ML20216C252
| ML20216C252 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/22/1987 |
| From: | Barnes I, Ellershaw L, Hale C, Spessard R, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20216C144 | List: |
| References | |
| 50-445-87-02, 50-445-87-2, 50-446-87-02, 50-446-87-2, NUDOCS 8706300248 | |
| Download: ML20216C252 (34) | |
See also: IR 05000445/1987002
Text
w . ,
2 ',
'. !
"" ',
'
b
. . .
l'
.( .
- y 'A
-
- 4
,;,
'
g
-
.a- 1 ,
7,.
4 ,- .#,
_
," ,- <-
( ,
q
.;
,
4
ff 1
..
. APPENDIX'B'
.m
'
'
, ,
'NRC COMANC 5 PEAK RESPONSE TEAM-ACTIVITIESLINSPECTION REPORT
~
"
', e ..U. S. NUCLEAR REGULATORY COMMISSION-
4 REGION.1V,
- ,
r NRC Inspection Report: '
50.445/87-02 Permits: . CPPR-126
< J' '50-446/87-02~ CPPR-127'
ct ; Dockets: 50-4451 Category: $2E
50-446--
.
, Construction' Permit-
Expiration Dates: ..
..' . Unit 1: August.1, 1988..
1 ' Unit 2: August'1, 1987-
Applicant: TV Electric.
tSkyway Tower
400 North Olive Street
,
Lock. Box 81 <
Dallas,: Texas .
75201
e
'
Facility Name': Comanche Psak Steam Elect'ric Station-(CPSES),:
Units'l'& 2
Inspection At: . Glen Rose,-Texas
,
Inspection Conduct d:2 January 1 through. February 28, 1987-
Inspectors:- n ~
/I k
- - L' E. Ellershaw, Reactor. Inspector, Region IV Dath /
CPSES Group _ . .
E (paragraphs 2.a-f, 2.h-1, 2;n, 2.s, 3.c,
4.a,'and 4.b)
l
C. J. %Te, Reactor Inspector, Region IV Date / i
CPSES Group
(paragraphs 2.g, 2.m, 2.q-r, 3.b, 3.d, and 5) ;
1
i. t
-
'
.
"
0. [U64 &
P..C. Wagner, React 6r Inspector, Region IV
(o ft 5 / 8 7
Date
l
!
CPSES Group i
(paragraphs 2.0 p, 3.a, and 4.a)
<
"
8706300248 870622 o
n_
"
, PDR ADOCK 05000445 .
~ G- PDR ,
j
J
r,
. ,
l
2 l
i
i
i
Consultants: EG&G J. Dale (paragraphs 2.a-f, 2.h, 2.j-1, and 4.b) !
A. Maughan paragraphs 2.0-p and 4.a)
W. Richins paragraphs 2.n and 4.a)
V. Wenczel paragraph 5)
..
Parameter -K.J.Graham
Birmingham (paragraphs
(paragraphs 2.1, 2.s,2.g,
and2.m.
3.c 2.q-)r, 3.b, and 3.d)
D. Jew (paragraph 4.a)
Reviewed By: G /15 /97 :
R. L. Spessard, Deputy Director, Divisi @ of Date l
Inspection Programs, Office of Inspect 1on i
and Enforcement
Approved: " $ 7
I. Barnes, Chief, Region IV CPSES Group Date
i
Inspection Summary i
Inspection Conducted: January 1 through February 28, 1987 (Report 50-445/87-02;
50-446/87-02)
Areas Inspected: Nonroutine, unannounced inspection of applicant actions on
previous inspection findings, Comanche Peak Response Team (CPRT) Issue-Specific
Action Plans (ISAPs), assessment of VII.c populations, and the ISAP sample
selection process. l
Results: Within the four areas inspected, two deviations (several concrete
pours were not included on the Population Items List, paragraph 4.a.[3]; and
documents missing from the ISAP VII.c project files, paragraph 4.a.[4]) were
identified.
.
l
,
1
1
!
l
I
e_ e
1
3 !
l
DETAILS i
l
!
'1. Persons Contacted
3
- J. M. Ayres, Quality Engineering (QE) Supervisor, TV Electric
- R. P. Baker, Regulatory Compliance Manager, .TV Electric
- J. L. Barker, Engineering Assurance Manager, TV Electric -
- J. W. Beck, Vice President, TU Electric j
- G. L. Bell, Nuclear Licensing, TV Electric 1
P. Boortz, Engineering Assurance Supervisor, Evaluation Research I
Corporation (ERC) 1
D. Boultan, Population Engineer, ERC -j
D. Boydston, Issue Coordinator, ERC
- E. J. Brabazon, Deputy Program Manager, CPRT
T. Braudt, CPRT, TV Electric
'**
J. A. Buck, Senior Review Team (SRT), CPRT l
- F. G. Burgess, CPRT Project Manager, TU Electric
R. E. Camp, Unit 1 Project Manager, TU Electric
- W. G. Counsil,. Executive Vice President, TV Electric
- R. D. Delano, Nuclear Licensing Engineer, TU Electric
D. Ferguson, Results Report Review Committee Chairman, CPRT t
- J. R. Gelzer, Issue Coordinator, ERC l
- M. R. Gross, Jr., Staff Member, CPRT !
- J. Guibert, SRT, CPRT !
- P. E.'Halstead, Site Quality Control-(QC) Manager, TV Electric j
- T. ' L. Heatherly, Regulatory Compliance Engineer, TU Electric j
- G. S. Keeley, Nuclear Licensing Manager, TU Electric ,
'
- J. E. Krechting, Director of Engineering, TV Electric ;
D. McAfee, Quality Assurance (QA) Manager, TV Electric
l
J. McNally, Population Engineer, ERC
J. W. Muffett, Executive Assistant, Engineering & Construction, .j
TU Electric i
- L. D. Nace, Vice President, TV Electric i
- W. Nyer, SRT, CPRT
A. Patterson, Issue Coordinator, ERC )
- D. M. Reynerson, Unit 2 Project Manager, TV Electric
G. W. Ross, Issue Coordinator, ERC ,
R. K. Sanan, Issue Coordinator, TERA i
J. Schauf, Construction Evaluation Engineering Group Supervisor, ERC !
- C. E. Scott, Startup Manager, TU Electric
- J. Smith, Operations Staff, TV' Electric
- M. R. Steelman, CPRT Support, TU Electric
- J. F. Streeter, QA Director, TV Electric 3
J. Tableriou, Population Engineer, ERC !
T. G. Tyler, CPRT Program Director, TV Electric
C. Vincent, Issue Coordinator, ERC
F. Webster, Engineering Statistics Advisor, CPRT ]
D. R. Woodlan, Licensing Supervisor, TU Electric j
l
i
!
i
- -
. !
4
- J. E. Wren, QC Services Supervisor, TV Electric
J. E. Young, Issue Coordinator, ERC
R. Zill, QA & Personnel Supervisor, ERC
The NRC inspectors also interviewed other applicant employees during this i
inspection period. l
1
- Denotes personnel present at the February 10, 1987, exit interview. l
- Denotes personnel present at the March 3, 1987, exit interview. !
- Denotes personnel present at both of the above exit interviews.
2. Applicant Actions on Previous Inspection Findings
(0 pen) Open. Item (446/8513-0-09): Potential deviations were
~
a. l
identified by ERC concerning:~ (1) weld location,.(2) undersize welds,. 'j
(3) welding not per weld symbol, and (4) violation of minimum thread i
engagement. These conditions were documented on Deviation Reports !
(DRs) I-S-HVDS-109-DR-1, DR-2, DR-3,'and DR-4 and incorporated into !
Nonconformance Report (NCR) M86-250134X. This item will remain open
pending disposition of the NCR. i
i
Since these conditions were determined.to be not nonconforming, this !
item is closed.
!
b. (0 pen) Open Item (445/8514-0-15): Potential deviations were j
identified by the ERC inspector concerning a missing color code and 1
"
the allowable distance between color code marks was exceeded. These
were identified on DRs I-E-ININ-066 DR 1 and DR 2 and subsequently on
NCR I-85-102025SX. This population was reinspected at a later date
for additional attributes and the package designation changed from
I-E-ININ-066 to I-E-ININ-066R. The reinspection generated one
additional DR, DR I-E-ININ-066R-DR-3, which resulted in the issuance
of NCR I-86-101916X. This NCR also incorporated the previously
identified NCR. This item will remain open pending disposition of ;
the NCR. I
c. (0 pen) Open Item (445/8514-0-16): A potential deviation was I
identified by the ERC inspector concerning location of sending
Units 1-LS-6712 and 1-LS-6717 being reversed on the tank for
package I-E-ININ-069. This was subsequently identified on-
DR I-E-ININ-069-DR-1, and NCR I-85-101890SX. Because of added
attributes, this population was reinspected and the NCR superseded by
NCR I-86-101915X. This item will remain open pending disposition of
!
the NCR.
d. (Closed) Open Item (445/8514-0-24): A potential deviation was
identified by the ERC inspector concerning a missing nameplate and an
actuator spring that could not be located on the damper associated
with reinspection package I-M-HVIN-043. A subsequent inspection by
another ERC inspector revealed the existence of the required
nameplate and also identified from review of vendor I
i
6
-
.-
. .
5
Drawing 5800-M-027, Revision CP-1, that the damper was a motor
actuated fail-safe damper, Model No. SL-100-ML-N, which does not
utilize a spring for activation._ The NRC inspector confirmed by
examination of the damper and review of the vendor drawing that the
results of'the subsequent ERC inspection were correct. This item is ,
I
closed. '
e. (0 pen) Open Item (445/8514-0-28): A potential deviation was
identified by ERC concerning an undersize horizontal brace. This-
condition was identified in DR.I-S-HVDS-023-DR-4 and incorporated
into NCR M-86-100321SXR1. This item will remain open pending
disposition of the NCR.
f. (0 pen) Open Item (445/8514-0-29): A potential deviation was
identified by ERC concerning undersize fillet welds. This condition
was identified in DR I-S-HVDS-041-DR-4 and incorporated into
NCR M-85-101991XR2. This item will remain open pending disposition
of the NCR.
g. (Closed) Open Item (445/8516-0-12; 446/8513-0-08): The ERC
nonconformance evaluation checklists did not provide for the
evaluation of the technical adequacy of NCR dis'ositions.
p
This ERC QA/QC RTL'and the VII.a.2 issue coordinator has stated that
evaluation of the technical adequacy of NCR dispositions is outside l
the scope of ISAP VII.a.2. The applicant has, however, initiated a
program (performed by Stone & Webster Engineering Corporation) to )
evaluate the disposition of 300 NCRs with use-as-is or repair !
dispositions for technical adequacy. The evaluations assessed the
NCR dispositions to determine: (1) if the disposition fully addressed .
the nonconformance; (2) if an adequate technical justification was I
provided; and (3) whether the disposition block was correctly
identified. To provide further assurance, the applicant has decided i
to expand its program to assess the technical adequacy of the
remaining NCRs with these disposition categories. This activity will
be overviewed by TERA as an independent third party. NRC inspection
of this' process will be reported in a subsequent inspection period.
h. (0 pen) Open Item (445/8516-0-15): Potential deviations were
identified by the ERC inspector concerning locknuts missing from
clamp bolts and a bolt hole was incorrectly located. This condition
was subsequently identified in DRs I-S-0S42-25-DR-1 and DR-2 and
incorporated into NCRs M-23216NR1 and M-25338N, respectively. This
item will remain open pending disposition of the NCRs.
i. .(Closed) Deviation (445/8516-D-35): The ERC inspector failed to
record the presence of existing additional field welds to those
specified on the drawing for Verification Package I-S-LBSR-041 and
did not provide objective evidence of reinspection. The deviation
resulted from inspection personnel not being able to distinguish
vendor welds from field welds on vendor supplied components. ERC
r
- -
.. .
6
..
.-
Quality Instructions (QIs) QI'019, QI-027, and QI-029 were ' revised to
incorporate inspection requirements for these welds. Weld
inspections performed prior to the procedure change were reviewed and
supplemental inspection. instructions were. issued on a case-by-case
basis to assure compliance with revised procedural requirements. The
NRC inspector reviewed the corrective action taken and concluded that
the revised instructions should prevent recurrence.
j. (0 pen) Open Item (445/8516-0-38): Potential deviations were
identified by ERC concerning: (1) weld symbols and locations,
(2) undersize welds, and (3) a Hilti Kwik Bolt embed violation.
These conditio'sn were documented in DR I-S-HVDS-029-DR-1 and DR-2,
and incorporated into NCR M-85-102014X. This item will remain open
pending disposition of the NCR. !
,
k. (0 pen) Open Item (445/8516-0-39): Potential deviations were
identified by ERC concerning: (1) incorrect member dimensions,
(2) incorrect weld configuration, (3) incorrect weld size,
(4) incomplete fusion in welds, and (5) violation of weld undercut
criteria. These conditions were documented in DRs I-S-HVDS-089-DR-1,
DR-2, DR-3, DR-4, DR-5, and DR-6. These DRs were then. incorporated
into NCR M85-102027X for DR-1 through DR-5 and NCR M86-103774X for
DR-6. This item will remain open pending disposition of the NCRs. !
1. (0 pen) Open Item (445/8516-0-40): Potential deviations were
identified by ERC concerning: (1) dimension violations, (2) incorrect
duct dimension, (3) incorrect orientation, (4) welds were undersize, )
and (5) incorrect weld profile. These conditions were documented in
DRs I-S-HVDS-103-DR-1, DR-2, DR-3, DR-4 AND DR-5. These DRs were
then incorporated.into NCR M85-101991X. This item will remain open
pending disposition of the NCR.
m. (Closed) Violation (445/8518-V-03; 446/8515-V-02): Item A.1, failure
to certify an inspector in accordance with procedural requirements.
As corrective action for this violation, the applicant committed to ;
revise Procedure CP-QP-2.1, " Training of Inspection Personnel," with !
date of full compliance by May 21, 1986. The procedural revision was
to provide for identification of qualification responsibility and u
authority of Level III personnel involved in training and s
certification activities including those areas where a cross-over of !
. qualification authority existed. The violation was issued due to the l
failure to identify this cross-over authority. The NRC inspector i
verified that CP-QP-2.1, Revision 21, dated May 8, 1986, and
associated memorandum TUQ 3748 dated May 12, 1986, provide for this
identification of cross-over authority. This item is closed.
Item A.2, failure to follow procedures when justifying waivers of
on-job training (0JT) in the certification of four QC inspectors.
The NRC inspector has reviewed the information provided in the
>
.
}
' l h _'_ V ';y J
- 4. .S p
7
~
<
, supplementa1 re'sponse-to this violation. This review and ,
. . reinspection of the files for the four QC. inspectors: verified that-
. justification other.than ". .-2 hours OJT and previous related
inspection activity.. . ." was. included.' The justification on the
waivers included.".:. . demon'stration of practicalJfield ability to
, the satisfaction of a certified Level II." This. demonstration
. provided ". . ." assurance'that the individual does have ' comparable'
or ' equivalent'. competence to that which would have been
. gained . . ..." Therefore, specification.on the waiver of the
previous related inspection activity was'not required in these cases.
,'
Since'the required information was included elsewhere in' the q
certification files, a violation did not occur in this example'and q
this item.is closed.' U
n. ;(Closed) Open Item (445/8603-0-15): This open item: addressed.
d.
i : inspector certification documentation for fill and backfill
placements. ERC . issued DR R-S-FILL-GEN-DR-1 regarding inspector
certification-for the safe' shutdown impoundment dam construction for
the period April 24, 1976, through April'19, 1977. Inspector
certification documentation for Freese & Nichols Consulting; j
Engineers (F&N)'a'nd Mason & Johnson Associates, Inc. (M-JA) could not 1
be located during the initial ERC documentation reviews.
"
TU Electric subsequently requested copies of. certification records 'l
from F&N and M-JA. These documents were obtained and are being
transmitted to the Permanent Plant Records Vault (PPRV). The NRC j
inspector reviewed these inspector certification documents and found' 1
.that the inspection personnel were qualified to perform the :
inspections and/or. laboratory tests. This item is closed. 1
i
o. (Closed) Unresolved Item (445/8607-U-17): Incomplete craft
installation procedure instruction. NRC ins ector review of- ^
Revision 5 of Construction Procedure EEI-8, p' Class 1E-and non-Class
Cable Terminations," had identified the omission of installation i
requirements for uninsulated cable splices. This omission ~was noted
in NRC Inspection Report.50-445/86-07; 50-446/86-05 during the
evaluation of.CPRT commitments related to preinsulated environmental {
sealed (PIES) splices. During-this report period, the NRC" inspector
reviewed Revision 6 of EEI-8 dated September 23, 1986, and determined
_
that adequate provisions for all types of splices had been
incorporated therein. It should be noted that the adequacy of the ,
splices installed under the old procedure revisions is being
addressed in ISAPs I.a.2, " Inspection Reports on Butt Splices;"
I.a.3, " Butt Splice Qualification," for PIES splices; and I.a.1, ,
" Heat Shrinkable Insulation," for uninsulated splices.
p. (Closed) Unresolved Item (445/8607-U-18): Incomplete inspection '
procedure instructions. In addition to revising EEI-8, the CPRT also
committed to having certain inspection requirements for PIES splices
installed in control boards incorporated in the QC inspection !
procedure, QI-QP-11.3-28, " Class 1E Cable Terminations." The NRC
'
L: l
r:
]
1
1
. .
8 j
1
l
)
inspector review of Revision 28 of this procedure had indicated that
>
other. types of splices and PIES splices installed in locations other I
than control panels were not subjected to the same requirements as
the PIES splices in control panels. Further NRC inspector review of j
the applicable facility commitments and of Revision 31 to !
QI-QP-11.3-28 found that all of the applicable provisions not J
previously included had been incorporated into the' procedure. It
should be'noted that the adequacy of the splices instal. led under the { ;
old procedure revisions is being' addressed in ISAPs I.a.2, i
" Inspection Reports on Butt Splices;" I.a.3, " Butt Splice
Qualification," for PIES splices; and I.a.1, " Heat Shrinkable
l
.j
Insulation," for uninsulated splices. j
1
q. (Closed) Violation (445/8615-V-06): Failure of the Unit 1 PFG to f
provide specific instructions for the control of design documents
issued for extended time periods.
.i
The NRC inspector verified tha!. Procedures CP-CPM-7.4 and CP-CPM-7.4A i
were revised July 25, 1986, to provide instructions for the control
of design documents issued for extended time periods. As stated in
the response, these two procedures were superseded by issuance'of
Procedures CP-CPM-7.1 and CP-CPM-7.1A on December 15, 1986, when the
Unit.1 and 2 PFGs were combined. The NRC inspector verified that a
daily review of the Package Inventory Card for document packages
issued for extended time periods was required in these procedures and
that the requirement applied to both Units 1 and 2. These procedural i
revisions provide the required controls. This item is closed.
r. (Closed) Violation (445/8615-V-07; 446/8612-V-07): Failure to I
control the activity by which the onsite fabrication shop provides
.
inspection traceability of identical shop fabricated items. j
s
NRC review of Procedures CP-CPM-7.3A, " Material
Storage / Identification for Structural Steel Fabrication,"' Revision 0,
DCN #2, dated August 12, 1986, and QI-QP-11.14-1, Revision 24, dated
July 28, 1986, verified that these procedures were revised to
incorporate methods to control inspection traceability of identical
shop fabricated items. Since the violation was issued for failure to
procedurally control the activity and no hardware deviations were
noted during the previous inspection, the above revisions to the )
applicable procedures close this item. '
s. (0 pen) Open Item (445/8615-0-11): During inspection of Verification
Package I-M-MEIN-035, the NRC inspector identified that an equipment ,
'
foundation anchor bolt nut was not bearing load and that a 1/4" gap
existed between the anchor nut and the load bearing mating surface.
Subsequent NRC review of ERC overview inspection documentation
revealed that an ERC overview inspector had already identified the
deviating condition and that DR I-M-MEIN-035-DR2 had been issued and I
validated, resulting in the issuance of NCR M-23094 NR-2. This item
remains open pending disposition of the NCR.
___-
r ,
,L..
_
- .
9
,
' ~
3.' :CPRT-ISAPs (excluding'ISAP VII.c)
..
a. Heat-Shrinkabl~e Cable Insulation Sleeves (ISAP I.a.1)
I* ,
During this: inspection _ period,.the activity. identified by NRC
Reference.01.a.01.07 was. inspected as-follows:
.
.
!: Establish' Sampling Plan / Select Sample (NRC Reference'01.a.01.07)-
.The NRC inspector reviewed the CPRT: files and determined that a
sample of 128. heat'shrinkab'le. insulation. sleeves was. selected by the
CPRT for inspection from 'a total of 1359 locations listed in the
action plan. A detailed dis'cussion;of the sample selection process
for this ~ISAP .is contained in paragraph 5.b(1) below. ,
Since the:. sample selection process was determined to adequately
fulfill the CPRT commitments, this activity and NRC inspection is
complete. '
No violations'or deviations were identified.
b. QC Inspector Qualifications (ISAP I.d.1)
.During ~ this inspection period, the NRC inspector inspected the
processing of DRs and the. verification of inspector qualifications
performed during ISAP I.d.1 by ERC personnel for inspectors whose '
. certifications were not found acceptable during ISAP VII.c review.
This inspection was accomplished by first reviewing.the controlling
Procedures.CPP-025, '.'QC Inspector Qualification Evaluation," and
CPP-010, " Preparation of Deviation Reports," and then performing a
detailed review of DRs related to inspector certification that were
generated during'the VII.c review process. The DR processing was
reviewed.by.the NRC inspector for'the following attributes:
-(1) Inspector certification related DRs were forwarded to the
ISAP I.d.1 issue coordinator in accordance with CPP-10.
(2) The validity of DRs was properly evaluated by the ISAP I~.d.1
issue coordinator.
(3) The transmittal of DRs was in accordance with CPP-10.
<
(4) The determinations of inspector qualification for the
uncertified QC inspectors was proper and the determinations were
documented on the Inspector Certification Evaluation Summary
(ICES) form.
(5) The determinations to reinspect any previous work of unqualified
inspectors were proper and documented on a memorandum addressed
to the ISAP VII.c file as required by procedure.
l
.. .
10
(6) Reinspections of any previous work performed by the unqualified !
QC inspectors were accomplished in accordance with QI-005,
" Evaluation of Inspector Performance."
(7) ~ Validated DRs were transmitted to TU Electric for documentation
on an NCR/DR.
~
The above procedures were determined by the NRC' inspector to provide
the necessary controls for evaluation and processing of the DRs. The
procedures specified the personnel responsible for performing the
DR evaluations and the actions required for documenting the
evaluations. The procedures also provided guidance for the
DR evaluations by reference.to ISAP I.d.1, "QC Inspector
Qualifications," and QI-005, " Evaluation of Inspector Performance,"
which detail the methods to conduct evaluation of QC inspector
certification and qualification.
The process by which ERC performs an analysis of file documentation ,
to evaluate the qualifications of QC inspectors is being inspected by !
the'NRC under its review of ISAP I.d.1. That process is identical to
the process utilized for evaluation of inspectors identified by
ISAP VII.c, with the exception that proper QC inspector certification i
is determined by the ERC VII.c inspectors in accordance with VII.c !
inspection / documentation review required in 28 of the 75 QIs used for
reinspections.
,
During sample inspection of the document review packages, the NRC has l
been verifying whether a certification exists for the inspector of i
record, where required. l
To evaluate the system by which inspector certification / qualification l
is evaluated, the NRC selected a sample of 32 DRs concerning-
inspector certifications that were identified during the VII.c
document reviews. All 32 DRs were found to have been transmitted,
processed for validation, and maintained as specified by CPP-10 and l
CPP-025. The NRC inspector verified that the results of the I.d.1 !
issue coordinator's review of the certifications in question were J
documented on inspector certification summary forms and that !
justification for the results was provided. l
!
The NRC inspector found that of the 32 DRs selected, 28 were I
determined by the issue coordinator to be valid and 4 were determined )
to be invalid. NRC review of the packages for the four invalid DRs j
found that the certifications had existed for the certifications !
questioned by the VII.c DRs and that documentation existed to support
the certifications.
NRC review of the packages for the 28 valid DRs found that
2 inspectors were determined by the I.d.1 issue coordinator to be
unqualified for the inspections performed. Therefore, a I.d.1 q
Phase III reinspection was specified as corrective action. The !
26 remaining inspectors were determined by the I.d.1 1ssue
i
!
, ,
i' 1
11 I
l
1
coordinator to have been qualified for the inspections performed. ;
The basis for the disposition of the 28 valid DRs is shown in the i
following' table: ;
q
Inspector qualified under equivalent Brown & Root (B&R) 1
'
certification. 9 H
Inspector qualified under Level II and all daughter
certifications. 1 3
Inspector qualified under contractor certification other {
than B&R (e.g., R. W. Hunt). 4 1
Inspector qualified as determined by Special Evaluation i
Team /RTL review. 2
6
Inspector qualified but administrative / clerical errors i
require DR. 5
Inspector qualified under previous similar certification. 5
Total determined qualified. 26 .!
Total determined not qualified and sent to Phase III
for Reinspection. 2
The NRC inspector verified during review of the validated VII.c DRs
that the I.d.1 determinations of qualifications were supported by
documented evidence of comparable prior certification, sufficient
training and examination for the inspection activity, or in the case
of the two inspectors determined by the issue coordinator's review to i
be qualified, that previous training and inspection activity was
sufficient and applicable for the certification in question.
l
The NRC inspector verified that the 28 valid DRs were transmitte'd to l
TU Electric and NCRs were prepared.
As reported in NRC Inspection Report 50-445/86-22; 50-446/86-20, the
NRC inspector reviewed four reinspection matrices utilized for the
ISAP I.d.'1 Phase III reinspection of construction inspectors whose l
qualifications were determined to be unsupported by file
documentation. The four matrices were found to be in compliance with
QI-005, " Evaluation of Inspector Performance." Additionally, the NRC
inspector witnessed two field reinspections which were satisfactorily
performed by ERC inspectors in accordance with these matrices.
No violations or deviations were identified. The evaluation of DRs
pertaining to inspector qualifications generated by ISAP VII.c or
other.ISAPs will continue to be inspected by the NRC.
c. Inspection for Certain Types of Skewed Welds in NF Supports I
(ISAP V.a)
Status of NRC Inspection Activity
The NRC inspector verified compliance with the following ISAP V.a
activity commitments:
~ ,
u
'd e-
12
'I
Chronology of Inspection Methods (NRC Reference 05.a.01.00) i
The methods for QC inspection of type-2 skewed welds and the written
procedures describing the methods and means of documenting the l
inspections have changed during the construction of the CPSES
project. The technical focus of ISAP V.a is the inspection of the
geometric and dimensional characteristics of skewed welds at
' locations where simple fillet gauge measurement was not possible.
In order to determine what inspection instructions were applicable
for specific time frames, a chronology of inspection methods i
documented in QC procedures was developed by the third party to .
correlate the period of time and specific procedure revisions for !
inspection of type-2 skewed welds.
The inspection techniques used and the methods of documenting the .
inspections of type-2 skewed welds involved the following procedures: l
QI-QAP-11.1-26: which addressed the fabrication, installation and
inspection of ASME pipe and attachments welded to the pipe.
-QI-QAP-11.1-28: which addressed the fabrication, installation and
inspection of ASME pipe supports except for attachments welded to the
pipe.
'
CP-QAP-12.1: which addressed the final verification of ASME pipe
supports prior to certification (preparation of the ASME N-5 form).
Relevant historical changes affecting these quality procedures are as
follows:
QI-QAP-11.1-28: Revision 12 dated September 3, 1982, and Revision 13,
dated September 21, 1982 - Specific criteria for the measurement of
type-2 skewed welds using the scribe line technique was incorporated
into the procedure at that time. ,
QI-QAP-11.1-28: Revision 16 dated December 15, 1982 - The type-2
skewed weld inspection methodology was deleted from the pipe support
procedure,
CP-QAP-11.1-26: Revision 9 dated December 16, 1982 - The type-2
skewed weld inspection methodology was incorporated into the piping
procedure.
QCWI-1:' Dated February 21, 1983 - This B&R instruction was issued to
inform inspectors to use inspection methodology and acceptance
criteria in piping Procedure QI-QAP-11.1-26 when measuring type-2
skewed welds on pipe supports.
- im <
\
4, A
- y
,,
V'( .
- (
6'., 4
,
g
-,
pm <
a
.q
'
m' h
j
'
CP-QAP-12.li Revision' 4 dated February 2.c1983,- and Revision' 5 dated
March 18,-1983.- These'. revisions'were issued to. initiate reinspection
-
'>
g ~o fLall' accessible structural' welds on ASME. pipe supports.
%e '
3
. QI-QAP-11.'l-26: Rev'idion13datedAugust4,1983-!Theprofile
. technique for measuring' size of type-2' skewed welds was added to the-. 1
'c'
piping. procedure.' ',
.
' QI-QAP-11.1-28:' Revision;29 dated January 25, 1985.- The scribe line"
L technique for measurement of type-2 skewed fillet welds was
reincorporated into the support procedure.
l
3
- QI-QAP-11.'l-28:JRevision 30 dated April 15, 1985 - The profile j
technique for measurement of-type-2 skewed welds was incorporated- '
into the support procedure.
_
.,
'
-Six different methods'of documenting'the results-of' type-2~ skewed
weld inspections were permitted by procedure' at various times. These'. '
methods were: i
(1) HIR Hanger Inspection Report -
(2) CSC Component Support. Checklist
.
(3) MWDC- Multiple' Weld Data Card
l
.(4) WICL Weld Inspection Checklist f
(5)' CSF/SWIR ' Component Support Fillet and Skewed Weld-
Inspection Report
(6) COT Construction ~ Operation. Traveler
The NRC inspector reviewed historical revisions of the ASME, Quality
' Assurance Procedures / Instructions Table'of Contents to verify the
accuracy of the developed chronology and also checked the methods
permitted by these procedures for documenting type-2 skewed welds. 'l
NRC inspection of this activity is complete. NRC inspection of
activities listed above also provide a basis for completion of
activities required by NRC Reference 05.a.01.01 and 05.a.01.02.
No violations or deviations were identified.
d. Document Control (ISAP VII.a.3)
,.
'
Du' ring t' his report period, the activities identified by NRC Reference
07.a.03.04 and the closeout of related external issues were inspected
as follows:
.
, w dq
4
'
I
, .-
>
i ' ,
L '
14
.
, >
'
.'
ProcedureEvaluation-(NRCReference07.a'03.04) f
This ISAP required an evaluation of'the current CPSES document ]
- control; procedures. The-issue coordinator' performed the evaluation,. j
l conducted and documented the results'of the interviews, and completed !
a procedure checklist, which in total formed.the basis for the .
~
evaluation. ,
.The; NRC' reviewed the procedure checklist and compared it to the. ..
requirements in Criterion VI of. Appendix B.to'10 CFR Part'50, and to.
the commitments'in the CPSES FSAR. The procedure checklist was found- .;
to address'the requirements'and commitments;concerning distribution !
and control of documents affecting' quality. Utilizing this
'
.
checklist, the NRC inspected the current controlling Procedure DCP-3, ^
Revision 19, "CPSES Document Control Program," to verify.that ERC had
implemented the checklist properly and that the procedure met the.
above requirements and commitments. -The procedure was found to
'
properly contain.the following attributes: measures to assure that
all documents, and changes to documents,'were reviewed and approved.
~by. authorized personnel prior to distribution; and measures'to assure .
that all documents used for construction or. inspection, activities
~
H
were maintained current and in a' controlled status; Additionally,. ,j
the procedure provided for: retrieval'or identification of superseded.
documents and for'an ' ongoing monitoring of' document control-
performance of all controlled doc'ument. files.by an independent.
monitoring team. 'No differences between'the.NRC and ERC~results were
noted in the completed checklists.
In. addition, the NRC inspected the implementation of DCP-3 by
requesting a sample'of 20 drawings and 10 procedures'from the .
document control center (DCC)'and one satellite. These documents. .
. were fourid to beLat their current ' revision with all design changes - i
entered when compared to the DCC master list of controlled documents.
^
Thelimplementation'of tho independent monitoring team was inspected- l
by the NRC inspector by interviewing the head of the monitoring team,. ;
. reviewing' monitoring'reportsLand executive summary reports, and -i
reviewing the report distribution which included the Vice-President,.
Engineering and Construction. Th'e monitoring team's reports !
'
indicated that-the' document control groups were achieving an error
-rate of less than 0.1%.
The NRC interviewed the ERC engineers responsible for 11-of the- :I
'
32 populations.in ISAP VII.c to obtain similar information from the
. implementation of the VII.c ISAP. These engineers stated that of the
4,000 drawings utilized during inspection of .the 11 populations, they
found 6 document control errors or a 0.15%' error rate.
Based on"the' foregoing NRC inspections and the favorable comparison ,
with the results of the ERC inspections, this item has been properly l
t , i
<l
_
,
i
, , ,
i
'
15
implemented. No violations or deviations were noted during the
inspection of this area of the document control program. j
l
Closeout of Related External Issues
Two external issues related to document control were identified in l
ISAP VII.a.3. The issue of unauthorized procedures used for i
cold-springing of piping was addressed in ISAP V.e and was not
considered further in this ISAP. The issue that a " Controlled Copy"
stamp was improperly used by B&R ASME QA personnel was addressed.
!
'
The NRC interviewed the current B&R document review supervisor who
stated that the document review group does not cuerontly use a
" Controlled Copy" stamp; however, this supervisor did state that for
a short time a stamp was used to mark drawings prior to presentation
to the Authorized Nuclear Inspector (ANI) for review. The NRC also
interviewed the B&R QE group supervisor that was involved when this
stamp was used. This individual indicated.that the stamp was used on
copies of small bore typicals before presentation to the ANI for
review. .1he practice was stopped and the stamp defaced after
issuance of $pecial Inspection Services (SIS) Report 355, which
documented the ANI's concern about the use of the stamp. Evidence of
the stamp dafacing was p'rcvided by a memo to the QA file dated
August 10, 1984, bearing an imprint:of the stamp before and after
defacing.' The corrective actions taken appear sufficient to prevent
recurrence. The improper use of the " Controlled Copy" stamp had been
previously determined by the NRC Technical Review Team (TRT) in c
SSER 11 to have had no adverse safety implications. No further NRC
inspection cf this item is planned.
4. Construction / Reinspection (ISAP VII.c) i
a. Establishing Populations
Section 4.3.1 of ISAP VII.c, Revision 1, required safety-related
hardware to be categorind into populations with homogenous work
activities (HWAs)' and associated quality characteristics (attributes) i
from which the required-random samples were selected. It also
required that a description and justification for homogeneity be
prepared for each population. Finally, each population was to have a
.
list of all final QC accepted safety-related itens. The CPRT 1
guidelines for establishing homogenous populations were contained in
the project procedure for ISAP VII.c, Procedure CPP-005, Revision 3.
This procedure required the discipline engineers to review equipment
lists from CPSES in order to subdivide the plant into homogeneous
populations that have been constructed using reasonable bemogeneous
work processes. The equipment reviewed, as specified in !
paragraph 3.0 of ISAP VII.c, was limited to that which was safety
related, construction complete and final QC accepted. The equipment {
i
4
'f
w yg , x ,
k[p wQAK
W-.
,I 4
l
l
,tc .t. g
$ i
'
16 i
!
!
1 '
i
.would be inspected for attributes selected after a complete ' review of l
engineering documents pertaining to the individual populations.
-
I
W
The generation of a Population Description, Master Population list,
1 Population Items List, and a Work Process Memorandum are also
. procedurally required along with adequate control of subsequent j
revisions to each of these documents.
The NRC inspectors reviewed six ISAP VII.c populations '(i.e. , Large
Bore Supports. Rigid, Large Bore Supports Nonrigid, Small Bore Pipe !
Supports, Pipe Welds / Material, Concrete Placement, and Electrical !
Cable) to ensure that the homogenous populations were correct and i
'.
adequate and that ERC procedures, primarily CPP-005, were being l
adhered to. .
(1) Large Bore Supports Rigid (LBSR), Large Bore Supports Nonrigid -
(LBSN), and Small Bore Pipe Supports (SBPS)
The NRC inspector's review of these three populations was
performed concurrently because the population descriptions are
similar except for the population boundaries (large bore rigid,
large bore nonrigid, or small bore) and the Population Items
Lists were all derived from the same source document;.the Hanger
Installation Tracking System (HITS) list.
(a) Population Descriptions i
? !
'
/- NRC inspection verified that the systems listed by the CPRT
,U-
for inclusion in these three populations were designated in
Section 17A of the FSAR as safety related, either Safety
{, Class 1, 2, or 3, and Seismic Category I. Cross checking
,
from FSAR Table 17A to the three populations, however, by
~~
the NRC inspector identified that the Chilled Water System
(CWS) was omitted from the CPRT populations. Subsequent
review of the Population Items Lists did reveal that the
C CWS was included in the population; it was only
,
inadvertently left off the Population Description lists of
'
systems. The NRC inspector agreed that the listed
I population boundaries described all supports within the !
definition of each population and that the Population
Descriptions adequately described those items which are not
L
included within the scope of the populations. For example, ,
the Population Description for Small Bore Pipe Supports, l
,, Revision 1, dated July' 23, 1985, states that the population
L
~
boundaries shall be small bore (2" NPS and smaller) pipe
supports located in Units 1 and 2 and common areas which
are seismic category I and of Safety Class 1, 2, or 3. The
scope of each population item shall include the support
cc nponents shown on the individual drawings. Exclusions
frw this population will be building structural members,
small bore piping, large bore pipe supports, and instrument ,
!
)
(- - =
'
Q , d
- ,
y. .
,
s
t
( ,'-
' '
t, 17 N'
.,
'
8 .
) '
,
c >
!
$ ) , t
' i
'
piping and tubing supports. All CPRT sign-ohfs for revbiw' 3
.g cod approval as wall as' control and filing in CPRT records "
v} of the population' descriptions wersperformed per ,
' s p rocedure. i
h'
,
'
{
t t s 4
s t ,d
A. ,
s(b) Master Population List ' ,L4
i '
.
I
.
'
,
^
NRC inspector r,etfew of the original Master Population List 1
%'
'
p and all. su'eseedint . revisions (one throtsh five) verified
(L '
4' -that the ebovd thre4 populations were included on the list
' <
and that t'eview;Jarproval, and contpol of the documents are
4 e per procedurej i '
, -
! .
. t
(c) Population Items Lirt
\- k
Each of th'e three Population Items Lists were derived from
the HITS list. Th6 CPRT initially established the validi,ty
n and, accuracy of the HITS. list and then segregated out ths
t ,
' 6, three homogenous' pipe support populations (LBSR, LBSN, and
s j
SDPS). To establish validity anA accuracy of the HITS
list, the CPRT randomly selected M B&R Hanger Location
,
(BRHL) drawings out of the listed total of 2013 and <
m
'
manually checked to see that all supports listed on the .
', 'N 4 .,
3 J60 BRHLs were also listed on the HITS list. To verify th9 j
/ -
. 'J" 7
accuracy of the support status listed on the' HITS list, '
? <
>
(. s . s60 supports were randomly selected from the 60 BRHLs and 3 t
,' their status individually verified by checking records in'
'
4
}
v the various vaults and processing areas. This was require 0
because only final QC accepted pipe supports were to be
reinspected under the VII.c program. No discrepant
s
,
,
conditions were detected by the CPRT.
,
, <$
To assess validity and accuracy of the CPRT. verification of
!, . the HITS list, the hRC . inspector selected 10 out of the
,
f. { l Ii
,
60 BRHLs that the CPRT had reviewed, and verified that all
,
,' '
supports shown on the BRHLs.were included on the HITS list. .;
To further assess the HITS list, ten additional BRHLs not !
'
selected by the CPRT wera seiected by the NRC inspector and ,
4 1 ,
'
checked against the liITS list.foi sepport inclusion. These
'
' { \, 10 BRHLs were selected such that a cecss section of
l 7 safety-related systems within the population were included
in the review. Finally, the NRC inspector reviewed the
'
,
!
n ,
,
completion status'of 10 of the 60 supports that the CPRT
s '
'
'
had verified by researching records in the various vault
[,{l 3 < Jocations. No discrepancies were identified.
,g r \ > ,
- (d) Work Process Memoranda
"
< Pevision 3 to Procedure CPP-005 dated May 28, 1986,
,
,
required all ISAP VII.c populations to have a Work Process
,
Memorandum. This memorandum was to identify safety-related
.
,
..
.
]
. .
18
construction work processes and attributes that can be
reinspected and/or verified by document review. l
During this report period, the Work Process Memoranda
covered under this inspection were in the final draft
stages; therefore, they will be reviewed at a later date.
This is an open item pending completion of NRC review of ,
these Work Process Memoranda (445/8702-0-01; l
446/8702-0-01). ,
I
(e) Revisions l
NRC review of all revisions to the Master Population List,
Population Descriptions, and the P7."slation Items List for
-the three populations revealed that the criteria of
Section 5.5 of Procedure CPP-005 were being adhered to as
far as sign-offs for review and approval, and control and
'
vaulting of the subsequent revisions.
No violations or deviations were identified.
(2) Pipe Welds / Material (PIWM)
This population was created by combining the two populations i
which were previously titled Large Bore Pipe Welds / Material ;
(LBWM) and Small Bore Pipe Welds / Material (SBWM). In addition
to this combination, mechanical equipment, site-made, pressure
boundary welds were added to the PIWM population, and tubing
welds were organized into a separate populaticn (TUWM). At the
present time there is no documentation on file relative to the
basis-for these actions. This is an open item pending
development of such documentation and NRC review (445/8702-0-02;
446/8702-0-02).
(a) Population Description
NRC inspection verified that the systems listed by the CPRT
for inclusion in this population were designated in
Section 17A of the FSAR as safety related, either Safety
Class 1, 2, or 3, and Seismic Category I. In reviewing
Table 17A, however, it was observed by the NRC inspector
that the Boron Thermal Regeneration System, Combustible Gas
Control System, Post Accident Sample System, and the Plant
Gas System were not listed in the CPRT Population
Description, though they should have been. Subsequent
review of the Population Items List, however, verified that
these systems were included in the population; they were,
apparently, inadvertently left out of the Population
Description.
l
l
,
o e
i
19
The NRC~ inspector concurs with the population boundaries
and items not included in the population, as listed in the
Population Description.
,
(b) Master Population List
NRC review of the original Master- Population List and all
subsequent revisions (one through five) verified that the
PIWM population was included on the list and that review,
approval, and control of the documents were per procedure.
(c) Population Items List
l
The source document for the Population Items List was the
B&R Comanche Peak Craig Computer Tracking System (CCTS)
Report WEC-C-WE-REPORT issued June 12, 1985. This report ,
was a computer sort of all safety-related and QC accepted i
large and small bore pipe welds and instrument tubing welds
contained in the B&R computerized data base Welding
Engineering Component Master Report used for tracking
construction progress of site-made welds.
Attachment 6.3 of ERC Procedure CPP-005, Revision 3,
states, in part, "The Responsible QA/QC Discipline
Engineer . . . [p]rovides the basis for accepting the list !
as valid." In addition, "The QA/QC Lead Discipline
Engineer and the QA/QC Engineering Supervisor review
Population Items List? to ensure that they are complete,
accurate, and consistent with the requirements of this
procedure." ERC stated on the Population Items List that
the following four steps were taken to validate the list:
1) A verification was made that the 591 site-made welds
listed on the ASME III N-5 Data Report Index for the
Unit 1 Auxiliary Feed Water system were on the
! Population Items List. 1
L
2) A review was performed of field welds specified on all
26 Unit 1,BRP drawings for the Residual Heat Removal
j system and 26 randomly selected Unit 2 BRP drawings
l with respect to their inclusion in the
l WEC-C-WE-REPORT. All welds were found to be included.
I
!
3) A review of 675 WDCs from several Unit 2 systems for
instrument piping welds was performed with respect to
i their inclusion in the WEC-C-WE-REPORT. All welds
were found to be included. !
4) A review was performed of the construction completion
(C/I) status of welds listed in the Welding
Engineering Component Master Report. From this
a
.Y
, ,
I ef' ? 9-
.
t
review, it was ascertained that most of the diesel
, ,
' generator (Unit 1 and Unit-2) piping site-made welds '
had not been assigned a complete / incomplete status
runder the C/I column. . Accordingly, these welds.were
not . identified in WEC-C-WE-REPORT computer sort of ~
. complete,-QC accepted piping welds. These' welds were
. added to the WEC-C-WE-REPORTLto complete the'
Population' Items List.- 1
a
The NRC inspector. initially. compared the systems listed in
.
'
FSAR Table.17-A to the source document to assure
H . consistency. Next, the NRC inspector randomly selected-
,23 BRP drawings'for' Unit 1 and Unit 2'not previously:
selected by the CPRT and verified that the 416 site-made.
welds were included on the Population Items List. No
omissions'were noted.
To further. verify accuracy of'the CPRT approach, 10 of the
52 BRP drawings reitiewed by the CPRT were compared to the
source' document. .No discrepancies were found.
(d) : Work-Process Memorandum
See paragraph 4.a(1)(d) above.
.
(e) ' Revisions
NRC review of all revisions to the' Master Population List,
Population Descriptions, and the Population Items List for
the population revealed that the criteria of Section 5.5 of
Procedure CPP-005 were being' adhered to as far as sign-offs
for review and approval and. control'and filing in CPRT
records.of the subsequent revisions. j
No. violations or deviations were identified.
s
'
(3) Concrete Placement (CONC)
The concrete placement. population contained 7617 concrete pours
identified on a computer' printout generated by B&R from concrete
pour cards.
-(a) -Population Descriptions
The'NRC. inspector. reviewed ERC document QA/QC-RT-328, I
Revision 0, " Population Description for Concrete
Placement." The population boundary included. all.
Category'1 concrete construction that had been completed
and approved as of August 1, 1985. The Category 1 l
structures were listed in Attachment A of the Population d
-
Description. The NRC inspector verified that Attachment A
i
'
o
..i .
21
J
agrees with the FSAR, Section 3.2.1.1.1, which also lists )
Category 1 structures. A subsequent review of the j
Population Items List (see below) verified that the list 1
contained concrete pours from each of the Category 1 !
structures listed in Attachment A. The NRC
inspector' concurred with the population boundary and the
items not included within the scope of the population. The
CPRT. review and approval as well as the filing in CPRT
records of the Population Description were performed per
Procedure CPP-005.
(b) Master Population List
NRC review of the Master Population List, Revision 5,
verified that the concrete placement population was
included on the list. Review, approval, and control of the
Master Population List was per Procedure CPP-005.
(c) Population Items List i
The NRC inspector reviewed ERC document QA/QC-RT-1628,
Revision 1, " Population Items List Concrete Placement."
The population source was a 254 page computer printout
generated from individual concrete pour cards by B&R. This
list included the concrete pour number, date poured and a
brief description of the area poured for each of the
7617 concrete pours in the population. According to this
document, the population list " . . . includes all
safety-related concrete pours in Unit 1, 2 and areas common
to both units."
Attachment 6.3 of ERC Proceduro CPP-005, Revision 3,
states, in part, "The Responsible QA/QC Discipline
Engineer . . . [p]rovides the basis for accepting the list
as valid." In addition, "The QA/QC Lead Discipline
Engineer and the QA/QC Engineering Supervisor review
Population Items Lists to ensure that they are complete,
accurate, and consistent with the requirements of this
procedure." ERC stated on the Population Items List that
the following three steps were taken to validate the list:
1) Twenty arbitrarily chosen pour numbers identified on
B&R drawings were found to be on the population list.
2) An arbitrary selection of concrete pours from
Inspection Report Logs were reviewed against the
! population list and no discrepancies were identified.
3) A review of the population list confirmed that no time
gaps were apparent in the pour dates.
- e ,
>
'
"
.22
.The NRC' inspector reviewed the steps taken by ERC to-
validate the population list fo'r ' concrete placement.' Only
step.1 above was documented. A handwritten, unsign'ed and
undated' memo describes the 20 concrete. pours (10 from the
random sample and 10 from the safe shutdown sample).that~
were verified by ERC to be on the population list. The
20 concrete pours selected by ERC for verification of the
completeness of the population list represent only
0.26. percent of the total population of'7617. The extent
of'the ERC review is. inadequate to ensure accuracy and'
.
' completeness of the Population Items' List. .The NRC
inspector. verified that the 20 concrete pours' selected by-
ERC were on the population' list.
In' addition,.the NRC inspector prepared a randomly se.lected
, list of 134 concrete pours from 17 B&R drawings'and
compared this list with the Population Items List to.
determine if the 134 concrete pours were included. The
following discrepancies were discovered:
'1) Pour Nos. 205-9810-039 through 205-9810-056 are shown
as block-out type pours in the east diesel generator
' foundation, Unit 2,.on Drawing SSB-20655, Sheet.1,
Revision 5. Pour Nos. 205-9810-040 and'205-9810-048
through 205-9810-056 were not on the Population. Items
List and no corresponding pour cards'could be obtained
in the TV Electric records center. Pour
Nos. 205-9810-039 and .205-9810-041 through-
205-9810-047 were assigned on drawings at least twice
and are shown, for example, on Drawings SSB-20605,
Sheet 1, Revision 7, and'SSB-20618, Sheet 1,
Revision 2, to be concrete curbs, removable slabs,
etc. ; not block-outs. Pour Nos. 205-9810-039 and
205-9810-041 through 205-9810-047 were on the
Population Items List. They did not, however,
represent the block-out pours in the diesel generator
foundation as determined by checking the' concrete pour
cards. The NRC inspector verified by field
inspections that the block-out pours had been
installed.
2) Pour No. 205-4822-003 is shown as a shielding wall for.
the Primary Sampling room on Drawings SSB-20605,
Sheet 4A, Revision 0, and SSB-20605, Sheet 4,
Revision 0. This pour number was not on the
j Population Items List. A pour card for this pour was
located in the TV Electric Records Center. The NRC
inspector verified by_ field inspection that the
shielding wall had been installed.
-
,
1
q
- v+ ^
./' i
, ..]
23 U
, ,
u
'
The above discrepancies ' indicate that the Population It' mse
List .is not entirely complete and accurate and does not- <
include ". . .~all safety-related concrete pours in
LN t 1, 2.and areas common to both units," as stated. .The ;
ERC review of the- Population -Items List to ensure accuracy ' i
This:is a deviation'
'
and completeness was inadequate. ;
(445/8702-D-03;-446/8702-D-03). i
(d) Work Process Memorandum'
i-
See paragraph 4.a(1)(d)'above. l
(e)' Revision's
NRC review of all revisions to the Master Population' List,
Population Descriptions, and-the. Population Items' List for i
the population revealed that the criteria.of Section 5.5 of
Procedure CPP-005 were being adhered to as'far as sign-offs
for review and approval, and control and filing in CPRT q
Records of the subsequent revisions.
No violations or deviations other than as'discu sed in (c):
above were identified.
(4) ' Electrical Populations
.The NRC inspector reviewed the Population Items List
documentation for each of the electrical. populations to
determine which sources were used to develop the population and
the basis for the CPRT determination that the developed
population.was accurate.
The NRC inspector found that the conduit, cable, cable tray,
electrical equipment and NIS cable termination (CDUT, CABL,
CATY, EEIN, and NIST) population lists were generated using the
TU Electric Electrical. Management System (EMS) as a source. EMS
~
-was a computerized cable and raceway schedule developed by site
-
personnel'to track'the status of Unit 1, Unit 2, and Common ,
cables and raceways. Cable and raceway' changes authorized by I
design' change authorizations (DCAs) were entered into EMS on a
daily basis. . The EMS then provided a printout of these daily
changes on a Daily Activities Report. Since EMS was neither a
required permanent plant
'
.the previous EMS revision. document
s and nor controlled
Daily Activity by procedures,
Reports had not
been retained as permanent plant records; however, the NRC
inspector observed that' copies of the EMS printouts which had l
been used by ERC for population list development, were retained l
in the QA/QC Review Team files in the CPRT document control '
center.
- I
,
_
,
h
t
rr.
- , Dc ,
p ,
,
24
+,
The electrical cable.(CABL) population was. selected for a more
p' - detailed NRCfinspection to evaluate the implementation of the-
appropriate procedures for establishing and accepting the
'
_ population.
(a)l Population Description.
1, The NRC inspector's review of the Population Description
.
for cables identified that the population was to include.
'
-all Class 1E', safety-related power, control and instrument l
cables. - The population boundary for samples selected.for '
reinspection / documentation reviews was' restricted.to those
cables which had been installed, terminated on both. ends
and QC accepted. Excluded from the population were
electrical conductor seal assemblies, NIS cable connectors,
and unscheduled lighting (except.for sep'aration barrier
material inspections). These three groups were. excluded-
from the cable population-because they were included in <
,
other populations. Based'on his understanding of the >
systems involved, the NRC inspector concurred that the
population boundary and the items not included within.'the
scope of the population represented a valid. population of
involved electrical cable. The CPRT! review and approval as H"
well as the filing of the Population Description was
performed per Procedure CPP-005.
(b) Master Population List
'
NRC' review of the Master Population' List, Revision 5,
verified that the electrical cable population was included
on'the list.. Review, approval, and control of the Master-
Population List was per Procedure CPP-005.
'
(c) Population: Items List.
Procedure CPP-005 required the responsible QA/QC Discipline'
Engineer to prepare a list of all applicable items ~within
the population out1.ined in the Population Description along
with the. method of development. This' list was then to be) ,
reviewed and approved by the QA/QC Engineering Supervisor- '
who would forward it to the QA/QC RecordsfAdministrator.
The NRC inspector verified that a comparison of the items l
documented in the Cable Population Items List to the items
required by CPP-005 was performed by the QA/QC Discipline
r Engineer. The list was divided into three parts:
. Population List Source; Basis for Accepting the List; and
J Basis for Accepting any Additional Items. The NRC
inspector determined that this met the requirements of.
CPP-005.
I
..t
v:W .
'25 -
The Population List Source contained 'the-listing and'
. description of the documents used to, develop the listing of- !
. applicable electrical cables'. The sources referenced were !
E
the EMS cable report (ELE SAFETY RPT) dated June 17, 1985,
'
and'the Gibbs & Hill (G&H). Lighting Panel. Schedule, ~ .
-
Drawings 2323-El-0942-01'through -05-and.E2-0942-01 through
-03. NRC inspector review'of these documents disclosed'
~
that Drawing 2323-E2-0942-03 did not exist. The NRC.
inspector then reviewed the file applicable to the Basis
for Accepting the List and questioned how the EMS was-
validated by the CPRT as'a'completeLsource of applicable-
electrical. cables. The NRC inspector'wasLinformed that.the
.QA/QC Discipline Engineer responsible for the cable '
population had selected 30~ cables each from the raceway.
schedules for Unit 1 and Unit 2 (2323-El-1700-
'o and 2323-E2-1700) and.then. compared these' cables to the EMS
-listing he had used in order to verify the validity of the
source documents.: The NRC inspector also' verified, by a 1
review of the CPRT files, that the'QA/QC Engineering. . .
Supervisor had approved and forwarded the list as required... '
-The NRC inspector determined, based on the above, that the
requirements of CPP-005 had been fulfilled in establishing
this population.
In an effort to separately evaluate the acceptability of.
the cable population (which contained over 14,000 cables)
the NRC inspector chose an arbitrary sample of affected:
cables. Between 1 and 6 cables from each safety-related
plant system from the Unit 1 and the Unit 2 raceway
schedules in the plant permanent records vault and
14 cables from the unscheduled lighting panel drawings were
selected. This resulted in a sample which contained.
125 cables from 55 systems in Unit 1 and 122 cables from
51 systems in Unit 2. These cables were then" compared to
the CPRT's cable population list to provide assurance that
the population-list used by ERC'was complete. The
comparison of these -lists produced the following findings:
1) The list of Essential and Emergency Lighting cables
was not in the, file,
,
2)- Pages 813 and 814 of the EMS listing were missing'from
the file,
3) Cable E0000425 was not' included in the file list, and
p
4) Cable E0135036.was shown as EG135036 in the file list.
The NRC inspector then determined that: a copy of the list
of Essential. and Emergency Lighting cables was available in '
the electrical conduit population files; the missing EMS
l
a + ,
h?
- T# ,
26 I
'
.
1
'I
~
'pages were available from working copies; DCAs 18,100
and 18,547 authorized a designation change for cable !
E0000425:to A0000425; 'and the improper separation train
p
'
' designation _(G vs. 0) for cable E0135036 was a. data entry
error.', Since;the NRC's inspection showed that the cable
population.lis.t developed by the CPRT'from.the EMS. appeared
to be more. complete than the Cable and Raceway Schedule J
from the permanent plant record vault, the NRC inspector )
found that the population list was' acceptable. . However,- 1
"
the condition of the record files not being' complete as-
evidenced by 1) and 2) above is a deviation from ERC ,
Procedure CPP-004, " Project Working Files," Revision 2,- !
dated D.ecember:17,1985 (445/8702-D-04; 446/8702-D-04). -
(d). Work Process Memorandum
See paragraph 4.a(1)(d) above.
(e) ' Revisions j
,
NRC review of all revisions to the Master Population List, .;
Population Descriptions,.and the Population Items List for-
-
-
H
the population revealed that the' criteria of Section 5.5 of 1
Procedure.CPP-005 were being adhered to as far as sign-offs
for review and approval, and control and filing in CPRT
records of the subsequent revisions.
No violations or deviations other than as discussed in (c),
above, were identified,
b. Reinspection of HVAC Equipment Installation (HVIN)
Status of CPRT Activity
A total of 181 HVAC equipment packages were randomly selected and
inspected from a population of 604 packages representing Units 1, i
2 and common. A total of 331 DRs were written with 187 determined to
be valid. ERC has completed all planned HVAC equipment installation
reinspections.
Status of NRC Inspection Activity
The NRC inspector reviewed the HVIN population with respect to HVAC .!
fire dampers and their inclusion in the population. The NRC 1
inspector identified that approximately 30 percent of the_ random and W
engineered samples consisted of fire dampers that were statused as j
" Abandoned In Place"; i.e., nonsafety related. This raised a j
question with respect to the inclusion of nonsafety-related equipment ]
in the HVIN population. This was discussed with the population
engineer who provided the following information. Due to problems
that were identified with fire dampers which limited their ability to
!
!
l
V. . . . . .
. . - .. - . .. --- . --- - .
_. i
1
I
, o ..
i
27
,
<
i l
1
function correctly, a study.was performed (GTN-60298 dated July,27, l
1984) that concluded certain fire dampers could be " Abandoned In l
Place" and would not be required for a safe shutdown. These dampers j
were included in the HVIN population as an accessory connection only 1
and were inspected for proper mounting and bolting, but not l
operability, to assure that these dampers would not interfere with d
operation of the HVAC system at some later date. ERC issued letter
QA/QC-RT-5584 dated February 2, 1987, to the population file, j
providing this'information. The NRC inspector verified the validity l
of the information through review of the study and supporting
^
documentation and found this to be consistent with ISAP VII.c
regarding Populations Items List development.
The NRC inspector has previously witnessed four inspections and
performed five inspections with no further inspection activity
planned for this population. i
No violations or deviations were identified.
.5. ISAP Sample Selection Process
The purpose of this NRC inspection was to determine whether the methods
used to select items and related documentation for reinspection or review-
was performed in accordance with the requirements of the CPRT Program.
Plan, Appendix D, Revisions 0 and 1, "CPRT Sampling Policy Applications
and Guidelines." Appendix 0 prescribes the various applications of
sampling within the CPRT program and defines guidelines for selecting
samples whenever random sampling techniques are used in ISAPs and Design
Specific Action Plans (DSAPs). This inspection was restricted to the
review of ISAP sample selections. The scope of the inspection covered
electrical, mechanical and piping, QA/QC, and the Quality of Construction
ISAPs. The inocerational and testing ISAP sample selection was reviewed
in a previor "^9pect!.m with results documented in NRC Region IV !
Inspection Report 50-445/85-18; 50-446/8S-15. Another activity previously
inspected by the NRC for compliance to Appendix D was the ERC Overview
Inspection Program's sample selection. Results of this inspection were
' documented in NRC Region IV Inspection Report 50-445/86-22; 50-446/86-20. &
'
The NRC approach used to review ISAP documentation and the inspection of
samples selected was: (1) to review the requirements identified in
Appendix 0 and the applicable procedures, and (2) to verify implementation
of the sample selection process by comparing the samples selected to the
controlling commitments. Samples were then reviewed to assure that:
random number selection and item number calculations were correct; items
identified for inspection had a valid sample number and a random number l
assignment; errors in the selection of items for inspection had been ;
resolved; departures from the sampling process had been identified; '
populations were clearly defined and segregated; minimum sample size
criteria were correct and documented and enlargement of sample size was
made, as necessary, to assure that the minimum sample size would be
achieved for all attributes; expansion of sample size, based on identified i
J
..
,
28
hardware deficiencies,-conformed to requirements; and the sample selection
process was suitably documented to provide an auditable trail. I
Of the 19 external source issue ISAPs considered for inspection,
5 completed and 1 in process ISAP were inspected. From ISAP VII.c, 5 of
31 in process populations were inspected. The following are the results
of this NRC inspection. j
!
a. QA/QC ISAPs
(1) ISAP VII.a.2: Nonconformance and Corrective Action (inprocess).
This ISAP contained six populations, each requiring a separate
sample selection that would provide a.95/5 screen. (The
95/5 screen or sampling plan provides a 95% confidence that not
more than a 5% deficiency rate exists in the sampled
population.) Of the six populations, the sample selection for
NCRs covering the years 1975 to 1977 was reviewed by the NRC i
inspector. Twenty-one of the sixty-three selected samples were i
examined. No errors were noted in random number calculations or
sample item identification from the. population item list. It
was determined, based on the NRC inspection, that the NCR sample [
selection conforrned to Appendix D requirements.
(2) ISAP VII.b.2: Valve Disassembly (complete).
During the NRC's inspection of VII.b.2', no errors in the 95/5
sampling plan were found. The NRC inspector reviewed 21 of the
111 sample selections and found them to conform to Appendix D, 3
ERC's implementing Procedure QAI-002, Revision 2, " Sample ;
Selection"; and CPP-006, " Sample Selection." Prior to '
completion and issuance of the VII,b.2 Results Report on
March 19, 1986, ERC's QA/QC surveillance group and the Results
Report Review Committee's (RRRC) review of sample selection
identified errors in the selection process. Corrective action
by the ISAP issue coordinator included revising the Random
Sample Identification List and performing additional hardware !
reinspections.
b. Electrical ISAPs
(1) ISAP I.a.1: Heat Shrinkable Insulation Sleeves (Revision 1 of ,
the Results Report issued December 30., 1986). )
i
The NRC inspected 13 of the 111 samples selected for this ISAP. j
From the CPRT reinspection of the initial 60 items randomly l
selected, providing a 95/5 sampling plan, one was considered to I
be a defect requiring sample expansion. As required by
Appendix D of the CPRT Program Plan, the sample was expanded by J
an additional 35 randomly selected items. Four of the l
1
i
5
I
c , sm
!
29
,
additional thirty-five samples were found.to be_ invalid and were
deleted because they represented locations that did not use heat
shrinkable insulation sleeves. To reach the required expanded
sample size, seven additional items were selected. Thus, the
total valid samples selected by CPRT for reinspection was 98;
however, during implementation of ISAP I.a.2, " Inspection
! 3 Reports on Butt Splices," 146 items were discovered that had
been inadvertently excluded from the original heat-shrinkable
insulation sleeve population. Proportional sampling was used on
this additional population by selecting 12 of the 146. The CPRT
advisor on engineering statistics approved the use of this
'
proportional sampling which was not addressed in Appendix D of
the CPRT Program Plan.
Due to errors in the calculation of the random numbers, one item
that should have been inspected in the additional 35 items
selected had been'omitted. This item was, however, inspected .
and is referenced in the working files as the " missed sample." i
With the' inspection of the " missed sample," the total number of
valid randomly selected items inspected was brought to 111 (the-
initial 98, 12 from proportional sampling, and the one " missed
sample").
Based on the review of sample selection documentation,: detailed j
inspection of 13 sample selections, and a review of other
'
sampling activities associated with this ISAP, the NRC inspector
determined that the I.a.1 sample selection process conformed to !
Appendix D.
(2) ISAP I.a.4: Agreement Between Drawings and Field Terminations
(Revision 2 of the Results Report. issued July 23,1986).
Of all the ISAPs and VII.c populations using random sampling,
this ISAP used a 95/1 screen instead of 95/5. Both screening
techniques are addressed in Appendix D,. Table 1. As with
ISAP I.a.1, additional population items were discovered during
ISAP implementation. Proportional sampling was again used and
approved by the CPRT engineering statistics advisor. Based on a .
review of sample selection documentation and verifying in detail l
the selection process (38 out of 383 selected items), the NRC ]
inspector determined that I.a.4 sampling conformed to i
Appendix D. j
1
c. Mechanical ISAPs:
(1) ISAP V.a: Inspection for Certain Types of Skewed Welds in NF
Supports (Results Report issued October 22,1986).
1
The NRC inspector examined in detail 16 of the 60 samples 1
selected and found sample selection conformed to Appendix D;
however, three documentation inconsistencies were noted between .
l
_ .. . . . . .
-J
- ,
. ~ a
i
30
the Random Sample Identification List (RSIL) and ERC Procedure
QI-006, Attachment 6.5, Revision 2. Listed on Attachment 6.5
were the 60 hangers inspected by ERC as taken from the RSIL.
The inconsistency was not with the actual unique hanger number,
but with the alphanumeric suffix character which~ indicates the
type of hanger; i.e.,.A-anchor, S-spring, R-rigid, or K-snubber. !
Three hanger types were incorrectly coded as "K" instead'of "R".
The suffix characters also identify building, elevation, and
code class. From reviewing the actual packages inspected, the
NRC inspector verified that the~ correct hangers were selected
and inspected. The ISAP V.a issue coordinator is in the process
of correcting the documentation inconsistencies identified by
the NRC.
(2) ISAP'V.d: Plug Welds (Revision 1 of the Results Report issued
December 18,1986). '
This ISAP contained four populations. Sample selection for each
population was based on the 95/5 screen. The NRC inspector !
examined 67 of the 250 sample selections from the 4 populations.
Eleven errors were found by the NRC inspector involving
calculation of the random number which resulted in a different
/ random item being selected. It should be noted that prior to-
the issuance of the Results Report (Revision 1), the statistical
advisor reviewed 100% of this ISAP's sample selection. . Based on
'
.
this review, 14 of the 250 samples had been identified with the
same type errors that the NRC inspector had identified. These
14 errors included the 11 errors found by this NRC inspection.
The scope of the statistical advisor's review of sample
selection is further discussed in paragraph e. below. Based on
results obtained from ERC inspections, plug weld testing, and
bounding analysis performed by Ebasco, the statistical advisor
determined the errors found in the sample selection did not
impact inspection results nor was there a need.to reopen the
inspection program. Since the errors only resulted in a
different item being randomly selected and inspected and the
statistical advisor determined that the sampling process itself
was not compromised, it was not necessary for these errors to be
, corrected. This conclusion was supported by referenced
documentation which was found in the Results Report working
'
file.
d. ISAP VII.c: Construction Reinspection / Documentation Review Plan
(inprocess).
i
This ISAP is unique because the VII.c work activities are divided j
into 32 homogenous populations. On completion of all work 1
activities, a summary Results Report will be issued. Details of l
reinspections and document reviews performed will be addressed as
appendices to the summary Results Report. At the time of this NRC
inspection, the Results Report and associated appendices were in
i
I
L j
_ -
.
<
r
4 * .-
1
31
their draft form and subject to various CPRT inprocess reviews; e.g., l
RRRC, ERC engineering assurance and QA. J
Thirty-one of the thirty-two populations used statistical random g
sample selection with the 95/5 screen (one population had less than 1
60 items, field fabricated tanks, thus all items were included in the '4
sample). The NRC inspector examined sample selections for'5 of the
31 populations that used statistical sampling. From these
5 populations, 154 of the 502 sample items selected were inspected
for compliance to Appendix D of the CPRT Program Plan and ERC
Procedure CPP-006, Revision 3, " Sample Selection." Procedure CPP-006
was more prescriptive than Appendix D in-that.it provided ERC
personnel with details for implementing the requirements-for. sample i
selection. The five populations inspected by the NRC were: Cable
Tray, Nuclear Instrument System Cable Termination, Electrical
Equipment Installation, Instrumentation Equipment Installation, and
Large Bore Piping Configuration.
Typical errors encountered were calculation of random sample number; ;
use of duplicate random numbers; incorrect population item used;
deviations from Appendix D not adequately documented; selection of
items related to safe shutdown; and numbering of inspection work
packages. Problems encountered that were not deviations from
Appendix D or CPP-006 but made verification of sample selection
difficult were: inadequate guidance for proportional sampling which
was necessary when increases in population sizes were required;
method of numbering Population Item Lists; and inadequate guidance
for the resolution of problems encountered during sample selection.
These errors and problems are discussed below.
e. Sample Selection Review by the SRT
The statistical advisor to the CPRT has conducted and is continuing
to conduct reviews of ISAP sample selection. By direction of the
SRT, the statistical advisor was required to conduct reviews of those
ISAPs and VII.c. populations using sample selection to assure
conformance to Appendix D. This requirement was delineated in CPRT
memorandum CPRT-138 dated December 3, 1985, which the statistical
advisor stated is being implemented by a 100% review of the sample
selection process for all ISAPs and VII.c populations utilizing
statistical sampling. To date, the statistical advisor has reviewed
100% of the sample selection process for 9 of 22 ISAPs and 19 of the 1
31 VII.c. populations using statistical sampling. '
A checklist was developed and used by the statistical advisor to
perform the reviews and to document the findings and actions
required. On completion of the review, the issue coordinator or
population engineer was given a copy of the checklist. Each finding
and the actions required were discussed with the audited group. A
formal tracking mechanism to verify completion of actions required
had not, as yet, been developed or implemented. From interviews with
,
e
s - * .o
32
the statistical advisor, a formal procedure and tracking system will
be developed and implemented to assure actions required are completed
in a timely manner. This activity will be.followed by the NRC as an 1
open item (445/8702-0-05; 446/8702-0-05).
Each of the errors and problems found by the NRC inspector had been l
identified and documented by the statistical advisor.
To assure that no Results Report is published with open sample i
selection errors, the'RRRC revised its working file check list on
February 17, 1987, to require all open sampling errors identified
against a Results Report be resolved prior to.RRRC approval of the
working file and submittal of the Results Report to the SRT.
f. ERC's Review of ISAP and VII.c Sample Selection
(1) Engineering Assurance
ERC has established an engineering assurance (EA) group to i
perform final review and assembly of records and supporting l
documentation (working file) required for ISAP VII.c prior to j
turnover to the CPRT central file. This effort was governed by i
Procedure CPP-026, Revision 0, " Final Review of ISAP VII.c
Working Files." EA had performed an initial review of VII.c
sample selection during July and August 1986. A written ,
checklist was used to direct the review and document findings i
for follow-up. Several items remain open. It should be noted
that during the EA initial review of sample selection not all
sample selections were finalized. Work was still in process to ;
develop and complete.some populations and perform sample ;
selections. The final review by EA for sample selection was f
scheduled to start in February 1987, but was contingent on
Population Random Selection Identification Lists being completed j
and approved. j
i
(2) ERC C a ity Assurance i
l
The QA surveillance group has performed 19 surveillances of in l
process ISAP activities. These surveillances, performed j
immediately prior to Result Report submittal to the SRT, were to 1
determine that Results Reports appropriately addressed the i
respective action plan. For those ISAPs using sample selection, 4
the surveillances included an in depth review of sample
selection methodology and results. The purpose of thr sample
selection review was to verify the sample selection process
methodology and results were adequately documented and conformed
to the requirements of Appendix D of the CPRT Program Plan.
With respect to ISAP VII.C, QA surveillance performed a review
of sample selection which included population description and
selection methodology for first and second samples taken,
proportional sampling, and extended sampling. As described
I
t
, 9
'
V
1 ;
,
. g y,
[, <
'
. .
t
33
p
, ,
Jabove,'EA'will perform a 100 percent review of VII.C sample
selection' activities.
.In addition tdLQA' surveillance off1 SAP sample selection, the ERC.
QA audit group;has performed two programmatic audits :of the
'
sampling process as documented in ERC audit reports ERC-86-05.- i
-
and ERC-86-06. LNo findings were.noted in~those audit reports, a
< g. - Overview Quality Team (0QT)
. .
.
1
From interviews with the 0QT, the NRC determined that.the.0QT j
has not planned any reviews of ISAP- sample selection., ' The
review responsibility for ISAP sample' selection had been ]"
,
j
assigned to the CPRT statistical advisor and the RRRC. The
sample selection for several:ISAPs have been examined by the
0QT.' These were'notfin depth reviews such as those conducted by
the.ERC_QA surveillance group or the CPRT statistical advisor. 1
Rather; the 0QT reviews were to determine' that statements.made
in the.ISAP Results Reports with respectato sample" selection l
methodology and results'were. traceable to supporting j
documentation in the'ISAP working file. .The 0QT: compared j
Results Report statements;to the working _ file'to verify that th'e H
documentation existed with regard to population definition, 1
population size,. sample selection methodology, results of sample
selection, and the justification for additional and/or expansion
of sample selection. 3
.
.
1
In summary, of the 50 action plans using sample selection (19 external. 1
issue ISAPs and 31 VII.c populations),.the NRC inspected 11 for j
conformance to Appendix D. From the 11 action plans, 330 of the
1480 sample selections.were examined for errors by the NRC < inspector. . Fo
- those action plans-inspected, the sample selection efforts were found to s
conform to Appendix D. Those errors in the sampling process that were
identified by the NRC inspector had also been identified by the CPRT- f
statistical advisor and action to correct or disposition the errors had
either been taken or was.being taken.
At present, the statistical advisor does not have a system to verify the
completion of action required to correct or disposition identified errors.
j
j
A commitment has been made to develop and implement such a system. .This _l
- commitment will be followed as a NRC open item, as discussed in I
paragraph 5.e. above.
No violations or deviations were identified. I
'
6. Exit Interview
Exit interviews were conducted February 10, 1987, and March 3, 1987, with
- !
the applicant's representatives identified in paragraph 1 of Appendix B of
!
j
-
,
o .,
34
this report. During these interviews, the NRC inspectors summarized the
scope and findings of the inspection. The applicant acknowledged the
findings. l
I
i
?
I
l
1
i
l
,
.