ML20215J864
| ML20215J864 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/16/1986 |
| From: | Barnes I, Ellershaw L, Hale C, Wagner D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20215J811 | List: |
| References | |
| 50-445-86-03, 50-445-86-3, 50-446-86-02, 50-446-86-2, NUDOCS 8610270219 | |
| Download: ML20215J864 (49) | |
See also: IR 05000445/1986003
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APPENDIX C
COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-445/86-03
Permits: CP"?-126
50-446/86-02
CPPR-127
Dockets:
50-445
Category: A2
50-446
Licensee: Texas Utilities Electric Company (TVEC)
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas 75201
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Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 and 2
Inspection At: Glen Rose, Texas
Inspection Conducte - February 1 through March 31, 1986
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Inspectors:
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L.E. Ellershaw, Reactor Inspector, Region IV
Dat~e
CPSES Group
(paragraphs 6. , 7. , 8.e-9, 8.j, 9.g-m)
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Johbl%
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C.J. H 1 , Reactor Inspector, Region IV
Date
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CPSE
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(paragraphs 2.f-j,3.,4.,5.a-c,8.c-d,8.h-1)
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A P.C. Wagner, Reactor Inspector, Region IV
Date
CPSES Group
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(paragraphs 2.a-e, 5.d, 8.a-b, and 9.a-f)
Consultants:
EG&G -
J. Dale (paragraphs 6., 9.j)
A. Maughan (paragraphs 2.c-d, 9.b.-d)
W. Richins (paragraphs 8.e} 8.f, 9.k, 9.1)
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V. Wenczel (paragraphs 5.b
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Parameter - J. Birmingham (paragraphs 2.h-i, 3.d, 8.c-d, 8.h-i)
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8610270219 861017
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ADOCK 05000445
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J.Gibson(paragraphs 2.e,9.e.)
K. Graham (paragraphs 7.,8.j,9.m)
D. Jew (paragraphs 8.g, 9.g-1)
Teledyne -- J. Malonson (paragraphs 4., 5.c)
Approved:
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<o/$M6
I. Barnes, Chief, Region IV CPSES Group
Date
Inspection Summary
Inspection Conducted: February 1 through March 31, 1986 (Reports 50-445/86-03;
50-446/86-02)
Areas Inspected: Nonroutine, unannounced inspection of applicant actions on
previous inspection findings, Comanche Peak Response Team (CPRT) issue -
specific action plans (ISAPs), applicant management of QA activities, CPSES QC
surveillance program, assessment of allegations, pipe supports, and followup on
NRR liner plate concerns.
Results: Within the seven areas inspected, five violations (failure to take
corrective action with respect to Inspection Process Control group findings,
paragraph 5.a; inadequate site operation trend analysis, paragraph 5.b;
inadequate control of a design change, paragraph 5.d; inadequate resolution of
a nonconforming condition, paragraph 6; failure to comply)with ACI requirements
for radiographic examination of a liner weld, paragraph 7 and five deviations
(failure to comply with approved instructions in performance of reinspections,
paragraphs 9.g and 9.j; incorrect consideration of impact of a revision to a
quality instruction (QI) on previous inspections, paragraph 9.k; inadequate
engineering review for applicability of an inspection attribute, paragraph 9.j;
omission of a required inspection attribute from a QI, paragraph 9.n; and
failure to identify an unacceptable weld surface condition, paragraph 9.m) were
identified.
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DETAILS
1.
Persons Contacted
D. L. Anderson, Supervisor of Audits, TUGCo
- J. L. Barker, Executive Assistant to Executive Vice President, TUGCo
- J. W. Beck, Vice President, TUGCo
A. K. Bordine, Operations Q-List Engineer, TUGCo
- C. T. Brandt, TUGCo Quality Engineering (QE) Supervisor (Ebasco)
- R. E. Camp, Project Manager, Unit 1 (Impell Corp.)
- W. G. Counsil, Executive Vice President, TUGCo
D. E. Deviney, Operations QA Supervisor, TUGCo
- P. E. Halstead, Quality Control (QC) Manager, TUGCo
M. Keathly, Evaluation Research Corporation (ERC) Lead Electrical QC
Inspector
P. Leyendecker, Surveillance Supervisor, TUGCo
J. B. Leutwyler, Brown & Root (B&R) Electrical QC Supervisor
J. Mallanda, CPRT Electrical Review Team Leader
D. M. McAfee, Quality Assurance (QA) Manager, TUGCo
- J. T. Merritt, Director, Construction, TUGCo
M. Obert, ERC Issue Coordinator
- J. Redding, Executive Assistant, TUGCo
B. C. Scott, Supervisor, Vendor Audits, TUGCo
P. Stevens, Electrical Engineer, TUGCo Nuclear Engineering (TNE)
- J. F. Streeter, Director, QA, TUGCo
- T. G. Tyler, CPRT Program Director, TUGCo
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J. Ziemian, ERC Lead Mechanical QC Inspector
- Denotes those persons who attended the March 4, 1986, exit interview.
- Denotes those persons who attended both the March 4, 1986, and the
April 4, 1986, exit interviews.
- t* Denotes those persons who attended the April 4, 1986, exit interview.
The fiRC inspectors also contacted other CPRT and applicant employees
durir.g this inspection period.
2.
Applicant Actions on Previous Inspection Findings
(Close_d) Unrasolved Item (445/8518-U-02; 446/8515-U-01):
Electrical
a.
penetratien assemblies (EPAs) not properly qualified.
Further review
of this unresolved item disclosed numerous problems which have been
documented in a separate inspection' report; i.e., NRC Inspection
Report 445/86-04; 446/86-03. This item is closed.
b.
(Closed) Open Item (445/8513-0-02):
Lack of inspection procedure for
ISAP No. I.b.4.
The adequacy of the provided procedures to conduct
ISAP No. I.b.4 was further evaluated by a review of ISAP Nos. I.b.2,
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Revision 4, dated January 24, 1986, and I.b.4, Revision 4, dated
January 24, 1986. The inspections required in I.b.2 include the
issues addressed in I.b.4; therefore, procedures for inspection are
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not required in I.b.4.
This item is closed.
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-c.
(Closed)OpenItem(445/8514-0-09): Comparison of ERC with NRC
review results for documentation packages. Comparison of ERC and NRC
documentation reviews of seven verification packages was deemed to be
ineffective because of revisions to the applicable procedures. The
NRC inspector reviewed again the involved packages; the results are
discussed elsewhere in this report. This item is closed.
d.
(0 pen)OpenItem(445/8516-0-20):
Potential deviation regarding
underinsertion of EPA closure flange stud in nut. The condition of
the nuts not being engaged flush with the ends of the closure studs
was documented in ERC Deviation Report (DR) 1-E-EEIN-062-DR-1. This
DR was incorporated into Nonconformance Report (NCR) E85-102021SX,
This item remains open pending NRC review of the disposition of the
NCR.
e.
(Closed)OpenItem(445/8518-0-12): During an independent NRC
inspection in December 1985 of instrument 1-PT-2325, Verification
Package No I-E-ININ-053, it was observed that tubing associated with
the instrument was not color coded to identify its assigned
separation group (train / channel), and that separation spacing was
apparently not maintained on the tubing run. ERC inspection
personnel, similarly identified these conditions on
DRs I-E-ININ-053-DR1 and DR2; the corresponding TUGCo NCRs are
I-85-1012775X and I-85-101278SX dated October 3, 1985.
Gibbs & Hill, Inc (G&H) Pressure Instrument Specification Sheet
No. 05.14, indicated that 1-PT-2323 is a "Q" item (class 1E connected
to a safety class 2 system). The TUGCo "Q" list, 1Q-LIST-MS-0323,
indicates that 1-PT-2325 is safety class 1E, seismic category I, has
two component functions, and must remain functional during and after
a Safe Shutdown Earthquake (SSE). The CPSES FSAR, Figure 10.3-1
(SH-1), shows that 1-PT-2325 controls the power operated atmosphere
steam relief valve (1-MS-259) associated with the main steam line
from steam generator #1. Also, Section 7.4.f of the FSAR lists this
relief valve, controlled by 1-PT-2325, as an essential component
under hot standby conditions. Hot standby is defined in this section
as, ". . . a stable condition of the reactor achieved shortly after a
programed or emergency shutdown of the plant and is the safe
shutdown design basis for CPSES . . . ."
The TUGCo disposition of NCRs I-85-1012777SX and 101278SX stated that
no nonconformance existed because the instrument was "non-Q," and did
not fall within the scope of the QA program. Subsequently, ERC
initiated Technical Information Request (TIR) No. 130 dated
October 31, 1985, requesting further clarification of color code
identification for separation groups I, II, III, IV, A, or B.
The
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TUGCo response to TIR 130 stated that color coding of instrument
impulse lines was required only for those instruments annotated by a
diamond symbol on drawings of the 2323-M1-2500 series, because these
were the only nuclear safety-related instruments designated by G8H
Specification 2323-MS-625.
The NRC inspector's review of the instrument tabulation sheet,
2323-M1-2505-03, Sheet 3 of 5, revealed that 1-PT-2325 was assigned
to separation Train "A", but was not associated with the diamond
symbol. Drawing 2323-M1-2500-N, Sheet 1 of 1 indicates that the
diamond symbol ~is used to identify field mounted instruments which,
because of their safety function, require the connecting impulse
tubing to have separation from similar tubing runs on the redundant,
counterpart instrument. On February 13, 1986, TUGCo redispositioned
NCRs I-85-101277SX and 101278SX, to state that no nonconformance
existed because the instrument was nonsafety-related (i.e., not
required for safe shutdown). On February 20, 1986, TUGCo revised the
response to TIR 130, to state that devices that did not have
redundant counterparts were not color coded, and did not require
inspection for separation.
Because 1-PT-2325 did not appear to have a redundant counterpart,
this open item pertaining to maintaining separation color coding and
spacing of the tubing run is closed.
The FSAR listing of the power. operated atmosphere steam relief valves
as essential components for maintaining hot standby, brought into
question the definition of safe shutdown as identified on the
disposition of NCRs I-85-101277SX and 101278SX, and as depicted in
design documents and implementing procedures / instructions. This item
is considered unresolved pending clarification of requirements by the
applicant (445/8603-U-01;446/8602-U-01).
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f.
(0 pen) Violation (445/8432-02;446/8411-02): Procedures were not
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established for regular management review of the status and adequacy
of the construction QA program nor was it apparent such reviews were
made. Actions taken and being taken by TUGCo include the following:
Procedure DQP-CQ-5, " Senior Management Overview," Revision 0,
September 23, 1985, has been implemented and two committee meetings
have been held. The following management personnel are members of
this committee: Vice Presidents of Operations, Engineering /
Construction, and Licensing /QA; Director of QA; the Managers of QA
and QC; and the Operations QA Supervisor. The Executive Vice
President of Nuclear Engineering and Operations has attended both
meetings thus far. Based on the NRC review of the minutes of these
meetings, it is apparent that senior plant management is being
appraised of QA/QC problem areas and their input is being provided to
corrective as well as preventive action programs.
In addition, an
INP0 audit we conducted in the summer of 1985, and the CPRT onsite
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activities are directing more management attention to existing and
potential problem areas and weaknesses.
Further independent
management assessment of the plant will be provided by annual _JUMA
audits, the first scheduled to begin February 24, 1986.
The subject of management assessment is still being evaluated.by the
CPRT in ISAP No. VII.a.5. TUGCo will respond to this violation when
the CPRT effort is complete. This item remains open awaiting that
response.
g.
(0 pen) Violation (445/8432-03;446/8411-03):
Four examples of
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failures in the program audits of safety-related activities:
(1) inadequate audit procedures; (2) failure to verify proper
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implementation of all elements of the safety-related program
annually; (3) Westinghouse site activities were not audited in 1977,
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1978, 1979, 1980, and 1981; and (4) since 1978 vendors have not been
audited annually.
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(1) At the time of this violation, the audit program for internal
and external audits was prescribed in Procedure DQP-CS-4, "TUGCo
QA Audit Program." Subsequent revisions and new procedures
describe in more detail how TUGCo's. commitments are being
implemented. Currently, the TUGCo audit program is being
implemented with several procedures that are topically specific.
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These procedures include: DQA-QA-2, " Indoctrination and
Training of TUGCo QA Dallas Personnel"; DQP-QA-15, "TUGCo QA
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Audit Program"; DQP-VC-14," Conduct of External Audits";
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DQP-AG-2, " Conduct of Internal Audits"; DQP-AG-3, "CPSES
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Operations Phase Audit Program"; DQP-AG-4, "CPSES Construction
Phase Audit Program"; and DQP-AG-6, " Internal Audit Deficiency
Followup / Closeout."
(2) TUGCo was committed to audit annually all applicable elements of
the QA program. This internal audit program is based on an
annual schedule of audits in areas of continuing and ongoing
safety-related activities. Organizations, disciplines, and
areas or activities to be audited are based on review and
evaluation of site procedures. Subactivities within a given
organization, discipline, or area are audited on a sampling
basis determined by the current site schedules. Therefore, site
procedures and instructions form the basis for the majority of
the audit programs; however, there is no intent that all
implementation activities of all procedures and instructions
will be audited annually (p.aragraph 3 of this report), TUGCo is
Based on the NRC's inyection of the
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internal audit program
complying with their internal audit program commitments.
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(3) Westinghouse (W) site personnel's principal responsibilities
were to coordinate construction site activities relative to the
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W equipment and to provide advice and consultation on testing
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and startup programs. While most of the necessary audits of
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these W site responsibilities are performed through TUGCo audits
of thel corporate offices (e.g., Pensacola or Monroeville),
periodic audits onsite are necessary. Such an onsite audit was
conducted in November 1984. The scope of this auait included
the review of the qualifications of the site personnel and
resulted in one finding. Then in September 1985 an evaluation
of the W site activities was made, which concluded that a 1985
audit was not merited based on the absence of problems and no
changes in the W scope during the previous year.
In sumary,
limited items are auditable onsite and these items are now
considered for auditing each year; most W site functions are
controlled by the offsite W organizationi and these are audited,
evaluated, or both annually.
(4) Amendments 52 and 54 to the FSAR were submitted to the NRC on
August 2;,1984, and January 21, 1985. These amendments
proposed the adoption of Regulatory Guide 1.144, which comitted
TUGCo to a minimum of annual evaluations of vendor performance
and triannual audits of vendor QA programs. By NRC letter
(Noonan to Counsil) dated September 30, 1985, this proposal was
accepted with certain changes in the wording. These word
changes were made in Amendment 57 dated December 20, 1985.
Currently, the NRC finds that the vendor audit program is in
compliance with TUGCo comitments.
(See paragraph-3 of this
appendix.)
The subject of the audit program and auditor qualifications is
continuing to be assessed by the CPRT in ISAPs VII.a.4 and VII.a.5,
and the NRC is inspecting this activity on a continuing basis. TUGCo
will respond to this item when efforts on these ISAPs are complete.
Accordingly, this item remains open.
h.
(Closed) Violation (445/8432-05;446/8411-05): One of six inspectors
training files reviewed had not completed the required eddy current
testing course.
The procedural requirement in violation was deleted.before the end of
the subject inspection on the basis that eddy current capabilities
were not necessary for these inspectors. An NRC review of several
TUGCo audit reports supported this TUGCo position.
i.
(Closed)UnresolvedItem(445/8432-04;446/8411-04): Without the
number of required annual audits clearly defined, it could not be
determined if there existed an adequate audit staff to effectively
implement the comitted audit program.
The scope of the internal audit program is more clearly defined
currently, and there are presently 12 internal auditors. Additional
support is available through contract personnel and TUGCo plans to
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qualify other QA personnel as auditors to supplement their staff as
necessary. The scope and staffing of the internal audit program is
addressed further in' paragraph 3 of,this report.
j.
(Closed) Unresolved Item (445/8432-06; 446/8411-06): The onsite
surveillance program appears'to~ lack sufficient purpose, direction,
coordination, and feedback to the overall QA program.
In late 1984, the site surveillances were performed by one group of
four individuals and a supervisor. Currently these surveillances are
conducted by four groups with a total staff of 29. The surveillance
groups functional areas and staffing are: documents, 4 people;
startup/ turnover, 5 people; construction, 8 people; and inspection,
12 people. The surveillance program is defined and controlled by six
procedures. These procedures address the concerns expressed in the
previous NRC inspection. A more detailed NRC inspection of the total
onsite surveillance program is provided in paragraph 4 of this
report.
3.
Applicant Management of QA Activities
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a.
Organization and QA Program
The NRC inspectors reviewed the QA comitments described in FSAR
Section 17.1, " Quality Assurance During Design and Construction,"
through Amendment 56 dated October 15, 1985.
Since the NRC's last
inspection in this area (50-445/8432; 50-446/8411), several changes
have occurred in the QA program (e.g., adoption of triannual audits
of vendors discussed elsewhere in this report) and organization.
A Director of QA has been added to the QA organization who reports to
the Vice President, Nuclear Fuels and QA. Re
are the managers of QA (Dallas) and QC (site) porting to this director
The functions and
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responsibilities of the Manager of QA are essentially the same;
however, reporting to this manager are an assistant manager and four
supervisors; vendors, audits, QE and administration.
Except for the
changes in titles, the functions and responsibilities of the QC
Manager are the same; however, a QC Services Supervisor and a QC
Surveillance Supervisor have replaced the QA Supervisor, and a QC
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Coordinator has been added.
While the division of QA/QC functions and responsibilities remains
essentially the same between the site and corporate office, the
organizational changes have divided some activities and provided
additional management control.
In addition, a number of personnel
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changes have been made in the past year including new QA and QC
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Managers. The corporate QA staff has increased slightly, but the
site QC staff has increased more than 50 percent. This increased
staff has provided among other things, more attention to product
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quality through surveillances of QC inspector effectiveness and
hardware,
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The aforementioned changes in staff and QA/QC emphasis has resulted
in revision and restructuring of the implementing procedures. The
NRC inspectors reviewed several of the revised and new procedures.
The results of these reviews are provided in subsequent paragraphs of
this report.
Revision 15(October 15',1985) of the Corporate Quality Assurance
Program was reviewed. This program continues to provide the
corporate policy concerning QA and a description of comitments to
assure that all phases of design, fabrication, construction, testing,
and operation are consistent with quality requirements.
A QA program change intended to involve utility management more
closely in QA matters was the formation of the Senior Management.
Overview Comittee (SM0C) in September 1985. The functions of this
comittee are described in DQP-CQ-5. This comittee, which meets at
least three times per year (more often as necessary), is composed of
the following members: the Vice Presidents of Operations,
Engineering / Construction, and QA; Director of QA (chairman); Managers
of QA and QC; and Operations QA Supervisor. The minutes of meetings
conducted thus far were reviewed by the NRC inspector. These were
consistent with the controlling procedure.
In this area of the inspection, no violations or deviations were
identified.
b.
Reviews of QA Program Effectiveness
The CPRT provides management with an ongoing view of the quality and
effectiveness of the QA program. The NRC assessment of CPRT efforts
are provided in monthly inspection reports. Management programs in
addition to the CPRT include the periodic SM0C meetings, audits by
outside organizations (e.g., INP0 in 1985 and JUMA scheduled for
1986), and trend analyses of NCR's and "UNSAT" inspection reports for
construction activities and deficiency reports for operations
activities.
The construction trend reports for November and December 1985 were
reviewed for compliance with Procedure QI-QP-17.0-1, Revision 1,
" Preparations and Distribution of Trend Reports." Potentially
adverse trends and conditions were identified in these reports. The
responses to the November and December reports were reviewed to
assure proper actions were taken. Corrective actions in the November
report response included the replacement of a craft foreman in the
electrical discipline with a request for additional monitoring in
that area. The management evaluation of the December report is still
in process.
Two SM0C meetings had been held by the end of 1985. The first SM0C
meeting was on September 25, 1985, with the second in November. The
minutes of both meetings were reviewed by the NRC inspector. This
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forum provides a means of resolving QA issues and developing QA
positions by management with diverse organizational interfaces. Two-
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procedural weaknesses were noted concerning the minutes of these
neetings: . attendees were not listed nor is there a means of
identifying the. sequence of the meetings; e.g., sequential . numbering
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by year.
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Procurement Control
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Purchase orders (P0s) to seven currently active vendors were reviewed
by the NRC inspectors to verify that appropriate quality requirements
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were included based on QA reviews,-vendors were properly on the
approvedvendorslist(AVL),andvendoraudits/evaluationswere
current. These P0s were processed in'accordance with commitments
except for the following.
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Two P0s were issued to Metal-Bellows (for flexible metal hose)
CPD-0320 in May 1980 (with three supplements in November 1980,
January 1981, and April 1982) and CPD-0322 (with supplements in
December 1984,May, September,andOctober1985). The preaward
survey (PAS) was performed April 23-24, 1980, and the vendor was-
placed on the AVL; however, no audits or reevaluations, as required
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by DQP-QA-15, "TUGCo QA Audit Program," and DQP-VC-11, " Vendor
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Evaluation Methods," were conducted until the audit of January 23-24,
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1985, which was required at least every three years, and a
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reevaluation performed August 16, 1984, which was required annually.
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This is a further example of the violation identified during a
previous NRC inspection (445/8432-03; 446/8411-03). The action taken
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by TUGCo (the January 23-24,1985, audit) brought this item back into
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compliance with the current TUGCo vendor audit program.
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The PO with Stone & Webster Engineering Corporation (S&W),
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CPF-12658-5, issued in July 1985 and presently containing four
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supplements, was reviewed by the NRC inspectors, which procured
engineering services for pipe stress and qualification activities,
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The PAS was scheduled for July 9-10, 1985, but was cancelled and S&W
was placed on the AVL-based on the NRC letter from the Vendor
Inspection Branch dated August 1983 approving the S&W QA topical
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report, SWSQAP 1-74, Revision D.
The P0 nor any of its supplements
impose this QA topical on S&W, nor is there other documentation
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indicating that S&W is using this topical for the activities procured
in this P0. This oversight was identified to TUGCo personnel and P0
Supplement 5 was initiated and issued on February 18, 1986, imposing
Revision D of SWSQAP 1-74 on all applicable S&W activities.
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In addition to the above reviews the NRC inspectors reviewed the
various revisions of the AVL from July 1983 to January 1986,
comparing the vendors on the AVL with the required audits and
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evaluations. The AVLs prior to 1985 contained at least 18 vendors
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with delinquent audits. This condition was identified in NRC
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Inspection Report 50-445/8432 as a violation. By the end of-CY 1985
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the vendors on the AVL were current based on the NRC inspector's
review of vendor audits and evaluation reports compared with the
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" active" vendors on Revision 24 of the AVL dated January 1986. This
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recovered control was the result of: (1)'deliberateauditand
evaluation scheduling; (2) the re-statusing of applicable vendors to
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" Inactive" or completely deleting them; and (3) the adoption by TUGCo
and subsequent NRC approval of Regulatory Guide 1.144, Revision 1,
which permits triannual audits with annual evaluations of vendor.
performance.-
d.
Internal Audits and Auditors
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During the NRC inspection of the TUGCo QA audit program, the
following documents were reviewed: audit procedures, 1985 and 1986
audit schedules, audit reports, and audit records.
The "TUGCo Dallas Procedures / Instructions Manual" was reviewed to
verify procedural control-of QA Division organization, personnel
indoctrination and training, QA manual, QA records, document control,
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and corrective action relative to the audit program. Procedural
controls were adequate except for two areas. Methods to provide
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assurance that the applicable elements of the_QA program were audited
annually were not procedurally defined, and review of documents that
input to the audit plan / schedule was not documented formally.
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The qualifications of the audit and vendor surveillance staff were
reviewed. The results of this review will be used in assessing the
CPRT activities on ISAP No. Vll.a.4. Auditors added to the staff in
1985 increased the total staff number and the average years of
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experience. NRC review of the 1985 audit schedule as performed found
the construction audit schedule had been met.
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Twelve audit packages from 1985 were reviewed to determine adequacy
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of audit team makeup, time spent on audits, audit and audit checklist
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preparations, audit documentation, and. followup of corrective action.
The twelve audit samples included audits of document control,
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engineering, procurement, QA/QC, operations, and site contractors.
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In all cases, audit preparation, performance, and followup were in
compliance with applicable procedures. One audit, TCP 85-10, on
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valve assembly and installation had open deficiencies, but review
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showed that correspondence was timely and that an identified
deficiency was receiving a higher level of management attention as
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required by procedure.
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The 1985 audit schedule was reviewed to determine if all applicable
elements of the QA program had been audited. A matrix of audits
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performed versus applicable criteria of Appendix B to 10 CFR Part 50
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had been developed by the QA audit supervisor for tracking purposes.
This matrix,- however, is not under procedural control and did not
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assure that all applicable elements of the QA program were audited in
full; only that the criteria identified had been audited in part.
Thisitemremainsopen(446/8602-0-02).
A required document review for impact on the audit plan / schedule of
documents such as: HRC correspondence, CPSES Procedures / Instructions,
Construction /Startup Surveillance and Status Reports, and Quality
Trend Reports was stated by the QA audit supervisor to have been
performed. This review, however, was not formally documented relative
to its performance, what personnel performed the review, and the
outcome of the review. This subject is considered an open item
(446/8602-0-03).
4.
During the period of TRT activity at CPSES, and subsequent HRC
inspections, the QA site surveillance program was found to be poorly
structured and ineffectively implemented.
In March 1985, the applicant
reorganized and restructured the surveillance program, and revised
existing procedures or provided new procedures for its implementation.
This program is conducted under the responsibility of the surveillance
supervisor who reports directly to the QC manager.
The QC surveillance program implemented at CPSES is structured to provide
a vehicle by which ongoing construction, inspection and startup/ turnover
related activities may be monitored by site certified personnel to assure
proper and consistent methods of construction, inspection, and
documentation are maintained.
Currently, the surveillance progran is divided into four areas:
(a) Construction,(b)RecordReview,(c) Inspection,and
(d) Startup/ Turnover, with a QC supervisor for each area.
a.
Construction Surveillance Group
Construction surveillances, implemented by TUGCo
Procedure CP-QP-19.0, " Construction Start-up/ Turnover (CST)
Surveillances," provide for surveillance. of construction activities
in accordance with site construction procedures. These surveillances
are performed by observation of work in progress, completed work,
and/or review of documentation. The areas of activity covered by
these surveillances include construction, fabrication / installation,
equipment storage and maintenance, and housekeeping practices.
Surveillances are performed using prepared checklists whose
attributes are derived from the procedures that control the activity
under surveillance. Personnel conducting surveillances are trained
in the applicable procedures and certified as surveillance
specialists.
The NRC inspector's review of CP-QP-19.0 found that the procedure
provides adequate description and direction for the conduct of
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surveillances by this group. Surveillances are unscheduled;.however,
the area and frequency are determined by the surveillance supervisor
with consideration given to the level of construction activity, the
results of previous surveillances, and project trend information.
Surveillances by this current group were initiated in October 1985.
During December 1985 and January 1986, the emphasis was directed to
the as-built verification of cable tray supports in Unit 2 to prevent
a repeat of the problems encountered in Unit 1.
These support
surveillances resulted in corrective action that revised the as-built
verification inspection procedure.
This inspector reviewed five surveillance reports conducted in
October 1985 and found that all the reports revealed compliance with
the procedure; however, the checklists did not identify the specific
items observed, nor were the results of observations other than
" SAT /UNSAT" clearly documented.
In discussions with the group
supervisor, he stated that this condition was recognized by the
surveillance supervisor and program improvement was implemented.
This inspector's review of documentation for surveillances performed
in January and February 1986 noted improvements and found that
identification of items and observation results were adequately
documented.
b.
Records Surveillance Group
This surveillance activity, implemented by TUGCo
Procedure CP-QP-19.11A, " Records Surveillance," provides a review of
documentation for permanently installed items to verify that Unit 2
QA records package contents are complete and documents contained
therein(e.g.
reports,etc.}operationstraveler,welddatacards, inspection
are legible, accurate, and in compliance with the
applicable procedures.
Reviews are accomplished'using a generic
surveillance report checklist of attributes common to all record
packages. Deficiencies, when found, are recorded on the surveillance
checklist which then becomes the surveillance deficiency report (SDR)
issued for the required corrective action.
Followup verification for correction of SDRs is accomplished and
documented within the surveillance group by the surveillance document
reviewer who originated the report or the group supervisor. Closeout
of the SDR is documented in either case by the supervisor's
signature.
If an NCR is issued, it is processed in accordance with
existing site procedures for the control of nonconformances.
Verification of the implementation of the NCR disposition is
accomplished by QE and QC external to the records surveillance group.
Copies of the surveillance reports are issued to the corrective
action group for trending. Personnel performing surveillances are
trained and certified as documentation reviewers.
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The NRC inspector reviewed Procedure CP-QP-19.11A and found that the
procedure is sufficiently detailed as to purpose and scope, and is
adequately descriptive of the attributes necessary for the
performance of the reviews and detection of deficiencies.
Additionally, the NRC inspector reviewed all documentation
surveillance reports for January, February, and March 1986 and found
that the performance and reporting of these-surveillances was in
compliance with the controlling procedure.
c.
Inspection Surveillance Group
Inspection surveillances, implemented by TUGCo Procedure CP-QP-19.13,
" Inspection Surveillances," provide surveillances of construction-
related QC inspection effectiveness by sample reinspection of QC
accepted item / component and/or observations of inprocess QC
inspection activities. Surveillances are tentatively scheduled on a
monthly basis with concurrence of the site QC manager, with
consideration given to the level of QC field inspection activity,
results of previous surveillances, and Project Connodity Trend Report
information.- Component reinspection is conducted on selected items,
with emphasis placed on assessing hardware quality through
verification of hardware and evaluation of original inspector results
when unsatisfactory conditions are found.
Personnel performing these
surveillances are trained in the applicable construction and QC
inspection procedures and certified as inspection surveillance
specialists. Deficiencies detected by these surveillances are
documented on NCRs that are processed under the existing site
nonconformance procedure. Verification of the implementation of the
NCR disposition and closeout is accomplished by QE and QC external to
the inspection surveillance group.
Although the inspection surveillance program was reorganized and
restructured in late 1985, the inspection surveillance group activity
has been-limited due to the time raquired for hiring, indoctrination,
training, and certification of personnel and procedure preparation
and approval.
Inspection surveillances were well underway by
March 1986.
The NRC inspector's review of CP-QP-19.13 found that the procedure
provides adequate description and direction for the conduct of
surveillances by this group. Additionally, this inspector reviewed
the reports for all surveillances (18) conducted through the end of
March and found that the surveillances were performed and documented
in compliance with the procedure.
d.
Startup/ Turnover Surveillance Group
The startup/ turnover surveillances, implemented by TUGCo Procedure
CP-QP-19.0, " Construction, Startup/ Turnover Surveillances," provide
surveillances of activities as outlined in the TUGCo startup
administrativeprocedures(SAPS). Surveillances include the review
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of the SAPS for progransnatic requirements, the witnessing of
prerequisite tests, and establishing " hold points" for witness, by
this group, on all pre-operational tests conducted by the startup-
group. Additional responsibility includes surveillance of system
turnover activities.. Personnel performing these surveillances are
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trained in the applicable procedures and certified as surveillance
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specialists.
The NRC inspector's review of CP-QP-19.0 found that the procedure
provides adequate description and direction for the conduct of
surveillances by this group. Surveillances are unscheduled; however,
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the area and frequency are determined by the surveillance supervisor
with consideration given to the level of startup/ turnover activity,
the results of previous surveillances, and project trend report
.
information. Deficiencies detected are addressed in SDRs. Followup
verification for correction of deficiencies is accomplished and
documented within the surveillance group by the specialist who
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originated the report, or the group supervisor.
If an NCR is issued,
it is processed in accordance with existing site procedures for the
control of nonconformances.
Verification of the implementation of
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the NCR disposition is accomplished by QE and QC external to this-
surveillance group.
The NRC~ inspector reviewed the reports for the months of October 1985
.
through February 1986 and found that, although the surveillances were
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in compliance with procedures, the checklists did not adequately
identify the item under surveillance and the results of observations
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were poorly documented. This condition was recognized by the
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surveillance supervisor and program improvement had been im)lemented.
The MRC inspector's review of surveillance reports for Marci 1986
found that the condition had been corrected.
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e.
Training Qualification and Certification
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TUGCo surveillance personnel are indoctrinated, trained, qualified,
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and certified in accordance with TUGCo Procrfure CP-QP-19.9,
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" Training, Qualification and Certification of Surveillance
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Specialists." This procedure provides the detailed requirements for
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the level of activity performed by the specialists in each of the
four surveillance groups and identifies the documentation to be
retained in each employee's training file.
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The NRC inspector reviewed the files for all surveillance personnel
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to determine that the documentation and file contents provide
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objective evidence that the procedural requisites leading to
certification have been met, were in compliance with the procedure,
and that there was evidence of TUGCo verification of education and
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previous employment. This review found that on-the-job
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training (0JT) was waived for three specialists. The waivers were
based on prior certification as QA specialists in startup/ turnover
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surveillances and the justification was documented in their file.
One document reviewer had completed the training requirements but had
not been certified to date. The NRC inspector found that the work
performed by this reviewer was approved by the supervisor in
accordance with procedural requirements.
The NRC inspector's review found that the conduct of training,
qualification, and certification of surveillance specialists and the
supporting documentation was in compliance with procedures.
f.
Review of Surveiliance Reports and SDRs
The NRC inspector reviewed surveillance reports to determine
compliance with the applicable procedures. This review found that
the surveillance checklist attributes developed by the surveillance
specialists were derived from the procedures, drawings,
specifications, and other documents applicable to the activity, item,
component, or system and the source documents were identified on the
checklist. The supervisor's signature on the checklist indicated his
approval prior to use. Observations were recorded on the checklists
and SDRs or NCRs, if applicable, were issued.
SDRs were processed in accordance with TUGCo Procedure CP-QP-19.10,
" Surveillance Deficiency Reports." The NRC inspector's review of
this procedure found it adequate in its descriptive detail and
direction to control the processing of the SDRs. The NRC inspector
reviewed a sample of SDRs from each of the applicable surveillance
groups and found that the deficiencies were adequately described, the
corrective action was clearly stated, and followup verification by
the SDR originator was documented. Additionally, the required review
and approval signatures were entered.
All surveillance group logs reviewed were current for the issue,
closure, and transmittal of the surveillance reports, including the
SDRs, to the assigned records storage location.
g.
Trend Evaluation and Reporting
In addition to the detection and correction of deficiencies, the
determination of QC inspection effectiveness, and the acceptable
quality of hardware, one of the surveillance program objectives was
to assess the collective output of the surveillance groups by
performing trend evaluations to ascertain the need for programmatic
corrective actions.
In interviews with the corrective action group supervisor,
responsible for the trend analyses, and the site QC manager they
stated that the trend evaluations of surveillance reports through
Itarch 1986 had not yielded sufficient data to establish trends.
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The QA/QC corrective action group (CAG), responsible for trending,
has performed preliminary assessments of the available surveillance
data on an ongoing basis. The site QC manager's evaluation of the
preliminary assessments to date resulted in additional training of
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personnel and' procedure revisions to increase effectiveness.
Additionally, the CAG is utilizing these preliminary . assessments as
4
input to the development of criteria for establishing the trending
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program of surveillance findings. The NRC inspector reviewed the
preliminary assessments and in further discussions the site QC
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manager stated that the initial surveillance program trending results
will be included in the April 1986 trend report.
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This inspection found that the trending program was implemented in
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compliance with the applicable procedures, although still in its
formative stages. The pending inclusion of the surveillance program
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trends in the April 1986 trend report will remain an open item
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(446/8602-0-04).
Future NRC inspections will consider the
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effectiveness of the trend criteria, the evaluation process, and the
trend results.
h.
Summary and Conclusion
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This inspection found that the applicable procedures were adequate to
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control the surveillance process. The review of surveillance
checklists, surveillance reports, SDRs, verification of personnel
certifications, and interviews with supervisors and surveillance
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personnel found that the surveillance program, except for the open
item regarding trending, was implemented in compliance with the
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applicable procedures.
During this inspection, an additional concern was identified that
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requires further review by the NRC. The surveillance function
reports organizational 1y to the site QC manager as do the QE group
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and all QC inspector groups, ASME and non ASME. The majority of the
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output of the surveillance group activities is a direct measure of
the performance and effectiveness of these groups, and therefore of
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the site QC manager's assigned responsibilities. Consequently, there
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exists a potential for violation of Criterion I of 10 CFR Part 50,
Appendix B, which requires that organizations (i.e., the surveillence
groups) have sufficient organizational freedom to identify quality
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problems and initiate, reconnend, or provide solutions. This subject
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isconsideredanopenitem(446/8602-0-05).
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No violations or deviations were identified in this area of
inspection.
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5.
Assessment of Allegations
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a.
4-85-A-121 and 4-85-A-131: Improper Actions Concerning the Inspection
Process Control Group
The following allegations were made by four individuals concerning
theInspectionProcessControl(IPC) group: 4-85-A-121, QC inspectors
are signing inspection reports " SAT" when the proper entry should be
"NA," further this individual did not trust the Safeteam; and
4-85-A-131, (1) IPC personnel were directed to document problems on
three-part memos, not on NCRs; (2) proper action was not taken in all
cases regarding problems documented on three-part memos; e.g., NCRs
not written, other paperwork not processed, or generic evaluation not
performed.
The NRC inspector reviewed the IPC organization and controlling
procedures. The IPC group was established in early 1985 to
systematically perform reliability assessments of the QC inspection
process by independently inspecting samples of post-process
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inspection attributes and identifying when process corrective action
was necessary. Procedures reviewed controlling this activity were
IPC-1, " Organization and Administration of the Inspection Process
Control Program," and IPC-3, " Reliability Assessment Program."
IPC-3
required that all current QC inspectors work be sampled at the end of
every 30 day period and the results be documented in a Sample Recheck
Request / Report (SRRR) form. The SRRR forms, when rejectable
attributes were identified, were sent to QE who initiated the
1
necessary corrective action.
IPC personnel were advised of the
action taken by QE for information purposes only.
(1) 4-85-A-121
The NRC inspector reviewed the completed SRRR forms for all QC
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inspectors. A sample of SRRR forms that were in process (QE
review not completed) was also reviewed. The dispositioning of
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identified rejectable attributes for 24 QC inspectors (70 SRRR
forms) was reviewed. This review included all of the associated
documentation; e.g., drawings, changes, NCRs, and inspection
reports (irs).
Of the 70 SRRR forms reviewed, the NRC inspector found 80
examples where " SAT" was entered by the QC inspector when "NA"
would have been the proper entry. Examples of IR attributes
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where " SAT" was incorrectly entered were Nelson stud spacing,
but liiltis were used; triax cable, but not used; ring torque lug,
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but ring torque lug not used; cable tray rung spacing, but it
was a solid tray; and supports, but no supports.
In a few of
the above examples an NCR was issued. When an NCR was issued,
the disposition was usually to correct the documentation,
nothing else indicated. When no NCR was issued, the corrective
action ranged from no action to a commitment that the QC
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inspector's supervisor would be advised. These examples
occurred from July 1985 to December 1985, when the IPC program
was revised and new personnel assigned. The QE basis for no
action in several of the examples where no NCRs were issued, was
that marking " SAT" where "NA" was applicable does not render the
quality of the item unacceptable. The NRC inspector agrees;
however, the numerous occurrences of this problem does indicate
a condition that is adverse to quality, which in the absence of
corrective action is a violation of Criterion XVI of 10 CFR Part 50, Appendix B.
Monthly IPC reliability assessment reports
to QC management identified this as a problem. The October and
November 1985 reports identified this problem as a generic
deficiency and requested action from the QC supervisor. The QC
supervisor sent a memo on January 24, 1986, to the training
supervisor to prepare a class for training personnel in the
implementation of CP-QP-18.0, " Inspection Report," but did not
mention the " SAT vs NA" problem. As of the end of March, this
training had not been scheduled. The foregoing is considered a
violation of Criterion XVI of 10 CFR Part 50, Appendix B
(446/8602-V-06).
In sumary, numerous examples were identified that substantiate
the allegation that " SAT" was used on inspection reports when
"NA" should have been used.
Since no details or basis were provided concerning this
individual's distrust of the Safeteam, the NRC was unable to
assess this concern. The CPRT is evaluating the exit interview
p(rogram established for the site which includes the Safeteam
ISAP No. VII.a.6). The NRC will be inspecting the
implementation of this effort.
(2) 4-85-A-131
The NRC inspector's review of applicable procedures did not
identify any provisions for the use of three-part memos to
document problems.
During the NRC inspector's review of the IPC monthly reliability
assessment reports, it was noted in the September and
October 1985 reports that potential discrepancies unrelated to
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the attributes being inspected were identified on three-part
memos and sent to the applicable QE group. On further review
the NRC inspector found that not only were three-part memos
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being used to document potential nonconforming conditions, but
the three-part memos were not being tracked and there was no
formal followup to assure that they were properly dispositioned.
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This condition was identified as a violation in a previous HRC
InspectionReport(50-445/86-01). An informal log of the
three-part rcemos was found within the IPC group, but there was
no assurance that all memos had been logged.
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Forty-seven memos were identified on this informal log; however,
six can no longer be found. The 47 problems referred to in the
log were reviewed by the NRC inspector. The problems identified
on some of the memos that were located resulted in NCRs being-
issued, while others appeared to require an NCR but none were
issued. On February 28, 1986,_NCR E-86-200637 was issued
requiring all retrievable memos to be reviewed and where
nonconforming conditions were found to; exist an NCR would be
issued.
Included in the action on.this NCR will be a reinspection in the
areas where the six missing three-part memos originated. The
conditions identified on the informal log will be the point of
focus in an attempt to identify the source of the original
concerns. This area will be inspected further by the NRC when
action on the NCR is completed. Accordingly, this matter is
consideredopen(446/E602-0-07).
In conclusion, the allegations were substantiated, with one
exception. Numerous examples were found where QC inspectors
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were completing irs with " SAT" when "NA" was the appropriate
I
entry (4-85-A-121). This was recognized by TUGCo as a generic
problem, but they failed to identify the magnitude of the
problem or take prompt action to correct, resulting in a
violation of 10 CFR Part 50, Appendix B. -It could not be
established that IPC personnel were directed to docuent
problemsonthree-partmemos(4-85-A-131);~however,this
practice was permitted and'was also identified as a violation.
It could not be determined that proper action was taken
concerning.the problems identified on these three-part memos in
every case. TUGCo recognized this and issued an NCR to
reevaluate all of the actions taken. The NRC will inspect the
disposition of this NCR when it is completed. The lack of trust
in the Safeteam on the part of one alleger could not be assessed
due to the lack of specifics; however, this program is being
evaluated by the CPRT and the NRC is inspecting the
implementation of this effort.
b.
-AQ-161 (4-85-A-31): QA Deficiencies Not Documented
It was alleged that Operations QA handled deficiencies without
documenting problems; thus, no preventative actions were effected
and, consequently, QA problems identified by operations did not
appear to be reported to the appropriate level of management.
The FSAR commitments for control of nonconforming materials, parts
and components were reviewed. Section 17.2.15 of the FSAR commits
and requires that nonconforming conditions be identified, documented,
reviewed, dispositioned, and reinspected for acceptability after
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dispositioning is completed. Further, Section 17.2.16 commits to
reporting significant conditions adverse to quality to the
appropriate level of management.
To verify the inniementation of the above nonconformance reporting
commitments, the NRC inspectors reviewed ongoing work to determine if
nonconforming conditions were documented, dispositioned, and
-appropriate corrective action taken to prevent recurrence.
In NRC
walkdowns of selected rooms, it was observed that nonconforming
conditions for safety-related hardware were brought into compliance
with the item's specification and/or drawing without an NCR being
written. These occurrences, as well as other departures from the
nonconformance reporting system discovered during NRC walkdowns, were
reported as a violation in a previous Region IV Inspection Report
(50-445/86-01).
In assessing the portion of the allegation dealing with problems not
being reported to management, it was found that NCRs were not
reviewed on a periodic basis for adverse quality trends as required
by the Op(OA.C&QAP), Section 3.9, "Nonconformances, Deficiencies and
erations Administrative Control and Quality Assurance
Program
Corrective Action." Consequently, the commitment that periodic
analysis of NCRs be forwarded to management to show quality trends-
did not occur. Applicant QA personnel were interviewed to determine
why the deviation from this commitment occurred. The reply was that
trend analysis performed in the early days of the Operations QA
program did not identify meaningful trends or recurring significant
conditions adverse to quality.
For calendar years 1984 and 1985, 421
and 240 NCRs, respectively, were written.
During the assessment of the operations nonconformance reporting
system i
identify,t was observed that the applicant has a separate method to
report,'and take corrective action on procedural
(programmatic) deficiencies that is different from the methods used
on hardware deficiencies. The deficiency report is used to document
procedural deficiencies.and the NCR is used to document hardware
deficiencies. Each employee is required to report observed
procedural deficiencies on a deficiency report and submit it to
operations QA for processing. The NRC inspector found that for 1985
approximately 50 percent of the deficiency reports (203) were written
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by non-quality personnel. Monthly, quarterly, and annual trend data
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reports were published presenting those deficiency reports. These
trend reports were issued to various levels of management including
onsite and offsite senior management.
Based on trend analysis of
deficiency reports, recurring conditions found adverse to quality
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were reported on corrective action requests to the appropriate levels
.of management. Therefore, the procedural system for deficiency
reporting does identify, document, and report programmatic problems
to the appropriate levels of management.
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Deficiency reporting procedure, STA-404, Revisions 1, 2, and 3, used
from February 1982 to January 1986 (current), were reviewed. The NRC
inspector found no revision that clearly differentiated between the
use of a deficiency report and NCR in the purpose, applicability, and
definitions sections. Revision 2 dated June 1985 revised the
deficiency report process instructions to include blocks "yes" or
"no" for specifying an NCR is required in connection with the
deficiency reports. Therefore, the deficiency reports written prior
to June 1985 potentially may not have NCRs written, even if hardware
deficiencies were present as a result of procedural violations that
were reported in the deficiency report system. Accordingly, the
deficiency reporting system used prior to June 1985 may not have
caused the identification and reporting of nonconforming hardware on
NCRs.
In conclusion, the potential that Operations QA corrected hardware
nonconformances without documenting them on an NCR, and thus without
corrective action to prevent recurrence, does exist. Accordingly,
this allegation was substantiated.
The portion of the allegation that QA problems were not reported to
the proper level of management was partially substantiated. NCRs
were not trended to identify conditions adverse to quality and
therefore not reported to management. However, quality trends for
deficiency reports were reported to the applicable levels of
management. The substantiation of this allegation has the following
implications in the Operations QA area: (1)inadequateidentification
and reporting of nonconforming conditions; (2) no NCR trend analysis
for 1984 and 1985; and (3) no evaluation of deficiency reports (prior
to June 1985) to determine if an NCR was required in connection with
the deficiency reports. These items have been identified as a
violation (445/8603-V-02).
c.
'AQ-156 (4-85-A30) and AQ-163 (A-85-A31): Improper Processing Of
Deficiencies
It was alleged that surveillance management did not initiate
corrective action when a surveillance identified QC directing craft
intheinstallationofequipment(AQ-156);andQCinspectorsallowed
craft to correct deficiencies during final QC inspections without QC
recording the "UNSAT" condition on the IR; thus, circumventing the
trendingprogram(AQ-163).
The NRC inspector determined that although the allegations were
resented by different allegers they pertained to the same subject
p(event). The allegers referred to a recent surveillance of
electrical conduit installation, but did not identify the
surveillance report by number or date. The NRC inspector searched
the surveillance report files and interviewed the construction
startup/ turnover surveillance (CSTS) supervisor and found that
surveillance report DSR 85-023 dated March 28, 1985, was consistent
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with the subject and time frame expressed by the allegers.
DSR 85-023 contained information which provided the details and
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. probable basis for the allegations.
(1) AQ-156
Based on the alleger's statements, the allegation was
characterized that QC was instructing electrical craft how to
install electrical conduit. Craft had not finished the job
correctly and QC was telling craft what had been-done wrong;
i.e., the junction box has to go this way, or this has to be
over here. The alleger perceived the foregoing as a concern
that QC was instructing craft in the performance of their job
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and that when the surveillance supervisor was advised of this
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concern he did not initiate any action.
In review of the applicable construction and QC inspection
procedures for this assessment; the NRC inspector did not find
j
any procedural constraints that would prohibit QC inspectors
from providing clarification of deficiencies, nor from providing
recommendations for their correction. The alleger did not
identify, nor did the NRC inspector find any procedural
deviations or program violations. The alleger's concern was
,
related to an activity which appeared to be an example of the
proper implementation of 10 CFR Part 50, Appendix B,
i
Criterion I, " Organization," which states in part:
"The authority and duties of persons and organizations
performing quality assurance functions shall be clearly
established and delineated in writing. Such persons and
organizations shall have sufficient authority and
i
organizational freedom to identify quality problems, to
initiate, recomend, or provide solutions, and to verify
the implementation of solutions."
.
This assessment found that the procedures in place complied with
this criterion and the alleged practice was not a violation.
The surveillance supervisor did not agree that the described
activity constituted "QC instructing craft," but rather was an
example of QC implementing the requirements of 10 CFR Part 50,
'
Appendix B.
The NRC's assessment of this allegation supports
the decision of the surveillance supervisor.
While the allegation was substantiated, both QL and the
'
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surveillance supervisor were acting in compliance with
requirements.
,
(2) AQ-163
Surveillance report DSR 85-023, discussed above, also provided
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the detail necessary to the definition and assessment of this
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allegation. This allegation is further characterized that
during QC inspections the accompanying craft would correct an
"UNSAT" condition detected by-the inspector, but there is a
gotentialthattheinspectorwouldnotdocumenttheinitial
UNSAT" on the inspection report.
If this occurred, the "UNSAT"
finding would not be captured as input to the trending program.
The NRC inspector found that this allegation was identified as a
'.
concern in DSR 85-023 issued to the site QC inspection
supervisor. The QC supervisor's response cited the words of
TUGCo Procedure CP-QP-18.0, " Inspection Report," that required
the QC inspector to record any identified "UNSAT" condition
without regard to the time or circumstances under which the
"UNSAT" condition was found. The surveillance report package
contained evidence that the res)onse was reviewed and accepted
by the surveillance specialist w1o identified the concern, and
the surveillance supervisor had reviewed, approved and closed
the report.
The NRC inspector interviewed the electrical QC inspection
supervisor, electrical inspectors, the site QC inspection
supervisor, and mechanical inspectors. The NRC inspector
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described the concern being assessed. These individuals were in
agreement that it was common practice for craft to accompany and
correct "UNSAT" conditions identified during QC inspections. As
the procedure required, the inspector would record the "UNSAT"
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condition, notwithstanding its immediate correction, and there
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was no resistance by craft to this process. These individuals
also stated they were not aware of any cases of procedural
noncompliance regarding the recording of this type of "UNSAT"
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conditions.
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Based on reviews of procedures, documentation, and interviews
!
with personnel, this assessment did not find any evidence that
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"UNSAT" conditions were not recorded nor that the construction
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and inspection activities related to the concern were conducted
in other than compliance with the applicable procedures. Since
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there was )rocedural compliance and the alleger did not identify
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or state t1at there was procedural noncompliance, there is
assurance that the "UNSAT" conditions were identified as
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required and included in the trending program. Accordingly,
this allegation was not substantiated.
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d.
4-85-A-130: A concern was raised by an anonymous caller that a
designchangeauthorization(DCA)allowedthereductionofNo.16AWG
4
sized electrical wire to No. 18 AWG size, and that this was a
!
breakdown of the engineering controls. The DCA identified by the
caller was DCA 18,016 dated July 8, 1983. This DCA affects the
2
internal wiring of four termination cabinets, 1-TC22 and 1-TC23 in
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Unit 1 and 2-TC22 and 2-TC23 in Unit 2.
These termination cabinets
are located in their respective unit's lower cable spreading room.
When a cable connector was added to each of these termination
cabinets in order to connect its internal wiring to the appropriate
section of the main control board, it was determined that the
connector would only accept connection to No.18 AWG, or smaller,
electrical wire. The cabinets' internal wiring,'which was-installed
by the vendor, was specified on drawings numbered W-TC22701-D,
W-TC22702-D, W-TC23701-0 and W-TC23702-D, for cabinets 1-TC22,
2-TC22,'l-TC23 and 2-TC23, respectively, to be 16 AWG minimum
stranded, copper with 17 mil Tefzel insulation, gray.
In an effort
to resolve the problem of the installed wiring being larger than the
connector would accept, DCA 18,016 was initiated.
The DCA 18,016 solution states, "Use the #16 AWG Tefzel wire for the
internal connections from the terminal strip to the connector.
Remove enough strands from the #16 AWG, by using the #18 AWG
stripper, to reduce the size of the wire to #18 AWG at the connector
end of wires. Note: This DCA is for clarification only. Design
review is not necessary." A Field Design Change - Design
Verification Report was, however, completed on June 3,1984
This
report concluded, based on a telephone conversation with the vendor,
that " approval of this DCA is based on the assurance that the #16 AWG
Tefzel wire will become no less than a size #18 AWG when the strands
are removed."
Following the NRC inspector's questioning of the feasibility of
performing the DCA's proposed solution, he was informed that tests
conducted by the applicant confirmed the removal of strands with a
wire stripper was impractical.
Initial inspection of this subject identified what appeared to the
NRC inspector to be, less than 16 AWG size internal wiring connected
-to terminal board, TB-2, in the Unit 1 termination cabinets, 1-TC22
and 1-TC23; additionally, these wires had orange and green colored
insulation, respectively. The wiring in the Unit 2 cabinets, 2-TC22
and 2-TC23, appeared to the NRC inspector to be the correct wire size
which had the specified, gray colored insulation.
In an effort to
verify the acceptability of the wiring in the Unit 1 cabinets, a
review of the vendor surveillance, receiving inspection and
installation / modification documentation was conducted. The NRC
inspector was unable to locate any record that other than the
specified (#16~AWG, gray Tefzel insulated) wiring had been installed
by the vendor or any documentation to indicate that a wiring change
had been authorized onsite. The applicant's representatives,
however, have provided information, in response to the NRC
inspector's requests, to indicate that changes to the installed
wiring in 1-TC22 and 1-TC23 have been authorized by DCAs 8939 and
8940 for the use of additional wire, if required, to complete earlier
.
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wiring modifications; however, no records had been located, as of the
end of this report period to indicate which wire was actually
installed nor how the #16AWG wire was reduced to #18AWG. ThisJmatter
is an unresolved item ending completion of the applicant and NRC
reviews (445/8603-U-03.-
The applicant's representatives also provided the NRC inspector with
completed copies of the construction operation travelers
(EE85-11696-2-5202 and EE85-11693-2-5202) which were used to install
the cable connectors in the Unit 2 termination cabinets, 2-TC22 and
2-TC23. -Review of these documents-indicated that it was recognized
that the solution proposed in DCA 18,016 was impractical, and
instructions were included to use small, diagonal pliers to remove 6
of the 19 strands from the No. 16 AWG wire so that connection to the
connector could be accomplished. The DCA, however, was not revised
to reflect this new solution. The failure to revise the DCA is an
apparent violation of Criterion V of Appendix B to 10 CFR Part 50
(446/8602-V-08).
6.
Pipe Supports
During a previous pipe support inspection, the NRC inspector observed two
baseplates of pipe support No. AF-1-035-029-533A, which were attached to
the wall with eight 1" Hilti Kwik Bolts, three of which were installed
through an embed plate. Subsequent to this inspection, additional review
of the documentation identified a violation.
A B&R memo dated October 19, 1980, addressed drilling through an embed
plate and hitting a rebar at a 5-1/2" depth that appeared to run at a 45'
angle to the vertical. The response from the design engineer stated that
no structural rebar should be encountered at this location and depth and
was probably a construction installed " Template" bar and could be cut as
required.
On November 6, 1980, NCR M-80-00161 was initiated, addressing drilling
through the rebar and the requirements of B&R Procedure CEl-20 which
states that engineering approval is required to cut rebar.
In addition,
the NCR stated that the above mentioned memo gave approval for drilling
through the probable template bar at the 5-1/2" depth; however, the NCR
also identified two other cut rebar. The tentative disposition of the NCR
!
was "use as is."
In support of this disposition, DCA 9091 was initiated
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on November 18, 1980, addressing one cut rebar. The solution of the DCA
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stated that the described condition is acceptable. The DCA also listed
the NCR as being supporting documentation. As a result of the DCA
approval, the NCR was closed on December 19, 1980, and it referenced
DCA 9091 as support for the "use as is" disposition.
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The failure to disposition all of the identified nonconforming conditions
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isaviolation(445/8603-V-04).
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7.
Followup on NRR Liner Plate Concerns
A public meeting was held on November 5-6, 1985, in Granbury, Texas, to
discuss licensing issues for the Comanche Peak project. The subject of
deviations identified during the reinspection / verification sampling
program was addressed by ERC and NRR.
Personnel from ERC indicated that
excessive undercut on containment liner welding had been identified as a
deviation from inspection procedure requirements, and documented on a DR.
The safety significance evaluation (SSE) group from ERC analyzed specific
cases where excessive undercut exists and determined that the safety
function of the containment liner had not been impaired. The basis for
this conclusion was that the specific material properties provide a design
margin that is not compromised by the depth of the undercut identified.
Personnel from NRR expressed concern that the identified deviation was a
code violation (Proposed Section III, Division 2 of the ASME Code) and
questioned what actions would be taken by the applicant. The team leader
for ERC's QA/QC review team responded that a minimum of three actions
would be taken by the applicant: determine if corrective action is
necessary; determine if applicable commitments were violated; and
determine reportability requirements per 10 CFR Part 50.55(e).
Due to the expressed concern identified by NRR, a n. ore comprehensive
evaluation of quality of construction for containment liner plate was
initiated. The NRC inspector identified that ERC Verification Package
No. I-S-LINR-060 DR-2 documented undercut greater than 1/32", which is a
deviation from quality standards required by paragraph CC-4542.3 in
ACI-359. This paragraph states, "The surface of welds shall be free from
coarse ripples or grooves, overlaps, and abrupt ridges or valleys. Abrupt
changes in section thickness such as undercuts or reinforcements which do
not exceed 1/32", and which do not encroach on the section thickness
required to satisfy the rules of CC-3000, are permitted. The surface
condition of the finished weld shall be suitable for the proper
interpretation of nondestructive examinations (NDEs) of the weld.
If the
surface of the weld requires grinding, care shall be taken to avoid
reducing the weld or base material below the required thickness."
In addition to the above requirement, G&H Specification 2323-SS-14,
Revision 3, paragraph 8.4.2.3 states, "The surface of welds shall be free
from coarse ripples or grooves, overlaps, and abrupt ridges or valleys.
Abrupt changes in section thickness stch as undercuts or reinforcements
which do not exceed 1/32 in, and whic'i do not encroach on the section
thickness required to satisfy the design are permitted. The surface
condition of the finished weld shall be suitable for the proper
interpretationofnondestructiveexaminations(NDEs)oftheweld.
If the
surface of the weld requires grinding, care shall be taken to avoid
reducing the weld or base material below the required thickness."
As a result of ERC DR I-S-LINR-060-DR-2 being issued and validated, TUGCo
issued NCR M-85-101128SX. This NCR was awaiting disposition as of the end
of this report period.
Review of the disposition of this NCR is an open
item (446/8602-0-09).
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The NRC inspector reviewed portions of the following containment liner QA
records: welding procedure specification; welder qualification records;
NDE p(CBI) quality assurance manual; CBI RT film and reports of RTrocedu
Co.
examinations; and CBI record drawings, which document all containment
liner weld joint fabrication activities.
While reviewing RT film and reports of RT examination for Unit 2
containment liner welding of seam No. P84, Film #146, the NRC inspector
noted that the term " pickup and reshoot" was entered in the remarks column
and film grading was marked unacceptable for a line entry documenting the
results of Film #146 Tracer 2.
Tracer 2 was required due to weld
inclusions identified by CBI when grading Film #146.
'
Discussion with a.CBI QA superintendent revealed that " pickups" are
surface imperfections that require additional work for cosmetic purposes
on the area in question to comply with specifications, code and/or CBI
requirements and customer /CBI evaluator interpretations.
The NRC inspector reviewed the CBI RT examination procedure,
RTP-(74-2427/8), and noted that paragraph 5.1 states, "The weld ripples or
weldsurfaceirregularitiesonbothinsideandoutside(whereaccessible)
shall be removed by any suitable means to such a degree that the
radiographic image due to any irregularities cannot mask or be confused
with the image of discontinuity."
In addition to the surface preparation
requirement before performing radiographic examination, a CBI inspector
whowascertifiedasbeingqualifiedforvisualexamination(VT),had
signed the finish joint checked column on the record drawing, indicating
that fabrication of the weld joint complied with the applicable
specifications and standards.
Section CC-5521.1.1 of ACI-359 states, in part, "If the 12" radiograph in
the 50-ft-long increment of weld does not meet the acceptance standards,
two 12" film shall be taken at other locations within the 50-ft-long
increment . . . if either of the second radiographs does not meet the
acceatance standards . . . the remaining portion of the 50-ft increment
of tiis weld shall be radiographed."
Subsequent to the unacceptable film grading of Film #146 T2, CBI welders
deposited additional filler material to-resolve the unacceptable linear
indication identified by markup of the radiographic film. The additional
weld material did eliminate the marked-up indication. However, the NRC
inspector identified that an unacceptable linear indication existed at
film location #146 T2 in addition to the " pickup" (additional welding)
performed by CBI to remove an unacceptable linear indication.
Section CC-4545.3.1 of ACI-359, defect removal, states, " Unacceptable
defects detected visually or by the examinations required by CC-5500 shall
be removed by mechanical means or by thermal gauging processes. The area
prepared for repair shall be examined and comply with the requirements of
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Contrary to the requirements of ACI-359, CBI did not expand the
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radiographic film examination of containment liner welding when an
unacceptable tracer location linear indication was identified; performed
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unauthorized, undocumented repair welding at the tracer location; and
failed to implement the required NDE examinations when repair welding was
performed. These findings constitute a violation (446/8602-V-10).
8.
CPRT ISAPs (Excluding ISAP No. VII.c)
a.
Flexible Conduit to Flexible Conduit Separation (ISAP No. I.b.1)
The objectives of this action plan are (1) to determine by testing
and analyses the minimum acceptable separation between two cable
trains within SERVICAIR flex and (2) to reinspect all panels which
potentially could violate the final separation criteria.
Paragraph 4.1.4 of this ISAP requires: (1) revision of
Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical
Details," and any other related documents to reflect this final
separation criteria; (2) revision of the applicable QC inspection
procedures; and (3) review of these revisions by the Review Team
Leader (RTL). NRC inspector review of the above documents disclosed
the following:
(1)DCA21,446, Revision 1,datedOctober8,1985,
approved modifications to the control board internal wiring
separation criteria by providing revised and additional typical
details for separation requirements to Drawing 2323-El-1702-02,
Revision 2; (2) TUGCo Instructions QI-QP-11.3.40, " Post Construction
Inspection of Electrical Equipment and Raceways," Revision 21, dated
January 8,1986, and QI-QP-11.3-28, " Class IE Cable Terminations,"
Revision 28, dated March 7, 1986, both reference the revised
separation requirement by drawing details and specifically discuss
theServicairflexibleconduit;and(3)therewerenorecordsinthe
CPRT files to document the RTL review of the above changes.
Documented review by the RTL will complete this item (NRC
Reference No. 1.b.01.07).
No NRC violations or deviations were identified.
b.
Conduit to Cable Tray Separation (ISAP No. I,b.3)
The oujective of this action plan is to substantiate the
acceptability of the criteria governing the separation between
conduits and cable trays, and submit the evaluation and supporting
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documentation to the NRC.
The NRC inspector evaluated the CPRT files to determine which of the
aspects of this action plan had been completed. The five aspects
submittal to the NRC, (4) preparation, (2) report review, (3) report
involved are: (1) report
personnel qualification, and
(5) acceptance /decisioncriteria.
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Review of the CPRT working files revealed that the initial analysis
of conduit to cable tray separation was.provided by G&H letter dated
September 27, 1984. This analysis was required because no formal
analysis had been performed to justify the design and construction
documents. Review of the G4H analysis by the RTL and the Third Party
Advisor resulted in clarifications to, and the removal of
inconsistent assumptions from, the provided analysis. These problems
were discussed in the RTL's March 12, 1986 memorandum. A final
revision of the analysis was provided in the G&H letter to TUGCo
dated March 6, 1986.
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TheRTLapprovedRevision0oftheresultsreport(RR)onMarch14,
1986, and transmitted the report to the SRT. The SRT requested
certain clarifications to the report which were incorporated into
Revision 1 by the RTL. Revision 1 of the RR was approved by the SRT
on March 26, 1986.
The NRC inspector also reviewed the FSAR change request
documentation.
(A FSAR change request is required to be initiated as
l
part of the Action Plan.) The initial FSAR change request was
submitted to TUGCo by G&H letter dated September 19, 1985; comments
I
by the TUGCo FSAR coordinator have resulted in a finalized change
request.
Further review of the CPRT files for this ISAP indicated that
appropriate personnel resumes and objectivity questionnaires were
included and acceptable; therefore, this aspect of this ISAP is
considered complete.
Revision 1 of the RR concluded that the separation criteria for
conduit to cable trays meets the intent of IEEE-384 (1974) and
Regulatory Guide 1.75, Revision 1, January 1975, and, therefore that
the acceptance criteria had been met and no root cause evaluation was
required.
The formal submittal of the RR will be evaluated for technical
adequacy and documented in separate correspondence.
No NRC violations or deviations were identified,
c.
QC Inspector Qualification (ISAP No. I.d.1)
During this report period, NRC inspections were conducted for the
activities identified by NRC Reference Nos. 1.d.1.03, and 1.d.1.04.
SET Evaluation of ASME and non-ASME Inspector Qualification
(NRC Reference No. 1.d.l.03)
TheNRCinspectorconfirmedthattheSpecialEvaluationTeam(SET)
had completed the Phase II review of the remaining inspector
qualifications by reviewing the sumary sheets for these inspectors.
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Additional inspectors may be added as a result of other ISAPs. The
summary sheets were found complete and to meet the requirements of
this ISAP. Using the Phase II review as a basis, the SET validated
the Phase I reviews conducted by TUGCo Audit Group of non-ASME
inspectors and the Phase I reviews conducted by ERC of ASME
inspectors. These reviews were previously reported by the NRC
inspector. Sumary sheets requiring response from TUGCo are being
addressed. The NRC inspector reviewed 5 percent of the TUGCo
responses that have been completed and found that the TUGCo responses
addressed the SET identified problems. The completed TUGCo responses
have been sent to the ERC QA/QC RTL who is responsible to determine
if inspectors whose qualifications cannot be demonstrated as
satisfactory will be evaluated in Phase III. The NRC inspector will
review the results of these evaluations as they are completed.
No NRC violations er deviations were identified.
Phase III Sample Selection and Reinspection (NRC Reference No. 1.d.1.04)
The NRC inspector reviewed the qualification records system utilized
by TUGCo. The qualification records system was found to be a
computerized program of required qualifications versus inspector
certifications. The system provides a means of ensuring that
collected qualification data can be recorded in a clear and concise
form that is readily retrievable. Additionally, the system provides
an effective means of identifying inspectors requiring updates to
their certification files such as annual evaluations or annual eye
exams. This system is in part a result of recommendations coming
from the implementation of this ISAP.
No violations or deviations were identified.
d.
Guidelines for Administration of QC Inspector Tests (ISAP No. I.d.2)
During this report period, NRC inspections were conducted for the
activities identified by NRC Reference No. 1.d.2.02.
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Evaluate Recomendations and Revise Instructions (NRC Reference
,
No. 1.d.2.02)
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The NRC inspector verified that the subtasks in paragraph 4.1.2 of
this ISAP have been completed. The daughter instructions of
CP-QP-2.1 have been deleted and their training requirements
incorporated into a more comprehensive CP-QP-2.1.
Inspector
certification exams currently in use by TUGCo have been revised to
assure that they meet the current procedural requirements of
CP-QP-2.1. Accomplishment was verified by review of four
examinations and their exam banks of questions. The NRC inspector
also reviewed other TUGCo improvements made to enhance training,
e.g., creation of a " tickler" system to assure updating of inspector
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certifications and eye exams and centralized filing of OJT
requirements. No further NRC inspection is planned for this
activity.
No NRC violations or deviations were identified.
e.
Maintenance of Air Gap Between Concrete Structures (ISAP No. II.c)
Th'e following activities for ISAP No. II.c were reviewed by the NRC.
inspector during this report period:
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Removal of Debris or Rotofoam (NRC Reference No. 2.c.02.00)
The NRC inspector has witnessed cleaning and repair of both single
and double walled gaps on numerous occasions. These inspections
included witnessing the use of a variety of tools used for debris
removal and a review of the overall process.
During this report p(eriod, the NRC inspector witnessed gap cleaning
operations along:
1)theLA-AFwallgapbetweentheAuxiliary
Building and the Fuel Building, (2) the gap between the Unit 1
Reactor Building and the Fuel Building, and (3) the gap between the
Unit 1 Reactor Building and the Auxiliary Building. Most
observations were made from the roof where crews were removing debris
,
at depths of approximately 60 to 90 feet using a variety of specially
built tools. . Activities were observed using remote video equipment.
No NRC violations or deviations were identified.
Analyze Final As-Built Condition (NRC Reference No. 2.c.03.00)
Calculations by G&H of the' minimum gaps required to preclude
interactions of Category I buildings and of the internal structures
and the containment wall of the Reactor Building (calculations
LIS-100c, Set 1 and Set 2) were reviewed by the NRC inspector. These
calculations utilize displacement data from G&H books FMI-IR and
FMI-2R, dated September 1975 and December 1976, respectively. The
NRC review did not extend to the calculations of the relative
displacement data presented in these two books.
The methodology and assumptions used were compared against the design
commitments contained in Sections 3.7 and 3.8 of the Comanche Peak
FSAR. Numerical calculations LIS-100c, Set 1 and Set 2, and the
transfer of relative displacement dats from books FMI-1R and FMI-2R
were. extensively checked.
'
A third party review of these calculations was done by Hansen, Holley
'
and Biggs Inc., Consulting Engineers under contract to TERA, who
concluded that the G&H approach was conservative. The conclusions of
this third party review were examined by the NRC inspector and found
to be consistent with established engineering practices.
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NRC inspections were not performed on other activities during this
report period.
No NRC violations or deviations were identified.
f.
Improper Shortening of Anchor Bolts in Steam Generator Upper
4
Lateral Supports (15AP No. V.b)
.
The following activities for ISAP No.'V.b were reviewed by the NRC
inspector during this report period:
i
Examine Bolts Blind Threaded Holes, and Assembly Dimensional
Tolerances (NRC Reference No. 5.b.03.00)
i
Reinspection of the bolt holes and threads in the steam generator
upper lateral supports for all compartments in Unit 1 began on
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March 25, 1986. The following construction operation travelers were
used for this reinspection:
Compartment No.
Traveler No.
1
CE-86-222-8902
2
CE-86-223-8902
3
CE-86-224-8902
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4
CE-86-225-8902
A total of 144 bolt holes are being reinspected by TUGCo and/or
Westinghouse personnel. The travelers include the reinspection of
the following six attributes:
(1) internal pitch diameter,
(2)internalminordiameter,(3)holedepthandthreadlength,
(4) thread damage, (5) angle of bolt inclination, and (6) bolt to
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base plate gap measurement.
i
The NRC inspector witnessed partial reinspections of from 1 to 6
attributes on the following 13 bolt holes:
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Location
Bolt Hole Nos.
Compartment 1 West End
1W7, 1W9
Compartment 4 West End
4W1, 4W6, 4W10, 4W13, 4W15, 4W17
Compartment 4 East End
4E7, 4E8, 4E9, 4E16, 4E18
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'Four of the above bolt holes were unsatisfactory. Bolt holes 4W1 and
4W6 had thread damage.
Bolt hole 4E7 had a misaligned shim requiring
repair before reinspection. Bolt hole 4W15 had excessive bolt to
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base plate gap.
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The NRC inspector also reviewed the reinspection procedures as
specified in the above listed travelers and witnessed the exchange of
temporary bolts for compartment 1.
Temporary bolts were installed in
either 3 or 4 bolt holes, in a pattern specified by G8H to provide
temporary support of the beams during reinspection.
NRC inspections were not performed on other activities during this
report period.
No NRC violations or deviations were identified.
g.
Installation of Main Steam Pipes (ISAP No. V.g
The following activity was identified in NRC Inspection Report
50-445/86-01; 50-446/86-01 as being part of the program proposed by
the applicant. This activity had not been previously inspected by
the NRC.
Activity
ISAP
NRC
Paragraph No.
Reference No.
Interview Personnel Involved with
4.2
5.e.02.00
Steam Line Adjustment
The CPRT conducted interviews with personnel involved with the steam
line adjustment, in order to establish a starting point for assessing
the steam line adjustment and reconstructing the sequence of events.
Discussions with the involved personnel by the NRC inspector
confirmed these CPRT interviews. This activity is now complete.
No NRC violations or deviations were identified.
h.
Receipt and Storage of Purchased Haterial and Equipment
(ISAP No. VII.a.9)
ISAP No. VII.a.9, issued during this report period, is a result of a
concern by the NRC that verification of material and equipment
compliance with procurement / design requirements needed to be
addressed. This is the initial report for this ISAP and the specific
activities of this ISAP are delineated in the following table. The
activities will be reported as they are completed.
Table of Activities for ISAP No. VII.a.9, Receipt and Storage
of Purchased Material and Equipment
Activity
ISAP Para
NRC Reference No.
Select Procured Items to be Audited
4.1.2
7.a.9,01
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Develop Checklists for Program Review
4.1.3
7.a.9.02
,
Review Program Documents for Adequacy
4.1.3
7.a.9.03
Develop Checklists for Records Audits
4.1.4
'7.a.9.04
Perform Audit of Records
4.1.5
7.a.9.05
Identify Deviations
4.1.5
7.a.9.06
Qualification of Personnel
4.3
7.a.9.07
1.
Onsite Fabrication ( ISAP No. VII.b.1)
During this report period, the activity identified by NRC Reference
No. 7.b.1.02_was inspected as follows:
Identify and Select Samples from ASME and non ASME Fabrication
(NRC Reference No. 7.b.l.02)
The NRC inspector verified the selection of safety-related fabricated
items. This was accomplished by the NRC inspector witnessing the
selection activity in part and subsequent review of the entire sample
selection. The sample selection was found to conform to the
requirements of this ISAP, para
The selection of ASME
packages (principallyhangers) graph 4.1.2.2.
is complete. Selection of non-ASME
packages (principally electrical items) is ongoing and will be
reported later.
No NRC violations or deviations were identified.
j.
Hilti Anchor Bolt Installation (ISAP No. VII b.4)
The NRC inspector has verified implementation of the following
activity by witnessing performance of ERC's reinspection / verification
effort in accordance with ERC QI-063, " Reinspection of Torque for
Drilled-In Concrete Expansion Anchors (Hilti Bolts):"
Activity
ISAP
NRC
Paragraph No.
Reference No.
Torque Verification Program
4.1.7
7.b.04.07
To date, 131 of the estimated 180 torque verifications have been
completed, of which the following 18 were witnessed by the NRC
inspector and determined to be acceptable per QI-063:
Verification Pkg. No.
Equipment Tag No.
System *
Unit No.
I-S-HLTV-010
AB-900-1H aG-01
1
1-S-HLTV-216
AB-900-1M-4G-01
1
___
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I-S-HLTV-024
FB-810-1F-WP2
1
I-S-HLTV-017
FB-806-1G-WPS
1
I-S-HLTV-060
FB-806-1G-WP5
1
I-S-HLTV-037
DG-844-1K-1AZ
1
I-S-HLTV-318
JB15-30130
N/A
1
I-S-HLTV-084
AF-1-043-001-Y43R
1
I-S-HLTV-120
AF-1-043-001-Y43R
1
I-S-HLTV-205
AF-1-043-001-Y43R
1
I-S-HLTV-074
AF-1-043-001-Y43R
1
I-S-HLTV-315
C16R09450-1
N/A
1
I-S-HLTV-203
AF-1-001-021-Y33R
1
I-S-HLTV-107
AF-1-097-020-533R
1
I-S-HLTV-173
CTH-1-341
N/A
1
I-S-HLTV-172
CTH-1-3336
N/A
1
I-S-HLTV-179
CTH-1-5644
N/A
1
I-S-HLTV-175
CTH-1-2696
N/A
1
- VA - Heating, ventilation, air conditioning
AF - Auxiliary feedwater system
N/A - Not Applicable
The acceptance criteria used by ERC was as follows:
o
The position of the nut was noted prior to torquing by marking
the it.tersection of two flats (point) and the corresponding
location on the attached fixture
o
Torque was applied to the nut and the verification was
determined to be acceptable if either the nut did not turn
before the applicable test torque value was reached, or the
minimum installation torque was reached prior to the nut turning
a full turn.
If the nut turned one full turn before the minimum
installation torque value was reached, the torque verification
was determined to be rejectable.
No NRC violations or deviations were identified.
9.
ISAP No. VII.c
A discussion of the NRC inspection activity is contained in the following
subparagraphs for those populations which were inspected during this
report period:
a.
Electrical Cable
Status of CPRT Activity
ERC has completed 40 reinspections and 78 documentation reviews of
sampled electrical cables as of March 31, 1986. The decrease in the
above total completions from those reported in previous inspection
reports is the result of ERC rework required by revisions to the
.
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.
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acceptance criteria and by the establishment of (and movement of some
.
sampled cables into) a new population for plant lighting systems. A
discussion of the lighting population is contained in a subsequent
section of this paragraph.
Status of NRC Inspection Activity
The completion status for NRC inspection activity is unchanged from
the previous report period; i.e., the NRC inspectors have, as of
March 31, 1986, witnessed 21 ERC reinspections, performed 6
independent inspections, and conducted 10 documentation reviews.
The NRC inspector observed two unusual looking electrical cables
while conducting an independent inspection related to allegations of
improper electrical cable installation.
(See paragraph 5.d of this
Appendix.) The electrical cables were imprinted with "No. BAWG
VULKENE SUPREME" and were covered with a brown colored insulation.
The cables had been designated safety related, Train A, by the
attachment of bands of orange colored tape and were located in
Train A cable tray T130CCQ34 in the Unit i lower cable spreading
room. These two single conductor cables did not appear to the NRC
inspector, based on his prior knowledge of the list of approved
electrical cable vendors, to be approved for use at CPSES.
Information provided to the NRC inspector by the applicant's QE
representatives, identified the cables as a two conductor cable
numbered E0106306.
In addition, an NCR (No. 82-01977 dated
November 10,1982) had been written to question this cable's
installation. The disposition of NCR E82-01977 states that cable
E9106306, and the Train B counterpart, cable EG106317, had been
supplied by the vendor and were acceptable. A review of supporting
r
records indicated that the cables were provided in October 1982 by
l
General Electric Company (GE) as part of the 125VDC distribution
systems' ground detection circuitry. Review of the AVL, Revision 7,
dated August 1982 showed that the vendor, GE of Plainville,
Connecticut, was an approved vendor.
Based on this information, the NRC inspector had no further concerns.
No NRC violations or deviations were identified.
b.
Cable Trays
Status of CPRT Activity
ERC has completed 103 reinspections and 103 documentation reviews as
of March 31, 1986.
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
-
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_
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J
Status of NRC Inspection Activity
The NRC inspectors have witnessed 11 ERC reinspections, conducted 6-
independent inspections and performed 7 documentation reviews as of
March 31, 1986; these totals remain unchanged from those previously
!
reported.
The performance of the seven documentation reviews was reported in
NRC Inspection Report 445/85-14; 446/85-11, with the results being
made an open item (445/8514-0-09) pending comparison of ERC findings
for the same reviews. -When the comparison of findings was undertaken
during this report period, it was discovered that revisions to the
,
applicable procedure (QI-017) had affected the attributes to be -
verified. Therefore, to assure completeness and clarity, another
independent documentation review was performed of these same
verification packages prior to the comparison of review results. The
verification packages reviewed were for the following Unit 1 cable
trays:
1
Verification Package No.
Cable Tray No.
Location
R-E-CATY-004
T149CDJ17
Cable Spreading Room
R-E-CATY-023
T129CBD68
Room 121
R-E-CATY-024
T139RCJ28-
Reactor Building
R-E-CATY-036
T149SDA05
Room 65
R-E-CATY-055
T129FBUO4
Fuel Building
R-E-CATY-060
T129FBU05
Fuel Building
R-E-CATY-129
T129RBK17
Reactor Building
Comparison of NRC and ERC review results produced the following
common findings:
R-E-CATY-004: An inspector signed off welding as being satisfactory,
but no welding IR or traveler was found. DR R-E-CATY-004-DR01 and
NCR E85-101525SX have been written for this deficiency. This finding
,
!
is an open item (445/8603-0-05) pending disposition of the NCR.
R-E-CATY-024: Using QA records, it could not be verified that the
welder with symbol BSY was qualified at the time he made the weld on
this cable tray. DR-E-CATY-024-DR01 and NCR E85-101525SX have been
written for this deficiency. This finding is an open item
(445/8603-0-06) pending disposition of the NCR.
No NRC violations or deviations were identified.
c.
Electrical Conduit
i
Status of CPRT Activity
'
ERC has completed 29 reinspections and 80 documentation reviews of
sampled electrical conduit as of March 31, 1986. The decrease in the
,
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.
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number of reinspections from the. number reported in previous NRC
inspection reports has been due to some of the samples being replaced
because of selection questions, the implementation of a new
population for lighting (discussed later in this paragraph) and some
reinspections required by revisions to the applicable procedure.
Status of NRC Inspection Activity
The NRC inspectors have, as of March 31, 1986, witnessed 14 ERC
reinspections, conducted 5 independent inspections, and performed 15
documentation reviews. These totals are unchanged from those
previously reported.
ERC memorandum QA/QC-RT-1626 dated March 12, 1986, which transmitted
Revision 4 of QI-008, was reviewed by the NRC inspector. The
revision to this procedure will require backfit reinspections by ERC
l
to verify the proper rating of junction boxes installed in the
. reactor building. The addition of this attribute will provide
assurance of compliance with the environmental qualification of
terminal blocks installed in these junction boxes.
No NRC violations or deviations were identified.
d.
Electrical Equipment
Status of CPRT Activity
ERC has completed 76 reinspections and 20 documentation reviews of
sampled electrical equipment installations as of March 31, 1986. The
decrease in the number of reinspections and reviews from previously
reported totals was caused by the rework of completed packages to
incorporate additional, new requirements.
Status of NRC Inspection Activity
l
The NRC inspectors have, as of March 31, 1986, witnessed 11 ERC
reinspections, performed 3 independent inspections and conducted 10
l
documentation reviews; these totals are unchanged from those
previously reported.
'
!
The NRC inspector began the comparison of ERC and independent NRC
i
documentation review results for those reviews previously reported as
open items (445/8514-0-12 and 445/8516-0-29). The comparison
activity could not be completed because 7 of the 10 documentation
packages had been returned to the ERC engineering organization for
revision in response to ERC memorandum QA-QC-RT-1382 dated
February 28, 1986.
In accordance with this memorandum, 21
verification packages will be revised, the documentation reviews will
__ _,
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be redone, and the results documented using a new checklist. The NRC
inspector will evaluate the need to reperform the NRC documentation
reviews when these verification packages are reissued.
No NRC violations or deviations were identified.
e.
Instrumentation Equipment
Status of CPRT Activity
"
-
ERC has completed 107 reinspections and 107 documentation reviews of
sampled instrumentation equipment as of March 31, 1086.
Status of NRC Inspection Activity
The NRC inspectors have, as of March 31, 1986, witnessed 11 ERC
reinspections, performed 7 independent inspections and conducted 5
documentation reviews of sampled instrumentation equipment.
During this report period, ERC reissued all of the previously
completed instrumentation packages to the instrumentation inspectors
to reinspect for certain attributes. The attributes reinspected
included material identification, tubing size, routing, air gap, and
bend radius. The NRC inspector witnessed three of these Unit I
reinspections during this report period:
Verification Package No.
Instrument No.
System
I-E-ININ-030R
1-PI-4762
I-E-ININ-034R
1-PI-1094
I-E-ININ-046R
1-FT-918
Safety Injection
The ERC inspectors identified the following to the NRC inspector as
subject to evaluation as potential deviations:
(1)
I-E- ININ-030R:
(a) The tubing immediately adjacent above and below the drain
valve did not contain longitudinal color coding for
material size, identification, and traceability.
(b) The information to verify flange material identification
and traceability was not included in the verification
package.
(c) Four air gap violations (less than 1/8" clearance) between
the tubing installation and adjacent tubing runs were
identified and are located at:
the bottom of the ceiling
penetration in room 51; approximately 3'-4" upstream from
{
.
.
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the floor penetration in room 66; approximately 4'-4"
upstream from the floor penetration in room 66; and
approximately 4'-6" from the root valve.
(2)
I-E-ININ-034R:
(a) The information to verify flange material identification
and traceability was not included in the verification
packege.
(b) One air gap violation (less than 1/8" clearance) between
the tubing installation and an adjacent tubing run was
identified, located approximately 4'-6" from the root
valve.
(3)
I-E-ININ-046R:
Two air gap violations (less than 1/8" clearance) between the
tubing installation and adjacent tubing runs were identified
and are located at the bottom of the ceiling penetration in
room 54 and approximately 3' north of the vent valve in room 67.
The above six findings are open items pending the NRC inspector's
review of ERC's disposition and/or the applicant's applicable
corrective action (445/8603-0-07 through 445/8603-0-12).
No NRC violations or deviations were identified.
f.
Lighting
This new population was initiated as part of the ISAP No. VII.c.
reinspection and documentation review program because of installation
cnd inspection differences between plant lighting and other
electrical systems. These differences would affect the homogeneity
of the other populations, i.e., cable and conduit, if the lighting
circuits were included.
The procedures that were issued for the lighting system installation
required only limited QC inspection of the distribution panels and no
QC inspection of the other connection boxes or fixtures.
Status of CPRT Activity
ERC has completed 24 reinspections and 62 documentation reviews of
sampled lighting circuits as of March 18, 1986, in accordance with
QI-071 and QI-072, respectively,
i
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Status of NRC Inspection Activity
The NRC inspector was informed by the ERC electrical engineers on
March 18, 1986, that ERC had completed the documentation reviews for
all 62 verification packages, with few deficiencies being identified.
ERC reinspection of 24 inspection packages resulted in 133 findings,
which were documented in 49 DRs. All of these findings were located
in various junction or pull boxes, which did not require QC
inspection. The most prevalent findings were loose or damaged
crimped splices, damaged wire insulation, and too many wires in the
connection boxes.
(The wire used in the lighting system, except for
long rows of fixtures where stranded wire is used, is solid
conductor, No. 12AWG).
The NRC inspector was also informed that, because of the magnitude
and significance of the findings, ERC had ceased inspection
activities and was preparing a report to present findings and
recommendations to TUGCo. The NRC inspectors will perform some
independent inspections of lighting systems in Unit 2 as the system
is installed.
No NRC violations or deviations were identified.
g.
Large Bore Piping Configuration
Status of CPRT Activity
ERC ha~s completed 84 reinspections of large bore piping
configurations out of the planned random and engineered sample size
of 85. The combined sample size was increased from a previous figure
of 82 as a result of further evaluation of the engineered sample size
in which it was determined that three additional packages were
required to meet the sample criteria.
Fifty-three valid DRs have
been identified and issued.
Status of NRC Inspection Activity
To date, the NRC inspector has witnessed seven ERC reinspections and
performed four independent inspections, of which the following
independent inspection occurred during this reporting period:
Verification Package No.
Drawing No.
System *
Unit No.
I-M-LBC0-148
BRP-RH-1-58-006
RH
1
While performing the independent inspection, three instances were
identified where the separation criteria of paragraph 5.2.6.2 of
QI-025 were not met and documentation could not be located which
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would justify this condition. The stated criterion is that a minimum
clearance of 2" must exist between two pipes, including insulation,
when the operating temperature of at least one of the lines equals or
exceeds 200"F. The ERC inspector signed off attribute 1.f on the
checklist, which deals with separation, as acceptable.
(1) Line 2-CC-1-060-152-3 is in contact with the inspected line at a
location 6'6" north of wall 7-S and 10' west of wall D-S.
The
two lines are parallel and are in contact for about 4'.
(2) Line 2-CC-1-061-152-3 is in contact with the inspected line at a
location 12'6" north of wall 7-S and about 8' west of wall D-S.
(3)' Line 1-CC-1-062-152-3 is closer to the inspected line than the
allowable 2" at a location 6'6" north of wall 7-S and 7'6" west
of wall D-S
Theseidentifiedinstancesconstituteadeviation(445/8603-D-13).
h.
Small Bore Piping Configuration
Status of CPRT Activity
ERC has completed 87 reinspections of small bore piping
configurations out of the combined random and engineered sample size
j
of 88. Sixty valid DRs have been identified and issued by ERC.
'
Status of NRC Inspection Activity
To date, the NRC inspector has witnessed seven ERC inspections and
performed two independent inspections, of which the following
independent inspection occurred during this inspection period:
Verification Package No.
Drawing No.
System *
Unit No.
1-M-50C0-101
BRP-CC-2-AB-044
2
,
- CC - Component Cooling Water System
1
No NRC violations or deviations were identified.
i.
Instrument Pipe / Tube Supports
Status of CPRT Activity
ERC has cor.pleted 106 reinspections of instrument pipe / tube supports
out of the combined random and engineered sample size of 111. Three
hundred thirty-nine valid DRs have been identified and issued by ERC.
ERC has completed 34 document reviews of these packages with 4 valid
DRs being issued to date.
-
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.-.
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_ .
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-
. -
-.
.
a
44-
-
Status of NRC Inspection Activity
To date, the NRC inspector has witnessed four reinspections and
<
performed seven independent inspections of which the following two
independent inspections occurred during this reporting period:
Verification
Instrument
<
Package No.
Tag No.
Sy stem *
Unit No.
I-S-INSP-107
1-PT-2326-C
MS
1
I-S-INSP-126
1-PT-2328
MS
1-
i
- HS - Main Steam, Reheat and Steam Dump
No NRC violations or deviations were identified.
j
HVAC Duct Supports
.
Status of CPRT Activity
A. total of 89 HVAC duct supports were randomly selected from a
population of 2580 supports representing Units 1, 2, and common. To
l
date ERC has inspected 79 supports and initiated 253 DRs, primarily
in the areas of undersize welds and configuration discrepancies. Of
the 253 DRs, 233 have, to date, been established as valid.
e
Status of NRC Inspection Activity
To date, the NRC inspector has witnessed seven ERC reinspections and
performed one independent inspection. The independent inspection and
results, are as follows:
Verification
Duct
l
Package No.
Support No.
System *
Unit No.
I-S-HVDS-075
DG-844-2K-1J
2
,
- DG - Diesel Generator
I-S-HVDS-075: QI-035, Revision 0, requires that verification be made
with respect to weld sizes meeting the requirements of the duct
support detail drawing. The checklist applicable to this
verification package showed that the ERC inspector had measured and
'
accepted two skewed fillet welds using a Fiber Metal Fillet Gauge.
'
The NRC inspector found that neither a Fiber Metal Fillet Gauge nor
any conventional measuring device could be used to measure one leg of
the fillet on each weld.
The ERC inspector's acceptance of these welds is an NRC deviation
(446/8602-D-11).
,
J
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- - ~ . , , - -
, - , , -
-..g...
.
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--.
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-~...-n.
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-
- .
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,
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..
.
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___
_ _ _ _ _ _ _ _ _ _ _ _ _
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QI-035 requires verification of member lengths and all other
dimensions that describe the lengths and positions of members in the
support frame. This attribute on the checklist was signed off as
being acceptable by the ERC inspector. The NRC inspector identified
that for several members, there was either a lack of, or insufficient
information provided in the drawing. Therefore, verification of
member lengths could not be performed.
'
The ERC inspector's acceptance of this attribute is an NRC deviation
(446/8602-D-12).
Section 5 in Revision 2 of CPP-008 states in part, ". . . Should an
attribute appear on the generic checklist and not be applicable to
the specific item, the engineer indicates 'N/A' and provides
reasonable justification for the entry." The NRC inspector observed
that attributes 2F.1, 2F.2, and 2F.3 dealing with enhed plates and
spacing violations had been N/A'd by the engineer. The_noted
justification for this entry was "No embedded Pls;" however, the NRC
inspector identified the existence of an embed plate with dimensions
of approximately 20'X8".
The engineer's error relative to this attribute is an NRC deviation
(446/8602-D-13).
k.
Reinspection of Small Bore Pipe Supports
Status of CPRT Activity
Reinspection of the combined random and engineered sample of 76 small
bore pipe supports is complete. Ninety-seven deviations have been
identified, and to date, 53 have been evaluated as being valid.
Documentation review is also complete with 23 valid deviations
identified. Thus far, a total of 56 valid deviations have been
evaluated for safety significance with no safety significant
deviations being identified.
Status of NRC Inspection Activity
The NRC inspector has witnessed 7 reinspections and independently
inspected 11 small bore pipe supports. The following three supports
were independently inspected during this report period:
Verification
Pipe
Package No.
Support No.
- System
Unit No.
I-S-SBPS-031
WP-X-AB-042-010-3
WP
Common
I-S-SBPS-034
SW-1-SB-013-009-3
1
l
_ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ - _
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I-S-SBPS-246
CH-X-FB-009-002-3
Common
- CH - Vcntilated Chilled Water system
SW - Service Water System
WP - Solid Waste Processing System
The NRC inspector reviewed ERC Description Memorandum QA/QC-RT-1436
and ERC QI-019, Revision 3. Paragraph 5.3.5(A) of ERC QI-019 includes
the addition of a clarification of the requirements for clearance.in
the gravity direction between the pipe and the support for small bore
box frame supports, and states, in part, "Where design shows 0 inch
on one side and 1/16 inch on the other side, the sum of both gaps may
not exceed 1/8 inch or be less than 1/32 inch *. . . ."
- Where design shows 0" on bottom (in the gravity direction) then it
shall be such with no allowable variation."
The clarification preceded by -an asterisk was not included in
previous revisions of QI-019.
Section II of ERC Description Memorandum QA/QC-RT-1436 lists changes
incorporated in Revision 3 of ERC QI-019 and, with respect to
paragraph 5.3.5(A) states, in part, "Added clarifying information on
allowable clearances for dead weight and 0" clearance
supports . . . ."
Attachment A to the above ERC Description Memorandum lists previously
issued reinspection packages and states that Yerification
Package I-S-SBF'i-051 is not affected by changes incorporated in
Revision 3 of ERC QI-019.
The NRC inspector previously measured a gap of 1/16" in the gravity
direction for Verification Package I-S-SBPS-051. Drawing CP-AA-040,
Revision 0, for this pipe support specifies a clearance of zero in
the gravity direction. The changes in Revision 3 of QI-019 do, in
fact, affect the previous inspection of Verification Package
I-S-SBPS-051. ThisconditionisanNRCdeviation(445/8603-D-14).
1.
Documentation Review of Fill and Backfill Placement
Status of CPRT Inspection Activity
Documentation review of fill and backfill placements is nearly
complete with 179 of 180 packages reviewed. A total of 310 valid
deviations have been identified.
ERC DR R-S-FILL-GEN-DR-1 was issued
to address inspector certification for the safe shutdown impoundment
dam construction during the period April 24, 1976, through April 19,
1977.
Inspection certification documentation for Freese & Nichols
Consulting Engineers and Mason & Johnson Associates, Inc. could not
be located. This DR applies to 60 of the 180 fill and backfill
packages and is an open item (445/8603-0-15).
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Status of NRC Inspection Activity
The NRC inspector performed independent documentation reviews of the
following seven fill and backfill packages:
Verification Package No.
Inspectors Daily Report No.
R-S-FILL-015
1184
R-S-FILL-027
1425
R-S-FILL-035
1417
R-S-FILL-043
1191
R-S-FILL-125
B&R Dated 12/1/77
R-S-FILL-140
B&R Dated 12/29/77
R-S-FILL-143
B&R Dated 9/14/77
4
No NRC violations or deviations have been identified.
m.
Inspection of Non-Pressure Boundary Welds for a Supplementary
Evaluation of Visual Welding Inspection Techniques
Status of CPRT Activity
To date, 52 randomly selected samples of weld joints obtained from
ISAP Nos. VII.b.3 and VII.c populations have been inspected before
removal of coatings. The following 29 were inspected during this
report period:
Verification Pkg. No.
Equipment Tag No.
System *
Unit
I-S-NPBW-015
RC-1-135-907-C47W
RC
1
I-S-NPBW-077
RC-1-135-909-C47W
RC
1
I-S-NPBW-045
1-TE-5400
NI
1
I-S-NPBW-041
MS-1-003-904-C77W
MS
1
I-S-NPBW-071
CC-1-RB-004-007-3
1
I-S-NPBW-008
VME-1
1
I-S-NPBW-051
8"X18"-90
1
,
'
I-S-NPBW-076
RMD-1
1
I-S-NPBW-086
EMD-6
1
I-S-NPBW-066
EMD-1
1
I-S-NPBW 's33
54"X38" Str Duct
1
I-S-NPBW-026
CB-830-IN-1R
N/A
1
1-S-NPBW-068
FW-1-017-912-C47W
1
I-S-NPBW-025
FW-1-017-913-C47W
1
1-S-NPBW-043
CP2-MEFT1F-01
N/A
2
I-S-NPBW-107
CT-1-008-001-5225
1
I-S-NPBW-111
AF-1-101-001-523K
1
I-S-NPBW-104
CC-1-RB-033-007-3
1
1-S-NPBW-101
CC-1-228-007-C53R
1
I-S-NPBW-109
CC-1-126-702-F43R
1
I
_--__.
-_
_
_ - _ _ _ _ _ _ _ -
_ _ _ - _ .
.
.
-48-
I-S-NPBW-097
EMD-2
1
I-S-NPBW-085
CP-1-ELDPEC-05
N/A
1
I-S-NPBW-096
AB-810-1L-WP23
N/A
1
I-S-NPBW-098
MS-1-RB-036-007-2
MS
1
I-S-NPBW-091
BSC SUB SMD-2
ll
I-S-NPBW-092
AF-1-102-031-543R
1
I-S-NPBW-087
CC-1-EC-006-005-3
1
I-S-NPBW-083
CC-1-EC-007-013-3
1
I-S-NPBW-110
CT-1-047-007-C92R
1
To date, 27 of the randomly selected weld joint samples have been
inspected after removal of coatings. The following second phase
inspections (20) were performed during this report period:
Verification Pkg. No.
Equipment Tag No.
Sy stem *
Unit
I-S-NPBW-035
AF-1-043-001-Y43R
1
1-S-NPBW-063
AF-1-001-021-Y33K
AF-
2
I-S-NPBW-005
1-FI-4695
NI
1
1-S-NPBW-014
FW-1-019-902-C57W
1
I-S-NPBW-046
FW-1-102-901-C57W
1
I-S-NPBW-077
RC-1-135-909-C47W
RC
1
I-S-NPBW-015
RC-1-135-907-C47W
RC
1
I-S-NPBW-016
I-LS-4795
NI
1
I-S-NPBW-052
1-FT-156
NI
1
I-S-NPBW-025
FW-1-017-913-C47W
1
I-S-NPBW-010
MS-1-001-902-C77W
MS
1
I-S-NPBW-017
MS-1-001-908-C67W
MS
1
I-S-NPBW-004
FW-1-017-908-C77W
1
I-S-NPBW-041
MS-1-003-904-C77W
MS
1
I-S-NPBW-076
RMD-1
1
I-S-NPBW-051
8"X18"-90
1
I-S-NPBW-026
CB-830-1N-1R
N/A
1
I-S-NPBW-091
BSC SUB SMD-2
1
1-S-NPBW-067
SG-1-852-1J-1AF
N/A
1
I-S-NPBW-008
VME-1
1
- RC - Reactor Coolant System; NI - Nuclear Instrumentation; MS -
Main Steam System; CC - Component Cooling Water System; VA - Heating,
l
Ventilation, Air Conditioning; FW - Steam Generator Feedwater
'
System; CT - Containment Spray System; AF - Auxiliaiy Feedwater
l
System; and N/A - not applicable.
Status of NRC Inspection Activity
(
'
The NRC inspector has witnessed 100 percent of the inspections performed
on welding in the coated and uncoated condition. Listed below are the NRC
findings with respect to ERC's supplementary evaluation of visual welding
inspection techniques:
._-___
. _.
.
_ .
- - -, --
_ _ . -
-
.
_ _
.
- __
_
.
.
..
-49-
I-S-NPBW-063: . ERC inspection of a 5/16" fillet weld was documented
" accept" in the coated condition. After the weld coating was removed, the
' same weld was documented " reject" due to a 1/2" long segment of weld being
approximately 1/32" undersize. This was documented on a DR and the
disposition of this finding is an open item (445/8603-0-16).
l~
the weld joining item 1 to the support steel identified on Drawing
I-S-NPBW-014: ERC rejected, before removal of the coating, the surface of
FW-1-019-901A-C57W, in accordance with QI-062, Revision 0, Attribute 5.2.D
,
which states " Verify surface of welds are sufficiently free of overlap,
abrupt ridges and ripples so proper interpretation of. radiographic and/or
other required NDE could be accomplished." After removal of the coating,
ERC documented the surface of weld condition as " Accept." The NRC
inspector's examination of the subject > id surface, before and after
removal of coating, identified that the weld surface condition was not
suitable for NDE due to excessive ridges and ripples that could impair
accurate interpretation of NDE results. An NRC review of fabrication
'
records identified that the weld had been examined and accepted by the
magnetic particle (MT) method of NDE by CBI. Subsequent to the NRC
inspection, ERC obtained an independent NDE Level III examiner's opinion,
.
who was contracted from the technical service division of Daniel
International Corporation. Following this independent examination, ERC
i
issued a DR documenting the weld surface condition as " Reject."
'
Acceptance of the weld surface condition by_ERC, during inspections
erformed as re
p(445/8603-D-17) quired by I-S-PWRE-006 and I-S-NPBW-014, is a deviation
i
.
.
I-S-NPBW-107: While witnessing performance of the reinspection, the ERC
inspector identified that grinding at the toe of fillet welding exceeded
the allowable undercut depth. The ERC inspector stated that the QI did
not require inspection for base material defects and the finding would be
documented as an "out-of-scope observation." An NRC evaluation of the
purpose and scope of QI-029, the applicable QI for the population from
,
which reinspection / verification PKG-I-S-NPBW-107 was chosen, did not
include a requirement to inspect base material. The failure of ERC
engineering to identify and include base material defects as a safety
,
significant attribute which can be reinspected, as required by
'
paragraph 5.1 in Revision 2 of ERC's CPP-007, is a deviation
,
(445/8603-D-18).
l
10. Exit Interview
l
Exit interviews were conducted on March 4 and April 4, 1986, with the
applicant representatives denoted in paragraph 1 of this appendix. During
<
these interviews, the NRC inspectors summarized the scope and findings of
-
the inspection. The applicant acknowledged the findings.
i
1
.
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