ML20236C631
Jump to navigation
Jump to search
| ML20236C631 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/23/1987 |
| From: | Barnes I, Ellershaw L, Hale C, Will Smith, Wagner P NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20236C585 | List: |
| References | |
| 50-445-87-16, 50-446-87-13, NUDOCS 8710270275 | |
| Download: ML20236C631 (67) | |
See also: IR 05000445/1987016
Text
{{#Wiki_filter:_ _ _ _ _ _ _ _ _ - - _ _ - _ __ ____- _ _ _ _ -__ _ ____ - ____
.
l
l
l
APPENDIX C
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF SPECIAL PROJECTS
NRC Inspection Report: 50-445/87-16 Permits: CPPR-126 1
50-446/87-13 CpPR-127 '
Dockets: 50-445 Category: A2
1
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
Inspection At: Comanche Peak Site, Glen Rose, Texas
Inspection Conducted: August 5 through September 2, 1987
%
I\
v
Inspectors: x
') /LLL, /0
L .\ E. Ellershaw, Reactor Inspector / Dave '
(paragraphs 2.g-n, 2.r, 3.a, 3.f, 3.h-j,
0.b-e, and 9)
\
1 l0 b 77
C. J. Hale, Reactor Inspector Datd
(paragraphs 2.o, 2.t-u, 3.e, 3.g, 4, 5.d-e, and 6)
kojo20275871023"
G Dock 0500o445
PDR
_7 ~ . - _ - - ,
., ,
2
0
$fh foY
W. F. Smith, Reactor Inspector
/0/2S/87
Dat'e
(paragraphs 2.a, 2.q, and 5.a-c)
f.E. W e
P. C. Wagner, Reh& tor Inspector
io/zs/e7
Date
3
I
(paragraphs 2.b-f, 2.p, 2.s, 3.b-d, 7.a-c and 8.a)
.
Consultants: EG&G - J. Dale (paragraphs 2.k, 3.a and 3.f)
W. Richins (paragraphs 2.g-j, 2.1, 2.m-n, 2.r,
and 3.1)
V. Wenczel (paragraph 6.a)
l
Parameter - J. Birmingham (paragraphs 2.0, 2.t, 4, I
and 5.d-e) l
K. Graham (paragraphs 3.h, 3.j, and
8.b-c) l
D. Jew (paragraphs 8.d-e)
l
Reviewed by: ffha& [0Y
I. Barnes, Senior Project Inspector
Y2h77
tat'e
Inspection Summary:
Inspection Conducted: August 5 through September 2, 1987 (Report j
50-445/87-16; 50-446/87-13) f
'
Areas Inspected: Nonroutine, unannounced inspection of applicant
actions on previous inspection findings; follow-up on violations .
'
and deviations; follow-up on 10 CFR Part 50.55(e) reports; general
plant areas (tours); Comanche Peak Response Team (CPRT)
issue-specific action plans (ISAPs) III.a.3, III.c, VII.a.2, and
VII.b.1; nonconformance processing; corrective action programs; and
site design reviews.
Results: Within the eight areas inspected, three violations
(actions to prevent repetition not taken for nonconforming
conditions, paragraph 2.u; 6.9kV jackshaft welds did not meet weld
criteria and were not identified during inspection, paragraph 6.b;
and cotter pins missing on sway struts, paragraph 8.b) and one
deviation (administrative procedure does not have committed
administrative controls, paragraph 2.a) were identified,
i
-- _ - -- - - A
, --. -- ,
. .
3
,
DETAILS
1. Persons Contactec
*D. B. Allen, ISU Coordinator, TU Electric
*R. P. Baker, Engineering Assurance (EA) Regulatory Compliance
Manager, TU Electric
V. Barish, Issue Coordinator, Evaluation Research Corporation
(ERC)
R. Beam, Conduit Walkdown Supervisor, EBASCO l
'R. A. Berry,. Project Engineer, Stone & Webster Engineering
Corporation (SWEC) ,
*D. N.-Bize, Regulatory Compliance Supervisor, TU Electric '
*M. R. Blevins, Manager, Technical Support, TU Electric
J. T. Blixt, Nonconformance Report (NCR) Group Supervisor,
Brown and Root (B&R)
D. Boydston, Issue Coordinator, ERC
T. Brandt, Assistant to Director of Quality Assurance (QA),
TU Electric '
l
R. Broome, Pipe Fabrication Shop, B&R
A.-Clay, Pipe Fabrication Shop, B&R
P. Cowell, Supervisor of. Structural Integrity, Impell
Corporation
*R. D. Delano, Licensing Engineer, TU Electric
M. Dempsey, Electrical Engineer, SWEC
D. E. Deviney, Manager, Operations QA, TU Electric
S. Esfandiari, Project Engineer, Impell Corporation
*S. L. Ellis, Unit 1 Test Manager, TU Electric
K. Fitzgerald, HVAC Engineer, EBASCO
*M. D. Gadon, Senior Review Team (SRT), CPRT, TU Electric
S. Golub, Welding Engineer, SWEC
*P. E. Halstead, Manager, Quality Control (QC), TU Electric
M. J. Harvey, Warehouseman, B&R
S. Harrison, Supervisor of Support Engineering, TU Electric
*T. L. Heatherly, Regulatory Compliance Engineer, TU Electric
*D. A. Hodge, CPRT Interface, TU Electric
*C. R. Hooten,' Unit Manager, Comanche Peak Engineering,
TU Electric
*J. J. Kelley, Manager, Plant Operations, TU Electric
C. Killough, Quality Services Supervisor, TU Electric
*R. L. Moeller, Westinghouse Site Manager, Westinghouse
*L. D. Nace, Vice President, Engineering & Construction,
TU Electric
T. R. Neely, Supervisor, B&R
*D. E. Noss, QA Issue Interface Coordinator, TU Electric
E. Odar, Project Engineering Manager, EBASCO
J. O'Hearn, Electrical Engineer, SWEC '
.
C. Killough, Quality Services Supervisor, TU Electric
*G. R. Purdy, Site QA Manager, B&R
G. Ross,-Issue Coordinator, ERC
*M. J. Riggs', Plant Evaluation Manager, Nuclear Operations,
TU Electric
____- --- - .
_ - _ _ _ - _ _ _ _
!
-. ..
4
*A. H. Saunders, EA. Evaluations Manager, TU Electric
*A. B. Scott, Vice President, Nuclear Operations, TU Electric
*C. E. Scott, Manager, Startup, TU Electric 4
I
D. Schmidt, Senior Coordinator, Technical Audit Group,
TU Electric ;
'
B. G. Schuler, NCR Evaluation Task Coordinator, SWEC
D. Shelton, QE, B&R i
'
L. K. Skinner, Warehouseman, B&R
*T. G. Tyler, Director, Projects, TU Electric
*C. S. Weary, Supervisor, Equipment Qualification, TU Electric
The NRC inspectors also interviewed other applicant employees
during this inspection period.
* Denotes personnel present at the September 2, 1987, exit
interview. ;
2. Applicant Actions on Previous Inspection Findings (92701)
a. (Closed) Unresolved Item (445/8511-U-02): Resolution of
the Joint Test Group's (JTG's) failure to require hot
preoperational retesting of steam generator water level,
pressurizer level, and pressurizer pressure instrument
detectors after replacement. On pages J-73 through J-77
of the CPSES Supplemental Safety Evaluation Report No.7,
dated January 1985 (SSER-7), the NRC Technical Review j
Team (TRT) identified two completed preoperational test l
data packages where the JTG had approved retests i
requiring only a cold calibration after level instrument d
detectors had been replaced on steam generators and the
pressurizer following integrated hot functional testing
4
(HFT). The detectors should also have been checked under i
hot plant conditions to satisfy preoperational test ]
requirements. The TRT directed the applicant (see page j
J-77, paragraph 6.a of SSER-7) to address the appropriate
resolution in the deferred preoperational tests.
Deferred preoperational tests are those preoperational !
tests which have been formally deferred until the $
required conditions can be achieved during the Initial i
Startup Testing Program. This is because the plant may i
not be scheduled to achieve those conditions before
licensing and fueling, i.e., hot standby, and it is not
always prudent to cycle the plant through a thermal
transient just for a small increment of testing. The NRC
reviews, and must consider the safety significance of, i
'
these deferrals as part of the licensing process. It was
l
not known by the TRT during the 1984 reviews whether
l another HFT would be conducted before initial fueling. i
1
!
The JTG conducted a reevaluation of the completed test l
.
packages as committed in ISAP III.a.1, " Hot Functional
I Testing (HFT)," paragraph 4.1.2. Subsequently, the NRC j
_ _ - _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _
- -- -
. "
5
staff conducted implementation inspections for
ISAP III.a.1 as documented in NRC Inspection Reports
50-445/85-11, 50-446/85-06 and 50-445/85-16,
50-446/85-13. In paragraph 5.h of 50-445/85-11,
50-446/85-06 the NRC inspector identified another case
where a pressurizer pressure transmitter had been
replaced subsequent to HFT, but again the JTG approved a
cold calibration as the only designated retest.
The TRT position on the issue has been that Regulatory
Guide (RG) 1.68 (Revision 2 of August 1978), to which the
applicant is committed per FSAR Appendix 1A(B), requires
tests designated in the FSAR as preoperational tests to
be completed and the results evaluated and approved by
the applicant prior to issuance of the Operating License.
RG 1.68 also requires the system being tested to be
" essentially complete." This means complete to the
degree that outstanding construction items could not be
expected to affect the validity of test results. Failure
to install components required to be tested, or the
subsequent replacement of tested items can be expected to
invalidate the test. RG 1,68 requires that, to the
extent practical, the plant conditions during the tests
should simulate the actual operating'and emergency
conditions to which the system, structure, or component
may be subjected. The phrase ". . . to the extent
practical" means earthquakes, steam line ruptures, or
other extremes that could damage or shorten the design
life of equipment are not appropriate for preoperational
testing.
Issuance of the Operating License is dependent upon,
among many other things, the applicant meeting RG 1.68 in
their preoperational test program, or the staff being .l
provided adequate justification, usually in the form of l
specific, limited deferrals, when the preoperational test 1
program cannot be completed as committed.
The applicant's preoperational test procedures appeared 1
to implement the objectives of RG 1.68, based on TRT !
reviews and previous procedure reviews conducted by the
NRC Operations Senior Resident Inspector. For example,
'
1CP-PT-34-05, " Steam Generator Narrow Range Level
Verification," demonstrates at hot, no load conditions
that the narrow range level channels for each steam 1
generator indicate properly at the upper and lower
instrument taps, and compare properly with each other for
actual changes in steam generator water level.
1CP-PT-55-05, " Pressurizer Level Control," demonstrates
the control, level indicating, and alarm aspects of
pressurizer level instruments with a prerequisite
(paragraph 6.13) requiring the plant to be in hot
u__________ _
j
. _ _ _
_ _ _ _ _
)
!
.- *
6 l
i
standby. 1CP-PT-55-10, " Pressurizer Pressure Control
System," demonstrates the system's capability to maintain
pressurizer pressure and to restore pressure after a
pressure deviation, with a prerequisite (paragraph 6.18)
requiring the plant to be in hot standby.
These same objectives are not met by only a cold
calibration of the installed replacement detectors. In
the ISAP III.a.1-Results Report, Revision 1, " Hot
Functional Testing (HFT)," issued on June 24, 1987, the
CPRT stated that the JTG's reevaluation of the above test
data packages led to the conclusion that the test
objectives had been met and confirmed the original JTG
decision concerning the retest requirements for the
replaced detectors. The CPRT and the SRT concurred. The
NRC staff did not agree, and a meeting to discuss the NRC
concern was held on August 31, 1987, between the NRC
Assistant Director for Inspection Programs, CPSES Project
Division; the TRT Test Programs Lead; the Senior Resident
Inspector for Operations; TU Electric Vice President,
Operations; Manager, Startup; Technical Support Lead,
Startup; and the CPRT Team Leader. The TRT's concerns
over retesting were discussed with the following results:
(1) The Startup group will produce objective evidence
that the five instrument detectors discussed above
all demonstrated satisfactory operating
characteristics during the heatup of the plant to
normal hot conditions in December 1984/ January 1985.
This evidence was produced on September 1, 1987.
(2) -The applicant understood the TRT's concerns that
there may be other such components or systems that
may have been inadequately retested following
maintenance or modifications. In cases where
preoperational test acceptance criteria may not have
been fully met on retests, the applicant appears to
have inappropriately adopted the practice of
assuming the items would eventually be fully checked
as a result of the post-licensing Initial Startup
Test Program. These should have been identified as
outstanding retests instead of being signed off as
complete. The applicant has indicated that the
Prestart' Test Program currently being developed for
Unit 1 will retest them or identify, with
justification, those which will not be retested _
prior to licensing. The NRC staff has reopened l
applicable portions of the preoperational test
inspection program to monitor the applicant's Unit 1
Prestart Test Program which will ensure that all
preoperational test acceptance criteria are met
I
--- - - - _ - _ _ - _ _ _ _ - . - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ _ .
&
-
:,
'
.
y
and/or. exceptions identified with adequate
justification prior to licensing.
(3) .StartupfAdministrative Procedure CP-SAP-22, " Retest
Control," Revision 3 of July 20, 1987, now provides
adequate: instructions for assuring that equipment
will be retested to maintain the state of readiness
previously established by the preoperational tests.
(4) Operations Administrative Procedure STA-623, " Post
Work Testing," Revision 1 of June 26, 1987, appears
to be adequate to assure the operability.of safety-
related equipment as defined in the Technical '
Specifications; however, it does not contain
controls to ensure adequate retesting of systems or
design features that have been maintained lor 4
modified following preoperational testing and prior
to licensing on systems turned over to Operations
control, such that.the parameters recorded in the
preoperational test records remain valid. In view
of the long period of time between preoperational
testing ~and licensing at CPSES, the staff recognizes
that-there will be cases where initial
preoperational testing criteria will not be met due
to normal wear and aging of some components. If
these components are not restored, this will require
analyses to justify use in an "as is" condition.
As stated above, Appendix 1A(B) of the FSAR
indicates the applicant is committed to RG 1.68,
Revision-2, 1978. This RG requires, in part, the 2
establishment of administrative controls to ensure
adequate retesting of systems or design features
maintained cn: modified during or following i
preoperational testing. In addition, RG 1.68
' requires that upon licensing, all safety-related
systems and design features must meet the
preoperational test acceptance criteria as described .
'in the FSAR with any and all exceptions identified
to the NRC and appropriately justified. {
l
Failure to have the above controls is a deviation 1
from RG 1.68, Regulatory Position C.2 l
(445/8716-D-01). l
{
(5) It was recognized that in the absence of detailed
retest requirements for every conceivable kind of
work that could be performed on safety-related J
equipment, there will be cases where engineering l
judgement will be necessary to specify post work i
retests which ensure the previous results of j
preoperational testing are still valid. TU
l
,
,
.. .
8
l Electric's Startup and Operations programs provide '
adequate controls for this except as noted in
paragraph (4) above,
b. (closed) Open Item (445/8511-0-07): Inadequate
separation distance between electrical cable trays. The
NRC inspector observed that cable tray T140CDJ17 had two
1" openings in the solid bottom cover and that the tray
was located only l'9" from the cable tray below. The
separation distance requirements in effect at the time of
the inspection required that a 3' distance be maintained
for the above installation. The NRC inspector has noted
that the applicant issued design change authorization
(DCA) 25,487 subsequent to the inspection. The DCA
revised the required separation distance applicable to
the above installation to 1". The installation in
question, therefore, meets the present separation
criteria. The revised criteria have been submitted in
Amendments 60 and 62 to the FSAR and are currently under
review by the NRC.
l c. (Closed) Open Item (445/8511-0-14): Damaged separation
barrier material (SBM). This open item pertained to
instances of damaged SBM or fire wrap material that were
, observed by the NRC' inspectors during ISAp VII.c
inspections. The specific locations of damage and the
associated applicant noncomformance reports (NCRs) were
delineated in NRC Inspection Report 50-445/86-01;
50-446/86-01. The SBM " blankets" are constructed from
layers of fire retardant material which are then sewn
inside a fiberglass cloth. Further review disclosed NCR
CE 87-4577 had been dispositioned to remove all SBM from
Unit i raceways, because incomplete installation
requirements had led to the conclusion that the quality
of the installations was indeterminate. Therefore, this
open item is moot.
d. (Closed) Open Item (445/8511-0-16): Inadequate
separation distance between conduit and cable tray.
While performing ISAP VII.c inspections for the conduit
population, the NRC inspector noted separation distances
less than were allowable at the time of the inspection
(also see Open Items 445/8511-0-17 and -18, below).
Subsequent to those inspections, the applicant issued
DCA 25,487. This DCA reduced the required separation
distances between conduits and cable trays to 1". The
observed separation distances were in compliance with
! this revised criteria. As noted in paragraph 2.b above,
the revised separation criteria were submitted to the NRC
in Amendments 60 and 62 to the FSAR.
..
. _ _ _ _ _ _ _ . _ _ _ m. - - - - -
, _ _ . _
' '
> >
V
:s . -
-9
-
L p b e.) -(Closed).open Item (445/8511-0-17): Inadequate conduit
'
L to: cable tray separation. distance.' See open Item (,, '445/8511-0-16, above.-
.
'
f. (Closed) open' Item (445/8511-0-18): Inadequate conduit l
to cable tray separation distance. See open Item'
445/8511-0-16,L above.
g. (closed): Open: Item (445/8513-0-41): .During an NRC
witnessed: reinspection of Verification Package
I-S-SBPS-028'for support WP-X-AB018-012-3, the ERC
inspector identified two potential. deviations:
(1) incorrect l bolt hole spacing,fand (2) excessive. gap ,
between the pipe and shim. This resulted^in Deviation 1
Reports (DRs)-I-S-SBPS-028 DR1 and DR2, respectively.
DR1 was revoked on November 27, 1985, and DR2 was revoked
October 7, 1985, for the following reasons: (1) "The
condition no longer exists in field. Based on review of
operations at the time of inspection; there was j
maintenance' work going on in general area of support and
-
piping. At the time of reinspection a condition could
have existed causing the pipe to be raised .015" from the
Support." and (2)'"Further reinspection of the
dimensional variance for attachment location to the
baseplate revealed that dimensions:given on support
detail drawing are accurate and within tolerance."
The NRC inspector reinspected Verification Package
I-S-SBPS-028 and interviewed the original ERC inspector.
Based on these actions, the NRC inspector concluded that
the original measurements had'been taken on an incorrect ;
base plate. The error had been corrected during a ,
-subsequent inspection that'found all measurements to be :
within~ tolerance. ~j
i
h. (Closed) open Item (445/8513-0-42): During a
~
reinspection of= Verification Package I-S-SBPS-035, the
ERC inspector identified a potential deviation pertaining
to insufficient Hilti bolt embedmont. The support
drawing, CH-2-AB-015-008, Revision 3, indicates the lower
north Hilti requires an 8" minimum embedment; however,
'the ERC. inspector' measured a total embedment of 7 7/8".
This condition caused the initiation of DR
I-S-SBPS-035-DR1 for a violation of minimum embedment,
and which resulted in the~ issuance of NCR 85-M-22006.
This NCR was dispositioned as follows:. "Per CEI-20,
paragraph 3.1.4.1, the change in bolt projection during ,
tightening of the nut shall not exceed one nut height.
Since the 7 7/8" embedment now existing is within one nut
height of the 8" embed specified, and the bolts were
torqued to the required 150 ft. lbs. (reference
IRMH-50366), the condition is acceptable as is." The NRC
1
. .
10
I' i
inspector has reviewed Verification Package I-S-SBPS-035
and QEI-020, and concurs with the disposition of NCR
85-M-22006. This open item is closed. ,
i. (Closed) open Item (445/8513-0-43): This item addressed
a potential deviation regarding incorrect bolt spacing on {
a small bore pipe support base plate. This condition was l
identified by CPRT during an NRC witnessed inspection of 1
Verification Package I-S-SBPS-038, documented on CPRT DR l
I-S-SBPS-038-DR1, and incorporated into NCR M-23382N. i
NCR M-23382N states that this condition is not a )
nonconformance based on additional inspection. The i
measurement in question is acceptable and within the f'
+ 1/4" tolerance. The NRC inspector checked the
measurements and concurs with the disposition of NCR
M-23382N. This item is closed.
j. (Closed) open Items (445/8513-0-50, 445/8513-0-51, and
445/8513-0-52): These items addressed potential
deviations identified by CPRT during inspections of
Verification Packages I-S-LINR-03, -30, and -60 which
were witnessed by the hRC inspector. Excessive weld
reinforcement was documented on CPRT DRs I-S-LINR-03-DR1,
-30-DR1 and -60-DR1. Weld undercut and unacceptable weld
seam surface were documented on CPRT DRs I-S-LINR-60-DR2
and DR3 respectively. These DRs were incorporated into
NCR M-85-101128SX, Revision O, which was dispositioned
"use-as-is" based on an evaluation of radiographic
examinations and a comparison of actual to nominal yield
strengths. The disposition of this NCR is the subject of )'
NRC violation 445/8631-V-01 and will be tracked by the
NRC using this violation number. These open items are
therefore closed.
k. (Closed) Open Item (445/8514-0-23): During an ERC
reinspection of Verification Package I-M-HVIN-040 (a
fan), three potential deviations were identified:
(1) inlet and outlet duct connection gaskets had low and
uneven compression, (2) diameters for foundation anchor
bolts and duct connection bolts were illegible on
drawings provided in the inspection package, and
(3) exhaust duct connection bolts did not have full
thread engagement with nuts. The ERC inspector initiated
DR I-M-HVIN-040-DR1 dated October 22, 1985, for items (1)
and (3), above. A new legible copy of the drawing
clarified the required diameters for the foundation
anchor bolts and the duct connection bolts; therefore,
this item was not added to the DR. Item (1) on DR1 was
deleted when inspection after removal of caulking from
the mating flanges showed the gasket material to be
satisfactorily compressed. Item (3) on DR1 resulted in
the issuance of NCR CM-87-5963X on April 29, 1987, which
_ _ _ _
- _ - _ _- - _ _ _ _ _ - _ _ _ _ __ _ _ - _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ - -_-_-_ - __
. .
11
was dispositioned as follows: "This non-conforming
condition will be addressed by CAR-111 through the
implementation of CPE-FVM-CS-029."
l The NRC inspector has reviewed Verification Package
I-M-HVIN-040, DR1, NCR CM-87-5963-X, CAR-111 and
CPE-FVM-CS-029. CPE-FVM-CS-029 is a complete walkdown
,
and reverification program for HVAC and' includes the
i
inspection of Attribute 3.6.3.E.H.8, " Minimum engagement
is such that tip of bolt is flush with outside face of
nut." The NRC inspector concurs with the disposition of-
DR1 and NCR CM-87-5963-X and agrees that implementation
of CPE-FVM-CS-029 (which has already begun and will be a
subject of'NRC inspection) will identify and cause to be
corrected any other deviating conditions. This open item
is closed.
1. (closed) Open Item (445/8514-0-33): This item addressed
a potential deviation identified by ERC during an NRC
witnessed inspection of Verification Package I-S-CONC-40.
The locations of concrete cast-in-place inserts
(Richmond) were out of tolerance. This condition was
documented on DR I-S-CONC-40-DR1 and was later
incorporated into NCR C86-100082SX. This NCR was voided
per Note 14 on Drawing 2323-S-0640, Revision 5, which
states, in part, " . . . Where such installation (of
Richmond inserts) is prevented by interferences with
rebar or other embedments that are impractical to move,
the concrete inserts are to be relocated to clear such
interferences." As a result, the location of Richmond
inserts was deleted as an attribute by ERC in Change
Notice 001 to QI-043, Revision 1, " Reinspection of
Concrete Placement." The NRC inspector concurs with this
action and considers this item to be closed.
m. (closed) Open Item (445/8516-0-45): This item addressed
potential deviations identified by ERC during an NRC
witnessed inspection of Verification Package
I-S-STEL-066. Hilti bolt size, initially identified as a
deviation, was subsequently verified to be correct per
DCA 16019, Revision 12. ERC DRs I-S-STEL-066-DR1 and DR2
were issued regarding dimension and location of a
structural member. A member fabricated out of
1/2" plates is designed to be 6'0" long with a top
elevation of 828'0". The as-built length is 5'11 3/4"
and the top elevation is 828' 3/16". These DRs were
incorporated into NCR M-86-101229X and dispositioned
"use-as-is" per DCA 16019, Revision 13, which documents
and authorizes the above dimension and location. The NRC
inspector reviewed the NCR and DCA 16019, and concurs
with the disposition.
, _ _ _ _ _ _ -
-c
-
.
2
n. (Closed) Open Item (445/8518-0-19): During an NRC
witnessed reinspection of Verification Package
I-S-CONC-080, the.ERC inspector identified that an anchor
bolt projection was out-of-tolerance and would be subject
to evaluation as a potential deviation.
Design Drawing 2323-s-0758 requires a 4" projection. QC
was' unable to determine actual projection due to all
bolts being cut off on a skewed plane. This condition
was documented on DR I-S-CONC-80-DR1 which was superseded
by NCR-C-86-100076-SX.
The NCR was dispositioned "use-as-is" with the following
justification. Due to a field obstruction, anchor bolts
were cut off on a skewed plane at a maximum of
15 degrees,.which is structurally acceptable since it
extends beyond the nut by 3/8" to 5/8". The NRC
inspector has reviewed the above documents related to
this open item, including the equipment pad and anchor,
and concurs with this disposition.
o. (Closed) Open Item (446/8602-0-02): No process was
apparent to assure that all applicable elements of the QA
program were audited annually.
The applicant has developed and issued Administrative
Guide QIA-7102, " Development and Maintenance of the
' Internal Construction Phase Audit Plan / Schedule,"
Revision O. The intent of this administrative guide is
to provide the methodology and criteria for development
of the internal audit plan / schedule for the construction ;
phase.
The guide is implemented in five phases. Phase one
identifies the construction activities and subactivities
which are required to be audited. Phase one is
accomplished by a review of project documents such as the
QA Program Plan and project procedures. Phase two
identifies the elements of Appendix B that are applicable
to the activities and subactivities identified in phase
one. Phase three identifies those site procedures and
instructions that govern the activities and subactivities
identified in phase one and determines the audit
requirements for those procedures. Phase four develops a
- set of standard annual audits and audit scopes to address
L all of the activities and subactivities identified in
phase one. Phase five requires a review of the annual
audits and audit scopes to verify that all applicable
elements of Appendix B are audited at least annually.
.
The NRC inspector has reviewed the applicant's actions
[ performed for each of the five phases and has determined
l
l
___ ___ _ _ __ _____ - _
l
- - _ - _ _ _.
'
" *
-
13
,
r l- l' .that continued implementation of Administrative Guide
QIA-7102 should: identify the elements of Appendix B that
are required to be audited; assure that these elements
are included in audit scopes; and verify that each
applicable element is audited annually. Since this
administrative guide provides a process to assure that
all applicable elements of the QA Program are audited
annually, this item is closed.
p. (Closed) Unresolved Item (445/8604-U-14): Missing cable
support plate on electrical penetration assembly (EPA)
1E-14. .The NRC inspector had observed that the support
plate had been removed from 1E-14 and that no temporary
support had been provided. In response to the other
findings contained in the inspection report containing
this item, the applicant agreed to replace all EPAs
provided by the Bunker Ramo Corporation (BRC) with
modules provided by the Conax Corporation. Details of
the replacement process are included in Inspection
Reports 50-445/86-32, 50-446/86-26; 50-445/87-03,
50-446/87-03; and 50-445/87-07, 50-446/87-06. Since the
module pigtails involved in this item were Conax modules ] '
which had been earlier installed, the discussions of
pigtail supports contained in paragraph 3 of the latter
report are applicable to this item. Those previously
installed Conax EPA modules which had not been provided
with adequate pigtail support were replaced. Since the
modules which may have been damaged have been replaced .
and since the replacement program has implemented
adequate controls to ensure pigtail support, the NRC
inspector has no further questions on this matter.
q. (Closed) Open Item (445/8607-0-23): During an
implementation inspection of ISAP III.b, the NRC
inspector noted that ERC commitments, to conduct
evaluations to determine whether preoperational test
procedures were designed and performed in a manner which
complies with the FSAR, had been deleted from ISAP III.b
and moved to ISAP III.a.1. Subsequently, the ISAP
III.a.1 and ISAP III.b Results Reports were published.
Upon review of both, the NRC inspector noted that the
CPRT had moved the commitment, as well as the discussion
of implementation results, back into ISAP III.b.
Accordingly, there is no need for this open item,
r. (closed) Open Item (445/8607-0-31): This item addressed
potential deviations identified by ERC during an NRC
witnessed inspection of Verification Package
I-S-STEL-164. ERC issued DRs I-S-STEL-164-DR1, DR2, DR3,
and DRS regarding, respectively, undersized welds, weld
undercut, an alteration (holes in stiffeners) not shown
on the design drawing, and the out-of-tolerance location
--
. _ _
!
i
- *
14
of field installed details. -These DRs were incorporated
into NCR M86-101181X and dispositioned "use-as-is" per
DCA 25219 which documents the conditions identified in L
DRs I-S-STEL-164-DR1, DR2, and DRS. NCR M86-101181X
states that DR I-S-STEL-164-DR3 is not a nonconformance
based on additional inspection which showed that the
stiffener holes were in the specified stiffeners as shown ;
on Drawing 2323-SI-0635 and Revision 1 of DCA 16,660 3
dated April 8, 1983. The NRC inspector verified the
above by inspection of the structure and review of the
drawing and DCA and concurs with the disposition of NCR
M86-101181X. This item is closed.
s. (Closed) Open Item (445/8615-0-09): Incorrect location
indicated on drawing. During an ISAP VII.c inspection of i
electrical equipment, an ERC inspector identified to an l
NRC inspector that an electrical cabinet was not located i
in the position shown on the Unit 1 cable spreading room
layout drawing. The DR written for this condition
(I-E-EEIN-051-01) resulted in NCR E86-103765X being
issued by the applicant. The NCR was dispositioned i
" VOID: This is not a nonconforming condition. I
Cpl-ECPRTC-41 was found by Engineering to be located as l
shown on drawing #2323-El-0712-02 (25'-8" South of SA)." f
The NRC inspector measured the distance from the frame
SA wall to the centerline of the cabinet-and observed the
24'-8" distance documented by the ERC inspector; however, '
the NRC inspector observed that this was from the inside
wall surface of frame SA and not the centerline of the l
frame as shown on the drawing. Since the wall was ,
approximately 2' thick, an addition of l' was appropriate ;
for the measurement. The NRC inspector, therefore,
agreed with the NCR disposition.
t. (Closed) Unresolved Item (445/8626-U-05; 446/8622-U-04): ,
Documentation was not provided concerning whether Hilti !
bolts with modified length designators were properly
evaluated and whether the safety implications of the
modifications to the length designators had been
determined.
The NRC inspector has obtained additional ildor.?ation
regarding this deficiency; i.e., that five Hilti bolts
were determined to be undersized by an ultrasonic test
(UT), identified during the corrective action associated
with SD?? CP-80-10. These bolts were documented and
dispositioned on NCR-E-81-00001. Additionally, a sixth
Hilti bolt, found by UT to be longer than specified, was
also documented and dispositioned by this same NCR. NRC
review of NCR-E-81-00001 found the disposition to be:
scrap the five undersize Hilti bolts, and for the
- _ - _ _ - - _ - _ _ . __ _ -___- _ - - _ .
* *
15
oversize Hilti bolt (after correcting the length
designator) "use-as-is".
The NRC inspector met with one of the QC inspectors who
performed the corrective actions for SDAR CP-80-10.
During this meeting, the QC inspector indicated that
while no specific instructions had existed to inspect for.
Hilti bolts with modified length designators, the
. inspectors were aware of the potential for this condition
[
and had inspected for it. The NRC inspector reviewed the
, '
instructions given to the inspector for the UT
examinations performed under SDAR CP-80-10. The
instructions (i.e., QI-QAP-9.2-4B, Revision 0, and
QI-QP-11.2-5, Revision 0) required the QC inspector to
compare the length indicated by the Hilti bolt length
designator to the actual bolt length as determined by the
UT examination. The NRC inspector determined that
Hilti bolts with modified length designators would have
been discovered by QC during the corrective action for
SDAR CP-80-10. NRC review of the results of SDAR
CP-80-10 found that over 3,600 electrical group Hilti
bolts were inspected by UT examination and that no
additional instances of modified length designators were
discovered. NRC review of the file documentation for
SDAR CP-80-10 found that the 3,600 electrical group Hilti
,
bolts inspected accounted for virtually 100% of the Hilti
bolts installed in the cable spread room and the
auxiliary building at elevations 790' and 810' (except
for inaccessible and 1/4" Hilti bolts). Since these
3,600 bolts were installed in the same area and by the
same electrical craft personnel identified with the
modified.Hilti bolts (the subject of SDAR CP-80-10), the
inspection and UT of only these bolts was an appropriate
action to determine if similar deviations existed in
other Hilti bolts installed by this electrical craft
group. NRC review of notes and memos addressed to or
sent from the then current site QA supervisor indicated
that he was aware of the modification of the length
designators and had considered including them in the
results of SDAR CP-80-10. Since the identified Hilti
bolts with modified length designators had been found in
a support for a nonsafety-related Train "C"
instrumentation cable, and since the results of
corrective action for SDAR CP-80-10 indicated that the
modification of Hilti bolt length designators was
l apparently an isolated occurrence, the decision not to
include this information in the report appeared
justifiable to the NRC inspector.
The additional information obtained concerning NCR
i
E-81-00001 provided how the nonconforming condition of
l the identified Hilti bolt was documented and how the l l
-
..
16
.
>
hardware was corrected. The information concerning
actions taken to determine the extent of the unauthorized
modification resolves the NRC concern-that the safety
implications of the deviations may not have been
evaluated. Therefore, this item is closed.
u.' (Cloced) Unresolved Item (445/8711-U-01; 446/8709-U-01):
NCRs were invalidated and no action was taken even when
additional corrective or preventive actions were
indicated.-
The NRC inspector selected 17 NCRs that had been
invalidated and discussed each of these with the
personnel involved; i.e., M-21543, M-26189, M-28401,
M-21982, M-28567, M-21861, M-20857, M-26470, M-26471,
M-21940, M-21942, M-21594, M-21881, M-21983, M-26033,
M-26060, and M-28674. In nine NCRs, the NCR appeared to
have been invalidated properly; i.e., a nonconforming
condition did not exist and no corrective or preventive j
-actions were necessary. In eight of the NCRs, '
discrepancies were noted such as a procedure revision was
indicated but none made, all items on the NCR were not
addressed, the justification for invalidation did not
appear to address the concern, or the nonconforming item
had been replaced or removed prior to the NCR being
invalidated as "no longer nonconforming," with no other
action being indicated even though the NCR may have been
valid when it was initiated.
Subsequent to the issuance of this unresolved item, the
Director of QA initiated a review of all invalidated NCRs
processed during the previous 12 month period. This
review considered over 200 invalidated NCRs. Most of
these NCRs were processed properly, being generated for
the most part from CPRT DRs or out-of-scope observations,
which indeed were not nonconforming. As documented in
office memorandum QQD-323 on August 20, 1987, 37 of these )
invalidated NCRs appear either to have been valid or that
further action was appropriate, but no further action was
taken. CAR 070 was initiated on August 26, 1987, to
further assess the identified NCRs and initiate any
necessary corrective actions concerning this aspect of
NCR processing.
This further NRC inspection indicates a violation of
Criterion XVI of Appendix B to 10 CFR Part 50 and a
failure to implement NEO 3.06, " Reporting and Control of
Deficiencies," which requires programmatic
deficiencies / weaknesses to be identified and corrected to
preclude recurrence (445/8716-V-02; 446/8713-V-01).
_ _ _ _ _ _ _ _ _ _
I
! i
*
17 l
L l
3 ', vo llow-up on Violations and Deviations (92702) i
a. (closed) Violation (445/8516-V-08): The NRC inspector
identified that a Richmond Insert had been substituted
for a 1 1/4" Super Hilti Kwik Bolt. It was determined
that this change was made per DCA 13349; however, the ;
change was not subject to the same design control
measures as those applied to the original design. The )
applicant responded to the above violation by letters J
TXX-4826, dated June 16,.1986, and TXX-4992, dated
September 5, 1986, which provided the following
explanation. l
DCA 13349, as issued, allowed the substitution of a 1"
diameter Richmond Insert for a 1 1/4" diameter Super )
Hilti Kwik Bolt. The DCA made no mention that the
substituted Richmond Insert was to be grouted in
previously placed, hardened concrete. As a result of
this, the design control and associated design review for
the DCA did not receive the same design control measures
as those applied to the original design. The DCA (13349)
was reviewed and additional calculations were done to
show the design change was acceptable. This review of
the DCA was performed in accordance with project
procedures which are supposed to assure that the design
change receives the same design control measures as those
applicable to the original design. Further calculations
have been completed and show that the support is a
acceptable assuming zero load resisting capacity of the
Richmond Insert. DCA 13349 was revised to clarify that
the Richmond Insert was grouted versus poured in place.
Three design engineers were assigned to review all
structural DCAs and to verify whether or not any other
document exists with respect to grouted in Richmond
Inserts. This review was initiated on September 2, 1986,
and completed September 5, 1986. No other documents were
found which pertained to grouted in Richmond Inserts.
The NRC inspector reviewed the revised DCA 13349 and )
Calculation SRB-128C, Set 2, Revision 10, and found the
information to be accurate and all corrections have taken
place. The NRC inspector considers this to be an I
isolated instance.
b. (Closed) Violation (445/8604-V-08; 446/8603-V-08):
Failure to stagger electrical splices. The applicant's
'
August 4, 1986, response to this violation stated that
the requirement to stagger the splices for these valve
isolation tank EPAs had not been included in the source
or receipt inspection checklists because the requirement
was not included in the equipment specification but only
- _ _ _ _ _ _ _ -
- .
. - - - -- .- . . . - - - - - -
V; ,
'
. O^ .
'
K '
b
...- ..
18
'
.1 .
' e .
indicated.on a drawing. The-applicant'ccamitted to .,
implement a program'to correct problems ~with the receipt q
inspections;.this program will be inspected as part of ' ;
the'closecut of.related violation 445/8604-V-07; -{
'446/8603-V-07. The applicant further~ committed to the
'
l
replacement oftall BRC.EPAs; see the discussion of
unresolved item 445/8604-U-14 above (paragraph'2.p).
Since the EPAs'in question are being replaced with-
assemblies of a-different design which do not include
pigtail ~extensionLsplices, this specific concern'is moot.
{
This finding was also identified as Violation I.B.4.b in
Report EA 86-09.
:
c, .( Closed). Violation (445/8604-V-12): Installation'of
cable supports of a design different than shown on the i
vendor drawing. 'The applicant's August 4,'1986, response
to this item explained that the differences'between the.
standard containment' EPA and these valve isolation tank
EPAs led to'the confusion which resulted in noncompliance I
with a drawing requirement. The' response further stated !!
that all BRC'EPAs would be replaced and that the '
installation instructions'for the replacement EPAs would
more clearly convey the. applicable requirements.
=!
The NRC. inspector observed that the replacement EPA 1E-79 i
was installed on August 11, 1987; the other.three EPAs j
cited (1E-76, -77'andL-78) had been previously installed.
Since these replacement EPAs are of a different design,
the original concerns are moot; however, the NRC
inspector also observed that appropriate support was
being provided for the EPA pigtails in accordance with -;
craft and QC? procedures.- Detailed inspections of those j
'
; procedures and the associated installation instructions
were documented in NRC Inspection Reports 50-445/86-32,
-50-446/86-26; 50-445/87-03, 50-446/87-03; and
50-445/87-07, 50-446/87-06. l
Further NRC inspection related to the adequacy of the
receiving inspection reports (RIRs) will be conducted as
'
part of the closecut of violation' 445/8604-V-07;
446/8603-V-07'which is related to these same four EPAs.
This finding was also identified as Violation I.B.1.a and
I.B.4.a in Report EA 86-09.
'
d. (Closed) Violation (445/8604-V-15): Lack of EPA pigtail
support on the inboard side of 1E-14. The applicant's
August 4, 1986, response to this item stated that the
appropriate support had not been provided because of the ;
failure to follow the appropriate procedures. The l.
. ...
1g
applicant further stated that a support would be provided
and that training would be conducted prior to the
installation of replacement EPAs. The NRC inspector has
documented compliance with the requirements that the
pigtails be supported in NRC inspection reports related
to the EPA replacement program (50-445/8203, 50-446/87-03
.
and,50-445/87-07, 50-446/87-06), and the completion of
l
craft and QC training in NRC Inspection Report
50-445/86-36; 50-446/86-26.
On August 11, 1987, the NRC inspector observed the
determination (disconnecting the pigtails from the field
cables) activities for Module A of EPA 1E-14 on the
inside of the Unit i reactor building. This activity was
required by'Startup Work Authorization (SWA) 30926 to
allow module removal in accordance with Work order (W.O.)
C85-293 for seal ring rework. The NRC inspector had no
questions on the determination activity but did observe
that the pigtails to the field cables did not have very
much slack. A review of the W.O. package showed that DR
C87-188 had been written to document the lack of slack on
a number of EPAs, including 1E-14.
This finding was also identified as violation I.B.1.c in
Report EA 86-09.
e. (Closed). Violation-(445/8622-V-16; 446/8620-V-07):
Several pieces of stainless and carbon steel pipe outside
Warehouse C and the Welder Qualification Training Center
were not stored in accordance with procedures.
The applicant's response committed to revise the
applicable procedure (MCP-10) providing several methods
of capping. stainless steel pipe and retrain the
appropriate personnel in the procedural requirement.
These actions were stated as being completed prior to
April 1, 1987.
The NRC inspector reviewed Document Change Notice (DCN) 1
to MCP-10, " Storage and Storage Maintenance of Mechanical
and Electrical Equipment," Revision 9. This DCN provided
several ways and combinations for protecting the ends'of
stainless steel pipe. MCP-10 has since been superseded,
in part, by ACP-14.2, " Storage and Maintenance of
Mechanical Equipment," Revision 0. The new procedure has
similar wording concerning the capping of stainless steel
pipe.,
To verify the retraining of personnel in the storage
procedure, the NRC inspector reviewed the training files
for both Warehouse C and the fab shop personnel. The
files confirmed that these personnel had received
- _ - _ - _ _ _ -
_ _ _ _ _ _ _ _ _ _ _ _ _ _ .-
,
' '
20
o
i
training on the revised procedure. In addition, the NRC
inspector discussed storage practices with two
individuals in each area, who demonstrated a proper
knowledge of the controlling procedure.
To verify'the effectiveness of the corrective actions,
l the NRC inspected both the outside storage areas
(Warehouse C and pipe fab shop). No further violations 5
were identified.
f. (closed) Deviation (445/8607-D-13): It was identified
that the ERC inspector and the overview inspector signed
'
off Attribute 3, regarding spherical bearing gap for
Verification Package I-S-PS7N-146, as being acceptable.
However, an NRC inspection of this package revealed that-
the spherical bearing had been heavily painted, thus
precluding an accurate measurement of either the gap or
the spacers.
As a result of the identified deviating condition,
Attribute 3 for Verification Package I-S-PS7N-146 was
"N/A'd" to indicate that this attribute was
nonrecreatable. In addition, on August 1, 1986,
out-of-scope observation (OOS) 796 was initiated to
identify this condition. This resulted in the issuance
of NCR M-25383N dated September 17, 1986. On August 1,
1987, the NRC inspector accompanied an ERC inspector on a
reinspection of all pipe support spherical bearings
previously inspected by the ERC inspector identified in
this deviation. Seven packages were reinspected which
resulted in a total of four OOSs (including OOS 796).
, TU Electric has also undertaken a hardware validation
program (HVP) for, among other things, 100% of the pipe
supports which includes spherical bearing gap in the
inspection attributes. NCR M-25383 was dispositioned to
say that " Existing paint on spherical bearings is not a
non-conformance since component exhibits freedom of
movement." The NRC inspector has reviewed all of the
above documents and concurs.
g. (Closed) Deviation (445/8622-D-01; 446/8620-D-01):
Committed corrective actions concerning preparation and
evaluation of objectivity forms were not accomplished
for certain CPRT personnel. Three examples of the
deviation were identified.
(1) The support staff for the CPRT Program Director and
F personnel on the records review committee had not
completed objectivity forms.
The NRC inspector verified that the above personnel
had since completed the required forms and the forms
= - _ _ _ - _ _ _
m-.
,
]
L., .: 21
had been evaluated by the proper level of management
by the committed date of March 23, 1987. Further,
the NRC inspector inspected the files of all new i
CPRT personnel added since March 23, 1987, a total
of 34 files. These files were in compliance with
commitments.
(2) The objectivity form of the CPRT Program Director
had-not been evaluated by the appropriate CPRT
manager as committed in the April 1, 1986, letter
from Mr. Counsil.
Revision 3 to the CPRT Program Plan, dated
January 25, 1986, exempted the SRT chairman ind the
CPRT Program Director'from the objectivity
requirements, since both were then applicant ;
. employees. 1
i
(3) The TERA Revj ew Team Leader (RTL) objectivity form :
was not completed by the date committed. j
As indicated in the deviation the TERA RTL !
objectivity form was completed July 17, 1986.
In~ summary, the committed corrective actions have been
accomplished. A further inspection by the NRC of the
files of personnel added to the CPRT since the corrective
actions were completed did not identify other deviations
indicating effective implementation of preventive
actions. Accordingly, this deviation is closed.
h. (Closed) Deviation (445/8622-D-10):
'
Positive j
displacement charging pump TBX-CSAPPD-01 was not tagged l
with ERC deviation tags even though eight DRs had been ;
: issued with respect to noncomplying nut torque i
requirements and mechanical coupling alignment.
In response to the Notice of Deviation (NOD), TU Electric ,
l
stated they had no reason to believe ERC inspection
personnel did not place deviation tags identifying the l
noncomplying conditions associated with pump l
TBX-CSAPPD-01. Therefore, the ERC tags had fallen off or l
were inadvertently removed. The purpose of placing ERC l
'
deviation identification hold tags on hardware is to
assist TU Electric in identifying the deviating hardware
for their control. Based on the DRs written by ERC,
TU Electric placed a hold tag on TBX-CSAPPD-01 as
- .
evidenced by NCR M-25151N. A memo was prepared by the
'
t CPRT Program Director to TU Electric emphasizing the I nature and significance of ERC deviation tags. l p I ,
- _ _ -
, .- - - _ . _ . - _ . - --_ ___ _ -__ -
,
I i
~
.$ 0 !
*
'af
,
-Thd NRC inspector. reviewed memorandum CPRT-897Jwhich
1
addressesLtheJsignificance'of ERC. deviation
. identification tags'and verified, by field' inspection,
. that.a'nonconformance' hold. tag had been placed on.the
nonconforming equipment.
Li .- (Closed)' Deviation (445/8631-D-02): The ERC inspector
entered "N/A" for Attribute B.3.1, structural' bolting l !
, tightness,.on the inspection'chscklist for Verification
Package R-S-STEL-117 when, in. fact,ithe attribute does: ,
HA ' apply., Eight 3/4" A193 bolts are associated with the 'j dih
"*
reinspected' member and tightnessowas signed off on the
, construction traveler. ERC' reinspected this. attribute,.
found it acceptable, and corrected the inspection
checklist.. ERC also reviewed the work of the. responsible ;
inspector on similar verification packages and. concluded ;
that.'the error was.an isolated occurrence.' The NRC:
inspector verified the above and concurs with ERC's i
conclusion.
Lj . (Closed) Deviation (445/8631-D-03; 446/8625-D-01): ERC !
lDR R-M-FFTA-001 DR-6, which documents that Chicago Bridge
& Iron.(CBI) did not supply a metal material verification j
summary sheet'(MVSS), was' improperly invalidated evenL
'
.though.the described condition was.not acceptable. The-
CBI' material requirement table MRT-73121/2 requires asea
minimum r 0that.the MVSS be supplied.
The quality instruction (QI-42) failed to specify that
the use of " Supplemental Summary Sheet of Material
"~ Verification" (SSMV) as'a continuation sheet for the
" Metal Material Verification. Summary Sheet" is an.
. acceptable' method for CBI to denote' material piece mark .
?- identifications. j
A change notice to QI-042 was prepared on June 25, 1987,
to specify that the use of " Supplemental Summary Sheet of
Material Verification" by CBI is acceptable.
The NRC inspector reviewed the CBI QA manual and k
. determined that, although'MRT-73121/2 did require an MVSS j
for each piece mark number, it is an acceptable i
documentation practice to use the SSMV as a continuation )
sheet for the MVSS.
The NRC inspector verified that ERC QI-042 had been
L revised as stated. I p l
1
.. . I
, 1 __ _-__- __ -
. -
' '
23 ;
I
4. Action on 10 CFR Part 50.55(e) Deficiencies Identified by the' q
Applicant (92700)
a. (Closed) SDAR CP-80-10: Unauthorized modifications were {
made by craft to the wedge area of concrete anchor l
(Hilti) bolts. -
i
This condition was initially reported to the NRC on
y October 1, 1980. At that time the applicant performed an j
investigation to determine the extent of the '
nonconformance and to determine the corrective actions
required. The Resident Reactor Inspector (RRI) reviewed :
the sampling basis for the applicant's investigation, l
observed portions of the ultrasonic testing performed, l
and reviewed the applicant's final report. Based on I
these activities, the RRI closed the item in NRC I
Inspection Report 50-445/81-18. l
l
The applicant reopened this item by means of a i
supplemental report to SDAR CP-80-10 dated July 15, 1987. ]
This action was taken to clarify certain statements found ;
in the file documents for SDAR CP-80-10 by the NRC ]
inspector. The supplemental report clarified that j
SDAR CP-80-10 specifically addressed unauthorized )
modification to the wedge area of Hilti bolts.
l
The supplemental report also clarified that five ,
nonconforming Hilti bolts identified during the original ,
investigation of SDAR CP-80-10, which appeared to have (
modified length indicator stamps, were outside the scope j
of SDAR CP-80-10. These five bolts were addressed by the
applicant separately on NCR E-81-00001. The supplemental l
report stated that the applicant's conclusions regarding i
SDAR CP-80-10 remain unchanged. j
!
The NRC inspector reviewed the applicant's corrective
actions regarding these five Hilti bolts and determined
that the corrective actions taken were appropriate. (See
the closure of unresolved item 445/8626-U-05;
446/8622-U-04 in paragraph 2.t of this report for related
information.)
Based on the RRI's closure of this item in NRC Inspection !
Report 50-445/81-18 and NRC inspection of the unresolved
item (50-445/8626-U-05; 50-446/8622-U-04), this item is
closed.
b. (Open) SDAR CP-86-48: A review of NCR dispositions j
indicated that some dispositions may have been l
technically inadequate. I
l
1
1
___
n.
,
* *
;v 24 . -
'
H
'
The' applicant reported to the NRC that it initiated a
program-to review the adequacy of certain NCR
dispositions. The~ review program is the result of ,
investigative actions relative to Corrective Action l
Report (CAR) 062. A description of the review program
was provided.to the NRC in an interim report, .
SDAR CP-86-48, dated July 15, 1987. A description of the j
three phases of this NCR review program follows. j
Phase I of'the program is to identify those NCRs and
TU Electric design deficiency reports (TDDRs)-which
contain dispositions. involving engineering requirements;
e.g., use-as-is, repair, or void. If the engineering-
involvement identified on the NCR or TDDR is the subject f
of other ongoing engineering validation efforts (e.g., !
HVAC reverification program), those NCRs and TDDRs are !
sent to the applicable engineering group for technical ;
'
evaluation of the dispositions. All other NCRs and TDDRs
identified are sent to Phase II. (The' scope of the
Phase I review will include all NCRs and TDDRs processed
or inprocess before the effective date of Procedure
NEO 3.05, " Reporting and Control of Nonconformances," '
dated December 22, 1986).
1
Phase II of the program provides for a technical
evaluation of the disposition of each NCR or TDDR ,
identified in Phase I. j
Phase III of the program requires that appropriate j
actions be initiated to resolve any disposition i
inadequacies. !
)
SWEC is performing this review and has almost completed l
the Phase I activity. Phase II is ongoing, and Phase III J
is being implemented as required. NRC inspection of all ]
phases of the review program is being performed and will !
be reported in this and subsequent reports. I
The NRC inspector reviewed SWEC Procedures
CPE-TD-SWECO34, Revision'1, "Nonconformance Report (NCR) ,
and Design Deficiency Report (TDDR) Evaluation," and '
PP-041, Revision 1, "Nonconformance Evaluation '
Procedure." These procedures govern the SWEC review of
NCRs and TDDRs. The NRC inspector determined that these ]
procedures provided the necessary guidance for the review l
of those documents reported to be of concern in l
SDAR CP-86-48,
1
To assess the implementation of the Phase I review of
NCRs the NRC inspector reviewed 60 of the completed )
Phase I reviews. The NRC inspector found that SWEC had "
l
properly identified those NCRs: (1) whose dispositions
l
-
+ ,
w~'4 .
3 , q
"> j <
, /g a ;
-.y
.
,
'."
['{ 3 25
'
~.
' /< ,
'
% ,
involved engineering requirements, (2) that,wir4 te be l
"Q/ '
reviewed by other engineering validation ef'fcd6, and
'O) that were dispositioned, or in the proccus 'cf 'being i
dispcnitioned before December 22, 1986, and therefore
wsre Mequired to be evaluated in Phase II of.the SWEC
:, fyeview program. The results of the NRC inspection of '
4 l
i'fthene
review.NCRs was consistent with the results of tho'SWEC
,
,s ,
/
..i. ,
seNCRstobeaddressehI4yndther
Concerning t
engineering validation efforts, the W;C inspector found r, Y( q
l
that the method.s for transferring t! his \fd.u;onsibility didQ ' '
not provide accountability ofithese IIC Q or assurance . $
that all NCf.s would be evaluated consiitent'with the SWEC
^
'
program. Thisconcernhasbeenexpressedtejthe
applicant and will be'followed up as an opert item >
(445/8716-0-03; 445/3713-0-02).
,s S
Other forms used' to' document deficiencies; such as test
deficiency reports (TDRs) and field deficiency reports'( i
(FDRs) are similari in many respects to NCRo and TDDRs.
It is not clear at/ this time if these docunvents will be
included in the SDAR Cp-86-48 review program. ThelNRC
will follow this matter as an open" item-(445/8716Hb-04;
446/8713-o-03).s,
\
No violations or devk,tions were noted. \ NRC inspe$ tion
of this jtogram is coiytinuing.
,, .
+ 52 l CPRT ISAps
' ~
,
[
Technical S, specification For Deferred Tests (ISAP III.a.3[
.
a.
(72400q),
During:the TRT inspection of test programs in the
preoperational test area, the NRC operationn resident
inspectors expressed concern that the orderly progress of
Initial Startup (ISU) testing may be hampered by
Technical Specification (TS) limiting conditions for
operation (LCOs), due t'o hhc nature and extent of
preoperational tests which had been deferred into the ISU
program. The NRC usually approves preoperational test
deferrals with the stated assumption that TSs will be met
while the test is being conducted. In or6er to achieve
the plant conditions (i.e., hot plant at normal cressure
and temperature) to cenduct the deferred preoperitional
tests, the TSs requiro some of the systems being tested
to' be fully operable. However, operability cannot be
eerified cn most systems until preoperational testing is
completed. :An example is thermal expansion testing,
!
where numerods snubbers were deferred; thereby rendering
c ,
.
.
-- _ _ _ _ ____
r 7si . gj
%
: ,
1l
* '
26 Q 1,
^
u i
<
systems needed to enter hot plant modes of operation as
inoperable.
This issue was addressed in NRC. Inspection Report
50-445/85-16; 50-446/85-13 under prxagraph 6.e of
Appendix D. After the issue had been re.ised,
j the
applicant conducted another hot testing sequence in
November and December 1984, during which most of the
preoperational tests previously scheduled for deferral
were completed. In a letter dated?Janutry 24, 1985,.the
NRC closed this issue, and on page y-18 of SSER-7, the
staff indicated that it will not requipe TU Electric to-
evaluate required plant conditions' for the deferred
preoperational tests against the applicable TS LCOs q
because TU Electric had informed the TRT that the tests s'
will be conducted prior to fuel load.
The CPRT issued ISAP III.a.3, Revisi$n 3 on February 27,
1986, to readdress the issue and to 'rcote that although
many of the individual testing items were completed as
stated above, there remained four items open pendird F, / /
completion of satisfactory testing and ono item open i
pending NRC approval of a proposed TS change. The,ISAP
indicated that no action was required because TU LGectric
has had adequate administrative controls to ch6'tre')that'
TS requirements are considered when scheduling ,i <
preoperational test deferrals. , ( ' h,
On October 15, 1986, the CPRT issued the ISAP'dII.e.3 , ) J
Results Report, " Technical Specification for Defeyr61,if'
Tests,"whichreiteratedandsupplementeddetailsofitho[
ISAP, documented the CPRT findings and explained what the. s
findings revealed, and then reached a conclusion based onj,
' ' '
the findings. ,
'
f
The NRC staff reviewed the results report to (1) ensurd ,
that it accurately reflected what the actica plan was,
(2) verify that CPRT findings reported were consistent
with what the NRC inspectors found while conducting the
ISAP implementation inspections, (3) ensure that
conclusions reached had valid bases, (4) ascertain that
root causes and generic implications, if,any, were fully
addressed and satisfactorily resolved, and (5) check to
ensure the 14 questions posed by the At' omic Safety and
Licensing Board (ASLB) with respcLt to the results report
were adequately answered and did noo'open new issues.
The ISAP III.a.3 Results Report concluded that: )
l
(1) Station procedures provide for evaluation of
deferred preoperational testing and include, among j
(
l
i
__ !
g f 7;
d, -
-pp .
7
(4 m .gf
3, 'e ,
'
6,1 - -
.s 27
hh' s 1 1
Jhlh '
/t , !
d[ gi .pther things, consideration of thc requirements of. )
4 j j qpha TSs.
'
f I
.,
s u+ . I
,u fZi_ '
Since the potential cf deferred preoperational
~
.
*'i O testing always exists, even if diligence is :
1 exercise,d to keep it to an absolute minimum, the .{
,
ICPRT
.( review.of amended the ISAP to include identification and '
the specific station procedures which
addres4 3he NRC concerns on meeting TS LCOs. The
accepttsce" criterion was that the station procedures
must specifically require that evaluation of j
deferred preoperational test procedures include the i
[h consideration of TS requirements. )
4
'
The CPRT determined that STA-805, Revision 2, " Deferred J
. Testing," requires', in part, that a safety evaluation be ;
4
performed as a part of the test deferral process,
addressing in accordance with STA-707,
Revision 3,jTS " requirements,
Safety Evaluations." STA-707 specifies how
safety evaluations shall be performed, documented,
reviewed and approved to meet the requirements of 10 CFR !
50.59.
The NRC inspector reviewed the same administrative
. procedures above and concluded that there are adequate
' controls in effect to ensure that test deferrals are
properly reviewed and cycluated against possible TS
i
impact, which will allociate the NRC resident inspectors'
concerns about TS LCOs being met.
l
l
s
As required by the Program Plan, the CPRT addressed the j
,
'
question of root causes and generic implications. Since !
noitesting deviation or deficiency was identified and no I
ge3eric condition exists which indicates that there are
~
~ inadequate administrative contnols over deferred
gr' operational testing, no root cause or generic
implication 4 determination is required. The staff 3
concurs, bdsed on independent reviews of STA-707 and l
STA-805.
On April 14, 1986, the ASLB issued Memorandum
79-430-06-OL relative to a motion to ccmpel production of
checklists, which contained 14 questions needing to be
resolied in results reports. On March 2, 1987, the
applicant responded to the ASLB's 14 questions as they
apply to the ISAP III.a.3 Resuits Report. The NRC staff
I reviewed the questions and the CPRT responses to
determine whether the; document would have any impact on
f t the.resvlts and conclusions drawn from ISAP
implementation. The staff found that the responses were
"
consistent with observations made by the NRC inspector
f redative to ISAP III.a.3 and none of the responses
it
'
l ! .
_ _ _ _ - ,
!
* '
28
f l
I
l indicated a need to pursue any old or new issues any I further. Therefore, the staff considers the 14 questions
and their responses to have no impact on the outcome or
closure of this ISAP; and thus, has determined the
ISAP III.a.3 Results Report to be acceptable as written.
Summary of Completion of ISAP III.a.3:
(1) NRC Conclusion:
The staff concluded that there is no cause for
concern that the applicant may not consider TS
impacts with deferred preoperational tests.
Administrative controls to prevent this are in
effect at CPSES as evidenced by NRC reviews of
STA-805 and STA-707. In addition, this issue was
previously closed by the staff on page J-18 of
SSER-7. Therefore ISAP III.a.3 is closed.
(2) Remaining NRC Inspection Activities:
None.
No violations or deviations were identified.
b. Preoperational Test Review and Approval of Results
(ISAP III.a.5) (70400)
In Memorandum 79-430-06-OL dated December 21, 1984, the
ASLB expressed a need to know how the Joint Test Group
(JTG) could have approved completed preoperational test
1CP-PT-02-02, "118 VAC RPS Inverters," when the package
contained test data which did not meet the stated
acceptance criteria, and what assurance is there that
similar errors do not exist in other startup test
results. As a result, the applicant implemented ISAP
III.a.5 to (1) identify the factors which contributed to
the approval of test data which did not meet
specifications, and (2) to provide reasonable assurance
there are no similar errors in other test data packages.
The CPRT subsequently informed the NRC staff that actions
committed by the ISAP were complete. The staff completed
an implementation inspection to verify that actions were
completed as stated in the ISAP, and to ensure auditable
documentation was on file to support the actions taken. 1
t
In order to maintain a correlation between the areas
inspected and the corresponding sections of ISAP III.a.5, j
'
Revision 0, the inspector addressed each area by
assigning an NRC reference number using the ISAP
paragraph number assigned by the CPRT for each action:
I
!
l
'
_______
__ _ _ -
4
l
'
29-
'
l
l
l
3.a.5/4.1.1: The CPRT committed to review the original l
test date package for 1CP-PT-02-02.to determine the j
reason for approval of test results which did not meet j
the stated acceptance criteria. The approach taken was )
to review the author's performance on 1CP-PT-02-02 and j
any other tes~s he wrote, the performance of the test I
engineer conducting the test, and finally the completed
test package review and approval process. The NRC
inspector found these reviews and.the results obtained
were adequately documented in the CPRT files. The
results will be discussed later during the results report
review' conducted by the staff.
3.a.5/4.1.2: The CPRT committed to examine the test data
in all 205 test data packages to determine if there were
any.other instances where test data did not meet the
stated acceptance criteria, using the sampling plan in I
Appendix D of the CPRT Program Plan. .The NRC inspector
noted that a tota 1> population of 3391 acceptance ;
criteria, which represent the total from the 205 test
packages, were sampled. Ninety-five samples were to be i
drawn at random since there was already'one defect
(lCP-PT-02-02). Otherwise, 60 would have been
appropriate. The NRC inspector noted-that 101 samples
were drawn, which conservatively exceed the minimum
of 95. The inspector then withdrew 10 percent of the
sampled acceptance criteria and conducted a similar
independent review. There were no deficiencies found.
Adequate documentation existed indicating.that all
101 samples had been evaluated the the CPRT.
3.a.5/4.1'.3: The CPRT committed to process any
identified discrepancies according to Appendix E of the '
CPRT Program Plan and-that corrective action, if
required, would be implemented in accordance with
Appendix H. The staff-verified that these actions were
addressed in the ISAP III.a.5 Results Report, the review
of which will be discussed during a later inspection.
No violations or deviations were identified.
c. Prerequisite Testing (ISAP III.c) (70301)
On page J-85 of SSER-7, allegations relating to the
conduct of prerequisite testing by unqualified personnel
were characterized. The NRC TRT investigated and found
that the allegations had neither safety significance nor
generic implications as reported on page J-88 of SSER-7.
However, during the inspection of 35 test data packages,
the TRT found that craft personnel had verified and
signed for initial conditions on some prerequisite test
data sheets, which is contrary to Section 4.10.9 of
_ _ - _ _ _ _ _ _ _ -
g-
1
.. . .
30 i
l
Startup Administrative Procedure-(CP-SAP) 21, " Conduct of
Testing,"'which required this to be~done by the System' l
Test Engineer (STE). This practice was' inappropriately )
- authorized by a Startup Interoffice Memorandum-(SIM)' {
' issued'by the Lead Startup Engineer'on March 31, 1983.
.
The SIM. countermanded the requirements of CP-SAP-21 by.
allowing-test. support crafts to verify and sign for
initial conditions in selected Prerequisite Test .
: Instructions. The TRT required TU Electric:to rescind
the SIM and-take action to ensure there were no other
memoranda issued in conflict with approved procedures.
The TRT.alsoLrequired TU Electric to conduct a review of j
all other prerequisite' test records to determine those
that had initial conditions signed by craft personnel,
-and to assess the impact of those improper verifications
on theLtesting that followed.
_
As;a result of the TRT findings,~the applicant.
implemented ISAP III.c to identify SIMs which may be in .)
conflict with' approved CP-SAPS, identify prerequisite j
test records which may have initial conditions signed as-
comple'e
t by craft personnel, and to evaluate the impact ]i
of improper verifications on subsequent testing. l
1
The CPRT subsequently informed the NRC staff that actions !
' committed by the ISAP were complete. The staff conducted
an implementation inspection to verify that actions were
completed as stated in the ISAP, and to ensure auditable
documentation was on file to support the actions taken.
In order to maintain a correlation between the areas
inspected and the corresponding sections of ISAP III.c,
Revision 4, the inspector' addressed each area by
assigning an NRC reference number using the ISAP
paragraph number assigned by the CPRT for each action:
3.c/4.1.1: The applicant rescinded SIM-83084 above by
issuance of SIM-84220, dated September 25, 1984. The
inspector verified this by personal observation of the ,
'
memorandum.
3.c/4.1.2: The applicant committed--to instruct STEs that
SIM-83084 had been rescinded, and that it is their
responsibility to verify and sign for initial conditions '
in Prerequisite Test Instructions as required by
CP-SAP-21. The inspector noted that this training was to ,
be conducted as directed in SIM-84220, and documented on
sign-off sheets attached to SIM-84220. The NRC inspector
.
found the signed off sheets documenting the training as
-
satisfactorily completed in the Startup Organization's
j, files. I '
:
L__ m_i. _ . _ . ._ _ _.. ._ __
{l? < y !
* '
. 31
I ,
3.c/4.1.3: The applicant committed to instruct all test
support craft personnel that they shall not verify and
sign for initial conditions nor shall they conduct any
tests without the supervision of an STE. The inspector
noted that this was implemented through both SIMs 84220
and 85049. The completion of all test support craft
personnel training in this area was documented in one of
the attachments to SIM-84220 and in a similar attachment
to SIM-85049. The inspector observed the documentation
in the files.
3.c/4.1.4: Both Startup Management and the CPRT reviewed
all SIMs issued between June 1982 and June 1987 to
.
I
determine if any other directives had been issued which
conflict.with the requirements of the CP-SAPS. This
consisted of several volumes of binders containing a
i
total of 717 SIMs. No additional conflicts between the
SIMs and the CP-SAPS were found, however there were eight
SIMs that could not be located. Four were voided and
thus were of no consequence, and Startup management
indicated that the remaining four probably did not create
any conflicts based on the subject matter. The inspector !
'
did not necessarily agree, but did concede that the
probability of any of the four SIMs having a problem was
remote based on the absence of problems with the 709 SIMs
that were reviewed. Subsequently the NRC inspector
scanned four volumes at random, thus looking at about 200
SIMs and found no problems.
3.c./4.1.5: All prerequisite test records were reviewed
to identify other cases where craft personnel signed for
initial conditions. The NRC inspector reviewed
documentation showing the results of the reviews. The
inspector observed that about 12 per cent of.all
safety-related test instruction data sheets contained
test support craft sign-offs for initial conditions.
This was not unexpected in light of the effects of
SIM-83084 discussed above. The review was well
documented with a clear representation of where the .
I
inappropriate sign-offs were found.
3.c/4.1.6: The applicant committed to analyze all
Prerequisite Test Instructions identified in 3.c/4.1.5 l
'
above to determine the consequence of improper initial
conditions verifications. The conclusion reached was
that this would have no impact on subsequent testing, as
documented in SIM-86155 dated September 15, 1986. The
NRC inspector noted that for each Prerequisite Test ,
Instruction that was found to have initial conditions i
signed off by individuals other than STEs, a TDR was f
initiated and dispositioned. Of the 31 Prerequisite Test j
Instructions that were utilized, 19 had improper J
l
!
\
i
1
f
_-- _ _ 1
-
- -- . ._
i
* '
32
3
verifications, and thus 19 TDRs were written. The NRC
inspector reviewed all 19 TDRs. Each TDR had a completed
checklist and evaluation to determine the impact an
improper verification on each one of the initial
conditions would have on the conduct of the test. Where l
there could have been impact, it was pointed out that the i
result would be an unsuccessful test, wherein the STE :
would be involved and would have to take corrective i
action in order to accomplish the test satisfactorily.
In general, rationales for non-impact were (1) might only
cause delays, (2) the craft involved had sufficient ~
expertise and training to properly accomplish the task,
and (3) th6 initial condition was administrative in
nature and thus had no effect cn1 the test. The staff
agrees with the rationales used on the basis of prior TRT
reviews of test support craft training files, as reported
on page J-86 of SSER-7, and on the adequacy of technical
supervision and oversight provided by the STEs, which is
discussed on page J-88 of SSER-7.
I
3.c/4.1.7: The applicant committed to evaluate the
results of all the above activities to assess the impact j
on later testing, particularly on Unit 2. As a result of
that evaluation the NRC inspector noted that CP-SAP-19,
" Indoctrination / Training / Qualification Requirements for
Startup Personnel" was revised to establish a more formal
program to qualify test support craft personnel. The
applicant's. requirements are more stringent than those'of
ANSI N45-2.6, " Qualification of Inspection, Examination,
'and Testing Personnel for Nuclear Power Plants." The
applicant also made some improvements in the Prerequisite
Test Instruction Manual to better utilize procedures that
will be used in the future by operations personnel.
3.c/4.1.8: This section of the ISAP discusses the
handling of identified discrepancies in accordance with
Appendix E of the CPRT Program Plan and corrective action
according to Appendix H. The NRC inspector noted the
initiation and dispositioning of TDRs where appropriate
during the implementation of this ISAP. No further
action is required under this section of the ISAP.
No violations or deviations were identified.
d. Nonconformance and Corrective Action Systems
(ISAP VII.a.2) (35061)
During this report period NRC References 07.a.02.03,
07.a.02.04, 07.a.02.08, 07.a.02.09, 07.a.02.12, and
07.a.02.13 were reviewed as follows.
__________________ -
l
l
* '
33 q
l
l
Evaluate TRT and SSER Findings on NCRs (NRC Reference
07.a.02.03), Evaluate TRT and SSER Findings on CARS and
Trending (NRC Reference 07.a.02.08)
ISAP VII.a.2 required the CPRT to perform a review of the l
NRC TRT findings-that were relative to the nonconformance j
and-corrective action systems.- These TRT findings were I
documented in_SSERs-7, -8, -10, and -11. The CPRT review )
of the TRT findings was to deterhine: (1) if the TRT l
finding was valid, (2) whether the deviation was an l
isolated occurrence or, (3) whether the deviation was the
result of a deficiency in the nonconformance and
corrective-action systems.
The CPRT review is complete and the results have been )
'
issued.in Sectiou 5.5, " External Source Issues," of the
ISAP VII.a.2 Results Report. The supporting
documentation is found in the ISAP working file (subfile i
VII.a.2.3a001 and 002).
An NRC review of the CPF T review results and file
documentation verified as stated in Section 5.5 of the-
results report, the CPRT review team did not perform a
review of TRT findings as originally described, rather
the CPRT review team evaluated the TRT findings and other
external source issues for impact on their independent
evaluation of the nonconformance and corrective action
systems. (Note: these systems include NCRs, CARS, and
trend reports.) The NRC inspector finds this change in
implementation to be appropriate in that it focuses the
CPRT review on the potential system deficiencies implied
by the findings rather than on the finding itself.
Resolution of individual TRT findings and other external
source issues will be included as a part of the
collective evaluation according to current CPRT plans.
The NRC inspector found that the CPRT had instituted an
issue review and tracking group to assure that all
external source issues, including TRT findings, would be
addressed. This group had assigned to ISAP VII.a.2 a
list of issues determined to be relevant to the
nonconformance or corrective action systems. NRC review
of the list of issues assigned to ISAP VII.a.2 found that
it included TRT findings from SSERs-7, -8, -10, and -11
and issues from other external sources such as the
Management Analysis Company (MAC) Report, the Lobbin
Report, and the Construction Appraisal Team (CAT) Report.
The NRC inspector reviewed SSERs-7, -8, -9, -10 and -11,
and determined that the list included appropriate TRT
findings and that no exclusions were apparent. The CPRT
list included issues such as:
4
i l l L-___________- >
._ - . _ ____ _ ._ _ __ ___
,
*
'
34
- QC inspectors failed to assure control of a
nonconforming pipe; i.e., did not tag or segregate
the pipe.
- -Interoffice memoranda were used improperly to
disposition NCRs.-
- NCRs were voided improperly or were disapproved and
,
subsequently destroyed.
- There was a frequent and improper use of the'NCR
disposition to "use as is".
-
QC inspectors were intimidated to accept NCR
corrective actions.
The list of external source issues and the results of the
issue coordinator's assessmentLof each finding for impact
on ISAP VII.a.2 conclusions are described in the ISAP
working file (subfile VII.a.2.3a, Section 001 and 002).
The NRC inspector reviewed the-list and the issue
coordinator's assessment and found that the CPRT-
conclusions in general concurred with the' conclusions of.
the TRT; i.e. , that it could or could: not be
substantiated. The NRC inspector also found that the
CPRT review team, based on the external source issues and
its own review of the nonconformance and corrective
action systems, had determined that deficiencies had
existed in those systems. For example, the CPRT review
team had identified deficiencies in the procedures that
controlled the nonconformance and corrective action
systems. The CPRT had identified that these procedures
lacked the necessary detail to assure a satisfactory
resolution of identified concerns. The CPRT issued
progra.n deviation report (PDR) 59 to document this
devie.cion and to notify the applicant of the need for
corrective action. Additional CPRT review team findings
were reported under PDRs 52, 64, 66, 67, 68, 69, 71, 72,
and 74. The NRC inspector finds these PDRs to have
properly documented the CPRT review team's findings and
that the recommendations for improvements in the
nonconformance control and corrective action systems to
be appropriate. NRC follow-up of these recommendations
and the applicant's actions will be performed and
reported as a specific activity in subsequent reports.
No NRC violations or deviations were noted and no further l
inspection of these reference items is planned.
l
> l
l
1
1
- _ --- a
- - _- _
* *
35
Report Hardware Concerns and Input to Corrective Action
Review (NRC Reference 07.a.02.04); Report Hardware
Concerns and Input to 55(e) Deportability Review (NRC ?
Reference 07.a.02.09)
The ISAP required the CPRT to notify the applicable
Review Team Leaders (RTLs) of any potential hardware
concerns.found during the implementation of ISAP VII.a.2
'that would require further evaluation. The results
report indicates those notifications were'made.
The NRC inspector found during inspection of the i
ISAP VII.a.2 activities that the CPRT review team had '
documented those concerns with rotential hardware impact
on DRs. The NRC inspector verified that the DRs have
been brought: to the attention of the QA/QC RTL and that
the DRs have been referred to TU Electric for corrective
action. NRC review of the PDRs issued as a result of
ISAP VII.a.2 found that they did not have a direct impact
on hardware. The PDRs were also referred'to TU Electric
for corrective action.
Based on the above, the NRC inspector determined that the i
ISAP requiremer.t to notify the applicable RTLs of J
potential nardware concerns found during implementation q
of ISAP VII.a.2 had been complied with and that the l
-concerns had been properly documented.
!
Initially, ISAP VII.a.2 was to evaluate the results of
the nonconformance system (including NCRs and "other
forms") review for input to both the corrective action
and the 10 CFR Part 50.55(e) reviews. Further, that the
results of the corrective action review would be reviewed
for input to the 10 CFR Part 50.55(e) review. As the
CPRT began implementing this ISAP, it became apparent
that input from the nonconformance system review to the
corrective action review, and the corrective action
review to the 10 CFR Part 50.55(e) review, was not I
meaningful and was not pursuad. The bases for the CPRT's
departure in this area of the ISAP was: (1) the
corrective action system was structured to address
potentially generic system and process problems having
input from systems such as the trending program and not
NCRs or systems which were related to singular hardware
problems; and (2) the corrective action system had little
or no input to the 10 CFR Part 50.55(e). The
deportability system functions from input from the
nonconformance system, which was considered in the CPRT
evaluation.
The NRC inspector has reviewed the bases for this
departure from ISAP VII.a.2 and has verified that input
_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ -
>-
mm- ' ,L~
.
4
;
s e
'
A
n t '
36
;from'the nonconformance system was provided to the:10fCFR
Part 50.55(e). deportability review.- Based on this review i
and verification, the NRC' inspector concurs with:the ,
actions taken by the CPRT in this regard.
No violations or deviations;were'noted and-no-further-NRC ;
. inspection of-these reference items is planned. I
Expand Review if-Deficiencies are'Noted (NRC Reference
07.a.02.12
ISAP VII.a'.2 required.that, "If deviations are
identified, additional reviews will be conducted as
required to identify the full extent of the programmatic
deficiencies. In addition, areas or. groups of
~1
deficiencies which require, evaluation or reevaluation for
110 CFR Part'50.55(e) deportability shall be identified'
and referred'to TUGCo for processing." NRC: inspection of
the CPRT' procedural review, performed to evaluate'the
deportability system, found that the CPRT hadJidentified- ,
'
a program deviation.in~the TU Electric deportability
system. The CPRT identified that TU-Electric Procedure, ,
:CP-QP-16.1, "Significant Construction Deficiencies," the '
controlling procedure for deportability, did not
adequately identify significant deficiency reporting
requirements.from October 1979 through November:1985.
Since the CPRT review team was able to. identify the~ time
frame of the deficiencies additional reviews were not '
;
required. Based on its review of significant deficiency.
analysis reports (SDARs), the CPRT had determined that, '
.
in spite of the lack of formal requirements forl
determining reportabilityfof__ deficiencies in CP-QP-16.1, )
the determinations that were made by TU Electric of an j
' item / event's deportability were reasonable. _Therefore, I
the CPRT found it unnecessary to refer any SDARs.to l
TU Electric for reevaluation of their deportability.
Based on review of a portion of the CPRT sample, the NRC
inspector verified-that those determinations of
deportability reviewed by the CPRT were appropriate. The
NRC_ inspector noted that the CPRI had written PDR 69 to
document TU Electric failure to raview all NCRs for
deportability. PDR 69 has bcon referred to TU Electric.
The CPRT concern that the control of SDAR records is no:
in compliance with' ANSI N45.2.9 has been documented on
PDR 52 and also referred to TU Electric. ,
.
I
L Based on the_above results and previous inspection of the l l' CPRT reviews of the deportability procedures and their j '
implementation, the NRC inspector concludes that the CPRT
reviews were of a sufficient size to identify and scope
_ _ _
i
I l
* *
37
h 1
1
program deficiencies. The NRC inspector also concluded-
that all identified concerns and deficiencies have been
properly documented and referred to TU Electric for 1
action.
No violations or deviations were noted and no further NRC 3
inspection of this reference item is planned. J
1
Third-Party Overview of the NCR Review Program (Reference
07.a.02.13)
The applicant has initiated a program to review the
adequacy of NCR dispositions which involve an engineering
requirement; i.e., use-as-is, repair, or void
dispositions. This program has been reported to the NRC
as part of SDAR CP 86-48 and is described in an interim
report, TXX-6560. The interim report stated that the NCR
review program would be accomplished in three phases.
_
Phase I of the program is a screening review performed to
identify those NCRs whose dispositions would be evaluated
further in Phase II. The criteria of the Phase I
screening review were: (1) the NCR disposition was issued
prior to the issuance of corporate Procedure NEO 3.05, l
" Reporting and Control of Nonconformances," (effective I
I
date, December 22, 1986) (2) the disposition of the NCR
involved engineering requirements (i.e., use-as-is, ]
repair, or void) as determined by an assessment of the 9
actual written disposition; and (3) the NCR was not
already the subject of other ongoing engineering i
validation efforts; e.g., Pipe Support Engineering
(SWEC), Equipment Qualification (Impell/SWEC), Cable Tray
Hangers (EBASCO/Impell), Conduit (Ebasco/Impell), and
HVAC (Ebasco/Impell). The NCRs passing this screening
review would then go to Phase II.
Phase II consists of a detailed technical evaluation of
the dispositions of the NCRs coming from Phase I.
Phase III consists of the resolution of any concerns
involving NCR disposition adequacy.
The scope of this review program has been expanded to
include a review of the technical adequacy of
dispositions of TDDRs, as described in Procedure
CPE-TD-SWEC-034, Revision 1, "Nonconformance Report (NCR)
and Design Deficiency Report (TDDR) Evaluation."
Section 3.0 of the ISAP VII.a.2 Results Report stated
that third-party engineers were performing an overview of
the review of NCR and TDDR disposition adequacy and that
the results of both the NCR and TDDR review and the
third-party overviews would be reported in a supplement
____________________________a
a
!
.
,
38
\
to the VII.a.2 Results Report. The NRC inspection of
this activity has been initiated and will be reported as ,
work in this area progresses. The first such report is !
found in paragraph 4.b of this report.
"
No violations or deviations were noted during inspection
of NRC Reference 07.a.02.13 and no further inspection of
this reference item is planned.
4
e. Onsite Fabrication (ISAP VII.b.1) (35061)
During this report period, NRC Reference 07.b.01.07 and
07.b.01.10 were reviewed as follows.
Analyze Data for Fabrication Compliance (NRC Reference
07.b.01.07) Report Programmatic Implications and Issues
to Other ISAPs (NRC Reference 07.b.01.10)
Implementation of ISAP VII.b.1 required the CPRT to
perform a review of the procedures that control onsite
fabrication and a review of a sample of fabrication ;
'
package.1
Subsequent to the procedure reviews, the CPRT was to
perform an auclysis of the resulting data. This CPRT
analysis was completed and reported in Section 5.6 of the
ISAP VII.b.1 Results Report. The analysis assessed '
,
whether the shop fabrication activities met the
requirements of 10 CFR Part 50, Appendix B, Criteria V,
IX, and X as committed in the CPSES FSAR. The specific
requirements of each criteria are:
Criterion V requires that activities affecting quality be
prescribed by and accomplished in accordance with
documented instructions and procedures;
Criterion IX requires that special processes such as l
welding and NDE be controlled and be accomplished by I
qualified personnel using qualified procedures; and l
1
Criterion X requires that a program for inspection of I
activities affecting quality be established and I
performed. This program shall include: (1) inspection I
independent of the activity being inspected; !
(2) examination or testing of each work operation where l
necessary to assure quality, or if impossible or l
disadvantageous monitoring of the work operations, or j
both examination and monitoring if necessary to assure j
control; (3) as necessary, mandatory inspection hold I
points shall be assigned and shall be indicated in
appropriate documents.
i
__
; ,
' '
- -
~p
y , ", { .
t,
y + -
1 .
.
'
y
'
,
.<> ^\
l
t s. a
L .y31 - A
'
.. . 39-
. m
'
l '
f, 1
1 "i -n
'
> q
l
;A1't hough other1 Appendix B criteria may also have'been
~
+ > fapplicable,1they were in the scope of review of other. o '
.
'
ISAPs;'e.g., nonconformance control'is assessed.by:
'
,
ISAP VII.a.2.
l: 4
aThe NRC inspector previously inspected'thelimplementation
, of the procedural: reviews.and the package reviews . J l
'
(performed.for?ISAP VII.b.1 and reported the details of J
,E those; inspections;in NRC Inspection. Reports 50-445/86-22,. J
,
g -50-446/86-20;-and150-445/86-31,,50-446/86-25. Using:the
results of.these inspections, the NRC inspector reviewed
Lthe!CPRTfanalysis and found that the CPRT had properly:
identified certain deficiencies.__The CPRT identified' 1
"
that~ the historical procedures for construction: and , ,
4: Linspection activities containedfinadequacies;.e.g.,_'B&R
Procedure: QI-QAP'11.1-28.did not provide; details for
inspection 1of site fabricated U-bolts.nor:did it require- 1
the documentation ~of U-bolt' inspection'results. The
identified procedural inadequacies were documented on .
PDRs'38 and 39. ' The NRC inspector also found that the
'
w 'CPRT review of welder qualification and inspector !
4
certification Was an accurate assessment of the.-status of
o certifications..
welder. qualifications and QC. inspect'r
'
As. reported in NRC' Inspection ReportsL50-445/86-22,
50-446/86-20; and 50-445/8631, 50-446/86-25,' the NRC
inspector reviewed 11 documentation. packages!(9 ASME and
.< 2 non-ASME) to the criteria used in the CPRT review. .
Based on the NRC review of the 11 fabrication packages R '
and NRC review'of the CPRT findings for the remaining.
eighty packages, the NRC inspector'found that the'CPRT
hadTproperly determined that:
(1) The non-ASME packages showed a lack of documentation
in eight packages which would preclude the CPRT 1
document reviewers from verifying the qualifications
of.the_ welders involved; and ;
(2)' Inspector certifications in 44 sample items were
found to be questionable.
The instances of a lack of weld documentation were
documented on DRs and were reviewed by the CPRT Safety
"
, Significance Evaluation Group (SSEG). The SSEG
established through review of additional documentation
that the welders were qualified. The NRC inspector
. reviewed the reports of-the SSEG and found that the SSEG
had established the dates that the welds were actually
made and'then verified that the welder was qualified on
that date.
-_.
i
,. .
The NRC inspector verified the results-of the SSEG review
by inspection of.the documentation that established the
date that the welds were made and by reviewing the site
Welders Qualification Matrix (WQM) for each welder in
question. In all instances, the welders' qualifications
were verified. Although a similar lack of documentation
of welder qualifications may exist in other non-ASME
packages, the NRC inspector concurs with the CPRT
conclusion that it is probable that documentation for
welder qualifications exist. This is based on two
factors: (1) the welders' qualifications were originally
verified by QC; and (2) in all eight identified instances
where the date the weld was performed was established,
the welder was found to have been qualified when the weld
was made.
The instances of questionable inspector certifications
were documented on generic DRs 32, 33, and 34 which were
referred to ISAP I.d.1, "QC Inspector Qualifications" for
evaluation and input to the results of that ISAP as
required.
The CPRT also identified concerns relative to material
traceability, the lack of evidence of inspection for site
fabrication of U-bolts, and the uncontrolled " star stamp"
marking of Hilti bolts. The NRC inspector verified
during review of fabrication packages that these concerns
were properly identified and reported to the appropriate
ISAP issue coordinator.
The NRC inspector reviewed the ISAP VII.b.1 DRs and
verified that the material traceability problems had been
identified and sent to the ISAP VII.a.1 issue
coordinator.
The concern of QC documentation deficiencies relative to
site fabrication of U-bolts, along with other concerns
such as inadequate / inconsistent information, insufficient
data, and missing records or illegible records, has been
documented on PDRs 38 and 39 and will be considered in
the collective evaluation being performed by CPRT. NRC
inspection of the collective evaluation-will be reported
when completed.
The concern for " star stamp" marking of Hilti belts has
been documented on CPRT PDRs 38 and 39. The issue is
being addressed by two CARS, B&R CAR-058, which documents
the issue for ASME related Hilti bolts and TU Electric
CAR-074, which documents the issue for non-ASME related
Hilti bolts. The NRC inspector reviewed these CARS and
found that they address the CPRT concern as described in
PDRs 38 and 39. The issue of " star stamping" has been
l
- _ _ -.
-
7, .
,_ y
, ', +
-
1
'~
'
41
*
k
identified to'the NRC as a potentially. reportable item
"
'
and willLbe inspected by the NRC as that effort ;
progresses.
Based on the above, the NRC' inspector determined that the t
'
.CPRT properly analyzed the data'resulting from the
reviews of procedures and fabrication packages.,The'NRC.
Linspector alsofdetermined that the CPRT documented'its
findings ~on DRs or PDRs and referred them to TU Electric
'for' action or to other ISAPs for~further evaluation .
4
'(e.g.,'ISAPs VIT..a.l and I.d.1)-or referred them to the-
CPRT collective evaluation.
No violations or deviations were noted during inspectio'n
of.these reference items and no further inspection of
these items is planned.
6. Inspection of NCR Process (35061)
.This is a continuation.of an inspection initiated during the
-previous. report period (50/445-8713; 50/446-8710)~.
4
a. Operations Deficiency Report Program
The purpose of-the NRC inspection was to determine
whether methods for the initiation, processing, and
control of plant operations deficiency. reports at CPSES
were. performed in accordance with Nuclear Engineering and
Operations Procedure NEO 3.06, Revision 0, " Reporting and
Control of Deficiencies". Station Administration
Procedure STA-404, Revision 5, " Control of Deficiencies,"
is the operations procedure which implements the
requirements of NEO 3.06. Provided below is a summary of
the STA-404 deficiency reporting process, the methodology
used by the NRC to inspect the deficiency reporting
process, and inspection results.
(1) STA-404 Ded ciency Reporting Process
Upon discovery of a. deficiency (e.g., departure from
procedures), a deficiency report is initiated. The
initiator is required to. provide, among other
things, a description of the deficiency observed, ,
the activity affected, observation date, and the
initiator's name. The deficiency report is then
reviewed by the preparer's department-head for
validity. Since December 22, 1986, (NEO 3.06
effective date), 324 operations deficiency reports
have been originated by operations, engineering, and i
QA/QC. .Of these 324 deficiency reports, 11 had been
'
invalidated, 136 had been closed, and 177 were still
inprocess.
__
,
* '
42
An evaluation by QA is then conducted to accomplish
the.following: (1) determine if the deficiency
report is valid, complete, and sufficient in detail
for the problem to be understood and resolved; (2)
assign responsibility for dispositioning with a
response-due date; (3) perform an analysis to
determine if the condition requires the initiation
of an NCR; and (4) transmit the deficiency report to
engineering for deportability review.
Dispositioning is accomplished by the assigned
organization, which evaluates the identified
deficiency and provides the cause of the deficiency,
action to correct the deficiency, action to preclude
recurrence, and a proposed implementation date. QA
then_ reviews the proposed disposition and concurs
before disposition activities proceed. When
disposition is complete, QA/QC verifies
implementation and that engineering review for
deportability (10 CFR Part 50.55(e) and Part 21) has
been performed.
(2) NRC Inspection
A review was conducted to determine if STA-404
adequately addressed the requirements of NEO 3.06.
The results were that STA-404 was consistent with
NEO 3.06 and provided adequate implementing
instructions. To verify implementation of STA-404,
the NRC inspector developed an inspection plan and
checklist which detailed the organizational
responsibilities and requirements identified in
STA-404. A sample of deficiency reports was
compared the checklist to determine if deficiency
reports were initiated, processed, and controlled as
prescribed. The sample selected was 43 of the 324
deficiency reports initiated since December 22,
1986, which included the 11 deficiency reports that
were invalidated, 14 closed deficiency reports, and
18 deficiency reports that were inprocess.
In developing the checklist, consideration was given
to the interface between operations, engineering,
and QA/QC. The scope of the inspection was
structured to include operations deficiency reports
initiated for installed plant equipment, inprocess
modifications, maintenance actions, and QA/QC
related functions.
, l !
_ ._. __ _ _ _ _ _ -
' '
43
>
(3) Inspection Results
(a) Initial Evaluation for Validity
The NRC inspector determined that the
preparer's manager and-QA/QC had reviewed the
43 deficiency reports for validity,
completeness, and that sufficient detail
existed in order for the identified problem to
be clearly understood and resolved. Of the 11
deficiency reports that were inspected which
had been invalidated, four were by the
preparer's manager and seven by QA/QC. The
invalid deficiency reports were found to have
adequate justifications to substantiate the
invalid dispositioning. The remaining 32 were
determined by the NRC to have been properly
evaluated as being valid with the required
detail to enable problem resolution; i.e., ,
'
determination if an NCR was required,
assignment of dispositioning responsibility,
and response due date.
(b) Comanche Peak Engineering (CPE) Review
During the inspection, the NRC determined that
each of the 14 closed deficiency reports were
submitted to and reviewed by CPE for
deportability under the provisions of 10 CFR
50.55(e) and 10 CFR Part 21. Each of the 18
inprocess deficiency reports were also found to k
have been submitted to engineering for l
reportabiljty review, as substantiated by filed I
three-part transmittal memos.
(c) Dispositioning
The NRC inspector found that dispositioning by
the assigned organization was provided for the
closed deficiency reports and for those ;
inprocess deficiency reports (11) that had i
already been dispositioned. Deficiency cause,
actions to correct, and actions to prevent l
recurrence appeared to be adequately
identified. Of the 11 dispositioned inprocess
deficiency reports, 7 had exceeded their
disposition completion date. NEO 3.06 requires
when dispositioning can not be completed by the
proposed date, "an extension shall be requested
by informing QA in writing that an extension is
required". Included in the request would be a
new date and a justification for the requested
p. m y - -
- - - - --- -
' '
Qw * M ; , J
_
'
~
(f >
'
s ,
,
,
[q
'
,
t,- .. 1 '
744-
-
s:- , .
- . extension. Forithese 11' inprocess deficiency:
?
e ; reports, nofextension requests were found.- The
' '
; iremaining seven inprocess-deficiency: reports
. b- weresnot dispositioned;Lhowever,'these:
~ deficiency reports' exceeded theidate:when:a
proposed? disposition was. required. .AsLwith the.
..
disposition complete dates,1NEO:3.06 re' quires
Lwritten' requests for proposed 1 disposition;date
,
,
' extensions.-
'Both of these conditions were: observed by the ,
; applicant during:airecent.TU Elec'tric QA audit.
-
;of theJoperations deficiency report program.:
e The audit was conducted;from MayL4 through^ July
6',- 1987, and'reportedjin audit. report
TUG-10-87. fat'present, the' applicant _is in'the
process /.ofiresolvingithe:identifiediconditions. .i
For both the closed and inprocess deficiency
reports which were dispositioned,agA reviews '
-and' concurrence were found'to have1been
adequately performad;and' documented.
(d) Disposition' Accomplishment'
Basedonthereview'oftbe14_closeddeficiency.
. reports,1the NRC determined.thatfQA/QC' verified.
_
disposition implementation, closed the
deficiency-report, and performed the required
. reviews for accuracy and completeness of
documentation.
t
.(e) Records and Deficiency' Report Tracking ;
Completed. records were found to have been
turned over to the operations permanent records
vault, as required. The Deficiency Report Log
was reviewed and found to contain the
appropriate entries for'both closed and-
inprocess deficiency reports.-
The computer Deficiency Status Report,'which
was used to account for and track deficiency !
reports, was examined. This report provided
the status of inprocess deficiency reports
including implementation dates for disposition
and engineering evaluation and days the
deficiency report has been open. A summary of
the Deficiency Status Report was found to.have l
been included in the monthly QA Status Report !
as required by STA-404. With respect to i
trending and corrective action, quarterly
reports were generated which trended deficiency
i
i
~
1
_ _ _ _ _ _ _ _
l
45
'
i.
reports and addressed the initiation of
corrective action requests.
'
In' summary, of the 324 deficiency reports (valid and
invalid) initiated since the implementation of NEO 3.06,
the NRC inspected 43 for conformance to requirements of
NEO 3.06 as implemented by STA-404. Based on this
inspection, the NRC determined that the applicant has
established and implemented a program to document,
process, and correct deficiencies for operations
activities at CPSES. The one error in implementation
identified by the NRC inspector during this inspection '!
had previously been identified by a TU Electric audit and
corrective actions had been initiated. No other
violations or deviations were identified.
b.- Construction Nonconformance Reporting
The documenting of nonconforming conditions in the-
construction area is controlled in two categories based
generally on equipment type: ASME (B&R) and non-ASME (TU i
Electric). While the two procedural processes are very
similar, this inspection was directed at the non-ASME
process and the management review and tracking activities
common to both ASME and non-ASME nonconformances.
The procedures controlling the activities'irspected
during this report period are:
CP-QP-16.0, " Reporting Construction Deficiencies,"
Revision 27
QI-QP-16.0-8, " Processing Construction Deficiencies,"
Revision 1
QI-QP-16.0-9, " Processing Programmatic Deficiency
Reports," Revision 1 ;
QI-QP-16.0-10, " Initiating and Processing Nonconformance l
Reports," Revision 1 i
l
These procedures were inspected and were found to j
incorporate the requirements of NEO 3.05 and NEO 3.06. !
The following is a brief description of the three
reporting processes: construction deficiency report
(CDR), deficiency report, and NCR.
.
'
While a CDR may be initiated by any individual noting a
potentially. nonconforming condition, the most frequent
initiators are QC inspectors. The initiator obtains a
CDR form and completes the upper portion of the form
which includes the item identification, its location, and ,
a complete description of the nonconforming condition.
The initiator then contacts the NCR Group (NCRG) and
_.
.
-,
w
*
I
w e'
L ,
'. 46
k L !
!
obtains the next sequential number and. enters it on the
! CDR form. The CDR form, thus completed, is sent to the
NCRG where it is reviewed by a QE for completeness, i
validity, assignment of action party, and distribution. l
'
Based on the QE's review, the approved CDR is sent to
construction management for disposition if: (1) the CDR ,
'
is valid, (2) the nonconforming condition can be
corrected by rework or replacement (scrap), andL(3) the
rework or replacement can be accomplished without
'
engineering involvement. If the QE believes the proper :
disposition of the CDR is use-as-is or repair, or if
construction management believes engineering involvement
is necessary to resolve the CDR, the QE closes the CDR by
transferring the documented condition to an NCR. If the
QE review of the CDR concludes that a nonconforming
condition does not exist, the CDR is voided and a
justification is documented. This action must be with
the concurrence of the,NCPG supervisor in which case the
voided CDR is returned"to the initiator.
Deficiency reports may be initiated-by QA, engineering,
or startup personnel when a programmatic deficiency is
apparent (this'is in contrast to a CDR which in most
cases relates to hardware problems). Therefore, during
the processing of CDRs and NCRs, the QEs may identify' 'r .
procedural or process deficiencies'that result in ?
deficiency reports being initiated in addition to or
> resulting from the disposition of a CDR or an NCR. Once
the deficiency report is initiated and validated by the
responsible department head, the NCRG numbers and logs
the deficiency report then sends the deficiency report to
the individual responsible for its disposition. Since
the deficiency report documents programmatic problems,
its disposition must include a determination of the cause
and actions to correct and prevent recurrence of the
deficiency. If the deficiency report is invalidated, the
NCRG supervisor must concur and the deficiency report is l
returned to the initiator.
An NCR may be initiated by QA, engineering, startup, or
subcontractor personnel when a condition is identified
that requires a repair, use-as-is, or engineering
involvement in its disposition. The initiator prepares
the upper portion of the NCR form which is then sent to i
the NCRG. If the NCR'is valid, it is approved, logged,
numbered, and sent to engineering for disposition. If
the NCR is deemed invalid, a copy is returned to the ,
initiator.
The following activities are common to the processing of
CDRs, deficiency reports, and NCRs:
__________-____-_____-_________L
wn , . .
.
.
'
--
_ - _ - _ - _ _ - - _ -
fyW , " *y~
.
@ W. , ,
, v w
>
< -
- m
b;7[ ,yl,'
,
S. , '47' ,
m p w
j '
,
3
3
,
E .R
I
-(1) Tracking -1 Separate handwritten 4 logs'are maintained' i
; %@ for each type report which providessunique numbers' '
"
and other brief. descriptive:information.
*
-(2)?istatus - Computer files are maintainedifor'each
l report and~the file--is-updated at eachastepnin.the
' , ,
process: by the NCRG; e.g. ,' at validation, Jwheni
disposition is'proposedh when!dispositionais: -
_
completed, etc. ,
,
n ,
(3)': Deportability TEA reviews each' report forp >
reportabilityc under 10 CFR Partr50.55('e).
s .i
' '
a.
(y4) . Verification - Prior'to the,closureJoffany. report' ,
10A/QC. physically verifies that the-documented
,
: disposition / actions have been? completed'.
. ,
ToLverify procedural implementation!and effectiveness,
, '
the NRC: inspector reviewed thefCDR,fdeficiency report,
~
, and NCR logs, the latter in detail. Fromfthe NCR-log, '
* 12'NCRs issued subsequent'to the NEO 3.05' effective-date'
were selected'~for; inspection. The resultsLof the NRC- l
:X , '[4' inspection of thesef12 NCRs and.related documents ~ '
i
,
.follows. '
.
aCC 87-66
The torque on.Hilti bolts on watertight doors was the
subject of-thistNCR. This NCR resulted:from'CDR 86-64CC. 1
The documents associated with this NCR were. inspected and.
#
no; process; discrepancies were identified by the.NRC
vinspector. N
CM 87-1058
'
ThisLNCR was-the result of CDR 87-1260-MC. Four items
'
'were identified on the NCR: Hilti bolts with.-unacceptable <
gaps.under the' nut, another with questionable:embedment, 'd
an undersized weld, and an excessive base metal reduction )
adjacent to a1 weld. These items concerned an HVAC
seismic support. Based on an' inspection of-supporting
documentation, this NCR appears to have been processed
properly; however, there is an apparent procedural
' '
. weakness. . QI-QP-16.0-10 states that NCRs shallLaddress t-
only specific nonconformances, not to be extended to
~
similar products or activities. The NCRG supervisor
interprets this statement as intended to-prevent generic
, NCRs. This is a reasonable-interpretation, but it leaves
. two questions unanswered that is typified by-this NCR:
- (1) when more than one item requires a disposition, the
dispositions may not all be the same category, and (2) if a
any, or all but one, of the items are deemed invalid, the
i
I
= = = - _ - _ _ -
. _ _
, f t
f .- 48
~
.
fact that at least one item is valid will prevent the
NCR, CDR, or deficiency report from being returned to the 1
initiator. While this NCR does not suffer from either of
these problems, further inspection of this matter is
necessary and will be considered an open item
(445/8716-0-05; 446/8713-0-04).
:
CM 87-2805
This NCR was transferred from CDR 87-3288-MC which
identified an NCR (M-86-104911) that had been
dispositioned'and closed but did not address the-
nonconforming condition. NCR M-86-104911 identified a
noncomplying beveled washer and a gap between the cable
tray and a clamp; the disposition, reviewed and approved
by a QE, was to grout the described support member. This -;
disposition does. not appear to relate to cn even address
the noted nonconforming condition. NCR CM 87-2805 was
initiated March 4, 1987, and essentially restates the
condition described in M-86-104911. The disposition of-
CM 87-2805, also reviewed and approved by a QE, simply
states craft to rework and QC to reinspect. As of this
inspection, the disposition has.not been completed nor
has any other' apparent action been taken. The NRC will ,
~
consider this item open until this NCR has been
'I
completed, at whict time the NRC inspector will inspect
this matter further (445/8716-0-06).
CM 87-4564
This NCR resulted from CDR 87-4488-MC-N-X, a finding
initially identified by the-CPRT concerning a broken o
cotter pin. Engineering invalidated the NCR on l
June 4, 1987,'and the NCRG supervisor approved the
completion of the NCR on July 2, 1987. On June 22, 1987, '
the procedure controlling NCR processing by engineering
(ECE 3.05) was revised prohibiting the invalidation of
NCRs, instead such dispositions were to be use-as-is with
a statement of explanation. The NRC inspector searched
for other examples of NCRs invalidated during the
transition phase of the procedure revision but found
none. Training records were reviewed which verified
engineering personnel were trained in the procedure
revision. While other NCRs similar to this one may
"
exist, none were found nor did the NRC inspector find any
other NCRs processed after June 22 that had been
invalidated. This occurrence appears to be very limited I
and perhaps confined to NCRs already in process when the
procedure was revised. No further NRC inspection of this
matter appears warranted or is planned.
,
!
j
<
e ,a- 49
4
!
h ~CE 87-5067
'
, L On' April 7,'1987, CDR 87-5438-EC was initiated stating .)
that 6.9kv switchgear was disassembled and reassembled !
'
without identifying parts as they were removed and:
without QC witnessing the proper. reassembly of-the parts
as required by instructions.on-the traveler.- On April-8,
the CDR was closed by transferring:the concern.to
deficiency report.C87-1783 for the: programmatic
' deficiency and NCR CE 87-5067 for:the potential hardware
deficiency'(mixing of parts.during reassembly). The NCR
was closed based.on engineering's statement.that no '
engineering documents were violated; thus, no
nonconforming condition existed.
Ths basis usedJto support' engineering's closure of this
NCR was that the traveler was more restrictive than the
specification and that QC did witness.all or part af the ,
activities in question. In effect, engineering w ts
voiding this NCR which-was permitted by procedure unt!.1
the June 22,.1987, revision.to ECE 3.05. The NRC;
inspector found the disposition of this NCR (closed on
April 21, 1987) to-be proper and the same as a use-as-is
disposition.
Deficiency report C87-1783 was closed on August 27, 1987;
however, the disposition appears questionable. The cause
of the deficiency was stated as being a misinterpretation i
of'the traveler, but no action was taken to correct or
prevent recurrence of this apparent programmatic
deficiency. A further review of the associated !'
documentation for this item by the NRC inspector l.
identified CDR 87-7101-EC which also questioned the
disposition of-deficiency report C87-1783. .CDR
87-7101-EC was transferred to a new deficiency report
(C87-2446) on May 22, 1987. Disposition of deficiency
report C87-2446 was due on August 17,1987, but had not
been made by the close of this inspection. Review of the
disposition of this deficiency report is considered to.be ;
i
an open item (446/8713-0-05).
CM 87-6385
This NCR was initiated April 30, 1987, and documented
three cable tray hanger problems identified on inspection l
report (IR) ME-1-91659, which required engineering i
'
disposition. The problems were: (1) a gap at the
support, (2) a gap between the cable tray and the clamp,
and (3) improper use of a beveled washer. The
engineering disposition, given on May 20, 1987, was to
rework each in accordance with the applicable procedure
and QC to reinspect. All actions appear proper, but this
- _ _ - - _ _ _ _ _ _ .
_ _ _ _ _
__-____-
>
o
y
,
. .
50
)
59
NCR is another example of the open item noted earlier
(445/8716-o-05; 446/8713-0-04).
CE 87-665A
This NCR resulted from CDR 87-6629-EC, which identified
six cables with unacceptable damage to their insulation.
The engineering disposition was to rework the cables and
six irs were generated. .The work was completed on June
19, 1987. The disposition was verified by QA/QC. The
NCR was closed on July 27, 1987. All CDR and NCR
activities were consistent with the controlling
procedures.
CE 87-6936
This NCR was written because of an error in processing an
earlier NCR. The NRC inspector obtained copies of the
earlier NCR (CE 87-5172, Revisions 0 and 1), which was
issued as a result of CDRs 87-5594-EC and 87-5595-EC. CE
87-5172 was issued because the nitrogen used to
{
,
w? pressurize and tent 46 EPAs could not be verified to meet
specification requirements. Revision 1 to CE 87-5172 was
issued to delete one EPA and add another from the
original list of affected EPAs; however, in transcribing
the EPA numbers, the 'QE inadvertently lef t one EPA off
the Revision 1 list. This error resulted in the issuance
of NCR CE 87-6936 on May 15, 1987, which added the
omitted EPA to the work activity, but did not address the
deficiency in the process that permitted this error. On
July 1, 1987, CDR 87-8283-EC was issued listing five
process and documentation errors associated with the NCRs
identified above (CE 87-5172 and CE 87-6936). This CDR
was transferred to DR C87-2922 which proposed a
disposition that would be completed by November 30, 1987.
The disposition, though net yet complete, proposed
< correcting the documentation errors, but did not indicate
any actions associated with preventing recurrence.
On July 27, 1987, another CDR (C87-8861-EC) was initiated
relative to NCR CE 87-5172, Revision 1, wherein an IR was l
issued for work on an EPA that referenced CE 87-5172, but
the EPA is.not listed on the NCR. This process or
documentation error was transferred to deficiency report
C87-3172, which is awaiting disposition.
While reviewing the EPA document package, the NRC
,
inspector noted two other CDRs. These CDRs, 87-7336-EC
(transferred to deficiency report C87-2660) and 87-7780,
were inspected.further by the NRC inspector.
t'
mm___ _ - - _ _
_
!
<
- *
51
i
i
Deficiency report C87-2660 identified a drawing (El-0507) i
that did not depict the current EPA function and
locations. DCA 46588 has been proposed to correct this
problem which engineering has determined is a l
documentation problem only; i.e., El-0507 was'not )
intended to show location and function of EpAs, since !
drawing El-0511 provides this information. The )
disposition of this deficiency report (C87-2660)'does not ;
;
propose any preventive action, but the disposition has
not been approved as yet. !
CDR 87-7780, identifying six NCR/CDR processing problems,
was initiated on June 18, 1987, but had not been approved
or dispositioned by the close of this inspection.
In summary, the NRC review of NCR CE 87-6936 and related
CDRs and deficiency reports noted several nonconforming
conditions with specific hardware, all of which have been
properly. corrected. In addition, several potential i
programmatic or processing items were noted that are
~
awaiting disposition. These are documented on deficiency v
reports C87-2922, C87-3172, and C87-2560 and CDR 87-7780.
Review of the processing and dispo"Acion of these
documents is considered an open item (445/8716-0-07;
446/8713-0-06).
CM 87-7401-X q
This NCR was transferred from CDR 87-6864-MC-X, listing
items identified by the CPRT inspection affort. The NCR
'
identified five potentially nonconforming conditions.
While the NCR is still inprocess, it has been handled in
accordance with procedures thus far. It is, however, a
further example of a previously identified open item
concerning multiple problems documented on a single NCR
(445/8716-0-05; 446/8713-o-04).
CE 87-7763
This NCR, dispositioned use-as-is, was transferred from
CDR 87-7421-EC, which identified various pieces of carbon
steel being used on EPAs. The problem described on the
CDR referenced a previous NCRO(CE 87-249) which required
the replacement of carbon steel lock washers with '
stainless steel washers because of the potential for
corrosion. The justification for the use-as-is
disposition was that further evaluation of the atmosphere
and environmental conditions had determined that the
affected EPAs would not be subject to a corrosive
atmosphere. The NRC inspector reviewed these further
evaluations and discussed the results with the
responsible engineer. The results of the evaluation were
! l . _ _ _ _ _ _ - . _ .
___________________________._______j
~
s ., -
'
/ 3 '
,.f,
.
9 4 + i
N & -j[
'. r
y -' ~p x
;c :.. ,;
, <
T52
,
,
W >
,
I j ,
ifoundedLon1the design' basis for inside. containment:which;
under-'normalLeonditions requires a,noncondensing;
* <
. atmosphere,Jor dry _airienvironment, usually less than: 70 0
T- relative humidityi 'The NRC inspector agrees with this-
,
_ assessment' based oniaireview of,the applicable: documents,
'which: included the'FSAR. design' bases and the corrosion'
specialist'sl evaluation.
CE 87-7984
'
'
.During;the-NRC inspector's review of the-NCR.logh .,
CE 87-79841wasinoted:to.have been entered on June: 12 ,'
1987, but no other-information was given. 1The NRC.
3: inspector-requested the' status'and" location of theLNCR.
'.AfterLaltime, the QE advised
evidence.could-be'found the NRC inspector
that wouldfindicate thatwas-
theLNCR no
~evertissued, except for the' partial log; entry.- No other
such occurrence was noted in anyof; the logs. . This
appes;s.to have-been an isolated occurrence; however,
thisLitem will besheld open for,further inspection ~
:(445/8716-o-08; 446/8713-0-07.).: >
CE 87-8979'. '
This NCR concerns the welds on jackshafts for the 6.9kV
circuit breakers that had:been-returned to'the vendor int
repair. 'This problem had its beginning'in January 1986..
when the wold on a jackshaft failed due principally to
~
lack of fusion. .As;a consequence,;all.jackshafts from-
this vendor (BBC, Brown Boveri, Inc.) for 6;9kV circuit
breakers were returned for repair. The' repair 1i nvolved 'j~
rewelding, but used weld acceptance criteria less.
stringent than the drawing, requirements.t This. relaxation
of weld 1 criteria was based cn1 a 10,000' cycle test-
performed on a pair (left hand-and right' hand) of
jackshafts returned from the site, but before weld' repair
was performed. On the. basis of the foregoing and
'
inspection of each repaired jackshaft by vendor and-
applicant personnel before return..to the site, CE 87-8979
was dispositioned use-as-is. The NRC inspector: reviewed
the 10,000 cycle test results, the applicant's vendor
inspection trip report, the revised weld acceptance'
criteria, and the quality assurance release form for
returning the jackshafts to the site. . The NRC inspector
~
requested the QC inspection records and the tested-
a jackshafts for future inspection (445/8716-0-09; l' 446/8713-O-08). The NRC inspector then inspected ~the L repaired jackshafts being reinstalled in the 6.9kv L circuit breakers. About 12 items were visually inspected ,
and 5 were inspected using a Fiber Metal products weld 1
fillet gage. One of these five (#273) was found to j'
violate the revised weld criteria even though all
1
1
- - - - - - -
.
y7
T e,
.
[L j >
! y . , . . .< < j '.. '
< '
g 45 3 l
L
;
/ %<
1; x. . ,
7 ljackshafts had been inspected by both. vendor and'
' :e,pplicant personnel (445/871F-V-10; 446/ 8 713-V-09 ) .
,
'^ The applicant wasLadvised'of the'NRC's finding and NCR pE
87-90600 was ic%e,iated on September 2, 1987 t Further-
,'
inspection by the applicant has identified other .
;.
'
jackshafts that fail j to meet the revised. criteria. The
y*
,
NRC'will inspect this matter further in'c#nnection with \ '
I
the identified violation. ' ' ll N ; <
q
The foregoing inspection of the construction nonconformance '
.i reporting process did not. identify any signi'ficant problems
with NCR processing, even though one violation regarding
vendor inspections was ident$fi.ed. A number of open items do ;
remain that require further'NRC inspection.
. 7. : plant Tours
The NRC inspectors made frequent tours of.the Unit 1, Unit 2,
5 and. common areas of the facility to observ'e items such as
'. housekeeping, equipment protec tion, and in-process' work
activities. The follcaing items of significance were
,
observed:
a. Valve Operator Test ___(51053)
On August 11, 1987, the NRC inspector witnessed an
acceptable stroke test (opening and closing) of a motor
operated valve (MOV). The valve (MOV 1-8806) was the .
refueling ~ water storage tank to the suction of the safety j
injection pump isolation valve for Train B. This 6" gate / "!
valve was positioned by a Limitorque, Type SB, Size 00
valve operator. An inspection by NRC of finternal wiring'
'
of the valve cperator disclosed no problems with bend R
,
radiij. terminal lugs, or conductor identification. ]
The NRC inspector did note the existence of two cap-type
wire splices on what appeared to be vendor installed
conductors. A review of the W.o. C86-7445 package o
disclosed that it had been issued to conduct an equipment )
-qualification (EQ) walkdown. The checklist for this j
walkdown specifically listed splices as an attribute to l
a :be ahecked. Further review of the W.O. package revealed I
!
f' two' ;nmper wires had heen replaced due to the lack of
'h1 identification information on the previcvsly installed a
'
jumpers; i.e., conductor and insulation type and )
manufacturer information was not visible. The !
replacement of these jumpers was documented on an IR form !
(No. Ip 031-135) which was included in the W.O. package. l
1
No violations or deviations were idyntified.
I
!
,
1 1
1
___.
7_
l
. ..
54
b. Valve Leakoff Piping (49055) <
On August 17, 1987, the NRC inspector obserYed tilat the
leakoff piping from. three valves located in ' Room i92 of ,
the Unit 2 safeguards building was routed tothe idoor
-
drain. Since one of the valves was the reactor boolant
letdownheatexchangertemperaturecontrol3alve,\ ,the ;
leakoff would be radioactive. (The leakoff connection is
'
4 '
designed to direct any valve stem leakage to a
radioactive water collection facility.) The NRC
inspector checked the Unit 1, Room 92, and observed the )
same configuration. Unit 1 and Unit 2 are mirrcq images l
and should be the same if the installation is acfeptable.
A review of the FSAR showed that,the floor draiv in-
Room 92 was directed to Floor Drain Sump No. 1 is the
respective unit (Figure 9.3-6) which is a radioactive
liquid collection point. Since the possible radioactive
leakoff liquids will be' properly collected for each unit,
the NRC inspector had no further quer,tions. <
No violations or deviations were identified.
)
c. Electrical Penetration Assembly (EPA) (51053) ;
( !
On August 18, 1987, the NRC inspector witnessed the i
ferrule removal from EPA 2E-60; medule A. A description ;
of the need for and methods used t'or ferrule removal is .
contained in paragraph 2.b of NEC, Inspection Report j
50-445/87-03; 50-446/87-03 for EPA 1E-09. The NRC j
inspector observed that procedures were followed and
verified that the EPA body war-not damaged during the
ferrule removal process. i
i 9
8. Corrective Action Program (CAP) /
The NRC inspectors have begun the verification of the
applicant activities associated with,the CAP. In an effort to
consolidate the inspection efforts related to the CAP, the
associated inputs will be included in a single paragraph in .
this, and subsequent, inspection reports. Previous NRC 1
inspection activities related to the CAP were documented in j
paragraphs 6 and 7 of NRC Inspecticn Report 50-445/87-11; ;
50-446/87-09. ;
The following NRC inspection activiti'es related to the CAP
were conducted during this report perj;od:
a. Electrical (51063)
The NRC inspector reviewed the field verification methods >
(FVM) procedure for the electrical conduit sleeves,
FVM-EE-023, " Instructions to Acquiro bata for Cable
Y_-___-_-_________-___
_.
._ _ _ _ __ _ _ _ _
'
, I;
,
,
'
-
,,
'
# h _55
~
1
Percent-Fill Calculations:and. Identification'of
'
Thru-Floor and:Thru-Wall Embedded Conduit Sleeves."' The 1
< ' procedure provided informationiand sample data collection-
-
l
6 ' sheets to.indicatenthe type of data,that must be
collected'so that an accurate calculation can be made'of
the percentage of cable fill ~which exists in various
. thru-wall'(TWS).and.thru-floor.(TFS) conduit sleeves.
Basically, the number of each. type of' electrical cable.
~
-v through each sleeve must be recorded so.that the' 1
di . cross-sectional an a of the cable fill, can be determined. H
SWEC had~ completed'their walkdowns and-the collected data:
~
i
,7
was being used.to calculate lthe percent fill'of the TWS
and TFS.~
.t-
The NRC inspector-selected:a sample of three walkdown.
j ' O' i der packages to verify?the accuracy of the collected data.
6
' .$jf The results were: -{
y , ,- *
-j
Areq;133' p 1
4 This.ahaa ce prised the' north wall of the 807': floor
>" elevatidn of the.' electrical and control building.between I
frames,B-A and C-A which is the~ wall;between-the Unit 1 l
. < , ~ andLUnit 2 cable spreading rooms.- The 39 TWS were. j
j
~
jjk '
, depicted'on' Bisco: seal map Drawing EC807-133-2.- of the.
- 39' penetrations shown-on this drawing, only 162were: ,
?
, accessible without having some. scaffolding erected; all.
'" t 'of[theaccessibleTWSwereeitherconnecteddirectlyto
conduit'or were. unused spares. The NRC inspector did J
1 ,[.# ./ n6te'that one of the spare TWS was-opened and had-two- .l
.j
~
.p,, temporary cables pulled through. The inspector agreed
g
-
with the SWEC findings'for this area. l
q
Area 180 l
This area comprised the east wall of the 790' elevation ;
of the Unit 2 side of-the auxiliary building as depicted I
# on Bisco seal map Drawing AD-790-180-12. There were i
43 penetrations shown on this map; of these, 12 were not
electrical (i.e., piping) and 18 were unused spares.
The NRC inspector verified the acc'uracy of the collected
data for 10 of the 13 TWS by inspection from the west ,
side of the wall because of access limitations. The I
remaining three-5" TWS were too full to perform an
accurate., count of each-type of cable without opening the
y)
.
. ; cable hundles;1 however, the figures for the total number
A of cables' through these sleeves appeared appropriate to 1
.. the inspector (i.e., 49 through 4037, 45 through 4038,
4 and 51 through 4039). The NRC inspector also noted that
two incorrect listings were made on the data sheets. l
l
!
a
l . s
a-__--_ .
,__-- ,
!
- '
56
,
i
.Both-of these errors were related to the first
description code digit..
I
The first digit indicates the color and therefore, the j
service of the cable (e.g., 1-orange, Train A; 2-green,
Train B). The error involved identifying cables as W-113
indicating orange colored, 2/0 AWG Triplex, when, in
fact, the cable was. black and; therefore, should have ;
been designated W-013. However, the conductor size was ;
correctly listed'as 13, so the percent fill data was
correct.
]
j
Area 226
,- This area comprised the Unit 1 half of.the 832' elevation 3
'
floor of the auxiliary building. The NRC inspector
verified the accuracy of the data for 9 of the
10 safety-related cable TFS and verified the accuracy of
the other TFS indicated on the Bisco seal map drawing
(AB-B31-226-1) used as the guidance for this area. The
inspector noted that the majority of the TFS in this area
were for nonsafety-related (Train C) cables. The NRC
inspector's data agreed with the SWEC data. l
No violations or deviations were identified.
b. Large Bore Pipe Supports (50090)
s
The applicant is currently involved with implementation
of the Post Construction Hardware Validation Program
(PCHVP) which was established due to revision of CPSES
installation design requirements. The Large Bore Pipe
Support CAP of the PCHVP is being implemented to assure
that the pipe support hardware meets the validated design '
requirements. SWEC will perform a detailed engineering
analysis of each individual safety-related pipe support ,
design and identify any modifications required. !
Construction and QC activities will be performed under {
the B&R ASME QA Program. TU Electric Procedure CPSP-12, l
"As-Built Verification," will provide verification of j
as-built configuration of piping and pipe supports in I
accordance with the applicants response to NRC IE
Bulletin 79-14. TU Electric Procedure CPPP-22, l
" Clearance Walkdown," has been developed to provide l
assurance that pipe supports permit the piping systems to
move within their maximum displacement in each of the
i three orthogonal directions as a result of dynamic forces j
and thermal effects.
[
The Large Bore Pipe Support CAP indexes all engineering
l
and QC procedures required for implementation. The NRC
! inspector has performed a preliminary review of these l
l
L l _ ._____________a
__ ,
, , 57-
procedures and will continue'to reOiew and evaluate their
- adequacy during future inspections. The implementing
procedures were reviewed to determine whether:
i
. means have been established to verify that any j
significant design and field changes from approved {'
' drawings are adequately controlled and processed
commensurate with the original design control
activities. j
. means have been established to ensure that quality
requirements are met.
. procedures and instructions pertaining to pipe !
supports and restraints have been reviewed and !
approved.
Previous NRC inspections of pipe supports which have been {
completed by construction and field accepted by QC under l
the PCHVP were documented in NRC Inspection Report l
50-445/87-11; 50-446/87-09.
The NRC inspector performed inspections of inprocess work i
activities on the following pipe supports: ;
CT-1-053-445-C62R
DO-1-DG-044-011-5 l
DO-1-099-700-S53R 1
DO-1-067-708-S53R 1
1
Items verified were control of welding-electrodes,
installation of concrete expansion anchors, accuracy of
inprocess QC dimensional inspections, welding quality, i
and compliance with work package instructions. Craft i
personnel were interviewed to determine knowledge of l
procedures and compliance with work instructions. While l
I
the NRC inspectors were interviewing craftsmen performing
work on pipe support DO-1-067-708-SS3R, and prior to.the
inspector's review of the associated work package, a QC
inspector arrived and reviewed the work package. Upon
completion of the QC review, work was stopped due to a QC
hold point on a repair process sheet being bypassed by
the craftsmen. NCR 87-A00491, Revision 1, was initiated. l
This finding is an open item pending review of the I
applicant's NCR disposition and processing
(445/8716-O-11). l
The NRC inspectors performed a documentation review and
field installation inspection of the following pipe
l supports, which were construction complete and accepted
by QC, to determine whether the applicant is adequately
l
L ____m_._.-_-.__
.
._ - - _ . _ . _
_- _. . _ _ _ _ _ _ . . _ - .
% i
: ... 58
,
preparing,' reviewing, and maintaining a system of quality l
'
'
records: l
Support Drawing No. Pipe Isometric No.
.CC-1-226-002-C53R, R/1- .CC-1-RB-020A
- CS-1-158-022-S42R, CP-1 'CS-1-SB-060
CS-1-239-005'-A42R, R/5 CS-1-AB-03
-CC-1-043-010-A43K,.R/7 CC-1-AB-002
SI-1-044-029-S32R, R/S SI-1-SB-012.
CC-X-027-010-A43R, R/6 CC-X-AB-013
CC-1-007-026-A43K, R/4 CC-1-AB-030
CS-1-110-002-A42R, R/5 CS-1-AB-004
CC-1-155-003-S53R, R/4 CC-1~-SB-012 ;
CH-1-204-713-E33R, R/3 CH-1-EC-003A.
CS-1-251-022-S53R, CP-1 CS-1-SB-023 ,
.CC-1-173-010-S53R, R/4 CC-1-SB-033 1
CT-1-001-002-S22K, CP-1 CT-1-SB-012 3
AF-1-002-710-S33R- CP-1
, AF-1SB-002~
.CH-1-249-005-S43R,-R/2 CH-1-SB-013
.CC-1-043-020-A43K, R/4 CC-1-AB-004
CS-1-319-002-S53R, CP-1 CS-1-SB-012A-
:DO-1-067-709-S53R, R/3 DO-1-DG-021
AF-1-101-003-S33R, R/3- AF-1-SB-020 i
RH-1-014-007-532S, CP-2 RH-1-SB-014 .
AF-1-109-003-S63K, R/3 AF-1-SB-29B i
SF-X-007-011-F43, R/3 SF-X-FB-017B l
CC-1-295-006-C53R, R/4 CC-1-RB-041
'
i NRC inspection of pipe support CC-1-295-006-C53R on
. August 21, 1987, identified that the sway strut rear
.
bracket load pin.did not have a cotter pin installed on
eitherLside of the sway strut rear bracket. TU Electric
CAR-65, in-response to a'CPRT identified deficiency,
required QC verification of the proper installation of
cotter pins and that QC procedures be revised to include
QC verification of cotter pins and snap rings when
removal and reinstallation are required. The failure of
the required corrective action to assure that
configuration control is maintained is a violation
(445/o716-V-12).
.c. Small Bore Pipe Supports (50090) '
1
The applicant is currently involved with implementation
of the PCHVP which was established due to revision of
CPSES installation design requirements. The Small Bore
Pipe Support CAP of the PCHVP is'being implemented to
assure that the pipe support hardware meets the validated
design requirements. Implementation will be performed in ,
conjunction with the Large Bore Pipe Support CAP by SWEC l
and B&R using the same engineering and QC procedures. l
1
4
i
L_._---______...-__.__ . . - _ _ __
WX4 . ,
-
q w
-
-
-
T , , m
k? , , fA .
'> r '
.r,, > - m 9,
.p .
r ,
"
'
.
,N 7,. -
59
s >
on
' '
' :1
' '
'See' paragraphf 8.b"forfdetails)of'NRC. inspection-off
implementing procedures-
,e
'
cThe'-NRC. inspectors; performed aidocumentation'. review and?
4 : field? installation inspection 3of the following pipe
-
supportsLto determine whetherLthe applicant is; adequately-
J preparing,~ reviewing, and maintaining a' system of quality
'
-*
records:
-
Support Drawing'No.- Pipe Icometric No.-
E
V , le > CS-1-112-714-C41R,'R/1 CS-1-RB -0 2 8 '
CC-1-RB-008-002-3,:R/1 ~Cr-1-RB-008
>
CS-1-105-701-C41S, R/2 ": -1-RB-031B
,. -CT-1-SB-035-002-2, R/3- CT-1-SB-035
No' violations or deviations were' identified.
f
'
a < ~d. Conduit supports A & B Train and C Train'>2" (48053)
This PCHVP Was. instituted to-field walkdown and analyze
1
thefsafety-related conduits / supports.(trains"A;& B) and '
nonsafety-relatedLconduits/ supports (train C). greater ~ >
than 2". This'is for Units 1 & 2 conduit contained-
within. Unit 1 and common areas. EBASCO has.been
contracted by'TU. Electric to. implement lthis program. .Thei
~
' scope of this.NRC inspection. involves. assessing the-
U^- adequacy of the EBASCO implementation ofEthe' appropriate
FVMs when performing the walkdowns. At:the present time,-
'EBASCO.has1 completed approximately_'3800 conduit runs out
of the 67001 contained within their scope'of activities
forLthis PCHVP.-
-The NRC inspector reviewed the-following FVM procedures:
procedure Number Title
CPE-EB-FVM-CS-014, R5 Design Control of
Electrical Conduit Raceways
for Unit 2 Installation in- "
.
. Unit 1 and Common Areas
CPE-FVM-CS-033, R1 Design 1 Control of
Electrical Conduit Raceways
-for Unit 1 and Common" Areas
CPE-FVM-CS-056, R0 Design' Control and
I.
As-Built Data Collection of
Electrical Conduit' Raceways ]
b-
for Unit 1 and Common Areas-
. v.
'
l.
> 'I
b l o ' L _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
--
.s-,
y
, . 60
These Inn 4 procedures established the methods and sequence i
'
by which the data collection for the applicable
conduits / supports field verification was to be performed
and documented. They provided, among other things, the j
criteria, inspection attributes,.and tolerances that the
field walkdown engineers should adhere to when 4
'
implementing this PCHVP. The documentation of the
collected data from the individual field walkdowns is to
be in the form of newly generated isometric drawings of i'
the conduit runs and red line marked drawings of the
appropriate conduit supports.
The NRC inspector, for this inspection period, selected a !
sample of 13 completed conduit walkdown packages to
verify the accuracy and correctness of the EBASCO
collected data. The following is a list of the NRC
inspected packages: j
Conduit Number Size Room * Area ** Number of
Supports 1
1
C13011026 3/4" 161A RB1 2 )
C14W13101 2" 154 RB1 9 i
C14W30916 1 1/2" 154/155A RB1 5 ;
C12K04629 3" 103 SG1 9 !
C13G08636 1 1/2" 88 SG1 5
C13010190 3/4" 70 SG1 2
C14G20043 1" 109 SG1 3
C14021197 1" 70 SG1 4
C03G05670 5" 133 ECB 2 !
C12K03128 5" 146 ECB 1
C13G07049 3" 133 ECB 3 l
C14K15522 4" 133 ECB 2 l
C16B10045 4" 135 ECB 3 ;
*ECB - Electrical / Control Building
RB1 - Unit 1 Reactor Building
SG1 - Unit 1 Safeguards
** Number of supports includes conduit, junction box, and
pull box supports.
The NRC inspector's walkdowns were performed while
adhering to the criteria of the appropriate FVM. Even Il
though certain data recorded by the NRC inspector may not
have matched that recorded by the EBASCO field walkdown
engineer, it was deemed to be acceptable since the
difference in recorded dimensions was still within the ;
tolerances specified in the applicable FVM. Based upon u
I this, no discrepancies from the FVM criteria were
identified.
i
_
- -
- _ . _
- _
- =_ _. . _ - _ _ .
_
s .- 61
.
No vtolations or deviations were identified.'
~
c. Conduit Supports c' Train less'than or equal'to 2" (48053)
.
This.PCHVP involves a= multi-level screening process.of
Train C. conduit (2" diameter and under) systems for CPSES 1
Unit 1, Unit.2, and common areas. The' Train C conduit o
systems are those classified:as-nonsafety-related-
-including the rec 1'assified'nonsafety-related; lighting-
-systems which were initially classified'as-
safety-related. Though these. conduits are
nonsafety-related, the-screening process is necessary to
assess what'effect it would have oniother. safety-related
equipment / components during a seismic event. Impell has
, been contracted by TU Electric.to' implement this PCHVP.
The scope of this NRC-inspection will involve assessing
the adequacy of.the Impell' implementation of the
appropriate FVM and' project instructions (PIs). It
includes, but'is not limited to, determining the level of-
. screening required and the accuracy and correctness of ,
'
field walkdowns, reviewing engineering calculations
-required to analyze the structural integrity of the
conduits and supports, and performing a final room
walkdown to ascertain whether any Train C conduit
contained within the Impell scope had been inadvertently
.omitted from their screening process. At the present
time,JImpell has walked down, reviewed, and closed out-
approximately 160 out of the 240' rooms within the Unit 1
and common area scope.
The NRC inspector reviewed the following FVM and Impell
PI procedures: ;
Procedure Number Procedure Title
ECE 9.04-03, R0 Post Construction Hardware
Validation Program
Implementation Plan-Impell
Corporation
CPE-IM-FVM-CS-095, R0 Train C Conduit Program l
PI-0210-052-003 Seismic Evaluation of
Train C Conduit Supports
PI-0210-052-004 Train C As-Built Walkdown
PI-0210-052-005 Procedures for Implementing
Screen Level 6 ,
PI-0210-053-001 Multi-Level Screening
i
.
-. , . _ _
,. . _ _ . _ _ .
a.
-
'
-
,
. .. ,
'62
Criteria'for Train C
Conduit (two-inch andJ
under)'at'CPSES
4'
"PI-0210-052-002 Level Four Screening.
Criteria for: Conduit
(two-inch and-under)'_at
-
-
CPSES
PI-0210-053-003 Level Four Screening
Criteria for Type'2.
Supports, Train C'(two-inch
and under) at CPSES-
PI-0210-053-007 Level Four Screening
Criteria for Type 7-S-17
Supports, Train _C~Two-Inch
and under (including
reclassified lightire
systems
The FVM and Impell PI procedures establish the types of
screening-processes to'be utilized by<the_Impell field.
walkdown engineers and how they are.to-be implemented.
They provided, among other: things,Jthe criteria,
inspection attributes, and tolerances'that the field
walkdown. engineers.should adhere to when implementing the-
various' screening levels contained'within this PCHVP.
From.this collected data, the engineering evaluations'of
the conduits-and supports, if necessary, are performed.
-
.The NRC inspector chose to perform a review /walkdown of'
the total scope of Impell's work for Room 206'in the
Unit 1. safeguards building. :This was to verify the
accuracy of the data Impell collected during their
walkdowns and the appropriateness of the engineering
calculations. The Impell-work entailed. Level 5 support
walkdowns and engineering evaluations, Level 4 and'
Level.2 evaluations, and conduit support modifications.
The following calculation /walkdown packages relevant to
Room'206 were reviewed by the NRC inspector during this
Linspection period:
..
I i
.
_ - -
,
. .- 63
'
I
Calculation Number Title l
l
L4-S-1-AUX-206 Level 4 - Conduit Support l'
Evaluation
A-01828* Level 5 Support Evaluation
A-02846* Level 5 Support Evaluation ,
A-02854*
i
Level'5 Support Evaluation
A-02914* Level 5 Support Evaluation
A-02932* Level 5 Support Evaluation ;
A-02974* Level 5 Support Evaluation
L2-S-1-AUX-206 Level 2 Conduit Support '
Evaluation
0210-C14K17440-01* Train C Conduit Support
Modification '
0210-C14K17440-02* Train C Conduit Support
Modification
0210-CKTS-01* Train C Conduit support ;
Modification
0210-CRT5-01* Train C Conduit Support '
Modification
0210-HT-09A-01* Train C Conduit Support ,
Modification j
0210-AB3-14-01* Train C Conduit Support
Modification
* Denotes those packages where field walkdowns and
engineering calculations were required. f
The NRC inspector's review included verifying the Impell
I
field walkdowns to the actual as-installed conditions and
the criteria of the appropriate PI and, where applicable, l
a thorough review of the engineering calculations for the I
relevance of the methods of analysis used, correctness !
'
and accuracy of the calculations, and the adequacy of the
correlation between the field collected data and the
analyses themselves. No discrepant conditions were
identified by the NRC inspector during the review of the
above listed calculation packages.
To complete the assessment of the Impell screening
process for Room 206, the NRC inspector must finish
performing field walkdowns and the engineering
calculations review on-three additional Level 5 support
evaluation packages. In addition, a final walkdown of
the coom will be performed to determine if any Train C
condtit had been inadvertently omitted from the Impell
review. This is to be completed in a subsequent
inspection period.
No violations or deviations were identified.
I
_________ _ __ . _ .
j
_ _ _ - _ __ _
, . 64
9. Significant Meetings (50100)
On August'27,'1987, representatives of TU-Electric, SWEC and
Ebasco Services, Inc., met with the NRC site staff to discuss
a-proposed program dealing with the visual inspection of a
sample of. welds both in the coated condition and after removal
of the coating. The objective of the program is to provide
additional assurance that previously visually inspected and
accepted welds _do not contain defects of a type which could be
masked by the application of coatings.
Eleven representative groups from which the samples are to be
selected have been tentatively identified for this program.
The criteria used for establishing the groups are as follows:
. Welding process
. Base material
. Code or specification
. Contractor performing the work
Group 1 consists of carbon steel structural type supports;
i.e., most cable tray supports, instrumentation supports,
conduit supports, and the supporting structures of pipe whip
restraints, welded by B&R using the shielded metal arc process
(SMAW) to the AWS D1.1 code.
Group 2 consists of ASME Section III, Subsection NF, carbon
steel component supports welded by B&R using SMAW.
-Group 3 consists of.ASME Section III carbon steel piping
welded by B&R using the gas tungsten arc welding process.
Group 4 consists of ASME Section III carbon steel piping
welded by B&R using SMAW.
Group 5 consists of gage steel; i.e., cable trays welded by
B&R using SMAW to AWS Dl.1.
Group 6 consists of HVAC duct support structural welds.
Group 7 consists of HVAC structural steel to sheet metal >
>-
1/16".
- Group 8 consists of HVAC structural steel to sheet metal <
1/16". I
Group 9 consists of HVAC duct work sheet metal welds.
i
!
1
_ _
E !
, - 65
i
Group 10 consists of welds in HVAC air handling equipment,
plenums, and equipment supports, except for flare bevel groove
welds.
Group 11 consists of flare bevel groove welds in HVAC air
handling equipment, plenums and equipment supports.
Additional details of the program are being developed'and will
be presented-to the NRC staff subsequent to this inspection
period.
10. Site Design Reviews
During the week of August 10-14, 1987, D. Terao of OSP-HQ
staff and NRC consultants from Teledyne Engineering Services
(TES) performed audits of the as-building process used for
HVAC, piping and pipe supports, and Train C conduit supports ]
(less than or equal to 2" diameter) at CPSES.
For HVAC, D. Terao and TES consultants R. Wray and R. Rose
performed-an audit of the as-building process and program
applicants to HVAC ducts and duct hangers. The audit
performed by D. Terao and TES consultants R. Hookway and ] :
D. Messinger of the as-building process for piping and pipe i
supports (less than or equal to 2" diameter), D. Terao and TES
consultants J. Flaherty and E. Solla reviewed project
instructions for multi-level screening criteria, as-building i
'
and acceptance criteria, and the program for auxiliary
building Room 206. A field walk down of Room 206 was also
performed. j
i
The purpose of the reviews was to ensure that the as-building I
criteria included all important attributes needed by !
Corrective Action Program contractors to adequately perform j
their design verification activities. Staff findings will be ;
included in a supplement to the CPSES Safety Evaluation Report i
upon completion of staff audits. )
11. Open Items
i
Open items are matters which have been discussed with the i
licensee, which will be reviewed further by the inspector, and i
which involve some action on the part of the NRC or licensee I
or both. Open items disclosed during the inspection are
discussed in paragraphs 4.b (two items), 6.b (six items), and
8.b (one item). !
l
I
__ _____ __- - a
. - - _ _ _ - __
%
4
4
. if y . . 66
4
.\' . p
12 '. Exit ~ Interview (30703)
- An exit interview-was conducted onJSeptember 2, 1987, with.the
applicant'sl representatives identified in paragraph 1 of this
- report. During-this exit interview, the NRC inspectors
summarized the scope and. findings of the inspection. The-
applicant acknowledged the. inspection' findings.
, <
h
k
I
;
l
1
!
. ,
u
'
.
)
L' l1
- . _ _ _ . - - - _ _ _ _ . _ _ _ _ _ _ - _ - _ - _ _ _ _ - _ _
-
.-- , _
,
,
, ,
,
-1
; ,, %
4
DISTRIBUTION:
4
TiId5Nd6YlissijT"50$iM7~N6E" ' '" ~ "'
.NRC " PDR ""*"' ~" ,
LPDR' -
ioSP Reading: ;
..CPPD-LA 1
:CPPD Reading..(HQ) j
L* Site Reading )
*CPRT' Group '
* SRI-OPS-
* SRI-CONST- i
AD for Projects !
* MIS' System, RIV -!
*RSTS Operator, RIV
RPB, RIV
RIV. Docket: File -
*DWeiss,.RM/ALF .
JTaylor .
-
!
JKeppler/JAxelrad
CIGrimes.
-PFMcKee
'JLyons , -i
'AVietti-Cook-
MMalloy
.JMoore, OGC
LJGilliland, RIV'
FMiraglia.
EJordan
JPartlow i
"
.BHayes
*w/766 i
-;
I
l
4
;
i
-
,
'!
p l 1= l l
_ _ _ _ _ _ _ _ _ . _ . . _ _ _ _ _ _ _ _ _ . . _ . _ _ _ _ _ . _ _ _ _ _
}}