.02.00
o Review Procedure QI-QAP-
05.a.02.01
11.1-26, -11.1-28 and CP-QAP-
12.1 to Determine if
Inspection Method was Adequate
to Address Unique Aspects of
-
Skewed Weld Dimensional
Configurations.
o Third party to Assess
05.a.02.02
Adequacy.
o Revise Procedures Where
05.a.02.03
Applicable.
o Third party to Evaluate the
05.a.02.04
Physical Significance of any
Procedural Changes
Select Random Sample for Inspection
4.1.3.
05.a.03.00
o Develop Sampling Plan in
Accordance With Appendix I
05.a.03.01
o Perform Sampling Evaluation
-
05.a.03.02
to Determine if Procedural
Ambiguities Resulted in
Undersized Welds
o Perform Analysis to Determine
05.a.03.03
Allowable Stress Levels for
Those Found not to Meet Design
Requirements
o Determine Whether Sample is
05.a.03.04
to be Expanded
,
o Determine Need for Additional
05.a.03.05-
Inspection
Reinspection by Third Party
4.1.4
05.a.04.00
o Inspection Criteria Will be
05.a.04.01
Based on Revised Procedures
Resulting From NRC Reference
No. 05.a.02.00
- - - -
-
-
-
-73-
Use of Results
4.1.5
05.a.05.00
o Assess Root Cause and
05.a.05.01
Generic Implications
o Identify any Physical
05.a.05.02
Modifications and Procedural
Changes Required
o Identify Corrective Actions
05.a.05.03
Required
-Third-Party Will Oversee and
4.1.6
05.a.06.00
Verify the Review Program
As of this reporting period, inspection activities are as follows:
Review Procedure-QI-QAP-11.1-26, -11.1-28, and CP-QAP-12.1 to
Determine if Inspection Method was Adequate to Address Unique
Aspects of Skewed Wold Dimensional Configuration (NRC Reference
No. 05.a.02.01)
These procedures were reviewed and were found to originally not
adequately address type 2 skewed welds.
Refer to NRC Inspection
Report 50-445/85-13; 50-446/85-09.
This activity is complete.
Third Party to Assess Adequacy (NRC Reference No. 05.a.02.02)
Third party assessment of adequacy concluded that revisions
would be required.
Refer to NRC Inspection Report 50-445/85-13;
50-446/85-09.
This activity is complete.
Revise Procedures Where Applicable (NRC Reference No. 05.a.02.03)
It was verified that the procedures were revised to properly
address type 2 skewed welds, including their inspection and
subsequent documentation.
Refer to NRC Inspection Report
50-445/85-13, 50-446/85-09.
This activity is complete.
Reinspection By Third Party (NRC Reference No. 05.a.04.00)
The reinspection of the random sample of 60 NF supports
containing 99 type 2 skewed welds is complete.
Refer to NRC
Inspection Report 50-445/85-13, 50-446/85-09.
NRC witnessed and
independent inspections are complete and are referenced in NRC
Inspection Reports 50-445/85-13, 50-446/85-09; and 50-445/85-14,
50-446/85-11.
This activity is complete.
Inspection Criteria Will be Based on Revised Procedures Resulting
From NRC Reference 05.a.02.00 Activity (NRC Reference 05.a.04.01)
The reinspection effort was performed in accordance within the
revised procedures which resulted from the actions taken in
activity 05.a.02.00.
The NRC inspector verified compliance with
i
_
i
-74-
the inspection procedure requirements.
Refer to NRC Inspection
' Report 50-445/85-11; 50-446/85-06.
This activity is complete.
NRC inspections have not currently been performed in the other
activities.
Open Item 445/8511-0-04 was identified with respect to the
dispositioning of 12 undersize skewed welds documented on NCRs.
With the exception of the previously documented violation
(445/8514-V-03), no other NRC violations or deviations have been
identified.
(2) Improper Shortening of Anchor Bolts in Steam Generator
Upper Lateral Supports (ISAP No. V.b)
The objective of this ISAP is to ensure that the anchor bolts in
the steam generator upper lateral supports meet design
requirements.
Other installations dependent on bolt thread
engagement will be sampled and reinspected.
The program
proposed by the applicant as set forth in ISAP No. V.b,
Revision 2, dated January 24, 1986, consists of the following
activities:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Rework of Unit 1 for Acceptable
4.1.1
05.b.01.00
Thread Engagement
Inspection of Unit 2 for Acceptable
4.1.1
05.b.02.00
Thread Engagement
Examine Bolts, Blind Threaded Holes,
4.1.2
05 b.03.00
and Assembly Dimensional Tolerances
Determine Potential Generic
4.1.3
05.b.04.00
Applicability Through Sample
Reinspection of Two Separate
Populations
..
Inspection of Richmond Inserts'on
4.1.3.1
05.b.04.01
ASME Pipe Supports
,
Inspection of Blind Hole Bolted
4.1.3.2
05.b'.04.02
Connections
-
Identify Root Cause and Generic
4.1.6
05.b.05.00
Implications
-
-.
.
-
F
-75-
Rework of Unit 1 for Acceptable Thread Engagement (NRC
Reference No. 05.b.01.00)
.
Inspection of the thread engagement of anchor bolts in the steam
generator upper lateral supports for Unit 1 is complete.
Further work is waiting the completion of analysis of the upper
lateral supports by Gibbs & Hill (addressed separately under
DSAP 71). . The NRC inspector independently inspected thread
engagement on bolt 1E15 on steam generator No. I and found it to
be acceptable.
Inspection of Richmond Inserts on ASME Pipe Supports
TNRC Reference No. 05.b.04.01)
This population consists of approximately 1800 safety
_
significant pipe supports with Richmond' inserts.' A~ total of 60
pipe supports will be selected'and all Richmond inserts
'
associated with these supports will be reinspected. ' The initial .
review of the population by TERA' revealed error's? Currently,
TUGCo is re-evaluating the population _for accuracy and
completeness.
~
'
Inspection of Blind Hole Bolted Connections (NRC Reference
No. 05.b.04.02)
This population consists of blind hole bolted connections where
thread engagement is an important design attribute.
This
population has been prepared and is currently being reviewed by
TERA.
No NRC inspections have occurred of other ISAP No. V.b
activities.
No NRC violations or deviations have been identified to date.
(3) Design Consideration for Piping Systems Between Seismic
Category I and Non-Seismic Category I Buildings (ISAP No. V.c)
The TRT discovered that piping systems, such as Main Steam,
Auxiliary Steam and Feedwater, are routed from the Electrical
Control Building (seismic Category I) to the Turbine Building
(non-seismic Category I) without any isolation.
To be
acceptable, each seismic Category I piping system should be
isolated fro:n any non-seismic Category I piping system by-
separation, barrier or constraint.
If isolation is not feasible, then the effect on the seismic
Category I piping of the failure in the non seismic Category I
piping must be considered (CPSES FSAR 3.78.3-13.1).
-76-
The objective of this action plan is to assure that piping
systems routed from seismic Category I to non-seismic Category I
buildings meet the FSAR criteria.
This objective.has been
assigned to the Project Piping and Supports Program (PPSP) with
a third party overview by the Design Adequacy Program (DAP).
The program proposed by the applicant, as set forth in
ISAP No. V.c, Revision 2, dated January 24, 1986, consists of
the following activities:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Identification of all Unit 1,
4.1.1
05.c.01.00
2,'nd Common Piping With
a
Seismic /non-Seismic Interface
Review and Discuss Events and
4.1.2
05.c.02.00
Reasons for Auxiliary Steam .
Pipe Situation
Recommendations to PPSP and DAP
4.1. 3 -
05.c.03.00
are to Address Potential
Implications Which Should be
Considered During Implementation
of PPSP/DAP.
Prepare and Issue Results Report
4.1.4
05.c.04.00
As of this reporting period, inspection activities for the items
referenced above are as follows:
Identification of All Unit 1, 2, and Common Piping With
Seismic /Non-Seismic Interface (NRC Reference No. 05.c.01.00)
The CPRT has generated lists identifying all Unit 1, 2, and
common piping with a seismic /non-seismic interface.
The NRC
inspector has reviewed these lists to verify validity and to
assure no pipe lines have been omitted. This activity is
documented in NRC Report 50-445/85-13, 50-446/85-09; and is
considered complete.
There was no NRC inspection activity on this ISAP during this
report period.
(4) Plug Welds (ISAP No. V.d)
The TRT confirmed the existence of uncontrolled repairs to
misdrilled holes in seismic Category I pipe supports, cable tray
supports, and base plates in Units 1 and 2.
-77-
- The program proposed by the applicant, as set forth in
Revision 2 of the ISAP, to demonstrate the adequacy of the
corrective actions consists of the following activities:
ISAP
. NRC
Activity
Paragraph No.
Reference No.
Select two Random Samples
4.1.1.1
05.d.01.00
of ASME Pipe Supports and
Base Plates
Reinspection of ASME Pipe Supports
4.1.1.1
05.d.02.00
and Base Plates
Document, Investigate, and
4.1.1.1
05.d.02.01
Disposition Detected Deficiencies
o Utilize Mockups to Verify
05.d.02.02
and Refine Detection
Techniques
o Select Field Inspectors Based
05.d.02.03
on Performance of Detecting
Mockup Plug Welds
Identify Plug Welds in ASME Pipe
4.1.1.2
05.d.03.00
Supports and Base Plates
o Make Comparison to Prior
05.d.03.01
Inspection to Determine if
Welds Were Authorized and
Documented
Expand Sample Size if one or More
4.1.1.4
05.d.04.00
Unauthorized or Undocumented Welds
are Found in ASME Pipe Supports
or Base Plates
For Detected, Unauthorized or
4.1.1.5
05.d.05.00
Undocumented Plug Welds Found
in ASME Pipe Supports or Base
Plates Determined not to Affect
-
1
'
Quality, Additional Inspection
'
may Be Performed Based on Observed
,
Trends in the Inspection Results'
,
,
Unauthorized and Undocumented
4.1.1.6 *
05.d.06.00
Plug Welds to ASME Pipe Supports
and Base Plates Will be Identified
by NCRs and Modified if Required
QC Inspection and Documentation
4.1.1. 7
05.d.07.00
Procedures to be Reviewed and
Changes Recommended if Required
,
D
-78-
Third-Party to Provide Overviews
4.1.1.8
05.d.08.00
of Reinspection Effort
Cable Tray Support Plug Welds
4.1.2
05.d.09.00
o Sample Inspect Cable Tray
05.d.09.01
Supports the Same as Pipe
Supports and Plates.
o Determine Frequency and
05.d.09.02
Location of Plug Welds.
o Determine Effects of Plug
05.d.09.03
Welds on Quality of Supports.
Authorized Cable Tray Support
4.1.3
05.d.10.00
Plug Welds
o Third party to Review Design
05.d.10.01
Change Authorizations (DCAs)
for Cable Tray Supports
o Third party to Determine
05.d.10.02
Whether Sufficient Basis
Existed for DCAs.
4.1.4
05.d.11.00
Inspections
o Third party to Review
05.d.11.01
Historical Programmatic
Requirements and
Implementation Procedures
for QC Documentation.
o Third party Review to Assess
05.d.11.02
Compliance With QA Program,
Licensing Commitments of FSAR,
and Perform an Evaluation on
any Lessons Learned for Future
Program Modification.
Root Cause and Applicability
4.1.5
05.d.12.00
o Determine Root Cause
05.d.12.01
o Determine Generic Implications
05.d.12.02
Procedures
4.2.1
05.d.13.00
o Develop Inspection Procedure (s)
05.d.13.01
for Cable Tray Supports, Pipe
Supports and Base Plates.
o Train and qualify inspectors
OS.d.13.02
L
f
k
4
-
-
-79-
Existing QC Procedure Criteria
4.2.2
05.d.14.00
for Visual Inspection Will be
Used.
Issuance of Results Report
05.d.15.00
As of this reporting period, inspection activities are as follows:
Select Two Random Samples of ASME Pipe Supports and Base
Plates (NRC Reference No. 05.d.01.00)
NRC inspection identified that the two selected random samples
<
were not exclusively ASME Code,Section III supports and base
plates.
As a result, a deviation was identified and documented
in NRC Inspection Report 50-445/85-13, 50-446/85-09.
Subsequent
to this, additional samples were selected and inspected. This
activity is complete.
Reinspection of ASME Pipe Supports and Base Plates (NRC
Reference No. 05.d.02.00)
The ERC reinspection effort has been completed and is documented
.in NRC Inspection Report 50-445/85-16, 50-446/85-13.
This
activity is complete.
Document, Investigate, and Disposition Detected Deficiencies
(NRC Reference No. 05.d.02.01)
,
!
During the NRC's independent and witnessed inspections, there
were no unauthorized plug welds found.
During a review of ERC
documentation, no evidence of unauthorized plug welds were found
and no deficiencies detected.
This information is referenced in
,
NRC Inspection Reports 50-445/85-11, 50-446/85-06; 50-445/85-13,
50-446/85-09; 50-445/85-14, 50-446/85-11; and 50-445/85-16,
50-446/85-13.
This activity is complete.
4
Utilize Mockups to Verify and Refine' Detection Techniques
s
(NRC Reference No. 05.d.02.02)
~
At the beginning of this reinspection effort, mockups of plug
welds in various types of plate _and structural members were
~,
constructed and utilized to train field inspectors. In~ addition
to mockup training, the inspectors were required to observe
documented field plug welding.
Completion of this activity is
pending the NRC inspector's review of training records ^and
inspector certification.
!
-
.
.
- -
-
-
-
_
..
-80-
Select Field Inspections Based on Performance of Detecting
Mockup Plug Welds (NRC Reference No. 05.d.02.03)
Selection of field inspectors was based on their performance in
detecting a minimum of 75% of plug welds in the mockups.
This
4
activity will be verified by the NRC inspector's review of the
activity listed above.
Identify Plug Welds in ASME Pipe Support and Base Plates
'
>
(NRC Reference No. 05.d.03.00)
Four olug welds were identified in two ASME pipe support base
plate >.
Refer to NRC Inspection Report 50-445/85-13;
50-446/85-09.
Planned NRC inspection of this activity is
complete.
Make Comparison to Prior Inspection Records to Determine
!
if Welds Were Authorized and Documented (NRC Reference
i
No. 05.d.03.01)
A review of prior inspection records was conducted with respect
to the four plug welds that were identified, and it was verified
that these welds were authorized and documented.
Refer to NRC
Inspection Report 50-445/85-13; 50-446/85-09.
Planned NRC
inspection of this activity is complete.
'
Expand Sample Size if one or More Unauthorized or
Undocumented Plug Welds are Found in ASME Pipe Supports
I
or Base Plates (NRC Reference No. 05.d.04.00)
There were no unauthorized or undocumented plug welds found in
.
ASME pipe supports or base plates; therefore, the sample size
was not increased.
Refer to NRC Inspection Report 50-445/85-16,
50-446/85-13.
The NRC inspector considers this activity closed.
For Detected Unauthorized or Undocumented Plug Welds Found
in ASME Pipe Supports or Base Plates Determined not to
Affect Quality, Additional Inspection may be Based on
Observed Trends in the Inspection Results (NRC Reference
No. 05.d.05.00)
There were no unauthorized or undocumented plug welds
identified; therefore, no observable trends were establisted,
thus precluding the need for additional inspections.
Refer to
NRC Inspection Report 50-445/85-16; 50-446/85-13.
The NRC
inspector considers this activity closed.
3
i
}
4
- - - ,
v
.n-
,e-,
-,
e,
rm. - - - - , ---- ---, - - . ,-- ~ - <
n----
-+s-,
--~n--,-----
-.--,,------.-c,
- - - - - - - -
-wn-
n -
-81-
Unauthorized and Undocurnented Plug Welds to ASME Pipe Supports
-
and Base Plates Will be Identified by NCRs and Modified if
Required (NRC Reference No. 05.d.06.00)
No unauthorized and undocumented plug welds to ASME pipe
supports and base plates were identified, thus precluding the
need for NCRs and modifications.
Refer to NRC Inspection Report
50-445/85-16; 50-446/85-13.
The NRC inspector considers this
activity closed.
Cable Tray Support Plug Welds (NRC Reference No. 05.d.09.00)
.
The status of NRC inspection activities is listed below.
Sample Inspect Cable Tray Supports the Same as Pipe
Supports and Plates (NRC Reference No. 05.d.09.01)
To date, all planned NRC inspections have'been completed.
Results_of previous NRC inspections are documented in NRC
'
--
Reports 50-445/85-14, 50-446/85-11; 50-445/85-13, 50-446/85-09;
and 50-445/85-11, 50-446/85-06.
Determine Frequency and Location of Plug Welds (NRC Reference
No. 05.d.09.02)
To date, all planned NRC inspections have been completed.
Results of previous NRC inspections are documented in NRC
Reports 50-445/85-14, 50-446/85-11; 50-445/85-13, 50-446/85-09;
and 50-445/85-11, 50-446/85-06.
Procedures (NRC Refe.ence No. 05.d.13.00)
The status of NRC inspection activities is listed below.
After
the completion of inspections by ERC, the NRC inspector will
perform an assessment of ISAP No. V.d commitment implementation.
Develop Inspection Procedure (s) for Cable Tray Supports,
Pipe Supports, and Base Plates (NRC Reference No. 05.d.13.01)
ERC QI-007 was developed to provide instruction for the
identification and inspection of plug welds in cable tray
supports, pipe supports, and base plates.
Train and Qualify Inspectors (NRC Reference No. 05.d.13.02)
All of the inspectors used for this effort successfully
demonstrated their ability to identify plug welds in the mockup
supports prior to the initiation of the reinspection effort.
The remaining outstanding activities will be inspected during
subsequent reporting periods.
-82-
(5)
Installation of Main Steam Pipes (ISAP No. V.e)
The TRT investigated an allegation that a Unit 1 main steam line
had been installed incorrectly and had been forced into proper
alignment after flushing operations by use of the main polar
crane and come-alongs.
It was also claimed that pipe supports
.
had been modified to maintain the line in its forced position
and vibrations following detachment of the flushing line could
have damaged the main steam line.
Based on its investigation,
the TRT determined that the alleged incident pertained to
restoration of the Unit 1, Loop 1 main steam line to its
initial, correct installation position.
The program proposed by the applicant, as set forth in ISAP
No. V.e. , Revision 2, dated January 24, 1986, consists of
performing a special engineering investigation of the steam line
adjustment, and a generic study of possible damage in other
piping, including the Unit 1, Loop 4 main steam (MS) line.
These two items consist of the following activities:
a)
Engineering Investigation of Steam Line Adjustment
ISAP
NRC
Activity
Paragraph No. Reference No.
Review Procedures for MS Pipe
4.2
05.e.01.00
Erection and Support Placement
Interview Personnel Involved With
4.2
05.e.02.00
Line Adjustment
Evaluate Engineering Significance
4.2
05.e.03.00
of Procedures and Practices
Perform Analytical Evaluation of
4.2
05.e.04.00
Stresses and Support Load Changes
.
Establish Engineering Significance of
4.2
05.e.05.00
Stresses and Support Load Changes
From Previous Step
,
l
Review Existing UT Examinations
4.2
05.e.06.00
and Hydrostatic Tests
Determine the Need for Reinspection
4.2
05.e.07.00
of Portions of MS Line
!
.
,
.
-83-
b)
' Generic Study of Possible Damage to Other Piping
ISAP
NRC
Activity
Paragraph No.
Reference No,
Review Procedures and
4.2
05.e.08.00
Specifications for Pipe
Erection and Support
Placement
Review NCRs and Pipe Deviation
4.2
05.e.09.00
Request Forms (PORFs) nith
Circumstances Similar to
Steam Line
Interview Installation Personnel
4.2
05.e.10.00
~
to Determine 0*her Piping With
Circumstances Similar to Steam
Line
Review all Other Sources of
4.2
05.e.11.00
Residual Stresses to Piping
Systems
Evaluate Engineering Significance
4.2
05.e.12.00
of Other Residual Stresses
Perform Engineering Evaluations
4.2
05.e.13.00
on Other Lines if Required
i
Where Required, Modif" Gibbs &
4.2
05.e.14.00
Hill Specifications and
Procedures to Avoid Similar
Occurrences
.
As of this reporting periou, inspection activities for the items
referenced above are as follows:
,
Review Procedures for MS Pipe Frection and SLpport Placement
- -
(NRC Reference No. 05.e.01.00)
i
Prior to evaluating the MS line ir.ta11ation problem, the
applicable procedures were revieved by R. L. Cloud and ,
Associates (RLCA).
These procedures are contained in the
appendix of the RLCA report.
The NPC. inspector, while reviewing
the RLCA report, has documented the relevar.cy and adegaacy of
those procedures in NRC Inspection Report 50-445/85-11;
50-446/85-06.
,
This activity is now complete.
No NRC violations or deviations were identified.
-r-
Evaluate Engineering Significance of Procedures and Practices
(NRC Reference No. 05.e.03.00)
Evaluate and cite practices, and incorporate the results of the
-review into activity 05.e.04.00.
The NRC inspector's review of
this activity was performed in conjunction with activity
05.e.01.00 and 05.e.04.00 and is documented in NRC Inspection
Report 50-445/85-11; 50-446/85-06.
This activity is .aow complete.
No NRC violations or deviations were identified.
Perform Analytical Evaluation of Stress and Support Load
Changes (NRC Roference No. 05.e.04.00)
The RLCA report documents a comprehensive static analysis of the
Unit 1, Loop 1 MS line lift.
The different loading conditions
included deadweight, lifting condition, disconnect of the
,
temporary line condition, and flushing condition.
These loading
conditions were used in conjunction with various temporary
supporting schemes.
The various analysis parameters were
evaluated and included in the stress analysis, such that the
results represent conservative, worst case, or bounding
i
conditions consistent with the sequence of events.
'
During the NRC inspector's review of the RLCA stress report, an
unresolved item (445/8514-U-13) was identified in October 1985.
The unresolved item was concerned with the following:
1)
While the use of a "come-along" for horizontal adjustment
is mentioned in Section 1.3, " Additional Background," it is
not addressed in the analytical portion of the report.
2)
The 18-inch bypass line is modelled in as a schedule 60
pipe, but drawing FSM-00165 specifies a schedule 40 pipe.
Documentation was not available to substantiate that a
schedule 60 pipe was used.
Even though the schedule 60
piping is conservative as far as stress is' concerned, it
will have some impact on other conclusions made in the
report such as n rtical displacements.
3)
Figure 'i-12 in the analysis does not represent computer
output No. RLCA P142-1-551-018, in that the node numbers do
not correspond.
4)
The NRC TRT identified that sagging occurred during
flushing operations.
RLCA states that sagging occurred
before flushing.
The date of the flushing should be
established.
-85-
Documentation has been produced by the CPRT which:
1)
Shows that 18-inch schedule 60 pipe was purchased for use
on the by pass line (item 2) above)
2)
Narrows down the actual date of flushing of this system to
the beginning of March 1982.
This date.is two months after
the documented polar crane lift date of. Loop 1 (Item 4
above).
The other two portions of the unresolved item (Items 1 and 3))
involve changing or adding statements in Revision 1 cf the RLCA
'
report.
With the exception of following up on the unresolved item, NRC
~
~
inspection of this activity is complete.
,
Additional information is documented in NRC Inspection
a
Report 50-445/85-14; 50-446/85-11.
'
'4
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,
J
No NRC violations or deviations were identified.
Establish Engineering Significance of Stresses and Support ~
Load Changes From Previous Step (NRC Reference No. 05.e.05.00)
The stresses in the MS Unit 1, Loop 1 piping, which was analyzed
in the previous activity, are documented and compared to the
applicable ASME Section III allowables in the RLCA report.
The
stresses are extracted from the appropriate ANSYS computer
output after including the proper stress intensification factor
for elbows and welds.
The maximum stress condition occurred
during a deadweight analysis with temporary supports, and this
stress was 60% of the appropriate ASME Section III allowable
stress.
Support loads were not affected since support hardware
was not attached to the piping at the time of polar crane lift.
NRC inspection of this activity is now complete.
Additional
information is documented in NRC Inspection Report 50-445/85-14;
50-446/85-11.
No NRC violations or deviations were identified.
Review Existing UT Examinations and Hydrostatic Tests for
the Affected Piping on Unit 1, Loop 1 (NRC Reference
No. 05.e.06.00)
The CPRT has reviewed the inspection data for all associated
shop, field, and pre-service inspection welds.
Their review of
hydrostatic test records for Loop 1 showed the hydrostatic test
.-
f
-86-
package to be complete and the results satisfactory.
Subsequent
NRC inspection showed documentation to be complete and
acceptable.
Refer to NRC Inspection Report 50-445/85-18;
50-446/85-15.
No NRC violations or deviations were identified.
Determine the Need for Reinspection of Portions of the Line
That may Have Been Highly Stressed (NRC Reference No. 05.e.07.00)
While the analysis showed no regions of the line to De more than
60% stressed when compared to the appropriate ASME Section III
allowable, CFRT elected to reinspect two regions of the Loop 1
line.
One reinspection was at the field weld (FW-7) in the
region of highest. stress, and the other was at the field weld
(FW-14) connecting the line to the containment penetration.
Radiographic examinations (RTs) were performed to ASME
Section III requirements and compared to the' original, inspection
reports.
The new RTs had satisfactory results.
Two ultrasonic
tests (UTs) were performed and compared to the: original baseline
pre-service inspection performed by Westinghouse Electric.
Corporation.
Both reinspections indicated the' welds are'of
acceptable quality and that the pipe sustained no damage as a.
result of the alignment correction.
,
.
9
Subsequent NRC inspection of the RTs and'UTs verified the CPRT
findings and also verified that the reinspections were performed-
in accordance with approved site _ procedures by NDE personnel
certified to at least Level II requirements of SNT-TC-1A. 'This
information is documented in NRC Inspection Report 50-445/85-18;
50-446/85-15.
No NRC violations or deviations were identified. This activity
is complete.
Review NCRs'and JDRFs With Circumstances Similar to the Steam
Line (NRC RefeTeIwe No. 05.e.09.00)
The CPRT identified 12 NCRs on safety-related piping where
o
fit-up was a problem.and temporary supports may have sagged,
settled, or failed,-or cold springing may have been stated or
implied. :llowever, further review of the 12 NCRs revealed that
the fit-up problem was not related to the above causes or had
cold springing of the line into final alignment occurred.
The NRC inspector's review of these NCRs verified the CPRT
findings.
Review of the PORFs by the CPRT showed that the PDRF was only
used to document acceptance of tolerance deviations, with
_
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-87-
respect to gradients, centerlines, sleeve centerlines, and
clearances.
None of these four categories affect the fit-up of
the piping; therefore, they would not identify circumstances
similar to the main steam line installation. This information
was documented in NRC Inspection Report No. 50-445/85-13;
50-446/85-09.
No NRC violations or deviations were identified.
Specific Additional Samples of Piping Fit-up Will be Chosen
and Specific Engineering Evaluations Performed (NRC Reference
No. 05.e.13.00)
An analytical evaluation of a polar crane lift for Unit 1,
Loop 4 main steam line was performed.
The maximum stress
condition occurred during a deadweight analysis and this stress
was 36% of the appropriate ASME Section III allowable stress.
Reinspection of the line in two locations similar to activity
05.e.07.00 above also occurred with satisfactory results.
NRC inspection of these actions confirmed the CPRT findings.
This activity is complete.
No NRC violations or deviations were identified.
No NRC inspection has been performed in other activities to
cate.
(6) Gap Between Reactor Pressure Vessel Reflective Insulation
and the Biological Shield Wall (ISAP No. VI.a)
This ISAP addresses the adequacy of the testing and analysis
performed to confirm that sufficient air flow is provided in the
annulus between the reactor pressure vessel reflective
insulation and the biological shield wall.
The program proposed
by the applicant as set forth in ISAP No. V1.a Revision 2,
dated January 25, 1986, consists of the following activities:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Verify Cooling Requirements fo'r
4.1.1
06.a.01.00
'
Units 1 and 2 are met
,
,
,
Review Procedures, Programs, etc.
4.1.2
06.a.02.00
'
"
for Effect of Non-Safety Items
on Safety Items
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-88-
Modify Procedures and Programs
4.1.2
06.a.03.00
if Inadequate
Verify Implementation of Programs
4.1.3
06.a.04.00
and Procedures for NonSafety-
Related Items
Program for Identifying Critical
4.1.5
06.a.05.00
Spaces
Inspection of Critical Spaces and
4.1.6
06.a.06.00
QC Inspection Program
Review of Current and Past
4.1.7
06.a.07.00
Housekeeping Methods
No NRC inspection activity has occurred on this ISAP to date.
(7) Polar Crane Shimming (ISAP No. VI.b)
Investigation of the polar crane rail support system by the TRT
identified girders with gaps under the bottom flange that
reduced the bearing surface to less than required, three
rail-to-rail. ground wires broken, two shims partially worked out
from under the rail, two broken Cadwelds, and. conditions
indicating there may still be circumferential movement.
The program proposed by the applicant within Revision 2 dated
January 24, 1986, of the ISAP to demonstrate the adequacy of the
corrective actions consists cf the following activities:
ISAP
NRC
Activity
Paragraph No.
Reference No.
Polar Crane Rail Girders
4.1.2
06.b.01.00
o Inspection of Seat-to-
06.b.01.01
Bracket Connections.
o Third party Review of
06.b.01.02
Findings Assess Safety
Significance Design
Requirements net.
o Third party Review of
-06.b.01.03
Inspection and any Corrective
Action.
e a
Polar Crane Rail Movement
4.1.3
06.b.02.00
o Develop Measurement Program,
06.b.02.01'
'
Execute, and Evaluate.
'
o Determine Cause of Rail
06.b.02.021
'
Movement, Assess Safety
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.
Significance and Recommend
Modifications.
o Gibbs & Hill to Analyze
06.b.02.03
and Design and any Required
Modifications
o~ Third party Review of. Design
06.b.02.04
Rail and Rail Support System
4.1.5.
06.b.03.00
o Inspect Rail and Rail Support
06.b.03.01
System to Identify any Safety
Significant Deviations.
o Prescribe Corrective Action
06.b.03.02
on any Found Deficiencies.
o Third party Verification of
06.b.03.03
-Inspection and Review of
Corrective Action.
Maintenance and Surveillance Programs
4.1.4
06.b.04.00
o Review Existing Maintenance
06.b.04.01
and Surveillance Programs.
o Third party to Recommend any
106.b.04.02
"
Required Changes.
Historical Records
' 4.1.1
06.b.05.00
-o. Review-History'of Crane
u06.b.05.01
<
Support System Construction
and Performance.
o Identify and Categorize Design
06.b.05.02
Requirements in Terms of
Performance or Structural
Function.
As of the reporting period, no NRC inspection activity has
occurred on this ISAP.
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- 9.
CPRT ISAP'No. VII.c
~
a.
Electrical Cable
.
<
Status of CPRT Activity
,
- ERC has completed 81 reinspections and-79, documentation reviews'of..
'
sampled electrical cable as of Janua,ry 31, 1986.
The decrease in the
.
above totals, from those previously reported, was due to the, removal
of some completed samples for evaluation in a new; lighting population
-
and from errors detected in the sample selection. process'es: ~.
,
.-
s. ,
'
Status of NRC Inspection Activity
'[^ "~
,
.
~'
The NRC inspectors have, as of January .31,1986,' witnessed 21'ERC .
'
reinspections, conducted 6 independent inspections and' performed
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-90-
10 documentation reviews of sampled electrical cables.
These totals
remain unchanged from those previously reported.
The requirements for construction testing and startup testing related
to electrical equipment were reviewed by the NRC inspector.
These
requirements are contained in paragraph 6.15 of Gibbs & Hill
Electrical Erection Specification 2323-ES-100, Revision 2, dated
October 15, 1980.
Paragraph 6.15.1(t) of the specification requires
the contractor to perform tests on all cable reels'in accordance with
the manufacturer's recommendations.
The-NRC inspector,was not'able
to locate any documentation which would confirm that these required
tests were performed.
The failure to perform the required tests on cable reels _is an
apparent violation of Criterion V of Appendix B to 10 CFR Part 50
(445/8601-V-14; 446/8601-V-04).
'
'
.
b.
Cable Trays
Status of CPRT Activity
.
- ,
,
,
+.
ERC has completed 91 reinspections~and 84. documentation reviews of
sampled cable. trays as of January 31, 1986.
Status of NRC Inspection Activity
The NRC inspectors have witnessed 11 ERC reinspections, conduc'ted 6
independent inspections, and performed 7. documentation reviews as of
January 31, 1986.
Review of the NRC files and records disclosed that Verification
Package No. I-E-CATY-024 had been incorrectly identified as
I-E-CATY-047 in NRC Inspection Report 50-445/85-11; 50-446/85-06.
The status of the identified open items (50-445/8511-0-09, -10 and
-12) from the inspection of this cable tray is addressed in
paragraph 2 of this Appendix.
The results of the following three independent reinspections of
Unit 1 cable trays, which were conducted by NRC inspectors during
November 1985, were compared to the ERC inspection results during
this report period:
Verification Package No.
Cable Tray No.
Location
I-E-CATY-141
T140AF004
Aux. Bldg.
Hallway
I-E-CATY-174
T12GRBM27
Reactor Bldg.
I-E-CATY-247
T13GCCM62
Cable Spread
Room
No NRC violations or deviations were identified.
-91-
.
c.
Electrical Conduit
Status of CPRT Activity
ERC has completed 72 reinspections and 72 documentation reviews of
sampled electrical conduit as of January 31, 1986.
The decrease in
the above, from previously reported totals, was due to the removal of
some of the sampled conduits from the population because of problems
discovered in the original sample selection process and for
reinspection activities necessitated by redefined inspection
criteria.
,
Status of NRC Inspection Activity
The NRC inspectors have witnessed 14 ERC reinspections, conducted 5
'
independent inspections and performed 15 documentation reviews of
sampled electrical conduit.
Review of the NRC files and records disclosed that three inspections
of Unit 1 electrical conduits had been conducted (one in October and.
two in November 1985) but had not been reported pending comparison of.
inspection findings to the results of the ERC inspections.
The
comparison of results has been completed for two of'the following
conduits:
..
Verification Package No.
Conduit No.
Location
I-E-CDUT-110
C12G06346
Control Bldg.
I-E-CDUT-111
C02012621
Safeguards Bldg'.
I-E-CDUT-113
C13G04051
Room 100
Verification Package No. I-E-CDUT-111 has been reissued to the ERC.
inspectors for another reinspection.
This is an open item pending
NRC inspector review of the ERC reinspection findings
(445/8601-0-15).
-
No NRC violations or deviations were identified.
d.
Electrical Equipment Installation
Status of CPRT Activity
ERC has completed 78 reinspections and 21 documentation reviews of
sampled electrical equipment installations as of January 31, 1986.
Status of NRC Inspection Activity
The NRC~ inspectors have witnessed 11 ERC reinspections, conducted 3
1
independent inspections and performed 10 documentation reviews of
sampled electrical equipment installations as of January 31, 1986.
,
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-92-
The NRC inspector performed an independent inspection of Verification
Package No. I-E-EEIN-015 for ECSA-1-8802A during November 1985 and
compared inspection results to the ERC inspection results during this
report period.
The seal assembly is for valve MOV-8802A which is a
-
safety injection accumulator outlet valve inside the Unit 1 Reactor
Building.
No NRC violations or deviations were identified.
e.
Piping System Bolted Joints / Materials
Status of CPRT Activity
ERC has completed 71 reinspections of piping system bolted
joints / materials out of the total random and engineered sample size
of 73.
In the December reporting period, it was reported that ERC
had completed 73 reinspections.
The reason for the variance in
completed reinspections is because two packages were removed from_the
sample as a result of it being discovered that construction work had
been performed on these flanges subsequent to the initial
reinspection, thus invalidating the reinspections.
Eight valid DRs
have been generated as a result of the above reinspections.
ERC has completed 68 document reviews of these packages with 9 valid
DRs being issued to date.
These are the same numbers that were
reported in the December reporting period.
Status of NRC Inspection Period
To date, the NRC inspector has witnessed eight reinspections,
performed five independent inspections and performed two document-
reviews.
No NCR inspection activity occurred during this reporting
period.
f.
Concrete Placement
Status of CPRT Activity
Reinspection of concrete placement packages is approximately 88%
~
complete with 97 verification packages in:the combined'first and
second samples.
Forty-one valid deviations have been identified
relating primarily to unfilled holes, voids, and debris in the
concrete surface.
Documentation reviews have not'yet been started.
Status of NRC Inspection Activity
,~
The NRC inspector has reviewed ERC QI-043, Revision 1, and witnessed
,
i
15 reinspections representing approximately 15% of the combined first
i
and second samples.
The NRC inspector has also independently
l
inspected six concrete placements. The following ERC reinspection
was witnessed during this report period:
l
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Verification
Concrete
' Package No.
Placement No.
Building
Unit No.
I-S-CONC-087
IRCN-CPC-101-5805-026 Reactor
1
Verification Package No. I-S-CONC-087 involved the reinspection of
the exterior wall of the Unit 1 Reactor Building between the 955' 6"
and 961' 6" elevation, approximately 150 feet above grade level.
The
corresponding interior wall is inaccessible due to the steel
containment liner.
Attribute 2A, size, was verified using the
results of a B&R survey requested by ERC. Attribute 3A, surface
inspection, was verified using an ERC procedure specified in a
Supplemental Inspection Instruction written for this package.
High
power binoculars were used to identify areas of cencern (potential
voids, etc.) in the concrete surface. Two areas with potential voids
were inspected using one-man staging at the elevation of the exterior
wall.
No voids or other deviations were identified.
Comparison of
potential voids, cracks, and other surface defects identified using
the binoculars with the results of actual hands-on inspection in two
areas using the one man staging confirms that the procedure in the
Supplemental Inspection Instruction was adequate. The NRC inspector
witnessed apprcximately 75% of this reinspection.
No NRC violations or deviations were identified.
g.
Small Bore Pipe Supports
Status of CPRT Activity
Reinspection of small bore pipe supports is 100% complete with 76
supports reinspected.
Eighty-five deviations have been issued with
60 valid. deviations identified to date.
These deviations relate
primarily to Hilti bolt embedment, bolt hole spacing and edge
distance in base plates, and pipe clearances.
Documentation review
is also 100% complete with 23 valid deviations identified.
A total
of 31 valid deviations identified during documentation reviews were
listed by ERC in December 1985.
Subsequently, eight deviations
previously identified as valid have been invalidated when additional
documentation was located.
To date, 47 of 33 valid deviations
(combined reinspection and documentation review) have been'e' valuated
by ERC and found to not be safety significant.
Status of NRC Inspection Activity
.
The NRC inspector has reviewed ERC QI-019,? Revision'2, and QI-020,
Revision 0, and witnessed seven reinspections representing
'
approximately 9% of the combined first and second samples.
The NRC
inspector has also independently inspected eight small bore pipe.
supports including the following three s'upports during this report
period:
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Verification
Pipe
Package No.
Support No.
- System
Unit No.
I-S-SBPS-044
CC-1-RB-003-006-3
1
I-S-SBPS-012
MS-1-RB-010A-013-2
MS
'l
I-S-SBPS-037
CH-X-FB-003-021-3
Common
- CC - Component Cooling Water System, CH - Ventilated Chilled Water
4
System, MS - Main Steam System
Verification Package No. I-S-SBPS-037 involved the reinspection of a-
portion of a gang type box frame supporting four small bore pipes'.
The support. selected for this reinspection attaches.to the structure
of support No. CH-X-FB-005-022-3 and has pipe attachment-drawing
No. CP-AA-999 Revision 4.
This-drawing shows pipe clearances only,
with all structural portions shown in phantom.
The other three pipes
in the gang support are assigned separate pipe support numbers in a
similar manner.
Thus the gang support as a whole is assigned a tota 1
1
of five support numbers, one for the. structural framework and four
_
involving pipe clearances only. All attributes on the checklist for
.
Verification Package No. I-S-SBPS-037 with the exception of (1)
identification, (2) location and. orientation, and (3D) clearances had
"NA"-(not applicaole) entered by the ERC engineer.
No material
(structural steel, anchor bolts, U-bolts, snubbers, etc.) or welding
was involved in the reinspection so that few attributes on the
checklist were applicable.
The NRC inspector examined .the 76 ERC verification packages for small
bore pipe supports and identified the following 21 packages in which
insignificant reinspections were performed:
2
--
clearance only, no material
2
clearances and shim only, no structural members
--
.
2
U-bolts only, no structural members
--
1
--
Shear lugs only, no structural members
14
--
Pipe support attachments consisting.of one to three
minor box members, no structural framework.'
_
,
'
Paragraph NF-1110 of Subsection NF'in Section III of the 1974 Edition "
of the ASME Code, entitled " Aspects of Construction Covered by .These
Rule,," defines supports by stating in part.
.
"(b) Nuclear power plant component supports for.which rules'are
specified in this Subsection are those metal supports which
'
are designed to transmit loads from the pressure retaining
barrier of the component to the load carrying building
structure, whether concrete or structural steel . . . ."
i
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_,
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-95-
The above packages are only partial supports by this definition.
Paragraph 4.1 of the CPRT Action Plan for 7.c states, in part, "The
results of the sampling for each population will be evaluated and
utilized to provide significant input into the overall evaluation of
construction adequacy." Verification packages with few attributes
reinspected and addressed on the checklist may not provirie this
significant input. The homogeneity and validity of tha small bore
,
pipe support population is questioned.
This matter is considered
-
unresolved. (445/8601-U-16, 446/8601-U-05).
No NRC violations or deviations were identified.
'
h.
Pipe Whip Restraints
Status of CPRT Activity
ERC has completed 56 reinspections of pipe khip restraints out of the
planned combined random and engineered sample size of- 111.
The
sample size was increased from the December reported sample size of
110 as a result of ERC's identification that, in order to meet the
engineered sample criteria, the sample size must be-increased by 1;
Seventy valid DRs have been identified and issued.
-
,
._
Status of NRC Inspection Activity
To date, the NRC inspector has witnessed five'ERC reinspections and
performed two independent inspections.
There was no NRC inspection
activity performed during this report period.
i
Instrument Pipe / Tube Supports
.
Status of CPRT Activity
ERC has completed 85 reinspections of instrument pipe / tube supports
out of the combined random and engineered sample size of 111.
The
combined sample size was, increased from a previous figure of 102.
After further evaluation of the engineered sample size, it was
determined that nine adaitional packages were required to meet the
sample criteria.
Two-hundred and seventy valid DRs have been
identified and issued by ERC.
4
Status of NRC Inspection Activity
To date, the NRC inspector has witnessed four reinspections and
performed a total of five independent inspections.
There was no NRC
inspection activity during this ' report period.
-
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. _.
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j.
Large Bore Piping Configuration
Status of CPRT Activity-
.
ERC has completed 81 reinspections of large bore piping
configurations out of the planned random and engineered sample size
of 82.
Fifty-one valid DRs have been identified and issued.
Status of NRC Inspection Activity
To date, the NRC inspector has witnessed seven ERC reinspections and
performed three independent inspections.
The following independent
inspections occurred during this inspection period:
Verification
Package No.
Drawing No.
Unit No.
System *
I-M-LBC0-038 ~BRP-CS-1-SB-029
1
'CS
"
I-M-LBCO-103
BRP-RC-1-RB-022
1
-
-RC
I-M-LBC0-144
BRP-CC-1-RB-046
1
CC~
,'-
-
- CS - Chemical and Volume Control System, RC - Reactor Coolant.. System,
CC - Component Cooling Water System
'
,
While performing the independent inspection on. Verification Package
No. I-M-LBCO-038, the following conditions were identified:
(1) A 0.75-inch clearance existed between spool piece.No~.22Q2 on
Drawing BRP-CS-1-SB-060 at a point 12 inches above sleeve No. 3
on the inspected line, yet attribute 1.f in the ERC inspection-
checklist was checked off as being acceptable.
Paragraph
5.2.6.2 in QI-025 requires a minimum 1-inch clearance.
Acceptance of the below minimum clearance is a deviation
(445/8601-0-17).
(2) Attribute 1.e. in the IRC inspection checklist had N/A inserted
by the QA/QC engineer, thus was not inspected.
This attribute
addresses assuring that branch connections are in accordance
with the piping isometric drawing.
The NRC inspector identified
,
the e<istence of a branch connection which should have been
inspected.
The failure to identify the applicability of this attribute is a
deviation (445/8601-D-18).
(3) During the independent inspection performed on Verification
Package No. 1-M-LBC0-144, the following conditions were
identified:
<
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(a) Paragraph 5.1 in Revision i to QI-025 provides for a i
2-inch tolerance with respect to location of piping and
piping system components.
Field survey measurements taken
by B&R on December 6, 1985, as requested by ERC, show the
distance from the end of the containment penetration at
field weld No. 18-A to the working point of the 76 bend,
to be 10 feet 5 7/16 inches.
However, isometric drawing
No. BRP-CC-1-RB-046 shows this distance as 10 feet
8 1/8 inches, which is 11/16 inch in excess of the i 2-inch
,
tolerance.
This attribute (1.d) on the inspection
checklist was accepted by the ERC inspector.
Acceptance of this measurement is a deviation
(445/8601-D-19).
I
(b) Paragraph 5.2.6.3 in Revision 1 to QI-025 require that all
lines with operating temperatures less than 200 F be
installed, such that an air gap exists between the pipe or
pipe insulation, and other objects.
Attribute 1.f. " Piping
Clearances" in the inspection checklist was signed off by
,
the ERC inspector as being acceptable.
However, the NRC
inspector observed a portion of a support in contact with
the inspected line's pipe insulation at approximately
14 feet south of the 76 bend.
This is a deviation (445/8601-0-20).
k.
Mechanical Equipment Installation
Status of CPRT Activity
Reinspection of 46 mechanical equipment installation items from the
combined random and engineered sample of 190 has been completed.
A
total of 35 deviations have been identified, 28 of which have been
reviewed with 21 determined to be valid.
Status of NRC Inspection Activity
The NRC inspector reviewed QI-059 and performed the following
independent inspection'of a motor-driven auxiliary feedwater pump:
Verification
Equipment
Package No.
Tag No.
System *
Unit No.
I-M-MEIN-009
CPI-AFAPMD-01
,AF
1
- AF-Auxiliary Feedwater System
- '
,
No NRC violations or deviations were identified.
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,
-98-
During this inspection, the NRC inspector observed what appeared to
,
be an unacceptable weldment on an adjacent AF system valve, Tag
No. I-FV-2456.
A seismic arrester bracket had been welded over the
raised cast identification letters of the actuator barrel assembly,
resulting in a weld which exhibited incomplete fusion and overall
poor workmanship.
This finding is an unresolved item pending further
NRC review (445/8601-U-21).
1.
Inspection of Non-Pressure Boundary Welds For A
Supplementary Evaluation of Visual Welding Inspection Techniques
Status of CPRT Activity
To date, 23 randomly selected samples of weld joints obtained from
ISAP Nos. 7.b.3, ISAP 7.b.5, and ISAP 7.c have been inspected before
removal of coatings.
The following 12 samples were inspected during
this report period:
Verification
Equipment
Package No.
Tag No.
System * Unit No.
I-S-NPBW-014
FW-1-019-902-C57W
1
I-S-NPBW-050
FW-1-018-901-C57W
1
I-S-NPBW-046
FW-1-102-901-C57W
1
I-S-NPBW-049
FW-1-015-901-557W
1
I-S-NP3W-010
MS-1-001-902-C77W
MS
1
I-S-NPBW-017
MS-1-001-908-C67W
MS
1
I-S-NPBW-004
FW-1-017-908-C77W
1
I-S-NPBW-067
SG-1-852-1J-1AF
Structure
1
I-S-NPBW-055
CB-790-2N-100
Structure
1
I-S-NPBW-005
-1-FI-4695
NI
1
I-S-NPBW-016
1-LS-4795
NI
1
I-S-NPBW-052
1-FT-156
NI
1
- FW - Steam Generator Feedwater System, MS - Main Steam System, and
NI - Nuclear Instrumentation
The following seven weld joints were inspected after
removal of coatings in January:
Verification
Equipment
Package No.
Tag No.
System *
Unit No.
I-S-NPBW-007
D0-1-DG-009A-0043
D0
1
I-S-NPBW-053
CS-1-241-010-A42R
1
I-S-NPBW-048
CS-1-058-701-A42R
1
I-S-NPBW-021
VA-X-005-702-A73R
, Common
I-S-NPBW-030
SI-1-104-001-C42S
1
I-S-NPBW-075
SW-1-007-700-J03S
1
I-S-NPBW-059
MS-1-RB-010A-013-2
MS
1
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Heating, Ventilation, Air Conditioning; SI - Safety-Injection System;
'SW - Service Water System; and MS - Main steam System
A comparison of weld joint inspection results for the coated and
uncoated condition revealed no discrepant conditions.
Status of NRC Inspection Activity
The NRC inspector has witnessed 100% of inspections performed on weld
joints in the coated and uncoated condition.
No NRC violations or deviations were identified.
10.
Exit Interview
An exit interview was conducted February 6, 1986, with the applicant
representatives identified in paragraph 1 of this appendix.
During this
interview, the NRC inspectors summarized the scope and findings of the
inspectbol.
The applicant acknowledged the findings.
.
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