ML20237G310
| ML20237G310 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/05/1987 |
| From: | Barnes I, Ellershaw L, Hale C, Wagner P NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20237G293 | List: |
| References | |
| 50-445-87-06, 50-445-87-6, 50-446-87-05, 50-446-87-5, NUDOCS 8708140013 | |
| Download: ML20237G310 (58) | |
See also: IR 05000445/1987006
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APPENDIX C
U. S., NUCLEAR REGULATORY COMMISSION
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OFFICE OF SPECIAL PROJECTS:
NRC Inspection Report: 50-445/87-06 Permits: CPPR-126
l 50-446/87-05 CPPR-127
L Dockets: 50-445 Category: A2 i
50-446- '
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Construction Permit. l
Expiration Dates: j
Unit 1: August 1, 1988
Unit'2: August'1, 1987 :
Extension request
submitted-
Applicant: -TU Electric
Skyway Tower ,
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400 North Olive Street
Lock Box 81
Dallas, Texas 75201
Facility Name: Comanche Peak Steam Electric Station (CPSES), l
Units 1 & 2
Inspection At: Glen Rose, Texas
Inspection Con $ucted: March 1 through April 30, 1987
Inspectors: k -
. An Lt_N
E. Ellershaw, Reactor Inspector
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L. /Date- I
(paragraphs 2.a-2 r, 2.u, 2.v, 3.a-3.1,
4.f-4.h, and 4.m)
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@ n:]ttOL
C. J.LWale, Reactor Inspector
de-/97
' Date
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(paragraphs 2.s, 2.t, 3.j-3.o, 4.e,
and 4.1-4.k)
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P. C. Wagner, Rhactor Inspector
s/e/97
Date
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(paragraphs 4.a-4.d)
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Consultants: EG&G - J. Dale (paragraphs 2.u, 3.d, 3.g, and 4.m)
A. Maughan (paragraph 4.c)
W. Richins (paragraph 4.f) )
V. Wenczel (paragraphs 3.j, 3.k, 3.m-3.o
and 4.j) i
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Parameter - J. Birmingham (paragraphs 2.s, 2.t, 4.e,
4.1 and 4.k)
K. Graham (paragraphs 2.v, 3.b, 3.c, 3.h
and 3.1)
D. Jew (paragraphs 2.a-2.r, 3.a, 3.e, i
3.f, 4.g, and 4.h) i
Reviewed By: v 8 % P/r[P7 '
I. Barnes, Senior Project Inspector Date
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Inspection Summary
Inspection Conducted: March 1 through April 30, 1987 (Report
50-445/87-06; 50-446/87-05)
Areas Inspected: Nonroutine, unannounced inspection of applicant
actions on previous inspection findings, follow-up on items of
noncompliance / deviations, and CPRT issue-specific action plans
(ISAPs); i.e., I.a.1, I.a.2, I.b.1, I.b.4, I.d.2, II.c, V.c, V.e, !
VII.a.1, VII.a.2, VII.a.6, VII.a.9, and VII.b.3.
Results: Within the three areas inspected, one violation (cables
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stored outside without proper protection, paragraph 4.k) and two
deviations (unsatisfactory corrective actions for previous
inspection findings, paragraphs 3.c and 3.g) were identified.
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DETAILS
1. Persons Contacted
P. Amoruso, Issue Coordinator, Evaluation Research Corporation
(ERC) l
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l ***R. P. Baker, Regulatory. Compliance. Manager, TU Electric
'***J. L. Barker, Engineering Assurance Manager,ETU Electric
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- G. L. Bell, Nuclear. Licensing Engineer, TU Electric
D._Boydston,_ Issue Coordinator, ERC
, *F.-G. Burgess, Comanche Peak _ Response Team-(CPRT) Project
i Manager, TU Electric
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- R. E. Camp, Unit 1 Project Manager, TU' Electric
M. Chamberlin, Pipe. Support Engineering Supervisor, Stone &
Webster Engineering Corporation (SWEC)
- R. D. Delano, Nuclear Licensing Engineer,-TU Electric
- D. E. Deviney, Operations Quality Assurance (QA) Manager,
TU Electric.
D. Ferguson, Results Report & Working File Review Committee j
Chairman, CPRT I
- T. L. Heatherly, Regulatory Compliance Engineer, TU Electric
- J. J. Kelley, Construction Director, TU Electric
- J. E. Krechting, Director of Engineering, TU Electric i '
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- O. W. Lowe, Engineering Director, TU Electric _
l *G. M. McGrath, Test & Startup Supervisor, TU Electric :
- J. W. Muffett, Executive Assistant, TU Electric !
- L. D. Nace, Vice President, TU Electric ;
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P. E. Ortstadt, Issue Coordinator, ERC l
- D. Palmer, Performance Assessment Supervisor, TU Electric
W. Parry, Audit Supervisor, TU Electric
G. Purdy, QA Manager, Brown & Root (B&R)
- J. Redding, Executive Assistant, TU Electric
- D. M. Reynerson, Unit 2 Project Manager, TU Electric
- S. F. Sawa, Assistant Unit 2 Project Manager, TU Electric
- C. E. Scott, Startup Manager, TU Electric-
- J. C. Smith, Operations Staff, TU Electric
- M. R. Steelman, CPRT Support, TU Electric
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- P..B. Stevens, Electrical Engineering Manager, TU Electric ;
l P. Streeter, Issue Coordinator, TERA
- C. L. Terry, Executive Assistant, TU Electric
L *T. G. Tyler, CPRT Program Director, TU Electric
C.. Vincent, Issue Coordinator, ERC
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F. Webster, Engineering Statistical Advisor, CPRT.
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- D. Woodlan, Docket Licensing Supervisor, TU Electric j
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! The NRC inspectors also interviewed other applicant employees
during this inspection period.
- Denotes personnel present at the April 6, 1987, exit interview.
- Denotes personnel present at the May 5, 1987, exit interview.
- Denotes personnel present at both of the above exit interviews.
! 2. Applicant Actions on Previous Inspection Findings (92701)
a. (Closed) Open Item (446/8509-0-01): Potential deviations
regarding an expansion joint number not being documented,
a flange not being installed as shown on Drawing
BRP-DO-2-DG-002, and a flanged section of piping not
installed as shown on Drawing BRP-SW-2-YD-005.
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Subsequent to the inspections, it was determined by the ;
ERC population engineer that in order for a piping
isometric to be "QC Accepted" and " Construction
Complete," as required by the CPRT Program Plan, the
isometric must have undergone "N-5" walkdown and
issuance. These two isometric drawings had not been
"N-5" issued; therefore, should not have been included
and were removed from the Large Bore Piping Configuration
(LBCO) sample. The subsequent revision to the Population
Items List (Revision 1) clearly identified that only
"N-5" issued isometrics should be included within the ERC
scope for LBCO. The NRC inspector concurs and this item
is closed.
b. (closed) Open Item (446/8509-0-02): It was ascertained J
that accessibility walkdowns conducted on large bore i
piping runs prior to reinspection did not address a check
for completion of construction. The reason for this was
that the LBCO population included packages which were not j
"N-5" issued. Subsequent revision of the LBCO population l
items list and removal of packages which had not been l
"N-5" issued precluded this from occurring in the future. l
It should be noted that the accessibility walkdown !
determines whether a particular package can be inspected; I
not whether the inspection attributes are acceptable. 1
This item is closed.
c. (Closed) Open Item (446/8509-0-03): Potential deviation
regarding lack of flow direction indicator on a valve.
This condition was identified by ERC during a NRC
witnessed inspection on Verification Package
I-M-SBCO-052. Subsequently, it was determined by-review
of Section 5.3.4 in ERC Quality Instruction (QI) QI-026
that the flow direction indicator is not required for
this type of valve (gate valve); thus, this item is not a
deviating condition. The NRC inspector concurs with this
determination; therefore, this item is closed.
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d. (Closhd) Open Item (446/8509-0-04): Potential deviation
regarding a linear pipe dimension and'a valve stem angle
not being in accordance with' Drawing BRP-CS-2-AB-089.
These conditions were identified by ERC during a NRC
witnessed. inspection on Verification Package
, I-M-SBCO-062. The valve on the horizontal run of pipe,
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as depicted on theg isometric drawing, had its stem
orientated on a 45 vertical angle. At the time of
inspection, the ERC inspector was ugsure as to whether
the whole body should be rotated 45 to achieve the valve
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stem angularity or if the valve'should hgve been
manufactured with the valve stem at a 45 ' angle.
Subsequently,gERC determined that the valve body should
be rotated 45 prior to installation. Since the valve
was installed in this condition, this item is not a
deviation. The condition of the linear pipe dimension"
being out of tolerance by 1" was documented on Deviation
Report (DR) I-M-SBCo-062-DR01. This.DR was incorporated
into Nonconformance Report (NCR) M-22009 which was
subsequently dispositioned to require that the. isometric
drawing be revised and reissued as Revision 4. -Any
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effect the out-of-tolerance dimension would have on the
pipe stress, analysis is to be accounted for'by SWEC
during theirNrequalification performed under the
Corrective Action Program. This item is closed.
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e. (closed) Open Item (445/8511-0-05): Evaluation of valve I
bonnet' identification number mismatches (incorrect valve l
bonnet installed) identified by ERC during ISAP VII.b.2 i
inspections of pre-:ously disassembled valves. ERC has
performed safety significance evaluations (SSEs) and B&R
has issued NCRs in response to the ERC DRs. The SSEs
included programmatic and generic implications. NRC
review of this subject area is documented in NRC
Inspection Reports 50-445/86-07; 50-446/86-05 and
50-445/86-22; 50-446/86-20. The NRC inspections revealed
thatt.of the four deviating conditions identified by ERC,
two were resolved when additional information was found ;
in the TU Electric vault which substantiated that the
installed bonnets were of.the same size, temperature and
pressure-rating as was required. One condition was
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resolved with the acquisition of additional paperwork i
from the salve vendor which substantiated the correctness
of the' installed bonnet. The final condition required a
replacement bonnet along with proper documentation of the
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f. (Closed) Open Item (446/8511-0-05):. Potential deviation.
regarding an orifice flange on a piping run-not having an
identification tag or a flow direction indicator.
Subsequent to the inspection, it was determined that this
package had not been "N-5" issued; therefore, should not
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have been included in the LBCO population (see previous ,
write-up on open item 50-446/8509-0-01 in paragraph 2.a, I
above). This item is closed.
g. (closed) Open Item (446/8511-0-06): Potential deviation
regarding certain field survey elevation measurements
being out of tolerance with the elevations.shown on
Isometric BRP-CS-2-AB-101. The problem atose because two
different elevations on the B&R pipe drawing (BRP) were
shown for the same run of pipe. This condition was
identified by ERC during a NRC witnessed inspection on
Verification Package I-M-SBCO-079. Subsequently, a. '
Technical Information Request (TIR) was submitted to the I
applicant, who determined which elevation shown on the l
BRP was correct. This elevation was not out of tolerance
with the field survey measurements. The subsequent
revision to the isometric, Revision 4, was corrected so
that this discrepancy no longer exists. The NRC i
inspector concurs with this determination; therefore, '
this item is closed.
h. (open) Open Item (446/8511-0-08): Potential deviation
regarding the location of two' capture plates being 1/16"
out of tolerance. This condition, which was identified
by ERC during a NRC witnessed inspection, was documented
on ERC DR I-S-PWRE-052-DR01. This DR was incorporated
into NCR M-22041 which was then initially transferred to
. Construction Deficiency Report (CDR)-87-3627 and then to
NCR CM-87-2854. This item is still open pending NRC
review of the disposition of NCR CM-87-2854. ,
i. (Open) Open Item (446/8511-0-09): Potential deviation
regarding grout not completely covering the base-plate
shims for Verification Package I-S-PWRE-518. It was
determined that this particular deviation is not covered
by the Pipe Whip Restraints (PWRE) population but would
be covered under one of the grout populations; therefore,
no DR was issued. In accordance with ERC procedures, an
out-of-scope observation (005) was written and processed
under 005 No. 205. The OOS resulted in the issuance of
l NCR C-86-200378X which has not yet been dispositioned.
Therefore, this item will remain open.
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j. (Open) Open Item (446/8511-0-10): This item addressed
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one aspect of an OOS-(No. 215) which was identified while
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ERC was inspecting Verification Package I-S-PWRE-052. A
Richmond insert on concrete column No. 15 overlapped a
, Hilti bolt embedment for a pipe support on the adjacent
l column face. The NRC inspector verified by review of
' applicable procedures and documentation that the ERC
procedures were complied with and that the applicant had
issued NCR M-86-200382SX in response to the OOS. The NCR
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has not yet been dispositioned and, accordingly, this
item will remain open.
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k. (Open) Open Item (446/8511-0-11): This item addressed ;
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the second aspect of 005-215 which was identified during )
an ERC inspection of Verification Package I-S-PWRE-518.-
OOS No. 215 documented the presence of a crater which had
been chipped out of the base-plate grout. As discussed ,
.in paragraph 2.j above for 005-215, the NRC inspector {
verified by review of ERC procedures and observation of '
applicable documentation that ERC. complied with
procedural requirements and had notified the applicant of 1
-this OOS. This item will remain open pending disposition
of NCR M-86-200382SX by the applicant.
1. (open) Open Item (445/8514-O-27): Potential deviation i
regarding insufficient clearance between the inspected i
line and three other lines and a linear dimension being
out of to3erance. These conditions were identified by j
l ERC during a NRC witnessed inspection of Verification
l Package I-M-SBCO-061, Drawing BRp-CH-X-FB-006. The
i out-of-tolerance dimension and insufficient clearance
between the inspected line and the other lines were
documented, respectively, on DRs I-M-SBCO-061-DR01 and l
l DR02. The two issued DRs resulted in the issuance of NCR )
! M-23461N. This NCR has been dispositioned but required '
f a.tions have not yet been accomplished. Therefore, this
item will remain-open pending completion of these actions
l and NRC review.
m. (Open) Open Item (445/8514-O-35): Potential deviations
regarding.out-of-tolerance conditions of Hilti bolt
locations and embedments, misaligned Unistrut spring
nuts, length of fillet welds being too short, and a
torque value equal to a minimum of 70% of the initial
specified torque not being applied to bolts. These
deviations were documented on DRs I-S-INSP-004-DR01
through DR14 and were incorporated into NCR CI-87-879-X.
Subsequently, the NCR was transferred to CAR 72X,
Revision 2, which was issued on February 4, 1987. This
CAR was initiated as a result of CPRT recommendations
which were made as a result of the identification of two
construction deficiencies in the Instrument Pipe / Tube ,
Supports (INSP) population. The recommendation was for
the applicant to " inspect 100% of sprin; nuts for
instrument / tubing supports for torque fitup and
alignment, bolt torque and damaged hardware." No
r schedule for completion of inspections and rework has
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been determined yet. This item will remain open pending '
NRC review and inspection of CAR 72X actions.
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n. (open) open Item (445/8514-0-36): Potential deviations
regarding the use of incorrect clamps, clamps not )
installed per drawings, misalignment of Unistrut spring
nuts, loose nuts on U-bolts, and a torque value equal to ] 4
a minimum of 70% of the initial specified torque not l
being applied to bolts. These deviations were documented l '
on DRs I-S-INSP-017-DR02, DR03, DR05 through DR10, and
DR12 through DR16. NCR I-86-102060X was initiated to .
address DR12 through DR16'while NCR I-86-100315X will
-disposition the remainder of the DRs. This item will
reraain open pending closure of the NCRs by the applicant 3
and review of the dispositions by the NRC inspector.
o. (open) open Item (445/8514-0-37): Potential deviations
regarding a member length being out of tolerance, an
undersized weld, and no die stamp of a unique
identification number on a support. These deviations,
which were documented on DRs I-S-INSP-024-DR02, DR03, and j
DR04, were incorporated into NCR 100053SX. This item !
will remain open pending final disposition by the
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applicant and review of this disposition by the NRC
inspector.
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p. (open) open Item (445/8514-0-38): Potential deviations
regarding out-of-tolerance support dimensions, spring
nuts used in lieu of hex nuts, misalignment of Unistrut 1 '
spring nuts, and a torque value equal to a minimum of 70%
of the initial specified torque not being applied to
bolts. These deviations, which were documented on DRs
I-S-INSP-057-DR01 through DR07 and DR09, were
incorporated into NCR I-86-100341SX. Based upon CPRT l
recommendations, this NCR was transferred to CAR 72X (see l
discussion on open item 50-445/8514-0-35 in
paragraph 2.m. above). This item will remain open
pending NRC review and inspection of CAR 72X actions.
q. (Closed) Unresolved Item (445/8514-U-13): This item
addressed four conditions identified by the NRC inspector
where the R. L. Cloud & Associates (RLCA) stress report ,
for ISAP V.e, " Installation of Main Steam Pipes,"
- contained inadequate information.As discussed in NRC
l Inspection Report 445/86-01; 446/86-01, two of the items
! have been closed out and the other two involve editorial ,
changes to the subsequent revision of the RLCA stress
report. The NRC inspector concurs that the remaining two
conditions have been adequately addressed by the CPRT
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incorporated into the ISAP working file and Revision 2 ef
the stress report. This item is closed.
t r. (open) open Item (445/8516-0-49): Potential deviati7ns
regarding capture plate locations being out of tolerasce,
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and anchor bolt nuts and washers not bearing adequately
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to the base plate. These conditions, which were
t identified by ERC during a NRC witnessed inspection, were
documented on DRs I-S-PWRE-053-DR01 through
I-S-PWRE-053-DR04. Subsequently, they were incorporated
into NCR M-23364N. This item will remain open pending
disposition of the NCR and NRC review of the disposition l
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and any specified rework- . j
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L s. (Closed) Open Item (446/8602-0-03): A required review of I
l documents for impact on the audit plan / schedule was not )
documented; i.e., did not identify the documents l
reviewed, the personnel performing the review, nor the
review outcome.
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TU Electric Administrative Guide QQA-020, " Updates of
Annual Internal Audit Schedules," provides instructions
for the conduct of the reviews required by TU Electric j
Procedures DQP-AG-3, "CPSES Operations Phase Audit i
Program," Revision 1, and DQP-AG-4, "CPSES Construction
Phase Audit Program," Revision 2. Also provided are
methods for documenting the reviews and communicating
l requirements for changes to the annual internal audit !
- schedule to the supervisor, QA audits. The NRC reviewed j
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Administrative Guide QQA-020 and determined that it l
provided the instructions necessary to control the review 1
of documents for impact on the internal audit schedule.
The NRC found it detailed the responsibilities of the
audit coordinators to perform the document review, to log !
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the documents reviewed and the outcome of that review.
Further, the NRC reviewed the log used to document this i
review and found it to be in accordance with the l
Administrative Guide. The issuance and implementation of
the Administrative Guide QQA-020 closes this open item.
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- t. (Closed) Open Item (446/8602-0-04)
- Verify input of the
surveillance program findings into the April 1986 trend
report.
During NRC inspection of ISAP VII.a.2, the NRC inspector
reviewed the April 1986 trend report and subsequent trend
reports. Results of this review showed that findings
from the construction surveillance, document
surveillance, and start-up surveillance programs were
trended and reported in the trend reports and that
potential adverse trends (PATS) and potential-adverse ;
i conditions (PACS) were identified.for corrective action
as applicable; however, input from the inspection
surveillance program was not included until the May 1986
report. This was due to the inspection surveillance
program being reorganized and restructured starting in
late 1985 and continuing into 1986. As a consequence,
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surveillance under the new organization did not begin i
until late March 1986 and meaningful data had not been l'
generated in time for the April trend report.
The inclusion of surveillance program data into trend I
reports closes this item.
u. (Closed) Unresolved Item (446/8602-U-16): The support
identification for cable tray support CTH-2-7136 was
incorrectly identified on Drawing CTH-7137. An
inspection of the support was conducted by the NRC
inspector who noted that the No. 288796 was stamped on
the upper portion of the vertical cross member. This
number was also delineated on the drawing; however, this '
numerical identification was not consistent with the
typical alphanumeric designations used for cable tray
supports. It was later identified to be the material
heat number. At that time, TU Electric QA issued NCR
M-85-201803 which documented the discrepancy in the
support numbers and provided for the revision and correct
! identification of support CTH-2-7136 on Drawing
! CTH-2-7137. The NRC inspector verified that the drawing
has been revised and now shows the correct support
identification; therefore, this item is closed.
v. (closed) Open Item (445/8603-O-16): ERC inspection of a
5/16" fillet weld in the coated condition was documented
" accept". After the coating was removed, the same weld
was documented on a DR as " reject" due to a 1/2" long
segment of weld being approximately 1/32" undersize. The
NRC inspector subsequently verified that the documented
deviation had been evaluated for safety significance and
that the results were acceptable. The associated NCR
M-23500N was dispositioned "not a nonconforming
condition" with the justification "The undersized portion
does not exceed 10% of total weld length." The NRC
inspector verified that the acceptance criteria in the
applicable inspection procedure, NCIG-01, Revision 2, was
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compatible with the disposition. The acceptance criteria
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allows a fillet weld to be undersized by 1/16" for 1/4
the length of the weld. The NRC inspector concurs with ,
the disposition; therefore, this item is closed.
3. Follow-up on Items of Noncompliance / Deviations (92702)
a. (Closed) Violation (446/8509-V-04): Four of twelve studs ,
on Flange No. 6 on Drawing BRP-SW-2-018 had loose nuts.
This was contrary to the stated criteria for precluding
flange leakage. To correct this condition, the applicant
took the following actions:
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(1) NCR M-18697 was issued to disposition the
nonconforming condition. The disposition required
retorquing the nuts to an acceptable value and q
checking to ensure that no damage to any equipment '
had occurred.
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(2) Construction operation Traveler (COT) )
MW-85-4185-2-0402 documented the retorquing of the !
nuts. !
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(3) Though the applicant could not specifically identify ]
the cause as to why this condition existed, craft R
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personnel were further trained and informed that no
unauthorized work is allowed on previously inspected
items. This training, which dealt with steps
necessary to break an inspected flange joint, was
completed February 5, 1986.
Based upon review of the NCR and the documented training
l record and inspection of the reworked flange in the ;
field, the NRC inspector concurs with the action taken by
the applicant to close this issue.
b. (Closed) Deviation (445/8513-D-01): Due to a
misunderstanding of ISAP V.d sampling requirements,
non-ASME plug welds were included on the population items ,
-list and chosen as samples although the intent of
ISAP V.d was to sample ASME plug welds only. ,
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TU Electric committed to select and inspect additional NF
pipe _ supports in order to achieve a sample of 60 ASME-NF
supports in each unit. The NRC inspector verified by-
documentation review and inspection, that additional
supports were selected and inspected and that the ;
required sample quantity was achieved. Therefore, this
item is closed.
As a result of this finding, however, NRC letter dated
April 3, 1986, requested that TU Electric clarify what
actions were taken to assure similar misunderstandings of
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requirements did not occur in other action plans. TU
Electric letter TXX-4819 stated in response to this
request that the statistical consultant, with the help of
the Results Report Review Committee, reviewed the
sampling aspects (i.e., population definition, sample
l selection, etc.) of all action plans as part of the-CPRT
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review of the action plans issued in Revision 3 of the
CPRT Program Plan. This review was stated to have been
completed February 1, 1986, with no significant problems
identified.
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On March 11, 1987, NRC inspectors contacted the CPRT
statistical consultant to review documentation of the
results of his review as committed to in TXX-4819. The
statistical consultant stated he was unaware of the
commitment and that the review performed prior to
submittal of Revision 3 of the CPRT Program Plan was
primarily of methodology'and did not encompass detailed
verification of the adequacy of specifics of population
definition and sample selection for the action plans.
Accordingly, the NRC inspectors were unable to establish i
from available documentation that actions have been taken
, which would identify the existence of errors in other i
action plan populations. This item will remain !
unresolved pending clarification by the' applicant and NRC j
review (445/8706-U-01; 446/8705-U-01). I
c. (Open) Deviation (445/8513-D-03): An ERC inspector
failed to document the existence of four 9/16" diameter
drilled. holes in Item 2 of ASME Pipe Support
CT-1-053-436-C52R that were not shown on the design
drawing.
The NRC inspector verified that ERC subsequently
initiated OOS No. 126 which documented the existence of
the four 9/16" diameter drilled holes. The 005 resulted
in the issuance of NCR M-23190N which has not yet been
dispositioned. Therefore, the deviation remains open.
The applicant responded to the above deviation by letter
TXX-4740 dated April 3, 1986, and committed to have the
l recently instituted ERC overinspection group repeat a
number of completed reinspection which would include a
review for blatant out-of-scope observations. A
determination would.be made, based on the findings of the
overinspections, as to whether or not additional
reinspection and/or inspector training on documenting
out-of-cccpe observations would be required. TU Electric
committed to be in full compliance by April 30, 1986.
The NRC inspector contacted the ERC overinspection group
l
in order to verify implementation of the stated -
corrective action commitments. The ERC overinspection
group supervisor and QA manager stated that they were
l
'
unaware of the specified corrective action. (corrective
action had not'been completed as of the end of this
inspection period.) The NRC inspector additionally
ascertained that there was no documentation available
which would demonstrate that a comparison of out-of-scope
observations identified by the overinspection group with
those identified by the reinspection effert had'been
performed. The absence of such a comparison would
preclude making any determination as to whether or not
l
l --_---_ -
. .
13
additional reinspection and/or inspector training would
have been required. The failure to implement committed
corrective action is a deviation (445/8706-D-02).
d. (Closed) Violation (446/8513-V-10): Damaged Unit 2
battery room Ventilation Exhaust Duct System EMD-3.
During an inspection of HVAC ductwork, the NRC inspector
identified that Flanges 17 and 18 on Exhaust Duct System
EMD-3 were either damaged or altered during installation.
This resulted in a 1/4" gap between Flange 17 and ,
Flange 18, which'was in excess of the allowable' gap of !
5/32". As a result of this inspection, Bahnson ;
'
Deficiency and Disposition Report (DDR) 0381 was
initiated. The disposition of DDR 0381 was Use-As-Is for {
the following reasons:
(1) The duct is classified as non-ESF (Engineered Safety
Feature) after it leaves the fan on the discharge ;
side. i
(2) An acceptable leak test was performed on the duct. l
(3) The bent flange does not impair the integrity or
intended design of the duct.
The NRC inspector has reviewed the applicable documents j
including Leak Test Report 412-8/27/85 and concurs with '
the DDR disposition. I
e. (Open) Deviation (445/8514-D-04): Two ERC inspectors
failed to identify that the serrated grooves of Unistrut
spring nuts were not aligned with the channel clamping
ridge as required by Section 5.0 of QI-055. This
condition was identified for Support 7D in Verification
Package I-S-INSP-007 and support 28A in Verification
Package I-S-INSP-028.
Corrective action taken included reinspection and-
issuance of appropriate DRs, reinspection of a minimum of
25% of all work previously inspected by these two
l inspectors, and a documented training session was
conducted for one of the inspectors of record and all
i
'
other ERC inspectors performing INSP inspections using
QI-055. Based upon the results of ERC reinspection of
25% of the work of the other inspector of record,.a
decision was made to terminate his services and reinspect
100% of his work. The NRC inspector verified by document
i review that these committed corrective actions had'been
l implemented.
l
'
The DRs documenting the deviating conditions will
eventually require rework per the criteria of Corrective
<
l
l _. _ - _ _ _
,
- _ - _ _ _ _ _ _ _ _ - _
I
. . j
i 14 l
<
Action Report (CAR) 72X. This item will remain open j
pending rework of these supports to the CAR 72X criteria j
( and NRC inspection of this rework. j
l' 4
I
f. (Open) Deviation (445/8516-D-50): Failure of an ERC
inspector to identify that the serrated grooves of a i
Unistrut nut were not aligned with the channel clamping
ridge as required in Section 5.0 of QI-055. This finding i
pertained to Support 33A in Verification Package
l I-S-INSP-033.
l
The corrective actions included reinspection and issuance f
l
of DR I-S-INSP-033-DR02, generation of NCR I-86-100071SX ,
j to disposition the condition, and documented training of l
'
the inspector relative to this finding. Since numerous I
DRs were generated relative to the misalignment of
Unistrut spring nuts, TU Electric initiated CAR 72X to
disposition this condition on a generic basis (see i
discussion regarding CAR 72x in paragraph 2.m. above).
This item will remain open pending NRC review and 1
inspection of CAR 72X actions. l
g. (open) Violation (445/8516-V-13): Failure of QC
inspectors to detect undersize welds. During an
inspection of pipe support CC-1-131-010-543R located in
Unit 1, the NRC inspector identified four undersize
welds. This condition was subsequently documented on NCR
M-25650N dated March 11, 1986. This item was left open i
pending NRC review of the NCR disposition. l
TU Electric letter TXX-4826 dated June 16, 1986, states,
in part, with respect to action to prevent recurrence for
the above violation, "The support addressed was inspected
in 7/83 in the earliest versions of the As-built
Inspection Program. Due to problems related to
undersized welds, B&R Procedure QI-QAP-11.1-28, !
Revision 24, issued April 24, 1984, was revised to
require the QC inspector to assign a weld number to each
weld shown on the design drawing, and to document both
the required size of the weld per design drawing and the
actual deposited weld size. . . . " j
!
The NRC inspector reviewed B&R Procedure QI-QAP-11.1-28,
Revisions 16, dated December 15, 1982, through
'
Revision 24 dated April 18, 1984; and Revision 25 dated
June 11, 1984. l
I
Paragraph 5 in Revisions 16 through 23 states, in part, j
"Results of visual examinations shall be documented on a 1
l Hanger Inspection Report and WDC or Traveler if
used. . . . Weld sizes will be recorded on the Weld
Inspection Checklist. .. . . "
i
. - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. .
15
Paragraph 3.6 in both Revision 24 and 25 states, in part,
"Results of visual examinations shall be documented on a
WED/MWDC or Traveler if used. . . . For hangers, weld l
sizes will be recorded on the Weld Inspection
l Checklist. . . ." i
A review of the Weld Inspection Checklist (WICL) attached
to each of the identified revisions, revealed the 3
following.
1
l
'
Each WICL is identical, in that columns exist for the l
weld number, size, QC inspector (QCI) initials and date, !
applicable drawing or component modification card (CMC),
and comments. Each of the instructions for filling out {
i
the WICL requires the QCI to assign weld numbers in i
I numerical sequence to all the field welds on the drawing
and/or CMC, and to record these numbers on the WICL. It
further requires the QCI to measure the actual weld size
e and to record the lowest size measured on the WICL. The
l QCI shall initial and date the WICL for the inspected
'
welds and he shall sign and date the hanger design
l drawing and/or CMC.
These requirements have existed virtually unchanged since
i before the applicant inspection of the identified support
in July 1983. The submittal of erroneous preventive
1
measures constitutes a deviation (445/8706-D-03). ;
h. (Closed) Deviation (445/8518-D-17): ERC inspectors ;
failed to identify an undersize fillet weld and a fillet
weld which was underlength. The particular welds were
accepted on the applicable verification package
checklists.
Subsequent to the NRC inspection, ERC initiated two DRs;
one for the undersize weld and one for the underlength
weld. The NRC inspector verified that the DRs had been
written and validated as required by CPRT project
procedures. The DR which documents the underlength weld
was subsequently invalidated by project Deviation Report
(PDR)-4 which generically addresses underlength fillet
wolds on tube steel. As a' result of pDR-4 being issued,
the applicable ERC pipe support inspection QIs were
revised to delete the requirement for weld length
verification (wrap around) on tube steel shapes unless
specified by the design drawing. The project initiated
'
CAR 78X, which remains open at the end of_this report
period, to disposition underlength tube steel " wrap
around" welds on a generic basis.
The-DR which documents the undersize weld resulted in the
initiation of NCR M-23182N which resolved the identified
L __ _ _
1
. .
16
condition. The committed corrective actions have been
verified by the NRC inspector to have been implemented. -I
The NRC inspector reviewed the ERC overview inspection
files for the two ERC inspectors who failed to identify :
the deviating weld conditions, in order to resolve any
concern about inspector performance. In accordance with ,
the requirements of ERC-QA-28, previously completed
inspections were randomly selected, overview inspection i
verification packages were prepared and inspected, and a j
comparison of inspection results was documented. The 1
overview inspection supervisor determined that the two ]
ERC inspectors had an acceptable performance record and -
his conclusion was subsequently verified by the ERC
onsite QA representative.
1. (Closed) Deviation (445/8603-D-17): ERC inspection of 1
I
Verification Package I-S-NPBW-014 documented that the
surface of a weld was suitable for nondestructive-
examination (NDE). The same weld had been previously- i
rejected during a preceding quality inspection required
by I-S-PWRE-006. NRC inspection of the weld determined
that the weld surface was not suitable.for NDE.
Subsequently, ERC issued DR I-S-NPBW-014DR1. To resolve
the issue, a B&R Level III inspector performed a magnetic ?
particle examination (MT) of the weld. The MT results
indicated that the weld and weld surface were acceptable. q
The NRC inspector reviewed the MT report (29023) and l
concurs that a deviation does not exist.
j. (Closed) Violation (445/8603-V-02): Incomplete site I
i operations trend' analysis.- This violation consisted of
l three parts.
!
part 1: Hardware deviations identified on NCRs were not
evaluated for adverse trends and thus not reported to
required levels of management. The NRC inspector
verified (by reviewing appropriate documentation) that j
l the following actions were taken by the applicant. A I
trend analysis system was established in 1986 to evaluate
NCRs for conditions adverse to quality. The-results of
these evaluations will be reported to management on a 1
l
quarterly basis; e'g., in 1986 - Quality Assurance-Status
.
Reports issued in March, June, September and December
were reviewed. Trend analyses were performed for all
NCRs generated prior to January 1986. .These results were '
.
reported to the appropriate levels of management via
interoffice memoranda ~QIM-86162 and QIM-86204. Based on
review of this documentation which confirmed
implementation of applicant commitments, this item is
,
closed.
,
_ -__-- ._--_---_._.__ __._-
.
.
s
_.
. .
17
l'
i Part 2: Site procedures did not clearly describe )'
l conditions under which a DR or an NCR was to be written.
l The NRC inspector verified that issued Procedures
l NEO 3.05, Revision 1, " Reporting and Control of ;
'
Nonconformances," and NEO 3.06, Revision 0, " Reporting
and Control of Deficiencies," clearly defined the site ,
guidelines for deficiency and nonconformance reporting. l
I
i.lso verified by the NRC was that the appropriate
implementing procedures were revised to include NEO
requirements. Revised implementing procedures included
l STA-404, Revision 4, " Control of Deficiencies," and
i STA-405, Revision 13, " Control of Nonconforming
Materials." Based on the foregoing, this item is closed.
'
Part 3: Prior to June 1985, no evidence was found that !
,
DRs were reviewed for potential conditions requiring an l
1
NCR as required by procedure. To assure that l
nonconforming conditions did not go undocumented, the I
l
applicant committed'to review ali DRs issued prior to {
l June 1985 to assure required NCRs had been written. The i
l NRC inspector confirmed that all DRs were reviewed and no i
conditions requiring an NCR were identified. The results i
of these reviews were reported 'o
c the required levels of I
management via interoffice memorandum QIM-86202. I
Accordingly, this item is closed.
. k. (Closed) Deviation (445/8607-D-05): Failure of the
l
Senior Review Team (SRT) to assure quality of CPRT
activities. This deviation was in three parts.
Part 1: A series of CPRT Policy & Guidelines (PAGs) were
issued only in draft form. These PAGs were approved by
the SRT, but were not formally issued and controlled.
The CPRT responded to this item by preparing PAG-10,
Revision 0, " Policy for Issue and Control o.f Policy and
Guideline Documents." The series of PAGs were issued in
controlled distribution on May 30, 1986. The NRC
reviewed documentation for issuance, distribution, and
control of the PAGs and found them to conform to PAG-10.
Accordingly, Part 1 of this item is closed.
Part 2: A reference error was made in Appendix G,
Revision 0, of the CPRT Program Plan to guidance for a QA
element. The guidance for QA element, " Instructions,
Procedures, and Drawings," in Appendix G referenced the
wrong document. The proper reference should have been
the "CPRT Program Plan, CPRT Policies and Guidelines, and'
each ISAP." The NRC verified this error had been
corrected and approved by the SRT; however, at the time
of this inspection, Revision 1 of Appendix G was not l
! issued. The issuance of Appendix G, Revision 1, is i
scheduled to occur'in the next CPRT Program Plan revision l
!
!
_ _ _ _ _ _ _ _ _ _ _
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ - _ ,
l
.
. ;
18 )
i
I
prior to July 31, 1987. Based on SRT approval of the
revision to Appendix G correcting this error and a j
commitment to include this change in the next CPRT j
Program Plan revision, Part 2 of this item is closed. 3
Part 3: The SRT had not approved either the January or
February 1986 versions of the " Overview Quality Team
Program for Comanche Peak Response Team Activities." I
This document prescribes the charter and objectives of
the Overview Quality Team (OQT). The NRC verified that f^
the current version of the OQT program dated July 23,
1986, was reviewed and approved by the SRT and endorsed
by the TU Electric Executive Vice President. Therefore,
Part 3 of this item is closed.
1. (Closed) Deviation (445/8607-D-06): The documented OQT
program was not definitive.
In TU Electric letter TXX-4931 dated July 23, 1986, )
W. G. Counsil to V. S. Noonan (NRC), the applicant
identified the OQT's authority and responsibilities.
Included as an attachment was a revised OQT program.
Changes and enhancements to the program were:
requirements for a three month master schedule (to be
updated monthly) of planned activities; the scope of the
OQT activities was expanded to include all aspects of the
CPRT program; and establishment of procedural controls
for timely resolution by SRT and OQT of deficiencies
identified by the OQT. The NRC accepted the TU Electric
revision to the OQT program by letter dated January 13,
1987.
The NRC inspector reviewed OQT Periodic Progress and
Status Report from September 1986 to January 1987 and
found: the master schedule to be updated monthly;
overviews covered all aspects of CPRT program activities;
and identified deficiencies were tracked and resolved in
a timely manner. Based on this review and the NRC
January 13, 1987, letter, this item is closed.
l
m. (Closed) Deviation (445/8607-D-07): The ERC E&ESD
quality assurance manuals were not maintained and
controlled in accordance with Procedure ERC-QA-01,
Revision 0, " Preparation, Maintenance, and Control of
E&ESD Quality Assurance Manual."
ERC committed to the following actions to resolve this
deviation: recall of corporate QA program and procedures
manuals which were generic manuals rather than client or
project specific; evaluate the controlled distribution of
site specific CPSES QA/QC Review Team Management Plan and
Procedures Manual (QA Manual) to determine issuance on an
as-needed basis; evaluate impact of improper QA Manual
_ - _ _ _
i
. .
19
control on performed work; verify issued onsite QA
Manuals are current; and assign distribution
responsibility of future QA Manual changes to the onsite
l QA/QC records administrator. These actions were to be
i completed by August 28, 1986.
1
l The NRC inspected implementation of these commitments by j
verifying the following. Corporate manuals were removed
from the site. Distribution of controlled onsite manuals
was reduced from 44 to 11. Eight ERC personnel and three
non-ERC personnel now hold controlled copies of ERC
onsite manuals. The NRC inspector confirmed that work i
was not impacted by improper QA Manual control by
verifying that those individuals performing vork j
activities had the appropriate procedure at their work j
location. The NRC inspector's review of ERC's QA/QC 1
Surveillance Report II-8635 confirmed that controlled QA )
Manuals were current to June 9, 1986, Table of Contents, j
The review by the NRC inspector'of distribution for five {
manual revisions made from April 3, 1986, to August 28, i
1986, confirmed their accuracy and that the onsite QA/QC 1
records administrator now distributes such changes. The
NRC inspector reviewed six controlled QA Manuals and
found them current. Based on the NRC inspector's !
verification of implementation of these ERC commitments, l
this item is closed. j
n. (Closed) Deviation (445/8607-D-08): ERC's Audit Status
and Audit Action Request Logs were not maintained in
accordance with ERC Procedure ERC-QA-18, Revision 0,
" Administration of Quality Assurance Auditing."
ERC committed to assigning an individual the
responsibility to maintain the subject logs and to update
the incomplete entries. The NRC inspector verified that
a lead auditor had been assigned the responsibility for
maintenance of the subject logs. Both logs were examined
by the NRC inspector for the time interval of September
1985 through February 1987. Entries resulting from
12 ccmpleted audits were reviewed and were found to
conform to procedural requirements. Accordingly, this
item is closed.
o. (Closed) Deviation (445/8615-D-01): A certified Level II
overview inspector's experience as stated did not meet
the requirements of CPP-003, Revision 3.
ERC obtained further documented information concerning
this inspector's previous experience on August 12, 1986,
which the NRC inspector reviewed. The NRC inspector
agrees that based on this clarification, the individual
was qualified as a Level II inspector. A documented
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _-
.
20
review was found to have been performed by ERC beginning
in June 1986 to determine if this was an isolated
l occurrence. From ERC's review of the 10 overview
i
inspector qualification and certification files, this
instance was determined by ERC to be isolated. The NRC
inspector also performed a file review which confirmed
,
ERC's finding. With confirmation that committed actions
!
'have been completed, this item is closed.
4. CPRT ISAPs (Excluding ISAP VII.c)
a. Heat Shrinkable Insulation Sleeves (ISAP I.a.1) (25017)
)
The NRC inspection' activities for this ISAP were
documented in NRC Inspection Report 50-445/86-31;
50-446/86-25, with the exception of evaluating the root
causes and identifying corrective actions. Subsequent to
'
the above inspection, the applicant submitted Revision 1
.
of the results report (RR) dated December 30, 1986, to
l the NRC by letter dated January 16, 1987. I
Establish Root Causes/ Safety Implications (NRC Reference
_0_1.a.01.13)
NRC inspector review of Revision 1 of the RR showed that ]'
both a root cause analysis (paragraph 5.7) and a generic
implications evaluation (paragraph 5.8) had been
performed.
The CPRT Electrical Review Team (ERT) determined that an
adverse trend had been identified by this ISAP. This
determination was made because conditions similar to the ,
unacceptable CPRT inspection findings could exist in
harsh environments and compromise the integrity of the
environmental seal.
In addition to the above analysis and evaluation, a
generic implications evaluation was also performed. The ;
generic implications evaluation was included by the ERT '
because of the possibility of undetected heat-shrinkable
insulation sleeve (HSI) deviations located in harsh
environments. If such conditions exist, inadequate
protection of the cables and/or connections could result.
The NRC evaluation of the RR will be handled as a
separate issue.
Based on the above, the NRC inspection of this reference
item is complete,
i
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l
. . 1
21
1
Identify Corrective Action (NRC Reference 01.a.01.14)
In paragraph 5.9.of the RR, the ERT recommended'the
following corrective actions for the adverce trend ,
discussed above: (1) review the QC documentation for all 1
safety-related HSI installations, and'(2) reinspect all I
'
safety-related HSI installations located in harsh
environments. The results of these.two actions would
then be evaluated to determine if any further actions
would be required. The NRC inspector will review the
completion of the above actions, and third-party overview
of them, when completed. This is an open item
(445/8706-0-04).
The RR also. stated that the revised craft (EEI-8) and QC
(QI-QP-11.3-28) procedures should preclude problems with
HSI in future installations. NRC inspector concurrence
with the above was contained in the NRC inspection report
referenced above.
Based on the above findings, the NRC inspection )
activities for this ISAP are complete except for the open j
item identified above.
b. Inspections of Butt Splices (ISAP I.a.2) (51063) J
l ;
l The CPRT inspections of AMP Preinsulated' Environmentally
'
Sealed (PIES). splices committed to by this ISAP have been-
l addressed in previous NRC inspection reports. The l
l program and the completion of the Phase I and Phase II l
l inspections were discussed in the NRC Inspection Reports
50-445/85-16, 85-18, 86-01, 86-07 and 86-15 for Unit 1.
The remaining NRC reference activities are discussed
below.
Phase III Inspections and CPRT Overview (NRC References
01.a.02.11 and 01.a.02.13)
The NRC inspection of the Phase III inspection activities
was discussed in NRC Inspection Report 50-445/86-16;
50-446/86-13: the condition of a HSI sleeve overlapping
the fiberglass braid of the conductor jacket was .
I
identified. The NRC inspector reviewed the completed
CPRT file for this ISAP and observed that, in. addition to
discussing the physical inspections in a number.of-
c memoranda, CPRT overview activities and recommendations
! were also included. The completion of the overview
inspection was documented in ERC memorandum QA/QC RT-5089
dated December 8, 1986.-
The CPRT overview inspection identified four unacceptable
l splices which were documented to have been replaced.
L
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_ _ _ _ . _ _ _ . _ -
_ _ ..
1
. .
22
i
Based on the overview inspection and the applicant's 1
'
project inspector findings during the Phase III
'
inspections, the ERT issur' memorandum CPRT-803 dated
January 22, 1987. This me- .ndum included the
recommendation to the Projec'. that "the scope of
reinspection in Phase III be expanded to include all l
Class 1E cables (essential and associated) in Units 1, 2 i
and Common that might have been terminated to vendor 1
pigtails using AMP PIES splices prior to June 13, 1985." )
(Procedural controls in effect subsequent to June 13,
1985, should preclude the types of problems identified,
see NRC Inspection Report 50-445/86-07; 50-446/86-05.)
The completion of these recommended inspections is an i
open item (445/8706-0-05; 446/8705-0-02). !
l
Based on the above findings, NRC inspection of these I
activities'(NRC References 01.a.01.11 and 01.a.02.13) is i
complete, except for the open item identified above. 4
I
Root Cause and Corrective Action (NRC Reference
01.a.02.14) l
NRC inspector review of Revision 1 to the RR dated
April 1, 1987, showed that a root cause had been
determined. The RR stated that the ERT concluded "The
,
primary root cause was inadequate craft installation
'
procedures and a principal contributing cause was
inadequite QC inspection procedures." These issues were
also discussed in NRC Inspection Report 50-445/86-07;
50-446/86-05. The recommended corrective action was i
discussed above. Based on the NRC inspector '
determination that the ISAP requirements to establish a
'
root cause and recommend corrective actions have been
fulfilled, NRC inspection of this activity is complete.
i
Training of Third Party Inspectors (NRC Reference
l 01.a.02.15)
The NRC inspector reviewed the CPRT files for the
personnel associated with this ISAP and determined,
,
'
through the review of numerous memoranda, that the
required inspector training had been conducted. The
majority of the memoranda: (1) directed the third party
personnel to read various action plan documents and PAGs
and (2) documented that these reading assignments had
been completed. ERC memorandum QA/QC RT-060 dated March
20, 1985, documented the certification of the electrical
inspectors for various tasks. In addition, the NRC
inspector reviewed the training plan for ISAP I.a.2 and
found that it covered the radiography, visual checks, and
pullout tests for the splices. The CPRT inspectors also
_ ..
1
~
23 4
l
signed an attendance sheet indicating that they had read
the involved test procedure.
Based on the above review, the NRC inspector determined
that requirements of this reference item and hence NRC
l inspection are complete.
Inspector Certification (NRC Reference 01.a.02.16)
Section 4.3 of Revision 4 to this ISAP states, in part,
"Where tests or reinspection require the use of
certified inspectors, qualification at the appropriate
level will be to the requirements of ANSI N45.2.6."
Since a pullout test program was conducted to verify the j
acceptability of the splices, a discussion of this
l requirement was contained in the RR. The RR st ited that
i the qualification requirements were not a part of the "
l CPRT Program Plan at the time of testing, but the
l individuals supervising the tests were sufficiently
qualified to render the tests valid. The NRC inspector
identified two memoranda in the CPRT file which discussed l
why the Review Team Leader (RTL) determined certification '
to ANSI N45.2.6 was not necessary for the Issue
Coordinator (CPRT-860 dated March 19, 1987) or the )
Electrical Engineering Adviser (CPRT-858 dated March 18, l
1987). The memoranda discuss the involvement of the two
individuals in formulating the program and test
'
procedures as well as their professional qualifications.
The NRC inspector found this information to be
acceptable.
1
Based on the above review, NRC inspection of this
reference item is complete.
Personnel Qualifications and Objectivity (NRC Reference
01.a.02.17)
The ISAP required the involved CPRT personnel be
qualified in accordance with the Program Plan,
Section VII. The'NRC inspector reviewed the resumes and
objectivity questionnaires for the RTL, past and present;
the Issue Coordinator, past and pre:sent; and the
Electrical Engineering Advisor. Based on this review,
the inspector determined that the requirements of the
ISAP were fulfilled for these five individuals. In
addition, the RTL evaluation of the objectivity
questionnaires was documented in the CPRT files.
l
'
The NRC inspection of this reference item is, therefore,
complete.
!
,
L________________
,
i
i
=
,
,
24 ]
l
2
I
c. Flexible Conduit to Flexible Conduit Separation
(ISAP I.b.1) (51063)
'l
Analysis of Circuits (NRC Reference 01.b.01.01
The NRC inspector reviewed the CPRT files to determine if
the committed to analysis had been completed. The i
circuit evaluation was contained in two files; circuit i
analysis and computer analysis. The NRC inspector noted
that the ERT approved the above analysis in memoranda j
CPRT-679 dated October 15, 1986, CPRT-701 dated i
October 22, 1986, and CPRT-738 dated November 6, 1986. !
I
NRC evaluation of the analysis will be handled separately 1
as part of the RR evaluation. However, the establishing !
of the analysis and ERT review of the analysis fulfills
the CPRT commitment. NRC inspection of this reference
item is complete. j
i
Third Party Inspections and Examinations of Other Panels l
(NRC Reference 01.b.01.05 and .08) l
The NRC inspectors reviewed the current separation
criteria and the separation criteria required during the
third-party inspections under ISAP I.b.1. The NRC i
inspectors determined that the current separation
criteria were contained in numerous design change
authorizations (DCAs) and NCRs. The most comprehensive
source of separation requirements was found in DCA 21446
to the Cable and Raceway Separation Typical Details
Drawing 2323-El-1702-02. Revision 1 of this DCA dated
October 8, 1985, incorporated the wiring separation
criteria which was supported by the analysis and test
results prepared in response to this ISAP. The NRC
inspector also reviewed the separation criteria,
contained in DCAs 25487 dated January 22, 1987, and 14354
dated September 3, 1982, and the separation allowed
between nonsafety and safety-related cables in 480 VAC
switchgear cabinets that is delineated in NCR E83-004535,
! Revision 2, dated August 1, 1983. The separation
criteria used by the third-party QC inspectors was
delineated on Drawing 2323-El-1702-02, Revision 2, CPRT
QI-004, Revision 4, and Gibbs and Hill (G&H) letter
GTN-69715 dated December 27, 1984.
'
After reviewing the above separation criteria, the NRC
inspectors selected a sample of panels for inspection.
The panels selected were from the Unit 1 main control
boards, Common ventilation control panels, and other
l Unit 1 or Common panels containing two or more wiring
l trains (i.e., Trains A and B are safety related, Train C
i is nonsafety related).
_ _ _ _ _
. .
25 i
i
The NRC inspection of these selected panels, which had .
been previously inspected by the third-party inspectors, !
included a comparison of the observed separation
distances to the criteria used by the third-party
inspectors and to the current criteria. The NRC
inspection findings were then compared to the CPRT '
required inspections (NRC References 01.b.01.05 and .08)
to evaluate the effectiveness of those inspections. The
following findings were identified:
Main Control Board (CP1-ECPRCB-04)
(1) The Train A wiring at TB6-96 and TB6-97 was 5/8"
from a Train C, 120 VAC lighting conduit.
(2) The Servicair flexible conduit (Servicair flex)
containing nontefzel cable, NK131041, was 1 1/4"
from a Train A switch (1/1-8875C). (The separation )
requirements are different for tefzel insulated
conductors than for those conductors with other than
tefzel insulation. Tefzel is a brand name for a
l
specific type of insulation.)
l
l (3) Train A cable E0139485 was 2" from Servicair flex ,
l containing nontefzel Train C cable NK131041. I
(4) A Train C 120 VAC lighting wireway was 5/8" from a
Train B wireway.
(5) A Train C 120 VAC lighting wireway was mounted on
Train A wireway next to TB6. 1
l (6) A Train A wireway was touching a Train C 120 VAC
lighting wireway.
(7) The Servicair flex containing nontefzel Train C
cable NK131042 was 1/4" from the side of Train B
device (1/1-8890B).
I
(8) A Train C 120 VAC lighting wireway was 3/4" from a
.
Train B wf.reway.
!
(9) A Train C 120 VAC convenience outlet cable to Device
- 1-FR-157 was in contact with both a Train B cable
- bundle and 3 single Train A wires from Device
1-8811B.
'
(10) A Train C nontefzel cable in Servicair flex from a'
l Gaitronics device in the rear of the cabinet was in
l contact with a Train A wireway and a Train B tefzel
! Servicair flex covered cable.
l
I
_ _ _ _ _ _ _ . _ _ _ _ . . . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
-_
<
.
26
(11) A Train B tefzel cable was 1" from a Servicair flex
covered, nontefzel Train C cable going to Device
M203.
(12) A number of devices were found to have Servicair
flex covering the cables connected to them, but the
flex did not have connectors installed as shown on
DCA 8830. This resulted in the condition of the
electrical cables supporting the conduits instead of
the conduits supporting the cables. The NRC
inspector did not identify a requirement for the
connectors to be installed.
Vertical Ventilation Panel (CPX-ECPRCV-03)
(13) A Train A tefzel, Servicair flex covered cable was
touching Train B Devices X-HS-5877 and X-HS-5878.
(14) The firestop material had been removed from the
bottom of the cabinet leaving open access to the
cable spreading room and a plastic pull rope was
attached to a disconnected Kellum grip. The pull
rope had been tied off and was supporting the weight
of the cables and the Kellum grip. The NRC
inspector was later provided a copy of Item Removal
Notice (IRN) EO5884-CB dated October 22, 1985, for
this work in progress.
(15) A Train B tefzel, Servicair flex covered cable was
touching a Train A tefzel, Servicair flex covered
cable.
(16) A Train C 120 VAC lighting conduit was mounted on a
Train B wireway.
(17) A Train A associated, Servicair flex covered cable
was touching a Train B Servicair flex covered cable
going to Device X-HS-5706.
(18) Train C nontefzel cable NK131014 was 1 1/8" from a .
'
Train B tefzel Servicair flex covered cable.
l
(19) The Train B Servicair flex covered cable from Device
X-HS-5706 was touching a Train C wireway.
(20) Train C nontefzel cable NK131013 was 4 3/8" from a
Train B, Servicair flex covered' cable for Device
X-HS-5706.
l (21) A Train A associated Servicair flex covered cable
was touching a Train B wireway.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ - . . - - - - _ _ _ d
! .. .
27
l (22) The Train A tefzel, Servicair flex covered cable
l from Device X-HS-5877A was touching Train B tefzel
Servicair flex covered cable from Device X-HS-5877B.
(23) A Train A Servicair flex cable was 3 3/4" from
nontefzel cables to Device M-245.
(24) Train B nontefzel, Servicair flex covered cables
were 4" from Train C nontefzel cables to Device
M-245.
(25) Train-B tefzel cables were 4" from nontefzel cables
to Device M-245.
(26) Train C 120 VAC lighting cables on TB7 and TB8 were
measured to be 3" to 3/4" from Train A and Train B
wireways.
(27) Train C nontefzel cables were 1 1/2" from Train B
nontefzel Servicair flex covered cables near Device
M-245.
1
Balance of Plant (BOP) Analog Rack (CPX-EIPRCI-07)
(28) Train C cable NK140356 was in contact with Train B
cable, EG006930.
(29) Train C cable NK140356 was 3/4" from Train B cable
EG136195 and 1 1/4" from Train B cable EG136198.
l
'
(30) Train B associated cables AG134843 and A3139180 were
1 1/4" from Train C cables NK140357 and NK131085.
l
BOP Analog Rack (CPX-EIPRCI-02)
(31) Train B cable EG105711 was touching Train C cables
NK131102 and NK111085.
(32) The field cables coming into the bottom of the
cabinet contained a Train C cable bundle attached to
the Train B cable bundle.
BOP Analog Rack (CPX-EIPRCI-06)
(33) Train A cables EOOO6927 and AO109355 were touching
,
Train C cables NK140015 and NK131084.
(34) Train A cables E0136186 and E0136881 were 1 1/4"
i from Train C cable NK140353.
I
i
_ _ - - _ - - - _ _ _ .
. .
28
480 Volt Switchgear 1EB2 (CP1-EPSWEB-02)
l (35) Train B cables EG146409 and EG104643 were touching
! Train C power cables in compartments 5B, SC, and SD.
480 Volt Switchgear 1EB1 (CP1-EPSWEB-01)
1
(36) Train A cables were touching Train C power cables in
compartments 5B, SC, SD, and 6D.
Containment High Radiation Monitor Panel (1-RE-6290A)
(37) Train A cables E0028509 and EOO28508 were touching
Train C cables.
Sample Valve Panel (CP1-EIPRLV-08)
(38) Train B cables were touching a Train C 120 VAC
lighting conduit and outlet box.
The NRC inspectors then reviewed the CPRT inspection
records to determine if all of the findings presented
above had been documented as deviations during the CPRT
required inspections. However, the NRC inspectors
recognized that inspection and/or modification activities
occurring within the panels subsequent to the CPRT
< inspections could have led to some of the present
separation problems and could have resolved some of the
earlier problems. The NRC inspectors' review of various
- CPRT and facility records to ascertain the status of the
inspection findings disclosed the following:
(1) The CPRT inspection files documented a total of
233 separation problems in the main control boards
and the vertical ventilation panels; an additional
61 separation problems were documented for other I
panels. Comparison of CPRT and NRC inspection
findings showed that items 9, 10, 11, 13, 15, 17
through 28 and 31 through 38 had also been
documented by the CPRT inspectors. The NRC
l inspector considered the documented results of the
CPRT inspections to be acceptable and, therefore,
that the requirements of this inspection activity to
l have been fulfilled.
i
'
(2) The separation problems identified in BOP Analog
Racks (Items 28, 29, 31, 32 and 33) had been
documented in NCR E81-000905, Revision 1. This NCR
referenced the Westinghouse-Certificate of
Qualification, CQ-W9525, as the justification for
not requiring physical separation of the
l
safety-related and nonsafety-related wiring.
!
'
. _ _ _ _ _ _ _ _
,
i
.
. ..
29.
(3)- The separation' problem identified in the Containment
-Radiation Monitor panel (Item 37) had been
documented in NCR E86-103497X; the NCR was still
open awaiting disposition.
~
(4) lThe separation problems identified in the 480 volt
switchgear cabinets (Items 135 and 36) had been
documented-in NCR E83-00453S,. Revision 2. The
disposition of the'NCR-stated, "These non-Class 1E
cables'are isolated from Class 1E circuits by
tripping of the 480V switchgear breakers. As such,
these cables are tagged NK. These cables do not
u require physical separation from Class 1E wiring in.
( the switchgear (reference GTN-66801)." The NRC
'
inspector then reviewed G&H letter GTN-66801. -This
letter stated that a design review had been .
performed and contact between Train C power cables
and Train'A and B control wiring was allowed.
(5) The following items, which did not meet the
separation criteria that was in effect at the time
of the NRC inspection, were documented as follows:
. Main control Board - Items 1, 4, 5, 6, 8 and 9
were documented in NCR E85-101512S' dated
November 1, 1985.
. Common Ventilation Control Panel - Items 16 and'
26 were documented in NCR E85-1015895 dated
November 1, 1985.
. Sample Valve Panel - Item 38 was documented.in
NCR E84-100728S, Revision 1, dated October 31,
1986.
This is an open item pending dispositioning of the
NCRs (445/8706-0-06).
(6) The remaining items, while not meeting the earlier
separation criteria, were determined to' meet the
criteria in effect at the time of the NRC
inspection.
An additional problem related to electrical. terminations
was identified by the NRC inspectors on March-12, 1987,
while performing this separation inspection. The NRC
inspectors identified a lugged, but unterminated,
electrical conductor during the inspection of Common
Ventilation Panel 3 (CPX-ECPRCV-03). Since1the usual
practice when a conductor is spared is to cut'off the
terminal lug, the' inspector pursued theDreason for this
_ _____- - - __ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ __ _ ._ _ _ -__ __ ._ - _ - _ _
- _ _ _ _ _ _ _ - _ _ .
. .
30
l
lifted lead. The conductor was identified as the gray
conductor of Cable E0016583.
When questioned, appli: ant personnel initially informed
the inspectors that the lead should have been landed and
that there was no apparent reason for it to have been
disconnected. Applic6nt personnel further stated that
the lifted lead woulG have been identified by the
prerequisite (Step 4.5) of Start-up Test XCPEE20. The
applicant personnel informed the NRC inspectors that the
lead provided the closed indication for a control room,
motor operated, ventilation damper (CPX-VADPOU-45) which
is normally open and fails-as-is. NRC inspector review
of Figure 9.4-1, Amendment 51 of the FSAR showed this
damper is open in the Emergency Ventilation Mode. When
this condition was brought to the applicant's attention
by the NRC inspector, applicant personnel wrote
Deficiency Report (DR) P87-0090 on March 13, 1987, to
document the determinate gray conductor.
Subsequently, on April 9, 1987, applicant personnel
informed the NRC inspector that the lifted lead was
actually the black conductor of cable E0016583; the cable
did not include a gray conductor and the black color was
very light. The black conductor had been spared in
response to Package Process Form (PPF) 002 dated March 1,
1984, as implemented by Startup Work Authorization (SWA)
20656 completed on June 23, 1984.
The lack of a clear color code of the conductor and the
lack of procedural control for handling spare and spared
conductors caused this misunderstanding. The NRC
inspector has discussed these concerns with the applicant
personnel on a number of occasions; however, the
applicant does meet regulatory requirements.
TU Electric Inspections (NRC Reference 01.b.01.06)
The ISAP required separation inspections by project
personnel if the revised separation criteria differed
from the project criteria which had been used for the
CPRT inspections. The NRC inspector verified that these
inspections had been performed by reviewing the CPRT
files. The findings of the inspections of Unit 1 Main
Control Board Panel 4 (CP1-ECPRCB-04) and Common
Ventilation Panel 3 (CPX-ECPRCV-03) were documented in
NCRs E85-100438S, E85-101512S and E85-1004475. The above
inspections fulfilled the requirements of this activity
and NRC inspection of this activity is complete; however,
the above.NCRs have not, as yet, been dispositioned.
This is an open item pending disposition of these NCRs
(445/8706-O-07).
l
- .
)'
31
1
Revision of Unit 2 procedures (NRC Reference 01.b.01.07)
The revision of the Unit 2 procedures was documented in'
NRC Inspection Report 50-445/86-03; 50-446/86-02. During
'
this inspection period, the NRC inspector, through a
review of the CPRT files, verified that the ERT had
approved the procedure revisions. CPRT memorandum
CPRT-434 documented the RTL and Issue Coordinator review
and approval of the procedures. Based on the above, the j
NRC inspector determined that the requirements of this
activity have been fulfilled; therefore, NRC inspection
of this activity is complete.
Correction of Unit 1 Deficiencies (NRC Reference
01.b.01.09)
The ISAP required all deviations to the final project I
separation criteria to be noted on NCRs. The NRC
inspector reviewed the CPRT files and verified that the
identified separation problems were documented on NCRs.
A discussion of these NCRs is included above, in NRC
References 01.b.01.05 and .06.
The implementation of this activity is complete, and NRC
inspection of this reference item is also complete.
Root Cause Determination (NRC Reference 01.b.01.10)
The NRC inspector reviewed the RR, Revision 1, dated
December 10, 1986. Section 5.9 of the RR states that
since no deviations were found, no safety significance
evaluation, root cause analysis, or evaluation of generic
implications were performed. The NRC inspector noted
that the lack of identified deviations was related to the
revised separation criteria which presently allows
conduit of redundant trains to be in contact with one
another. The acceptability of this separation criteria '
.
is under NRC review and will be addressed in future
correspondence. Since the requirements stated in the
ISAP have been fulfilled, the NRC inspection of this
reference item is complete.
NRC evaluation of the RR will be handled separately.
The NRC inspection of ISAP I.b.1 is complete; the open
items addressed above will be followed as inspection
findings.
!
. _ __
g
. ,
1
32 l
{
{
d. Barrier Removal (ISAP I.b.4) (51063)
The rework activity to correct the problems identified by ;
the NRC TRT were verified and documented in NRC
,
Inspection Report 50-445/86-01; 50-446/86-01. The
! revision to the applicable maintenance procedures was
also discussed in that inspection report; however, the
NRC inspector noted that the RTL had not documented the
ERT approval of those procedures at that time.
Maintenance _ Procedures Revision (NRC Reference
01.b.04.02)
The NRC inspector re-reviewed the CPRT files and verified
ERT review and approval of the maintenance procedures and
other germane documents as evidenced by the following
memoranda:
(1) CPRT-484 dated June 23, 1986, documented the ERT
review of the electrical erection specification
(ES-100, Revision 2), the separation criteria
drawing (2323-El-1702-02, Revision 2), and the QC
inspection procedures (QI-QP-11.3-28, Revision 30;
-40, Revision 23; and -55, Revision 4); and
l
(2) CPRT-656 dated September 17, 1986, documented the
ERT review of Procedures STA-606, Revision 6;
,
MDA-107, Revision 0; INC-101, Revision 4; QAI-005,
!
Revision 2; and Inspection Plan 037, Revision 1.
In addition, the ERT review of the craft training was
documented in memoranda CPRT-619 dated September 2, 1986,
and CPRT-765 dated December 8, 1986.
The NRC inspector also reviewed the craft training plan
for separation requirements, attached to memorandum
NE-1165 dated September 29, 1986, and found it to be
acceptable.
Based on the above reviews and the inspections discussed
above, the NRC inspection of this reference item is
complete.
,
Use of Results (NRC Reference 01.b.04.03)
The NRC inspector reviewed the RR for this ISAP
(Revision 1 dated December 17, 1986) which was submitted
to the NRC by letter dated January 16, 1987. The results
of this ISAP were used to perform a root cause analysis,
establish generic. implications and recommend corrective
actions.
- - - _ _
_ _ _ _ - - - - -
,
_
~ '
33
i
l
1
The CPRT found that the corrective actions, if adequately ]
2
implemented would correct the identified problems and
resolve the root causes for the Unit 1, Unit 2 and Common
multi-train panels.
NRC evaluation of the RR will be handled separately. )
!'
The requirements of this activity have been fulfilled and
NRC inspection of this reference item is complete.
e. Guidelines for Administration of OC Inspector Tests
(ISAP I.d.2) (35061) i
The following activity for ISAP I.d.2 was reviewed by the
NRC during this report period.
<
Special Evaluation Team Evaluate Effectiveness of i
Procedure Revision (NRC Reference 01.d.02.03) l
l
To evaluate the effectiveness of the revised I
training / certification Procedure CP-QP-2.1, " Training of i
Inspection Personnel," the NRC reviewed recent l
certifications and recertifications for 10 TU Electric QC j
inspectors. These certifications and recertifications )
were reviewed for compliance with the applicable revision i
of CP-QP-2.1 (Revisions 18, 19, 20, and 21 were found I
applicable) and for conformance to the requirements of I
ANSI N45.2.6-1978 and Regulatory Guide 1.58, Revision 1. j
The results of the NRC review found no deviations from i
Procedure CP-QP-2.1 nor from the ANSI Standard and the j
Regulatory Guide. A previously reported violation !
(445/8518-V-03; 446/8515-V-02) was closed in NRC
Inspection Report 50-445/87-01; 50-446/87-01 based on- !
CP-QP-2.1, Revision 21, defining the qualification
responsibility and certification authority of discipline
Level III inspectors.
No violations or deviations were noted. No further NRC
I
inspection of this reference item is planned.
f. Maintenance of Air Gap Between Concrete Structures
(ISAP II.c) (46053)
l The following activities for ISAP II.c were reviewed by
l the NRC inspector during this report period:
l
l Reinspect and Assess As-Built Condition (NRC Reference
02.c.01.00)
The NRC inspector has evaluated the reinspection of the
initial (prior to ISAP II.c corrective actions) as-built
i gap condition as documented in NRC Inspection Reports
- _ - _ _ _ _ _ _ _ _
1
- *
34
i
i
50-445/86-01, 50-446/86-01;.50-445/86-15, 50-446/86-12; j
and 50-445/86-22, 50-446/86-20.
No violations or deviations were identified and no
further NRC inspection of this reference item-is planned. 1
i
Removal of Debris or Retofoam (NRC Reference 02.c.02.00) j
. . . .
. 1
l The NRC inspector has witnessed the. removal of debris and H
rotofoam in numerous gaps.using a variety of equipment
and techniques. These activities were. documented in NRC
l- Inspection Reports 50-445/86-01, 50-446/86-01;
I 50-445/86-03, 50-446/86-02; 50-445/86-07, 50-446/86-05;
50-445/86-15, 50-446/86-12; 50-445/86-22, 50-446/86-20;
and 50-445/86-26, 50-446/86-22. i
No violations or deviations were identified. .Further NRC
inspection activity will be confined to monitoring of the
status of the gap cleaning process.
Documentation of Final As-Built Condition (NRC Reference
02.c.04.00)
The NRC inspector witnessed.QC inspections of the final )
as-built condition of seismic gaps subsequent.to debris
{
removal and/or width modifications. The applicant's
inspection of gap width and condition was performed per
QI-QP-13 . 0-16. The applicant's inspection of concrete
surfaces within the gaps was performed per QI-QP-11.0-5. .
These inspections were documented on the following {
construction operation travelers. 1
'
Traveler CE87-1979-02-8903
Inspection of the. secondary wall separation gap,
diesel generator building, Unit 2.
Gap width, gap condition, and concrete surfaces were
satisfactory. Minimum gap observed was 3/4",
minimum allowed was 5/8".
t
Traveler CE87-1973-02-8903 '
'
Inspection of the secondary wall separation gap,
safeguards building, Unit 2. ;
Gap width, gap. condition, and concrete surfachs wEr
satisfactory. Minimum gap observed was 1 1/2",
minimum allowed was 1".
a
s
4
, u ,
+ '
$;
l
j' .'
+
'/ ik
~
r-~
]
i
1
'
35
1
! j
Traveler CE87-1968-01-8903 l
Inspection of the secondary wall separation gap, q
safeguards building, Unit 1. j
i
Gap width and condition was satisfactory. ' Minimum
gap observed was 1 3/4", minimum allowed was 1". ,
Concrete surfaces were unsatisfactory as the QC l
inspector was unable to verify the type of coating ;
on exposed rebar. These conditions were documented j
by the applicant in an inspection report (IR). '
Traveler CE87-1969-02-8903
l
Inspection of the secondary wall separation gap,
'
safeguards building, Unit 2. Gap width, gap
condition, and concrete surfaces were satisfactory.
l Minimum gap observed was 1 1/2", minimum allowed
was 1".
Traveler CE87-2019-02-8902
i Inspection of the secondary wall separation gap,
reactor building, Unit 2.
Gap width and condition were satisfactory. Minimum
gap observed was 1 1/4", minimum allowed was 7/8".
Concrete surfaces were unsatisfactory as exposed
rebar was observed located at the surface of the top
of the wall within the gap. These conditions were i
documented by the applicant in an IR.
Traveler CE87-1843-8904
Inspection of the secondary wall separation gap,
electrical control building, Unit 1. j
l
The QC inspector was unable to inspect gap width, I
gap condition, and concrete surfaces as the gap was !
partially sealed. These conditions were documented I
by the applicant in an IR and rework was initiated. 1
l
l
1
I
____ - _ _- A
' '
36
Traveler CE87-1729-8903
Inspection of the single wall gap between safeguards
building and reactor building, Unit 1.
Gap width was less than the allowable minimum of
2 3/4" in several areas and was noted on the IR as
being unsatisfactory. Inspection of gap condition
and concrete surfaces wc ;iot completed, as rework
is required to increase gap width.
Traveler CE87-1731-8901
Inspection of the single wall gap between fuel
building and reactor building, Unit 1.
Gap width was less than the allowable minimum of
1 3/4" in several areas and was noted on the IR as
being unsatisfactory. Inspection of gap condition
and concrete surfaces was not completed, as rework
is required to increase gap width.
The minimum allowed gap dimensions were specified in
three DCAs. DCA 21829, Revision 6, lists minimum gap
values for double wall, single wall, and basemat gaps for
Unit 1 and common structures. DCA 24214, Revision 4,
lists minimum gap values for double wall, single wall,
l
and basemat gaps for Unit 2. DCA 31556, Revision 0,
l lists minimum gap values for secondary walls in Units 1,
2 and Common.
The maximum gap values were specified in DCA 25562,
Revision 1 (Unit 1 and Common) and DCA 24799, Revision 1
(Unit 2). The maximum allowable gap is 2" greater than
the gap dimension specified on the design drawings.
The above DCAs and the supporting calculations will be
reviewed as part of NRC Reference 02.c.03.00.
The NRC inspector verified that the above inspections
were performed per Procedures QI-QP-11.0-16 and
QI-QP-11.0-5. NRC inspections will continue during
subsequent report periods.
During these inspections, the NRC inspector observed
exposed noncoated and coated rebar at the surface of the
concrete within the gap being inspected. The current
inspection procedures require that all exposed rebar be
coated with Bitumast No. 50 to retard corrosion. Some of
this rebar was apparently exposed during gap widening and
cleaning activities. The existence of exposed rebar
within the gap indicates that additional rebar has less
. _ - _ -
,
- '
37 j
l than adequate concrete coverage. In addition, the
! eduction in wall thickness could affect the structural
integrity of the wall. The significance of the exposed
rebar, potential for additional rebar to have less than
adequate concrete coverage, and the reduction in wall i
thickness is an open item pending justification that the i
walls remain in compliance with the ACI Code and the FSAR
(445/8706-0-08; 446/8705-0-03). j
No violations or deviations were identified. ;
!
Review Procedures for Gap Maintenance (NRC Reference
02.c.06.00)
The NRC inspector reviewed historical and current TU ]
Electric QC procedures for seismic gap inspection and )
maintenance. The review was done primarily to: l
(1) assess the adequacy of current procedures for '
inspections and preventive measures instigated as a
l
'
result of ISAP II.c; and (2) assess the sequence of
events leading to the existing condition. The latter
objective is addressed in this report under NRC Reference
02.c.08.00.
Procedure QI-QP-ll.0-3, Revision 4, " Concrete or Mortar
Placement Inspection," was revised as a result of this ,
ISAP to add a listing of seismic gap boundaries and to l
add requirements for gap inspection and maintenance both
during and after cleaning. The gap boundaries were
initially identified from arrangement drawings showing
interfacing gaps between the seismic Category I l
structures listed in FSAR Section 3.2. Additional
seismic gaps were added to subsequent revisions of this
procedure as the scope of ISAP II.c was expanded.
Inspection requirements were added in Revision 5 of
QI-QP-ll.0-3 to address: (1) the as-built inspection of
the seismic gaps, (2) documentation of both the initial
and final condition of the gaps, (3) debris removal,
(4) both temporary and permanent seals or barriers to
preclude intrusion of debris into the gaps, and (5) final
QC inspection. Revision 5 included gaps between seismic
Category I structures described above. Revision 6 added
gaps between Category I and non-Category I structures
such as the gap between the refueling water storage tank
and the Unit 1 pipe tunnel. Also added in Revision 6
were a listing of lowest applicable elevation for each
identified gap (generally grade level) and a provision
for using video equipment for estimating gap width.
Revision 7 added gaps between internal structures and the
containment structure for the Unit 1 and 2 reactor
buildings. Revision 8 added gaps at the top of secondary
_-
_ _ _ _ - __ - -
' '
38
walls and extended inspections to the base mat level for
seismic Category I structures.
The NRC inspector reviewed TU Electric QC Procedure
QI-QP-11.0-16, Revision 0, " Building Separation Gap and
Condition Inspections." This procedure consolidates gap
inspection requirements from previous procedures to
facilitate QC inspector training. The NRC inspector
concurs with the CPET conclusions that the current
procedures adequately address gap inspection and
maintenance.
The NRC inspector also reviewed the following historical
procedures:
CCP-14, Revisions 0 through 4, " Concrete Prepour
Inspection and Pour Card Sign Off."
QI-QP-11.0-5, Revisions 0 through 5, " Inspection of
Concrete Repair."
QI-QP-11.0-3, Revisions 0 through 4, " Concrete or Mortar
Placement Inspection."
CP-QCI-2.4-9, Revisions 0 and 1, " Inspection of Elastic
Joint Filler Material Removal."
CP-QCP-2.4, revisions dated July 14, 1975, February 3,
1977, and December 30, 1977, " Concrete Inspection and
Testing."
These procedures were used by CPRT and the NRC in
evaluating the sequence of events leading to the existing
gap condition. The results of these evaluations are
discussed in this report under NRC Reference 02.c.08.00.
No violations or deviations were identified and no
further NRC inspection is planned for this reference
item.
Determine Generic Implications (NRC Reference 02.c.07.00)
The CPRT determined in paragraph 5.12 of ISAP II.c
Results Report, Revision 1, the following generic
implications:
(1) The root cause of inadequate procedures for
inspection and protection of the seismic gaps
implies that the condition and as-built width of
other critical air spaces is unknown. This is
addressed in ISAP VI.a.
.
.,_ _ _ _ _ _ . _ , _ _ _ _ _ _ - _ _ _ _ _ _ _ . - _ _
I I
I
'
39
'
i
(2) The root cause of inadequately defining construction
tolerances for the width of the seismic gaps will be
addressed by inspecting all gaps and correcting the
width, if necessary (unless otherwise justified).
This root cause will be considered within DAP and by
l the QA/QC Review Team.
1
(3)
'
The root cause of the incorrect initial disposition
of NCR C-83-1067 (see discussion of NCR C-83-1067
under NRC Reference 02.c.08.00) was investigated by
evaluating other NCRs approved by the same engineer )
in a six-month time frame. No other technically
incorrect dispositions were identified by CPRT. A
comprehensive investigation (not a CPRT activity or
, ISAP) of the technical adequacy of NCR dispositions
l is being performed by TU Electric and overviewed by
l
dam .
The NRC inspector verified that generic implications were
determined and documented. The validity of the generic
implications will be evaluated as part of the NRC review
of the results report for ISAP II.c.
No violations or deviations were identified and no
further NRC inspection is planned for this reference
item.
Assess Fequence of Events Leading to Existing Condition
(NRC Reference 02.c.08.00)
CPRT reviewed documentation in an effort to assess the
sequence of events leading to the existing gap condition
and to determine root cause and generic implications.
The documentation included correspondence between the
engineering and construction organizations, concrete pour
and inspection procedures, inspection reports, and NCRs
written regarding seismic gap width and debris. The CPRT
review was documented in the ISAP II.c working files.
The following files were reviewed by the NRC inspector:
(1) Review of Project Procedures, II.c.4f-002 dated
June 18, 1986.
(2) Review of Historical Documents Related to Seismic j
Gap, II.c.4f-003 dated June 18,.1986. J
l
(3) Review of Additional Historical Documents Related to
the Seismic Gap, II.c.4f-003 dated August 28, 1986.
1
The NRC inspector reviewed the following historical j
documents related to the seismic gap:
1
_ _ _ -- ______ -_ _ _ _ _ _ _ _ _ _ _
- - _ - _ _ _ _ _ _ _
40
l'
(1) Request for Information or Clarification (RFIC)
C-029 dated January 24, 1976.
(2) Field Problem / Action Request (FPAR) No. 110 dated
February 13, 1976.
(3) G&H Telex GTT-1543 dated September 6, 1977. ;
(4) TUSI memorandum, TUS-5012, dated October 7, 1977. l
(5) TUSI memorandum, TUS-5019, dated November 2, 1977.
(6) G&H letter to TU Electric, GTN-71282, dated March 6,
1986.
(7) B&R QA checklists for CP-QCI-2.4-9, " Inspection of
Elastic Joint Filler Material Removal Checklist,"
both date'd January 3, 1978. 1
(a) Fuel building location AF/IF-5F; elevation
810'6" to 813'6".
(b) Auxiliary building radius wall 9B-LA; elevation
810'6".
(8) G&H memorandum, GHF-2390, dated January 30, 1978.
(9) B&R memorandum, IM-12939, dated February 19, 1978. ,
l
(10) Inspection reports per QI-QP-11.0-3, Revision 0- 1
(a)
'
IR-C-0319 dated September 14, 1978.
(b) IR-C-0320 dated September 14, 1978.
(c) IR-C-7705 dated September 20, 1978.
(d) IR-C-7706 dated October 17, 1978.
(e) IR-C-7707 dated October 11, 1978.
(f) IR-C-7708 dated October 3, 1978.
(11) NCR C-83-01067, Revision 0 dated April 13, 1983,
'
(engineering review / approval dated April 18, 1983).
(12) NCR C-83-01067, Revision 1 dated April 13, 1983,
(engineering review / approval dated November 20,
1985).
(13) B&R letter, BRF-7223, dated October 12, 1977.
41- q
(14) G&H memorandum, GHF-2142, dated October 20, 1977.
(15) TUSI memorandum, TUF-3955, dated November 3, 1977.
(16) B&R letter, BRF-7412, dated November 9, 1977.
1
(17) TUSI letter, TGH-10144, dated November 17, 1977. -
(18) G&H telex, DAX-75, dated; November 28,_1977.-
(19) TUSI memorandum, TUF-4021, dated November 29, 1977.
(20) .G&H memorandum, GHF-436, dated February 16, 1976.
(21) TUSI memorandum,.TUQ-1622, dated April 18, 1983.
(22) TUSI memorandum, TUS-4106. dated April 26, 1983.
The NRC inspector also reviewed historical. procedures
used by CPRT in' evaluating the sequence of events leading i
to the existing gap condition. These procedures are
listed as part of NRC Reference 02.c.06.00.
The root cause determined by CPRT for the presence of
debris and concrete _in the seismic gap was inadequate ,
procedures (for discussion of current procedures, see NRC l
l Reference 02.c.06.00 in this report). Construction l
l procedures lacked requirements for protection of the gap,
j and post-pour verification that the gap was per design.
l QC inspection procedures lacked adequate instructions for'
l
inspection of gap condition (presence of debris), width
and protection. The design parameters for the gap were
,
'
present on the design drawings but were not adequately
incorporated into the QC procedures. QC, engineering,
and construction management.were all~ aware of the
inadequate gap protection during and after construction
but the condition was allowed to go uncorrected. The
concrete found in the gap was in most cases the result of'
form leakage or spillage.
The CPRT concluded that the root cause that led to less
( than design gap width was: (1) the design did not clearly
define how construction tolerances were to be applied to
specified minimum gap widths, and (2) the QC program did
not require regular post-pour verification of the
as-built gap width. CPRT states that construction
tolerances per ACI 301-72 may have been applied to the
minimum gap values listed on design drawings such.that,
in a worst case condition, the as-built gap represents
the minimum design specified value minus the construction
tolerances for each wall.
.
-- _ _ - - _ - - _ _ _ _ - _ - _ - - - - , , - - . _ - _ - - - - - - . - --- ---w- - , - - - . - _ - - ---._.u
.
l
.
42
The CPRT determined the root cause of the incorrect
initial disposition of NCR C-83-1067 to be a technical
error on the part of the responsible engineer. This NCR
identified the presence of debris and unsatisfactory gap
width recorded on two inspection reports written in 1978.
The NCR was written and closed in 1983 and has since been
reopened. The NCR was initially closed based on a
statement that the seismic displacements were less than
those resulting from the pressurization structural
integrity test (SIT). This statement is technically'
incorrect, as FSAR Section 3.8.1.3.2 includes the
factored sum of seismic, pressure, and temperature
effects for the containment.
l
I
The NRC inspector concurs with these conclusions based on
inspection of the documentation listed above.
No violations or deviations were identified and no
further NRC inspection is planned for this reference
item.
l Evaluate the Need to Update the FSAR (NRC Reference
! 02.c.09.00)
The NRC inspector reviewed FSAR Change Request GHCP-080
, dated May 30, 1986. The change request deleted the
l 1" minimum gap width specified at base mat locations
- only. The revised requirement as stated in the change
request is to provide " Sufficient space . . . to prevent
contact during a SSE that would have adverse effects on
the building analysis and design." TU E.lectric has
committed to provide a gap in these areas at least equal
to the minimum required by analysis. Any debris allowed
to remain in the gap must be analytically justified. NRC
review of this analysis is a separate activity (NRC
Reference 02.c.03.00). The CPRT review of this FSAR
change request was documented in the ISAP II.c working
file II.c.4f-004, "FSAR Update Review," dated June 18,
1986.- This file was reviewed by the NRC inspector.
No violations or deviations were identified and no
i further NRC inspection is planned for this reference
item.
NRC inspections were not performed on other ISAP II.c NRC
reference items during this report period..
- _ _ -
<
- .
43
4
g. Design Consideration for Piping Systems Between Seismic
Category I and Nonseismic Category I Buildings (ISAP V.c)
(37055)
With the issuance of the RR on October 29, 1986, the CPRT
,
has completed implementation of this ISAP. The following
l is a summary of NRC inspection activity.
Review and Discuss Events and Reasons for Auxiliary Steam
Pipe Situation (NRC Reference 05.c.02.00)
CPRT review of this task concluded that changing the
isolation anchor to a two-way restraint was acceptable
provided the seismic analysis considered the actual
restraint conditions and loads from both sides of the
interface are included. This was done to alleviate high
thermal stresses on Line 10-SA-X-19-152-S. It was also
shown that G&H evaluated the effect this support change
would have on pipe break locations and that pipe break
locations did not change. A review of records by the
third-party confirmed that, per procedure, the Damage
Study Group (DSG) was notified of the results of the
i reanalysis.
l
'
Further third-party review revealed that the original
seismic interface criteria contained in G&H Procedure
l AB-11, " Structural Anchors Separating Safety Related
Piping Class 2 and 3, ASME III, Seismic Category I from
Non-Safety Piping - Load Calculation Guideline," did not
I
contain criteria to consider a turbine building
structural failure per Section 3.7B.2.8. in the CPSES
FSAR. This review, which confirms the NRC Technical
Review Team (TRT) findings, was documented on
Discrepancy / Issue Resolution Report (DIR) E-0349,
Revision 1, in accordance with DAP-2 and classified as a
deviation.
Additionally, based upon the above third-party review,
DIR D-0098 was issued and classified as an observation.
This DIR deals with the lack of technical justification
for the load factor used to account for interface anchor
loads from the nonseismic piping. The engineering
significance of the DIR cannot be determined until the
piping reanalysis is completed under the SWEC
requalification program. At that time the third-party
will review the technical justification and make a
determination on the adequacy of the original criteria.
The DIR will be reclassified in accordance with the
results of that determination.
The NRC inspector verified, through documentation review,
that the required interaction; i.e., information
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ - - _ _ -
r-
I
i
- *
44
transmittals between G&H and the DSG had occurred. Also,
replacement of the interface anchor with a two-way
restraint is acceptable as long as the actual mode of j
isolation is considered in the analysis. 1
The third-party assigned the responsibility for closure
of DIRs E-0349, Revision 1, and D-0098, including the
safety significant evaluations and root cause/ generic
implicaticas assessments, to the DAP. To facilitate
tracking, this is an open item pending completion of the
SWEC requalification program (445/8706-0-09).
l
No violations or deviations were identified. l
l
[ Recommendations to Project Piping and Supports Program
(PPSP) and/or Design Adequacy Program (NRC Reference
05.c.03.00)
Based on third-party review of the SRT/TRT findings and
the auxiliary steam pipe situation, three recommendations
were made by RLCA:
i
(1) The SWEC requalification program should include
sufficient justification / documentation to
demonstrate compliance with the FSAR commitments
related to piping with seismic /nonseismic
interfaces. Of particular interest are piping
interfaces between seismic and nonseismic buildings.
,
'
(2) Other nonseismic Category I high and moderate energy
piping and restraints should be reviewed and/or
reevaluated as necessary as part of the SWEC
requalification program.
(3) The DA' should address the technical adequacy of the
work performed under the two above recommendations
including criteria and implementation.
By virtue of the issuance of the above recommendation to
-
, the appropriate parties, including SWEC, RLCA has
l completed implementation of this task.
! The implementation of the recommendations are to be
performed by SWEC and reviewed by the third-party under
DSAP IX within the DAP.
'
Based upon review of the ISAP V.c RR and the TRT concerns
!
-_
- ' * 45
which initiated this ISAP, the NRC inspector concurs that
implementation of these recommendations will adequately
address the TRT concerns.
No violations or deviations were identified and no
further NRC inspection of this reference item is planned.
h. Installation of Main Steam Pipes (ISAP V.e) (49065)
Perform Analytical Evaluation of Stress and Support Load
Changes (NRC Reference 05.e.04.00)
During the NRC inspector's review of the RLCA stress
report, an unresolved item (445/8514-U-13) was
identified. Two of the four items were addressed and
closed in NRC Inspection Report 50-445/86-01. The
remaining two items resulted in changes which have been
incorporated into Revision 2 of the RLCA stress report.
l
These items are addressed and closed in paragraph 2.q.
'
above.
Inspection of this reference item is now complete. No
violations or deviations were identified.
Review Procedures and Specifications for Pipe Erection
and Support Placement (NRC Reference 05.e.08.00)
This reference item, along with the subsequent ones to be
addressed, deals with the CPRT actions related to
" Generic Study of Possible Damage to Other Piping." This
review was the first step in the generic study of
possible damage in other piping.
The following specifications / procedures were reviewed by
the CPRT:
Specification / Procedure Revision Title
G&H Specification 5 Piping Erection
2323-MS-100 Specification
B&R Procedure PCP-1 0 Process Pipe
Installation
B&R Procedure CP-CPM-6.9 0 General Piping
Procedure
B&R Procedure CP-CPM-6.9E O Pipe Fabrication
and Installation
B&R Procedure CP-CPM-6.9I 2 Pressure Testing
_ _ _ _ _ _ - _ _ _ - _ -
._____..__.__.___ ..___._ _ _ _ _
l-
- * 46
l i
l'
l As a result of the CPRT review, certain changes to
j procedures were recommended. These procedure changes are
'
addressed later in this report under NRC Reference
05.e.14.00. It was found, however, that the applicable
procedures were adequate in terms of standard industry
practice.
Based upon review, the NRC inspector concurs that the
review performed by the CPRT was encompassing in that all
appropriate procedures / specifications were reviewed.
Though there were inadequacies in the ;
procedures / specifications identified by either the )
project (applicant) or the TRT.(NRC), review of NCRs and
interviews with pipe fabrication personnel by RLCA did )
not reveal any other cases similar to the two main steam l
pipes (discussion relative to NCR review is addressed j
under NRC Reference 05.e.09.00 in NRC Inspection Report
50-445/8709; 50-446/8707). Therefore, it is concluded
that, despite a lack of specificity, the
l procedures / specifications were adequate enough to j
preclude any incidents similar to the main steam piping.
The procedures / specifications which lacked specificity
were revised in an appropriate manner. This activity is
covered under NRC Reference 05.e.14.00 which is discus 3d
in this report in a separate paragraph.
NRC inspection of this reference item is complete. No
violations or deviations were identified.
l
Interview Installation Personnel to Determine Other {
Piping with Circumstances Similar to Steam Line (NRC j
Reference 05.e.10.00)
]
i
Nine craftsmen and members of supervision involved in the l
installation of piping at CPSES were interviewed by the ,
CPRT to determine whether there may have been other I
instances involving temporary supports and piping where
uncontrolled springing of piping may have occurred.
These interviews are documented and contained within the
ISAP working file. None of the interviewees could recall
any similar instances.
The NRC inspector verified the interviews by reviewing
four of the documented interviews and reconfirming the
general interview content with the persons interviewed,
including whether they could recall any other cases of
uncontrolled springing of piping.
NRC inspection of this reference item is complete. No
violations or deviations were identified.
k.n_ - . - - -___.-._ -
. _ - _ _ - _ - _ .
' s
47
Review All Other Sources of Residual Stresses to Piping
Systems (NRC Reference 05.e.11.00)
The CPRT identified that during normal pipe installation,
the potential exists for some moderate springing. This
results from piping being installed within tolerances
specified in procedures but still not perfectly aligned
with the piece of equipment or piping spool it will be
attached to. When repositioning the pipe end for
alignment purposes, certain stresses are induced into the
pipe and some of these may be residual.
The NRC inspector concurs that there is a possibility for
residual stresses to exist in piping systems subsequent
to pipe installation. The effect that these residual
stresses have is discussed in the following section.
No violations or deviations were identified.
Evaluate Engineering Significance of Other Residual
Stresses (NRC Reference 05.e.12.00)
The CPRT conducted a study to determine what effect
residual stresses induced by the springing of pipes would
have on the different failure modes that piping might be
l expected to undergo. The following failure modes were
i
evaluated in conjunction with residual stresses:
!
'
(1) Bursting due to overpressure (ductile failure).
(2) Fatigue cracking.
(3) Stress corrosion cracking.
(4) Brittle fracture (nonductile failure).
(5) Plastic collapse or other distortion-related
mechanisms; i.e., progressive distortion.
(6) Creep.
(7) Stress rupture.
For all the above cases, it was concluded that residual
stresses would have no detrimental impact on the steam
lines. It was also concluded that residual pipe stresses
associated with the normal erection process of other
lines will have no adverse effects.
The CPRT study was reviewed by the NRC inspector and was
found to be adequate and very specific as to what effect
residual stresses may have on the main steam lines. The
. .
_
- _ _ _ _ _ _ _ _
- . 48
NRC inspector concurs with the conclusions with respect
to the main steam lines; however, the scope of,this
section within the ISAP required an assessment of damage
in piping-other than the Unit 1., Loop 1, main steam line.
There was insufficient discussion with respect to the
failure modes dealing with fatigue cracking, stress j
corrosion cracking, brittle fracture, creep, and stress <
rupture, and the effects that potential residual stresses
might have on other piping systems.
This is an open item pending receipt of additional l
information from the CPRT addressing the validity of the
scope of the present study (445/8706-0-10;.
446/8705-0-04). J
Where Required, Modify G&H Specifications and Procedures
to Avoid Similar Occurrences (NRC Reference 05.e.14.00)
l
The CPRT recommended changes to G&H Specification
2323-MS-100 and B&R Procedure CP-CPM-6.9E. The
recommended change to 2323-MS-100 was in response to TRT
(NRC) required changes as called for in SSER No. 10.
Though it appeared to RLCA that the current construction
procedures were generally adequate, they still considered i
it prudent that the applicant make the changes to the !
procedures to strengthen them and to give them more
'
specificity. j
i
l The changes recommended by RLCA are listed in Table 6 of
<
the RR.
,
The NRC inspector reviewed the recommended revisions for
their appropriateness and the adequacy of their
implementation. The seven changes to Procedure
CP-CPM-6.9E would make it clear where temporary supports
could/should be located and when they are to be removed,
types of materials to be used, and methods of welding to
be performed. The one change to G&H Specification
2323-MS-100 reemphasizes the need to assure there is
proper support fcr lines prior to flushing or hydrostatic
testing.
All the above changes have been implemented by virtue of
subsequent issue of Procedure CP-CPM-6.9E, Revision 8,
and DCA 23,327 to G&H Specification 2323-MS-100 with the
l
exception of one change. TU Electric has committed to
incorporate this change, which deals with limiting the
use of less desirable materials for supports, in the next
L___-___-___________-_- _ ._ -- _ - _ _ _
I
- * 49
i issue of Procedure CP-CPM-6.9E. This is an open item
l pending NRC review of the committed procedure revision
(445/8706-O-11; 446/8705-0-05).
No violations or deviations were identified.
l
i. Nonconformance and Corrective Action Systems
(ISAP VII.a.2) (35061)
l
Review Trend Analysis Vs. FSAR (NRC Reference 07.a.02.07)
l
l
To determine project compliance with FSAR commitments,
the NRC inspected the B&R and TU Electric trending
systems by reviewing the current and historical
procedures that controlled that activity and also by
reviewing a cross section by time of the issued trend
reports. Trend reports reviewed during this inspection
are listed below:
l
TREND REPORTS REVIEWED
COMPANY TITLE DATE OF REPORTS
REVIEWED
B&R QA Activity Report 12/74, 2/75
B&R QA Activity Report 7/76, 8/76
B&R QA Activity Report 4/77, 12/77
B&R QA Activity Report 4/78, 12/78
B&R QA Activity Report 4/79, 6/79
TU Electric Corrective Action Report 1st Quarter 1981
TU Electric Corrective Action Report 1st Quarter 1982
TU Electric Corrective Action Report 1st Quarter 1983
TU Electric Corrective Action Report 1st Quarter 1984
TU Electric Corrective Action Report 4th Quarter 1984
TU Electric Corrective Action Report 1st Quarter 1985
TU Electric Trend Report Summary 11/85, 4/86, 9/86
For the years 1974 through 1979, trending of deficiencies
was performed by the constructor, B&R. The B&R trending
activity was controlled at first by CP-QCP-23, " Control
of Nonconformances and Corrective Action" and later by
CP-QAP-15.1, " Field Control of Nonconforming Items." The
latter procedure was renumbered to CP-QAP-16.1 in 1979.
NRC review of these early procedures found that they
contained little more than a reference to trending of
deficiencies and to issuing of a report. Specific
details were lacking in how to conduct the trend
analysis, how to determine what constituted an adverse
_ __ A
\ . , 50
i
trend, and how to implement corrective action. B&R
complied with these procedures from the beginning of the
program until April 1974 by issuing a summary of the j
Deficiency & Disposition Reports (DDRs) each month in l
13 broad categories and then issuing these results in a l
QA activity report, which input to the monthly project
report provided to the utility. In April 1974, B&R began
using trend categories which identified the deficiency by 1
type and by discipline. This refinement would permit a I
determination that a number of deficiencies existed for a 1
type of problem or discipline, but since no requirement i
existed to normalize the data against construction
activity levels or to compare the data to previous ;
activity levels, the use of trend categories did not l
assure the identification.of adverse trends. B&R
trending continued in this manner until the end of 1979. J
TU Electric assumed the trending responsibilities in 1980
and began to issue quarterly trend reports in accordance
with Procedure CP-QP-17.0, " Corrective Action." As with
,
the B&R procedures, the TU Electric procedure required
l
that deficiencies be trended and a report of the trends
l be issued to applicable management.
The TU Electric trend reports continued to use the trend
categories established by B&R and, based on the NRC
inspector's review of the issued trend reports, review
for adverse trends was performed in each category
containing five or more nonconformances. Documents in
the trend report files; such as, interoffice memoranda,
I letters to file, and 3-part memoranda, indicate that
consideration of site activity levels (normalization) was
often performed to assess the significance of the trend
and that corrective action of adverse trends took place
although not formally documented as such. TU Electric
trending continued in this manner until the issuance of
Procedure QI-QP-17.0-1, " Preparation and Distribution of
Trend Reports," Revision 0, dated December 18, 1985.
This procedure was the first to specify the methods and
criteria by which data was to be compiled and analyzed
for trends. The procedure was to be implemented by the
Corrective Action Group (CAG) and specified the criteria
to identify potentially adverse trends (PATS) and
potentially adverse conditions (PACS), which were to be
included in the monthly trend analysis report. By
requiring that: current NCRs be compared to the preceding
three-month average of NCRs; levels of acceptability be
established for unsatisfactory attributes on irs; and
upper and lower control limits be established for
inspection surveillance checklists, surveillance
deficiency reports, and record surveillance reports; the
, procedure provided a comprehensive and responsive system
_ _ - _ _ _ _ _ _ -
e
a . 51
to identify trends adverse to quality. Two sources of
data for trending were not covered by Procedure
QI-QP-17.0.-1 and were not trended by the CAG. These
,
were test deficiency reports and design changes, which
are currently processed by startup and engineering,
respectively, with their results included in the trend
analysis report prepared by the CAG. This is in accord
with the current procedures.
From 1974 to 1985 the procedures required the minimum
necessary to meet PSAR and FSAR commitments; deficiencies
were trended or categorically identified and reports were
compiled.and issued to management. This commitment can
~
be seen as early as Amendment 5 to the PSAR dated
j April 5, 1974. Amendments to the FSAR such as
Amendments 41 and 50 added descriptions of the types of
deficiencies to be trended; e.g., NCRs, DRs, and irs;
however, the procedures did not specify the criteria for !
i
l identifying adverse trends nor the details of how
! corrective action should be implemented and followed for
closure.
,
In December 1985, the issuance of Procedures
l QI-QP-17.0-1, " Preparation and Distribution of Trend
Reports," and QI-QP-17.0-2, " Tracking of Corrective
Action Items," provided the basic criteria for the ,
current program. These procedures specified the criteria l
to identify a PAT or a PAC and required the data to be
supplied to appropriate management for action. Revisions
made to these procedures in 1986 further defined the
methods to assure that proper corrective action and
follow up for closure were performed.
Normalization or adjustment for current site activity
levels was not part of the criteria to identify PATS or
PACS. (Normalization aids in identifying adverse trends
as activity levels change.) Comparison of the percent of
unsatisfactory irs to an established deviation level for
each trend attribute and the comparison of the current
monthly NCRs to the previous three-month average
compensated in part for this lack of normalization.
To assess the implementation of the trend program, the
NRC inspector reviewed trend reports. The information in
the April 1986 and September 1986 reports reviewed by the
NRC shows that they were compiled in accordance with
QI-QP-17.0-1 and QI-QP-17.0-2. The correspondence
between the " Action Party" and the CAG to follow up and
close PATS and PACS shows that current implementation of
corrective action is also in accordance with these
procedures.
_- -
_ _ _ _ _ _ _ _ _ _ _
. . 52 l
I
1
No NRC violations or deviations were noted. The ERC l
evaluation of trending will be inspected when it is j
complete. ;
j. Guidelines for Administration of Exit Interviews
(ISAP VII.a.6, Revision 2) (92720)
The ISAP was in response to the TRT's assessment of the
TU Electric exit interview program for departing
employees. Specific activities of the ISAP are
delineated in the following table.
Activity ISAP NRC l
Paragraph Reference l
\
Develop evaluation 4.1.2.1 07.a.06.01 !
attributes.
I
Develop check lists for 4.1.2.2 07.a.06.02
procedure and implemen-
tation evaluation. .
Implementation of 4.1.2.3-4.1.2.6 07.a.06.03 1
checklists. (SAFETEAM)
Implementation of 4.1.2.3-4.1.2.6 07.a.06.04 l
checklists. (omsbudsman)
Qualifications of -4.3 07.a.06.05
Personnel.
The following reference items for this ISAP were
inspected and completed by the NRC during this report
period.
Assessment of Developed Evaluation Attributes (NRC
Reference 07.a.06.01)
The ISAP required the development of a set of attributes
l
'
to be used in the evaluation of TU Electric's past and
present exit interview program. These attributes were to
be based on: commitments made by TU Electric in response
to NRC enforcement action, EA-83-64 from NRC Inspection
Report 50-445/83-03, 50-446/83-01; applicable
requirements of 10 CFR 50, Appendix B, Criterion I; and
criteria from similar industry programs. Thirteen
attributes were developea from these sources which
j included the following items: system for identification,
investigation and evaluation of concerns; resolution of
concern with the employee; notification to management of
those concerns with potential safety implications;
-- ____ _ __ - _ -
_ _ _ _ _ - _ _ _ _ _ . ,
I
= . 53
employee anonymity and protection from harassment and/or
intimidation; ombudsman /SAFETEAM/TU Electric
coordination; and independence of interviewer and
investigator.
l
The NRC reviewed the thirteen developed attributes and )i
I
compared them to the criteria and requirements outlined
above. These attributes appropriately included TU
!
Electric connitments made in response to EA-83-64 and the
l requirements of Criterion I. Ten of these attributes
l
were obtained from reviews of existing industry programs.
l
'
currently being implemented at the South Texas and
Braidwood projects.
The NRC inspector reviewed 44 documents which were used
during the development of the 13 attributes. These
documents included communications between TU Electric and
the NRC, and interoffice memoranda between TU Electric 3
organizations. One such document was the October 17, I
1983, NRC letter to the applicant in which the NRC l
accepted the TU Electric commitments that initially I
established the exit interview program. The purpose of l
,
this review was to determine if other commitments existed l
'
in addition to those identified by ERC. None were found. j
l
No violations or deviations were identified in this area
of inspection.
Assessment of Developed Checklists for-Procedure and
Implementation Evaluation (NRC Reference 07.a.06.02
l
The ISAP directed that checklists be used in the
evaluation of the exit interview program. Further, the
ISAP required that these checklists be developed from
attributes (13) identified during ERC's review of
TU Electric's commitment to have an exit interview
program and the criteria for similar industry programs.
The NRC's assessment of attribute development was
addressed above in NRC Reference 07.a.06.01.
Four checklists were developed by ERC: two checklists to
evaluate the policies and procedures of the exit
interview program (one for the ombudsman and one for the
SAFETEAM) for conformance to the 13 attributes; and two
checklists to evaluate policy and procedure
implementation of the exit interview program. The
purpose of this NRC inspection was to determine whether
developed checklists adequately: (1) addressed the-
13 attributes for the evaldation of the ombudsman and
SAFETEAM policies and procedures, and (2) provided
requirements to assess policy and procedure
implementation.
- - _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ - _
,
f !
!
. . 54 l
l
,
In reviewing the checklists for policy and procedure
i evaluation, the NRC found that the checklists had
structured the 13 attributes into 24 requirements to be ,
reviewed in the Ombudsman and SAFETEAM program. The !
l policies and procedures checklists for verifying )
l implementation defined 49 requirements for the Ombudsman l
l
program and 37 requirements for the SAFETEAM program. {
1
Based on the review of the four checklists, the NRC
determined that ERC adequately translated the l
13 attributes into checklists to evaluate the Ombudsman l
and SAFETEAM policies and procedures and that the j
checklists were adequate and to verify the implementation i
of the policies and procedures. I
l
No violations or deviations were identified in this
inspection.
l Implementation of Ombudsman Checklists (NRC Reference
1 07.a.06.04) i
l
The NRC inspector evaluated implementation of the two
checklists used by the ERC to assess the Ombudsman's exit ;
l
l interview program. Development of the checklists was
addressed above under NRC Reference 07.a.06.02. 1
l
! (1) Ombudsman Policies and Procedures Checklist - The
purpose of the NRC inspector's review was to
determine whether the checklist elements were
completed during the ERC review of the Ombudsman's
policies and procedures.
The Ombudsman's policies and procedures for the exit
interview program were described in nine TU Electric
corporate interoffice memoranda; TU Electric
Procedure DQP-QA-6, " Quality Assurance
Investigations," Revision 0; and TU Electric's
contract with Gilbert Associates (Purchase
Order 661-09212 dated December 9, 1983). ERC
compared these documents against their policies and
procedure checklist for conformance. In reviewing
the checklist, the NRC found each of the
< 37 checklist questions were answered by.ERC with
references given to the source document containing
the requirement. The NRC inspector verified that
each reference contained'the appropriate requirement
corresponding to the checklist item.
(2) Ombudsman Policies and Procedure Implementation
Checklist - This checklist was used by ERC to assess
the implementation of the Ombudsman's policies and
procedures. To complete the checklist, ERC compared
, m
- . 55
the 49 checklist elements to documentation which
provided information and evidence of the Ombudsman's
program implementation. These documents were
TU Electric interoffice memoranda; letters between 1
TU Electric and CPSES site subcontractors; Quality i
Assurance Investigation (QAI) files; QAI log book,
and completed exit interview questionnaires, j
.
j
As with the policies and procedure checklist, the
NRC inspector reviewed each element of the
implementation checklist and determined.that each of
the elements were completed. Sixty (60) references
were used as evidence to substantiate statements !
made in response to checklist elements. The NRC i
I
inspector reviewed each of the referenced documents
to assure that they provided evidence of procedure '
and policy implementation. Based on this review of
! the checklist and the identified references, the NRC
inspector determined that the procedures and
policies implementation checklist elements were
completed as committed.
I
No violations or deviations were identified in this area
of the inspection.
Evaluation of Personnel Qualifications (NRC Reference
07.a.06.05) ,
,
The NRC inspected the qualifications of the ERC personnel
performing activities related to this ISAP. ERC was
found to have verified each individual's education and i
'
experience in accordance with the CPRT Program Plan as
implemented by ERC Procedure CPP-003, " Indoctrination,
Training and Certification of Personnel." Objectivity l
questionnaires were also reviewed by the NRC inspector
and determined to have been completed and evaluated by
ERC as required. It was observed that the average
nuclear work experience for each participating individual
was 12 years, including 4 years of quality auditing.
. From the review of personnel qualifications and CPRT
l training and indoctrination, the NRC inspector determined
personnel were qualified in conformance to CPRT program
requirements.
!
No violations or deviations were identified in this area
of the inspection.
k. Receipt and Storage of Purchased Material and Equipment
(ISAP VII.a.9) (35065)
During this report period, the activities identified by
NRC Reference 07.a.09.03 were inspected as follows.
. - _ _ _ -.
I
'
i
,
o . 56
L
Perform Field Inspection of Selected Material and-
Equipment (NRC Reference 07.a.09.03
To assess the ERC implementation of field inspections
l
'
required by pa;=gvaph 4.1.3 of ISAP VII.a.9, the NRC
inspector selected EPC Verification Package 7.a.9.108 for
inspection. This verification package was for electr3- j
cable procured under TU Electric Purchase Order '
CP-0465.2.c. The item selected for field inspection was
Cable Type W-151 of which a 50' length was stored in the J
TU Electric cable reel yard. During performance of the
! inspection, the NRC inspector noted that several cable
l
reels were improperly protected from exposure to
sunlight.
The opaque plastic sheeting placed to protect the cables
from fading appeared to have shifted on seven reels
(W-416-1, W-316-1A, W-745-1CC, W-117-1, W-117-3, W-117-4,
and W-118-12C) such that a large portion of the cable was
exposed and fading had occurred. The NRC inspector
contacted the warehouse supervisor who stated that a
walkdown of the cable reel yard for exposed cable would
be performed to correct the problem. The failure to
maintain the protective covering over the cables is a
l violation (445/8706-V-12; 446/8705-V-06).
Inspection of the ERC field inspection activities is
ongoing and will be reported in a subsequent report.
1
! 1. Pipe Support Inspections (ISAp VII.b.3) (50090)
Verify TRT Identified Discrepancies (NRC Reference
07.b.03.01)
ERC reviewed the procedures and codes covering the TRT
inspected supports, and developed checklists addressing
the TRT identified discrepancies. These checklists were
then assembled along with instructions, documents, and
drawings, into reinspection packages. The reinspection
packages were used by ERC inspectors to inspect and
verify those supports and related discrepancies
identified by the TRT. The checklists, drawings,
instructions and documents assembled into reinspection
packages were reviewed by the NRC inspector and found to
adequately address the discrepancies identified by the j
TRT.
ERC identified a total of 252 discrepancies in Room 77N
l and 46 discrepancies associated with the TRT 42 Supports.
l These discrepancies were documented on DRs. The results
l of NRC inspections can be found in NRC Inspection Reports l
l 50-445/85-13, 50-446/85-09; 50-445/85-16, 50-446/85-13;
!
i ,
t
- - _. _ _. _ __ _ ___J
. _ ________ _ __
. , 57
50-445/85-18, 50-446/85-15; 50-445/86-07, 50-446/86-05;
50-445/86-15, 50-446/86-12; and 50-445/86-22,
50-446/86-20. NRC inspection of this reference item is
complete.
Perform Reinspection of Hardware (NRC Reference
07.b.03.04)
ERC was to perform a reinspection of identifiable
hardware inspected by TRT However, TRT did not identify
the inspected supports in Room 77N, only the type and
numbers of identified discrepancies. Therefore, in an
effort to include all supports inspected by TRT, ERC
inspected all 178 safety-related supports in Room 77N and
the TRT 42 supports. Thirty-three NRC inspections of
pipe supports were conducted to evaluate ERC performance.
The results of these inspections are documented in NRC
Inspection Reports 50-445/85-13, 50-446/86-09;
50-445/85-16, 80-446/85-13; 50-445/85-18, 50-446/85-15;
50-445/86-07, 50-446/86-05; 50-445/86-15, 50-446/86-12;
and 50-445/86-22, 50-446/86-20. NRC inspection of this
reference item is complete.
Compare Inspection Results and Identify Differences (NRC
l Reference 07.b.03.05)
ERC inspected a total of 220 pipe supports which resulted
in the identification of 298 discrepancies. These
discrepancies were then compared by ERC with the TRT
inspection results. ERC found that the 46 discrepancies
associated with the TRT 42 supports were consistent with
those identified by the TRT. The discrepancies
identified by TRT in Room 77N were identified by 'JRT to
only discrepancy category and not to specific supports.
ERC found, however, that the 252 discrepancies idantified
during the reinspection effort were consistent with those
identified by the TRT. The NRC inspector has reviewed
the ERC findings which consisted of 25 identifir.d types
of discrepancies in the TRT 42 issues and six types of
discrepancies identified in Room 77N, and as 7 result of
his own inspections concurs with the ERC res'alts. NRC
inspection of this reference item is complete.
Identify VII.c Pipe Support Populations Representative of
the TRT Samples (NRC Reference 07.b.03.'J7 )
The CPRT reinspection of the pipe supports in Room 77N
and the TRT 42 supports revealed that they fell in the
following three VII.c populations:
___ - _______ _ _ __ - ___ -
. . 58
(1) Large Bore Pipe. Supports - Rigid.
(2) Large Bore pipe Supports - Nonrigid.
(3) Small Bore Pipe Supports.
The NRC inspector reviewed all 220 reinspection packages
identified for Room 77N and for the TRT 42 supports and
confirmed that all pipe supports inspected by ERC fell
into the above populations. NRC inspection of this
reference item is complete.
5. Open Items
open items are matters which have been discussed with the
licensee, which will be reviewed further by the inspector, and
which will involve some action on the part of the NRC or
licensee or both. Open items disclosed during the inspection
are discussed in paragraphs 4.a, 4.b, 4.c (two items), 4.f,
4.g, and 4.h (two items).
6. Unresolved Items
Unresolved items are matters about which more information is
required in order to ascertain whether they are acceptable
items, violations, or deviations. One unresolved item
disclosed during this inspection is discussed in
paragraph 3.b.
7. Exit Interview (30703)
Exit interviews were conducted April 6, 1987, and May 5, 1987,
with the applicant's representatives identified in paragraph 1
of this report. During these interviews, the NRC inspectors
summarized the scope and findings of the inspection. The
applicant acknowledged the findings.