ML20214R963
| ML20214R963 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/22/1987 |
| From: | Barnes I, Ellershaw L, Hale C, Spessard R, Wagner P NRC, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20214R909 | List: |
| References | |
| 50-445-86-31, 50-446-86-25, NUDOCS 8706090070 | |
| Download: ML20214R963 (40) | |
See also: IR 05000445/1986031
Text
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APPENDIX C
NRC COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-445/86-31 Permits: CPPR-126
50-446/86-25 CPPR-127
Dockets: 50-445 Category: A2
50-446
Construction Permit
Expiration Dates:
Unit 1: August 1, 1988
Unit 2: August 1, 1987
Applicant: Texas Utilities Electric Company
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas 75201
Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 & 2
Inspection At: Gle n Rose, Texas
Inspection Conducted: November 1 through December 31, 1986
Inspectors:
_k_
L. E. _1 ershaw,
W
eactor Inspector, Region IV
[DpteAA!77
/
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CPSES Group
(paragraphs 2.a, 2.b, 2.e g, 4.a-1, 5.a and 5.c)
$ S- ~d S/22/P 7
p C. J. HB e, Reactor Inspector, Region IV bate
CPSES Group
(paragraphs 3.c g, 5.b and 6)
?0. 6 ions
E C Wagner, Reactor Inspector, Region IV
5/zz/ey
Date
~
CPSES Group
(paragraphs 2.c-d and 3.a-b)
0706090070 870601
PDH ADOCK 05000445
0 PDR
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Consultants: EG&G - J. Dale (paragraphs 4.d, 4.1 and 5.a)
A. Maughan (paragraphs 2.c and 3.a)
W. Richins (paragraphs 4.e-h)
V. Wenczel (paragraphs 5.b and 6)
Parameter - J. Birmingham (paragraphs 3.c 9)
K. Graham (paragraphs 2.a, 2.e and 4.a-c)
D. Jew (paragraphs 2.b, 2.f g and 5.c)
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. L. S'pe ard, Deputy Director, Di vision of
5)?i/89
Date
Inspection Programs, Office of In'spection
and Enforcement
Approved: 8e #/22/4'7
1. Barnes, Chief, Region IV CPSES Group Date
Inspection Summary
Inspection Conducted November 1 through December 31, 1986 (Report 50-445/86-31;
50-446/86-25)
Areas Inspected: Nonroutine, unannounced inspection of applicant actions on
previous inspection findings, Comanche Peak Response Team (CPRT) issue-specific
action plans (ISAPs), assessment of allegations, and the ERC collective
evaluation program.
Results: Within the four areas inspected, one violation (use of an incorrect
justification for a "use-as-is" disposition of a nonconformance report (NCR),
paragraph 2.e) and two deviations (incorrect deletion of an inspection
attribute from the inspection checklist by an Evaluation Research
Corporation (ERC) inspector, paragraph 4.h; and invalidation of a deviation
report (DR) by ERC engineering using a basis which was not consistent with
ISAP VII.c criteria, paragraph 4.a) were identified.
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DETAILS
1. Persons Contacted ,
Texas Utilities Generating Company (TUGCo)
- R. P. Baker, Regulatory Compliance Manager
- J. L. Barker,. Engineering Assurance Manager
- J. Bencivenga, Unit 1 Issue Coordinator
- T. Braudt, Senior Engineer
T. Brandt, Quality Engineering (QE) Supervisor
R. E. Camp, Project Manager, Unit 1
- W. G. Counsil, Executive Vice President
- R. D. Delano
- P. E. Halstead, Quality Control (QC) Manager
- T. L. Heatherly, Regulatory Compliance Engineer
- J. Krechting, Director of Engineering
- D. McAfee,-Quality Assurance (QA) Manager
- L. D, Nace, Vice President, Engineering & Construction
- D. M. Reynerson, Project Manager, Unit 2
P. Stevens, Manager, Electrical Engineering
J. F. Streeter, Director of QA
- T. G. Tyler, CPRT Program Director
- D. R. Woodlan, Licensing Supervisor
Comanche Peak Response Team (CPRT)
R. T. Bentley, Technical Assistant
J. Mallanda, Electrical Review Team Leader
Brown and Root (B&R)
D. Johnson, Electrical Training Instructor
K. Thrasher, Training Records Supervisor
Evaluation Research Corporation (ERC)
M. Keathley, Lead Electrical QC Inspector
C. Spinks, QC Supervisor
Impell Corporation
P. Passalugo, Equipment Qualification Engineer
Ebasco
M. Strehlow, Site Engineering Manager
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The NRC inspectors also interviewed other CPRT and applicant employees
during this-inspection period.
- Denotes personnel present at the December 9, 1986, exit interview.
- Denotes personnel present at the January 13, 1987, exit interview.
- Denotes personnel present at both of the above exit interviews.
2. Applicant Actions on Previous Inspection Findings
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a. (Closed) Open Item (445/8511-04): As a result of CPRT inspection
activities.-12 ASME pipe supports with undersize Type 2 skewed fillet
welds were identified and documented on NCRs.
The NRC inspector performed a review and assessment of NCR
dispositions, all of which have been designated "Use-As-Is." Results
of the NRC review are as follows:
NCR 85-0155 - The NRC inspector confirmed from review of
Drawing SI-1-914-003-S32A that the nonconforming condition had been
correctly found to be invalid. The drawing denoted that the weld
size requirements were not applicable to the weld in question for the
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identified undersized position.
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NCRs 85-0179, -180, -181, -182, -183, -184, -185, -186, -187, -202,
and -203 - Calculations were performed by TUGCo pipe support
engineering which substantiated compliance with the pipe support
design loading requirements. These calculations were subsequently
reviewed and approved by Operations Results Engineering and QA in
accordance with applicable procedures.
All pipe support design drawings were revised as required to reflect
the "Use-As-Is" dispositions,
i b. (Closed)OpenItem(445/8511-05): DRs identified by the CPRT during
l reinspection of disassembled valves were to be evaluated and the
! programatic and generic implications were to be reviewed. This has
been completed by the CPRT with their findings contained in the
results report. This item is closed.
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c. (Closed) Open Item (445/8514-07): Comparison of ERC and NRC review
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results. The comparison of NRC review findings to the ERC review
findings for ten electrical cable verification packages was discussed
in NRC Inspection Reports 50-445/86-01 and 50-445/86-26. The NRC
inspector reviewed the disposition of the NCR written to resolve the
last portion of this item. The ERC inspector had written
DR R-E-CABLE-035-02 for the failure of an applicant engineer to date
j
! when he. signed an authorization to pull electrical cable through a
cable tray. Subsequent NRC inspector review found no requirement for
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' a date to be affixed to the pull authorization. In addition, both QC
and installation procedures require checking cable trays to ensure
they are properly prepared prior to cable pulling. ,
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d. (Closed) Violation (445/8601-14; 446/8601-04): Failure to test
electrical cable reels. The requirement to perform field tests on
all electrical cable reels in accordance with the manufacturer
recommendations was removed from the electrical erection
specifications by design change authorization (DCA)-24088. The bases
for removing this from the specification was; (1) the testing
performed by the manufacturer prior to shipping and (2) the
additional onsite testing following cable installation. The NRC
inspector reviewed receiving inspection report (RIR)-10477 for a
shipment of electrical cable reels and verified that the manufacturer
performed tests were appropriately documented in the attached test
reports. The NRC inspector will perform further evaluations of these
manufacturer tests as part of the inspections related to the
ISAP VII.a.9 implementation. In addition, the NRC inspector reviewed
DCA 21,624, dated December 10, 1985, which clarified the requirement
to perform continuity and insulation measurement tests on installed
cables prior to terminating the conductors.
e. (Closed) Open Item (445/8602-09): Review of the disposition of
NCR M-85-101128. The subject NCR was issued to resolve ERC DRs which
addressed excessive undercut, excessive reinforcement, and
suitability of weld surface for nondestructive examination (NDE).
The DRs pertaining to excessive undercut had been identified as an
area-of concern by NRR because of potential noncompliance with Code
requirements (ACI-359-Proposed Section III, Division 2 of the ASME
Code). In order to verify implementation of applicant commitments,
the NRC inspector performed a detailed review of the nonconformance
disposition process. Applicant actions, with respect to the NCR
disposition, were evaluated for the time frame of November 1985
through June 1986.
The Revision 0 disposition of the NCR, use-as-is, was evaluated by
TUGCo Nuclear Engineering (TNE) and reviewed by QE. The technical
evaluation stated, " Radiographic Examinations to the welds in
question indicates that, the shapes and dimensions are not impending
[ sic] the NDT evaluation. Undercuts: By comparing the actual to
nominal yield strengths, it is shown that the remaining thickness of
material is within designed requirements (9.4 percent undercut verses
14.3 percent increased strength)."
NRC review of the disposition revealed that radiographic
examination (RT) had not been performed on the specific weld areas
identified by the NCR. Furthermore, a review of ACI-359 identified
that locations documented as having excessive reinforcement were not
in compliance with NDE requirements; i.e., excessive reinforcement is
not permitted in areas that require RT.
. The TUGCo QE supervisor was notified in regard to the absence of
applicable RT film and the NCR was subsequently reopened to revise
the disposition. The QE supervisor identified the following three
reasons for redispositioning the NCR:
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(1) Structural implications were not adequately addressed.
(2) A DCA was required to be issued for use-as-is dispositions.
(3) No RT film existed for nonconforming weld areas.
The failure to provide sufficient engineering technical justification
to establish that the nonconforming characteristics will result in no
adverse conditions and the fact that a design change document was not
issued as required by TNE-AD-5-2 is a violation (445-8631-V-01).
The NRC inspector examined the Revision 1 disposition of the subject
NCR to determine THE compliance with applicable procedural
requirements. As a result of the technical evaluation performed by
the QE group, which included reinspection / verification of field
identified conditions, it was determined that nonconformances do not
actually exist and the NCR was voided. It is apparent the TUGCo did
not verify the actual field conditions when processing the NCR per
Revision 0. The ERC inspector of record concurs with the
determination by QE that the nonconforming conditions identified do
not exist. The NRC inspector determined that the Revision I
disposition was in compliance with applicable procedural
requirements.
f. (0 pen) Unresolved Item (445/8607-28): CPRT did not completely
address all the ramifications that may result from the fact that the
NPV-1 Data Report- for Valves XSF-179 and 1-7046 are not consistent
with the installed bonnets.
Subsequently, all required vendor supplied documentation for the
as-built condition of Valve 1-7046 has been received onsite. This
included corrected copies of the ITT Grinnell heat code
identificatior, sheet correlating the as-installed valve to the NPV-1
Data Report issued to CPSES. The vendor documentation establishes
that the installed valve body / bonnet is as received from the vendor.
NCR M-23175N, Revision 2, dated October 17, 1986, incorporates this
documentation into RIR 1388.
For Valve XSF-179, a new valve bonnet complete with all necessary
documentation, including the NPV-1 Data Report has been ordered. The
old bonnet will be scrapped per Procedure MCP-10, " Storage and
Storage Maintenance of Mechanical and Electrical Equipment." This
replacement will be dispositioned under NCR M-23178, Revision 1.
This item remains open pending disposition of this NCR.
g. (0 pen) Unresolved Item (445/8622-05): Propriety of utilizing the
NIS-2 form to document as-installed components. This pertains to
Valves 1-7046 and XSF-179 addressed in NCRs M-23175N, Revision 1, and
M-23178N, Revision 0. Subsequent to the identification of this
unresolved item, all required vendor supplied documentation for the
as-built condition of Valve 1-7046 was received onsite. This
included corrected copies of the ITT Grinnell heat code
identification sheet correlating the as-installed valve to the NPV-1
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Data Report issued to CPSES. This vendor documentation establishes
that the installed valve body / bonnet is as received from the vendor.
NCR M-23175N, Revision 2, dated October 17, 1986, incorporates this
documentation into RIR 1388.
For Valve XSF-179, a new valve bonnet complete with all necessary
documentation, including the NPV-1 data report has been ordered. The
old bonnet will be scrapped per Procedure MCP-10, " Storage and
Storage Maintenance of Mechanical and Electrical Equipment." This
replacement will be dispositioned under NCR M-23178, Revision 1.
This item remains open pending disposition of the NCR.
3. CPRT ISAPs (excluding VII.c)
a. Heat-Shrinkable Cable Insulation Sleeves (ISAP I.a.1)
Revise Construction Procedure EEI-8 (NRC Reference 01.a.01.01)
The NRC inspector reviewed and made a comparison of the installation
attributes for heat-shrinkable insulation sleeves (HSIs) in
Revisions 4, 5, and 6 of Construction Procedure EEI-8, " Class 1E and
Non-Class 1E Cable Terminations." Revision 6 of Procedure EEI-8,
dated September 23, 1986, was the current revision. All three
revisions contained instructions for craft personnel to read the
manufacturer (Raychem) installation kit instructions prior to
installing HSIs and to install the HSI in accordance with those
instructions. QC hold points for verification and witnessing of the
installation were added in Revision 5.
The NRC inspector also reviewed the Raychem instructions for HSI
installation and compared those instructions to EEI-8, Revision 6; no
requirement differences between the Raychem instructions and EEI-8
were identified.
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The NRC inspector verified that the ISAP Electrical Review Team (ERT)
reviewed the revised EEI-8 and found no deficiencies. The ERT review
was documented in memorandum CPRT-706.
Since the requirements of this activity have been fulfilled, NRC
inspection of this activity is complete.
No violations or deviations were identified.
Revise Inspection Procedure QI-QP-11.3-28 (NRC Reference 01.a.01.02).
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A review and comparison of Inspection Procedure QI-QP-11.3-28,
l Revisions 23 through 30, was performed by the NRC inspector.
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Revision 30 was dated May 21, 1986. The procedure was revised to
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require QC to witness cable preparation, record HSI kit numbers,
j record sleeve numbers, record lot numbers, verify that braided cable
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Jacket material was removed, and verify that a minimum of 2 " of
sleeve was on each side of the conductor splice.
The NRC inspector verified that the ERT reviewed Revision 30 of the
procedure and found no deficiencies. This review was also documented
in memorandum CPRT-706.
Since the requirements of this activity have been fulfilled, NRC
inspection of this activity is complete.
No violations or deviations were identified.
Revise Inspection Forms (NRC Reference 01.a.01.03)
The NRC inspector verified that the inspection forms used with
Procedure QI-QP-11.3-28 had been revised to include specific
sign-offs for HSI attributes. The short form used in the past has
been deleted from the procedure. Based on NRC inspector review of
this procedure and inspection forms, the requirements of this
activity have been fulfilled and NRC inspection of this activity is
complete.
No violations or deviations were identified.
Train Craft Personnel (NRC Reference 01.a.01.04)
The NRC inspector reviewed the lesson plan used for training craft
personnel to Procedure eel-8 and held a discussion with the
instructor. The NRC inspector determined that the lesson plan
included the Raychem installation instructions for HSI. The NRC
inspector, in addition to reviewing the lesson plan, reviewed a
sample of 19 electrical terminators' (craft personnel) training
records to verify that all 19 craftsmen had been trained according to
Revision 6 of eel-8. The NRC inspector verified that the ERT had
also reviewed the craft training records and found no deficiencies.
This review is documented in memoranda CPRT-013 and CPRT-366. Based
on the NRC inspector review of the lesson plan and 19 craft training
records, the requirements of this activity have been fulfilled and
NRC inspection of this activity is complete.
No violations or deviations were identified.
Train / Certify Inspection Personnel _(NRC Reference 01.a 01.05)
_
A review was performed by the NRC inspector of the lesson plan used
for training QC inspectors to Procedure QI-QP-11.3-28. No
deficiencies were identified in the lesson plan. A random sample of
nine QC inspector training records was reviewed by the NRC inspector
for verification of training. Of the nine inspectors, seven had
received appropriate training and were certified to the current
revision of Procedure QI-QP-11.3-28. Two of the inspectors
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transferred to other departments outside of QC. The requirements of
this activity have been fulfilled; therefore, the NRC inspection of
this activity is complete.
No violations or deviations were identified.
Identify Required Sleeve Locations (NRC Reference 01.a.01.06)
The NRC inspector reviewed the CPRT files to determine the methods
used to identify the sleeve locations as required by the action plan.
The sleeve locations for: (1)penetrationassembliesweredetermined
from penetration connection drawings - 1004 penetrations (2) motors
from power distribution system one-line drawings - 293 motors.
(3) electrical devices in a harsh environment from
drawingsforharshenvironments-48 devices,and(physicallayout4)reductionsp
from drawings for probable locations - 14.
The NRC inspector found these methods to acceptably fulfill the
comitments made by the CPRT. The NRC inspection of this activity is
complete.
No violations or deviations were identified.
Issue Nonconfonnance Reports (NRC Poference 01.a.01.08)
The NRC inspector verified that 22 NCRs were issued for the
deviations identified as a result of the document reviews and
inspections performed for this ISAP. These NCRs are listed in CPRT
memorandum CPRT-739 dated November 5, 1986. The NRC inspector
verified that the project NCR files contained all 22 of these NCRs.
The files indicated that 12 were closed 2 were voided and 8 remained
open. The two voided NCRs were reviewed and found to clarify the
surface preparation requirements for bolted connections. Therefore,
the requirements of this activity have been fulfilled and NRC
inspection of this activity is complete.
No violations or deviations were identified.
Review of Inspection Reports (NRC Reference 01.a.01.09)
The NRC inspector verified, through a review of the CPRT files, that
theappropriateinspectionreports(irs)hadbeenreviewedbythe
ERT. The ERT leader signed each of the 47 irs contained in the
ISAP 1.a.1 files. In addition, the ERT review of the irs was
documented in CPRT memorandum CPRT-731 dated November 4, 1986.
The NRC inspector found the above documentation to acceptably fulfill
the CPRT commitment that the ERT review the irs. Therefore, NRC
inspection of this activity is complete.
No violations or deviations were identified.
_ _ _ _ __ - ____ _ ___-__- . _ _ _ _ - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ . _ _-____________ ___ ______ ____.
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Visual Hardware Inspection (NRC Reference OI.a.01.10)
, Eleven cables were identified by CpRT inspectors as requiring visual
- inspection because the irs did not reflect the installation of a HSI.
Five of these cables were found with no sleeve installed and none was i
required; four of the installed sleeves were found to be :
unsatisfactory when inspected and were replaced; all other
installations were acceptable.
The NRC inspector reviewed the irs written for these
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visual inspections, and found that the requirements of this activity
have been fulfilled. NRC inspection of this activity is complete.
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No violations or deviations were identified. ;
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Inspect 7 Cables /26_ Equipment Items (NRC _ Reference 01.a.01.11) l
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The NRC inspector reviewed the irs written for the
- CpRT visual inspections of an additional 7 cables and 26 pieces of l
j equipment that could have had installed reduction splices. No
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reduction splices were found by the CPRT inspectors. Therefore, the
< requirements of this activity have been fulfilled and NRC inspection i
of the activity is complete,
No violations or deviations were identified,
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j Review irs for 7 Cables /26 Equipment _ Items _(NRC Reference _01.a.01.12}
_ !
l Since no reduction splices were found during the visual reinspections !
- of the 7 cables and 26 pieces of equipment, no IR review was i
i required. Therefore, the requirements of this activity have been
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fulfilled and NRC inspection of this activity is complete.
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No violations or deviations were identified.
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j Est_ablish_ Root Causes/ Implications /SafetyJ NRC Reference 01.a 01.13) >
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- This activity will be evaluated after the results report has been
j issued.
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j Identify Corrective Action G RC__ Reference 01.a.01.14) l
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) This activity will be evaluated after the results report has been !
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j b NCR$ on Vendo_r installed _ Amp Terminal Lugs _(! SAP 1,a J l
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The applicant committed to reevaluate and redisposition all NCRs
! which had been written related to vendor-installed terminal lugs in l
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ITE Gould-Brown Bovert switchgear. These actions were to include ;
consideration of twisted as well as bent terminal lug barrels to
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confirm the acceptability of the "use-as-is" dispositions which had
been made for the involved NCRs. The applicant actions and NRC
inspector verification consisted of the following.
Disposition of NCRs (NRC Reference 01.a.05.01)
The NRC inspector determined, by CPRT records review, that all of the
involved NCRs had been redispositioned by the applicant; the details
of this inspection were contained in NRC Inspection
Report 50-445/86-01; 50-446/86-01. During this report period, the
NRC inspector verified that the remaining portion of this activity,
ERT approval of final NCR dispositions, had been completed. The
Review Team Leader (RTL) documented the review of the NCR
dispositions by memorandum CPRT-285 dated March 4, 1986. The ERT
review consisted of a visual examination of the involved terminal
lugs. During the ERT examination, a terminal lug, which was to have
been replaced, was determined to have remained installed. (The RTL
assumed that a lug on the same termination point of an adjacent
terminal board had been replaced in lieu of the required lug.) This
deviation was referred to the QA/QC RTL by memorandum CPRT-290 dated
March 6, 1986, in accordance with the CPRT Program Plan, Appendix B,
for inclusion in the collective evaluations. In addition, the NRC
inspector verified that NCR E86-100831 had been written to replace
the terminal lug in question; this rework had not been accomplished
as of the end of this report period.
Based on the above, the NRC inspector determined that the
requirements of this activity have been fulfilled; therefore, NRC
inspection of this activity is complete.
No violations or deviations were identified.
Vendor Analyh(NRC Reference 01.a.05.02)
The submittal and applicant review of the vendor (AMP, Incorporated)
engineering evaluation were also discussed in NRC Inspection
Report 50-445/86-01; 50-446/86-01. The NRC inspector determined, by
review of a memo in CPRT files, that ERT had reviewed the AMP
engineering evaluation report (EER)-136 and the additional
metallurgical analysis recommended by the RTL. These reports
confirmed the terminal lug qualification provided: (1) bending did
not exceed 90', and/or (2) twisting did not exceed 45*. Confirmation
is contained in memorandum CPRT-468 dated June 3, 1986, that the ERT
reviewed these reports.
Based on the above, the NRC inspector determined that the CPRT
commitments for this activity have been fulfilled; therefore, NRC
inspection of this activity is complete.
No violations or deviations were identified.
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Use of Results (NRC Reference 01.a.05.03)
The ISAP required a root cause and generic implications evaluation if
deficiencies were identified in the "use-as-is" NCR dispositioning.
Since no deficiencies were identified in the NCR dispositioning, this
requirement is moot. However, the NRC inspector verified that the
applicable installation specification (2323-ES-100), craft
installation procedure (eel-8), and QC inspection
procedure (QI-0P-11.3-28) had all been revised to include instruction
that terminal lugs were to be bent no more than 90* and twisted no
more than 45*.
Based on the above, the NRC inspector determined that the
requirements of this activity have been fulfilled; therefore, NRC
inspection of this activity is complete.
No violations or deviations were identified.
Related Activities (NRC Reference 01.a 05.04)
An evaluation of the disposition of the original NCRs and the
additional NCRs related to terminal lugs that were the subject of
memorandum CPP-19,359 dated February 25, 1986, will be included in
ISAP VII.a.2, "Nonconformance and Corrective Action Systems."
Based on these actions, the NRC inspector determined that the
implementation requirements of this ISAP have been fulfilled;
therefore, NRC inspection of this ISAP is complete.
No violations or deviations were identified.
c. Material Traceability (ISAP VII.a.1)
During this report period, the ISAP activities identified by NRC
Reference 07.a.01.02, and 07.a.01.08 were % nected as follows:
Evaluate Procedures for Material Control 04RC Reference 07.a.01.02)
The ERC evaluation of the site procedures for material control was
reviewed by the NRC inspector to verify implementation of ISAP
paragraph 4.1.2.2. The ERC review checklist was inspected and found
to properly include requirements found in Criterion VIII of
10 CFR 50, Appendix B, and the FSAR, Section 17.1.8, " Identification
and Control of Materials, Parts, and Components." NRC inspection of
the completed procedure reviews found them to properly indicate where
the attributes were incorporated. This was accomplished by the NRC
inspector selecting attributes on the review checklist and verifying
that the attributes were in the procedure. The NRC inspector
determined that using the ERC checklist, the resulting evaluations
would provide the necessary input for the analysis of material
control required by ISAP paragraph 4.1.2.7.
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No violations or deviations were identified and no further inspection
is planned for this reference area.
Qualifications of Personnel (NRC Reference 07.a.01.08)
The qualifications of personnel directly involved with gathering or
evaluating data for input to this ISAP were reviewed by the NRC
inspector. The resumes and objectivity questionnaires verified that
the qualifications of ISAP personnel were found to be in accordance
with the requirements of the CPRT Program Plan.
No violations or deviations were found during inspection of this -
activity.
d. Nonconformance and Corrective Action System (ISAP VII.a.2)
During this report period, the ERC VII.a.2 review team added
evaluation of the TNE Design Deficiency Reports (TDDRs) and the
system controlling their issue to the VII.a.2 ISAP. This activity
will be added to the table of activities reported in NRC Inspection
Report 50-445/86-01; 50-446/86-01 as follows:
Activity ISAP NRC
Paragraph Reference
Evaluation of the 4.1.4 07.a.02.14
TODR System
Implementation of this activity (evaluation of the TDDR system) was
inspected by the NRC as follows:
The NRC inspector reviewed the evaluation data sheets developed by
the VII.a.2 review team to perform their review of the TODR system.
The NRC inspection of the evaluation data sheets was performed to
determine if the requirements of Criteria III and XVI of 10 CFR
Part 50, Appendix B; CPSES FSAR, Section 17.1.2.3 and
Section 17.1.2.16, Amendment 55 (Regulatory Guide 1.28 and 1.64); and
TUGCo Procedure TNE-AD-5, all revisions, " Identification of Design
Deficiencies and Errors," were properly incorporated. The NRC
inspector found that the ERC evaluation data sheets included the
regulatory requirements of identifying the nonconformance, evaluating
the nonconformance for reportability, prescribing
corrective / preventive action, and assuring implementation of
corrective / preventive action.
The NRC inspector reviewed the methods that the VII.a.2 review team
used to identify the population of TDDRs and to generate a random
sample of 60 TDDRs. The methods were found to conform to the
'
requirement of the ISAP, paragraph 4.1.4, and to Appendix D of the
CPRT Program Plan. The NRC inspector selected six TDDRs from the ERC
sample to review in detail. These six TDDRs were reviewed for each
r
s
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ -a
.. . - - . - , . -
.
.. ..
I4
of the decision points listed on the VII.a.2 TDDR evaluation data
sheets (I5 items on each TDDR). The results of the NRC review of the
6 TDDRs (total of 90 decision points) was in agreement with the
'
results of the VII.a.2 review team. By inspection of review team
notes and files the NRC inspector also verified that the VII.a.2
review team had performed a review of the TDDR system, had reviewed
applicable TDDR files, and had interviewed key personnel associated
with the TDDR system. These actions were required by the ISAP and
were to familiarize the VII.a.2 review team with the mechanics of the
,
TDDR system.
No violations or deviations were noted for the above activities.
Further activity in this area will be inspected and reported as it is
completed.
e. Document Control (ISAP VII.a.3)
- During this report period, the ISAP activities identified by NRC
References 07.a.03.01, 07.a.03.02, 07.a.03.03, and 07.a.03.05 were
inspected as follows:
Identify Other-ISAPs Verifying Document Control (NRC Reference
07.a.03.01)
The issue coordinator for this action plan has identified the ISAPs
that perform activities which verify if plant hardware was installed
and tested in accordance with current design requirements:
ISAP III.d Preoperational Testing
ISAP VII.c Construction Reinspection / Documentation Review Plan
The NRC inspector reviewed ISAP III.d and ISAP VII.c and determined
that these two ISAPs would provide data to assess the impact of past
document control problems on the installation and testing of plant
hardware.
ISAP III.d was developed to determine if site document control
problems had an adverse effect on prerequisite or preoperational
testing.
ISAP VII.c required that a hardware reinspection or documentation
review be performed on selected samples from 32 defined populations.
This resulted in numerous hardware reinspections and documentation
reviews being performed by the CPRT. ISAP VII.c further required
that all valid DRs resulting from these hardware reinspections or
documentation reviews be evaluated by the Safety Significance
Evaluation Group and a root cause analysis be performed for each
safety-significant deviation or adverse trend arising from the
totality of DRs. Thus, VII.c provides data relative to the impact of
document control on safety-significant attributes of installed
hardware.
__
_ _ _ _ . - . - _ _ _ _ _ _ . _ - _ - - _ _ . _ _ _ . - _ ,_ ._
__ ._ . .. _ - _-_ . . .
I' .
-. ..
15
b
-
No violations or deviations were noted and no further NRC inspection
is planned for this reference area.
Evaluate ISAP III.d and ISAP VII.c Document Control Deficiencies
(NRC Reference 07.a.03.02)
The NRC inspector verified the evaluation of ISAP III.d and
ISAP VII.c document control deficiencies performed by the
ISAP VII.a.'3 issue coordinator. inis verification was accomplished
by the NRC inspector interviewirt the ISAP VII.a.3 issue coordinator
and reviewing the notes and data in the ISAP VII.a.3 working file.
Further, the NRC inspector reviewed the ISAP III.d Results Report on
plant testing, all current root cause analyses resulting from
ISAP VII.c, and the current results of 18 ISAP VII.c population
reports for identification of document control problems. The results
of this verification found that the ISAP VII.a.3 working file notes
accurately reflected that.the ISAP III.d Results Report reported no
deficiencies or adverse trends related to document control. The
,
ISAP VII.a.3 working file also accurately reflected that the root
cause analyses from implementation of ISAP VII.c identified no case
where document control deficiencies were identified as the root cause
of any safety significant deficiency, adverse trend, or unidentified
trend.
The NRC inspector's review of the current results from 18 of the
ISAP VII.c population reports found no indication that document
control deficiencies should have been identified as the root cause of
any safety-significant deficiency, adverse trend, or unidentified
trend.
The NRC inspector noted that the current results of the ISAP VII.c
r population reports are not final approved. The issue coordinator has
- indicated that if document control deficiencies are subsequently
identified by ISAP VII.c or any other ISAP to'be the root cause of
safety-significant deficiencies, a reassessment of the results of
ISAP VII.a.3 would be conducted by the Collective Evaluation Group.
The NRC inspector verified through review of the above items, that
ISAP VII.a.3 evaluation of ISAP III.d and ISAP VII.c for document
control deficiencies properly reflected the current status of these
ISAPs, and that the ISAPs did not identify document control problems
1
as the root cause of any safety-significant deficiency.
No violations or deviations were noted. The NRC inspector will
continue to monitor ISAP VII.c or other ISAPs for document control
i
problems that may affect this ISAP VII.a.3 evaluation.
- .._ . _ . _ _ _ . - -. ,. , - . . , - . - -- - . - , - - . - - -
_
e. ...
16
Determination of Corrective Action (NRC Reference 07.a.03.03)
ISAP VII.a.3 required that a determination of corrective action be
made if review of ISAP III.d and ISAP VII.c results identified
deficiencies in the document control program.
The NRC inspector verified and reported in this ~ report that
ISAP III.d and ISAP VII.c results did not identify deficiencies in
the document control program, thus no condition requiring corrective
action has been identified.
No violations or deviations were identified in this reference area.
Action on Adverse Trends / Deficiencies (NRC Reference 07.a.03.05)
ISAP VII.a.3 required that remedial action be performed for adverse
trends or safety-significant deficiencies whose root causes were
attributed to document control inadequacies.
The NRC inspector verified and reported in this report that, to date,
ISAPs VII.a.3, III.d, and VII.c results have not identified
deficiencies whose root causes were attributed to document control
inadequacies; thus, no remedial action for such deficiencies have
been required.
No violations or deviations were identified in this reference area.
f. Adequacy of-Purchased Safety-Related Material (ISAP VII.a.9)
ISAP VII.a.9 has been significantly revised by ERC to reflect
comments from the NRC staff. A table of specific activities for
Revision 0 of the ISAP was initially reported in NRC Inspection
Report 50-445/86-03; 50-446/86-02. A revised table to reflect
issuance of Revision 1 dated September 9, 1986, follows:
l' Activity ISAP NRC
Paragraph Reference
Select material / equipment to be 4.1.2 07.a.09.01
reviewed.
Develop reinspection checklists 4.1.3 07.a.09.02
for material and equipment selected.
Perform field inspection of 4.1.3 07.a.09.03
selected material and equipment.
i-
1- Document discrepancies from 4.1.3 07.a.09.04
'
reinspection.
l
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i
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17
Develop procurement program review 4.1.3 07.a.09.05
checklists.
Evaluate the current program for 4.1.3 07.a.09.06
adequacy.
Document discrepancies from program 4.1.3 07.a.09.07
evaluation.
Qualifications of personnel. 4.1.3 07.a.09.08
'The ISAP activities identified by NRC Reference 07.a.09.02 and
07.a.09.03 were inspected during this report period as follows:
Develop Reinspection Checklists for Material and Equipment Selected
(NRC Reference 07.a.09.02) and Perform Field Inspection of Selected
Material and Equipment (NRC Reference 07.a.09.03)
The NRC inspector' reviewed the completed reinspection checklists for
two VII.a.09 material / equipment samples. The samples were identified
by the VII.a.09 review team as I-M-VIIA 9-016 and I-M-VIIA 9-052. The
NRC inspector reviewed-these reinspection checklists to determine
that they addressed the criteria of ISAP VII.a.9, paragraph 4.1.3,
and reflected the specific requirements of the applicable procurement
specification and TUGCo/ vendor design drawings which were in effect
at the time of the material being received at CPSES. The
reinspection checklists were found to include inspection of the
chemical and mechanical test results (CMTRs), hydrostatic test
results, RIRs, authorized nuclear inspector review, pressure and
nonpressure boundary welds, functional linear dimensions, compliance
with. shipping requirements, proper nameplate information, proper heat
numbers, and that'the equipment had no visible arc-strikes. The NRC
inspector determined from review of the reinspection checklist and
ERC letter QA/QC-RT-4145, which details the inclusion or exclusion of
inspection attributes, that the reinspection checklist properly
reflected the procurement requirements.
The NRC inspector performed a document review and a field inspection
of the sample items per the ERC reinspection checklist. These
actions yielded the same results as the ERC reinspection includt.1g
discrepancies documented by ERC on DRs. An example of these
discrepancies was the failure to have records documenting that two
air accumulators were shipped and received with desiccant sealed
inside the tanks as required by the purchase order. The lack of
records for the desiccant was documented by ERC on a DR. During NRC
inspection of this DR, it was found that installation records for
these air accumulators had not been properly prepared. The applicant
has shown that the lack of installation records for the air
accumulators had been previously addressed in NCRs I86-103786 and
186-2021795 which resulted from an ISAP VII.c reinspection.
- .. .,
18
ISAP VII.a.9 is structured such that DRs resulting from reinspection
are not validated until after a review is performed to determine if
changes, authorized since the time of procurement, may_ invalidate the
discrepancy. The NRC inspector will review VII.a.9 DRs, especially
any invalidated DRs, to assure that the DRs are properly processed.
No violations or deviations were noted; further NRC inspection of
these ISAP activities will be reported as they are completed.
g. Onsite Fabrication (ISAP VII.b.1)
During this report period, the ISAP activities identified by NRC
References 07.b.01.02,.07.b.01.03, 07.b.01.04, 07.b.01.05,
07.b.01.06, and 07.b.01.09 were inspected as follows.
Identify and Select Samples from ASME and Non-ASME Fabrications
(NRC Reference 07.b.01.02)
The selection of the ASME safety-related fabricated samples was
previously reported in NRC Inspection Report 50-445/86-03;
50-446/86-02.
During this report period, the NRC inspector inspected the ERC
selection of non-ASME fabricated items (cable tray hangers). The
items selected required at least two of three work activities
(usually cutting and welding) and that they represented a reasonable
cross-section of both ASME and non-ASME fabrication shop activity.
The NRC inspector verified by review of the non-ASME items selected
(18) that the requirements and criteria for sample selection in
paragraph 4.1.2.2 of the ISAP were met. The non-ASME sample was-
found to include three items per-year from 1978-83, which was also an
,
ISAP requirement.
The ASME sample totalled .73 items (as reported previously) while the
'
non-ASME sample totalled 18 items. This total of 91 ASME/non-ASME
items complies with the ISAP commitment (72 item minimum) and is a
representative cross section of fabrication shop activities for the
years of interest (1978-85).
'
No violations or deviations were noted and no further NRC inspection
is planned for this area.
Review Fabrication Packages (NRC Reference 07.b.01.03)
The ERC review of ASME related fabrication packages was previously
inspected and reported in NRC Inspection Report 50-445/86-22;
50-446/86-20. During this report period, non-ASME fabrication
packages were reviewed and inspected by the NRC inspector. The NRC
, inspector selected two of the non-ASME fabrication packages for
review using the criteria listed on the ERC review checklist. The
fabrication packages selected for review were CTH01205 and CTH03254.
.. _ _ _ . _ . _ .
a.= ..
19
The results of these NRC reviews were compared to the documentation
of the same ERC reviews to determine their completeness and accuracy.
The reviews were found to have properly recorded the qualification
status of welders, certification status of QC inspectors, and the
material identity of component material. Other review criteria; such
as, all required inspections completed, required documentation
completed, and legibility were also found to be properly recorded.
No violations or deviations were identified.
'
NRC inspection of this reference activity is complete except for
closing of a deviation identified in NRC Inspection
Report 50-445/86-22; 50-446/86-20.
.
Hardware Reinspection of Fabrication Package Discrepancies (NRC
Reference-07.b.01.04)
During the ERC review of completed fabrication packages, the ERC
document reviewers noted discrepancies in the supporting documents
for the packages,.1.e., missing information on the Bill of Materials
and other documentation problems. These discrepancies were recorded
in DRs as required by procedure. The issue coordinator determined
that these discrepancies were document problems that did not require
a visual reinspection of the installed material to determine that a
deviation existed. In some cases, visual reinspections were
,
performed but only to gather information in support of the DRs.
During the NRC review of the ASME and non-ASME fabrication packages,
the'NRC inspector assessed the documentation discrepancies to
determine that the discrepancies were document problems and that the
I issue coordinator's action of not performing hardware reinspections
to resolve the discrepancies was proper.
No violations or deviations were identified and no further NRC
l inspection is planned for this reference area.
Review of Storage and Surveillance Procedures and Records for
Adequacy (NRC Reference 07.b.01.05)-
The NRC inspected-the ERC review of the storage, fabrication, and
inspection procedures applicable to onsite fabrication. The NRC
1 inspector verified that the attributes listed by ERC as necessary for
! control of material traceability, fabrication processes, and
!. completed item inspection and acceptance reflected the requirements
! of Criteria V, VIII, IX, X, and XIII of Appendix B to 10 CFR Part 50
'
and the Comanche Peak FSAR. The NRC inspector verified that the ERC
l. review results had properly identified where these attributes existed
j
in the current and historical procedures for onsite fabrication.
t No violations or deviations were identified and no further NRC
inspection is planned for this reference area.
(
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. . _ _ _ , , . . - - - - _ ,---_.v - _ _ _ , .-
. _ . . _ . _ _ _ _ - ___ . ~ - . - _ __
..E 5
20
Review ISAP VII.a.1 Deviation for Reinspection (NRC
Reference 07.b.01.06)
The commitment to review fabrication shop deviations identified by "
. ISAP VII.a.1 has been excluded from ISAP VII.b.1, Revision 2. The
ISAP VII.b.1 issue' coordinator determined that ISAP VII.a.1 was not
structured to. review fabrication shop packages.
The NRC inspector reviewed ISAP VII.a.1, Revision 1, to verify that
review of fabrication packages was not required in that ISAP. No
such requirement was found.and none appeared warranted. Therefore,
the issue coordinator's determination to exclude this commitment was
correct. No further NRC inspection is planned for this activity.
-No violations or deviations were identified during inspection of
reference item ISAP VII.b.01.06.
i
'
Notify TUGCo of Hardware Deviations (NRC Reference 07.b.01.09)
The NRC inspected a sample of the ASME and non-ASME fabrication
packages. These package inspections have been reported under NRC
Reference 07.b.01.03. During these inspections, the NRC inspector
verified-that deviations were documented on ERC DRs. ERC
Procedure CPP-016, Revision 3, " Safety Significance Evaluations of
-Deviation Reports," requires that a safety-significance
evaluation (SSE) be performed for each valid DR and that the
completed SSE be transmitted to the TUGCo QA coordinator who is
,
responsible to evaluate the SSE/DR in accordance with TUGCo
Procedure CP-QP-16.3, " Processing CPRT Deviation Reports /0bservation
Notices." The NRC inspector determined from the above review that
TUGCo QA is being properly notified of deviations found during
,
implementation of ISAP VII.b.1.
.
No violations or deviations were identified and no further inspection
-is planned for this reference area.
'
'4. Construction / Reinspection (ISAP VII.c)
a. Field Fabricated Tanks
Status of CPRT Activity
ERC has completed four reinspections and eight documentation reviews
of sampled field fabricated tanks. Thirty-six valid deviations have
been issued by ERC.
Status of NRC Inspection Activity
To date, the-NRC inspector has witnessed 10 percent of ERC
reinspections, performed documentation reviews of five Field
- Fabricated Tank packages, and performed inspection of approximately
., _ _ , . _ _ _ . .. , . . . _ _ _ _ _ . - - _ _ _ _ _ _ . . . . _ _ _ _ _ _
.- . . -- . _ . . _- - . . -_
-
,
s.. , ,
21
15 percent of'the population sample, of which the following
p documentation review occurred during this inspection period:
Verification Tank I.D. System * Unit
. Package
, R-M-FFTA-001 .CPX-CSATBA-01 CS Common (1)
- CS - Chemical ~and Volume Control
This review revealed that an ERC inspector had written
DR R-M-FFTA-001-DR6 to document the existence of CBI fabricated
'
material which did not comply with the requirements of ERC Quality
Instruction (QI) QI-042, Revision 0, Attribute 10. This attribute
states, " Verify that the Metal Material Verification Summary Sheet
identifies the correct material and that the 'CTR Checked' space is
signed." The ERC inspector noted ". . . Many of..the items' identified
to the requirements on the certified drawings were entered on a form
identified as a " Supplemental Summary Sheet of Material Verification"
(not noted in procedure QI-042) with no signatures of any kind for
verification." Subsequent review by ERC engineering determined that
the DR was not valid since the intent of QI-042 (that the correct
material was used) had been met.
The NRC inspector reviewed CBI contract requirements; i.e., CBI QA
, Manual and material requirements table MRT 73121/2 to assess the
i technical accuracy of the DR invalidation. The CBI material
requirements table identified that as a minimum requirement for
. Type A, B, and C material, a material verification summary sheet
.
shall be submitted to TUSI (B&R), and did not reference the alternate
, use of the Supplemental Summary Sheet for Material Verification. The
failure of ERC construction sample reinspection engineering to
validate a DR, which correctly identified that CBI did not comply
~
with their program requirements for materials, is a deviation
- . -(445/8631-0-03; 446/8625-D-01).
b. Piping Bend Fabrication .
Status of CPRT Activity
ERC has completed all of the required reinspections of the 92 random
( and engineered sample selections. One valid deviation was identified
by ERC. Documentation review was not required for this population.
l
[ Status of NRC Inspection Activity '
!
l The NRC inspector did not witness any ERC reinspections. To date,
the following four inspections have been performed, all of which
i occurred during this report period:
!
I
. .. - - =. ..
..- ..
22
Verification Package Drawing System * Unit
I-M-PB FA-021 BRP-RC-1-RB-010 RC 1
I-M-PBFA-022 BRP-SI-1-RB-022 SI 1
I-M-PBFA-031 BRP-CC-1-RB-035 CC 1
I-M-PB FA-032 BRP-CC-1-RB-068 CC 1
SI - Safety Injection
CC - Component Cooling
No violations or deviations were identified.
c. Fuel Pool Liners
-Status of CPRT Activity
!-
,'
ERC has completed 62 reinspections and 100 documentation reviews of
sampled fuel pool liners. Twenty-nine valid deviations have been
issued by ERC.
Status of NRC Inspection Activity
To date, the NRC inspector has witnessed three ERC reinspections,
performed documentation reviews of five Fuel Pool Liner packages, and
- separately performed three inspections, of which the following
documentation review occurred during this inspection period:
Verification Package Weld I.D. Unit
R-S-FPLR-001 #2050 2
R-S-FPLR-004 #969 2
i
R-S-FPLR-025 #865 1
R-S-FPLR-071 #1732 1
- R-S-FPLR-162 #2041 1
No violations or deviations were identified.
d. ~ Documentation Review of Category I Conduit Supports
l
Status of CPRT Activity
Documentation review of the 155 Category I conduit supports sample is
complete. As a result, ERC has initiated 616 DRs, of which 176 have
been established as being valid.
Status of NRC Inspection Activity
.
'
To date, the NRC inspector has performed eight inspections and
conducted five documentation reviews of Category I conduit support
!
,._.. .-, -,, ~ . - - . . .-_ _ _.- _ - - - ~. - . . . - . . _ ~ _ . _ - - . . _ _ - - - - - _ _ -.
+. . . . .
23
_ packages. 'All five.of the documentation reviews were conducted
during this report period and are as follows:
Verification Package Conduit Support -Unit
R-S-CSDP-021 C03016387-03 1
R-S-CDSP-072 C14YO9317-02 1
R-S-CDSP-040 EAB11-3 #16 1
R-S-CDSP-001 C12G07866-02 1
R-S-CDSP-039 C16R09450-01 1
No violations or deviations were identified.
e. Reinspection of Small Bore Pipe Supports
Status of CPRT Activity
Reinspection and documentation review of small bore pipe supports is
complete. Sixty-seven valid deviations from reinspection and six
valid deviations from documentation review have been issued. A total-
of 64 valid deviations have been evaluated for safety significance,
resulting in the identification of 2 safety-significant deviations.
Status of NRC Inspection Activity
-To date, the NRC inspector has witnessed 7 ERC reinspections,
performed documentation reviews of 5 small bore pipe support
packages, and performed 11 inspections, of which the following
documentation reviews occurred during this inspection period:
Verification Package Support System * . Unit
-R-S-SBPS-003 CH-1-SB-014-002-3 CH 1
R-S-SBPS-017' CC-1-EC-006-005-3 CC 1
R-S-SBPS-037 - CH-X-FB-003-021-3 CH Common
R-S-SBPS-044 CC-1-RB-003-006-3 CC 1
! R-S-SBPS-051 GH-X-AB-051-004-3 GH Common
- CC - Component Cooling Water
CH -Ventilated Chilled Water
GH - Gaseous Waste Processing
i No violations or deviations were identified.
4
f. Reinspection of Equipment Supports
,
Status of CPRT Activity
Reinspection and documentation review of equipment supports is
complete. Ninety valid deviations from reinspection and forty eight
valid deviations from documentation review have been issued. A total
.
., . , , - , , - - , , . . , , ..n --.- - - . ,. - ,-. , -
-,-,-,----+--.ee,-e- .w,, ,.w -,, _
.. . .
24
of 129 deviations have been evaluated for safety significance. No
safety-significant deviations have been identified.
Status of NRC Inspection Activity
'To date, the NRC inspector has witnessed-four ERC reinspections,
performed documentation reviews of five equipment support packages,
and performed seven inspections of which the following documentation
reviews occurred during this inspection period:
Verification Package Equipment Unit
R-S-EQSP-008 .CP1-VAFNAV-32 1
-R-S-EQSP-038 ILCS-5691A 1
R-S-EQSP-045 ILCS-5803 1
R-S-EQSP-049 CP2-EPTRET-04 Common
R-S-EQSP-052 CP2-ELDPEC-14 Common
No violations or deviations were identified.
g. Reinspection of Containment Liner and Tank Stainless Steel Liners
Status of CPRT Activity
Reinspection and documentation review of containment liner and tank
stainless steel liner packages is complete with 91 packages
inspected. Eighty-five valid deviations.from reinspection and twelve
valid deviations from documentation' review have been issued. A total
-of 87 deviations have been evaluated for safety significance. No
safety-significant deviations have been identified.
Status of NRC Inspection Activity
To date, the'NRC inspector has witnessed nine ERC reinspections,
performed documentation reviews of five liner packages, and performed
three inspections of which the following documentation reviews
occurred during this inspection period:
Verification Package Joint Unit
R-S-LINR-08 8D 1
i
R-S-LINR-12 P-88 2
R-S-LINR-50 P-366 1
R-S-LINR-60- P-387 1
R-S-LINR-67 B5(A) 2
No violations or deviations were identified.
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25
h. Reinspection of Structural Steel
Status of CPRT Activity
ERC has completed reinspection of 143 of a planned total of 144
structural steel reinspection packages. In addition, ERC has
reviewed 138 of 140 structural steel documentation review packages.
A total of 281 valid deviations from reinspection and 180 valid
deviations from documentation review have been issued resulting in
the identification of four safety-significant deviations.
Status of NRC Inspection Activity
To date, the NRC inspector has witnessed nine ERC reinspections,
performed documentation reviews of ten structural steel packages
(five packages had no documentation, see below), and performed four
inspections.
The NRC inspector-randomly selected ten structur O steel packages for
documentation review. Five of these packages were reviewed in
detail. A thorough inspection of the remaining five verification
packages was not possible because documentation, such as original
construction and inspection records, could not be located by ERC.
The NRC inspector confirmed _this situation. Apparently, no evidence
exists to show that these five packages were originally QC inspected.
The ERC inspector correctly rejected Attribute A.1 (for existence of
an inspection package) and entered NA, not applicable, for all
remaining attributes as required by ERC QI-046, Revision 2. One DR
per package was issued by ERC stating that, " Plant personnel unable
to locate any documentation at the Permanent Plant Records
Vault (PPRV) for this package." The disposition of these deviations
is an open item (445/8631-0-04).
The ten structural steel verification packages reviewed by the NRC
inspector were as follows:
Verification Package Equipment Unit
R-S-STEL-007 Mk A12 (2323-S1-0564) 1
- R-S-STEL-059 AFC0 Mk F180-1-RB 1
- R-S-STEL-088 AFC0 Mk C182-7-RB 1
R-S-STEL-117 Mk D2 (2323-51-0564) 1
- R-S-STEL-120 MRB-0565-DCA, Mk A 1
R-S-STEL-140 Mk C9-22 (MAB-0799-0C5, SH1) 1
R-S-STEL-146 Mk C9-4 (MAB-0799-0C7) 1
. - - . _ _ _=- . .-
t
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26
- R-S-STEL-164 DWG 2323-S1-0602 1
Jet Door 4' E of ES
- R-S-STEL-197 AFC0 Mk B176-1-SA 1
R-S-STEL-236 Mk C7R (2323-SI-0564) 1
'
- No documentation available for review.
The NRC inspector observed that "N/A" (not applicable) was entered by
the ERC inspector for Attribute B.3.1, structural bolting tightness,
in Verification Package R-S-STEL-117. The ERC inspector listed TUGCo
Instruction QI-QP-11.14-1 in the comment section for this attribute.
Paragraph 5.0.B.3.1 of ERC QI-046, Revision 2, states, in part,
" Verify, by review of the inspection report or Construction Operation
Traveler, that the bolts were tightened in accordance with the design
, drawings. . Record, (if listed) in the comments section of the
"
, checklist . . . the method listed for tightening . . . ."
Drawing 2323-SI-0564, Revision 2, shows eight 3/4" A193, Grade B8,
-Class 1, bolts in bearing connections for member D2. Tightness _of
these bolts is addressed and signed off on construction operation
traveler CE-82-358-4802. Paragraph 3.2.3.2.e of TUGCo
Instruction QI-QP-11.14-1, Revision 25, states, in part, "All
threaded bolts in bearing type connections shall be tightened
snug-tight.as a minimum." Attribute B.3.1, structural bolting
tightness does, in fact, apply to this inspection. This is a
deviation (445/8631-0-02).
1. Reinspection of HVAC Equipment Installation
Status of CPRT Activity
A total of 181 HVAC equipment packages were randomly selected by ERC
from a population of 604 packages representing Units 1, 2, and
common. To date, -331 DRs have been written with 187 determined to be
valid.
' Status of NRC Inspection Activity
To date, the NRC inspector has witnessed four reinspections and
' performed five inspections. No documentation review inspections are
scheduled for HVAC equipment installation. The five inspections were
performed during this report period and are as follows:
..
Verification Package Equipment Unit
.I
I-M-HVIN-032 CPX-VADPOC-64 Common
I-M-HVIN-133 CPX-VADPOC-62 Common
I-M-HVIN-041 CPX-VAFNCB-14 Common
I-M-HVIN-125 CPX-VAERFD-79 Common
I-M-HVIN-185 CPI-VADPFD-023 1
!
-_ _ . __ _ _ _ _ . , - . _. _ _ _ . - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.l
.. .,
'
27
No violations or deviations were identified.
5. Assessment of Allegations
a. 4-86-A 052: Questionable Entries on Cable Tray Support Packages
An allegation comprised of the following concerns was made by an
individual pertaining to the Unit 1 cable tray hanger walkdown
program:
(1) Cable tray clamp information recorded during a March 1986
walkdown effort had been changed to inaccessible (IA) as a
result of another walkdown team's inspection.
(2) An as-built drawing in package CTH-1-5604 did not have the
required two signatures of both walkdown personnel.
(3) There is a possibility that other packages exist without the
required two signatures.
(4) Package CTH-1-5604 is believed to be missing at this time.
(5) Procedure TNE-FVM-CS-001 was alleged to be only a guide, not a
procedure.
The NRC inspector reviewed Procedure TNE-FVM-CS-001, Revision 3,
which was in effect at the time of.the first walkdown. Section 2.4
states, in part, "If at the time of walkdown any part of a clamp is
inaccessible at the point of walkdown the entire item is to be
-identified as inaccessible (IA) on the drawing."
Section 3.2.3.5 of Revision 5 to TNE-FVM-CS-001 (in effect during the
second walkdown) states, in part, "After the redline process is
. complete, the walkdown team members will sign and date and put their
respective badge number in the available space above the title
block."
The NRC inspector located package CTH-1-5604, which was properly
maintained in Ebasco's document control center. During a review of
this package and an inspection of the support in question, the NRC
inspector identified the following:
Package CTH-1-5604 had been reissued to a second walkdown team
because of changes in the procedure with respect to the documenting
of clamp details. During the course of this second walkdown effort,
the walkdown team found that the entire clamp on each side was not
visible and should have been noted as such on the initial inspection.
The engineer of the second walkdown team lined out, initialed and
dated the original entries for tray clamps, and noted the correct
information on the drawing. The signatures and initials of the
engineer and the craft person performing the first walkdown, along
F'
a..*- c.
28
with the date (March 10,1986), were found in the notes section of
the drawing. The signatures of the engineer and lead engineer
performing the second walkdown, along with the dates _(April 3 and 6,
1986), were observed on the drawing. The NRC inspector was unable to
determine during his review of Revision 4 to the procedure, which
team members were to sign the drawing off but noted that the drawings
were to be signed off. Revision 5 to the procedure clarified the
requirement to be the two individuals performing the walkdown.
During a physical inspection of the support, the NRC inspector found
that approximately 1/3 of each clamp was covered with the tray and
could not be measured according to the procedure, thus an "IA" should
have been entered in the clamp detail block by the first walkdown
team. The second walkdown team.did identify the problem and noted
the correct data on the drawing. A subsequent (third) walkdown was
performed during this investigation and_ included the engineer who
participated in the first walkdown. The engineer concurred with the
decision of the second walkdown team and verified the validity of the
final walkdown package.
The NRC inspector noted that Section 2.1.1 of TNE-FVM-CS-001
identifies the document as a procedure and could find no indication
in any revision of the procedure where it had been_ identified as
anything other than a procedure. Eighty-five additional walkdown
packages were reviewed by the NRC inspector and all were found to be
in accordance with the requirements of the procedure.
In summary, Concern 1 was substantiated; however, the changes were
properly made and documented. Concerns 2, 3, 4, and 5 were not
substantiated. A copy of this inspection report will be provided to
the alleger,
b. 4-86-A-079: Design changes in the Instrumentation and Control Area
(I&C)
It was alleged that TNE drawing revisions incorporating outstanding
changes were not adequately controlled or implemented; for example:
(1) design changes are made without QC inspecting resulting work to
assure configuration agreement, (2) no mechanism was apparent in the
paper flow group (PFG) to notify QC that previous inspections of
hardware had been invalidated, (3) the drawings for level transmitter
supports inspected by QC had been changed since the QC inspections,
and (4) the supervisor of the group reviewing changes to drawings was
discouraging use of NCRs when inconsistencies were suspected to exist
between hardware installation and drawing configuration. The time
frame of this allegation was August 1986.
Based on information provided by the alleger and interviews with
CPSES personnel, it was determined that the above four examples were
related to the safety-related instrumentation and control (I&C)
systems. The above examples are concerns of the methodology TUGCo
o
e' , ' s . . .
29
used in controlling changes to design documents for.the installation
of Unit 1 and Unit 2 instrumentation and control systems, and the
in.pleme.itation of those design changes by field personnel; such as,
the PFGs, construction, and QC. The documents used to convey design
criteria and requirements for the construction and inspection of I&C
systems'were initial design drawings, revised drawings, and DCAs.
.
Each example was assessed by the NRC inspector as separate
concerns / issues and collectively for impact on the adequacy of the
I&C system design, construction and quality.
(1) Design changes were made without QC inspecting resulting work to
assure configuration agreement.
-Criterion X, " Inspection," of 10 CFR Part 50, Appendix B,
requires the inspection of activities affecting quality to
verify conformance with drawings, instructions, and procedures
for accomplishing the activity. This would include conformance
to the design drawings, revised drawings (which incorporate
outstanding design changes), and DCAs which are outstanding.
The NRC inspector reviewed the mechanisms used to implement
design changes in the field for both units. This review covered
the time period from December 1985 to December 1986, which
included the allegation time frame (August 1986). Each unit was
found to have a separate PFG and procedures for the development
of work packages that included design and changes to design
generated by TNE. The work packages identified requirements,
procedures, and instructions for construction, fabrication,
installation, and inspection activities. Unit I construction is
essentially complete and work activity performed in Unit I was
based on either hardware modification and maintenance or design
changes. Accordingly, TUGCo provided to Unit 1 PFG the
requirements for work package preparation as design changes,
maintenance, or modification activities occurred. TUGCo's
procedure-for delineating work package preparation requirements
to PFG was CP-CPM 1.2, " Construction Activities for Systems
and/or Areas Accepted and/or Controlled by TUGCo Plant
Operations." The procedure used by PFG to prepare and control
packages was based on requirements provided by CP-CPM 7.4,
Revision 0, " Unit 1 PFG Package Control," and CP-CPM-7.4A,
Revision 0, " Appendix A Package Preparation." Unit 2 is still
under construction and, as such, when new drawings, revisions,
or changes are issued that impact hardware, B&R reviewed the
design documents to develop the work package. Work package
development and preparation for Unit 2 was governed by
CP-CPM-7.1, Revision 2, " Package Flow Control" with
Appendices CP-CPM-7.1A through CP-CPM-7.1L.
During the review of PFG's function for the preparati9n of work
packages, the NRC found that TUGCo had identified instances in
which QC did not perform required inspections when drawings were
. . - . . .- .. . - . _ ...
%,9 .; .
30
revised. Both Unit 1 and Unit 2 were affected. Unit I
occurrences were in the area of electrical and I&C systems and
Unit 2 was in the mechanical discipline. Corrective Action
Report (CAR) 59, dated March 21, 1986, (Unit 1) and CAR 89,
dated' August 29, 1986, (Unit 2) address this problem. The
methods of identifying design changes on drawings (e.g., clouds,
revision triangles, and circles) were not implemented properly.
For example, Work Order C85-0003233 (PPF-140),
Drawing 2323-El-0049, Sheet 3, Revision CP-1, was initially
issued to govern a work activity related to Revision CP-1.
Prior to completion of the work, Revision CP-2 was issued.which
eliminated the revision clouds shown on CP-1, thus deleting the
identity of the area of the work activity.
As of this NRC inspection, CARS 59 and 89 have not been closed.
Based on reviews of procedural changes, documented responses to
the CARS, and interviews with CPSES personnel (TNE, PFG, and
QC-Corrective Action), the following actions were being taken to
disposition the issues identified in both CARS. When work is.in
progress, changes to design will be restricted to DCAs; drawings
will not be revised until the construction / inspection is
complete and DCA implementation has been verified.
The PFG is now required to notify TUGCo engineering when a DCA
has.been implemented. To assure timely drawing update, the
number of outstanding change documents (DCAs) have been limited
to five or the time limit of three months to incorporate
outstanding DCAs into the next drawing revision.
The Unit 1 and Unit 2 PFGs were consolidated into one PFG,
December 15, 1986. Procedures CP-CPM-7.1 and Appendices A-L
have been designated to govern PFG work package preparation and
control based on issued drawings and design changes identified
on DCAs. In addition, PFG will review in accordance with
CP-CPM 7.1J, " Review of Design Documents," all unincorporated
design changes issued prior to January 1987, to assure that such
design changes have been properly implemented and inspected.
(2) No mechanism was apparent in the PFG to notify QC that
previously accepted inspections were invalidated by design
changes.
The NRC inspector found that the PFG does not have a requirement
to notify QC when the PFG receives a revised drawing or design
change document, which when implemented would invalidate
previous inspections; however, the PFG prepares a work package
when a revised drawing or design change is made and QC
inspection requirements and hold points are identified. Then
during the performance of work prescribed by the work package,
QC involvement is triggered by the inspection requirements and
hold points delineated in the work package. Upon completion of
. - - - . - - - _
- - _. - __ - _ _ _ - . . _
- - -
- -
s e, < ,_ .-
31
craft and inspection activities, the PFG reviews the work
package'to assure completeness and that documentation conforms
to prescribed requirements. With the consolidation of Units 1
and 2 PFGs into one PFG, Revision 3 of CP-CPM 7.1 governs work
package review for completeness.
Even though PFG did not immediately notify QC that affected
inspections were invalidated upon receipt of a' revised drawing
or DCA, QC was required.to inspect modifications to old work
resulting from such changes. As a result of CARS 59 and 89, TNE
Procedure ECE-DC-21, Revision 5, dated October 31, 1986,
" Preparation and Review of Field Design Change," has been
revised to identify on the face of the DCAs when QC reinspection
is required. Futhermore, form ECE-DC-21.3, "QA/QC Notification
for Reinspection," is to be completed by TNE and transmitted to
the QC manager. The form notifies QC that design changes have
rendered the previously accepted installation or hardware as
potentially unacceptable. At the time of this NRC inspection,
QC was maintaining a log of such notifications and was
developing a mechanism to account for required QC involvement
resulting from changes.
(3) Level transmitter supports which QC accepted as being
satisfactory were contrary to the drawing.
In assessing this issue, the NRC inspector found that two NCRs
had been written to report incorrect installation of level
transmitter supports. The NCRs_were I-86-103982 and
I-86-103983; both dated September 11, 1986, subsequent to the
allegation. To date, these NCRs have not been closed. While
reviewing these NCRs and others related to Unit 1 and 2 I&C
nonconformances, the NRC inspector found two_ CARS that were
written against Units 1 and 2 I&C systems. CAR 88 (dated
August 7, 1986) identified problems with Unit 2 instrumentation
systems (within Unit I security boundaries) being installed and
inspected contrary to requirements of design drawings and site
approved construction and inspection procedures. The basis for
the CAR was 67 NCRs which resulted from walkdowns. CAR 105
(dated October 20,1986) reported discrepancies with the
installation of Unit 1 instrumentation; the cause being that
installation and inspection instructions did not contain
j adequate criteria. The CAR resulted when findings and
observations were trended from 23 NCRs associated with I&C
procedural inadequacies. Concurrent with CAR 105 was the
issuance of Stop Work Order 86-05; applicable to both units.
.
Stone & Webster (SWEC) engineering management has estimated
'
completion of action required to resolve both CARS as May 14,
1987.
'
(4) A Gibbs & Hill (G&H) group supervisor in charge of reviewing the
'
incorporation of outstanding design changes into revised
i
i
') ? ..
32
drawings was _ discouraging the writing of NCRs by revieviing
personnel. The supervisor was requesting that any suspected
inconsistencies between the physical installation and the design
drawing be identified to engineering (TNE) via 3 part memorandum
for further action.
Prior to November 7, 1986, G&H performed engineering services
for TUGCo under the direction of TNE. After November 7, SWEC
assumed the responsibility for engineering related to I&C-
systems for both units. Since.the G&H I&C design organization
was disbanded before the NRC inspections, G&H individuals
directly involved in this concern could not be contacted.
Accordingly, this concern was assessed from information provided
by the alleger and interviews of onsite personnel who were
cognizant of the G&H I&C engineering function.
-The subject G&H I&C group performed a design drawing checking
function in accordance with TNE-DC-7, Revision 18, " Preparation
and Review of Design Drawings." This function was to have
individuals not directly involved with the development or
revision of design drawings verify that the drawing was prepared
and reviewed in accordance with TNE-DC-7. In the case of
revised drawings, checkers / reviewers were to review the prepared
revised drawings against design change documents (DCAs) to
assure outstanding design changes had been adequately
incorporated. For this review, design checking experience was
required, not field knowledge of the installed hardware
(as-built condition); however, some'of these reviewers had
previous field experience. Suspected inconsistencies between
the as-built condition and the design drawings were recalled by
some individuals during these reviews. When this occurred,
these individuals were advised by their supervisor that their
responsibility was to verify outstanding design change
incorporation and not generate NCRs against suspected
inconsistencies. The supervisor suggested that suspected
inconsistencies be transmitted to engineering on a 3 part
memorandum for follow up.
During this inspection, the 3 part memorandums identified as
sent to engineering were not retrievable because of the
disbanding of G&H's onsite organization on November 7, 1986.
4
Accordingly, the NRC inspector could not determine if
engineering followed up on the suspected inconsistencies.
The scope of work to be accomplished by SWEC in determining the
design adequacy of the I&C systems is described in general in
the I&C Generic Issue Report. With the assumption by SWEC as
,
the I&C engineer of record, the work previously performed by G&H
design and engineering will no longer be used. From interviews
with SWEC personnel, the following actions have been completed
or are in process: qualification of all I&C equipment will be
,
E'
%
e [. u ,.
33
reverified, new design criteria will be established for I&C
supports, and a walKdown of all I&C systems to verify the
as-constructed constructed condition, which will then be
analyzed against the new criteria and equipment / installation
modifications made as required.
In summary, four concerns were cited as examples of the lack of
adequate I&C design control and implementation. Of the four
concerns, all were substantiated. Based on the documents
reviewed and the interviews by the NRC inspector, it was
apparent that TUGCo had also recognized these inadequacies and
had initiated or taken corrective actions.
Corrective action is being taken by TUGCo to revise methods of
conveying design changes to the craft and QC to assure the
performance of required' inspections. The concern that no
mechanism _is apparent in the PFG to notify QC when previous -
inspections for accepted hardware have been invalidated was
verified. No requirement existed to do so; however, PFG did
have a mechanism in place to notify QC of inspections to be
performed for work resulting from changes to design. As of
November 1, 1986, TNE has instituted a-procedure to directly
notify QC_of design changes which potentially render previous
inspections invalid.
- The concern that I&C-level transmitter supports were incorrectly
inspected by QC was substantiated. This condition was
identified in two NCRs generated by TUGCo. In addition, other
_ )
examples of QC accepting hardware not'in agreement with design
documents were found. These examples provided the basis for
Stop Work Order 86-05 which halted all installation of
safety-related instrumentation for Units 1 and 2. Actions are
t being taken to resolve the~ stop work order and the estimated
schedule for completion of required actions is May 1987.
! The concern that a G&H supervisor for the group reviewing
changes to I&C drawings and discouraging the use of NCRs when
inconsisten'cies were suspected to exist between hardware
installation and drawing configuration was apparently accurate.
The G&H design review group has been eliminated and the NRC
inspector was not able to interview all individuals directly
l
involved in the concern. From information obtained, the G&H
design review group was not verifying the conformance_of
as-built installation for agreement to drawing configuration,
j but performing a design check to verify the incorporation of
l- outstanding design changes by draftsmen into revised drawings.
i The supervisor apparently viewed these inconsistencies as
suspected problems and not factually known, thus his decision to
document them on other than NCRs. In any event, SWEC has become
the engineer of record in this area and has initiated walkdowns
j of all I&C installations to determine the as-constructed
l
c
- or,
34'
condition. The data obtained from these walkdowns will be
evaluated against new design criteria and modifications to the
as-constructed condition will be made as necessary.
In conclusion, the expressed concerns were recognized by the
applicant as problem areas for which appropriate actions to
correct were either taken or initiated. Based on NRC inspection
of these actions, they appear to have appropriately defined the
problems and their corrective and preventive actions have been
proper. No NRC violations or deviations were identified and no
further action concerning this allegation is planned. A copy of.
this inspection report will be provided to the alleger,
c. 4-86-A-107: Unqualified Walkdown Verification of Conduit
A concern was raised by an anonymous caller that an increasing number
of B&R craft are being used by Ebasco to conduct verification
walkdown inspections of Class 1 (safety-related) conduit. The
alleger, who supplied the identity of one craft, went on to state
that these craft were probably involved in the installation of the
conduit. The alleger inquired as to whether there was a regulation
against an installer conducting verifications.
Based on the identity of the craft supplied by the alleger and by
reviewing Ebasco organization charts, the NRC inspector deterinined
that the allegation was pertinent to the Ebasco Unit 1/ Unit 2
walkdown group. This particular group is responsible for performing
as-built walkdown inspections of Unit 2 safety-related conduits and
supports which are installed in Unit 1 and common areas. With this
as-built walkdown information, the Ebasco design verification
. group (DVG) is to seismically qualify the conduit runs.
r .During August 1986, there were 16 craft people involved with this
Ebasco walkdown group and were identified on the organization chart
as B&R craft and as a separate entity from the individual walkdown
engineers. The NRC inspector interviewed the Ebasco site field
supervisor and found that these craft people were initially brought
,
into the group to assist the Ebasco field walkdown engineers in
l taking measurements, locating and identifying conduit runs and
i supports, and securing support services required to perform the
walkdown. Eventually these craft people were allowed to go out on
their own and generate as-built isometrics of the conduit runs and
redline the conduit support drawings,
i Since no isometric drawings were initially made up for these
conduits, Ebasco generated the as-built isometrics to allow DVG to
get an accurate depiction of the conduit run when seismically
- qualifying it and to remain consistent with other Unit 2 conduit
l walkdown programs. The purpose of redlining support drawings was
twofold: (1) to obtain as-built information of the support for DVG
analysis for modified typical and individually engineered supports;
L
r
., c ,
35
-and (2) to' reverify that supports, initially identified as typical
supports by B&R QC during installation, are indeed typical supports.
For typical supports, DVG used generic support load capacities listed
in the 2323-S2-0910 package, which is the design and construction
guideline for conduit routing and support installation in Unit 2.
It was determined that the allegation, as stated, was true. Ebasco
does or has utilized upwards of 16 craft people to perform
verification walkdown inspections. Subsequent NRC inspection
revealed, however, that these craft people received documented
training identical to that received by other Ebasco walkdown
engineers. This training included formal classroom training on the
appropriate walkdown Procedure TNE-FVM-CS-014, "As-built Field
Verification Method," and a B&R training session, including passing a
test, on taking measurements. Ebasco was also required to, by
procedure TNE-FVM-CS-014, independently field verify all isometric
information. Furthermore, it was an Ebasco guideline to field verify
.
the redlined support drawings. Ebasco did, however, stop the
independent field checking of the redlined typical support dr?. wings
by internal memorandum on July 24, 1986. With the issuance of the
memorandum, all redlined typical support drawings which had not been
checked as of that date, were not to be checked and the dates
backdated to the memorandum issuance date. The reasoning behind this
was that the information obtained during the redline process was not
utilized by DVG during their analysis of the conduit. After
redlining a typical support drawing, craft reconfirmed the initial QC
inspection that the support was indeed a typical support. For
typical supports, DVG would review the redline information for
completeness and use the load capacity specified in the 2323-S2-910
'
package. If a typical support should fail the DVG analysis, DVG
would look at the information noted on the redlined support drawing
l only to come up with a-possible fix. Before a final fix was
instituted, the typical support was reinspected and the reinspect _fon
independently field verified.
I At this time, the NRC inspector determined that utilizing craft for
l these walkdown inspections was within procedural guidelines. The NRC
l inspector picked 12 packages walked down by the craft and by tracing
>
documentation back to the initial construction operation traveler,
l determined that in all cases the same craft person was not involved
l in the installation. The possibility, though, does exist that the
same craft person could be involved in installation and walk down of
the same conduit; however, QC inspection and independent field
,
verification of the conduit isometric provide sufficient independence
- to the total program.
'
To further assess adequacy of the Ebasco walkdown program and
performance of the craft walkdown inspection, the NRC inspector
inspected six conduit runs and applicable supports which the craft
had walked down. The NRC inspection included all the attributes
necessary to generate an isometric and to redline support drawings
-
%s-- ,
36
per the applicable walkdown Procedure TNE-FVM-CS-014, "As-built Field
Verification Method." No violations or deviations were noted.
In summary, the NRC inspector substantiated the allegation, in that
craft were being utilized by Ebasco:for walkdown inspections and the
potential does exist where the craft would walk down the same conduit
run or support that he had installed. There are, however, no
procedural or regulatory guidelines prohibiting this when there is
also sufficient independent verification involved. This independent
verification is in the form of QC inspection prior to the walkdown
inspection and independent Ebasco field verification of all isometric
and support red lining except for typical supports. In addition, NRC
inspection of six conduit runs which had been "walkdown" inspected by
craft revealed no procedural non-compliance.
6. ERC Collective Evaluation Program
The purpose of this NRC inspection was to determine if ERC has established
and implemented measures to perform collective evaluations of results
obtained from programmatic and construction related ISAPs. In accordance
with the CPRT Program Plan (Section VI), each completed ISAP will produce
a results report. The program plan requires ISAP and DSAP results reports
to be collectively evaluated (i.e., by discipline, population) to
determine if identified deficiencies are isolated occurrences or generic -
weaknesses. These evaluations are to be of sufficient scope to provide
reasonable assurance that there are no remaining undetected safety
significant hardware deficiencies. To implement the collective evaluation
requirements, ERC has developed Procedure CPP-014, " Collective Evaluation
of the Construction QA/QC Program and of The Quality of Construction."
The current version is dated October 30, 1986 (Revision 3).
CPP-014 describes ERC's methodology for collectively evaluating the
results of 39 CPRT ISAPs (excluding testing) and related input from other
applicable investigatory programs. Two separate evaluations are required
to be performed. One evaluation is to assess the adequacy of the
Construction QA/QC Program (programmatic); the other is to determine the
Quality of Construction Program (hardware) for the mechanical, electrical,
civil and structural disciplines. Each evaluation is to summarize
,
'
deficiencies, adverse trends, associated root cause(s), and generic
implications; corrective action to resolve deficiencies and adverse
j trends; and recommendations to preclude recurrence during the remaining
'
work on Unit 2. A summary report will integrate the results of the two
1
collective evaluation reports setting forth CPRT conclusions.
At the time of the NRC inspection, 10 of 39 ISAP results reports were
completed, approved and issued, and therefore, the collective evaluation
, process to evaluate programmatic and hardware results reports has not yet
! been fully implemented. In reviewing CPP-014, it appears to lack specific
- detail for collective evaluation performance. The collective
evaluation (CE) personnel stated that the collective evaluation leader in
the programmatic and hardware disciplines would develop controlled working
F'
- . ** .
37
instructions for given work activities. These work instructions were in
the process of being developed and would provide uniform methodology for
the performance and the documentation of the respective collective
evaluations.
During this inspection period, the NRC inspector was provided the initial
version of the. programmatic and hardware work instructions, dated
November 13 and 18, 1986. These instructions have been approved by the
Collective Evaluation Group Supervisor. Based on NRC review of these work
instructions and interviews with the involved personnel, the collective
evaluation process is described as follows:
a. QA/QC Program Collective Evaluation (programmatic):
(1) CPRT source documents will be used to establish a data base that
includes programmatic deviations, deficiencies, findings and
adverse trends. Source documents generated by activities
described in the CPRT Plan which specifically identify QA/QC
program deviations or address QA/QC problems during the
reinspection / documentation review are:
(a) ISAP results reports.
(b) ISAP VII.c population reports (Appendices).
(c) Program Deviation Reports (PDRs).
(d) Design Appraisal Program (DAP) Memoranda.
(e) Electrical Review Group Memoranda.
(f) Hardware Collective Evaluation Group Problem Forms.
(g) Collective Evaluation Matrix Coordinator Memoranda.
(2) Deviations, deficiencies, adverse trends including associated
root causes, generic implications and corrective actions are
documented on a QA/QC Program Work Sheet.
(3) PDRs are prepared in accordance with CPP-017, Revision 2, for
deviations and findings which are identified during the
collective evaluation process.
(4) Programmatic deviations, deficiencies, and findings will be
classified according to related 10 CFR 50, Appendix B, criteria
and a cause established for trending of programmatic items.
(5) Program items will be reviewed to identify any adverse trends
not previously identified in programmatic results reports in
accordance with CPP-11, Revision 2, " Evaluations of Adverse
Trend Analysis, Construction Deficiencies, and QA/QC Program
Deficiencies." If any new adverse trends are identified, causes
and generic implications will be developed using PAG-04,
Revision 0, " Guide on Root Cause and Generic Implication." As
required, corrective action recommendations will be developed
which may include performance of additional inspections or
document reviews.
c
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,
38
(6) Based on steps (1) through (5), a collective evaluation report
will be generated to summarize programmatic findings,
deficiencies, adverse trends and associated root causes and
generic implications. Corrective action to resolve deficiencies
and adverse trends will be identified with recommendations to
preclude recurrence during the remaining work on Unit 2.
Finally, the adequacy of the CPSES QA/QC Program will be
summarized.
Historically, the programmatic evaluation section of the collective
evaluation group was organized in late September 1986 with a staff of
two; by November 1986 staffing was four. Resources for staffing are
CPRT personnel who have completed their related ISAP assignment and
are ready for reassignment. During October and November 1986,
primary work activity of this group was participation in the CPRT
Results Report and Working File Review (RRR) committee meetings to
become acquainted with the subject matter of completed ISAPs, result
reports, and population reports. Secondary work involved development
of working instructions and the review of published and draft results
reports and population reports for preliminary identification of
potential programmatic items.
b. Quality of Construction Collective Evaluation (hardware):
(1) A data base of hardware deviations, deficiencies, and adverse
trends will be developed using applicable CPRT source documents
identified in a.(1) above and data extracted from DRs,
implemented hardware results reports, and ISAP VII.c population
reports. Other related source documents will be reviewed to
identify hardware deficiencies and adverse trends including
associated root causes, generic implications, and corrective
actions. Data from each deviation will be classified by
population, component, work process, and discrepancy type.
Sorting by work process, the data will be reviewed to identify
trends and evaluate for adverse conditions.
(2) After the data base is established, it will be searched for
adverse trends resulting from deviation trending, and for
adverse trends not previously identified in the hardware result
reports or ISAP VII.c population reports. These new trends will
be processed in accordance with CPP-011, Revision 2. Root cause
and generic implications will be developed using PAG-04,
Revision 0.
7
(3) Hardware deficiencies, adverse trends, and associated root
causes with generic implications will be correlated and \
summarized in a collective evaluation report entitled CPSES
Quality of Construction. The report will identify required
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actions to resolve deficiencies and adverse trends with
recommendations to preclude recurrence in Unit 2 remaining work.
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The adequacy of construction will be summarized including
recommendations for improvements.
The hardware collective evaluation section was organized in late
September 1986. By October 15, 1986, staffing was at five persons
obtained from organizations which have completed specific ISAP
assignments. As with the programmatic section, staffing will be
increased commensurate to the level of work. During October and
November 1986, the hardware section primarily participated in RRR
committee meetings to obtain familiarity with the subject matter of
the ISAP VII.c results report and its associated population reports.
Another major effort was the establishment of the deviation sorting
indexes and data base search methods. Development of the hardware
collective evaluation work instructions included trial testing,
c. Summary Report:
Both the programmatic and hardware collective evaluation reports will
be integrated into one summary report as input into the CPRT overall
Collective Significance Evaluation Report. This report in turn will
summarize the results of all CPRT ISAP and DSAP activities and any
special investigative work not covered by the ISAPs and DSAPs. At
this time, ERC has not finalized the methodology for integrating the
programmatic and hardware collective evaluation into the summary
report.
In summary, the NRC inspector determined that ERC has established and
documented a collective evaluation program to summarize the results of
ISAP activities. The program has not been fully implemented since only 10
out of 39 result reports have been approved and issued. To date, the
collective evaluation group has accomplished preliminary activities; such
as, organizing and staffing hardware and programmatic collective
evaluation sections; participation in RRR committees to become acquainted
with ISAP results report subject matter; and the development of
methodology for the collection and analysis of hardware / programmatic
deviation and deficiency data.
Procedure CPP-014, in general terms, outlines the overall collective
evaluation process. More specific direction for conduct of evaluations is
controlled by documented working instruct. ions. The final stages of the
program for integrating hardware and programmatic collective evaluations
into one summary report have not been formalized. Since the collective
evaluation program is only partially implemented, the NRC will inspect
further program implementation at a later date.
7. Exit Interview
Exit interviews were conducted December 9, 1986, and January 13, 1987,
with the applicant's representatives identified in paragraph 1 of this
appendix. During these interviews, the NRC inspectors summarized the
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scope and findings of the inspection. The applicant acknowledged the
findings.
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