ML20235V747
| ML20235V747 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/07/1987 |
| From: | Barnes I, Ellershaw L, Hale C, Michaud P, Will Smith, Wagner P NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20235V650 | List: |
| References | |
| 50-445-87-13, 50-446-87-10, NUDOCS 8710150302 | |
| Download: ML20235V747 (47) | |
See also: IR 05000445/1987013
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f:l ~ APPENDIX B
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U. S.-NUCLEAR" REGULATORY COMMISSION.
.m.
OFFICE OF SPECIAL PROJECTS
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NRC:Inspectio'.1 Report: '50-445/87-13 Permits: CPPR-126
50-446/87-10. CPPR-127 i
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Dockets: 150-445 Category: A2 I
50-446
Construction Permit
Expiration. Dates:
Unit 1: August 1, 1988-
Unit 2: Extension request
submitted..
Applicant: TU Electric
Skyway Tower
400 North' Olive Street
Lock Box 81
Dallas, Texas 75201
Facility Name: _ Comanche Peak Steam Electric' Station (CPSES),
Units 1 & 2
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Inspection At:. Comanche Peak Site, Glen Rose,. Texas
Inspection Conducted: July 8 through August 4, 1987 1
Inspectors: b. /d !P7
L.T E. Ellershaw, Reactor Inspector Date
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(paragraphs 2.b-d, 3.a, 3.k-1, 4.a, 4.e-f and 6) l
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C. O H'al'e, Reactor Inspector
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(paragraphs 3.h-j, 4.g-h, and 5)
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k P...W. Michaud, Reactor Inspector Date
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f .W..F.(paragraphs Smith, Reactor Inspector.
4.b-d)
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@CAcage m/7/e 7
- P.,C. .
Wagner, Reactor Inspector .
Date
(paragraphs 2.a, 2.e-f, 3.b-c,'8, and~9)
~ Consultants: EG&G -LJ. Dale (paragraphs 3.a and 6)
'W.-Richins (paragraphs 4.a and 4.f)
V. Wenczel (paragraphs 3.j and.5.b)
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A. Maughan (paragraphs 2.a and 8)
Parameter - J. Birmingham (paragraphs 3.h-i and
4.g-h)
K. Graham (paragraphs 3.k and 4.e)
D. Jew (paragraphs.2.b-d and 3.1)
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Reviewed by: 8w
Barnes, Senior Project Inspector
/o/7/P7
I. Date '
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Inspection Summary
Inspection Conducted: July 8 through August 4, 1987 (Report ,
50-445/87-13; 50-446/87-10) '
Areas Inspected: Nonroutine, unannounced inspection of applicant
actions on previous inspection findings, the nonconformance report
(NCR) process, allegation follow-up, general plant tours, and
Comanche Peak Response Team (CPRT) issue-specific action plans
(ISAPs); i.e., II.d, III.a.2, III.a.4, III.d, V.d, VI.a, VII.a.1,
and VII.b.l.
Results: One violation (failure to provide torque requirement for
bolts on pressure boundary portion of a charging pump,
paragraph 3.k) was identified. Three unresolved items were
identified (applicability of ASME code to capscrew installation,
paragraph 3.k; homogeneity of HVAC work, paragraph 6; and the
qualification of inverters with spliced wiring, paragraph 8.b).
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DETAILS
1. Persons Contacted '
- R. P. Baker, Engineering Assurance (EA) Regulatory Compliance
Manager, TU Electric
- W. G. Counsil, Executive Vice President, TU Electric
- R. D.'Delano, Licensing Engineer, TU Electric
- D. R. Ferguson, CPRT Program Director,'IT
- D. A. Hodge, CPRT, Evaluation Research Corporation (ERC)
- S. D. Karpyak, CPRT, TU Electric
- J. J. Kelley, Manager,. Plant Operations, TU Electric
- 0. W. Lowe, Director, Engineering, TU Electric
- R. L. Moeller, Westinghouse Site Manager, TU Electric
- D. Noss, Quality Assurance (QA) Issue Interface Coordinator,
TU Electric
- D. M. Reynorson, Director, Construction, TU Electric
- J. E. Rushwick, CPRT Review Team Leader, Testing
"A. B. Scott, Vice President, Nuclear Operations, TU Electric
- C. E. Scott, Startup Manager, TU Electric
- J. C. Smith, Plant Operations, TU Electric
- F. B. Stevens, Manager, Electrical Engineering, TU Electric
- T. G. Tyler, Director, Projects, TU Electric
The NRC inspectors also interviewed other applicant employees
during this inspection period.
- Denotes personnel present at the August 4, 1987, exit !
interview. I
2. Applicant Actions on Previous Inspection Findings (92701)
a. (Closed) Open Item (445/8514-0-05): Missing
identification tag on conduit C-13030852. During an NRC l
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witnessed inspection, an ERC inspector noted that a
l required tag was missing. Follow-up by the NRC inspector
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found that NCR E85-101928SX, which had been written for
this condition, had been dispositioned to require
identification of the conduit and was in a closed status.
The NRC inspector physically verified that the required
identification markings had been applied.
I b. (Closed) Open Item (446/8515-0-04): Potential deviations
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regarding clearances between a pipe and other pipes and
supports. ERC subsequently determined that these
conditions did not warrant the issuance of a deviation
report (DR) since they had been previously identified on l
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NCRs by Brown & Root (B&R). The NRC inspector concurs
and this item is closed.
c. (Closed) Unresolved Item (445/8607-U-09): Prior to the I
formation of the Overview Inspection Program under ERC
QA, the NRC inspector identified a deviation against ERCE
reinspection of Verification Package I-S-INSP-033. The-
verification package was changed and a DR issued to
reflect'the NRC identified condition.- Subsequently, an
overview inspector (OI) performed an inspection and
review of this package; however, no unsatisfactory
decisions on the part of the ERC inspector.were
identified. 'The fact that the NRC had identified some
unsatisfactory decisions against the initial ERC
inspector was not reflected in the OI's assessment of
this package.
As a result, the Overview Inspection Program, during its
assessment of the ERC inspectors, now factors in
deviations that the NRC has identified against the ERC
inspection program. Revision 4 to ERC Procedure
ERC-QA-28, " Overview Inspection Program," requires that
an unsatisfactory decision. identified by the NRC be. l
included in the " Overview Inspection Summary".(attachment j
6.3). Based upon document review, the NRC inspector
determined that the NRC identified unsatisfactory
decision on Verification Package I-S-INSP-033 has been
included on the " Overview Inspection Summary."
d. (Open) Open Item (445/8622-0-13): This item deals with
an unsatisfactory decision made by the ERC inspector on
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Verification Package'I-M-SBCO-121 and identified by the
OI. It dealt with the inspected pipe and a floor grating
support not meeting the separation criteria of
Section 5.2 of QI-026.
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The NRC inspector confirmed that the verification package i
was reinspected by ERC for this unsatisfactory decision
and that DR I-M-SBCO-121-DR-02 was issued documenting the
deviating condition. Subsequently, NCR M-23466N,
Revision 1, was issued. It was also documented that the i
OI discussed this finding with the original ERC
inspector. This item will remain open pending
disposition of the NCR by the applicant and review by the
NRC inspector.
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l e. (Closed) Open Item (446/8626-0-03): Equipment !
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qualification of reactor vessel level indicators. The
specification file which was reviewed by the NRC
l inspector contained a disclaimer from the contrcl panel l
manufacturer for responsibility of the qualification of
certain indication devices. These devices were the light
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< *, , emitting diodes (LEDs) and their holders. The NRC J
. inspector reviewed the Combustion Engineering, Inc. (CE)
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' Qualification Summary Report 4182-ICE-3310, Revision 10, !
for the provided Heated Junction Thermocouple. Monitor 1
System.(HJTC) which utilized these LEDs for. indication.
This report'provided verification that'the LEDs and their~ il
holders were qualified to the appropriate standards.
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During field' verification of the control room
Installation on' July-8, 1987, the NRC inspector also
~c hecked the two bay cabinets containing the HJTC chassis ;
for Unit 1 and Unit 2. The inspector noted that Train A I
equipment was mounted in the upper bay with Train B in i
the lower and that a Train A cable was routed up.through !
the lower bay in sealtite flexible conduit. The
inspector also observed an electrical separation problem
in the lower bay of the Unit 2 cabinet where Train B 4
cables were in contact with the Train A conduit; however, i
there was apparent work in progress, the completion of
which may resolve this problem. l
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The NRC inspector also noted that the chassis did not i
appear'to contain the test buttons for obtaining !
! individual thermocouple temperatures which were described l
in the above CE Report. The inspector questioned j
applicant personnel about this apparent inconsistency and
was informed that the summary report was referring to the
provisions contained within the chassis for obtaining i
temperatures and was not intended to infer that
individual test buttons existed. The NRC inspector's
review of the CE Operations and Maintenance Instruction
Manual for the HJTC system verified thic to be the case.
f. (Closed) Open Item (445/8626-0-09; 446/8622-0-08): ,
Inadequate NCR dispositioning. The NRC inspector
' concluded that the information contained on some NCRs was
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insufficient to determine the appropriateness of the-
disposition. 'The initiation of a corrective action ;
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request (CAR-062) and a new corporate procedure
(NEO 3.05) was discussed in NRC Inspection Report
50-445/86-26; 50-446/86-22 with implementation of these
issues being an open item. The implementation of these ;
programs is discussed in paragraph 5 below.
3. Follow-up on Items of Noncompliance / Deviations (92702) l
n. (Closed) Violation (445/8516-V-14): The NRC inspector
identified a spacing violation between a 1-1/4" Hilti s
bolt and a 1" Hilti bolt on adjacent fixtures of Support i
SI-1-039-044-S42R. This support had been previously l
inspected and accepted on December 21, 1981, without "
evidence of any design change documents approving this
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- condition. ;In response.to.thisTviolation:the' applicant
RM ..identifiedEtheLfollowing.
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~t. :The: apparent 7 separation violation had been identified by
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, , Pipe' Support Engineering (PSE)', and Engineering'
E , Evaluation _of Spacing Violation form (EESV No. PSE 637)
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v. w.wasigenerated.t.However, in the preparation of this ;j
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document,sthe engineeroincorrectly recorded the' support'
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identification.asLSI-1-039-004-S42R instead of the.
Q < Y' , correct SI-039-044-S42R. This' error.resulted in th'e-EESV
.Oi lbeing: incorrectly filed. Identification of!this
-n Econdition'resulted in the'EESV being. revised on April 30,
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1986, to reflect the correct support? identification- d
cm number. PSE surveyed the large: bore.EESV log land I
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z . identified'the existence of 1213 EESVs. PSE randomly '!
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"" . selected a sample of.50 EESVs.and' verified their: 1
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' correctness by visual. inspection of theLapplicable pipe !
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No other' deficiencies.of this nature were identified'by
s PSE'during this effort.
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' ,' The NRC, inspector reviewed the EESV log and verified.that j
l' EESV No~."PSE 637'had been revised. '!,
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' 4: s .The PSE Survey: Data Sheets which documented-the randomL ,
csample visual inspections were also reviewed.. The NRC l
inspector determined that this was.an isolated incident
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L , involving the~ incorrect recording of support '
identification,'therefore this violation is closed.
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b. (Closed)1 Violation (446/0611-V-02): Inadequate physical
p. : protection of level transmitter instruments.-
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-By' letter dated January 16, 1987, the applicant responded ;
,, y to the. condition 11dentified by the NRC inspector where
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(the Unit 2: level transmitters, 2LT-537 and 2LT-539, were
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uncovered and-unprotected from nearby. grinding
d- activities. The applicant committed to: (1) inspect'the
., level instruments in'accordance'with NCR I86-202744, and
'(2) train all appropriate construction personnel on
equipment protection-requirements'. The date for i
completion of the. actions required by the above NCR
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bi t was revised from Jutte 1 to July 15, 1987, by TU Electric l;
'f letter dated May 29, 1987. !
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The NRC inspector verified completion of the above l
7" actions.by documentation reviews and physical inspection.
NCR I86-202744 was transferred to Deficiency Report (DR)
C87-1252 which was closed based on QC inspections !
conducted on June 23, 1987. These inspections disclosed
no damage to the instruments or their tubing. The
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required training was completed, as discussed in B&R i
memorandum IM 29889, dated November 20, 1986. This memo '
documented that training meetings were conducted on l
July 24 and 25, 1986, which. emphasized the importance of~ j#
craftsmanship, protection of permanent plant equipment
and procedural compliance; the meeting minutes were
attached to the memo. The importance of protecting plant
equipment was further emphasized in a Project Directive 1
issued on August 6, 1986.
The NRC inspector also performed a physical inspection
which verified that the level instruments were not i
damaged and were adequately protected. The inspector did
note, however, that the labeling on the temporary,
plywood protection boxes was incorrect for 2LT-537, which
was labeled 2LT-539; he informed the applicant of this ,
shortcoming. l
Although this particular violation is being closed in
this report, the NRC onsite inspectors continue to have a
concern with protection of equipment. A meeting was held
with TUE on June 25, 1987, to discuss the NRC's concern
(see Inspection Report No. 50-445/87-10, 50-446/87-08).
NRC inspection of this concern will continue.
c. -(Closed) Violation (446/8611-V-03): Inadequate cable
tray protection from overhead welding activities.
The applicant responded by letter dated January 16, 1987, j
to the condition identified by the NRC inspector where l
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electrical cables in cable trays T24RREA16 and T24BREC11
were not covered for protection from welding activities j
taking place above the cable trays. The applicant i
committed to inspect the cables for damage in accordance
with NCR E86-202745 and to retrain the construction
personnel. The completion date for this NCR was also c
revised from June 1 to July 15, 1987, by the letter dated l
May 29, 1987, i
The NRC inspector noted that this NCR was transferred to !
DR C87-2287, which was closed on June 22, 1987, based on !
QC Inspection Reports (irs) 2-0120977 and 2-0120978.
These irs documented the inspection of the involved
electrical cables and concluded that the cables were
acceptable. The discussion of training in paragraph 3.b I
above, applies equally to this violation. The NRC l
inspector found these actions to be acceptable.
The NRC inspector then performed a physical inspection
which verified that the cables in these cable tray
sections, and in nearby adjacent sections, had not been {
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d. (closed) Violation (446/8612-V-01): Failure to follow i
procedure.
Travelers for conduit and junction box supports were not
being signed at the completion of'each operation as
required by Procedure CP-CPM 6.3. The applicant
explained that the intent was to' allow signing of the
travelers at any time after completion of the work, but !
the procedure did not accurately reflect this intent. !
Procedure CP-CPM 6.3 has been revised (Revision 12) to
allow craft personnel to sign travelers any time after
completion of work provided post-construction
verification is possible. The NRC inspector reviewed '
Revision 12 of CP-CPM 6.3 and the training records for
this revision and found them acceptable. Corrective i
actions are therefore considered complete.
e. (Closed) Violation (446/8612-V-02): Failure to comply
with procedural requirements. I
Torque wrenches were not used to set Hilti bolts at the
time of installation as required by Procedure CEI-20.
Bolts were torqued during a system walkdown prior to QC
inspection. Therefore, undertorquing was not considered
to be a problem. The potential effects of overtorquing
Hilti bolts was evaluated by the applicant and concluded
to have no impact on the existing installations. The NRC
inspector found the evaluation acceptable and verified ;
the appropriate personnel had been retrained on Procedure
CEI-20. No indication of recurrence was noted and
corrective actions are considered complete.
f. (Closed) Violation (446/8612-V-04): Failure to implement I
tool segregation requirements.
Tools used to cut stainless steel conduit had also been
used on carbon steel, contrary to the requirements of
Electric &l Erection Specification 2323-ES-100. The
applicant performed an evaluation of the impact of carbon
steel contamination on stainless steel conduit, which
concluded no harmful effects will result since no
pressure retaining function is served. A design change
authorization was issued to revise specification
2323-ES-100 to exempt stainless steel conduit and other '
electrical components from tool segregation requirements.
The NRC inspector reviewed the applicant's evaluation and I
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corrective actions and found them acceptable.
g. (Closed) Violation (446/8612-V-05): Failure to comply
with procedure.
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Changes were made to conduit and junction box supporte j
(types and locations) without prior engineering approval ;
or appropriate design documents, as required by Procedure
CP-CPM 4.1. The NRC inspector verified that after the !
. modifications were made engineering approval was obtained 1
for the as-installed configuration. Procedure CP-CPM 4.1 !
is now included in the mandatory training requirements l
for electrical construction personnel, and retraining on
this procedure was verified by the.NRC inspector. No !
evidence of a recurrence of this problem was.noted. l
Corrective actions are therefore considered complete. i
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h. (Closed) Violation (445/8615-V-08; 446/8612-V-08): This ,
violation concerned the failure of procedural controls I
for field generated requests to the onsite fabrication i
shop to specify sufficient information on the-request to i
assure that required QC inspections would be performed j
and material traceability maintained. J
The NRC inspector verified that B&R Procedure
CP-CPM-7.3A, Revision 0, " Material Storage / Identification
for Structural Fabrication," was revised by Document
Change Notice (DCN) 4 to specify the type of form and the i
information required when requesting fabricated items. '!
The NRC inspector reviewed training records to verify
that' applicable personnel had received training on the !
revision to CP-CPM-7.3A. l
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NRC review of the results report for ISAP VII.b.1,
"Onsite Fabrication," found that a review of 73 ASME and ,
18 non-ASME fabrication packages had been performed by f
the CPRT. Although deviations were identified during the j
implementation of this portion of ISAP VII.b.1, none of
the deviations were attributable to inadequate
information on the fabrication shop requests. The NRC ,
inspector reviewed 11 of the packages reviewed by the ;
CPRT together with the associated DRs and concurs with j
the CPRT conclusion that the fabrication shop requests J
were not the cause of any of the CPRT deviations.
Additionally, the NRC inspector reviewed the results of a ;
TU Electric review of nonstandard requests for 1
fabrication that was performed to assess past use of the
forms. The TU Electric review indicated that the
nonstandard forms were primarily for temporary or
miscellaneous steel items and were not intended for
permanent plant structures. The results also stated that
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any safety-related material was inspected by QC. The NRC
1 inspector reviewed 20 of the nonstandard requests and
l found that they were for temporary or nonsafety-related
material. In addition, the NRC inspector reviewed
inspection procedures pertaining to the installation of
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safety-related hangers, supports, and structural steel
and verified that they required the QC verification of
attributes such as materia 1' traceability and weld
acceptance to the extent that applicable codes and
standards required. Therefore, since the nonstandard
requests were used for nonsafety-related material and the
results of ISAP VII.b.1 and the results of a TU Electric
review indicate that deviations did not occur as a result
of insufficient information on either standard or
nonstandard forms, the corrective actions and the actions
to preclude recurrence are deemed sufficient. This item
is closed.
1. (Closed) Deviation (445/8622-D-03; 446/8620-D-04):
During review of Fabrication Package RH-1-063-010-522R
for ISAP VII.b.1, a CPRT document reviewer failed to
identify four QC inspectors and two welders listed in the
fabrication package.
The responsible CPRT document reviewer has been informed
of the review errors by the ISAP issue coordinator. All
document reviews performed by this document reviewer were
repeated by another CPRT' document reviewer. No
additional document reviews have been assigned to the
responsible document' reviewer. The NRC inspector
reviewed four of the rereviewed packages and' verified
they were proper. Additionally, NRC review of ERC
management records indicate no other document reviews
were performed by the responsible document reviewer.
Since all affected packages were rereviewed and no
additional packages have been reviewed by the individual,
this item is closed.
j. (Closed) Violation (446/8622-V-06): An informal log used
by the Unit 1 Task Group to document potential
nonconformances was discarded prior to the nonconforming
conditions being dispositioned.
The applicant determined that the log contained less than
15 items. These items were identified by the Unit 1 Task
Group during their field verification efforts, but were
items outside the scope of the equipment being examined.
The applicant is in the process of repeating the field
verification performed initially by the Unit 1 Task Group
using more detailed criteria. The controlling document
for this current field verification is TE-FVM-CS-014,
" Design Control of Electrical Conduit Raceways for Unit 2
Installation in Unit 1 and Common Areas," which contains
a mechanism to report potential nonconformances on
Construction Deficiency Reports (CDRs). Training has
been provided to the applicable personnel in the use of
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TE-FVM-CS-014, Revision 4, and the Procedure CP-QP-16.0,
Revision 26, " Reporting Construction Deficiencies."
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The NRC inspector reviewed training records for personnel
in the use of TE-FVM-CS-014, Revision 4. These records
included attendance lists and training outlines. !
Fifty-one individuals-received this training. For
CP-QP-16, Revision 26, training records disclosed
77 individuals completed reading assignments with respect
to initiating and completing CDRs.
Procedure TE-FVM-CS-014 was reviewed by the NRC inspector
to determine that the requirement for the reporting of
potential nonconformances on CDRs was properly addressed. i
The procedure was found to adequately address and include l
~ typical examples of potential nonconformance. To verify
implementation ~of potential nonconformance reporting on i
CDRs, the NRC reviewed the CDR log. It was determined
that 19 CDRs had been initiated since the last revision i
of TE-FVM-CS-014. These CDRs were found by the NRC I
inspector to be in various stages of processing. l
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Based on the NRC's verification of the applicant's
establishment and implementation of a mechanism to 4
identify and resolve potential nonconforming conditions, J
the scope of the effort required by TE-FVM-CS-014, and ]
the training provided in the use of the applicable
procedures, this violation is closed. l
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k. (Open) Deviation (445/8622-D-09): This deviation dealt I
with ERC engineering's failure to provide inspection
instructions for the verification of all safety-related ]
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attributes associated with Verification Package l
I-M-MEIN-107. '
TU Electric letter TXX-6396 dated April 27, 1987, states
that a review of documents describing repair or
modification work performed on TBX-CSAPPD-01
(I-M-MEIN-107) had been conducted and the verification
package had been issued for reinspection after l
appropriate supplemental inspection instructions were
added. In addition, all other mechanical equipment
installation (MEIN) population sample items were
reviewed, supplemental inspection instructions issued as
required, and reinspected.
The NRC inspector performed.a review of DRs issued by ERC
as a result of supplemental inspection instructions being ,
added to Verification Package I-M-MEIN-107. This review l
revealed that ERC inspectors identified eight deviations 1
from applicable installation requirements. DR
I-M-MEIN-107-DR3 was issued to document that the vent and l
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drain cover flange nuts on positive displacement charging
pump TBX-CSAPPD-01 did not meet test torque requirements;
i.e., two nuts on the flanged connections rotated when
test torque was applied. This DR was subsequently
cancelled when the ERC Safety Significance Evaluation
Group discovered that later work activities subsequent to
those identified by the original Construction Operation
Traveler ME-81-1579-4900 had been documented by startup t
work permit (SWP) Traveler Z-2214, and noted that no
torquing requirements were specified. The acceptance
criteria used during reinspection are supposed to be
derived from the latest work document gove531ng the work
performed. The basis for cancelling the b.i was the fact
that the SWP did not specify acceptance criteria and that
the purpose of ERC reinspection was to confirm the q
adequacy of construction work activities.
The NRC inspector reviewed the Union Pump Company's
Vendor Manual for positive displacement charging pump
TBX-CSAPPD-01 and determined that the flange covers
identified by ERC DR I-M-MEIN-107-DR3 are pressure
boundary parts and did require installation to a torque
value of 125 ft/lbs using a torque sequence specified by
the vendor instruction manual. ERC personnel, subsequent
to discussion of installation torque requirements with
the NRC inspector, issued QA/QC-RT-8327, which identifies
that the SWP instructions are incorrect.
Discussions with TU Electric startup personnel revealed
that when a SWP is being processed, startup personnel
shall provide a step-by-step description of work to be
performed including any reference to required procedures,
design documents or instruction manuals. The failure to
specify vendor manual installation requirements when
providing work instructions to craft and QC personnel is
a violation (445/8713-V-01).
During review of all applicable requirements for bolt
torquing, the NRC inspector identified that Union Pump
Company Drawing S-C8135, Parts 643-6 and 643-8
(capscrews) are designated as being subsection NF in
Section III of the ASME Code. These capscrews had been
installed without hardened washers which is a requirement
for bolts tightened by means of a calibrated wrench per
the requirements of the ASME Code. However, while the
vendor drawing does designate the capscrews as being NF,
it has not been determined whether the installation was
designated NF by B&R. Therefore, this is an unresolved
item pending completion of NRC inspection activities
(445/8713-U-02).
_ _ __ - __
.
~
14 1
l
1. (Open) Deviation (445/8622-D-14): In Overview Inspection
Package I-M-SBCO-121, there was a failure on the part of l
J
-the overview inspector to-identify two unsatisfactory
decisions made by the initial ERC inspector. These two
decisions involved pipe-to-hanger clearances as required
in Section 5.2.6 in Revision 2 of QI-026. i
i
corrective action taken included' reinspection of the line i
for pipe-to-hanger clearance violations as specified in j
the QI by ERC. This resulted in'the issuance.of DR q
I-M-SBCO-121-DR-3 on April 7, 1987. Subsequently, NCR '
CM-87-6087-N-X-R1 was issued to disposition and correct, j
if necessary, these discrepant conditions. At the
present time this NCR has,not been dispositioned by
engineering.
Corrective steps taken to avoid further deviations }
include discussions with the responsible overview l
inspector on August 4, 1986, and. documented training with i
the appropriate ERC inspectors on March 31, 1987. The !
NRC inspector verified that the documented training of !
the ERC inspectors had occurred by reviewing the training l
attendance sheet. 1
i
'
This item will remain open pending disposition of and
completion of the required actions specified in the NCR
and NRC verification. l
s
4. CPRT ISAPS q
a. Seismic Design of Control Room Ceiling Elements l
(ISAP II.d) (48053.)
The following activities for ISAP II.d were reviewed by i
the NRC inspector during this report period:
Installation of New Control Room Ceiling Structure and
Components (NRC Reference 02.d.02.00)
The NRC inspector has observed the installation of the
new control room ceiling structure and components on
numerous occasions. The installation was compared with
the design specified in the calculations reviewed for NRC
Reference 02.d.01.00 (see NRC Inspector Reports ]'
50-445/86-01, 50-446/86-01; 50-445/87-11, 50-446/87-09).
Items spot checked and compared included: (1) member
sizes and locations, (2) connection types and
configurations, (3) Hilti bolt identification and
location, and (4) structural bolting. A detailed
inspection of the ceiling support base plate installation
l and associated Hilti bolts was reported on in NRC
Inspection Report 50-445/86-01; 50-446/86-01. j
i
l
i
_ _ _ _ _ _ _ - _ _ _ _ _ _ i
- _ _ _ - _ _
,
.
-
15
,
No violations or deviations were identified. This
activity is complete and no further NRC inspection is
planned for this reference item.
NRC inspections were not performed on other reference
items during this report period.
b. Joint Test Group (JTG) Approval of Test Data
(ISAP III.a.2) (70400)
During the 1984 NRC Technical Review Team (TRT)
inspection of Test Program 1, as described on pages J-69
through J-77 of CPSES Supplemental Safety Evaluation
Report No. 7 (SSER-7), dated January 1985, the NRC
inspector noted that if a preoperational test is deferred
into the Initial Startup Test (ISU) Program, which
commences after initial fueling, the completed results
data would be reviewed by the Station Operations Review
Committee (SORC) in lieu of the Joint Test Group (JTG). }
The version of the FSAR in effect at the time of the
inspection did not provide for this shift in review
responsibility; i.e., the FSAR stated that the JTG was
responsible for reviewing preoperational test data.
Deferring this testing to another time frame, or
incorporating the deferred preoperational tests into ISU
procedures, did not in itself relieve the JTG of this
responsibility.
The action required by paragraph 6.b on page J-77 of
SSER-7 and accordingly the commitment in ISAP III.a.2 was
to revise the FSAR. During an ISAP implementation
inspection conducted in November 1985, as documented in
NRC Inspection Report 50-445/85-16; 50-446/85-13, the NRC
inspector verified that the FSAR had been revised (see
FSAR Amendment 54, Section 14.2) to clarify the division
of responsibility between.the JTG and the SORC. The FSAR
now supports station procedu'es
r which provide for the
deferral of tests from the preoperational test program,
which is under the purview of the JTG, to the ISU j
program, which is the responsibility of the SORC, a l
'
similarly qualified group.
On October 15, 1986, the CPRT issued the ISAP III.a.2
Results Report, "JTG Approval of Test Data," which i
reiterated the details of the ISAP, documented the CPRT I
findings and explained what the findings revealed, and
then reached a conclusion based on the findings. In I
addition, the CPRT identified and reviewed four Station
administrative procedures which implement the above
change to the FSAR to ensure that the commitment was
addressed by procedure.
_ _______--___ _ _ ___ _ -
_ _ _ .
.
. 16 i
i
I
The NRC inspector reviewed the results report to
(1) ensure that it accurately reflected what the action '
plan was, and (2) verify that CPRT findings reported were
consistent with what the NRC inspectors found while q
conducting the ISAP implementation inspections. -
The ISAP III.a.2 Results Report concluded that: i
I
(1) As noted in the FSAR sections qu3ted above, specific ;
commitment to review deferred preoperational test
results by the SORC is contained in the CPSES FSAR.
Clarification of the commitment was made in FSAR ;
'
Amendment 54 subsequent to the NRC TRT review.
(2) The CPSES procedures reviewed by the CPRT completely
address the implementation of the commitment for
SORC approval of deferred preoperational testing.
The implementation of the ISAP was discussed in
sufficient detail and provided accurate representation of
the CPRT findings, which supported the above conclusions.
The NRC inspector found that the processes described and
the results obtained were consistent with observations
made by the NRC staff during the implementation
inspections. During the course of the implementation ,
inspections, the NRC inspector noted that there was
sufficient auditable documentation in the CPRT files to
support all of the statements made in the results report,
fr
As required by the Program Plan, the CPRT addressed the j
question of root causes and generic implications. Since 1
no testing deviation or deficiency was identified and no j
generic condition exists which indicates that there is i
inadequate review of deferred preoperational testing, no
root cause or generic implication determination is
required. The staff concurs, since no deferred q
preoperational tests have been performed at CPSES to l
date. l
1
No violations or deviations were identified. NRC
inspection of implementation of this ISAP is comp 3-te.
c. Traceability of Test Equipment (ISAP 111.a.4) (70308)
During the NRC TRT evaluation of allegations made against
the testing program as described on page J-69 of SSER-7
dated January 1985, an inspection was performed to gain
an understanding of the alleged numerous problems
identified during the conduct of the thermal expansion
test. The TRT found that there were numerous problems
(see paga J-72 of SSER-7); however, they were all
formally and appropriately identified and were included
f
p
-
- -- - - - - - -
-
17
in the deferred preoperational tests awaiting the next
heatup of the plant. Based on the problems' identified.
having been tracked and' properly dispositioned, and the
applicant's plans to complete any additional required
preoperational hot functional tests prior to initial ;
'
criticality, the TRT found no safety significance to the
numerous problema. i
s
While reviewing the completed portions of Preoperational
Test 1CP-PT-55-11, " Thermal Expansion," the TRT confirmed
the allegation that the test data packages did not
contain the information that would be needed to trace
calibrated measuring and test equipment (M&TE) directly
to specific monitored locations. The information existed
in a separate log, which was not a part of the official
test data packages. On page J-77 of SSER-7 the TRT
directed TU Electric to incorporate the information
contained in the log into the official test data for
1CP-PT-55-11, and to establish administrative controls to
assure appropriate M&TE traceability during future i
'
testing and plant opers.tions.
In response to the TRT's statement in SSER-7, the
applicant issued ISAP III.a.4, Revision 4, on August 6,
1986. Commitments were made to achieve an objective to
ensure that 1CP-PT-55-11 has traceability of M&TE, and
that administrative controls are in place to assure i
traceability during future testing and plant operation. i
The CPRT subsequently informed the NRC staff that actions
committed by the ISAP were complete. The staff completed
an implementation inspection (as discussed below) to
verify that actions were completed as stated in the ISAP, .
and to ensure auditable documentation was on file to i
support the actions taken.
In order to maintain a correlation between the areas
inspected and the applicable sections of ISAP III.a.4,
Revision 4, the inspector applied a reference number to
each area addressed using the ISAP paragraph number i
assigned by the CPRT. The results of inspection of the
implementation of ISAP III.a.4 in each area follows:
3.a.4/4.1.1: The applicant committed to incorporate
'
the necessary information that provides the
traceability required of M&TE used during the test.
The NRC inspector noted that Test Procedure q
Deviation (TPD) 36 dated July 17, 1984, replaced i
Table II of 1CP-PT-55-11 with one that identifies 1
which M&TE was used at each temperature plateau on l
every test point. The traceability requirements are i
now met or exceeded in the data package.
]
l
cr= ;
L -
18 i
3.a.4/4.1.2: All startup personnel responsible for I
conduct of testing were to be reinstructed on the !
existing administrative requirements applicable to
the traceability of M&TE. The NRC inspector was ,
able to identify adequate documentation showing that ;
this had been completed in October 1984.
3.a.4/4.1.3: The applicant committed to reinstruct !
startup personnel responsible for conduct of testing !
on the existing startup administrative requirements j
applicable to the use of TPDs. . Documentation was on i
file showing that this was done in January 1985. '
3.a.4/4.1.4: The applicant committed to ena':re that
administrative controls are in effect for the ISU ;
Program to require that identification and j
'
calibration information for M&TE used.to obtain
acceptance data be entered on the permanent test
results record. The NRC inspector.noted that 'l
documentation indicating completion of this item was
on file, and then reviewed the initial startup i
administrative procedures (ISAs) to independently l
verify that the above controls are implemented. The !
results were satisfactory. For example, paragraph !
4.1.7.2 of ISA-001, " Initial Startup Test l
Procedures," implements the M&TE identification !
requirement.
3.a.4/4.1.5: Similarly, the applicant committed to '
verity that M&TE controls sirailar to 4.1.4 above l
Were in effect for Operations. The NRC inspector j
found documentation of completion on this item in s
the CPRT files, and independently checked 12 station j
procedures. Appropriate controls were found to be -
in place for operation and maintenance of the plant. j
!
3.a.4/4.1.6: The applicant committed to review !
startup administrative requirements for !
indoctrination and training for startup personnel to l
ensure that lessons learned from this ISAP, if any, ;
had been incorporated, and that when procedure i
changes were made, appropriate startup personnel
would be instructed on the changes. The NRC staff l
i
noted that the review was completed, and further !
noted that CP-SAP-19, " Indoctrination / Training / j
Qualification Requirements for Startup Personnel," ;
had been revised to provide more specific
reindoctrination controls. The NRC inspector
l
sampled three system test engineer (STE) training i
records and confirmed STE reindoctrination in
changes made to administrative requirements as a >
result of lessons learned and ISAP actions.
4
\
- - _ - _ - - _ _ _ _ _ _ _
- _-_-___ _____ _ _
9
19
. .
On August 8, 1986, the CPRT published the ISAP III.a.4
Results Report, " Traceability of Test Equipment," which
reiterated the details of the ISAP, documented the CPRT
findings and explained what the findings revealed, and
then reached a conclusion based on the findings.
b The NRC staff reviewed the results report to: (1) ensure
j that it accurately reflected what the action plan was,
(2) verify that CPRT findings reported were consistent
with what the NRC inspectors found while conducting the
ISAP implementation inspections.
The ISAP III.a.4 Results Report concluded that:
(1) The M&TE traceability information requested by the .g
NRC TRT is now included in the test data package for 1
1CP-PT-55-ll, " Thermal Expansion."
(2) Requirements exist in start:up and station
implementing procedures to ensure compliance with
TU Electric's MSTE traceability commitments.
The inspector found that the processes described in the
results report and the results obtained were consistent
with observations made by the NRC staff during the
implementation inspections. During the course of the
implementation inspections, the NRC inspector noted that
there was sufficient auditable documentation in the CPRT
files to support all of the statements made in the
results report. Also, while conducting implementation
inspections for ISAP III.a.1, " Hot Functional Testing
Data Packages," the staff reviewed 27 test data packages
and did not identify any deficiencies related to the
subject of M&TE controls.
No violations or deviations were identified. NRC
inspection of implementation of this ISAP is complete.
d. Preoperational Testing (ISAP III.d) (70301 and 70324)
During the NRC TRT inspection of the preoperational
testing program, conclusions were reached by the TRT that
none of the related allegations and findings had safety
significance or generic implications, except that past
document control system problems may have affected the
testing program. Details of these conclusions and
findings are in SSER-7. The primary ccncern was that
past preoperational testing may not have been conducted
using fully updated procedures because of the
difficulties System Test Engineers (STEs) had in
obtaining design document updates.
\
_ - - - - _ - - _ - _ _ - - - _ _ _ _ _ _ _ _ _ . _ . _ _ _
r7-- ;- ]
l.
!
- - 20
, .
In response to the TRT's concerns over possible past
document control' impacts on testing, the applicant !
committed to actions that establish measures to provide
greater assurance that current design data is utilized in
testing, and~to determine whether or not past document
control system problems had an adverse effect on the
testing program for Unit 1.
The actions were implemented by the CPRT and follow-up j
implementation inspections were conducted by the NRC i
staff as documented in NRC Inspection Reports j
50-445/85-16, 50-446/85-13; 50-445/85-18, 50-446/85-15;
50-445/86-07, 50-446/86-05; and 50-445/87-11,
50-446/87-09. j
i
On March 13, 1986, the CPRT published the ISAP III.d )
Results Report, "Preoperational Testing," which
reiterated the details of the ISAP, documented the CPRT ;
findings and explained what,the findings revealed, and ]
then reached.a conclusion based on the results of the I
findings.
]
The NRC staff reviewed the results report to: (1) ensure
that it accurately reflected what the action plan was, I
and (2) . verify that CPRT findings reported were j
consistent with what the NRC inspectors found while j
>onducting the ISAP implementation inspections. l
l
The ISAP III.d Results Report concluded that:
(a) The startup and document control center (DCC)
organizations have established sufficient measures j
to assure that STEs and other responsible personnel j
'
are provided access to controlled design documents.
(b) The results of the evaluation provide reasonable
assurance that the document control problems which I
existed prior to 1984 did not adversely affect the
testing program.
The NRC inspector noted that the results report provided
all of the ISAP details, as written in Revision 4 of the j
Action Plan dated February 27, 1986, and as reviewed by j
the NRC staff. The implementation of the ISAP was !
discussed in sufficient detail and provided an accurate
representation of the CPRT findings, which supported the
above conclusions. The NRC inspector found that the
processes described and the results obtained were l
consistent with observations made by the NRC staff during l
the implementation inspections. During the course of the f
implementation inspections, the inspector noted that !
there was sufficient auditable documentation in the CPRT
I
1
.
_ ,__
'
I
21 l
!
files to support all of the statements made in the l
results report.
No violations or deviations were identified during this
inspection. NRC inspection of implementation of-this
ISAP is complete.
e. Plug Welds (ISAP V.d) (57050)
The following activities for ISAP V.d were reviewed by i
the NRC inspector during this report period:
l
Utilitize Mockups to Verify and Refine Detection
Techniques; Select Field Inspectors Based on Performance ;
'
of Detecting Mockup Plug Welds (NRC Reference 05.d.02.02
and 05.d.02.03
The NRC inspector verified that plug weld mockups were
used to train ERC inspectors. The verification consisted
of a review of the ISAP working file which documented
that all ERC inspectors involved.in reinspection of plug
welds had demonstrated the ability.to detect 75% of the
mockup plug welds which was the minimum acceptable
detection rate. The NRC inspector examined the mockups
and made a comparison with existing field conditions. ,
This evaluation resulted in the conclusion that the i
mockups were representative, and were sufficiently j
adequate to be used as an inspector training aid. J
These activities are complete and no further NRC ,
inspection is planned for these reference items. j
]
QC Inspection and Documentation Procedures to be Reviewed
,and Changes Recommended if Required (NRC Reference
05.d.07.00) ;
I
The third-party (TERA) review of QC procedures concluded
that current inspection and documentation requirements ,
are adequate and in compliance with QA program
commitments. The NRC inspector has reviewed the current
procedures regarding inspection and documentation, and
concurs with TERA's conclusion.
This activity is complete and no further NRC inspection
is planned for this reference item.
I
Determine Effects of Plug Welds on Quality of Supports I
(NRC Reference No. 05.d.09.03) !
l
The method of slag removal which was used during the j
performance of plug welding was considered to be a l
_ - _ _ _ _ _ _ _ - _ _ _ _ .
--
22
concern relative to the quality of supports. Physical
testing and macroscopic examination was performed on test
coupons in which the different methods of slag removal
were incorporated, and is addressed in NRC Inspection
Report 50-445/86-22; 50-446/86-20. The test results
demonstrated that there are variations in the quality of
the welds, depending on the slag removal method used. l
'
However, the tensile strength of all of the test coupons
exceeded the minimum requirements of the ASTM A.36 base
material specification. The NRC inspector has reviewed !
the results of the tests, including the radiographs and
concurs with the conclusions.
This activity is complete and no further NRC inspection l
1s planned for this reference item. !
Authorized Cable Tray Support Plug Welds'; Third-Party to
Review Design Change Authorizations (DCAs) for Cable Tray
Supports; Third-Party to Determine Whether Sufficient
Basis Existed for DCAs (NRC Reference 05.d.10.00; !
05.d.10.01; and 05.d.10.02)
TERA performed a review of DCA-5347 to determine the l
adequacy of the generic authorization to repair
mislocated holes in cable tray supports. Ebasco
performed a reanalysis for TERA, which addressed the i
technical adequacy of the design change specified by i
DCA-5347. As a result of the Ebasco reanalysis, TERA i
issued Discrepancy / Issue Resolution Report (DIR)-D-0018 ,
which identified that adequate criteria for specifying i
which holes could be left unwelded were not clearly
stated, and that adequate justification for allowing ,
holes up to 3/4" in diameter to remain unwelded had not '
been provided. The NRC inspector reviewed the contents
of the ISAP working file and verified that the DIR
identified above does address the Ebasco identified
deficiencies.
Responsibility for closure of the DIR has been
transferred to DSAP VIII, which is overviewing the cable
tray support requalification program. These activities
are complete and no further NRC inspection of these NRC
reference items is planned. l
Documentation of OC Weld Inspections; Third-Party to ,
Review Historical Programmatic Requirements and )
Implementation Procedures for OC Documentation;
Third-Party to Assess Compliance with QA Program
Licensing Commitments of FSAR and Perform an Evaluation
on any Lessons Learned for Future Program Modification
(NRC Reference 05.d.11.00; 05.d.11.01; and 05.d.11.02)
_ _ _ _ - _ _ _ _ _ - _ _ _ .
,
'
23
TERA performed a review of historical programmatic
requirements and implementation procedures for.QC
documentation of plug welds. A list was developed.which i
identifies all fabrication construction procedures,
inspection procedures, and welding procedure
. specifications associated with construction activities in
which plug welding could occur. The NRC inspector
verified that the review required for developing the list
was performed and the documentation associated with the
review is contained in the ISAP working files. TERA- i
identified that all plug welding performed on cable tray
supports prior to November 1980 deviated from the QA
program requirements in that inadequate inspection
records exist. This deviation was documented on
DIR-D-2177 and forwarded to the QA/QC review team for
trending purposes on October 1, 1986.
Subsequent to November 1980, revisions to quality
inspection. procedures established a QC hold point for
plug welds and the requirements for QA documentation. It
was established by TERA through record review that this
documentation does exist for samples containing plug
welds made after the procedural revision.
The NRC inspector discussed documentation of QC weld
inspections with TERA personnel and performed a review of
DIR-D-2177, plug weld inspection records and current
inspection procedure requirements.. This review revealed
no inconsistencies or errors in TERA's approach or ,
conclusions, j
1
These activities are complete and no further NRC ;
inspection of these reference items is planned. I
Root Cause and Applicability; Determine Root Cause; and l
Determine Generic Implications (NRC Reference 05.d.12.00; 5
05.d.12.01; and 05.d.12.02)
l
l
An evaluation of root cause and generic implications was j
determined by TERA to not be required for this ISAP j
because no safety-significant deficiencies or adverse !
trends were identified. The NRC inspector concurred with
this determination. These activities are complete and no !
further NRC inspection of these reference items is i
planned. j
,
i
L___________ i
_ _ _ , ,
.
1
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24
l
l
l
Procedures; Develop Inspection Procedure (s) for. Cable l
Tray Supports, Pipe Supports, and Base Plates; Train and
Qualify Inspectors (NRC Reference 05.d.13.00; 05.d.13.01; l
and 05.d.13.02) I
A procedure for detection and inspection of plug welds,
QI-007, was developed by ERC. This procedure identifies j
acceptance criteria for the measurement of paint I
thickness during examination for plug welds. If any (
support did not meet the paint thickness acceptance
criteria, then the paint was required to be removed prior
.to inspection. The NRC inspector verified by document
review that training of ERC inspectors was conducted as
required by ERC Procedure QI-0U7, and certification was
accomplished in accordance with ERC Procedure CPP-003.
These activities are complete and no further NRC )
inspection of these reference items is planned. j
Existing OC Procedure Criteria for Visual Inspection will
be Used (NRC Reference 05.d.14.00) ;
i
ERC Procedure QI-007 was developed to provide criteria
for the inspection of plug welds. The NRC inspector ,
verified by comparison, that this procedure incorporated j
'
visual inspection criteria contained in existing site QC
procedures. This activity is complete and no further NRC ,
'
inspection of this reference item is planned.
Issuance of Results Report (NRC Reference 05.d.15.00)
Revision 1 of the results report for ISAP V.d was issued
December 18, 1986.
f. Gap Between Reactor Pressure Vessel Reflective Insulation
and the Biological Shield Wall (ISAP VI.a) (50071 and ;
50075)
1
The following activities for ISAP VI.a were reviewed by
the NRC inspector during this report period:
Review Procedures, Programs, etc. for Effect of Nonsafety
Items on Safety Items (NRC Reference 06.a.02.00)
CPRT evaluated the process used to identify and-resolve
adverse interactions between non-nuclear safety (NNS)
items and safety-related items. Seismic interactions are
evaluated under ISAPs I.c (Electrical Conduit Supports)
and II.d (Seismic Design of Control Room Ceiling
Elements). Additional programs (see Table 2 of ISAP VI.a J
Results Report, Revision 1) address nonseismic
interactions and are included within the scope of the
i
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25 j
l
Design Adequacy Program. The program segment evaluated
by CPRT under this ISAP was the process for the
multi-discipline review.and approval of NNS design
changes.
CPRT evaluated historical Gibbs &iHill and TUE-(formerly
TUGCo) Nuclear Engineering (TNE) procedures implemented
through mid-1985 that controlled the design process. The
evaluation focused primarily on multi-discipline reviews
and design reviews (design verification), and is
documented in Reference 9.21 to the ISAP VI.a Results
Report, Revision 1, TENERA memorandum dated August 15,
1986, " Design Control Procedure Review." CPRT concluded
in this memorandum that, " Clearly, the implementation of
multi-discipline engineering reviews has been a basic
function within the CPSES design process since the
beginning. These reviews have been applied to the-NNS j
and safety-related design scopes, both for original 1
design and design changes . . . . " CPRT also concluded j
that the TNE procedures in effect at the time the CPRT {
investigation began (June 1985) included a verification '
of the NNS classification and an engineering review of
any effects.on safety-related equipment. Design l
Verification was not required for the majority of NNS
design changes. Exceptions included specific NNS items
such as the fire protection system.
The NRC inspector reviewed the following historical
Gibbs & Hill and TNE procedures (9 of the 21 procedures
reviewed by CPRT) in order to verify the conclusions f
reached by CPRT. l
-
Gibbs & Hill PC-8, " Change Order Procedure -
Engineering and Design," Revision 1 (March 1972), l
Revision 2 (September 1974). l
1
-
Gibbs & Hill PC-9, " Change Order Procedure - Field," l
Revision 1 (March 1972), Revision 2 (September l
1974).
1
'
-
Gibbs & Hill DC-4, " Design Drawing Checking and
I
Approval Procedure," Revision 1 (March 1972),
Revision 3 (November 1973).
-
TNE-AD-4-2, " Control of Engineering Review and
Design Verification of Field Design Changes,"
Revision 1 (September 3, 1985).
l
'
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TNE-DC-7, " Preparation and Review of Design
Drawings," Revision 16 (February 14, 1986). ,
l
!
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L _ - - _ _ - - - - - - -
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l
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26-
-
TNE-DC-8, " Design Verification of Engineering
Documents," Revision 5 (October 26, 1984).
-
TNE-DC-8-1, " Engineering Review and Design
Verification of Field Design Changes," Revision 9
(September 5, 1985).
-
TNE-DC 12, " Preparation of Engineering Change
Notices," Revision 6-(January 28, 1986).
-
TNE-DC-21, " Preparation and Review of Field Design
Changes," Revision 4 (May 8, 1986).
The NRC inspector reviewed these procedures and concurs
with the conclusions stated by CPRT.- The implementation
of these procedures is addressed by NRC Reference
06.a.04.00.
No violations or deviations were identified and no
further NRC inspection is planned for this reference l
item. j
Modify Procedures and Programs if Inadequate (NRC
Reference 06.a.03.00) 4
CPRT evalue.ted a randomly selected sample of 60 NNS
change packages for potential nonseismic interaction with
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safety-related items (see NRC Reference 06.a.04.00, this
report). During these evaluations, CPRT noted.that some
packages were not'sent to all affected disciplines for
the interdisciplinary _ review. Procedure TNE-DC-8-1 did
not require a check of the completeness of the selection
of the affected disciplines.
ISAP VI.a Results Report, Revision 1, states that TU
Electric has committed to modify Procedure ECE-DC-8-1
(TNE-DC-8-1 was renumbered ECE-DC-8-1). This commitment
is contained in TU Electric letter NE 4555 dated
February 19, 1987, " Interdisciplinary Reviews of Design
Changes," which states, in part, that the following
changes will be made:
"The Supervising Engineer will be responsible for the
interdisciplinary review.
"The Supervising Engineer will use the review matrix in
ECE-DC-7 for guidance in selecting disciplines for review
of drawings. For nondrawing changes, the minimum review
is that required for the original document.
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"The organizations listed for interdiscipline review
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distribution will'be able to add other disciplines to the
review with the concurrence of the Supervising Engineer."
The NRC inspector concurs with the CPRT conclusion that
these changes will, ". . . enhance the Interdisciplinary
Review process in its ability to detect and prevent
adverse interactions that may be caused by NNS design
changes" (from ISAP VI.a Results Report, Revision 1). The
NRC inspector reviewed Procedure ECE 5.09-11, Revision 1,
which replaced Procedure ECE-DC-8-1, Revision 11, and
concluded that the above changes had been made.
No violations or deviations were identified and no
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further NRC inspection is planned for this reference ]
item.
Verify Implementation of Programs and Procedures for
Nonsafety-Related Items (NRC Reference 06.a.04.00)
CPRT concluded that a review of a representative sample ,
of DCAs and component modification cards (CMCs) would l
provide an effective test of the implementation of the {
NNS design change process. DCAs and CMCs have been used J
during most of the design process beginning mid-1977, are l
currently used by all disciplines, and are subject to the j
same basic review process as drawing and specification j
revisions. The review process, however, is often more 1
complex for DCA/ CMC initiated changes especially when l
unincorporated changes to the base documents exist at the j
time of the review. )
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CPRT randomly selected 60 NNS change packages from a
population of DCAs and CMCs. These packages were j
screened to assure that all involve some physical !
alteration in a Category I structure, represent currently
approved plant configuration, and have the potential for i
interactions with safety-related items. j
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Each DCA or CMC was reviewed (independent from any )
previous review) by TU Electric using then current !
(mid-1985) design review procedures. The reviews were
documented on change verification checklists (CVCs) and
reproduced on blue paper in order to distinguish them j
from actual CVCs being processed by engineering. The l
blue CVCs were processed in a manner similar to actual i
CVCs. A key element on the CVC is the Interdisciplinary I
Review, a technical review by disciplines selected by the l
CVC reviewer. The disciplines selected review the {'
package for potential adverse effects on the surrounding
design. The TU Electric review di.d not identify any
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adverse interactions resulting'from implementation of the
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change packages.
Subsequent to the TU Electric review, CPRT conducted a
third-party review of each change package using a .
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multi-discipline team. The third-party review. identified ;
one discrepancy regarding DCA 21181, Revision 0. This ,
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DCA nuthorized an increase in the thickness of piping
insulation for some NNS and safety-related lines. CPRT
determined that this change had not been reviewed by-the
piping discipline to assess the effect of the change cn1
piping analysis. Subsequently, TU' Electric conducted I
analytical studies and concluded that the increase in !
stresses in piping, piping components and supports did f
not exceed code allowables. The discrepancy identified .
in DCA 21181 was thus not saf?ty significant. 1
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CPRT.also identified two weaknesses in the NNS DCA/ CMC
design change review process. The first weakness was I
insufficient documentation accompanying some design !
change packages to allow CPRT to reach a conclusion on j
the effect of the change on safety-related items.- The i
information required was subsequently obtained by j
requesting specific documents and contacting individuals j
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knowledgeable of the design change.
The second weakness in the design review process 1
identified by CPRT involved Procedure TNE-DC-8-1. This
procedurc did not require any check of the completeness I
of the selection of the affected disciplines. Instances ;
were identified by CPRT where the CVC reviewer did not
send the package to all affected disciplines for the
interdiscipline review. l
TU Electric has addressed the first CPRT identified
weakness by establishing a new set of policies and
procedures within the nuclear engineering and operation
policies and procedures manual. The second weakness was
addressed by modifying the current design review
Procedure ECE-DC-8-1 (see NRC Reference 06.a.03.00, this
report).
The NRC inspector reviewed Reference 9.22 to the ISAP
VI.a Results Report, Revision 1, TENERA memorandum dated
February 27, 1987, " Evaluation of NNS Design Change
Packages." The NRC inspector also reviewed the sampling
and screening process used to select the 60 DCAs/CMCs,
the interactions and review checklists used Li CPRT, and
the following NNS change packages compiled by CPRT:
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- Package 1,-DCA 21191, Revision 0, Unit 1,
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Containment Building.- This DCA added type E15
' battery packs forLemergency lighting.
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-: Package :2, DCA'3149, Revision 0, Unit 1, Auxiliary l
- Building. This DCA moved a cable-tray approximately
3"'in elevation to prevent interference with a pipe. H
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. Package 4, DCA 20471, Revision 0, Unit 1, Electrical-
and control Building.' This DCA reduced the size'of' ']'
a 1" conduit;to.3/4" where it penetrates a' wall.
- Package 13, DCA 14524, Revision 0, Unit 2, . ..
,
Containment Building. This DCA revised a HVAC. duct 1
location and elevation to avoid physical
interferences with pipe supports.
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Package 15, CMC 63037, Revision 3, Unit 2, Diesel
Generator Building. This CMC rerouted aivent line
from the lube oil sump tank on the diesel generator
auxiliary skid. -l
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Package 18, CMC 98186,-Revision 0, Unit 1, .;
Electrical and Control Building. This CMC changed 1
the location of a' pipe offset to provide clearance
with cables.
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Package 44, DCA 8929, Revision-2, Unit 1, Electrical .!
and Control Building. This DCA modified the i
internal wiring of a termination cabinet. I
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Package 46, DCA 15443, Revision 0, Unit'1, Auxiliary '
Building. This DCA rerouted a ground wire and i
installed a 1" conduit.through a 1-1/2" sleeve
between the^ Auxiliary and Fuel Buildings.
The NRC inspector concurs with the conclusions drawn by
CPRT on'this reference item, in that the sampling effort i
identified no occurrences of a NNS design change causing i
an adverse interaction. Thus, there is reasonable
assurance that the review process related to DCAs/CMCs to
> detect and correct such interaction was effective.
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No violations or deviations were identified and no
further NRC inspection is planned for this reference
item.
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NRC inspections wero not performed on other reference !
items during this report period.' i
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g. Material Traceability-(ISAP VII.a.1) (35061)
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During this report period, NRC Reference Items l
07.a.01.04, 07.a.01.05, 07.a.01.06,t 07.a.01.07, and l
07.a.01.09 were reviewed as follows: 1
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Assure Actions on SSER Findings (NRC Reference
07.a.01.04)
!
ISAP-VII.a.1, Revision 1, required CPRT to perform a
review of all NRC SSER findings relative to material
traceability and to assure that adequate action is being ,
or has been taken to address the findings. Additionally, l
the CPRT was to review other external sources such as NRC
inspection reports and TU Electric management l
evaluations. The CPRT has instituted an external source .j
issues review and tracking group to assure that all
identified external source findings are adequately
addressed. These findings are tracked on a computerized ,
matrix and are accessible by field topics such as a field
for all findings assigned to an individual ISAP. This
_
tracking matrix will be inspected by the NRC during NRC
inspection of the CPRT collective evaluation process.
The NRC inspector obtained a list of those findings !
related to material traceability that have been assigned
by this matrix to be addressed by ISAP VII.a.1. The list
included five findings from SSERs 10 and 11, and one
finding each from the construction appraisal team (CAT)
report, the Management Analysis Company (MAC) report, and
an NRC inspection report. The findings included issues
and allegations such as: heat numbers from qualified
hanger structural steel were transferred to unqualified
steel (allegedly foreign), a welder was instructed to
weld a piece of nonsafety-related steel onto a
safety-related hanger, and an ASME survey conducted in
October 1981 had identified that TU Electric had failed
to maintain material traceability. Additionally, the NRC
inspector reviewed SSERs 7, 8, 9, 10, and 11; NRC
inspection reports; the NRC CAT report; and management
assessment reports initiated by TU Electric; i.e., the
Lobbin Report and MAC reports. By this review, the NRC
inspector found that additional issues related to
material traceability existed. During a discussion with
the ISAP VII.a.1 issue coordinator and further review of 1
the additional issues, the NRC inspector determined that
these issues were applicable to other CPRT ISAPs; i.e.,
VII.b.1, "Onsite Fabrication," VII.b.3, " Pipe Support
Inspections," and VII.c, " Construction Reinspection /
Documentation Review Plan." A review of the external {
source issue tracking matrix for some of these issues I
showed that they had been assigned to the other ISAPs. A
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review to assure external source issues have been I
addressed will be performed by the NRC durina inspection
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of the CPRT collective evaluation. ]
The NRC inspected the results of the CPRT review
performed for the eight material traceability issuet
assigned to ISAP VII.a.1. The NRC inspection found that
three of the issues were determined by the reporting 1
organizations to be acceptable. A brief description of
the three issues and their external source matrix numbers
follows:- CAT-127 found that traceability activities were
in accordance with site requirements; MAC-058 found that
TU Electric was performing mapping of embedded plate (not
required by the A3ME Code); RIV T.I.177 identified that
an originally questioned spool piece identity marking was
not in violation of ASME requirements. For the remaining
five issues the NRC found that the CPRT had properly
reviewed four issues and had in fact concurred with the
TRT conclusions for these items.
Review of the fifth issue found that CPRT had reviewed
the documentation and the NCRs concerning a mismarked
spool piece and determined that it was not an issue for
ISAP VII.a.1, rather it should be considered by ISAP VII
a.2, "Nonconformance and Corrective Action Systems." The j
NRC reviewed Documentation Package CT-1-SB-014-ITT-2; NCR
M-4015, Revisions 1-5; and NCR M-4942, Revision 3. From
review of this documentation the NRC inspector determined
that the traceability for spool piece T-1-SB-014-ITT-2
had not been lost and that the VII;a.1 issue coordinator
had properly referred the issue to the ISAP VII.a.2 issue
coordinator. This referral was accomplished by memorandum l
dated October 21, 1986.
Based on the above the NRC inspector determined that the
external source issues for ISAP VII.a.1 had been
addressed by ISAP VII.a.1 or were being addressed by
other action plans. This activity is complete and no
further NRC inspection is planned for this reference
item.
Results of Other Action Plans Related to Material
Traceability (NRC Reference 07.a.01.05 and 07.a.01.06)
ISAP VII.a.1 was developed to address the TRT findings
relative to material traceability; however, some of the
TRT findings were addressed by other CPRT action plans.
Therefore, ISAP VII.a.1 committed to: (1) review the
results of other ISAPs for adverse trends regarding
material traceability; (2) perform root cause and generic
implication analyses if safety significant deficiencies
or adverse trends were identified; and (3) review other
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root cause and generic implication evaluations for impact H
on the ISAP VII.a.1 assessment of material traceability.
The CPRT determined the other ISAPs whose results ma'f
relate to material traceability were I.a.1, VII.b.1,
VII.b.2, VII.b.3, and VII.c. .These reviews have been
performed and the ISAP VII.a.1 Result Report issued. The
CPRT found that ISAPs I.a.1 and VII.b.2 did not provide
any results related to material traceability. NRC
inspection of the CPRT reviews of the remaining ISAPs
follows:
(1) Results of Action Plan VII.b.3, " Pipe Support
Inspections"
The NRC inspector reviewed the action plan for
ISAP VII.b.3 and found that it~ required the CPRT to
validate the TRT finding of 46 discrepancies on pipe
supports, four of which related to material
traceability, and to conduct a reinspection of
randomly selected pipe support samples (to be
conducted under ISAP VII.c). The action plan also
required other activities not relevant to this
material traceability issue. The CPRT concluded
from its review of the ISAP VII.b.3 results that
" . no traceability problems were identified that
..
were associated with the pipe supports in this
population . . . " and that "Although some material
items in four pipe supports lacked material
identification on the item as reported in SSER ll,
sufficient alternate documentation was available to ,
confirm that acceptable material was used." l
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The NRC inspector reviewed the results of i
ISAP VII.b.3 as contained in the CPRT working files '
and the applicant's response to TRT findings dated
August 4, 1986, EA 86-09, Appendix A, item I.c.7,
which addresses the four pipe supports. The NRC
inspector found that the files for ISAP VII.b.3 did
not identify material traceability problems c:: DRs
relative to material traceability. Additionally, 1
the NRC inspector reviewed the documentation j
packages for the four supports reported by the TRT l
to lack material traceability. This review found, I
as identified by the VII.a.1 Results Report, that
sufficient alternate documentation was available to
assure material traceability for the supports in
question. The results of the NRC review of the
above agreed with the results of the CPRT review.
The four support packages reviewed were:
CT-1-013-532R, CC-1-126-012-F33R, CC-X-039-005-F43R,
and AF-1-035-011-533R.
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Based on the above, the NRC inspector determined
that ISAP VII,b.3 results were properly considered
by ISAP VII.a.l.
(2) Results of Action Plan VII.b.1, "Onsite Fabrication"
The.NRC inspector reviewed the action plan for
ISAP VII.b.1 and found that it required the issue
coordinator to perform a review of procedures and
records, such as audit and surveillance records, to-
identify trends and the effectiveness of site
corrective action (relative to onsite fabrication),
and to review safety-related fabrication document
packages both ASME and non-ASME. The NRC inspector
found that the VII.b.1 review of procedures had
identified deficiencies in the procedures for
preparation of ASME and non-ASME work packages such
as failure to require QC to document on QC
inspection reports the verification of welder
qualifications, or the verification of concrete
anchor bolts code stamps. These deficiencies,
however, were determined by CPRT to not adversely
affect the innpection activities. The NRC inspector
reviewed these procedural deficiencies and found
that required inspections relative to material
traceability could be performed.
The NRC inspector found that the CPRT review of
fabrication document packages consisted of a review
per the requirements of a prepared checklist of
73 ASME and 18 non-ASME packages (primarily pipe
hangers, pipe supports, and cable tray hangers).
Discrepancies found were documented on CPRT DRs.
The checklists and packages were previously
inspected by the NRC inspector during NRC inspection
of ISAP VII.b.1 (see Inspection Report 50-445/86-31;
50-446/86-25). The NRC inspector reviewed the DRs
resulting from the CPRT documentation package review
and found that 25 DRs documented material
traceability problems. The NRC inspector compared
the results of this review of DRs to the CPRT
results found in the ISAP VII.a.1 Results Report.
The NRC inspector found that the CPRT had summarized
the DRs into categories such as hardware mismarked
or material not traceable to a specific heat number
due to multiple heat numbers identified. The CPRT
had identified that none of the 25 DRs were safety
significant as related to the hardware. Paragraph
5.7 of ISAP VII.b.1 Results Report stated that since
document discrepancies were found in a majority of
the documentation packages reviewed a trend did
exist. The ISAP VII,b.1 issue coordinator performed
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a trend analysis of these DRs. . While no adverse' ,
trend was identified, the.DRs relative-to material- '
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traceability _ identified in'ISAP VII.b.1 were
transmitted to the issue. coordinator for ISAP-
VII.a.1, which the NRC inspector _ verified'.
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Based on the above and NRC review of the results~on l
material traceability, the NRC. inspector determined- l
that ISAP VII.a.l'had' properly considered the
results of ISAP VII.b.l.
(3) Results of Action Plan VII.c-" Construction'
-Reinspection / Documentation Review Plan"
The NRC inspector: reviewed the' action plan for
ISAP VII.c and found that'it' required the CPRT to
Lperform a sample reinspection of QC accepted
safety-related construction work, and a supplemental
review of related quality documentation for-
nonrecreatable and/or' inaccessible inspections. ForL :
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the purposes of the ISAP VII.c' review, construction
work was separated into 33 homogenous populations.
-The reinspection / document reviews for these
populations have been completed by CPRT and a draft
of the results prepared. The issue. coordinator for
.ISAP VII.a.1 reviewed the VII.c draft results
contained in Appendices 1-35 of the draft results
report for ISAP VII.c. These appendices indicated
that over 18,000 review points relative to material
traceability were performed during implementation of
ISAP VII.c and that over 200 DRs-relative to' I
material traceability discrepancies were identified.
The issue coordinator assessed these DRs (an
occurrence rate of about one percent) and the DRs i
from other ISAPs and concluded that there was no !
adverse trend related to material traceability
problems. The NRC inspector reviewed a draft of the
VII.c appendices and found that the draft ~ appendices
indicated over 25,000 review points were performed
resulting in 244 DRs. The results of the NRC review
differed slightly from the issue coordinator's
review results due to the.NRC reviewing a later
draft of the VII.c appendices. T,he draft reviewed
by the NRC identified;a greater number of review
points performed and a greater number of DRs
identified. The NRC review found that the DRs
documented _ discrepancies such as: the' transposition
of two digits in a heat number, failure to maintain
color coding on instrumentation tubing, and failure
to record heat numbers for material. The CPRT issue ;
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coordinator's review'of the draft results for ,
ISAP VII.c populations is considered acceptable for l
the purposes of the ISAP VII.a.1 review, since the
field inspections and document reviews required by
ISAP VII.c have been completed and all discrepancies
noted during performance of the field inspections
and document reviews have been documented on DRs.
Therefore, although evaluation of the VII.c .
populations is not complete, any additional
evaluation of VII.c data is unlikely to change the .
relative number of review points and DRs :
significantly. ,
Based on the above, the NRC inspector determined !
that the ISAP VII.a.1 issue coordinator had
appropriately considered the results of ISAP VII.c
relative to material traceability and had properly
determined that the discrepancies noted did not
represent a systematic or generic deficiency in the !
material traceability systems. These activities are ,
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complete and no further NRC inspection is planned
for these reference items 07.a.01.05 and 07.a.01.06. ;
Assess Material Control for Compliance (NRC Reference
07.a.01.07) and Criteria Met (NRC Reference 07.a.01.09)
ISAP VII.a.1 required the CPRT to perform a detailed
analysis of data gathered during performance of
activities specified in ISAP paragraphs 4.1.2.2 through
4.1.2.6. This review was to assess if the implementation
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of the material control systems for CPSES met the
requirements of 10 CFR Part 50, Appendix B,
Criterion VIII, " Identification and Control of Materials,
Parts, and Components" and the associated commitments of
the CPSES FSAR paragraph 17.1.8. This analysis was 1
presented by CPRT in Section 5.10 of the ISAP VII.a.1 j
Results Report. The NRC inspector has inspected the j
implementation of each of the activities specified in
paragraphs 4.1.2.2 through 4.1.2.6 (see NRC Inspection f
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Reports 50-445/86-31, 50-446/86-25; 50-445/87-06, j
50-446/87-05; 50-445/87-11, 50-446/87-09) and has used i
those inspection results during NRC review of the CPRT l
analysis. The results of the NRC review are as follows.
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The NRC inspector found that CPRT had performed each of
the activities specified in paragraph 4.1.2.2 through
4.1.2.6. These activities included: (1) review of
ISAP VII.c to determine those areas, where verification
of material traceability requirements would be performed; .
(2) evaluation of the procedural controls in effect for 1
TU Electric to determine if the requirements of 10 CFR l
Part 50, Appendix B, and the CPSES FSAR were included in
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the procedures; (3) evaluation of the findings of the !
October 1981, ASME Code survey to determire the root
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cause and generic implications and to determine.if the l
corrective actions implemented were appropriate; ;
(4) review of the SSER findings relative to material !
traceability to verify action is being taken to resolve.
each finding; and (5) review of ISAPs VII.b.1, VII.b.3,
VII.c, and other action plans to assure that issues
regarding material control and traceability.have been ,
addressed, to identify any root cause and/or generic
implications that could have an impact on material }
traceability, and to review the deviations relating to
material traceability found during implementation of
these ISAPs for adverse trends-or for impact on the
overall adequacy of material traceability.
The NRC inspector found that the review and evaluation of
the data gathered during the implementation of the above
activities was performed in sufficient detail for the
CPRT to assess whether TU Electric implementation of the
material control systems met the requirements of 10 CFR
Part 50, Appendix B, and the CPSES FSAR. The NRC
inspector found that the CPRT had properly identified
that the CPSES material control system was, in general,
in compliance with the applicable codes and standards as :
committed in the CPSES FSAR; that the CPRT had addressed 1
the deviations relating to material traceability found in !
the results of other action plans; and that the CPRT had i
properly noted those areas of the material control system l
which should be reviewed for possible revision. These i
recommendations for improvement of material control were
provided to the applicant. Implementation of the CPRT j
recommendations will provide more positive controls of i
purchase, receipt, storage, issue, and installation of i
safety related material.
No violations or deviations were noted in the CPRT
implementation of these activities. No further NRC
review of these reference items is planned. NRC i
inspection of TU Electric actions concerning the CPRT
recommendations will be inspected during a future
inspection.
h. Onsite Fabrication (ISAP VII.b.1) (35061)
During this report period, the following NRC reference
item was reviewed.
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Provide Input to ISAP VII.a.1'(NRC' Reference 07.b.01.08) l
ISAP VII.b.1 was' developed to address the.TRT findings
regarding deficiencies in the onsite fabrication shop.
Since some of the onsite fabrication shop deficiencies .
concerned the issue of material traceability addressed by !
ISAP VII.a.1, " Material Traceability," ISAP VII.b.1 j
required the issue coordinator.to " Provide'any !
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discrepancies related to material' traceability to ISAP
VII.a.1 Issue Coordinator for integration into that
action plan."
To verify this had been accomplished the NRC inspector !
reviewed a memo from the VII.b.1 issue coordinator which
advised the VII.a.1 issue coordinator of a' list of
material traceability discrepancies found during
implementation of ISAP VII.b.1. The NRC inspector
verified this action by review of the ISAP VII.a.1 file.
The NRC inspector reviewed the VII.b.1 working files _for
documentation on material traceability discrepancies and
found that all of the discrepancies related to material
traceability from the VII.b.1 file had been included in
the memo to the VII.a.1 issue coordinator. Additionally,
the NRC inspector reviewed the ISAP VII.a.1 Results ,
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Report,-Section 5.5, " Review of Action Plan VII.b.1
Results," and determined that the discrepancies had been
properly considered in that results report. 'NRC
inspection of how the discrepancies were addressed is
reported under NRC Reference 07.a.01.05 above. i
No NRC violations or deviations were noted and no further
NRC. inspection of this reference item is planned. J
5. NCR Process Inspection (35061) j
On December 22, 1986, NEO 3.05, " Reporting and Control of
Nonconformances," was issued which established a uniform
method of initiating, processing, and controlling NCRs,
applicable to all onsite organizations. At the same time NEO
3.06, " Reporting and Control of Deficiencies," was issued
which established methods for identification, control, and
correction of deficiencies. The NRC initiated an inspection
of the implementation of these procedures during this
reporting period. The following inspections have been
completed.
a. Controlling Site Procedures - NEO 3.05 and NEO 3.06
The NRC inspector compared NEO 3.05, Revision 1, and
NEO 3.06, Revision 0, to the requirements of 10 CFR i
Part 50, Appendix B, and the commitments in Chapter 17 of
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the FSAR. By this comparison the NRC inspector found
that the requirements and commitments were properly
translated into the controlling site procedures..
Using NEO 3.05-and NEO 3.06, each site organization was
required to develop procedures to implement the methods
and controls specified in these procedures. The NRC
inspector identified the following procedures prepared by
the site organizations affected by NEO 3.05 and NEO 3.06. ;
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Operations: STA-404, " Control of Deficiencies," Rev. 5 j
STA-405, " Control of Nonconforming
Materials," Rev. 13
Startup: CP-SAP-16, " Deficiency and Nonconformance
Reporting," Rev. 11
B&R: CP-QAP-16.0, " Reporting Construction ;'
Deficiencies," Rev. 1
QI-QAP-16.0-8, " Processing Construction i
Deficiency Reports," Rev. 1
QI-QAP-16.0-10, " Initiating and Processing
Nonconformance Reports," Rev. 1
AAP-16.1, " Controlling Nonconforming
Items," Rev. O
TU Electric: CP-QP-16.0, " Reporting Construction
Deficiency," Rev. 27
QI-QP-16.0-8, " Processing Construction
Deficiency Reports," Rev. 1
QI-QP-16.0-9, " Processing Programmatic 1
Deficiency Report," Rev. 1 l
QI-QP-16.0-10, " Initiating and Processing
Nonconformance Reports," Rev. 1
Engineering: ECE 3.05, " Reporting and Control of
Nonconformances," Rev. O
Grinnell Fire
! Protection: PG-NCR-6, "Nonconformance Reporting,"
Rev. 0 .
QCP-009, " Control Site Nonconformances,"
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BISCO:
Rev. 4
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During this and subsequent inspections, the-NRC is
verifying that these site procedures'have properly
translated the NEO 3.05 and NEO 3.06 requirements into
implementing procedures and that these latter procedures
are being effectively impicmented.
b. Operations NCR Program
The purpose of this NRC inspection was to determine
whether methods for the initiation, processing, and
control of plant operations NCRs at CPSES were performed
in accordance with Nuclear Engineering and Operations
Procedure NEO 3.05, Revision 1. NEO 3.05 documents the
requirements for the nonconformance reporting program at
CPSES and is applicable to engineering, construction,
startup (including onsite contractors), and operations.
Station Administration Procedure STA-405, Revision 13,
" Control.of Nonconforming Materials," was the operations
procedure which implemented the requirements of NEO 3.05.
The objectives of this inspection was to verify that
STA-405 addressed NEO 3.05 requirements and that STA-405
was implemented as written. Provided below is summary of
the STA-405 NCR process, the methodology used by the NRC
to inspect the NRC process, and inspection results.
Summary of STA-405 NCR Process
(1) Initiation - Upon discovery of a nonconforming
condition an NCR is initiated. The initiator is
responsible to provide, omong other things,
nonconforming condition details, component name and
identification, system, document or codes violated,
unit number, location, inspection report, and 4
initiator's name. Initiation of an NCR can be by I
any individual or organization observing a
nonconformance. Since December 22, 1986 (NEO 3.05
effective date), 692 operations NCRs have been i
originated by operations, engineering, construction,
and QA/QC. ]I
(2) QA/QC Evaluation - When an NCR is initiated, QA/QC
determines if the NCR is valid, complete, and
sufficient in detail for the problem to be
understood, located, and resolved. A hold tag is
applied to the nonconforming hardware or material,. I
if appropriate, and the shift supervisor is notified )
of the nonconformance. The shift supervisor !
determines equipment operability status and l
initiates a " Conditional Release" for nonconforming
items that are desired for installation, use, or to i
be stored in place. i
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(3) Technical evaluation and dispositioning
responsibilities are:
(a) Operations - provides " rework" or " scrap" i
dispositions based on an evaluation of the ,
nonconforming condition. [
(b) Engineering - determines " repair" or
"use-as-is" dispositions based on engineering
evaluations and reviews all NCRs for
t.' portability under 10 CFR 50.55(e). ,
(c) QA/QC - (i)' determines disposition is adequate,
complete, conforms to requirements, and that
suitable justification is provided including ,
supporting documentation; (ii) verifies >
'
disposition has been accomplished, removes hold
'
tags, closes NCRs, and notifies shift '
supervisor the item is ready for use; and
(iii) performs a post-review to determine if
the NCR and attached documentation is
acceptable and complete. l
Inspection Methodology
The NRC inspector developed an inspection plan and
checklist which detailed the organizational
responsibilities and requirements identified in STA-405.
A comparison was made between-the implementing
instructions in STA-405 to NEO 3.05 for consistency. The
results were that STA-405 provided adequate implementing
instructions for the requirements prescribed in NEO 3.05. i
To verify implementation of STA-405, a sample of NCRs was l
inspected to determine if NCRs were initiated, processed
and controlled as prescribed. The sample selected was
35 of the 692 NCRs initiated since December 22, 1986. Of
the 35 NCRs selected, 8 were classified as invalid,
27 were valid (10 closed and 17 in. process). To date,
89 NCRs have been closed and 603 remain in process.
In developing the NRC inspection checklist, consideration
was given to interfaces between construction, operations,
engineering, and QA/QC. The scope of the inspection was !
structured to include operations NCRs initiated for
e installed plant equipment, in-process work, and
'
nonconformances identified during receipt inspection.
Inspection Results
(1) QA/QC initial review - The NRC inspector determined
- that QA/QC did review the 35 sampled NCRs for i
l validity and completeness to assure that sufficient i
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- detail existed for the problem to be clearly
-understood, located, and; resolved. Since
l December.22,-1986, only.8~ operations NCRs have.been' D
determined to be invalid. These were returned.to;
These. invalidations
~
the initiator,.as' required- .
occurred; primarily).during'the'first-3 months of
the new NEO.3.05: program.- Based on the NRC's review'
of these eight. invalid NCRs,'with associated
justifications, the NRC concludes.the.eight NCRs
were processed properly. The remaining 27 NCRs
(closed and in-process) were' evaluated as: valid and-
-complete with'the required detail.
i
The NRC' inspector verified by field inspection'the
attachment'of hold tags as required'by STA-405 for-
those operations NCRs requiring hold tags.
(2) Shift. Supervisor - The NRC inspector verified that a
copy of the NCR was provided to the shift
supervisor, when required.. Of.the 17 in-process
NCRsireviewed by the NRC, 4 were conditionally
released. The~NRC inspector verified by field
inspection that the attachment of 22 conditional
release. tags was accomplished in accordance with
prescribed instructions and requirements.
(3)- Operations Dispositions --The'NRC verified that
' operations reviewed and provided. disposition for
each of the 27 valid NCRs. For those .
nonconformances requiring a " repair" or "use-as-is"
disposition, operations caused the NCR to.be
forwarded to Comanche Peak' Engineering for further
evaluation.
(4) Comanche Peak Engineering (CPE) - During this
inspection, the NRC determined that each of the
seven closed NCRs submitted to CPE for review had'
been evaluated for deportability. In the course of ;
inspecting these NCRs, the NRC found two instances i
l
in which the disposition of " invalid" was used by-
CPE. The specific words were " Invalid: .This is no
longer a nonconforming condition." Appropriate-
justification for this disposition was included on
the NCR.- NEO 3.05 does not permit an NCR to be
-
invalidated following the QA/QC validation process.
The TU Electric QA auditors had previously inspected
the operations NCR program and had already
identified this condition in audit report TUG-10-87.
This audit was conducted from May 4 through July 6,
1987. TUG-10-87 was a site wide audit of the NCR
and deficiency reporting program. Prior to the
completion of the TUG-10-87 audit, CPE Procedure
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ECE 3.05, " Reporting and Control of~Nonconfor-
mances," was revised'to preclude the use of
" invalid" as a disposition. Instead, a disposition
of "use-as-is" was required with the words "This is
not a nonconforming condition" or "This is no longer
a nonconforming condition," with a detailed.
justification. The NRC inspector sampled additional
NCRs of this type and verified they were ,
dispositioned properly. Based on the change to
ECE 3.05 and the review of both completed and
.in-process NCRs, the engineering dispositions were
found to be consistent with ECE 3.05 requirements.
(5) QA/QC Disposition Verification - Based on review of l
i
the 10 closed NCRs, the NRC determined that QA/QC
had: (1) verified the completeness and adequacy of
provided dispositions; (2) verified disposition
implementation; (3) removed and destroyed held tags,
when applied; (4) informed the shift supervisor,- es
applicable, that affected equipment could be
operated; (5) closed the NCR, and (6) performed the
required post reviews for accuracy and completeness
of documentation.
(6) Record Keeping - The NRC reviewed transmittal
records for in-process NCRs forwarded to the design
change tracking group, operations, and CPE.
Further, transmitted records were reviewed for the
10 closed and completed NCRs which were-sent to TU
Electric records management (permanent storage).
All transmittals were determined to conform to
procedures.
During the inspection of closed and in-process NCRs, it was l
noted that revisions and changes to NCRs were accomplished in
accordance with prescribed methods. Furthermore, the
computerized NCR tracking system was examined and determined
to provide NCR status as to: current revision, number of days
open, dispositioning, number of hold tags, organization
processing the NCR, and other related information.
Accordingly, methods exist to account for NCRs at all stages
of processing from initiation to closure. l
With respect to trending and corrective action, quarterly
reports were generated which collectively trended NCRs and
addressed the initiation of CARS.
l
In summary, of the 692 NCRs initiated since the implementation ,
of NEO 3.05, the NRC inspected 35 for conformance to NEO 3.05 i
and STA-405 requirements. Based on this inspection, the NRC I
determined that the applicant has established a mechanism to
document, process, and control operations NCRs. Those errors
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found in dispositioning of several NCRs had also been
identified by the applicant and corrected prior to the NRC's
inspection of operations NCR program.
j No other violations or deviations were identified.
!
6. ISAP VII.c - Reinspection of HVAC Equipment Installation
(HVIN) (50100)
!
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Status of CPRT Activities
A total of 181 HVAC equipment packages were randomly selected
and inspected from a population of 604 packages representing
Units 1, 2, and Common. A total of 331 DRs were written with
187 determined by ERC to be valid. ERC has completed all
planned HVAC equipment installation reinspection.
Status of NRC Inspection Activity
The NRC inspector reviewed the June 28, 1987, Work
Process / Attribute Memorandum (WP/AM) for HVIN with respect to
homogeneity. This document is required by paragraph 4.3.1
(Establish Populations) in Revision 1 of ISAP VII.c which
states, in part, "A supporting document for each population
will be prepared which documents the reasonable homogeneity of
"
each associated work activity. . . .
Paragraph 5, " Homogeneity Justification," in the WP/AM states,
in part, for both equipment setting and equipment connections,
"All the work activities (attributes) for this work process
were performed by the same contractor . . . . " This was one
of the bases used by ERC for establishing homogeneity.
However, it is the NRC inspector's current understanding that
both Bahnson Service Co. and B&R had performed these work
activities.- This is an unresolved item pending NRC
verification of whether more than one contractor was used and
completion of review of the other WP/AMs (445/8713-U-03).
7. Allegation Follow-up (99014)
a. (Closed) Allegation OSP-87-A-0039: An allegation was
received that 3 or 4 security guards at Comanche Peak
have bad credit ratings.
The allegation has been evaluated by the NRC CPPD staff.
The nexus between bad credit rating, security guards, and
safe plant construction / operation is not apparent. In
addition, the NRC has no clear regulatory authority over
hiring individuals with bad credit rating. By this
report, the applicant is informed of the allegation. The
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NRC plans no further action and this allegation is j
considered closed.
8. Plant Tours ,
i
a. Electrical Cable Installation (51063)
During a tour of the auxiliary building on July 28, 1987,
the NRC inspector observed that the thermolag and covers
had been removed from cable tray T23GACZ39 located on the
832' level. The green, safety-related Train B electrical f
4
cables were observed to be slumped at the through-the- 'l
floor sleeves to the next lower level which indicated a j
lack of support at higher levels and possible stretching j
of the cables. The inspector noted that the cable tray ;
numbering on the next level higher level of the auxiliary (
building, 852', was T23GACN96 and that no cable supports
were visible where this tray made a turn from vertical to
horizontal near the ceiling. In addition, the inspector
l
noted that Train B electrical cables made a transition
from conduit C23G05758 to this latter cable tray without ;
visible cable support. 4
Since it appeared to the NRC inspector that'these cables
may be overly stressed at some point, he requested an
explanation from the applicant. On July 30, 1987, the 1
inspector was informed that tywraps would be installed I
for temporary cable support until such time as the l
permanent cable grip supports were installed.
The inspector observed that the tywraps had not been
installed when he toured the above areas on August 4, i
1987. This inspection will be continued. ]
b. Inverters TBX-ESELIV-01, 02, 03, and 04 (51053)
During a follow-up inspection, the NRC inspector observed j
butt splices installed on the internal wiring of Static {
Inverter Power Supply Cabinets TBX-ESELIV-01, 02, 03, and
04. Some of these butt splices, using blue AMP PIDG type
connectors, had three wires connected; two of the wires 1
installed in one side of the connector and one wire in
the other side. The NRC inspector reviewed the wiring l
diagrams, drawing number 4950C67 sheets 1 through 10, for
these inverters and found that the drawings did not
indicate installed splices. The inspector then reviewed
the equipment specification (No. G676573, Revision 5,
dated March 13, 1975) to determine if the splices were
acceptable. Paragraph 3.1.2.B.10 of this specification
stated: "In no case shall splices by permitted in any
components manufactured by the supplier of the equipment
or purchased from other sources."
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On July 28, 1987, these splices were again discussed with
applicant personnel who informed the NRC inspector that
these splices had been installed by the vendor,
Westinghouse Electric Corporation, as allowed by a change
to Specification G676573 dated June 28, 1982. A copy of
this change was telecopied to the applicant on July 29
and shown to the NRC inspector on July 30, 1987. The-
transmittal letter for this specification change,
Westinghouse letter WPT-9099, also indicated that the
above drawing would be revised to indicate these splices.
Applicant personnel also informed the NRC inspector that
NCR PE 87-00574 had been written for these splices. The
NRC inspector then requested information which would
verify that the inverters had been qualified with the
splices installed. This is an unresolved item pending
receipt of documentation from the vendor on the
qualification of these splices (445/8713-U-04,
446/8710-U-01).
9. Significant Meetings
Electrical Splice Requirements Meeting (30702)
On July 22, 1987, NRC inspectors met with the Manager of
Electrical Engineering for TU Electric to discuss the use and
control of electrical splices. The meeting was held to
provide the clarification requested in the exit meeting held
on July 7, 1987. The inspectors were informed that all
splices receive the same installation and QC controls, and
that differences are only for some specific requirements.
These differences are: (a) only the AMP Preinsulated
Environmental Seal (PIES) splices,.which are installed inside
control panels, need to be staggered, and (b) those splices
which are installed in locations which could be expected to be
spliced need not be indicated on plant drawings. The NRC
inspectors again reviewed the craft (EEI-8) and QC inspection
(QI-QP-11.3-28) procedures to verify the requirements and
controls and found them confusing as to the requirements.
Another meeting was held on August 4, 1987, with the Manager
of Quality Control to gain additional clarification of the QC
requirements. It was the NRC inspectors' understanding that
the QC inspection procedure requires complete splice
inspection even though the craft procedure only requires a QC
check of the wire stripper tool setting. When the QC
inspector is called to verify the tool setting, the QC
inspection procedure requires complete splice inspection. The
other significant difference between these procedures is in
the area of environmental qualification; the craft procedure
requires heat shrinking only if so directed, the QC procedure
requires heat shrinking unless directed to the contrary.
These differences will be resolved with the pending issuance
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of Revision 3 to the Electrical Erection Specification;Lthe. !
above level-of detail will be contained in the specification
-rather than the individual procedures. 1
10 . . Management' Meetings (30702). l
a.: On July. 14, 1987, J. G'. Keppler, C. .I. Grimes'and L.
. Chandler met with W. G. Counsil and J. W. Beck to discuss 1
the status of plant rework activities and system
retesting.
~
b. On-July 15, 1987, C. I. Grimes and P.;F. McKee met with
.
W. G. Counsil'and J. W. Beck to' discuss programmatic
schedules and the proposed agenda for a public meeting on. .
July 29-30,-1987. I
c. J. E. Lyons, P. C. Wagner and F. Ashe attended a meeting f
with SWEC and TU Electric personnel on July 16, 1987. :
The' purpose of this meeting was for TU Electric to
present the CPSES position on electrical separation
criteria. TU Electric personnel described the evolution
to the present requirements and their basis for the
acceptability of those requirements.
d. On July 22,.1987, CPPD headquarters management and staff 1
met with representatives of TU Electric Nuclear Licensing
to discuss the status and schedule for. closing the open ;
licensing issues listed under item 11 of TU Electric ;
letter dated 6/25/87 (TXX-6500). !
i
e. On July 23, 1987, R. F. Warnick and C. J. Hale met with ,
O. W. Lowe, J. F. Streeter, J. L. Barker, and R. P. Baker i
to discuss utility plans relative to evaluating
nonconforming conditions for deportability under 10 CFR
50.55(e). (See IR 50-445/8710, 50-446/8708 for
background on this issue.) The applicant indicated that
new nonconforming conditions identified after July 25,
1987, will be screened for deportability under 10 CFR
50.55(e). The screening will be accomplished by either
EA or Operations, as appropriate, and will be-
accomplished within a maximum of 30 days. The backlog of
old nonconforming conditions'will be screened for ;
deportability within four months.
Previously (IR 50-445/8710, 50-446/8708) the NRC had
reported that the applicant would' categorize deficiencies i'
in old work by existing generic 50.55(e) reports.
Deficiencies in old work that did not fall under existing
generic 50.55(e) reports would be categorized into new .
50.55(e) reports as appropriate. The previous NRC report l
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also stated that this would constitute the basis for a
request for an exemption to 50.55(e). In the July 23 ;
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meeting the applicant indicated that it would be as much
work to. categorize the old deficiencies as it would be to
screen them for deportability; therefore, the new
commitment.
Recognizing the wording of 50.55(e), the need for a
finite time to determine deportability, the thousands of
items in the backlog, the accepted practices at other
nuclear plants, and the time needed to organize.and staff
such a function,-the NRC finds the applicants proposed
actions acceptable.
f. On July 29 and 30, 1987, J. G. Keppler and members of the
CPPD staff met with W. G. Counsil and members of'the
TU Electric staff in a meeting, which was open to'the
public, to discuss NRC questions pertaining to Revision 4
of the CPRT Program Plan and ISAPs.
!
g. On August 4, 1987, C. I. Grimes, P. F. McKee,.
J. E. Lyons, H. E. Schierling, M. Malloy, and A.
Vietti-Cook met in Bethesda, Maryland, with J. Redding
and J. Beck to discuss the schedule for the corrective
action program and related activities. Program and
schedule details will be documented in a future
TU Electric submittal.
11. Unresolved Items
Unresolved items are matters about which more information is
required in order to ascertain whether they are acceptable
items, violations, or deviations. Three unresolved items
disclosed during this inspection are discussed in
paragraphs 3.k, 6, and 8.b.
12. Exit Interview (30703) j
An exit interview was conducted August 4, 1987, with the I
applicant's representatives identified in paragraph 1 of this
report. During this interview, the NRC inspectors summarized
the scope and findings of the inspection. The applicant
acknowledged the findings.
I