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Rev a to CP244-8700, Concrete Testing Data Mgt
	ML20237K575
Person / Time
Site:	Comanche Peak
Issue date:	12/29/1978
From:	; BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.)
To:	;
Shared Package
ML20237J194	List: ML20237J222; ML20237J238; ML20237J260; ML20237J273; ML20237J334; ML20237J352; ML20237J365; ML20237J377; ML20237J391; ML20237J412; ML20237J434; ML20237J447; ML20237J453; ML20237J470; ML20237J608; ML20237J652; ML20237J761; ML20237J785; ML20237J825; ML20237J841; ML20237J884; ML20237J895; ML20237J953; ML20237J985; ML20237K030; ML20237K052; ML20237K056; ML20237K071; ML20237K102; ML20237K105; ML20237K116; ML20237K144; ML20237K158; ML20237K189; ML20237K221; ML20237K267; ML20237K294; ML20237K334; ML20237K348; ML20237K365; ML20237K413; ML20237K446; ML20237K454; ML20237K460; ML20237K517; ML20237K550; ML20237K575; ML20237K623; ML20237K640; ML20237K647; ... further results
References
	FOIA-87-87, FOIA-87-A-14 CP244-8700, NUDOCS 8708270220
	Download: ML20237K575 (34)
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nuowemo-f N/A j ' M/A _ [M844 [ [ f f [ __ i 4/A gyifndet No. J43J J'pt 9 W />, t nr.nes n,. est. N/A N/A /N ___ /Md*P im.orrr.eur. Ao B. _ N/A I 9/A Nam, Load - Ibs. L A$ 79 N3-77 N/A .[ u/A I A/A _.. \\ elk 3.c. x.e uv.e fB.Sf l 2BJ2 J nes Rarpectfu15ytubmitcad, KDBERT V. InJ1"J COMP MY Checked by: bdLJ'Mf_ y %a M W Form 11CP-E1001 ( Rev.11/70 MOOENT W.Huntf COMPANY, ......-..4................,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,__,,,,__,,_,,_ l
FEB 10 '97 00:41 LICENSE TUGCO p,. c,3g (kNobbGth 3777-6 7, Y 'f, 77 s is i m. i.m 13-C-9') 2 7 Daces _ ...v a n AS: 7saas Utilities services, Inc. Brevn & Ecec, Inc. Comanaba Pask Staae Slectric Sect P. C. 8cx'*1001 1980-1V82 Units 1 & 2 Glen Rose. Texas 76042 Jak No. 3-1195 8 4 R subcontract Ne. M-1105-07', Itunt Project No. 31,i GGotlemeM W ropore results ot Concreta Compression Teses, AftM C-39 (Hunt 1 I' M188/D M/ 81mep Inches 7eur Wo. Tic,kat No._ J 295'9 Tamparaturs 'T.' [6 2-fl 77 Air contant % _ ( Data Hade '//d Late Tasted _ 7-2 9-7 7 Concrets Mix '? aatssetsus.j t4.6A _ ue car, nao6; pro con _ s7An no e m o ' #4#o W/6 1 uh d f.M9 J/M W/* c/A sy u w se we. ar.n.tw 1s., nr. < J52 3 94W , ffMO dlk Yl$ i fgs. Lead - 1bs. N/A L 4/A do 8. 1 0. of Frsature 9/A \\... M/A_ 7137'?_ ').}3-77 (. J 28.2'l I 18.#l N/A ,f 4/A L te nsensuse fus i d tested by: respectfully suumiceed, n eeked by: M ROBERT W, itDM COMPAW 7 ~. s ' w__4 .c I i MEN E reta ner-tiool (Rev.11/76) HOUcMT W, HUNT C OM PI
FEB 10 '87 20: 44 LICENSE TUGC0 prt ;t 3 3 .m w u j / g e, .. m ni u m,em n. sa.n64. - m g e .e n,, Dacas __ [ " 8 ' U - hrer 3 -9927 Brown & Ract. 184 l P.O. Box 1001 760 0 Cien Rosa, Texas 3 & R/TUSI retention tims Ras Texas' Utilitiu Services, Inc. fe; the attoched document Comanche Pask Sttan C16ctric Station/ *4fAyaars af ter plant. Subjects 1980-1962 Units 2 & 2 ,hesins operse1on. 1 Job No. 3-1.195 3 & R Subeentract No. 35-1195-0225 7kmt Project No. 513 centlement i opy < 11assa schnowledge receipt of the following itan by signing sad JkP%sn8 Ltse Com. owd %+ w &ani ev this letter. y uf lfwe.pnts ]YItv oor ros- ~ i c w e + ?.o J pnv vy W a MvvT.INC R 9 8 87 '-9 I Alm 9 9 ion t rn,n sence a $U YfeCURANCk nc. t uo. ,3 -w 'W '^ .T. ~ kele p C,,n s, W ' W L.te-g -ZZ-7 7 bace CA RECORD Rourney I. p 4 2. '~* form BCP-9 rn.t No. ~
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N ,$-)f 72' w 1 - - 921 pace: s RE: Texas Utilition Sci,Jeon, 7ne. Comanche Peak Stcp F.lectric Stt.- Dreen 8. Root. Inc. P. O. hx'1001 1980-1982 Unite.1 4 2 Job Ho. 35-1195 Glen Rose, Texas 76043 B & I! Subcontract M. 3k1195-02 f nunt Project No, M,3 j Centlement We report results of Concreta Compressf.on Tests, ASTH C-M Blump Laches - AN? Your No, j QA-4"R/D'&JA-feaparature 'F, /f ', Ticket No._, '3J # # 7 V18 Att Centest % _ 7-22-7'1 bate Mnds ' ///,_ Cotierett Mix ___ Date tested _ /*/#-7 "7 _ Unit Weight _,.W/4 f/ = Age Daye TIEttd%CD 000 rrANDARB CVRED' ( C-9124- & 't31e _ C 4' 3 t 7 1 ( =t 3 J.,*. cyliader no, Wfl 4~feb _ f_3 09 $~ Y 't 7 strencth 1ss, Psi. / W 4'. l /4~// Job /6*1TD6 hY74'V>6 __ A <r kr. 1.ond - the, A*o A* o An v f f i;ve of Fra'eture 7-J 5 # 77 7-JV 77
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Y 1 Date neceived }?. // l Mf2 // W l J/ 27 J J Ares ? neepectruliysudestted, 7*d 6F - checked M itonnt 9, nutr contgy J y t wyn M IYE term uct-1:J ool ( R e v. 11/76) H ollC M T W. H U N1 COMPANY, ....., ~....................................,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
] FEB 10 '87 20:S1 LiCEHSE TUGC0 Pc C,33 l v Gift)CLbs Utf ; h e 7 o+ 7 3 n r. mist licy p ein s, m. 3777*fi 13-C-pp2/ UAtel /- / f* 7/ imus RE: Texas Utilities Sor$ Jcos:, foe, Brow & Root, Inc. Comanclie Pook Steam %ctrJe Stot P, 0, lex 1001 1980-19A2 Units 1 & 2 , Job Ho, M-1195 Clon Rose Teams 76043 5 & R Subcontract H.'. 35-1195-022 Ilunt Pro.)cct Wo. 513 dentlemens We report rasuits of Coneroca Comptesatoo Tesea, AShi C-39 Otunt E:001) 3 k[ Pour Ho, d e j - 5'A @ ~ o /.1 Slump Inches Ticket No._ 3 f f// Temperature 'F.' //,_ M f> 7-Jf-77 Air contane ! -- Date Mads - /// Date Tested
~~-/f'-77 hiereto Nix Ass Days.~~
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pro;r. 34 FEB i0 'G7 20154 L I CE 14SE TUGC0 1,W PtJef, r u m eesuun a ves.se o es ( [CA* M NE N' ".,u.;.)m' &,I y'" votA sattmantex ' Pas or cuanns
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FEB 10 'G7 21:08 LiCEHSE TUGCO PAGE.3G ... s ,,, K,,*,"* y,.... ... ~.... ghM}MhY!
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' eme MM27 Date e s seau o h t,-J ae.. J,0. 5ek :1M1 " Dias Base, Tasas F6043 a. .Re t 3*4 2/tt181 reteotten ! l' i%eets_MJtilities Seevises, tea, ~ h % Feak'Stees tieetria Stattee ' for the attached docr lu4 years after pla, j r~ 4 90 0- M 41 A nita 1 & 2 operac.s,o. 3eVhT.' 5>4195
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~ this letter. ktP IM.ll - DMt fe nn, a lj A s+. Tituex e Ref. o I, t \\ ROWN & ROOT, IND-f RECETVED g l JUL if, t9?$ a. Psas mRW sensar v. mm caex ' ULITY ASSURANCE s Mp,. e. c x x ~ ~w _f S&Q .ik;,% ^'Y ^~
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FEB 10 'en C1:11 LICENSE TUGC0 PAGE.39 ses monas wi rawoaco unocx, re. . r.. - A$L%DLf Ro3RRT W. Et!NT coMPANT, Esota*55R5 cueem t, mme fd 'p $g g g g. q = riu w. 3777 4
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ems v =w nroom 6 Shenn sneem "i: d s. dp'.: ..%.a... + ggy:2&.- rest offlee saa 1801 <;1em nase, fases 76043 .:teettee ter. F. L. Reasellai Project quality Assursese Manager 3 sub.iest Tomas Ottigt$es Serrimes Ise, Asfseamoe: Conaaabe Peak Steam Elastria Statio6 IS40-1942 Datts 1 a 1 Job amber 1195 5 6 R Saboentraat shamber SF119hc223 munt Frejeet 313 Gentleenat We report ruults of tests in accordance with requirements of A$rA C94-73a Appendin XI Concrete Unifomity llequirements made on the following equipment - Aeady Mix Truck (RET 01 6,'ef ght per cubic foot (air free basis) sample #1 = 153.32 lb/cu. ft. Sample it = 163.91 lb/cu. ft. Diffenwica in results
~~0,59 lb/cu. ft.~~
Maximus Permissible difference in results = /.de ib/cu. ft. Air Centent, Volume 5 of Concrete S6gle il a 4.21 5esple it = 4.51 Otfference in results a 0.31 Maximum Permissible difference in results = 1.05 E ............_... ram.megenutm1.NR.Y..
f 1 FEB 10 '87 El:14 LICENSE TUGC0 PAGE'.40 $A) DSOdd E upoet /d f /FM-ras us. 37y7,4 hd 3* 3 etffereece in.resulta e 11 inches +w wv.c -N l kutama perstissible difference in resvits = 1.5 inches WWfhirF C*erse g. ,,,,N.= 65,705 sample
~~W' Difference in reselts = 1.005i Maximum pers(ssible difference in results a 6,005 Averste compressive strength at 7 days for each sample, based on avere9e f~~
strength of all comparative test specimens, percent. i f sample #1 = 102.495 sample R = 97.605 1 Difference in results = 4.995 f Maximum penstssible diffemace in results = 1.5% The above results comply with project requirerwnts. Respectfully submitted, IT W. WLET CopFANYML X. Kinkade t. 1 !!! sulpu ,w. , a ~.. C. :. ' ~ up l ~,. MOggRT W. HUNY COMPANY. SNGsHSSAG A
ii /. I y. ..( m / /. In Reply Refer To: '-f -,' Dockets: 50-445/84-32 FF.B 15 EEIS 3/ r 50-446/84-11 / p ', - ' N,___ h'- M Texas Utilities Electric Company [ ATTN: M. D. Spence, Pr.esident, TUGC0 [g j, / >t Skyway Tower j i 400 North Olive Street p/ o /+ j,,, j <r. Lock Box 81 C Dallas, Texas 75201
~~Q>./..s v.~~
J f : ', I Gentlemen: This refers to the inspection conducted under the Resident Inspection Program by Mr. H. S. Phillips of this office and NRC contract personnel during the period August 20, 1984,, through September 20, 1984, of activities authorized by NRC Construction Permits CPPR-126 and CPPR-327 for the Comanche Peak facility, Units 1 and 2, and to the discussion of our findings with Mr. D. Chapman and other members of your staff at the conclusion of the inspection. Areas examined during the inspection included a review and evaluation of how effectively Texas Utilities Electric Company management has implemented the corporate quality assurance (QA) progrhm for design, procurement, and construction activities. Special emphasis was placed on evaluating the management of the audit program; management's action to regularly review the status and adequacy of the QA program; and followup on findings pertinent to program management identified by previous NRC and consultant inspection teams. Within these areas, the inspection consisted of selective examination of procedures and representative recorris, interviews with personnel, and observations by the inspectors. TF sse findings are documented in the enclosed inspection report. During this inspectier, it was found that certain of your activities were in violation of NRC requirements. Consequently, you are required to respond to this violation, in writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter. These violations may be related to findings identified by the NRC Technical Review Team (TRT). If the issues are considered to be similar, you may respond to the items separately or as part of the Comanche Peak Response Team Action { Plan. ec // ~ >dd908 71 2 p y uy.sw - g.p RRI hT TL/TP[tt D/[ /RP82 D/D S&P NRR g V SPhillips/lt DHunnicu RB':- tunter R0enise Noonan j /: /8f % dv/84 I: M M 84 .y W- /84' ' fy /8E i ,cV
<c1 Texas' Utilities Electric Company Should you have any questions.concerning this inspection, we will be pleased to discuss them with you. Sincerely, original signed byf D M. H U N N 1*C'i l D. R. Hunter, Chief Reactor Project Branch 2
~~Enclosure:~~
1. Appendix A - Notice of Violation 2. Appendix B - NRC Inspection Report j 50-445/84-32 l 50-446/84-11 j cc w/ enclosure: Texas Utilities Electric Company Texas Utilities Electric Company ATTN: B. R. Clements, Vice ATTN: J. W. Beck, Manager President, Nuclear Nuclear Services Skyway Tower Skyway Tower '400 North Olive Street 400 North Olive Street j Lock Box 81 Lock Box 81 Dallas, Texas 75201 Dallas, Texas 75201 bec to DMB (IE01) bec distrib. by RIV: RPB1 RRI-OPS TX State Dept. Health RPB2. RRI-CONST. Juanita Eilis EP&RPB R. Bangart Renea Hicks R. Martin, RA J. Gagliardo Billie Pirner Garde C. Wisner, PA0 D, Hunnicutt S. Phillips R. Denise, DRSP TRT (CPSES) (2) RIV File S. Treby, ELD g >r"Eisenhut, NRR j MIS System i i 'N j
0' APPENDIX A NOTICE OF VIOLATION Texas _ Utilities Electric Company Dockets: 50-445/84-32 Comanche Peak Steam Electric Station, Units 1 and 2 50-446/84-11 Construction Permits: CPPR-126 CPPR-127 Based on the results of an NRC inspection conducted during the period of August 20, 1984, through September 20, 1984, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 49 FR 8583, dated March 8, 1984, the following violations were identified: 1. Failure to Regularly Review the Status and Adequacy of the QA Program Criterion II of Appendix B to 10 CFR 50, as implemented by the Preliminary Safety Analysis Report (PSAR) and the Final Safety Analysis Report (FSAR), Section 17.1, " Quality Assurance Program," and ANSI N45.2-1971, requires that the quality assurance program shall prowide for tne regular review by the management participating in the program, of the status and adequacy of the part of the quality assurance program for which they have designated responsibility. Contrary to the above, the applicant did not establish quality assurance procedures to regularly review the status and adequacy of the construction quality assurance program; nor did the applicant appear to have reviewed the status and adequacy of the construction quality assurance program. This is a Sevcrity Level IV Violation. (Supplemer.t II) (445/8432-02; 446/8411-02) 2. Failure to Establish and Implement a Comprehensive System of Planned and Feriodic Audits Criterion XVIII of Appendix B to 10 CFR 50, states, in part, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program." The requirements are addressed in the PSAR and FSAR, Section 17.1, " Quality Assurance Program," which references negulatory Guide 1.28 (ANSI N45.2) and ANSI N45.2.12 (Draft 3, Revision 4). Those commitments require that a comprehensive system of planned audits be performed on an annual frequency. Contrary to the above, the following examples were identified which demonstrate the failure to establish and implement a comproh.:r.v:ve system of planned and periodic audits of safety-r. elated activities + required, as noted below: f e
1 Notice of Violation i a. Annual audits were not adequately addressed by the audit impicmentation procedures. TUGC0 Procedure OQP-CS-4, Revision 0, dated August 9, 1978, only required two audits of vendors fabricating reactor conlant pressure boundary components, parts, and equipment; one audit of ) vendors fabricating engineered safeguards components, parts, and j equipment; and audits of balance of plant (safety-related) as required by the quality assurance manager. l TUGC0 Procedure DQP-CS-4, Revision 2, dated April 16, 1981, required only that organizations will be audited on a regularly scheduled basis. TUGC0 Procedure 0QP-CS-4, Revisions 2 and 10, did not specify auditing frequencies for design, procurement, construction, and operations activities. TUGC0 Procedure DQP-CS-4, Revision 10, based audit requirements on Regulatory Guide 1.33, Revision 2, February 1978. This commitment did not fully address the requirements of the construction quality assurance program. Th.e above procedure and subsequent revisions failed to describe and require annual audits in accordance with commitments and requirements. Earlier audit procedures were not available to determine if they met requirements. b. Planning and staffing to perform 1983 audits was inadequate to assure that a comprehensive system of audits was established and implemented to verify compliance with all aspects of the quality assurance program, in that, of 656 safety-related procedures (which control safety-related activities) the NRC review revealed that the applicant sampled only 165, or 25 percent, during the 1983 audit program. Consequently, significant aspects of the safety-related activities were not adequately audited. I c. The Westinghouse site organization, established in 1977 to perform l Nuclear Steam System Supply (NSSS) engineering services, was not audited by TUGC0 during the years of 1977, 1978, 1979, 1980, and 1981. d. Audits of vend rs that manufacture or fabricate parts, components, and equipment for reactor coolant pressure boundary and engineered safeguards systems have not been conducted annually dating back to August 9, 1978. This is a Severity Lev?1 IV Violation. (Supplement II) (445/8432-03; 446/8411-03)
a Notice of Violation ! 3. Failure to Properly Certify a Vendor Compliance Inspector Criterion V of 10 CFR 50, Appendix B, states, in part, "Ac.ivities affecting quality shall be prescribed by documented inst uctions, procedures, or drawings, of a type appropriate to the c';t.sostances and shall be accomplished in accordance with these instructions, crocedures, or drawings." TUGC0 Procedure DQP-VC-4, Revision 6, dated January 5, 1984, requires that Level II inspectors (Corporate QA) shall attend and satisfactorily complete nondestructive testing courses including eddy current testing. Contrary to the above, one of six inspector's files had ne documentation to show that the inspector had attended and completed an eddy current testing course. Subsequent, discussions revealed that he had been certified without meeting this requirement. The vendor compliance supervisor stated that this inspection skill is not needed since there is no present vendor work activity which would require this skill; therefore, l this procedure was revised and the requirement omitted during this inspection. This is a Severity Level V Violation. (Supplement II) (445/8432-05; 446/8411-05) Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is hereby required to submit to this office, within 30 days of the date of this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown. Dated. 1 l
7 4 APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report: 50-445/84-32 Construction Permit: CPPR-126 CPPR-127 50-446/84 Dockets: 50-445 Category: A2 50-446 Licensee: Texas Utilities Electric Company Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas' 75201 Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 Facility Name: Inspection At: Dallas Corporate Office, Dallas, Texas Inspection Conducted: August 20, 1984 through September 20, 1984 //// 8 Inspector: Date H. S. Phi' lips, Senior' Resident Reactor Inspector Construction NRC Contract Personnel: B. Freed, Senior Project Engineer, EG&G Idaho, Inc. G. Thomas, Quality Engineer, EG&G Idaho, Inc. //.7. ?!f @ h' t mE8 Approved: Dite / D. M. Hunnicutt, Team Leader Region IV Task Force Inspection Summary Inspection Conducted August 20 throuch September 20, 1984 (Recort 50-445/84-32: 10-446/84-11) o nd A *R od-l@ ?b l- ~77 m [
4 E .g. Routine, announced inspection to determine how effectively Areas Inspedted: corporate management has implemented the QA program for controlling design, i procurement, and construction activities; and to determine how site management interfaces with corporate management. The inspection involved 74 inspector-hours by one NRC inspector and 176 inspector-hours by two NRC contract personnel at the corporate office and the-site. + Within the two areas inspected, three violations were identified Results: (failure to regularly review the status and adequacy of the QA program - paragraph 2b.; failure to establish / implement a comprehensive system of planned and periodic audits paragraphs 2c.(1) and 2d.(3)(a); and f ailure to properly certify a Level II vendor compliance inspector, - paragraph 2d.(3)(f). 1 i i k ? s ( 'S %. iS 1 ]
4 DETAILS 1. Persons Contacted W. Clements, Vice President Nuclear Operations, Texas Utilities Generating Company (TUGCO)- l
D. M. Chapman, Manager, Quality Assurance (QA), TUGC0

R. G. Spangler, Supervisor, QA Services, TUGC0

D. L. Anderson, Supervisor, QA Audits, TUGC0 A. H. Boren, Supervisor, Vendor Compliance, TUGC0 L *S. L. Spencer, QA Auditor, TUGC0 l
O. Z.1H9thcock,+QA Auditor, TUGC0 l H. R.f erf4LAuditor,TUGC0 1 A. Veg, itsfQA' Manager, TUGC0 L. M. Bielfeldt, Supervisor, Quality Engineering, TUGC0 C. Welch,' Supervisor, QA, TUGC0 J. H. Roberts, Supervisor, Construction /Startup, TUGC0 J. T. Merritt, Assistant Manager, Engineering and Construction, TUGC0 R. Gentry, Manager, Project Support Services, TUGC0 F. Peyton, Supervisor, Purchasing, TUGC0 i M. Strange, Supervisor, Engineering Support, TUGC0 R. Baker,. Staff Engineer, TUGC0 H. Harrison, Supervisor, Technical Services, TUGC0 G. Krishnan, Supervisor Stress Analysis Group, TUGC0 R. Williams, Drafting Supervisor, TUGC0 G. Purdy, Site QA Manager, Brown & Root Inc. (B&R) R. L. Moller, Site Manager, Westinghouse
~~Denotes those attending one or more exit interviews.~~
2. Texas Utilities Management of QA Activities a. Introduction The objective of this inspection was to determine the status of the construction QA program and the effectiveness of implementation of the corporate QA program for ongoing design, procurement, and j j construction activities. The NRC inspectors reviewed the QA commitments described in ] Section 17.1, " Quality Assurance During Design and Construction." Texas Utilities Electric Company (TUEC), as the applicant, has delegated to Texas Utilities Generating Company (TUGCO) the responsibility and authority for engineering, design, procurement,
~~c. construction, operation, and QA activities at Comanche Peak Steam Electrical Station (CPSES).~~
Gibbs & Hill Inc. (G&H), is the t chitect-Engineer (AE) and provides ifUGC0 with design, engineering, ', :nd procurement services as requested. Westinghouse (W) is the j .y g g:; clear Steam Supply System (NSSS) supplier and provides TUGC0 with j o design, engineering, procurement and fabrication services for the SS and the initial supply of nuclear fuel. Brown and Root, Inc. i 1 - - - - - - ------______________________.______________j
t v. (B&R) is the Construction Manager / Constructor and provides construction services at the site, including the QA program for ASME Division 1 Code work. b. Organization The TUGC0 corporate management structure and responsibilities were described in the Final Safety Analysis Report (FSAR); and the various TUGC0 QA manuals and procedures described how FSAR requirements were implemented to control design, procurement, and construction activities. Recent organizational changes pertaining to the QA program were described in FSAR figures 17.1-1, 17.1-2, 17.1-3, 17.1-4, and 17.1-5 which were included in Amendment 50 dated July 13, 1984. Recently, there have been three important QA personnel changes. A new site QA manager reported in March 1984, a new site quality engineering supervisor reported in August 1984, and a new vendor compliance supervisor was recently selected. These organizational changes were made to replace individuals.who were reassigned or promoted to other positions, and these changes were reported to the NRC. The independence and effectiveness of the QA effort do not appear to be adversely affected by these changes. The assistant project general (APG) manager reports to both the VP of engineering and construction and to the TUGC0 Executive VP of operations. Discussions with the APG manager confirmed this and that he was supervised by both. This management practice is questionable. The CPSES QA Plan Section 1.2, paragraph 1.2.1, does not describe the APG manager's interface with or the responsibility to the VP nuclear operations. Subsequent discussions with TUGC0 QA personnel revealed that this position was discussed in the startup QA manual. This item is considered unresolved pending clarification of the QA plan and further review during a subsequent inspection. (445/8432-01; 446/8411-01) c. QA Program TUGC0 QA Program Plan and subtier procedures for design, construction, engineering, and procurement described the control of all related project and quality activities. A sample of these procedures were reviewed and documented in NRC Inspection Report No. 50-445/84-22; 50-446/84-07. The Quality Assurante Program (cescribed in the FSAR) provided the delegation on d sign, engineering, construction, and procurement functions te orime contractors, subco0 tractors, and vendors. It stated that' /s fUGC0 audit ' program assured that these organizations had adecut" crograms and verified implementation of the overall QA progrt.r . TUGCO.
5-l The inspectors reviewed the QA program procedures and any objective evidence to determine if the applicant regularly reviewed the status and adequacy of the QA program as required by Criterion II of Appendix 8 to 10 CFR 50, the PSAR and FSAR, and ANSI N45.2-1971. Reviews and discussions revealed no documented requirements or evidence that the.QA program status and adequacy had been reviewed by the applicant. 'In order to determine if the QA program had been . assessed, the inspectors reviewed additional information. In late 1981 and 1982 audits were performed by a consultant (Fred Lobbin), by Sargent and Lundy (using INPO criteria), and by TUGC0 (using INP0 criteria). Each of these audits evaluated limited aspects of the QA program. In 1983 Cygna evaluated the design program. The Lobbin Report (February 4, 1982) R-82-01, contained four major findings: level of experience within the TUGC0 QA organization is low; .i.e., commercial nuclear plant design and construction QA experience; staffing for the audit and surveillance functions is inadequate; the number and scope of design and construction audits conducted by TUGC0 QA to date has been limited; and QA management has not defined clearly the objectives for the surveillance program resulting in a program which, in the author's (Lobbin) opinion "is presently ineffective." The TUGC0 QA manager responded to these findings in an office memorandum (QBC-18), dated February 23, 1982. This response basically concurred with these findings. l The response committee to recruit nuclear experienced individuals, to increase the number and scope of site audits, and to more effectively use the surveillance program. Two program reports (QBC-25 and 29) regarding these matters were issued from the QA manager to the VP nuclear operations on May 21 and August 31, 1982, respectively. Following the Lobbin Report, the NRC performed a CAT inspection (IR 445/83-18; 446/83-12 dated April 11, 1983) and included a review of the TUGC0 audit program at the corporate offices. The inspection included a review of 18 audits (conducted between 1978 and early 1983), auditor qualifications, audit planning and scheduling, audit reporting and followup, and audit program effectiveness. The report concluded that weaknesses existed in the established QA audit program and included the scheduling and frequ. ncy of audits, the lack of e effective monitoring of 4 ' construction program, and the lack of effective resolution of t' 'y'n audit findings. The inspection also indicated that the QA 7- . should have been more effective.
P 4 6-t Based on the findings in the Lobbin report, and the findings in the NRC CAT report, the QA program continues to exhibit weaknesses. The continuing weaknesses in the QA program over a significant period of time reinforce the need for the applicant to routinely assess the status and adequacy of the QA program routinely to ensure that the areas are identified and adequate and timely corrective action is taken to correct the QA program weaknesses. The failure to regularly review the status and adequacy of the QA program as required is a violation of Criterion II of Appendix B to 10 CFR 50. (445/8432-02; 446/8411-02) d. Management of the TUGC0 Audit Program (1) Program Requirements 4 FSAR Subsections 17.1.2, "QA Program," and 17.1.18, " Audits," require internal audits of (TUGC0 corporate and site activities) and external audits (prime contractors, subcontractors and vendors) to evaluate the effectiveness of the QA program by verifying conformance with design requirements; compliance with established requirements, methods and procedures; and implementation of corrective action. These commitments require the establishment and implementation of a comprehensive system of planned and periodic audits of all aspects of the QA program. The TUGC0 audit program consisted of internal and_ external audits of design, construction, engineering, and procurement activities. TUGC0 also retained responsibility for the external audits that were usually delegated to the AE and NSSS organizations; i.e., audit of vendors. In. addition to construction and vendor audits, the TUGC0 audit group was also responsible for performing preoperational/startup and plant operation audits. TUGC0 committed to the audit requirements of ANSI N45.2.12-1973, Oraft 3, Revision 0, Section 3, " Audit System," and these program management objectives are: to determine that a QA program has been developed and documented in accordance with applicable requirements; j ] to verify that the program has been implemented, to assess program effectiveness; to identify program nonconformance; and r to verify program correction where p mpriate. ( l 1 l l
[ y -7~ l This section also stated that'to achiave these ANSI standard ) objectives full management backing, manpower.. funding, and facilities shall tHe available to implement the system of audits. (2) NRC Evaluation of Plannina/ Implementation of Program The NRC inspector reviewed and evaluated the applicant's plans. procedures, and number of audits performed (see paragraph 2e below) and determined that planning was inadequate. This audit effort was too large for the four available TUGC0 auditors in 1981, even though additional specialists were utilized to assist with the audit activities. (a) The inspector' reviewed and evaluated planning documents (formal and informal) used by the TUGC0 QA manager, supervisor QA services, and supervisor QA audits. The review and discussions with these individuals revealed that annual audit plans were based on the audit of organizations rather than activities. TUGC0 Audit Procedure DQP-CS-4, Revision 0, dated August 9, 1978 required: semiannual internal audits, semiannual construction audits, annual AE audits, annual NSSS audits, and annual plant operation audits. However, for vendor audits the procedure required: first audit at 15 percent; and second audit at 60 percent t " item completion" by reactor coolant pressure boundary vendors; one audit of engineered safeguards vendors at 25 percent item completion; and audit of balance of plant (other safety-related) sendors as determined by the manager QA. This does not meet the requirements of paragraphs 3.4.1 and 3.4.2 " Scheduling," of ANSI N45.2.12 which requires, " Auditing be initiated as early in the life of the activity as practicable... applicable elements of the QA program shall be audited at least annually or at least once within the life of the activity whichever is shorter." 1
/' . Furthermore, Audit Procedure DQP-CS-4, Revision 2, April 16, d 1981, and Revision 10, June 4, 1984, have further reduced the (scheduling) frequency of audits. Revision 10 now states, in i part, "3 2.1, The following organizations will be audited on a regularly scheduled basis but in accordance with Regulatory Guide (RG) 1.33, Revision 2, January 1978, Regulatory i Position 4:
a. AE; b. NSSS; c. constructor; d. TUGC0 Internal;

e. Preoperational/Startup; f. Plant Operations;

g. Subcontractor...
~~3.2.1 In lieu of regularly scheduled audits of vendors TUGC0 QA will perform the following:~~
a. Monitor the individual vendor ratings which are based on vendor performance... b. for those vendors who cannot be evaluated based on vendor ratir gs... regularly scheduled audits will be performed based on level of activity." The NRC inspector discussed with TUGC0 management the fact that RG 1.33 is for operations and does not fully address the requirements of the construction QA program.
This failure to develop audit program procedures which adequately address and describe QA program requirements and commitments is a violation of Appendix B, 10 CFR Part 50, Criterion XVIII (445/8432-03a; 446/8411-03a). (b) In addition to evaluating to determine if annual audits were planned, the NRC inspector requested objective evidence which would demonstrate that planning for audits for calendar years 1983 and 1984 included a method to verify compliance with all aspects of the QA program and to determine the effectiveness of the QA program. The review of the objective evidence revealed that the planning was not adequate, particularly regarding the audit. basis, status, and tracking. The only objective evidence available consisted of a listing of planned audits of internal organizations and contractors each year and a summary of 1983 audit results and criteria audited; however, this data in many cases did not list the criteria audited and while reviewing older audits it was noted that an "after the fact" review resulted in identifying the applicable criteria covered for various organization'is. The inspector requested a listing of selected site procedures which were in effect in 1983 that were representative of site ' safety-related activities and subject to audit by TUGC0 corporate QA. The review of the listings provided and the 1983 audits revealed the following information: t l l 1
f .g. Audits of Total Procedures % Audited 1 Procedures Procedures Audited / Referenced in 1983 l l TUGC0 Quality Documents Index (December 20, 1983) 295 71 24 TUSI Engineering Instruction Index (December 2, 1983) 65 16 25 TUSI Nuclear Engineering Procedures / Instructions Index (September 26, 1983) 26 18 69 TUSI Engineering Procedures Index (November 4, 1983) 30 12 40 B&R Quality Document Index (November 22, 1983) 51 20 39 B&R Construction. Procedures Index (June 20, 1983) 189 28 15 Total 656 165 25 Only 25 percent of the proceduees (specific safety-related activities) were audited in 1983. Although audits on a sampling basis are acceptable, there was no evidence that all safety-related areas were audited. The audits did not encompass all aspects of the QA program in order to determ'ne effectiveness. The failure to properly plan or produce evidence of adequate planning for a comprehensive audit program to verify compliance with all aspects of the QA program resulted in the failure to audit significant parts of the QA program is a violation of Criterion XVIII of Appendix B to 10 CFR 50 (445/8432-03b; 446/8411-03b). The NRC inspector contacted the Westinghouse iW1 site manager to review the procedure listing for safety-related activities which TUGC0 had audited. As indicated below, no audits of NS5$ site activities were performed in 1983. Discussions with the (W sitemanagerrevealedthatnoauditshadbeenperformedby)iUGC QA in 1977, 1978, 1979, 1980, or 1981. This was discussed with the TUGC0 audit staff and QA manager who did not disagree with the stated audit frequency.
9 I J - M Site Organization External Total Procedures % Audited Procedures Precedures Audited / Referenced in 1983 Westinghouse (W) Site Applicable Procedure, QA Manual, May 1983 18 ; PPD Procedures 14 Installation Procedures 29 The failure to audit (W) procedures (safety related activities) annually as required by ANSI N45.2.12, Draft 3, Revision 0, of the QA program is a violation of Criterion XVIII of Appendix 8 to 10 CFR Part 50, (445/8432-03c; 446/8411-03c). The NRC inspector discussed The staffing of the Audit Program (c) with TUGC0 QA management the findings of the Lobbin Report and the NRC CAT Team Report regarding t@e staffing of the audit functions. The discussions revealed that the TUGC0 audit staff had been increased from 4 to the present number of 12 between 1982 and 1984, and TUGC0 management has been looking for 3 or 4 additional nuclear experienced auditors to furtt.er increase the audit staff. However, it was also revealed that management had not determined the total audits required nor the manpower needed to accomplish the audits. This matter is an unresolved item pending the determination of the number of audits and auditors that will be needed to effectively implement the audit program (445/8432-04; 446/8411-04). The NRC inspector determined through review of charts and (d) procedures that current organization provided organizational freedom from cost and schedule. (e) The NRC inspector evaluated audit personnel qualifications by reviewing 14 personnel files of lead auditors and auditors. This included presently employed and formerly employed auditors. These personnel were qualified as required by TUGC0 Procedure DQI-QA-2.1, Revision 7, and ANSI N45.2.23-1978, " Qualification of Quality Program Audit Personnel for Nuclear Power Plants." (f) The NRC inspectors reviewed TUGC0 Audit Procedures DQP-CS-4, Revision 10 (June 4, 1984), and DQI-CS-4.6, Revision 7 (April 13, 1984). As previously' discussed in paragraph 2.C(1), DQP-CS-4 does not include adequate commitments to perform annual audits and failed to address both design and construction and plant operations audit requirements. l
.. Implementation of the TUGC0 Audit Program e. The NRC inspectors selected three areas of the audit program to review and evaluate implementation. Results of this evaluation are discussed in the following paragraphs. (1) Internal Audits of Site Activities - The NRC inspector reviewed the index which showed all site audits and found that Audits TCP-1 through TCP-112 had been performed between March 1978 and August 1984. The number per year are: (1) 4 in 1978; (2) 3 in 1979;-(3) 10 in 1980; (4) 11 in 1981;. (5) 30 in 1982; (6) 29 in 1983; and (7) 22 during the first 8 months of 1984. After the audit program was found inadequate in the consultant's report (Lobbin),- the number of audits increased from less than 1.0 per month in 1982 to 2.5 per month in 1982. After the NRC CAT inspection report in 1983 this number increased to 2.7 per month for the first 8 months of i l 1984. This indicates that positive action concerning these reported weaknesses was taken; however, as previously discussed objective evidence was not available that the required number of audits and auditors has'been identified. This item was previously identified above as unresolved. The 1983 and 1984 audit schedule included each. audit scheduled, cancelled, and any additional audits planned or performed. Where audits were cancelled, they were resche.duled and other audits were added and performed. This effort was well j documented. In 1983 the TOCCO audit group performed 158 aucits. Sisty-five internal audits of site activities are as follows: construction /QC/ engineering - 33 audits; startup - 5 audits; and operations - 27 audits. The NRC inspector selected and reviewed 31 TCP 1983 audits of site activities. The audit files included notification to the organization audited, an audit plan, checklists, an audit report, audit response, and evaluation / closeout of findings. l Audit reports reflected good preparation.and execution. L Substantial findings generally resulted and were resolved. l Several lead auditors'were interviewed concerning the management of the TUGC0 audit program. They stated that the audit program had weaknesses or deficiencies in 1978 but they had witnessed l dramatic improvements and were confident that the audit program was currently working well. I
t- ,. (2) Assurance of Design Control - TUGC0 management verified that design was controlled in accordance with the QA program requirements and procedures through administering an effective audit program. The design control functions were delegated to the AE ahd iWl; however, TUGC0 was designated the engineering organization responsibility for plant design. The NRC inspector reviewed and evaluated the results documented in 15 TUGC0 internal and external audit reports which specifically relate to Criterion III of 10 CFR Part 50, Appendix B, design and applicable procedures. These represent all audits design and consisted of 8 audits of TUGCO, 3 of {Wl, and 4 of G&H, engineering organizations. All audit findings, concerns, and deficiencies were closed through correspondence and were later verified through subsequent audits. Management involvement was evident as the VP nuclear operations was on concurrence and was furnished status reports by the QA manager. In October 1982, TUGC0 initiated a special audit effort to review design using the Institute of Nuclear Power Operations (INPO) performance objectives and criteria. Sargent & Lundy personnel were used to perform this audit. This audit identifieo 13 findings and TUGC0 audit No. TNO-2, dated June 1983, verified corrective action. (3) Assurance Control of Procurement Activities - TUGC0 management elected to retain procurement responsibilities except for certain functions delegated to the AE and NSSS. The NRC inspector selected several functions retained by TUGC0 to i determine if their audit program effectively monitored or verified that procurement activities were accomplished in accordance with the QA program and applicable procurement procedures. Management involvement with procurement documents, bid / source evaluation, and specific QA inputs were reviewed by the inspector. The vendor audits and evaluation of vendors were a large work effort. The following are the results of this review and evaluation. The NRC Comanche Peak Special Review Team Report dated July 13, 1984, at the site identified a potential violation, i.e., failure to perform annual audits of vendors. The report documented an inspection of the procurement effort at site and part of this inspection included determining the frequency of vendor audits. As a result of the special inspection, the TUGC0 QA manager approved an FSAR change request, dated August 3, 1984, which asked that TUGC0 be allowed to adopt NRC RG 1.144 audit requirements in lieu of ANSI N45.2.12, Draf t 3, Revision 0, for construction and ANSI N45.2.12, Draft 4, Revision 2 for operations. This requested change would net change the requirement to perform internal audits annually but
, would reduce the requirement to perform annual audits of suppliers. Considering this requested QA program change ~which had not been approved by the NRC, the following are the inspection results: The NRC inspector reviewed the TUGC0 vendor audit' program (a) for 1983 to determine compliance with commitments (FSAR Section 17, paragraph 17.1.18), ANSI N45.2.12 and TUGC0 procedures DQP-CS-4 and DQI-CS-4.5. The annual audit schedule revealed that 60 vendor audits were scheduled during 1983. Audit TCLC-2 was cancelled -(lack of activity with Purchase Order CPC-307) and audit TBS-3 was rescheduled (delayed by 1 week) as a result of.NRC CAT Team inspection findings. The NRC inspector selected 3 vendor audit files, TV0-1, TMH-3, and TBF-2, for review to determine the extent of the audits as applicable to the audit plan checklist, noted deficiencies, concerns, and comments. Also included in this review were the corrective actions and/or preventive action documented in writing by the vendor in response to the applicable audit findings. Documents in file closed the audit findings and ~ 1 indicated that followup on corrective action would be verified during the next audit. The NRC inspector reviewed the vendor audit frequency to determine if TUGC0 established a schedule to annually audit vendors. The licensee commitment to ANSI N45.2.12, Draft 3, Revision 0, requires annual audits or at least once within the life of the activity. Neither procedural requirements were established, nor were vendors audited annually. The failure to establish procedural requirements and to perform annual vendor audits is a violation of Criterion XVIII of 10 CFR Part 50, Appendix B and ANSI N45.2.12, Draft 3, Revision 0 (445/8432-03d; 446/8411-03d). (b) The NRC inspector reviewed the approved vendors list (AVL) program for 1983 to verify that methods used by TUGC0 to qualify vendors to supply safety-related materials, parts, and services were consistent with the QA plan, procedural requirements, and commitments described in A review of supplemental memos and ANSI N45.2.13-1976. preaward survey files and revisions 9 through 12 of the AVL verified that the AVL was cprrent. This review showed 33 additions, 40. status changes, and 1 deletion to the AVL for the period January 24, 1983, through December 20, 1983. Thc proaward survey files reviewed were consistent with
p Procedures DQP-CS-4, Revision 10, and DQI-CS-4.2, o Revision 3, December 1, 1982. During the review of preaward survey files, the inspector confirmed that formal identification letters, the survey date, and the scope of the survey (checklist) were consistent with the vendor QA program. Also, the corrective action responses by the supplier concerning noted deficiencies, concerns, and comments were reviewed, and followup action verified.in a subsequent audit. (c) The NRC inspector reviewed the vendor performance evaluation (VPE) system to determine compliance with commitment and procedural requirements. TUGC0 Procedure DQP-CS-4.3, paragraph 1.1 stated that the purpose of the evaluation was to establish a comprehensive method of identifying system weaknesses in vendor QA programs through acceptable / unacceptable hardware information generated as a result of vendor release inspections. The VPE files included release inspection trip report cover sheets, vendor rating sheets, releases, and the inspection checklists as required by TUGC0 Procedure DQI-CS-4.3, Revision 4, paragraph 3.1. The NRC inspector reviewed 3 VPE packages to determine that the quality assurance services (QAS) group's review was consistent with procedural requirements. One vendor file (Paul Monroe Hydraulic) was still active pending engineering review and evaluation on the 0-ring discrepancy identified during release inspection at Remo Hydraulics (Purchase Order CPF-11436-5 issued to Paul Monroe Hydraulics) for 20 hydraulic snubber assemblies. As required by DQP-VC-3, one vendor package (Meddco Metals) was being held on a yellow flag sheet to alert TUGC0 auditors of next request for release so that TUGC0 auditors could accompany the TUGC0 vendor compliance inspector to resurvey the vendor. One other vendor (Volumetrics) performance evaluation record was reviewed and it showed a vendor rating of greater than 90. The NRC inspector interviewed the QA audit supervisor to determine what objective evidence (as required by referenced TUGC0 Procedure DQ1-CS-4.3, paragraph 3.2) was used to perform the vendor evaluation and support vendor ratings. Preaward surveys, previous audits, and receiving inspection reports were used as objective evidence to give the rating. The NRC it3pector reviewed the receiving inspection activity for previous release inspection shipments relative to the aforementioned vendors. Receipt inspection consisted of shipcing damage inspection, receipt of documentation, identification, and quality assurance release.
j r s (d) The NRC inspector reviewed the method by which the licensee performed source selection to determine that procedural requirements were met. QA plan Section 4.0, Rev~ision 4, July 31, 1984, required that a purchase order for safety-related items not be issued'to a vendor unless TUGC0 QA had reviewed and accepted the purchase order; i.e., QA i determines whether QA provisions are adequate and. determines-that a preaward evaluation recommends selection of the vendor. When procurement solicited bids outside the AVL, TUGC0 QA requested that an uncontrolled copy of the vendors quality assurance manual be sent with the bid response. In the event of a positive bid response from the unapproved supplier, the TUGCC procurement group forwards the QAM and a request for QA program evaluation, Form QA-VE, to the TUGC0 QA audit group supervisor to initiate a preaward survey per QA Procedure DQT-CS-4.4, paragraph 3.1. However, until the preaward survey is completed and a supplemental memo has been issued by the audit group supervisor, no further procurement action was taken. The NRC inspector reviewed the actions taken when an acceptable bidder takes exceptions to the purchase order or subcontract. Upon receipt of the exception, procurement filled out an expediting request, assigns a procurement log number, and forwarded this request to the field requisition originator for engineering review and evaluation. Should the engineering group allow the exception, the necessary actions; i.e., design changes, were initiated. The expediting request was returned to procurement accompanied by a field requisition documenting the change with the approval signatures of engineering and QA. l (e) The NRC inspector reviewed the method by which TUGC0 performed vendor item acceptance of safety-related materials, parts, and components. TUGC0 Procedure DQP-VC-1, Revision 8, June 4, 1984, paragraph 1.1, specified that the purpose was to er*ablish guidelines for performing final inspection and release of TUGC0 purchased equipment and applies to both safety-related and nonsafety-related equipment. This procedure allowed for a waiver, in which case the inspection checklist applicable to the procurement specification became the responsibility of CPSES receiving inspection as described in B&R CPSES Procedure CP-QAP-8.1, l Revision 8, June 11, 1984, paragraph 3.4.1 (f) The NRC inspector reviewed six' vendor compliance inspector's files to determine if training / certification i s ---- ------.
l 8 i records met the requirements of ANSI N45.2.6-1978 and TUGC0 ~ Procedure DQP-VC-4, " Guidelines for Certifying Vendor Compliance Personnel." Section 3.2.2 states that a Level II inspector shall attend and satisfactorily complete the nondestructive examination (NDE) courses. One inspector had not completed all of the NDE courses but had been certified. This finding was discussed with the vendor compliance supervisor who stated that there is no real need for certification in eddy current t3 sting since inspectors do not utilize this NDE technique and the requirements would therefore be deleted from the procedure. The NRC inspector verified the deletion of this requirement and procedural revision during this inspection. l The failure to certify the inspector in accordance with the procedure is a violation of Criterion V of Appendix B to 10 CFR 50 (445/8432-05; 446/8411-05). No other violations or deviations were identified. 3. TUGC0 Corporate QA - Site QA Activities Interface Appendix B to 10 CFR Part 50 requires TUGC0 to establish proper organizational and management interfaces, and procedures must describe how various organizations coordinate and communicate design, procurement, engineering, construction, and QA/ control activities and information. The following paragraphs describe inspection of this requirement. a. Site Organization TUGC0 Procedure CP-QP-3.0, Revision 15, July 30, 1984, described the site QA organization for design and construction. This organization consisted of a site QA manager, QA supervisor, and a QC supervisor. The site group performed no audit function, however, they did perform QA surveillance. The site group consisted of 13 QA/QC managers and more than 150 lead /QC inspectors and quality engineers. These personnel inspected non-ASME work. B&R QA manual and implementing Procedure CP-QAP-03.01, Revision 6, described their responsibilities for QA/QC and construction activities pertaining to ASME work. This organization consisted of a QA manager, QE supervisor, and a QC supervisor. The total QA/QC work force involved with design / construction activities was approximately 100. Several other site subcontractors such as Bahnson, Brand Industrial Services, Inc., and Chicago Bridge and Iron, have small QA groups on site and, as is the case with B&R, these organizations were audited by their respective corporate offices. I
E j. 1 The NRC inspector interviewed the TUGC0 site QA manager to determine how the site QA group interfaced with the corporate QA office. He stated that daily conversations occur between managers of these organizations, however, he did not make written summary reports. Quarterly trending reports which analyze reported nonconformances and i deficiencies are sent to the corporate QA manager. l b. Site Surveillance The.NRC inspector noted that surveillance were briefly mentioned in TUGC0 Procedure DQP-CS-4, Revision 10; however, there was no mention of how or if the surveillance would be used to complement the audit program. During discussions with the QA manager and other personnel, it was revealed that procedures were not tracked to assure that all were audited. The present audit staff could not audit all site procedures annually. The NRC inspector pointed out that the surveillance function may complement and be used to (1) check that all procedures,are implemented; (2) identify nonconforming trends; and (3) to feed potentially deficient or weak areas to the audit group which could, in turn, factor this information into the audit program. Audit priorities could then be established and-the audit per.sonnel could be more effectively used. TUGC0 Surveillance Procedures CP-QP-11.2, 19.3, 19.4, 19.5, 19.6, 19.7, 20.0, and 27.0 described the surveillance of specific activities; however, no general procedure which describes the overall surveillance program was provided. The present program did not appear to have sufficient purpose, direction, coordination, and feedback in relationship with the overall QA program. Furthermore, the inspection revealed that the surveillance staff had been reduced from a supervisor and eight technical personnel to four technical j personnel. Considering the Lobbin Report this reduction of l surveillance effort may not be a prudent action. As noted in the findings in the Lobbin Report; i.e., QA management had not clearly defined the objectives and scope of the surveillance { i program, it appeared that TUGC0 needed to strengthen the surveillance The TUGC0 management decision to commit to,a surveillance program. program was a strength, but this lack of purpose and direction and support was a program weakness. Additionally, the surveillance group was no longer observing work in Unit 1 but will now place most of their effort on Unit 2 construction activities. This matter is considered unresolved pending clarification of the audit and surveillance program efforte and further review during 2 subsequent inspection (445/8432-06; 446/8411-06). I 1
The NRC inspector randomly selected and reviewed 28 surveillance performed in 1982, 1983, and 1984. Findings and resolutions of these findings were reviewed and in each case, written responses and corrective action were adequate. c. Site Desion Activities The NRC inspector reviewed and evaluated selected site activities pertaining to design verifications, design changes, design inputs, and control of vendor drawings as follows: (1) Design Verification - The NRC inspector interviewed the TUGC0 supervisor of engineering, support, and other engineering personnel to determine how design verifications were performed, and examined the related procedures, logs, and design i verification packages. Authorized design verifiers were maintained on lists and an automated tracking system was in place to assure that all design changes, i.e., design change authorizations / component modification cards (DCA/ CMC) were verified. Three design verification reports were reviewed to assure that the design verifier was on the authorized list. Design verifiers were not to be involved in the original design review to assure an independence. It was noted that each DCA/ CMC was being reviewed for verification. If there was no authorized signoff, then the design was verified. Audit TGH-23, conducted during August 1984, concentrated on Unit 1 quality related activities for which onsite G&H design review team had responsibility. The audit involved evaluation of the program established and implemented for site review and processing of changes (CMA and DCC) associated calculations and 287 design review packages were reviewed. No major technical problems were identified during this audit. (2) Design Changes - The NRC inspector interviewed engineers and draftsmen in TUGC0 engineering to determine how design changes were processed and examined the related procedures, files, reports, and tracking systems. A master list was maintained identifying those individuals who were authorized to approve design changes and G&H updates this list by memo. The NRC review of three design review files verified that the reviewers were on the authorized list. The NRC inspector also reviewed'the method used to incorporate field changes (DCA/ CMC) into related drawings and the subsequent [ review, approval, and incorporation of changes into as-built (- drawings. One observation required additional discussions. The drafting supervisor's (piping support) authority to incorporate a change into a drawing was transmitted and signed by a clerk. This was clarified as being acceptable by management because it ( j
y y . 1 ) was in accordance with established procedure (CP-El 4.6-8, paragraph 3.3) and also, as a final control, the as-built ~ drawing was reviewed and approved by an authorized project engineer prior to release. ~ The NRC inspector examined how the TUGC0 administrative services ' group handled NRC 'IE Bulletins, Circulars, and Information These documents were coordinated by the operations Notices. support department and were distributed to the appropriate TUGC0 engineering group for action. Design changes-resulting from ) these inputs were processed in accordance with established ] 0 design control procedures'. Responses from personnel receiving these reports were reviewed to verify that the reports were _. adequately addressed. Summary reports and log sheets are.used-to keep management current as to the status of the responses. An INPO audit of the operating experience review program in 1982 noted the following good practice, "The procedures for handling industry experience are. excellent and are expected to provide a firm base for developing an effective industry experience program." TUGC0 QA audit Report TUG-41 was conducted in December 1983 to review implementation of the operations support program-for evaluating and responding to NRC IE Bulletins, IE Notices, IE Circulars, and generic letters. The auditors found the program in compliance with procedural requirements and the 1 1 overall effectiveness of the program appeared to be adequate. Design Document Control - lwo packages were reviewed and these (3) contained evidence of vendor data checklists, indexes, approval letters,'and the vendor stamp on drawings was observed. d. Site Procurement Activities The NRC inspector determined that the TUGC0 procurement function-was delegated to the TUGCO site organization. The major procurement-occurred several years ago; however, present procurement activities associated with items procured offsite for installation were performed byTUGC0orwerecontractedtoG&H,{WJ. orb &Rwhowereevaluated Procurement documents were reviewed, and qualified by TUGC0 QA. approved,-and controlled; and receipt inspection of safety-related items-on site was performed in accordance with written procedures and checklists. The NRC inspector selected two procurement actions for review: P.O.CPF-1233-SissuedtoCombuskion-Engineeringforthe procurement of a heated junction thermocouple system. CPF-10469-5 issued to Paul Monroe Hydraulics to refurbish four Rockwell International actuators.
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t' m..".',W L L ?ff. 0 L'. n. March 11, 1985 TXX-4435 Dorwin R. Hunter, Chief Reactor Project Branch.2 U.S. Nuclear Regulatory Commission I Office of Inspection & Enforcement 611 Ryan Plaza Drive, Suite 1000 Docket Nos.: 50-445 l Arlingtnn, TX 76011 50-446 COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 84-32 FILE N0;: 10130
~~Dear Mr. Hunter:~~
We have reviewed your letter dated February 15, 1985 regarding the inspection conducted under the Resident Inspection Program by H.S. Phillips of activities authorized by NRC Construction Permit CPPR-125 for Comanche Peak Units 1 and 2. Our review of the findings cited in the Notice of Violation under Appendix A to your letter indicates that two of the findings are similiar in nature to those identified by the NRC Technical Review Team (TRT). In accordance with one of your' proposed response options, we have elected to respond to findings 1 and 2 of the Notice of Violation as part of the Comanche Peak Response Team Action Plan. We are providing a. response to Finding No.'3 in Appendix A of your letter. To aid in the understanding of our response, we have repeated the finding from the Notice of Violation followed by a summary of our corrective actions. The documentation of specific corrective actions is available at the TUGCo QA Dallas office for your Inspector's review. If you have any questions, please advise. l Very truly yours, ./ A.R.Clements B ) BRC:tig j Attachment ._ M /MlA /lM / yy v a v rv I A Ut t~lNitDN thr TEXAN l*TILITIEN ELLCTNIC COMPANY l j
0 4 cc: NRC Region IV (0 + 1 copy) Director, Inspection & Enforcement (15 copies) U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. V.S. Noonan / l t i
F l a., f s-l TXX-4435' l .3/11/85 l Page 2 1 ATTACHMENT FAILURE.T0 PROPERLY CERTIFY A VENDOR COMPLIANCE INSPECTOR Failure to Properly Certify a Vendor Comoliance Inspector Criterion V of'10 CFR 50,~ Appendix B, states in part, "A:tivities affecting quality shall bW prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." j TUGC0 Procedure 0QP-VC-4, Revision 6, dated January 5, 1984, requires that Level 'Il inspectors (Corporate QA) shall attend and satisfactorily complete nonde- .structive testing courses including eddy current testing. Contrary to the above, one of six inspector's files had no documentation to show that the inspector had attended and completed an eddy current testing course. Subsequent, discussions revealed that he had been certified without meeting this requirement. The vendor compliance supervisor stated thy this inspection skill is not needed since there is no present vendor work activity _which would require this skill; therefore, this procedure was revised and the requirement omitted during this inspection. This is a Severity Level V Violation. (Supplement II) (445/8432-05; 446/8411-05) Corrective Steps which have been taken and the results achieved: The certification of'the inspector without the required eight (8) hour training was an oversight. /, review of' all six (6) Vendor Compliance Inspector's work reflected no instance where eddy current testing was involved. The procedure revision' discussed below was processed to reflect our actual inspection needs. Corrective steps which have been taken to avoid further violations: As there is no present nor planned vendor work activity which wouId require this skill, TUGCo Procedure 00P-VC-4 has been revised by deleting the requirement for an eight (8) hour training course in eddy current testing. Should the need for a familiarity with eddy current testing arise, the Vendor Compliance Supervisor will take the necessary action to either train or obtain' a qualified inspector. Date when full compliance will be achieved: Procedure DQP-VC-4 was revised August 27, 1984
,j ,g,j( h ) ./ In_ Reply Refer To: MI " Dockets: 50-445/84-32 50-446/84-11 c Texas Utilities Electric Company l ATTN: M. D. Spence, President, TUGC0 1 Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 f Gentlemen: i Thank you for your letter of March 11, 1985, in response to our letter and Notice of Violation dated February 15, 1985. We have reviewed your reply and j find it addresses the concerns raised in item 3 of our Notice of Violation. l We will review your corrective actions for items 1 and 2 as part of our examination of the Comanche Peak Response Team Program Plan. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained. Sincerely, ,,yeat synod W-g i WJHTER, Dorwin R. Hunter, Chief Reactor Project Branch 2 cc: Texas Utilities Electric Company ATTN: B. R. Clements, Vice President, Nuclear Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 l Texas Utilities Electric Company ATTN: J. W. Beck, Manager, Licensing ,-s u n Skyway Tower 'WN / ~ 400 North Olive Street ) Lock Box 81 Dallas. Texas 75201 j RPB2/PSB RPB2 DRS&P NR DMHunnicu t:gb DRHun er RPDeryise V dr/ V85 f/ /85 1-)/;D/85 A/n /85 \\ 4
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..u ?Ah! ",2fM"."!",.... March 11, 1985 TXX-4435 Dorwin R. Hunter, Chief I Rea: tor Project Branch 2 U.S. Nuclear Regulatory Commission 1 Office of Inspection & Enforcement 611 Ryan Plaza Drive, Suite 1000 Docket Nos.: 50-445 50-446 ~ ' Arlington, TX 76011 COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 84-32 i FILE NO.: 10130 i
~~Dear Mr. Hunter:~~
We have reviewed your letter dated February 15, 1985 regarding the inspection conducted under the Resident Inspection Program by H.S. Phillips of activities authorized by NRC Construction Permit CPPR-125 for Comanche Peak Units 1 and 2. Our review of the findings cited in the Notice of Violation under Appendix A to your letter indicates that two of the findings are similiar in nature to those identified by the NRC Technical Review Team (TRT). In accordance with one of your proposed response options, we have elected to respond to findings 1 and 2 of the Notice of Violation as part of the Comanche Peak Response Team Action Plan. We are providing a response to Finding No. 3 in Appendix A of your letter. To aid in the understanding of our response, we have repeated the finding from the Notice of Violation followed by a summary of our corrective actions. The documentation of specific corrective actions is available at the TUGCo QA Dallas office for your Inspector's review. If you have any cuestions, please advise. Very truly yours, f = w.5
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~ L a. TXX-4435; sN-3/11/85L Page 2- .i ATTACHMENT . FAILURE TO PROPERLY CERTIFY A 1 VENDOR COMPLIANCE INSPECTOR T. ~ Failure to Properly Certify a Vendor Compliante Inspector CriterionLV'of 10 CFR 50,.Appendii B, states in part, " Activities affecting quality.shall be prescribed by documented instructions, procedures, or drawings, ' of a type appropriate.to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." TUGC0 Procedure DQP-VC-4, Revision 6, dated January 5, 1984, requires that Level. II inspectors (Corporate QA) shall attend and satisfactorily complete nonde-structive; testing courses including eddy current testing. l ' Contrary to the above,:one of six inspector's files had no documentation to.show that the inspector had attended and completed.an eddy current testing course. Subsequent, discussions revealed that he had been certified without meeting this. requirement. -The vendor compliance supervisor stated that this inspection skill. .is not needed since there is no present vendor workiactivity which would require this skill; therefore, this procedure was revised and the requirement omitted during this inspection. This is a Severity Level V Violation. (Supplement II) (445/8432-05; 446/8411-05) Corrective Steps which have been taken and the results achieved: The certification of the inspector without the required eight (8) hour training was an oversight. A review of all six (6) Vendor Compliance Inspector's work reflected no instance where eddy current testing was involved. The procedure . revision discussed below was processed to reflect our actual inspection needs. Corrective steps which have been taken to avoid further violations: As there is no present nor planned vendor work activity which would require this skill, TUGCo Procedure DQP-VC-4 has been revised by deleting the requirement for an eight (8) hour training course in eddy current testing. Should the need for i a familiarity with eddy current testing arise, the Vendor Compliance Supervisor will take the necessary action to either train or obtain a qualified inspector. Date'when full compliance will be achieved: Procedure DQP-VC-4 was revised August 27, 1984 1
o. In Reply Refer To: Occkets: $0-445/85 40031986 50-446/85-05 Texas Utilities Electric' Company ATTH: W. G. Counsil Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Centlemen: This refers to the inspection conducted under the Resident Inspection Program by Messrs. J. E. Cummins and H. S. Phillips and others during the period April 1, 1985, through June 21, 1985, of activities authorized by NRC Construc-tion Permits CPPR-125 and CPPR-126 of the Comanche Peak facility, Units 1 anc 2, and to the discussion of our. findings with Mr. J. T. Merritt, and other members of your staff at the conclusion of the inspection. Areas examined during the inspection included plant status, action on ' previous NRC inspection findings, action on applicant identified design construction deficiencies (10~ CFR Part 50.55(e) reports) and plant tours. Within these areas, the inspection consisted of selective examination of proceoures and representative records, interviews with personnel, and observations by the inspectors. ~ These findings are documented in the enclosed inspection repcrt. During-this inspection, it was found that certain of your activities were in violation of NRC requirements. Consequently, you are required to respono to this violation, in writing, in accordance with the provision of'Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter. Since B&R Procedure 35-1195-CCP-10 has been revised to provide documented inspection of truck mixer blades, there was no abnormal blade wear identified as a result of blade inspection, and there have been consistent concrete strength and uniformity tests, no reply to violation 2.c is required. h RSS b RSS CPT G DRSP NRR hSPhillips/dc DMHunriicutt TFWesterman EHJohnson VNoonan ' !/.3/86 //g86 / / h/86 l /g/8p 7 /u/86 4B Y,~J ! % i M G.. f ,e-' .= ~ 9
Texas-Utilities. Electric Company 2 Should you have any questions concerning this inspection, we will be pleased l to-discuss them with you, i Sincerely, 06@o) S g, Y.. E. H. Johnson, Acting Director Division of Reactor Safety and Projects
~~Enclosures:~~
1. Appendix A - Notice of Violation 2. Appendix B - NRC Inspection Report 50-445/85-07 50-446/85-05 cc w/ enclosure: l Texas Utilities Electric Company ATTH: J. W. Beck, Manager, Licensing Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Juanita Ellis President - CASE 1426 South Polk Street Dallas, Texas 75224 Rene6 Hicks Assistant Attorney General Environmental Protection Division P. O. Box 12548 Austin, Texas 76711 Texas Radiation Control Program Director bec to DMB (IE01) bec distrib, by RIV:
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,,0 j f APPENDIX A NOTICE OF VIOLATION l l l Texas Utilities Electric Company Docket: 50-445/85-07 l Comanche Peak Steam Electric Station 50-446/85-05 Units 1 and 2 Permit: CPPR-126 CPPR-127 I During an NRC inspection conducted on April 1 through June 21, 1985, violations of HRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, j Appendix C (1985), the violations are listed below: i 1. Failure to Promptly Correct an Identified Problem with RTE - Delta Potential Transformer Tiltout Subassemblies 10 CFR 50, Appendix B, Criterion XVI, as implemented by Texas Utilities 1 Generating Company (TUGCO) Quality Assurance Plan (QAP), Section 16.0, Revision 0, requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficien-cies deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, a potential problem with RTE - Delta potential transformer tiltout subassemblies, which are used in the emergency diesel generator control panels, was identified to the applicant via a letter, dated June 15, 1983, from Transamerica Delaval Inc. This letter also provided instructions for correcting the potential problem. However, the applicant did not take the corrective action. The NRC initially reported this item as unresolved in NRC Inspection Report 50-445/84-40. This is a Severity Level IV violation. (Supplement II.E) (445/8507-01 446/8505-01). 2. Failure To Follow Procedures 10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 QAP, Section 5.0, Revision 2 requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accor-dance with these instructions, procedures, or drawings. Drawing 2323-51-0550, Revision 4, Section 6-6 specified the use of a. Class E" concrete for the Unit 1 reactor coolant pump and steam generator supports. w) ~ f-h.4 t 3.n aca 0:000g L
2 Contrary to the above, commercial nonshrink grout was used to grout the Unit 1 reactor coolant pump and steam generator supports in lieu of Class "E" concrete. (445/8507-02) This is a Severity Level V violation (Supplement II.E). b. Brown and Root Procedure QI-QAP-7.2-8, " Receiving of Westinghouse Safety Related Equipment," Section 3.1.d.1, requires a QC inspector to verify that the Westinghouse Quality Release (QR) document i checklist items be filled out completely and accurately. Contrary to the above, the voltage recorded on Westinghouse QR 41424 checklist, attachment 1, step 4.1, was outside the specified tolerance, but the QC receipt inspector accepted QR as satisfactory. (445/8507-03) ~ This is a Severity Level IV violation. c. Brown & Root Procedure 35-1195-CCP-10, Revision 5, dated December 4, 1978, requires that central and truck mixer blades be checked quarterly to assure that mixer blade wear does not exceed a loss of 10% of original blade height. Contrary to the above, on May 31, 1985, the NRC inspector determined that there was no objective evidence (records) that the mixing blades had been inspected quarterly since the trucks were placed in service in 1977. (445/8507-04; 446/8505-02) 1 This is a Severity Level V violation (Supplement II.E) ) d. Brown & Root Procedure CP-QAP-15.1, " Field Control of Nonconforming i Item, " states that nonconforming conditions shall be documented in a Deficiency and Disposition Report (DDR). Procedure CP-QCP-1.3, " Tool Equipment Calibration and Control," dated July 14, 1975, states that out-of-calibration equipment shall be identified on a DDR. Contrary to the above, on May 31, 1985, the NRC inspector reviewed the calibration file for scale (MTE 779) used for weighing cement and found that a 24-48 pound deviation from the required accuracy was encountered with the water and cement scales during a 1975 calibration of the backup plant scalts, however, no DDR was issued to identify this condition and require disposition of the scale and concrete (if any) produced. (445/8507-06; 446/8505-04). This is a Severity Level IV violation'(Supplement II.E). l
i 3-Pursuant to-the' provisions of 10 CFR 2.201, Texas Utilities Electric Company is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violations if admitted, (2 the corrective steps which have been taken and the results achieved. (3 the corrective. steps which will be taken to avoid further violations, and -(4 the date.when full compliance'will be achieved. Where good cause is shown, consideration will be given to extending the response time. Dated at Arlington, Texas, this 3rd day of February,1986 i e 4 i 1 i
.. n. APPENDIX B U. S. NUCLEAR REGULATORY COI411SSION REGION IV 1 j 'i NRC Inspection Report:- 50-445/85-07 Permit: CPPR-126- _ 50-446/85-05 CPPR-127 -Docket: 50-445; 50-446: . Applicant: Texas Utilities Electric Company'(TUEC) 1 Skyway. Tower .j 400 North Olive ' Street k ' Lock Box 81- ) Dallas, Texas 75201 i i Facility Hame: Comanche Peak Steam Electric Station (CPSES) Units 1 and 2 l 4
Inspection At: Glen Rose, Texas-Inspection Conducted: April 1, 1985, through June 21,'1985

l t
~~Inspectors: / y/ / //I[ H. S. Phillips, Senior Resident. Date . Reactor Inspector Construction .i .(pars. 1, 2, 3,~8, 9, 10, 11, 15, 16, 17, 18, and 19) .b 17.' M e w i k /cth/ 2 5' v~~
~~d. E. Cumins, Senior Resident Reactor Date~~
[ Inspector Construction (April 1 - May 10,1985) (pars. 1, 3, and 19) /~ i y' f id///ff / D. E. Norman, Reactor Inspector Date i (pars. 1, 12, 13, 14, and 19) i .b ll Ymts.x---t- /3/Ll?S' D. M. H~nnicutt, Section Chief Date u Reactor Projects Branch 2 (pars. 1, 4, 5, 6, 7, and 19) 10
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gWABMA5BS{}j? i
) i ~ -E-Approved: Mkbh //.2Fdd D. M. Hunnicutt, Section Chief, ' Date Reactor Project Section B Inspection Sumary Inspection Conducted April 1,1985, through June 21,1985(Report 50-445/85-07) Areas Inspected: Rcutine, announced and unannounced inspections of Unit 1 which included plant tours and review of plant status, action on previous NRC inspection findings (violations / unresolved items), review of documentation for site dams, and review of 10 CFR Part 21 and 10 CFR Part 50.55(e) construction deficiency status, The inspection involved 77 inspector-hours onsite by four NRC inspectors. Results: Within the areas inspected, five violations were identified: fail-ure to promptly torrect an identified problem with RTE - Delta Potential i Transformer Tiltout Subassemblies, paragraph 3.a.; comercial non-shrink grout { was used to grout the Unit i reactor coolant pump and steam generator supperts I in lieu of Class "E" concrete, paragraph 3.b.; hydrogen recombiners out-of-specification voltage recorded on quality release document but QC receipt inspector accepted, paragraph 3.c; failure to provide objective evidence to show that central and truck mixer blades were inspected, paragraph 8; and failure to issue a deficiency report on cement scales that were out-of-calibra-tion, paragraph 9.c. Inspection Summary Inspection Conducted April 1,1985, through June 21, 1985 (Report 446/85-05) Areas inspected: Routine, announced and unannounced inspections of Unit 2 which includeo plant tours and review of plant status, action on previous NRC inspection findings (violations / unresolved items), review of documentation for site dams, review of documentation for voids behind the stainless steel cavity liner af reactor building, obse.rvation of NDE on liner plates, inspection of concreN batch plant, review of calibration laboratory records for batch plant, review of concrete laboratory testing, inspection of level C and D storage, review of reactor pressure vessel (RPV) and pipin review of 10 CFR Part 21 and 10 CFR Part 50.55(e)g records / completed work, and construction deficiency l l status, and review of violation and unresolved items status. The inspection involved 335 inspector-hours onsite by four NRC inspectors. Results: Within the sixteen areas inspected three violations were identified: failure to correct RTE-Delta transformer problem, paragraph 3.a; failure to provide objective evidence to show that concrete central and truck mixer blades were inspected, paragraph 8; cod failure to issue a deficiency report on cement ( scales that were out-of-calibration, paragraph 9c. l l I -_.-_.-.______.___w____
. ' DETAILS 1. Persons Contacted Applicant Personnel M. McBay, Unit 2 Reactor Building Manager B. Ward, General' Superintendent, Civil D. Chandler, QA/QC Civil Inspector W. Cromeans, QA/QC, TUGC0 Laboratory / Civil Supervisor
J. Merritt, Assistant Project General Manager-

P. Halstead, Construction Site QA Manager
~~C. Welch, QA Supervisor TUGC0 (Construction)~~
~~J. Walters, TUGC0 Mechanical Engineer K. Noman, TUGC0 Mechanical Engineer J. Hite, B&R Materials Engineer G. Purdy, B&R CPSES QA Manager~~
~~Denotes those present at May 10, 1985 exit interview.~~
~~Denotes those present at June 10, 1985 exit interview.~~
The NRC inspectors also interviewed other applicant employees during this inspection period. 2. Plant Status Unit,j, At the time of this inspection, construction of Unit I was 99 percent complete. The fuel loading date for Unit 1 is pending the results of ongoing NRC reviews. Unit 2 At the time of this inspection, construction of Unit 2 was approximately 74 percent complete. Fuel loading is scheduled for approximately 18 months after Unit 1 fuel loading. 3. Applicant Action on Previous NRC Inspection Findings a. (Closed) Unresolved Item 445/8440-02: Potential Problem with Potential Transformer Tiltout Subassemblies. 1 By letter dated June 15, 1983, Transamerica Delaval notified the 1 l applicant of an RTE - Delta 10 CFR Part 21 report to the NRC 1 reporting a potential problem with the primary discornett clips of the potential transformer tiltout assembly used in the energency l diesel generator control panels at CPSES. The Transamerica Delaval 3
l i \\ i 1 - Ietter also provided instructions for correcting'the problem. However, the NRC inspector could not determine if the problem had been corrected at CPSES and made this an unresolved item. The applicant determined that the problem had not been corrected and subsequently performed the recommended corrective action. The Unit 1 corrective action work activities were documented on startup work permits 2-2912 (train A) and Z-2914 (train B). The Unit 2 work activities are being tracked as master data base (MDB) item 3003-31. The failure to promptly correct this identified problem is an apparent violation (445/8507-01; 446/8505-01). b. (Closed) Unresolved Item 445/8416-03: Commercial Grout Used in Lieu I oTT) ass "E" Concrete The applicant determined that the use of nonshrink commercial grout in lieu of the Class "E" concrete specified on drawing 2323-SI-0550 was acceptable. Design Change Authorization 21179 was issued to drawing 2323-$1-0550 accepting the use of the commercial non-shrink grout. However, the failure to grout with Class "E" concrete as specified on the drawing at the time the work was accomplished is an apparent violation (445/8507-02). c. (Closed) Unresolved Item 445/8416-04: Hydrogen Recombiners - _0ut-of-Specification Voltage Recorded on Westinchause Quality Release Document Quality Release N-41424 was revised by Westinghouse changing the specified voltage from 10+-2V to 12+-2V which put the questionable voltage within specification limits. However, the f ailure of receipt inspection to verify that the QRN-41424 was filled out accurately as required by Procedure QI-QAP7.2-8 is an apparent violation (445/8507-03). I d. (0 pen) Unresolved Item 445/8432-06; 446/8411-06; Lebbin Reoort Described Site Surveillance Program Weaknesses During this reporting period the NRC inspector reviewed the status of this open item several times and interviewed TUEC management and site surveillance personnel. The Lobbin report stated that the scope and objectives of the site surveillance program were unclear, lacking l both purpo'se and direction. There is no specific regulatory requirement to have a surveillance program; however, TUEC committed to have a surveillance program and has established procedures to implement such a program as a part of the 10 CFR Part 50, Appendix B, QA program. This extra effort is a strength; however, the NRC inspector also observed, as did the Lobbin Report, that the surveillance program lacks both purpose and direction to be effective and complimentary to the audit and
inspection programs. Since the TUEC audit group is not located on site, the TUEC surveillance program on site takes on added significance. This item was discussed with the TUEC site QC manager who described a reorganized site surveillance function and changes that have occurred. New procedures which describe this organization's duties and responsibilities are forthcoming. TUEC has elected to defer responding to the violations pertaining to the audit function in NRC Inspection Report 445/84-32; 446/84-11, but rather to have the Comanche Peak Response Team (CPRT) respond to this report and other QA matters. The surveillance issue is closely tied to the audit deficiencies in NRC Inspection Report No. 445/84-32; 446/84-11. This item will remain open pending the review and imple-mentation of the CPRT action plan. A special point of interest will be how audits and surveillance work together to evaluate the control of all safety-related activities on site to assure quality, especially the overview of quality control effectiveness. i 4 Document Inspection of Site Dams The NRC inspector reviewed documents describing the inspection activities p(erformed on the Squaw Creek Dam (SCD) and the safe shutdown impoundme SSI) for impounding cooling water for the two units at CPSES. The purpose of the SCD is to impound a cooling lake for CPSES. A secondary reservoir (SSI) is formed by a channel connecting the SCD impoundment to the SSI. Three documented inspections have been performed since 1980. The inspections were: Relevant data for SCD is contained in Phase I Inspection, National a. Dam Safety Program, Squaw Creek Dam, Somervell County, Texas, Bra:os River Basin, inspection by Texas Department of Water Resources. Date of Inspection: June 10, 1980. b. Inspection on August 25, 1982, by registered professional engineers from Mason-Johnston & Associates, Inc., and Freese & Nichols, Inc. c. Inspection on Septemoer 19, 1984, by a registered professional engineer from Mason-Johnston & Associates, Inc. The inspection activities consisted of visual inspections by inspection teams that included accompanying Texas Utilities Service Inc. (TUSI), and Texas Utilities Generating Company (TUGCO) representatives. Photographs were taken as a part of the documentation. The data for the
piezemeter observations and the data for the surface reference monuments were reviewed by applicant personnel and Mason-Johnston engineers. No items of significance were observed or reported by these inspection teams. Slight erosion areas were observed and reported. A cracked area on the service spillway upstream right bridge seat was observed by the inspection teams and continued monitoring of this area was recommended.by Mason-Johnston and Associates. No signs of cracks, settlements, or horizontal movement at any location within the SCD or the SSI were reported. The NRC inspector reviewed the apolicant's records and the Mason-Johnston inspection reports. These docume!ts indicated that the SCD and SSI were structurally stable arid that the applicant was performing inspection activities to maintain the structural integrity of these dams. The state of Texas requires periodic inspections of these dams (principally the SCD) due to inhabited dwellings downstream. The applicant has met these inspection requirements. No violations or deviations were identified. 5. Voids Behind the Stainless Steel Cavity Liner in Unit 2 Reactor Buildina In review of previous related TRT concerns, the NRC inspector reviewed applicant records, including NCR C-82-01202; UCR C-1784, Rev.1; NCR - C-1784, Rev. 2; NCR C-1766, Rev.1; NCR C 1791, Rev.1; NCR C-1824, Rev.1; NCR C-1824, Rev. 2; Significant Deficiency Analysis Report (SDAR) - 26, dated December 12,1979; DCA-20856; and Gibbs and Hill Specification 2323-SS-18. The review of records and documentation and discussions with various applicant personnel indicated the following: } Structural concrete was placed in Unit 2 reactor building at elevation 819 feet 6-3/4 inches to 846 feet 6 inches on June 21, 1979. This concrete was placed adjacent to the stainless steel liner wall s. The concrete forms for this pour were not removed until October 1979 due to subsequent concrete placements for the walls to elevation 860 feet 0 inches. When the forms were removed, honeycombs and voids were observed by applicant personnel. The applicant's review of the extent of unconsolidated concrete resulted in the issuance of SDAR-26 on December 12, 1979. Investigations were begun and Meunow and Associates (H&A) of Charlotte, North Carolina, were contracted to perform nondestructive testing on in-place concrete. M&A performed these tests on '. two foot grid pattern on the compartment and liner sides of all four steam generator (SG) compartment walls. The selected test locations did not include the locations where the voids were later found to be located. t-I [.
. In August 1982, preparations were made to pour the concrete annulus ~ around the reactor vessel. When the expanded metal formwork was removed from the reactor side of the compartment walls, voids were observed and NCR C-82-01202 was prepared. DCA 20856 was prepared as a procedure to repair the void area. DCA 20856 indicated that the voids were not extensive (a surface area of about 28 square feet by 8 inches maximum depth) and that the repair procedure assured that the total extent of voids had been identified. One half (0.5) of a cubic yard of concrete was used to complete the repairs as indicated on grout pour card 261. The applicant's review and evaluation of the gird pattern and a comparison of SG compartments 2 and 3 to 1 and 4 indicated that voids did not exist in SG compartments 2 anc 3. The review of test girds extended down to elevation 834 feet, which is the floor elevation of the liner. The liner walls of SG compartments 1 and 4 were not tested at elevation 834 feet, but at elevation 836 feet which is above the area of the identified voids. No testing was done on the liner side of the area of the voids below elevation 836 feet. The program also included removal of 2 inch x 2 inch plugs from the stainless steel liner at locations where test indications raised questions concerning the concrete. The inspections of the concrete by applicant personnel after the plugs were removed confirmed that there were no additional unconsolidated concrete areas (voids). In accordance with OCA 20856, the applicant removed stainless steel liner plates from three areas (one area about 1 foot by 1 1/2 feet and two areas about 3 feet by 1 foot, excavated or chipped to sound concrete, and cleaned the concrete surface area. One and one-quarter inch (1 1/4) diameter probe holes and grout access holes were drilled in the liner plates to determine the extent of and to assure full definition of the void area. Air access holes were drilled in the stainless steel liner plates to assure that grouting would be accomplished in accordance with the procedure. The procedure (DCA-20856) specifed that the grout was to be cured for 28 days or until the grout reached a compressive strength of 4000 psi. Repairs to the liner plates were specified in DCA-20856 and G&H Procedure 2323-55-18. DCA-20856 required that under no circumstances was cutting of the liner across weld seams, across embedded weld plates, or into leak chase seal welds or drilling through the liner at leak chase channels, embeds, or weld seams permitted. Documentation review indicated that DCA-20856 was adhered to and that no cutting or drilling occurred in prohibited locations. l No violations or deviations were identified. l l
. l 6. Nondestructive Testing Observations of Liner Plates in Fuel Transfer Canal The NRC inspector observed portions of non-Q liquid penetrant examinations (PT) being performed on liner alate welds following re-installation of the liner plates in the areas of t1e fuel transfer canal removed for inspection and repair of the concrete. The inspector performed the PT on the welds as required by the respir package and the procedure (QI-0P-11.18-1, " Liquid Penetrant Examination"). Scattered weld porosity was identified by the inspection. The porosity was ground out and a repeat PT was performed. The final inspection is scheduled to be performed by QC inspection personnel. The iiner plate areas to be inspected by PT were identified in DCA 20856. No violations or deviations were identified. 7. Cadweld Splice Observations and Records a. Calibration of Tensile Tester 4 The NRC inspector observed the calibration of the Tinus-Olson Universal Testing Machine (Model Number 600-12 Identification Number i M&TE-784) on April 2 and May 7, 1985. The machine was calibrated i just prior to performing tensile testing of cadweld splices and -subsequent to completion of tensile testing each day that tensile testing was performed. The machine calibration date for April 2, 1985, prior to start of tensile testing was observed by the NRC inspector and recorded as follows: Nominal load Calibration Reading Error Error Remarks (lbs) (lbs) (lbs) 0 0 0 0 0 machine on 4/2/S5 100,000 99,750 +250 +0.25 200,000 199,600 +400 +0.2 300,00 299,450 +550 +0.18 350,000 350,300 -300 -0.08 400,000 401,200 -1200 -0.03 500,000 501,350 -1350 -0.27 600,000 602,450 -2450 -0.40 The NRC inspector reviewed calibration data for March 4, March 8, April 2. April 3. April 30, and May 7, 1985. All calibration data met within the +/- 1% accuracy requirement specified by Calibration Procedure 35-1195-IEl-37, Revision 3, dated March 11, 1982. The reference standards were identifieo as follows:
9 ID No. llanufacturer Calibration Due Date RS-75 BLH Electronics January 27, 1987 RS-75.3 BLH Electronics January 27, 1987 b. Observation of Cadweld Splice Tensile Testing (1) Qualification Tensile Testing On April 2, 1985, the NRC inspector observed the following tensile testing of cadweld splices for cadwelder qualification: EBD 08, GBR Q1, GBH Q2, GBV Q1, BFD Q4, BFD Q3, BFH Q4, GAH Q1, GAV Q1, and GBV Q2. Each of the above qualification cadweld splices was tensile tested to 400,000 pounds (100,000 psi) and met the requirements stated in the procedure. (2) Production Tensile Testing 2 The NRC inspector observed the tensile tester calibrations and the following production cadweld splices tensile testing on May 7, 1985: FXD 3P, FYD 4P, FYD 8P, FRD 87P, and FUD 6P. Each of the abov. production cadweld splices was tested to 400,000 pounds (100,000 psi)and met the requirements stated in the procedure. (3) Installation of Production Cadweld Splices The NRC inspector observed installation of rebar and cadweld splices at frequent intervals (five or more observations per week during the weeks of April 8 and 15; May 6,13, 20, and 27; and June 3, 1985). The rebar installation for the Unit 2 closure was performed in the area identified as elevation 805 feet to elevation 875 feet and azimuth 300 degrees to 335 degrees. The installation activities observed included rebar spacing, incation of cadwelds, observation of selection and removal for testing of cadweld splices for testing, and determination of location of rebars and cadwelds for the as-built drawings. (4) Documentation Reviewed The NRC inspector reviewed the following documentation for the rebar placement and cadwelding for the Unit 2 containmer+ (reactor building) closure area: l
i b j . ) .) Drawings DCAs NCRs 2323-S-0785, Rev.7 22616, Rev. 1 C85-200294 2323-S-0786, Rev.9 22728 C85-200339 Rev.1 2323-51-500, Rev.5 22737 C85-200355, Rev.1 2323-S1-506, Rev.5 22836 2323-52-505, Rev.5 22878 (Sheets 1-7) 2323-52-508, Rev.2 22772 2323-52-506, Rev.3 No violations or deviations were identified. 8. Concrete BatcP Plant Inspection, Unit 1 and 2 The NRC inspector inspected the concrete production facilities for the-following specific characteristics for the following areas: (1) material storage and handling of cement, sggregate, water and admixture, (2) batching equipment scales, weighing systems, admixture dispenser, and recorders, (3) central mixer (not applicable because it had been dismantled)', (4) ticketing system, and (5) delivery system. The current batching is a manual operation since almost all concrete has been placed. The central mixer was dismantled and removed from site two l or three years ago when concrete placement was virtually completed. Presently, the backup batch plant (which was a backup system for the central mixer) is in operation to complete the remaining concrete pl acements. This batch plant is in good condition and complied with the subject checklist except for one area. The NRC inspector inspected the inside of one of three trucks used for mixing concrete (that is, the batch plant dispenses the correct weight of materials as required by the specific design mix numbers and the truck then mixes the batch to be placed.) The blades inside the truck are i subject to wear and should be checked at a reasonable frequency. The Brown & Root (B&R) representative responsible for checking the blades in j accordance with B&R Procedure 35-1195-CCP-10, Revision 5, dated December 4,1978, was asked for evidence that the blades had been checked for wear on a quarterly basis as required bv procedures and it was found that there was no record of such check g back to 1977 when they were initially checked. In the FSAR Volume V, Section 3.8.1.2.3, the applicant commits to ACI 304-73. In ACI 304, the maintenance of mixer blades is required. Procedure CCP-10, paragraph 3.10 " Truck Mixing," is silent on blade wear but Section 3.11 infers that the blades should be checked for both central and truck mixing. The inspection of both central and truck mixing blades
was not documented, although the B&R representative stated that the mixing blades were periodically inspected and laboratory testing would have probably indicated if there was a problem with the mixing blades. Strength and uniformity tests have consistently been within the acceptable range indicating that concrete production was acceptable even though mixing blade inspection was not documented. Otherwise, the condition of the inside of the truck was satisfactory as the drum and charging / discharging were clean. The water gage and drum counter were in good condition. This failure to follow procedures is a violation of 10 CFR 50, Appendix B, Criterion V. Subsequent to the identification of this violation, the blades were checked for wear and blade wear was presently within allowable limits (445/8507-04; 446/8505-02). No other violations or deviations were identified. 9. Calibration Laboratory for Batch Plant Unit 1 and 2 i The NRC inspector obtained batch plant scale numbers from tags which indicated that the scales had been calibrated and were within the calibration frequency. Cement (MTE 779), Water (MTE 766), admixture scale (MTE 764), and aggregate (MTE 780) were reviewed. The scales had been periodically calibrated since the batch plant was activated. The records were adequate except as follows: a. Scales MTE 766 records do not differentiate between the required accuracy of the scale and the digital readout. b. Scales MTE 779 and 780 records show various accuracy ranges for the same scale; i.e., MTE 779 (SN749687) records the following: report dated January 1976 gives 1%; report dated July 1976 gives 1% while the report dated October 1976 gives +/- 0.2%. The calibration appeared to be proper, however, the above items are unre-solved pending further review of the applicant's actions regarding the correction of these records (445/8507-05; 446/8505-03). c. Records for scales MTE 779 records contained B&R memo IM-1108 dated July 16, 1975, which described a nonconforming condition. This condi-tion affected the water and cement scales causing a 24-48 pound deviation (7,000 pound scale) during the calibration test. The memo stated that the condition was corrected and the scales were then calibrated; however, no deficiency report was written as required by B&R Procedure CP-QCP-1.3, " Tool and Equipment Calibration and Tool Control" dated July 14, 1975, and CP-QAP-15.1, " Field Control of Nonconforming Items," dated July 14, 1975. As a result there is no evidence that 1 ) i J
L. i l t . corrective action included an evaluation to determine if concrete production was adversely affected. This failure to assure that a nonconforming condition was evaluated is a violation of Criterion XV of 10 CFR Part 50, Appendix B, (445/8507-06; 446/8505-04),
10. Concrete Laboratory Testing Units 1, and 2 TUGC0 Procedure QI-0P-11.1-1, Revision 6, was compared with ASf1E Section III, Division'2, Subsections 5222, 5223 and 5224 to assure that each ASTM testing requirement was incorporated into the procedure.
The NRC inspector inspected the testing laboratory equipment and found the test area and equipment were in good condition and each piece of equipment was tagged with a calibration sticker which showed it.to be within the required calibration frequency. Test personnel were knowledgeable of test requirements and equipment. The NRC inspector witnessed field tests performed by laboratory personnel as follows: = Date Truck No. Mix No. Ticket No. Air Content (i,) Slump (in.) Tempt'F) 6/3/85 RT-41 925 64013 Req 8.2-10.3 NA 70 max Nea 8.7-9.1 NA 57 6/3/85 RT-35 128 64014 Req 5.0-7.0 5 max 70 max Mea 6.6 6.25* 57
~~Initial slump was high; however, after additional truck rotations the slump was found acceptable.~~
The following laboratory equipment was checked and found to be within calibration: Forney Compression Tester, MTE 3031; Temperature Recorder MTE 3013 and 3014; Unit Volume Scale, MTE 1053; Pressure Meters tite 3000B, J 3002 and 3004; Steves MTE 1286, 1239, 1272, 1274, 1136A, 1156, 1094, 1093, 1095, 1178, 1179, 1300 and 1180; Aggregate scales, MET 1058 and 1067; and 2" grout mold MTE 1111. The following test records for placement number 201-5805-034 were reviewed: (1) concrete placement inspection, (2) concrete placement summary and, (3) unit weight of fresh concrete. i Ho violations or deviations were identified. l l l l l
i 11. Inspection of Level C and D Storage Unit 1 and 2 4 The NRC inspector inspected all laydown areas where piping, electrical conduit, cable, and structural reinforcing steel were stored. These materials were neatly stored outside on cribbing in well drained ar=as which allowed air circulation and avoided trapping water. This met the Level "D" storage requirements of ANSI N45.2.2. The electrical warehouse contained miscellaneous electrical hardware. This building was required to be fire resistant, weathertight, and well 1 ventilated in order to meet Level "C" storage requirements. This warehouse was well kept and met all requirements except for a lock storage area located upstairs at the rear of this building (electrical termination tool room). Two minor problems were identified and the warehouse personnel initiated action to correct them. The first problem noted was that a box of nuclear grade cement was marked " shelf life out of date" but it had no hold tag. The box was subsequently tagged inaccordance with TUGCo nonconformance Procedure CP-QAP-16.1, Revision 24 (Nonconformance Report (NCR) E85-200453) after being identified by the NRC. During discussions with the warehouseman, the NRC oetermined that engineering told the warehouseman to mark the material and lock it up, but did not tell him to apply an NCR or hold tag. Also, the NRC inspector noted a very small leak in the roof above the electrical termination tool room. This leak was in an area that did not expose hardware to moisture. The roof is currently being repaired. The millwright warehouse storage area was inspected; however, only a small number of items or materials were stored in this area. The overall storage conditions in this area met or exceeded Level "C" storage requirements. No violations or deviations were identified.
~~12. Reactor Pressure Vessel and Internals Installation - Unit 2 1~~
This inspection was performed by an NRC inspector to verify final placement of the reactor pressure vessel (RPV) and internals by examining the completed installation and inspection records. Requirements for; Placement of RPV a. Requirements for placement of the RPV to ensure proper fit-up of all other major NSSS eluipment are in Westinghouse Nuclear Services j Division (WNSD) " Procedure for Setting of Major NSSS Components", Revision 2, dated February 13, 1979, and " General Reactor Vessel l Setting Procedure" Revision 2, dated August 30, 1974 The NRC ) 1 I ( j l b
. l inspector reviewed the following drawings, which were referenced in the RPV operation traveler, to verify implementation of WNSD recommendations: o WNSD drawing 1210E59 "Standara - Loop Plant RV Support Hardware Deteils ato Assembly" o WNSD drawing 1457F27 " Comanche Peak SES RCS Equipment Supports - Reactor Vessel Supports" o CE drawing 10773-171-004 " General Arrangement Elevation" o CE drawing 10773-171-005 " General Arrangement Plan" Neither site prepared installation drawings nor specifications (which implemented the WNSD recommended procedures) were available and the drawings examined did not show certain specific installation criterion such as centering tolerances, levelness tolerances anc clearance between support brackets and support shoes. The inspector considers this matter unresolved. (446/8505-05) b. Document Review The NRC inspector reviewed 'B&R Construction and Operation Traveler No. ME79-248-5500 which described the field instructions for installation of the Unit 2 RPV. Requirements recommended by WNSD procedures were implemented in the traveler. Worksheets attached to the traveler showed the RPV to be centered and leveled within the established tolerances. Traveler operation 29 required verification of a 0.020 to 0.005 inch clearance between the support bracket and support shce, after applying the shim plates. Change 5 subsequently changed the clearance to a 0.015 to.025 inch cle.arance. The installation data reflected in attachment 3B of the traveler j indicated on as-built clearance of 0.012 to 0.026 inch which exceeos j both the original and revised tolerances. This condition was I accepted on the traveler based on Westinghouse concurrence, and there l was no documented engineering evaluatio6 onsite justifying the final l tolerances. This matter is considered unresolved pending documentation l validating the final installation tolerances. (446/8505-06) l The NRC inspector reviewed the following receiving recoros for the RPV hardware and found them to be in ord.er: o Report No.14322 for 54 each closure studs, closure nuts, and closure washers o Report No. 09507 for vessel S/N 11713, Closure Head 11713 end 26 0-Rings
o Deviation notices and corrective action statements i The NRC inspector reviewed the following completec travelers for internals installation and found them to be satisfactory; o ME-84-4641-5500, " Assemble Upper Inter 141.s" 1 o ME-84-4503-4000, " Install and Adjust Roto Locks" o ME-81-2145-5500, "Retorque VI Column Extension" o RI-80-385-5500, " Transport and Install Lower Internals" o ME-84-4617-5500 " Repair Lower Internals" o ME-84-4640-5500. " Assemble Lower Internals" c.. Visual Inspection I At this time, visual inspection of the internals by the NRC inspector was not possible, and inspection was limited on the vessel placement to a walk-around beneath the vessel to inspect the azimuth markings and for construction debris between the vessel and cavity. No problems were identified in this area. d. Records of OA Audits or Surveillance The NRC inspector requested TUGC0 QA audits or surveillance performed by TUGC0 of the Unit 2 RPV installation. TUGC0 did not ) make available any documentation of an audit or surveillance which evaluated specified placement criteria, placement procedures, hardware placement, or as-built records. This item is unresolved pending a more comprehensive review of these activities 1 (446/8505-07). No deviations were identified; however, two unresolved items were identified and are described in the above paragraphs. (11.a and d) i 13. Reactor Vessel Disorientation On February 20, 1979, the applicant reported to the NRC Resident Inspector that a design error had resulted in the reactor support structures being placed in the wrong position on the reactor support pedestal such that the reactor would be out of position by 45 degrees. Initially, Unit 2 was to be a mirror image of Unit 1, however, a design change was initiated to permit identical components for both units. The design change was implemented for the reactor vessel, but not for the pedestal support locations. The problem was not considered by the applicant to be
L reportable under provisions of 10 CFR Part 50.55(e) since the error could not have gone undetected. The deficiency was reported to the NRC Office of Inspection and Enforce-ment on February 22, 1979 and during a March 27, 1979 meeting in Bethesda, Maryland, the applicant presented the proposed redesign and rework proce-dures.for relocating the pedestal supports. No unresolved safety concerns 4 with the repair were identified at the meeting. During this inspection the NRC inspector reviewed vario'is documentation relative to the disorientation problem, including design changes and the i construction traveler which implemented the repair, The following documents were reviewed: o NRC Inspection Reports 50-446/79-03; 50-446/79-07; 50-446/79-13 o TUSI Conference Memo, dated March 1, 1979, H. C. Schmidt to S. Burwell (NRC Licensing PM) c TUGC0 letter TXX-2980, dated April 30, 1979, to W. C. Seidle o NRC letter to TUGC0 dated May 29, 1979 o DCA' 3872, Revision 1, dated February 28, 1979,
~~Subject:~~
~~Rework of Structure for Placement of.the RPV Support Shoes o DCA 4122, dated March 22, 1979~~
~~Subject:~~
~~Replacement of Rebar for RPV Supports o Construction Traveler CE79-018-5505, dated March 14, 1979,~~
~~Subject:~~
~~Rework of Reactor No. 2 Cavity - New RPV Support Locations o Grout Replacement Cards No. 007, 008, 009, 010, 014, ano 015, various dates.~~
~~Subject:~~
Replacement of Grout around Rebar for Repair of RPV Support Shoes o Various Inspection Reports for Greut Properties and Application for RPV Support Shoes No violations or deviations were identified. i 14. Reactor Coolant Pressure Boundary (RCPB) Systems The inspection was perfomed to verify: the applicants system for preparing, reviewing, and maintaining records for the RCPB piping ard components; that selected records reflected compliance with NRC requirements and SAR comitments for manufacture, test and installation of l' 1 l-
m. In . 1 1 items;'and as-built hardware was adequ6tely marked and traceable to ~ records. The following items were randomly selected and inspected: 'a. Pressurizer Safety Valve - This item was inspected to the commitment stated in F5AR, Table 5.2-1 which includes ASME Section III, 1971 Edition through Winter 1972 Addenda. Valve S/N N56964-00-007, which is installed in the B position, was inspected. The following records were reviewed: J o QA Receiving Inspection Report No. 21211 i o Code Data Report Form NV-1 o Valve Body Certified Material Test Reports (CliTRs) The valve was in place, however, installation had not been completed; therefore, the hardware installation inspection consisted of verifying that the item was traceable to the records. b. . CVCS Spool Piece 301 - Requirements for this item are stated in ASME, Section III,1974 Edition through Summer 1974 Addenda, which is the commitment from the FSAR, Table 5.2-1. The item was field fabricated ~ from bulk piping and purchased elbows and installed in the CVCS with field welds number 1 and 6 (ref. BRP-CS-2-RB-076). The following -records were reviewed: o B&R Code Data Report o Field Weld Data Card o NDE Reports o QA Receiving Reports for piping and elbows o CMTRs The installed spool piece was inspected for weld quality and to verify that marking and traceability requirements had been met. The item had been marked with the spool piece number (3Q1) ano the B&R drawing number which provided traceability tc the material certifications. c. Locp 3 RC Cold Leg - Requirements for this item are stated in ASME, Section III,1974 Edition through Sumer 1974 Addenda, which is the comitment from the FSAR, Table 5.2-1. This piping subassembly consists of a 27 E inch cast pipe with a 22 degree elbon on the reactor end, a 10 inch 45 degree nozzle, a 3 inch nozzle, and three 2
(,. l i 1/2 inch thermowell installation bosses. The following records were reviewed for the subassembly: o QA Receiving Inspection Report No. 12389 o Westinghouse Quality Release (QRN 47523) o Code Data Report Form NPP-1 o 27 1/2 inch line CMTR o 3 inch nozzle CMTR o Field Weld Data Cards o NDE Reports -(1) Sandusky Foundry and Machine Company test report for the cold leg pipe certifies that material meets requirements of >ASME Section II, 1974 editions through winter 1975. Southwest Fabrication and Welding Company code
~~data report NPP-1 Form certified that the cold leg subassembly met requirements of ASME Section III, 1974 edition through winter 1975.~~
(2) The NRC inspector reviewed the procedures and hydro test data applicable to Unit 1, since Unit 2 hydro had not been completed. Requirements for the tests were presented in Procedures CP-0AP-12.2, " Inspection Procedure and Acceptance Criteria for ASHE Pressure Testing" and CP-QAP-12.1, "ASME Section III Installation, Verification, and N-5 Certification." Procedure CP-QAP-12.1 requires that a data package to be used in the test, be prepared with the test boundary and the additional followinc data shown: 1 o Base metal defects in which filler material has been added, and the depth of the base metal defect exceeds 3/8 inch or 10% of the actual thickness, whichever is less. o Untested vendor performed piping circumferential welds. o Approximate location and material identification and description for permanent pressure boundary att d. ment with
~~pplicable support number referenced, o~~
Weld history, which shall reflect weld removal and/or weld repair.
The completed hydro data package (PT-5501) for Unit 1, loop 3 cold leg was reviewed for' compliance with the above requirements. Drawing No. BRP-RC-1-520-001Lhad been used to annotate the test boundary. A haridwritten statement on the ' drawing indicated: "No major base metal repairs could be . located" and "No hangers with weld attachments could be located." Welds performed by the pipe subassembly vendor, including the 22 degree circumferential weld and the' penetration fittings had not been identified. The following items are unresolved pending_further review to determine: o-If the statement "no major base metal repairs" was based on-a visual inspection or on a review of vendor and site inspection and repair records. o If the shop circumferential weld attaching the 22 degree elbow to the pipe assembly was inspected during the test. o If welds for penetrations into pipe assembly were iinspected since. Procedure CP-CAP-12.1 does not require identification'of such welds and they were not identified on the drawing. The above issues will remain unresolved pending further evaluation by the applicant (445/8507-07; 446/8505-09). \\ d. Personnel Qualifications'- Personnel who had performed selected tasks l were identified during inspection of installation records. Training j and experience records for the personnel were reviewed to verify that employee qualifications and' maintenance of records were current and met requirements. Names or codes for five welders and two NDE .i examiners, who had performed tasks during installation of the items j being inspected, were identified and their qualification records reviewed. There were no questions in this area of the inspection. No violations or deviations were identified.
~~15. Special Plant Tours (Unit 1 and Unit 2)~~
On May 23, 1985, the NRC inspector conducted a tour of selected areas of Unit 1 and Unit 2. The group consisted of one NRC inspector, two NRC Technical Review Team (TRT) representatives, two allegers, and several TUEC representatives. The TUEC representatives ta0ged each area where a deficiency was alleged. With the alleger's consent, a tape recorder wa. 3 also used to note locations and describe any alleged deficiencies. The allegers indicated that they had identified all deficiencies during the l l I
p {. ,e a < tour and all other deficiencies that they had knowledge. The NRC TRT is analyzing this information and will decide what action, if any, should be L
~~taken, j~~
During this tour the NRC' inspector independently identified a questionable 4 practice in that the top of the the pipe chase at the north end of room 88 in Unit 1, safeguards' building had two large stickers which stated that j areas on the wall were reserved for pipe hangers GHH-SI-1-SB-038-006 and R1(?)1-087-X11. These stickers were dated 1980. It was not evident whether hangers were missing or none were needed in these locations and l 1 the reserve tags were not removed. TUEC representatives were unable to answer the question immediately. This item is unresolved pending further review-during a subsequent inspection. (445/8507-08). No violations or deviations were identified.
~~16. Routine Plant Tours (Units 1 and 2)~~
At various times during the inspection period NRC inspectors conducted general tours of the reactor building, fuel building, safeguards building, electrical and control building, and the turbine building. During the tours, the NRC inspector observed housekeeping practices, preventive maintenance on installed equipment, ongoing construction work, and discussed various subjects with personnel engaged in work activities. I No violations or deviations were identified.
17. Review of Part 21 and 10 CFR 50.55(e) Construction Reports Status The NRC inspector reviewed all reports issueo to date to assure that HRC-and TUEC status logs were complete and up to date. A total of 183 reports i
have been submitted to date. This inspection period one Part 21 report on Diesel Generator Oil Plugs and two 10 CFR 50.55(e) reports on the Equipment Hatch Cover and SA106 Piping (light wall) were submitted. No violations or deviations were identified.
~~18. Exit Interviews t~~
The NRC inspectors met with members of the TUEC staff (denoted in paragraph 1) on May 10 and June 10, 1985. The scope and findings of the inspection were discussed. The applicant acknowledged the findings. l m.a
Log # TXX-4727 File # 10130 IR 85-07 TEXAS UTILITIES GENERATING COMPAhT 85-05 SKYW AY TOWER. 400 HORT18 OtJVE STREET. l B. G S = DAIJ.AS. TEXAS T& SOS April 2, 1986 J.h0Afd."n'.5 l Mr.'Eric H. Johnson, Director Division of Reactor Safety and Projects 1 U. 5. Nuclear Regulatory Commission 1 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012 i
~~SUBJECT:~~
~~COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT N05.: 50-445/85-07 AND 50-446/85-05~~
~~Dear Mr. Johnson:~~
We have reviewed your letter dated February 3, 1986, concerning the inspec-tion conducted by Messrs. J. E. Cummins, H. S. Phillips, and others during the period April 1, 1985, through June 21, 1985. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak Stecm Electric Station Units 1 and 2. We requested and' received a two week extension in providing our response during a telephone discussion on March 6, 1986. We requested and received a secone two week extension on March 19, 1986. We have responded to the Notice of Violation in the attachments to this letter. We have attached the Notice of Violation to aid in understanding our response. Very truly yours, /[,('?LC' W. G. Counsil JWA/ arm Attachments c-Region IV (Original + 1 copy) Director, Inspection and Enforcement (15 copies) U. S. Nuclear Regulatory Commission Washington, D.C. 20555 l Mr. V. S. Noonan Mr. D. L. Kelley f A DIViblON OF TEXAS l'TELITIES ELECTRIC COMPANY
o gc + i APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Docket: 50-445/85-07 Comanche Peak Steam Electric Station 50-446/85-05 Units 1 and 2 Permit: CPPR-126 CPPR-127 During an NRC inspection conducted on April 1 through June 21, 1985, violations { of NRC requirements were' identified. In accordance with the " General Statement of Policy and Procedures ~ for NRC Enforcement Actiuns," 10 CFR Part 2 Appendix C (1985), the violations are listed below: 1. Failure to Promptly Correct an Identified Problem with RTE - Delta j Potential Transformer Tiltout Subassemblies s I 10 CFR 50, Appendix B, Criterion XVI, as implemented by Texas Utilities Generating Company (TUGCO) Quality Assurance. Plan (QAP), Section 16.0, Revision 0, requires-that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, de"cien-cies deviations, defective material and equipment, and nonconformances are promptly identified and corrected. l Contrary to the above, a potential problem with RTE - Delta potential transformer tiltout subassemblies, which are used in the emergency diesel generator control panels, was identified to the applicant via a letter, dated June 15, 1983, from Transamerica Delaval Inc. This letter also provided instructions for correcting the potential problem. However, the l applicant did not take the corrective action. The NRC initially reported this item as unresolved in NRC Inspection Report 50-445/84-40. This is a Severity Level IV violation. (Supplement II.E) (445/8507-01 446/8505-01). [ 2. Failure To Follow Procedures 10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 QAP, Section 5.0, Revision 2 requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accor-dance with these instructions, procedures, or drawings, b a. Drawing 2323-51-0550, Revision 4, Section 6-6 specified the use of Class "E" concrete for the Unit i reactor coolant pump and steam generator supports. l i l L
s ? 7, " Contrary to the.above, commercial nonshrink grout was used to grout the Unit i reactor coolant pump and-steam generator supports in lieu of Class "E" concrete. (445/8507-02) This is a Severity Level V. violation (Supplement II.E). - i b. Brown and Root Procedure QI-QAP-7.2-8, " Receiving of Westinghouse Safety Related Equipment," Section 3.1.d.1, requires a QC inspector-to verify that-.the Westinghouse Quality Release (QR) document checklist items be filled out completely and accurately. Contrary to the above, the voltage recorded on Westinghouse QR 41424 i - checklist, attachment 1, step 4.1, was outside the specified tolerance, but the QC receipt inspector accepted QR as satisfactory.- (445/8507-03) This is a Severity Level IV violation. I c. Brown.& Root Procedure 35-1195-CCP-10, Revision 5, dated D6cember 4, 1978, requires'that central and truck mixer blades be checked quarterly to assure that mixer blade wear does not exceed a loss of 10". of' original blade height.' Contrary to the above, on May 31. 1985, the NRC inspector determined that there was no objective evidence (records) that the mixing blades had been inspected quarterly since the trucks were placed in service in 1977. (445/8507-04; 446/8505-02) This is a Severity Level V violation (Supplement II.E). d. Brcwn & Root Procedure CP-QAP-15.1, " Field Control of Nonconforming Item, " states.that nonconforming conditions shall be documented in a Deficiency and Disposition Report (DDR). Procedure CP-QCP-1.3, " Tool Equipment Calibration and Control." dated July 14, 1975, states that out-of-calibration equipment shall be identified on a DDR. Contrary to the above, on May 31, 1985, the NRC inspector reviewed the calibration file for scale (MTE 779) used for weighing cement and found that a 24-48 pound deviation from the required accuracy was encountered with the water and cement scales during a 1975 calibration of the backup plant scales, however, no DDR was issued to identify this condition and require disposition,of the scale and concrete.(if any) produced. (445/8507-06;446/8505-04). This is a Severity Level IV violation (Supplement II.E). i
3 1 l 3- ) I Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is hereby required to submit to this office within 30 days of the date of the 1 letter transmitting this Notice, a written statement or explanation in reply, 8 including for each violation: (1) the reason for the violations if admitted,' the corrective steps which have been taken and the results achieved, the corrective steps which will be taken to avoid further violations, and l the date when full compliance will be achieved. Where good cause is shown. ? consideration will be given to extending the' response time. Dated at Arlington, Texas, .this 3rd day of February,1986 i i o .l m.
1 Response'to Notice of Violation r Item 1 (445/8507-01 and 446/8505-01) t i 1. Recson for Violation: The violation relates to a Part 21 notice provided by a CP3ES diesel generator subtier supplier (RTE-Delta) in June 1983. The violation is l the result of two unrelated administrative oversights in handling the Part 21 notice. The initial. oversight involved overlooking necessary corrective actions when a "potentially" reportable deficiency was cancelled dealing with the subject Part 21 notice. The second administrative oversight involved omission of the issue when a program was conducted in mid 1984 to assure corrective actions were accomplished.for prior Part 21 issues. l 2. Corrective Steps Taken and Results Achieved: Action for the specific finding was accomplished for Unit 1 per startup work permits Z-2912 and Z-2914 in December 1984. Unit 2 activities were identified by master Data Base Item 3003-31 (issued January 1985) l and completed in August of 1985. These actions were initiated in response to an NRC open item (445/8440-02).. 3. Corrective Steps to Avoid Recurrence: In response to an earlier NRC open item (445/8407-01), programmatic measures were established in mid 1984 to positively control corrective actions related to Part 21 issues. These measures included a review of prior Part 21 issues and required the handling of future Part 21 notices as."potentially" reportable deficiencies pursuant to 10CFR50.55(e). Programmatic controls for these issues are currently governed by TUGC0 Corporate Procedure NE0-CS-1, " Evaluation of and j Reporting of Items / Events under 10CFR21 and 10CFR50.55(e)." The oversight of the specific (RTE-Delta) Part 21 notice during the mid 1f84 review is considered to be isolated. The failure to recognize this issue was the result of the same identifier being assigned to two different items.- This was the subject of a previous violation (445/8440-01). No other instance of a similar nature was identified during our review of the earlier violation. 4. Date When in Full Compliance: Programmatic measures were established in mid 1984 to positively corJrol corrective actions related to Part 21 issues. All of the spe-ci?ic findings related to the RTE-Delta Part 21 notice were corrected it tugust 1985.
~., ~ I Response to Notice of Violation Item 2(a) (445/8507-02) '1. Reason for Violation: The violation is the result of a failure on the part of personnel pre-paring work control documents to properly recognize the hierarchy of design documents. Specifically, when design'and vendor installation documents differ, the design document establishes precedent. I Although consistent with the requirements of the vendor drawing (W Drawing 1457F29), the use of non-shrink commercial grout was contrary to the requirements of the design drawing (2323-51-0550). The design drawing specified the use of class "E" concrete. The use of grout as an acceptable design alternative should have been properly documented by design change prior to the placement. 2. Corrective Steps Taken and.Results Achieved: Based upon a review of the grout card (No. 186 issued November 1981) and the results of the compressive strength test for the grout used in this application, a design change (DCA-21, 179) was issued November 8,- 1984, to document acceptance of the installation. 3. Corrective Steps to Avoid Recurrence: Operational travelers (work control documents) for similar type installations issued during the same time frame as the installation identified in the violation will be reviewed for similar deficiencies. Results of the review will be completed by April 4, 1986. Although we believe the specific finding is an isolated case, a project directive will be issued re-emphasizing: 0.the requirements of properly documenting design alternatives prior to initiating construction activities, O tne precedence of design vs. vendor documents. 4. Date When in Full Compliance: Any corrective actions deemed necessary based on the results of the (Item 3) review will be reported by April 15, 1986, to Region IV. The project directive will be issued by April 15, 1986. 1
Response to Notice of Violation Item 2(b) (445/8507-03)- 1. Reason for Violation: The'out-of-tolerance condition was not detected by receiving inspection when reviewing the data-package. i i 2.. Corrective Steps-Taken and Results Achieved: Receiving inspection reports issued in same time frame as the receipt of the' equipment in question, were reviewed for similar. oversight. No-deficiencies were noted. Westinghouse QRN-41424 Rev. I was added to receiving inspection report package to identify the change in output values. 3. Corrective Steps to Avoid Recurrence: Construction receiving inspection personnel were retrained in reviewing receiving inspection documentation packages. 4. Date When in Full Compliance: February 27, 1986. i I I J \\ \\ t i i l i ..___________E__
m
~~....e Response to Notice of Violation-~~
_. Item 2(c) (445/8507-04.and 446/8505-02) i A-reply to this notice of violation is not' required'as noted in the NRC Region IV letter of February 3, 1986 (E.H. Johnson to W.G.-Counsil) { i i 1 I i I l
l l il Response to Notice of Violation Item 2(d) (445/8507-06 and 446/8505-04) j i
~~1.. Reason for Violation:~~
A review of the historical procedures files has indicated that the . majority of project procedures controlling safety related work, and . programmatic requirements wereinot issued until or after 7/14/75. I Although project practice at this early stage of construction was to defer safety related work until the appropriate implementing and sup-port procedures were issued and distributed, the established control l was inadequate in this instance. 2. Corrective Steps Taken and Results Achieved: 4 Concrete pour records were reviewed to determine which category I place-ments were made during the subject calibration interval, Nonconformance reports (NCR-C-85-101882 R. 1 issued 11/26/85 ] NCR-C-85-201617 R.1 issued 11/27/85) were initiated to document the two 1 placements made.. Engineering dispositioned these NCR's basing the decision on the design cylinder compressive results. These NCR's were closed in December 1985. 3. Corrective Steps to Avoid Recurrence: The site procedures controlling these activities and the associated programmatic requirements', were issued onsite after the discrepancy identified by the inspector had occurred and prior to the next sche-duled calibration. These procedures provided the necessary controls for handling nonconforming items, implemented a detailed calibration ( program and required auditing the effectiveness of the established 1 10CFR50 Appendix 8 Quality Program requirements; continuing periodic audits by TUGCO, Brown'& Root, and third parties have insured accep-table implementation of the controlled measuring and testing equipment calibration program. This appears to be an isolated instance since review of pour cards during this time period did not identify any safety related placements other than those addressed above. Safety related mechanical and electrical activities had not yet commenced.
~~4. Date When in Full Compliance:~~
CPSES is currently in full compliance with 10CFR50 Appendix B Criterion XII.
37 - jW L_ In Reply Refer To: IAAR 0 6 SE Dockets: 50-440/85-14 50-446/85-11 m Texas Utilities Generating Company ATTN: Mr. W. G. Counsil Executive"Vice President 400 North Olive, L.B. 81 Dallas, Texas 75201 Gentlemen: This refers to the inspection conducted by Mr. T. F. Westerman and other members of the Region IV Comanche Peak Group during the period September 30 through October 31, 1985, of activities covered by NRC Construction Permits CPPR-126 and CPPR-127 for the Comanche Peak Steam Electric Station, Units 1 and 2, and to the respective discussions of our findings with Messrs. J. B. George and J. C. Kuykendall, and other members of your staff at the conclusion of the inspection. Areas examined during the inspection included operations, construction, and Comanche Peak Response Team activities. An inspection was also performed by Region IV staff of. Unit 2 cable tray support modifications during this report period. Within these areas, the inspection consisted of selective examination of procedures and representative records. interviews with personnel, and observations by the inspectors. These findings are documented in the enclosed inspection report. During this inspection, it was found that certain of your activities were in violation of NRC requirements. Consequently, you are required to respond to these violations, in writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10. Code of Federal Regulations..Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter. During this inspection, it was found that certain of your activities appeared to deviate from commitments made to the NRC. These items and references to the commitments are identified in the enclosed Notice of Deviation. You are requested to respond to these deviations in writing. Your response should be based on the specifics contained in the Notice of Deviation enclosed with this letter. With respect to item A in the Notice of Deviation, the NRC has ascertained subsequent to this report period that ERC logs for tracking of equipment / service requests have not been utilizing procedurally required unique numbers for individual reauests. Accordinly, please address this as part of your response to item A in the Notice of Deviation. RIV: CPG / SRI / CON SRI /0PS @ CPG CPG DRS RR i l1 SHPhillipsq DLKelley IBarnes TFWesterman EHJohnson VSNoonan 3 /3/86 3 / S /86 3 / U/86 ?;/ 3 /86 3/{/86 L/. /8,6 V"j ~,f. y (3 W q'f W ,4 1 g 5 l{ g CeG31G04;6 iE60306 DR ADOCK 0500 l
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l APPENDIX A NOTICE OF VIOLATION i' Texas Utilities Electric Company ' Dockets: 50-445/85-14 50-446/85-11 l Comanche Peak Steam Electric Permits: CPPR-126 -Station,-Units 1 and 2 CPPR-127 During'an NRC. inspection' conducted on October 1-31, 1985, six violations of NRC requirements were identified. The violations involved failure to maintain sufficient chemistry records, a minimum wall violation not being documented on a nonconformance report (NCR), inadequate issue control for_ design documents, absence of procedures for controlling offsite shipment of original design . records, signing of inspection reports by a noncertified electrical inspector, and revision of drawings.without required review and approval actions.' In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below: A. Criterion XVII of Appendix B to 10 CFR Part 50, as implemented by. Section 3.8, Revision 4, of the Operations Administrative Control and Quality Assurance Plan, requires that (1) sufficient records shall be maintained to furnish evidence of activities affecting quality, and (2) that the records shall include the results and acceptability of tests and analyses, and the action taken in connection with any deficiencies noted. Contrary to the above: 1. A significant number of instances of missing data entries was notec in water chemistry records covering the period March 1983 through September 1985, with respect to the chemistry sampling frequency requirements of Procedures CHM-501, " Chemistry Control of the Steam Generators," and CHM-508, " Chemistry Control of the Primary Cooling Water Systems." No annotations were made in the records to explain why the samples were not taken. 2. Review of the water chemistry records showed instances of failure to make required entries to indicate when the Shift Supervisor was notified in regard to out-of-specification chemistry results. 3. The records did not identify what corrective actions were taken after entry of out-of-specification results. r ihJ150497860306 k 0 W 0%OOM5 ( PDR
>= . 4. Inadequate reviews were performed of the acceptability of water chemistry data, as evidenced by the presence of review and apprcval signatures on forms containing discrepant data results. This is a Severity Level IV violation (Supplement II) (445/8514-V-01). B. Criterion V of Appendix B to 10 CFR Part 50', as implemented by TUGC0 Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, cr drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Paragraphs 2.3 and 3.'1.1.1 of Brown and Root (B&R) Procedure CQ-QAP-16.2, Revision 25, require that nonconformances be identified, documented by completing the NCR form, and dispositioned. Paragraph 3.19.5.2 of B&R Procedure CP-CPM 6.9D, Revision 6, states, in part, with respect to NCRs for minimum wall violations, "... Welding engineering shall review the conditions stated on the NCR...." Contrary to the above, repair of a minimum wall violation associated with weld 21-2 in component CC-2-RB-053 was noted on October 9, 1985, from record review to have been performed without documenting the condition on an NCR form. This is a Severity Level IV violation (Supplement II) (446/8511-V-01). l C. Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Paragraph 3.1.1.1 of B&R Procedure DCP-3, Revision 18, states, in part, "... Issuance and receipt of controlled design changes are documented on the Document Distribution Log... by signature or initial of the file custodian and dated." Paragraph 3.2.2.5 of this procedure additionally requires that the face of a retained superseded document must be stamped " VOID." Contrary to the above: l 1. Satellite document control center 307 wa: noted on October 14, 1985, to be in possession of a controlled copy of Component Modification , Card 96181 for which receipt had not been signed for and dated on the ' document Distribution Log. l f 1 1 o
,a . 2. 'A copy of superseded Design Change Authorization (DCA) 21446, ' Revision 0, was noted on the same date to be present in two packages for Drawing 2323-El-1702, Sheet 002, Revision 2. Both copies of DCA 21446, Revision 0, were not stamped " VOID" on the face of the document. This is a Severity Level IV violation (Supplement II) (446/8511-V-02). D. Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Section 17.1.17 of the Final Safety Analysis Report, Volume XIV, Amendment 50, dated July 13, 1984, commits to procedures requiring that records be controlled and accounted for during transfer between organizations. Contrary to the above, original sole copy design recoros were ascertained on October 16, 1985, to have tien shipped to Stone and Webster Engineering Corporation, New York, without the establishment and implementation of procedures that address required control and inventory measures. This is a Severity Level IV violation (Supplement II) (445/8514-V-02, 446/8511-V-03). E. Criterion VI of Appendix B to 10 CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative and Quality Assurance Plan, requires that (1) measures shall be established to control the issuance of documents such as drawings, including changes thereto; and (2) the measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel. Paragraphs 2 and 4 in Revisions 7 and 8 of Station Administration Manual Procedure No. STA-405 require that all documented nonconformances, in which "use-as-is" dispositions are recommended, be forwarded to TUGC0 Operations Results Engineering group for review to determine if as-built documentation changes are needed. Paragraph 4.0 in Revision 0 of Nuclear Operations Engineering Manual Instruction No. 140E-201-5 requires that proposed drawing changes be submitted to the Operations Superintendent for review, approval, and authorization to Mstribute the revised drawing. l l l l
4 Contrary to the above, nine as-built drawings were revised and distributed .by TUGC0 Nuclear Engineering to reflect NCR identified undersize welds, t without receiving TUCGO Operations review, approval, and authorization to distribute the revised drawings. This is a Severity Level IV violation (Supplement II) (445/8514-V-03). F. Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, Section 5.0, Revision 3 dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Paragraph 3.0 of Procedure CP-QP-2.1, Revision 14, dated October 17, 1983, states, in part. "... inspection personnel... shall have experience in and shall have completed a technical training course and examination in the area of inspection responsibilities." Paragraph 3.7 of this procedure states,inpart,"...Inspectionpersonnelshallbecertifiedbfthe TUGC0 site QA supervisor as being qualified to perform their assigned tasks." Contrary to the above, it was noted on October 21, 1985, during review of documentation for Class 1E lighting system conduit EAB1-1 that the electrical inspector, who had signed inspection reports E-1-0024951 and E-1-0027419, had not been certified to the applicable Procedure QI-QP-11.2-25. Revision 17, dated February 13, 1984, " Inspection of New Installations for Class 1E Lighting Systems." This is a Severity Level IV violation (Supplement II) (445/8514-V-04). Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, includirg for each violation: (1) the reason for the violations if admitted (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time. Dated at Arlington, Texas this 6th day of March, 1986. l l
no ' .a. APPENDIX B NOTICE OF DEVIATION Texas Utilities Electric Company Dockets: 50-445/85-14 50-446/85-11 Comanche' Peak Steam Electric Permits: CPPR-126 Station, Units 1 and 2 CPPR-127 Based on the results of an NRC inspection conducted during the period of October 1 through 31, 1985, of Comanche Peak Response Team (CPRT) activities, four deviations from commitments to the NRC were identified. The deviations involved ERC equipment / service requests not being controlled as committed, inadequate ERC document review and procedure criteria with respect to inspection attributes that are inaccessible or nonrecreatable, failure of ERC document reviews to both detect a lapsed electrical inspector certification and to record required information in a verification package, and inspection attributes being attested to as acceptable by ERC inspectors which were found by subsequent NRC inspection to be unacceptable, fn accordance with the l " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the deviations are listed below: A. Section 4.1.6 of ERC Comanche Peak Project Procedure (CPP) CPP-012, "QA/QC Interface with Constructor /TUGCO," states, "The QA/QC Records Administrator controls requests for equipment / services and distributes and controls requests for technical information." Contrary to the above, the QA/QC Records Administrator does not receive copies of requests to provide for control of these documents (445/8514-0-01). B. Section 4.1 of CPRT Issue-Specific Action Plan (ISAP) No. VII.C, Revision 0, dated June 21, 1985, states, in part, "... Where required, documentation reviews will be utilized to supplement the reinspection for attributes which are nonrecreatable or inaccessible...." Section 4.1.3 of the ISAP states, in part, "... The inspection procedure will provide detailed instructions to the inspectors and/or documentation review s for performing the reinspection and/or documentation reviews Contrary to the above, the following examples were noted of inadequate procedural guidance and document reviewer performance in regard to nonrecreatable and inaccessible attributes: 4k' l - pDR= a m,,,,6 m s l g ADOCK 05000445 l l PDR l l - A
Gi ~ ZT _ g a,.. i ' , cp d. ' 2-1. Quality Instruction (QI) QI-013, Revision'4, lists no specific h attributes, but instead. specifies that the inspector verify insta11ations'in.accordance with one or more of.a listing of TUGC0 procedures; i.e., QI-QP-11.8-1, -5, -6,'and -8. The list of. g appropriate procedures does not, however, indicate the applicable revision number of each procedure. In that the number of nonrecreatable or inaccessible inspection attributes can vary from revision to revision of a procedure (e.g., Revisions 0 and 1 of TUGCC Procedure QI-QP-11.8-8).the absence of guidance on applicable procedure revision numbers doesinot constitute detailed instructions. 1 '2. During the documentation review of Verification Package No. R-E-CDUT-064, in accordance with QI-009, Revision 0, there was no evidence that a documentation check was made of inaccessible attributes for conduit C13916037 that were caused by the installation of separation barrier material (445/8514-D-02). C. QI-009. Revision 0, " Document Review of Conduit /R-E-CDUT," requires the ERC inspector to: (1) verify that inspection reports signed by electrical inspectors were dated after their date of certification and prior to their date of expiration, and (2) document the SBN inspr.ction report (IR) and/or latest construction operation traveler number at the bottom of the check 11st. Contrary to the above: 1. Review of ERC accepted documentation for conduit C14R13047 showed that the ERC inspector failed to identify that the certification to the applicable Procedure QI-QP-11.3-23 had lapsed for the TUGC0 electrical inspector signing IR-E-46087. 2. The ERC' completed' inspection record checklist for conduit C13016037 'in Verification Package No. R-E-CDUT-064 did not contain documentation of the SBM IR or latest construction operation traveler number (445/8514-D-03). D. Section 4 of CPP-009, Revision 3, states, in part, with respect to ISAP No. VII.c. " Qualified QA/QC Review Team personnel perform field reinspection of specific hardware items and reviews of appropriate documents in accordance with approved instructions...."' Contrary to the above, the following examples were noted where field reinspection of hardware items were not performed in accordance with approved instructions: 1. Attribute 4.5 in Section 5.0 of QI-055, Revision 0, states with respect to spring nuts, " Verify that the serrated grooves align with the channel clamping ridge." Checklists for support No. 0070 _m
i . (Verification Package No. I-S-INSP-007) and support No. 028 (Verification Package No..I-S-INSP-028) were signed by two separate ERC inspectors that this attribute was acceptable. NRC inspections showed, however, that the spring nut serrated grooves did not align with the channel clamping ridge on both of these supports. 2. Section 5.3.4.0 in QI-027 states with. respect to dimensional j tolerances not shown on design drawings, " Component member length +/-1/2 inch." The bill of material-on Revision 2 of drawing No. CT-1-097-402-C52R in Verification Package No. I-5-LBSR-023 shows item No. 4 (2 pieces) to be 7 3/4 inches long. The applicable inspection checklist used during the ERC reinspection of this pipe support shows the installed configuration to be acceptable. NRC inspection determined, however, tho actual length dimensions of the two pieces to be 6 5/8 inches and 6 1/2 inches, respectively, both of which are under the indicated minimum dimension of 7 1/4 inches. 3. Section 5.0 in QI-012 states, in part, " Verify that the piping / tubing and components... material agree with the Bill of Materials shown-on the_ Instrument Installation Detail drawing. Tubing is marked with longitudinal color coded marks for traceability. Use applicable drawing to identify tubing... Verify that the installed tubing has the proper slope. The required slope for process wetted lines is one '(1) inch per foot minimum. This slope requirement may be reduced to 1/4 inch per foot when physical layout is a problem. Verify that thera _is a proper air gap. The minimum gap spacing shall always be 1/8 inch to allow each instrument sensing line to expand independently at all bends without striking adjacent sensing lines, other equipment, concrete or steel building members." The applicable inspection checklist used during the ERC reinspection of instrumentation installation Verification Package No. 1-E-ININ-026 showed that the above attributes were inspected and accepted, as evidenced by the inspector's signoff (initials). However, NRC inspection of the instrumentation installation revealed: (a) Six sections of tubing had no color coding for traceability; ~ (b) Ten sections of tubings, in which physical layout was not a problem, had slopes of 7/16 inch to less than 1/4 inch per foot and one section had reverse slope; and (c) Two tubing sections had zero gap spacing between the high pressure and low pressure legs and the concrete pentration.
i 4. Section 1.7 in QI-012 requires that: (a) tubing bends be verified to have a minimum radius of four times the nominal tube si.te by using either a template, or by direct measurement and calculations; and (b) the measured and calculated values be entered into the Minimum Bend Radius Record, with date and inspector's initials. I During NRC inspection of Verification Package No. I-E-ININ-04, equipment tag No.1-FT-156, it was noted that the inspection checklist was dated and initialed, attesting to the fact that the tubing bends had been verified as having a minimum radius of four times the nominal tube size. However, review of the applicable tiinimum Bend Radius Record showed that the ERC inspector had neither measured and calculated, nor used a template to verify mininum bend i radius. In addition, the following notes had been entered by the ERC inspector: "1st 00* bend from instrument (hi & lo side)... cannot be measured with existing tools. Four (4) other bends visually more than 90* to accomodate slope" (445/8514-D-04). Texas Utilities Electric Company is hereby required to submit to this office, within 30 days of the date of this Notice of Deviation, a written statement or explanation in reply, including for each deviation: (1) the reason for tre deviations if admitted. (2) the corrective steps which have been taken and the results achieved, (3) corrective steps which will be taken to avoid further deviation from commitments made to the Comission, and (4) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown. Dated at Arlington, Texas, this 6th day of March, 1986
1,.[..- ^ [; APPENDIX C OPERATIONS INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report:.50-445/85-14 Permit: CPPR-126 Docket: 445 Category: A2 Applicant: Texas Utilities Electric Company (TUEC). Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam' Electric Station (CPSES), Unit 1 Inspection At: Glen Rose, Texas Inspection Conducted: October 1-31, 1985 Inspectors LL ///u 7/7 Pi D.
~~.~ Kelley, Senfor R ent Reactor Inspector Date /~~
(SRRI), Region /IV C Group (paragraphs 1,5, 7, ) M/ 5 W. F. Smith, Resident Reactor Inspector (RRI) Dat'e Region IV CPSES Group (paragraphs 1,2,3,4,5,6,7,8) Reviewed By: '[ e 3/3/P4 I. Barnes, Group Leader, Region IV CPSES Group Date 7N 3/1/ F6 Approved: ( T. F. Westerman, Chief, Region IV CPSES Group Date t-U p,e ma, iy PDR 1
1. i- . l. Inspection Summary Inspection Conducted: October 1-31, 1985(Report 50-445/85-14) Areas Inspected: Routine, unannounced inspectfon of (1) applicant actions on previous inspection findings, (2) maintenance procedures, (3) preventive maintenance programs, (4) plant tours, and (5) plar.t status. The inspection involved 117 inspector-hours onsite by two NRC inspectors. Results: Within the five areas inspected, one violation (failure to maintain sufficient chemistry records, paragraph 4) was identified,
*s j
a '? p....,. j s.;. j b I 4
DETAILS-
~~1..~~
~~Persons-Corfacted Applicant Personnel~~
~~A. B. Scott, Vice President' Operations~~
~~J. C. Kuykendall', Vice President~~
C. ' H. Welch, Quality Control Services Supervisor

R. B. ' Seidel.. Operations Superintendent S. N. Franks, Special Project and Technical
~~' Support Lead~~
~~M. R. Blevins, Maintenance Superintendent~~
~~~D. E. Deviney. Operations QA Supervisor.~~
R.'A. Jones, Manager, Plant Operations K. L. Luken, Lead Startup Engineer

R. R. Wistrand, Administrative Superintendent,

D. W.' Braswell, Engineering Superintendent

J. C. Smith, Quality. Assurance

T. L. Gosdin, Support Services Superintendent
G. M.

McGrath, Licensing / Compliance Supervisor Startup
~~M. J. Riggs, Operations. Support Engineer D. M. Jones, Maintenance Engineering Technician L. Parr, Maintenance Engineer~~
'K. Stenburg, Maintenance. Engineer T. Justis, Maintenance Engineer 'H. Haby, Instrumentation & Controls Staff Engineer W. Jones,-Instrumentation & Controls Staff Engineer - B. Taylor Instrumentation & Controls Engineer R..D. Delano, Chemistry & Environmental Engineer G. B. Moore, Chemistry & Environmental Supervisor R. L. Theimer, Chemistry Supervisor
~~Denotes applicant representatives present during exit interview of paragraph 8.~~
The NRC inspectors also interviewed other applicant employees during this inspection period.
.t t 4 7 i .4 [ 2. Applicant Actions on Previous Inspection Findings / \\ L ' a. (Closed) Open Item 445/8436-05: Applicant to' provide a responseL f L _ manual for the loose parts monitoring system. In Section 5.4.3 of .-the-$afety Evaluation Report (July 1981), the staff indicated acceptance of the applicant's loose parts monitoring. system. The-SRRI issued Open. Item.445/8436-05.to track the applicant's issuance d of a response manual for the.1oose parts monitoring system. On j .0ctober 10, 1985, EDA-310, " Analysis of Loose' Parts Monitoring System- 't Data" was issued, which provides instructions for use of the system, i This item is closed. ~ j 1 b. .(Closed) Open Item 445/8502-01: Voiding of signatures'in preoperational test data packages. During routine inspections of completed preoperational test data packages, the RRI noted inconsistencies in the methods used by System Test Engineers (STEs) to void or supersede previous signatures when test steps had to be-repeated.- Section 4.8 of CP-SAP. required the STEs to void entries. by lining through and signing (or initia111ng) the line-outs and dating them. Sometimes the STE failed to sign and date the line-out,- thereby casting doubt on the part of a reviewer as to whether the signature was for the line-out or for reperformance of the step. The RRI suggested that a more straight-forward method of superseding such; steps be considered. The applicant has since responded that the requirements of CP-SAP-21.will not be changed; thus the STEs will be expected to comply with Section 4.8 when voiding signatures. This item is closed. c. -(Closed) Open Item 445/8502-02: Unclear justifications for test procedure deviations (changes). While reviewing completed preoperational test data packages, the RRI identified a number of cases where the STE did not enter a clear and concise reason or justification for. making minor changes to test procedures, which are called test procedure deviations (TPDs).- It appeared that if more specific direction was provided in Startup Administrative Procedure CP-SAP-12, " Deviations to Test Instructions / Procedures," this problem might not have existed. The applicant has since issued Revision 3 of CP-SAP-12 which directs the TPD author to enter a detailed justification for each change. The RRI reviewed the revised procedure and is satisfied with the change. This item is closed. d. (Closed) Open Item 445/8502-03: Post-completion changes to test documentation. During an inspection of completed preoperational test data packages, the RRI identified what appeared to be post-completion changes to test procedures using test deficiency reports (TORS) as the authorizing document. Although this practice did not have any adverse effects on the test records, administrative procedures did not provide for such changes. The applicant's response to this item
,= j c. 2 >}. 1 I . was that test data packages were not being " revised or changed" by TDRs, per se, but rather were being." annotated" to show the correct information found.during the data package review which was in turn documented and evaluated by the TOR. This concern is being addressed 1 .by recent changes to the Startup Administrative Procedures Manual to ? clarify the entry of corrections during' completed test data reviews, For example, on July 8,1985, Revision 6 to CP-SAP-11, " Review, Approval, and Retention of Test Results," was. issued. The revised o administrative procedure now requires the Joint Test Group (JTG).to document test data review comments and resolutions,~and to include this with the. supporting documentation in the completed. test' data 1 package. This will provide a means by which problems found during the JTG review of test data can be documented along with the JTG-approved disposition. 'The TDR will still be utilized to document bonafide deficiencies and corrective actions (including retesting, if any); however, the applicant has indicated that changes or. revisions j wiii.not be made against completed test procedures. This item is' i closed. 4 e. .(Closed) Unresolved Item 445/8502-08: Discontinuity between reference drawing revisions in similar test procedures. While conducting an inspection of the completed preoperational test data package for'1CP-PT-29-03, Retest (RT)-2, the NRC inspector noted that the list of reference drawings contained later revisions of the same drawings referred to in.1CP-PT-29-03, RT-1, which was conducted later than RT-2. The issue was whether or not failure to update the references for ICP-PT-29-02, RT-1 had any affect on test performance. After the question was raised, the applicant responded by explaining that.RT-1 did not have the correct revision numbers; however, since the objective of both tests was to start and load test the emergency diesel generators,.the revisions of the' reference drawings had no significance and thus did not affect the outcome nor the objectives of the test. The applicant filed a copy of the response and explanation as a supplement to the completed test data packages for 1CP-PT-29-03, RT-1 and RT-2 for future reference. This item is closed. f. -(Closed) Open Item 445/8502-11: During an inspection of the completed preoperational test data package for ICP-PT-57-10, " Load Group. Assignment," the SRRI noted that TDR-3676 had identified a failure to accomplish the slow transfer of-train B bus 1EA2 when initiated by the. test procedure. Under corrective action, the-TOR referenced Maintenance Action Request (MAR) 84-4036 to repair and/or adjust the auxiliary switches and actuating bar at a later date. -Meanwhile, per the TDR, the switches were placed in the required position manually so that the test could be resumed, including a repeat of the slow transfer test, which was successful. The MAR ano j MAR retest documents were not in the test data package. Subsequent
1 t RRI review of the completed MAR revealed that the actuating bar~was in need of lubrication and operated freely once lubricated. The applicant's representatives explained that the state of the auxiliary switches was in a condition required for accomplishment of the test and that testing of this breaker was not an objective of the test; thus, it was not necessary to repeat the applicable section of 1CP-PT-57-10 after the actuating bar was lubricated and successfully 4 exercised. This item is closed. g. (Closed) Open Item 445/8502-12: Potential impact of reference drawing changes in preoperational test ICP-PT-57-10. During the completed test data package review of ICP-PT-57-10 conducted by the applicant, TDR;3956 was issued identifying a failure to update the correct revision of 15 drawings referenced in the test procedure. The SRRI was concerned that no documentation existed in the completed test data package showing that an evaluation was made to determine the impact this might have on the test results. The RRI verified that the applicant had since conducted the evaluation, documented the results on letter TSU-85169 of October 14, 1985, and incorp, orated the letter into the completed test data package. The evaluation did not identify any impact on test results. This item is closed, b. (Closed) Open Item 445/8506-02: Open TDR in a completed preoperational test package. During routine inspection of the completed preoperational test data package for 1CP-PT-64-01, the RRI found TDR 3799 filed in the package with no evidence that it had been properly dispcsitioned and closed. Subsequently, the hpplicant's representative responded by explaining that this TDR was not written against ICP-PT-64-01; however, it was filed in the package for information only. Any testing issues associated with this TDR and the referenced containment spray valves have been deferred to the initial startup test program. The RRI found this to be adequately tracked by TUGC0 Operations under DPTR-85-002. This item is closed. 3. Maintenance Procedures The objective of this inspection was to confirm that plant maintenance procedures were prepared to adequately control maintenance and surveillance testing of safety-related systems within applicable regulatory requirements. The inspection included verification that: o Adequate procedures and processes were in place for control of measuring and test equipment (M&TE); o Procedures had been published for performing preventive and selected corrective maintenance;
l l J ~ o. Adequate' procedures and programs existed for the implementation of surveillance required by Technical. Specifications (TSs); I All procedures were in the appropriate format as kpecified in the { o administrative control manual, and that they were technically i adequate to accomplish their stated purpose; and o Where appropriate, procedures prescribed steps important to the protection of the-health and safety of the workers'.and of the public. The maintenance procedure inspection commenced in September 1985 and continued through completion in October 1985. Details of the inspection conducted in September 1985 were reported in Appendix C of NRC Inspection Report No. 50-445/85-13. a. The following procedures were reviewed by the NRC inspector which met the objectives of this inspection and for which there were no comments or adverse findings: o .INC-101, Revision 4, "I&C Maintenance Program"; o INC-109 Revision 1, I&C Preventive Maintenance Program"; o INC-7323A, Revision 1, " Analog Channel Operational Test and Channel Calibration - Steam Generator NR Level, Loop 1, Protection Set III, CH 0518"; o INC-601, Revision 2, " Digital Multimeter Calibration"; INC-624, Revision 2, " Prest,ure Test Gauge Calibration"; o INC-631, Revision 1, " Dial-Type Thermometer Calibration"; o MMI-302, Revision 0, " Reactor Coolant Pump Seal Replacement"; o o MMI-320, Revision 0, " Pressurizer Spray Nozzle Inspection"; o EMI-313, Revision 1, " Centrifugal Charging Pump Motor Inspection"; and o EMI-806,-Revision 0, " Electric Penetration Removal, Repair, and Installation." b. Procedures INC-2006X, Revision 0, " Filling and Venting Flow and Differential Pressure Transmitters (Water or Steam)," and INC-2007X, Revision 0, " Venting and Filling Pressurizer and Steam Generator l Level Transmitters," were found to not meet the objectives of this inspection as identified below. On March 21, 1985, Severity Level IV l
. ~. i t q I ! i i l Notice of Violation 445/8445-02 was issued citing the applicant for i f failure to provide adequate procedures appropriate to circumstances. ) 4 The circumstances involved an Instrumentation and Control (I&C) i technician who attempted to fill a pressurizer level detector reference leg while the plant was hot in accordance with an inadequate procedure (i.e.. 101-2007), which led to errors and a first degree thermal burn on his forearm. One of the preventive actions in the applicant's response to the violation dated April 15, 1985, was to revise 101-2007 which became INC-2007X. Another action was to review the remaining applicable procedures for similar procedural problems. The applicant stated that there were no other procedural problems that would result in a similar incident. J ICI-2006 was among those reviewed and it has since become INC-2006X. In light of the problems found by the RRI when he reviewed these two representative procedures, violation 445/8445-02 could not be closed. This was discussed with applicant management during the exit l interview of November 1, 1985, and acknowledged. The revised procedures (INC-2006X and INC-2007X) contained. steps that were unnecessary, and contained instructions to perform preparations (i. e., assembling test equipment) in a radiation area when they could have been done in a nonradiation area. It was apparent to the NRC inspector that ALARA program considerations were not incorporated into the procedures. The ALARA ("As Low As Reasonably Achievable") Program is implemented by HPA-101, "ALARA PROGRAM," which requires procedures, planning, and training to ensure all ionizing radiation exposure is reduced to as low as reasonably achievable on the basis of the state of technology and the economies of reducing exposure relative to the benefits realized. Both of the above procedures were inconsistent as to how to isolate and equalize differential pressure detectors. a l Some steps were not flagged for radiological controls when potentially radioactive material was to be handled. Double valve isolation was not utilized as required by INC-101 to 0 protect the I&C technicians from temperatures in excess of 200 F. l Filling and venting of differential pressure detectors should include sweeping air bubbles out through the equalizer valves. INC-2006X did not provide for this. INC-2007X had a caution note which stated that the reference legs are connected to the high pressure side of the sensors. This is not true in the case of Rosemount Detector 1LT-459F, thus the procedure does not accurately reflect the equipment to which it is to be applied, { j i i ____.__.._._____________1_________________________.______________________J
c.. 'i.$ indicating inadequate procedure reviews. The above. deficiencies were discussed in detail with the applicant's representative, who subsequently provided the NRC inspector with a sample mark-up of INC-2007X which reflected ac.knowledgement and correction of ti,e deficiencies discussed. Since correction of deficiencies such as the above is related to corrective actions associated with violation 445/8445-02, additional tracking of this issue is not necessary. There were no additional violations or deviations identified. 4. Preventive Maintenance Programs l ~The RRI is conducting an on going inspection to verify that an adequate i preventive maintenance program is scheduled and implemented, both from a routine equipment readiness standpoint, and in consideration of the length of shutdown time between Unit 1 preoperational testing and startup. This inspection includes verification that adequate controls exist to, ensure equipment maintenance will be followed by appropriate tracking and performance of retests prior to restoring the,,, equipment to an operational status. l The NRC inspector interviewed' applicant representatives responsible for the implementation and tracking of preventive maintenance and surveillance testing. Three' groups have separate responsibilities in this area: o Maintenance Engineering: Mechanical and electrical maintenance, including meter and relay maintenance. o Instrumentation & Control: Maintenance of plant system instrumentation and controls. j o Results Engineering: Surveillance tests and inspections required by TSs. Maintenance Engineering has implemented a plant equipment preventive maintenance program in accordance with Maintenance Department Administration Procedure MDA-301, " Preventive Maintenance Program." The program was developed to satisfy the requirements of ANSI N18.7-1976 as well as the maintenance manuals furnished by Westinghouse and other vendors. The scope of the program. encompasses all electrical and mechanical equipment that.are not assigned.specifically to the I&C group. I&C implements an overall maintenance program on equipment within their cognizance in accordance with INC-101. There are other subordinate implementing procedures, such as INC-107, which cover all scheduled calibrations and all required TS surveillance items that are assigned to I&C. INC-109, for example, covers all preventive maintenance not already covered by INC-107.
r 1 .5 1 . 1 Results Engineering will implement the surveillance program in accordance with STA-702, " Surveillance Test Program." This provides for scheduling,. j tracking,' review and disposition of the records for all surveillance required by the TSs. The RRI interviewed representatives from each of the above groups, at which time the respective programs were explained. In general, it appears that a comprehensive preventive maintenance program is in place, that is managed through computer scheduling and tracking programs. During future i NRC inspections, it will be determined if the programs are effective and the equipment is being maintained in a satisfactory state of readiness. The RRI reviewed chemistry records for steam generators and primary fresh water cooling systems between January 1983 and September 1985 to ensure that required records were in place, that corrective measures were promptly taken when out-of-specification results were obtained, and that there_was a full continuity of samples taken consistent with frequency requirements. This review identified the concerns discussed below. The primary fresh water cooling systems chemistry results were recorded on Form CHM-508-1, which is required by CHM-508, " Chemistry Control of the Primary Cooling Systems." Systems under the purview of this procedure are Safety Chill Water, Non-Safety Chill Water, Diesel Generator Water Jackets, Component Cooling Water, and BTRS Chill Water. In general, a lack of data < entry discipline existed, but with an improving trend, from January 1983 to present. For example, in many cases sample results were not entered, but there was no explanation. Presumably, the systems were drained or otherwise not available for sampling. Out-of-specification conditions were not flagged such that the RRI could determine that necessary notifications and corrective actions were implemented. l Specifically, weekly samples were taken 10 to 12 days apart in November 1983. Sample data entries did not exist in the Records Center for the weeks of March 28, 1983; June 7, 1983; June 14, 1983; June 21, 1983; j June 28, 1983; October 3, 1983; December 16, 1983; December 23, 1983; and [ December 30, 1983. l Steam generator chemistry results for No.1 and No. 2 steam generators were reviewed for the period between January 1984 and September 1985. The i data appeared on Form CHM-501-1 which is a requirement of CHM-502, j " Chemistry Control of the Steam Generators." In many cases, out-of-specification results were not flagged as required by CHM-501,to indicate that the shift supervisor was notified and at what time. Some samples were not taken, but no explanation existed. As was the case with primary cooling systems, the attention to detail expected to be seen on )
.. a.. 3 -11 such records did not appear to exist, even though all the forms were Li: reviewed and approved by supervision. l Specifically, pH for both steam generators was recorded as being j out-of-specification low (i.e., as low as 9.0 when a range of 9.8 to 10.5 t was required by CHM-501, Attachment 1) from June 20, 1984,through October 8, 1984, with no apparent explanation. When the RRI questioned j this, the applicant's representative explained that there had been a J considerable amount of discussion between the applicant and Westinghouse and that there had been no urgent W ed to correct the condition since the i d steam generators were in cold wet layup. At the time, the applicant could not produce documentation supporting this information. The RRI was
~~presented with a copy of Problem Report PR84-361 which was originated on October 5, 1984; over three months after the problem of low pH became known.~~
The report did not identify the pH as having been out-of-specification 1ow for over three months, but, rather, stated that ~ the mechanical-seals on the recently installed recirculation pumps were leaking, causing carDon dioxioe entrainment, which in turn caused a " depression" of pil in the steam generators.. The engineering review did j not evaluate the ef fects of the long-term pH depression on steam generators. The RRI was also presented with Independent Safety Engineering Group Report 34-03, which documented a review of steam generator water chemistry control. The revi w included the period when pH j was depressed, but stated that, "... Plant chemistry personnel report r that the steam generators chemistry sample data is stable and no problem areas have been noted." There was no mention of the pH problem. The report concluded, ". *.. prompt response to out-of-specification conditions indicate that no significant corrosion related damage has occurred in the Unit 1 steam generators." The applicant was requested to provide the RRI with documented evidence which proves that the quality of the primary and secondary boundaries of the steam generators had not been compromised as a result of over three months out-of-specification low pH. This is an unresolved item (445/8514-U-01). The concerns identified above with respect to what appears to be missed chemistry samples, failure to indicate when and if the Shift Supervisor was notified as out-of-specification results were obtained, a lack of records to indicate corrective actions taken, and inadequate reviews of data forms constitute a violation of Criterion XVII of Appendix B to 10 CFR Part 50 (445/8514-V-01). 5. Plant Tours 'j During this reporting period, the SRRI and RRI conducted inspection tours of Unit 1. In addition to the general housekeeping activities and general cleanliness of the facility, specific attention was given to areas where safety-related equipment was installed and where activities were in progress involving safety-related equipment. These areas were inspected to ensure that iJ
-. - o Work in progress was being accomplished using approved procedures; o Special precautions for protection of equipment were implemented, and additional cleanliness requirements were being adhered to for maintenance, flushing, and welding activities; o Installed safety-related equipment and components were being protected and maintained to prevent damage and deterioration. Also during these tours, the SRRI and RRI reviewed the control room and shift supervisors' log books. Key items in the log review were: o plant status, o-changes in plant status, o tests in progress, and o documentation of problems which arise during operating shifts. No violations or deviations were identified. 6. Unresolved Items a Onresolved items are matters for which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. One unresolved item disclosed during the inspection is discussed in paragraph 4. 7. Plant Status as of October 31, 1985 a. Unit No. 1 is reported to be 99% complete; however, excavation is underway to facilitate replacement of main. condenser internals and a significant amount of rework continues on the control room ceiling. b. Unit No. 2 is reported to be 77% complete. The preoperational test program on systems associated with NRC inspections has not yet started. 8. Exit Interview An exit interview was conducted November 1, 1985, with the applicant representatives identified in paragraph 1 of this appendix. During this interview, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the findings. c'. s.. ' 500(- I
g ",. ; i 4 APPENDIX 0 CONSTRUCTION INSPECTION REPORT i U. S. NUCLEAR REGULATORY COMISSION l i REGION IV I i NRC Inspection Report: 50-445/85-14 Permit: CPPR-126 50-446/85-11 CPPR-127 Dockets: 50-445 Category: A2 ~. 50-446 l Applicant: Texas Utilities Electric Company (TUEC) Skyway Tower l 400 North Olive Street Lock Box 81 Dallas, Texas 75201 4 Facility Name: Comanche Peak Steam Electric Station (CPSES) Units 1 and 2 Inspection At: Glen Rose, Texas Inspection Conducted: October 1-31, 1985 Inspectors: //Mh 1-2 F - S'(. 'H. S. Phillips, Seniof Resident Reactor Date Inspector (SRRI), Construction, Region IV CPSES Group (paragraphs 1,2,3,4,5,6,9,10) 1 0AS l v1
~~Ll2 V ?b.~~
D. L. Telley, SRRI,30perattions, Region IV Date CPSES Group (paragraph 8) 5 Wm 2/28/f4 i D. E. Norman, Reactor Inspector Date Region IV CPSES Group (paragraph 7) l t 1 3 6 9190317 c PDR ADOCK ( M45' l O OR
.~ ~ ~ l e 1 l . l l Consultants: EG&G - J. H. McCleskey l Parameter - T. H. Young Reviewed By: I8~% J/3/p 4 I. Barnes, Group Leader, Region IV CPSES Group' Data Approved: 7/ J/7/J'6 I T. F. Westerman, Chief, Region IV CP5ES Group Date { i Inspection Summary Inspection Conducted: October 1-31, 19F5 (Report 50-445/85-14) Areas Inspected: Routine, unannounced inspections of Unit I wnich included plant tours, applicant actions on construction deficiencies, applicant actions on previous NRC inspection findings, and storage and handling of QA records. The inspection involved 204 inspector-hours onsite by two NRC inspectors and two consultants. Results: Within the four areas inspected, one violation (failure to establish written procedures for control and accountability of the shipment of original design records to Stone & Webster Engineering Corporation (SWEC), paragraph 5.b) was identified. Inspection Conducted: October 1-31, 1985 (Report 50-446/85 11) i Areas Inspected: Routine, announced and unannounced inspections of Unit 2 which incluced plant tours; applicant actions on construction deficiencies; applicant actions on previous inspection findings; storage, protection, and handling of QA records; audit of QA records; welding material control; and electrical cable tray / equipment walkdown. The inspection involved 227 inspector-hours by three NRC inspectors and two consultants. Results: Within the seven areas inspected, three violations (a repeat failure to document minimum wall pipe violations on a nonconformance report (NCR), paragraph 4.c; a repeat failure to control issue of design documents, i paragraph 4.g; failure to establish written procedures for control and accountability of shipment of design records to SWEC, paragraph 5.b) were identified.
q l > DETAILS 1. Persons Contacted Applicant Personnel J. Merritt, Assistant Froject General Manager P. Halstead, Manager, Quality Control (QC) L. Welch,'QC Supervisor R. Spangler, Corporate Quality Assurance (QA) Supervisor J. Walker, Corporate QA Auditor J. Marshall, Licensing J. Hicks, Licensing M. Strange,. Supervising Engineer, Support & Project, TUGC0 Nuclear Engineering (TNE) J. Ryan, Technical. Service, Supervisor S. Ali, THE QA Staff Engineer B. Jones, Unit 2 Supervising Engineer, Civil / Structural i R. Hooten, Project Discipline Engineer, Civil / Structural i J. Hodgson, Computer Operator Supervisor, PMCS Contractor Personnel W. Baker, Welding Engineer, Brown & Root (B&R) W. Wright, Welding Engineer, B&R G. Purdy, Site QA Manager, B3.R J. Gore, Subcontract Supervisor, B&R K. Thornton, Warehouse Superintendent, B&R C. Osborne, QA Vault Supervisor, B&R D. Leach, THE-QA-B&R K. Norman, Central Operations Supervisor, DDC-B&R D. Bleeker, DCTG Supervisor, B&R R. C. Iotti, Project Manager, Ebasco j A. Smithey, Supervisor IRV, B&R R. Walters, ASME QA Supervisor, B&R G. Maedgen, Welding Engineer, B&R T. Gray, Document Control Manager P. Patel, Unit 1 Civil Lead, TNE Design, Gibbs & Hill B. Jones, Expediting Supervisor, B&R L. Barnard, PMG File Clerk, B&R T. McCormack, Fire Protection Engineer, Impe11 S. Felman, Assistant Project Engineer, SWEC. H. Moscow, Supervisor Projects & Services, NY, SWEC J. Tate, 304 DU Satellite Supervisor, B&R i. J. Junge, 311 DU Satellite Supervisor, B&R J. Womack, 300/301 DU Satellite Supervisor. N l l~ 1
... R + i, ~4- .l R. Flaherty, 307 DU Satellite Supervisor, B&R S. Hazle, 310 DU Satellite Supervisor, B&R ~J. Day, 308 DU' Satellite Supervisor, B&R o J. Dickey, DCC-Area Supervisor, Engineer Satellites, B&R- .S.. Bruce, DCC Area Supervisor, Craft Satellites, B&R i 2.- Plant Tours At various times during the inspection period, NRC inspectors conducted ' general tours of the reactor building, safeguards building, and the electrical and control building.. During the tours, the NRC inspector-g observed ongoing construction work and discussed various subjects with. -personnel engaged in work activities. No violations or deviations were' identified.' 3. Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant a. The applicant's procedures pertaining to Significant Deficiency Analysis Reports (SDARs) were reviewed to determine how the process of deficiency identification through completion and signoff is controlled. Reviews were performed of site Procedures CP-QP-15.6, Revision 3, "SDAR Status Tracking"; CP-QP-16.1, Revision 6, "Significant Construction Deficiencies"; CP-QP-17.0, Revision 1, " Corrective Actinn"; and TUGC0 Procedures DQP-CQ-4, Revision 1, " Reporting of Significant Deficiencies"; DQP-QA-12, Revision 2, " Administration and Tracking of Significant Deficiency Analysis Reports"; and DQP-QA-11, Revision 1. " Corrective Action." Procedures CP-QP-15.6, CP-QP-16.1, DQP-CQ-4, and DQP-QA-12 do not address the SDAR file contents or provide a method for completion and signoff of the required corrective action.' Procedures CP-QP-17.0 and DQP-QP-15.6 address the documentation required for closing deficiencies, but there is no cross reference between SDAR/ corrective action with respect to SDAR file contents. This is an unresolved item pending completion of NRC review of SDAR procedural adequacy l (445/8514-U-02; 446/8511-U-01). b. The applicant classified the following reportable SDAR files as " Licensee Action Complete": SDARs CP-84-27, CP-84-29, CP-25-04, CP-85-05, CP-85-11, CP-85-12, CP-85-13, and CP-85-14. 'The above H files did not document or reference the location of documentation which would support the reported status of corrective actions be)Ag complete. Consequently, the NRC inspector did not perform a field verification for any of these files. c. The following nonreportable SDAR files were selected for review, since the applicant classified these as " Licensee Ar;' ion Complete": 1
5-(1) (Closed): The NRC inspector reviewed the following 50ARs: CP-84-05, CP-84-22, CP-84-23, CP-84-24, CP-84-26, CP-84-32, CP-85-02, CP-85-08, and CP-85-09. The applicant's evaluation and decision that these SDARs are not reportable appeared to be correct. (2) -(0 pen): The NRC inspector reviewed SDARs CP-84-30, CP-84-34, and CP-85-06. The files for these SDARs did not contain sufficient 'i information or documentation to determine whether or not the SDAR was nonreportable. The status of the files is an unresolved item pending the completion of a TUGC0 effort to make the files complete and subsequent NRC review (445/8514-U-03; 446/8511-U-02). I 4. Applicant Action on Previous NRC Inspection Findings a. (Closed) Unresolved Item (445/8422-U-02): Inverter transformer common ( failure. The NRC inspector reviewed the applicant's handling of the j defective transformers and concluded that the actions taken to evaluate and correct the deficiency were correct and adequate. The applicant's handling and reporting of significant deficiencies will continue to be monitored by the NRC inspectors. b. (Closed) Violation (445/8307-V-01): Excessive welding gap. In 1983, the NRC inspector identified an unacceptable fitting on pipe support Mark No. SW-1-102-106-Y33K. Recently, the NRC inspector followed up and reviewed NCR M5123-5, RPS 751947, WDC80668, related sketches, and inspection reports (irs). Corrective work was accomplished and QC performed required inspections. An engineering analysis of the installation which was performed in response to the violation showed strength was far in excess of minimum design requirements, even though it violated the procedure. In B&R memo -IM 325,208 dated April 13, 1983, supervision reemphasized the requirement to follow procedures to all affected personnel. c. (Closed) Violation (445/8315-01): Failure to write an NCR on base i metal repair. This violation concerned an instance where the NRC 1 inspector observed a minimum wall violation for which a NCR had not been written. On October 8 and 9, 1985, another NRC inspector reviewed this violation of paragraph 3.3.3 of site Procedure QI-QAP-16.1-2, Revision 4, dated May 20, 1982. The scope of this i procedure was changed to make further reference to system walkdown and the item in question was accomplished near this time frame. However, the applicant responded by documenting the questionec { minimum wall violation and the repair of the adjacent weld on a i l i l l l l
t l common NCR (M6611). These conditions had been found by separate NDE inethods, one before and one after the base metal repair. The NRC inspector reviewed two more recent base metal repairs to verify that the problems had been corrected. One repair performed in 1984 was-1 I found to have been in compliance with the then current procedures. The second repair was completed, reviewed, accepted, and ) documentation sent to the vault during September and October of 1985. This second report showed an original weld completed, reviewed, and i accepted in January and February 1985. Rework was performed on this j weld in September 1985 due to interference with a hanger installation 1 which resulted in a minimum wall violation. Further work to repair j the hanger was classified as a " Major Weld Repair" in accordance with 2 paragraph 3.3 of B&R Procedure CP-CPM-6.9G; however, no NCR was i generated. This failure to document a minimum wall violation on an NCR is a repeat violation of Criterion XV of Appendix B to a 10 CFR Part 50(446/8511-V-01). { It was noted that the inspector and the preparer of the repa,ir process sheet had recently received training on the newly revised q procedures involved which required the NCR be generated. The Assistant Project Welding Engineer who reviewed the repair process sheet had not been so trained on the procedure, as he had been exempted from the training by virtue of his positior. d. (Closed) Unresolved Item (446/8502-01): Responsible velding supervisors not familiar with welding rod control m;cedures. In 1985, the NRC inspector interviewed supervisors who were not familiar with welding rod control procedures which their crew of welders were responsible for implementing. The training program for supervisors was conducted in May 1985 and covered helpers through general foremen. In 1984/85, the NRC Technical Review Team (TRT) extensively reviewed j and inspected weld rod control and documented their findings in NUREG-0797, Supplemental Safety Evaluation Report (SSER) 10, Category j 9. In addition, the RIV inspector inspected weld rod control during this inspection period and identified no violations or deviations. ] (Closed) Unresolved Item (445/8323-07): Incomplete Class V(5) pipe e. supports record package. In 1983, the NRC reviewed packages which 4 had been combined into finalized packages. In 1984, the TRT reviewed a random sample of 11 Class V(5) support record packages. This review showed that packages with irs (by qualified inspectors) were in proper order. The TRT found the records satisfactory as reportec l on page N-252 of NUREG-0797, SSER 10 dated April 1985. 1 f. (Closed) Unresolved Item (445/8347-01): Containment surface area coating. This item addressed sloughing of protective coatings on
...- s i a w.w. .~ i.. < 1 Westinghouse supplied items. In SSER'9, NRR staff state they have reasonable assurance that debris generated by the. failure of all coatings inside the containment building under design basis accident
~~conditions will not unacceptably degrade the performance of post-accident fluid systems. This was based on TUGC0 and other.~~
studies referenced in NUREG-0797, SSER 9 on pages L-17 and L-18. NRR requires in SSER 9 that a preoperational and postoperational coatings program be proposed by TUGCO, but this. specific issue of sloughing of coatings on Westinghouse items is~ closed based on the SSER 9 conclusions. g. (Closed) Violation (445/8416-V-02): Failure to provide controlled issuance of design documents and changes thereto..Between May and-June ~20, 1984, an NRC inspector found that design documents and changes were not controlled by Operations Document Control Center (DCC). On October 11 and 14,'1985, the NRC inspector confirmed that the computer system and terminals referred to in the TUGC0 November 1, 1984, response were in place and in use. TheNRCinspectorreviewed12DesignChangeAuthorizations(DCAs)'and Component Modification Cards (CMCs) and followed the distribution of i 25 packages to 9 locations for various disciplines and verified corrective action. These DCAs and CMCs were traced in their routing at the central DCC and then on to the Paperflow Group or satellite DCCs and a review performed of how they are distributed from those locations. All items checked were distributed per DCP-3, Revision 18 (with Document Change Notices (DCNs) 1, 2, and 3), with the following exceptions: (1) CMC 96181, Revision 1, was issued on October 8, 1985, and satellite DCC 307 (craft) picked it up at central DCC. The CMC was not signed for as required by paragraph 3.1.1.1 of DCP-3, Revision 18, with DCNs 1, 2, and 3. _There was a similar occurrence on CMC 75003, Revision 2, as issued to satellite DCC 202/211 (TUGCO). Further, DCA 21446, Revision 1, was issued October 8, 1985, and satellite DCC 307 was in possession of it on October 14, 1985. One of two packages for Drawing i 2323-El-1702, Sht 002, Revision 2, had both Revision 0 and Revision 1 of DCA 21446 in it, with the other having only Revision 0 in it. Both Revision Os were not stamped " VOID" as required in paragraph 3.2.2.5 of DCP-3. On October 14, 1985, satellite DCC 307 issued Drawing 2323-El-1702,.Cht. 002, Revision 2, to an electrician for Class IE fie'.o work with Revision 0 of DCA 21446, rather than the curreno Revision 1, which is contrary to the requirements of paragraph 3.2.1.2 of DCP-3. On October 14, 1985, TUGC0 and B&R supervision contacted the electrician who indicated he had l 4
p% r.v..... i4 4,, a > q l%' ig, i - w I .y he gotten sheet 002 rather than srieet 001 by mis,take and had '/ returned it immedi?tely without installing anything to it. o n~ s These failures to follow design doc mient control procedures are J. a violation of Criterion V of Appendix B to 10 CFR Part 50 L (446/8511-V-02). + o s 3 (2) The following examples were noted of practices being followed that were not covered in controlled procedures: s '(a) Tni method used to issue orawir.g packages from the satellites to the field (e.g., crafts and QC) was not ,+ ,T addressed in DCP-3. The actual practice is that a DCC k person and the recipient sign for receipt of all the proper y 3\\ documentr (e.g., DCAs) and the proper revisions on the l ) computer printed "Open Design Change Log." r i (b) Another' practice of the DCC group is to log into the computer the status of the DCAs and CMCs. This st&tus is classifed as open, void, or not included (NI) and indicates whether a change is affecting all items built to a drawing, a single item utilizing the drawing, or no further use of i the change. Drawing 2323-5-0910, Sht. CSR-2A, Revision It had CMC 75003 issued against it. This CMC had status NI on .x Revisions 0 and 01 because it affected a single hanger utilizing the above drawing. However, Revision 02 did not have NI input and it showeo as open on the terminals. This F[P would reonire it to be included with the drawing package in L error. 11his was corrected on the terminal. This process of statusing the computerized document information is not lg (' described in DCP-3. i 3 + 4 OCC supervision stated and showed that the practices are described in' internal uncontrolled guidelines. This item is unresolved pending incorporating the guidelines into a .,. 1 s y y controlled psocedure (446/8511-0-03). 'N h,- (Closed) Violation (M-03-01): Gaps on Unit 1 polar crane bracket and seismic connections. In November 1984, a NRC inspector found that ,"J the gaps between the bracket and connectors exceeded the design tolerance. This item is addressed in NUREG-0797, SSER 8, along with s ', related problems with polar cranes. Discussion, conclusions, and actions to be taken are included in pages K-14, 15, 18 and 121-123 of y Appendix K to SSER 8. Since these actions will address ths! specific concerns of item 84-08-01, this item'is closed. 5. QA Records System Review ] The NNC inspector reviewed the applicant's record Feeping system after j ascertaining that records were being shipped off site without proper i 1 1 1 E _ _ _ _ _ _ _____ j
.w a. .w 9 I control and inventory. In Appendix IA(N) and 1A(B) of Final Safety Analysis Report (FSAR) Volume 1, Section 1.0, the applicant commits to Regulatory Guide 1.88 (i.e., Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records) and to American National l Standard, Institute (ANSI) N45.2.9, lith Draft, Revision 0, dated January 17, 1973. On page 1A(B)-36 in the Discussion, the applicant makes r$o exceptions to this standard. A brief description of QA records is contained in FSAR Section 17.1.17 (Amendment 50 dated July 13,1984). The description does not address the current QA records facilities and storage; i.e., temporary storage of records for the Paper Flow Group, Interim Record Vault (IRV), Permanent Plant Record Vault (PPRV), procurement records storage area (Warehouse A) and the TUGC0 Recoros Center. The applicant has not revised FSAR Section 17.1.17 to describe and reflect the current QA record system. This is unresolved pending the applicant's actions on the item described in paragraph a below (445/8514-U-04; 146/8511-U-04). a. Review of Corporate QA Manuals and Implementing Construction Procedure: The NRC inspector reviewed the TUGC0 Corporate QA Program Manual, Revision 14, dated April 30, 1985, and Quality Assurance Plan, Revision 14, dated August 30, 1984, to determine if ANSI N45.2.9 was referenced and if its requirements were translated into these documents. Only TUGC0 construction Procedure CP-QP-18.4, Revision 5, was found to reference ANSI N45.2.9. Operations and TUGC0 Nuclear Engir.eering procedures were not included in the scope of this inspection. Procedure CP-QP-18.4, Revision 5, does not address all aspects of ANSI N45.2.9 such as (1) definitions; (2) all facility locations; (3) method for maintaining control of and accountability for recoros removed from the site storage facility to organizations located on or off site; (4) temporary storage facilities (fire rated cabinets versus duplicates in remote, separated locations); and (5) special process records such as photographs, negatives, and microfilm. The permanent facilities are discussed with respect to ANSI N45.2.9 requirements described in paragraph 5.6; however, the drain system and dry chemical / gas fire protection system is not discussed. The IRV system is a permanent records vault for Unit 2 records until such records can be transferred to the construction PPRV where Unit 1 records are now stored. TUGC0 Procedure CP-QP-18.6, Revision 3, discusses records turnover from B&R IRV to TUGC0 PPRV but does not address the issues raised above. Also, these issues are not addressed in the B&R QA Manual, Section 17.0 dated October 31, 1984, or CP-QAP-18.1, Revision 3, dated July 11, 1984.
n -~ .... a.. 1,.c. 4 .. p. m..,.... i J J TUGC0' management stated _that all of their QA manuals are in revision j to improve.their written program. This item is unresolved pending
~~J the completion of that review (445/8514-U-05; 446/8511-U-05).~~
i -. b. Storage and Transmittal of Design Records to SWEC, New York: On i October 16, 1985, an NRC inspector was inspecting an open item previously identified as unresolved item 8226-U-07. As a result, the requalification package for pipe support CC-1-107-008-E23R was requested and the NRC inspector was informed that this design records L package had been included in a total of 5702(4654 for Unit 1, 1048 for. Unit 2) hanger packages that had been shipped to SWEC, New York, for a complete. reevaluation. The NRC-SRRI interviewed the TUGC0 engineering supervisor who answered questions about whether procedures controlled such shipment, the. number of. records per package, and how the records were to be protected during shipment. He stated that a first transmittal.was controlled by Procedure CP-EI-18.0-4, Revision 0, dated July'25, 1985, until Comanche Peak Project Engineering became a part of TNE on September 1,'1985, at which time the procedure was deleted. The SWEC project manager stated that Procedure CPPP-3 covers the receipt and indexing of these packages; however, CPPP-11 that will control the distribution of these packages to SWEC offices at Cherry Hill, New Jersey; Boston, Massachusetts; Denver, Colorado; Houston, Texas; and Toronto, Canada, will not be completed until' late October or early November 1985,-according to SWEC Supervisor Project Services, New York. The utility has taken corrective action that includes (1) making duplicate copies prior to shipping, and (2) all records initially sent to SWEC are being copied and a copy returned to the site. Region IV is pursuing with IE Headquarters, QA Branch the minimum protection that should be afforded records in shipment. The failure to have site procedures to maintain control and accountability of the shipment of records is a violation of Criterien V of Appendix B to 10 CFR Part 50 (445/8514-V-02; 446/8511-V-03). Storace and Trans.ittal of Construction Records to Chicago Bridge and m c. Tron (CBTTFAs a result oFknowledge of an earlier shipment of CBI L records off site, the NRC inspecter has asked the utility to provide f records to demonstrate the CBI-record controls that were implemented. It is CBI practice to ship all records off site for copying. This matter is considered unresolved (445/8514-U-06; 446/8511-0-06). The utility has indicated that the receipt of records from CBI was handled in the same manner as the receipt of records from any vendor. Region IV will inspect the receipt of vendor records and this matter is considered an open item (445/8514-0-01; 446/8511-0-01). l
a -. I l i d. Inspection of Storaae Facilities: The NRC inspectors visited all site storage facilities to determine if storage, preservation, and safe keeping of records are as required by Criterion XVII of Appendix B to 10 CFR Part 50 and ANSI N45.2.9, D aft 11, Revision 0, paragraph 5, " Storage, Preservation and Safe Keeping." The facilities inspected included TUGC0 Records Center, which is committed by the FSAR to ANSI N45.2.9-1974 and not the Draft 11, Revision 0 version; PPRV; IRV; Paper Flow Group storage areas for Unit 2 m6chanical and electrical; and the procurement records storage area. The facilities for the Paper Flow F-oup and procurement r.ecords are not identified or described in TUGC0 or B&R procedures; however, these facilities and the PPRV and IRV were evaluated with the following results: (1) TUGC0 Records Center - This vault is the final repository for: (a) Unit 1 records which describe completed construction, and (b) Unit 2 record packages for systems that nave been completed and turned over to operations. This facility was completed about March 1983. The NRC inspector found that this vault had access control and recordr were stored in closed containers, open face shelves, or in binders on top of furniture. Radiographs and other special process records are protected by controlling temperature and humidity. The NRC inspectors noted that a water sprinkler system had been installed in this facility. This presents a concern because those plant records which are stored in folders or binders in open faced cabinets will be deluged with water and will likely deteriorate. An additional consideration is that records stored in a manila folder may be washed out and possibly clog the drain in this facility, leading to flooding of the facility. This item is Jonsidered unresolved \\ ! pending applicant review of the facility with respect to the above observations (445/8514-U-07; 446/8511-U-07). A
~~2) PPRV - This vault served af the ' sole permanent vault from approximately 1975 until March 1983.~~
This permanent records facility has controlled access. It meets the design features for a permanent facility, as described in Section 17.1.17 of the FSAR; however, the NRC inspector had the following comments: (a) There is no fire suppression system inside this vault. Two hand-held extinguishers and a 2-inch fire hose are located outside the vault. One hand-held extinguisher is located
. inside the vault. Fire detectors and alarms are inside to alert the onsite fire department if a fire occurs. (b) If the 2-inch fire hose is used to extinguish a fire, the vault may flood because there are no fire drains and the floor is not sloped. Therefore, water may potentially enter the bottom cabinet drawers. (c) NCRs and corrective action reports were stored in binders in bcokcases. If fire hoses are used, these documents would probably be subjected to the force of water from the hose and damaged. Therefore, it would be desirable to store these records in closed containers. All other records were stored in nonfire rated cabinets which is acceptable if located in a permanent facility that meets ANSI N45.2.9 requirements. The failure to install a fire suppression system, drains, and a sloped floor appears to be a deviation from ANSI N45.2.9 requirements. However, this item is unresolved because this facility is described in FSAR Section 17.1.17. Region IV is forwarding this issue to IE Headquarters, QA Branch for clarification (445/8514-U-08; 446/8511-U-08). a (3) IRV - This area is not a separate building, but is actually part of the permanent vault that has been set aside as an interim storage area prior to placing records in the area designated for permanent records. This area has an access point that is separate from the permanent area and is controlled. The facility is the same as the permanent area, except a wall 4 separates the two. They share the same forced air system. This facility generally meets the requirements of 10 CFR Part 50, Appendix B, and ANSI N45.2.9; however, the NRC inspector had the j following comments: (a) Water had been leaking through the forced air system and beside a support girder. In a second location, approximately 2-3 gallons of water had leaked in through the forced air ventilation duct and was caught by a container placed under the duct. This is considered an open item (445/8514-0-02; 446/8511-0-02). j (b) The NRC inspector observed a coffee pot, sugar, and evidence of food on a table adjacent to the vault area. These were immediately removed from the vault by the utility.
E, e.-
^
~~4) Paper Flow Groups - The NRC inspectors visited trailers where the electrical and mechanical Paper Flow Groups are located to determine if QA records are stored there.~~
In SSER No. 11, the TRT considered the documents in the paper I flow groups to be inprocess; however, SSER No. 11 also indicated I that the records are maintained in fire proof cabinets. The NRC inspectors fuund that there are some records stored in nonfire-rated file cabinets. This matter is considered unresolved (445/8514-U-09; 446/8511-U-09). s (5) Storage of Procurement Records - In Warehouse A, procurement records were stored both in nonfire-rated and fire-rated cabinets. The NRC inspector found no master index of these records and the facility is not described in the FSAR or procedures. There was no way to determine whether duplicates of these records exist and if they r~tst be :;tored in fire-rated cabinets. This item is unresolved pending identification and description of this facility and indexing of records recently received from the TUGCO, Dallas, Texas, office to determine what records must be in fire-rated cabinets (445/8514-U-10); i 446/8511-U-10). 6. Audit of QA Record Systems / Facilities The NRC inspector asked if the unacceptable QA records storage and control conditions identified above in paragraphs 5.a and 5.d had been identified by TUGC0 or B&R audits. TUGC0 audited (TCP-85-20 dated January 16,1985) the PPRV but failed to identify any of the problems noted above. Two auditors audited this area from December 17 through December 20, 1984, and their report did not identify any storage facility problems. ANSI N45.2.9 requires that periodic audits shall be performed to assure facilities are I in good condition and temperature / humidity controls and protective devices are functioning properly. An Ebasco review or study dated June 16,1981, page 4 of 25, item g, l states with respect to the PPRV, "It is an established fact that the QAR l vault does not meet the requirements for a single storage facility and j that duplicate files are not maintained in lieu of single storage." On j October 23, 1985, the NRC inspector requested documentation which would show action taken in response to the Ebasco finding. TUGCO's Project and QC organizations had no such documentation. This item is unresolved pending review of the response to this audit finding (445/8514-U-11; i 446/8511-U-11). The NRC inspector asked PPRV personnel if 8&R had audited the record keeping / facility system and was informed that it has been several years since 8&R had performed such audits. This item is unresolved pending the review of B&R audits (445/8514-U-12; 446/8511-U-12). l i l i i _ L _ _ _.
. 7. Control of Weld Filler Material This inspection was performed to determine whether safety-related weld filler material purchase, storage, and distribution are in accordance with the applicant's work and QA procedures, and applicable ASME code requirements. Implementation of the following procedures was examined during the inspection: CP-QAP-8.1, Revision 9, dated October 15, 1984, " Receiving Inspection"; CP-CPM-6.9B, Revision 2, dated September 21, 1984, " Weld Filler Material Control"; and CP-CPM 8.1, Revision 3, dated July 2, 1985, " Receipt, Storage, and Issuance of Items." The following areas were examined: ( a. Procurement: Four purchase order packages which consisted of the purchase order, procurement specification, and field requisitions were inspected to verify that orders were properly approved and included required technical, packaging, and documentation requirements as specified in site procedures pertaining to weld filler material purchases. No violations or deviations were identified. b. Receiving Inspection: Receiving inspection records, for the filler material purchased to the procurement documents inspected, were examined to verify that all items required by Attachment 11 (Receiving Checklist) to CP-QAP-8.1 had been inspected. In each case, the checklist and a receiving inspection report had been completed and signed by a Level II QC inspector. In several instances, NCRs had been completed and material returned to the vendor as required by procedures. Certified Material Test Reports (CMTRs) for each purchase were also reviewed to verify that required inspections and tests had been performed and that material had been purchased from a vendor with a current ASME certification. It was also verified that heat codes and quantities of material shown on the Material Receiving Reports corresponded to what was shown on the CMTR. No violations or deviations were identified. c. Main Storage Areas: Two filler material storage areas located in Warehouse A were inspected for compliance with the above listed procedures. One area was designated as a Quality (Q) area and the
.a.s.o. s. ~.. } 1 33 other one was both a Q and Non-Q area. The Non-Q material was segregated as required from the Q material. Procedures in the storage areas appeared to be adequately implemented; however, the NRC had the following observation: Paragraph 3.2.1 of CP-CPM 6.98 requires that Q weld filler material original containers be marked upon receipt and during storage with the material classification, si:e, and heat / lot number. In the Q area, labels on several containers of Sandvik welding products (weld rod) had fallen off and others were loose. The material was still identifiable, because of the storage bin marking and marking on the i shipping carton; however, a loss of identification is possible when material is removed from the storage area. There were also several unopened cartons of Sandvik material whose status could not be determined. Loose or missing labels were identified on the following material; Lot 101172-2, 1/8 inch, AWS/ASME SFA 5.4; and tot 10149-1, 5/32 inch AWS/ASME SFA 5.4. This matter has been referred to B&R Welding Engineering for followup. d. Distribution Stations: Weld rods used in, safety-related applications are distributed from three areas (Rodhouse 2, 3, and 4). Each dist: 41ution station was inspected to verify compliance with requirements of CP-CPM 6.9B in the following areas: Storage facility (Level B); Identification of material; Controlled access into storage areas; j Control of stationary and portable rod ovens; Issuance, return, and accountability of material; and Completion and control of records. Label problems were also noted in Rodhouse 4 during this inspection. 8. Cable Tray and Equipment Walkdown During this inspection period, the NRC inspector performed a walkdown inspection of selected electrical components and cables to determine the degree of protection of class IE items from surrounding construction activities. The general level of protection appears adequate with the exception of the B Safety Train Diesel engine control panel (2DG02A). The visqueen covering had come loose in several spots allowing concrete dust from above to filter into the panel and settle on some of the installed relays.
S . In the area of cables, it was noted that cable ends were neatly coiled and the ends taped, cable tags were in place and cable jacket repairs were clearly marked. At one point in the Safety Train B switchgear room, a cable exiting a tray and entering the switchgear (cable No. C23G 06070 above the HVAC chiller No. 14.) appeared to be bearing hard on the square section of the cable tray side ladder at its exit point. In other pla es where cable exits tray, a piece of discarded cable jacket is used as a buffer. The observed point had no such buffer. No violations or deviations were indentified. 9. Unresolved Items Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Twelve unresolved items disclosed during the inspection are discussed in paragraphs 3.a, 3.c, 4.g, 5, 5.a, 5.c, 5.d, and 6. 10. Exit Interview i An exit interview was conducted November 1, 1985, with the applicant representatives identified in paragraph 1 of Appendix E. During this interview, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the findings. a
t-APPENDIX E U. S. NUCLEAR REGULATORY COMMISSION REGION IV COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT NRC Inspection Report: 50-445/85-14 Permit: CPPR-126 50-446/85-11 CPPR-127 Dockets:- 50-445 Category: A2 50-446 Applicant: Texas Utilities Electric Company Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 1 Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 Inspection At: Glen Rose, Texas Inspection Condu t d: October 1-31, 1985 Inspectors: s b L. E. Ellershaw, Reactor Inspector, Region IV 'Da t'e CPSES Group (paragraphs 1, 2.a 3, 6.b, 6.e-6.g, 6.j, 7.e-7.u) 9 = 1 C. J. @,'Re' actor Inspector, Region IV CPSES D6te ~ ~ Group (paragraphs 1, 2.b 4, 5, 6.c-6.d, 6.h-6.1) Yf ~5/7/E G-l A. R. Johnson, Reactor Inspector, Region IV Date CPSES Group (paragraphs 1, 6.a, 7.a-7.e) ] Consultants: EG&G - R. Bonnenberg, J. Dale, L. Jones, A. Maughan, W. Richins, R. VanderBeek I l-L ioT MgdFM 0500o 2* G 445 PDR I' l
~~y.,~~
.a.v ...s i .g. Parameter - J. Birmingham, D. Brown, J. Gibson, K. Graham, D. Jew, 8w 7/7/#4 Reviewed By: I. Barnes, Group Leader, Region IV CPSES Group Date l'ffl F '3h/% Approved: T. F. Westerman, Chief, Region IV CPSES Group Date ' Inspection Summary Inspection Conducted: October 1-31, 1985 (Report 50-445/85-14; 50-446/85-11) i Areas Inspected: Nonroutine, unannounced inspection of applicant actions on previous inspection findings, followup on alleged contractor improprieties, Comanche Peak Response Team (CPRT) procedures and instructions, and CPRT issue - specific action plans (ISAPs). The inspection involved 2363 inspector hours onsite by 5 NRC inspectors and 11 consultants. A summary of NRR and IE audit ] activities is provided in paragraph 4. { Results: Within the four areas inspected, two violations (revision of drawings without required review and approval actions, paragraph 2.a; signing of inspection reports by a noncertified electrical inspector, paragraph 8.c) and i four deviation (ERC equipment / service requests not controlled as committed, 4 paragraph 6.a; inadequate ERC document review and procedure criteria with respect to nonrecreatable and inaccessible inspection attributes, paragraphs 8.c and 8.e;. failure of ERC document reviewers to detect a lapsed electrical inspector certification and to record required information in a verification package, paragraph 8.c; and inspection attributes being attested to as acceptable by ERC inspectors which were found by subsequent NRC inspection to be unacceptable, paragraphs 8.e, 8.1, and 8.u) were identified. I f f
~a. q j } N h DETAILS ] 1. . Persons Contacted-D. L. Andrews, TUSI Director of Corporate Security J. Arros, TERA Civil / Structural Issue Coordinator C. I. Browne, Project Manager, R. L. Cloud & Associates, Inc. i
~~R. E. Camp, Assistant Project General Manager, Unit 1 (Impe11 Corp.)~~
~~i J. Finneran, TUGC0 Lead Pipe Support Engineer f $5. M. Franks, Special Projects and Technical Support Lead (Impe11 Corp.)~~
J. B. George, TUGC0 Vice President, Plant General Manager

P. E. Halstead, TUGC0 Site QC Manager J. L. Hansel, ERC QA/QC Review Team Leader C. K. Moehlman, TUGC0 Project Hechanical Engineer

C. Killough, TUGC0 Supervisor, Operations Quality M. Obert, ERC TRT Issue Coordinator A. Patterson, ERC Engineering Supervisor C. Spinks, ERC Inspection Supervisor

T. G. Tyler, TUGC0 CPRT Program Director

C. H. Welch, TUGCO-QC Services Supervisor R. Werner, Manager, Safeteam

P. B. Stevens, TUGC0 Project Electrical Engineer G. Benfer, Bahnson Services Co. Site QA Manager D. W. Snow, Brown & Root (B&R) QA/QC Coordinator T. Wright, TUGC0 Civil Engineer

G. W. Ross, ERC Onsite QA Representative J. Adam, ERC Supervisor, Safety Significance Evaluation Group D. M. Kim, Principal Mechanical Engineer, Gibbs & Hill (G&H)
T. Brandt, TUGC0 Quality Engineering Supervisor J. R. Honekamp, TRT Issues Manager, TERA P. Turi, TERA Issue Coordinator G. Purdy, B&R QA Manager l J. E. Young, ERC Issue Coordinator J. R. Gelzer, ERC Issue Coordinator
5. L. Crawford, ERC Issue Coordinator P. Thomas, ERC Supervisor, Inspection Group Services D. Alexancer, ERC Supervisor, Hardware Issues P. Amoroso. ERC Supervisor. Hardware Collective Evaluation R. Melton, TERA Documentation Coordinator J. Ma11anda, CPRT Electrical Review Team Leader
~~Denotes those persons who attended~~
..a exit interview. 1 The NRC inspectors also contacted other CPRT and applicant employees l during this inspection period. 1 Led
~ L l L l 2. Applicant Actions on Previous Inspection Findings a. (0 pen) Open Item (445/8511-0-04): This item remains open pending'the review and assessment of the dispositions relating to the 12 deviating skewed welds in NF supports. Further review with respect to the status of this item has resulted i in the NRC's identification of a violation. During ERC's reinspection of skewed welds in Unit 1, undersize conditions were identified and documented on B&R nonconformance reports (NCRs) as early as June 1985. CPSES Station Administration Manual Procedure No. STA-405 requires that all documented nonconformances, in which "use-as-is" dispositions are recommended, be forwarded to TUGC0 Operations Results Engineering Group for review to determine if as-built documentation changes are needed. Further, CPSES Nuclear Operations Engineering Manual Instruction No. N0E-201-5 requires that proposed drawing changes be submitted to Operations for review, approval, and authorization to distribute the revised i drawing. l The NCRs associated with the undersize skewed welds are identified as XI-2, -3, -4, -5, -6, -7, -8, -10 and -11. The applicable pipe support drawings were revised by TUGC0 Nuclear Engineering (TNE) to reflect the undersize weld conditions. Recalculations were performed to support the use of the welds without rework or repairs. While the NCRs were not formally dispositioned, this action, in effect, provided a "use-as-is" disposition. However, TUGC0 Operations did not review and approve the drawing revisions. In fact, in most cases TUGC0 Operations did not initiate their own NCR to address these conditions until after THE had revised and distributed the drawings. As of the end of this report period, TUGC0 Operations NCRs have not been dispositioned. The NRC inspector was informed by TUGC0 Operations personnel that their review has found a number of mathematical errors in the TNE recalculations, thus precluding a dispositioning of the TUGC0 NCRs. The failure of THE to acquire TUGC0 Operations review and approval prior to initiating drawing revisions is a violation (445/8514-V-03). i b. (Closed) Open Item (445/8513-0-06): Provisions for familiarizing QC inspectors with changes in QC inspection procedures. Details on this subject are contained in paragraph 7 d~of this appendix. 3. Followup On Alleged Contractor Improprieties The NRC inspector perform:d.. followup inspection with respect to the identification by a local c.t" spaper of alleged contractor improprieties. The inspection was perfor'- to ascertain whether the alleged l
u .v ~5-l improprieties, if substantiated, could adversely affect safety-related components and systems. NRC review of this subject revealed that the alleged improprieties, which consisted of eight specific items, had been reviewed by the TUGC0 Safeteam and by the TUSI Director of Corporate Security. NRC examination of the items, certain of which were substantiated, resulted in a determination that there was no instance where any substantiated item had any impact with respect to safety-related components or systems. The NRC considers this item to be closed. 4. NRR and IE Audit / Inspection Activities a. NRR: A site inspection was performed during October 10-11, 1985, pertaining to civil / structural issues. Audits were performed on October 25, 1985, at Ebasco and Stone and Webster, New York, i pertaining, respectively, to cable tray / conduit supports and small bore piping review. A site audit was perforraed of homogeneity of construction processes during October 9-10, 16-18, and 28-31, 1985. b. IE: An inspection of Design Adequacy RdView was initiated at TERA, Nethesda, Maryland, during October 28 through November 4, 1985. A site inspection of QA program procedures was performed on October 20-24, 1985. Copies of reports for these activities will be placed in the Public Document Room upon completion. 5. CPRT Procedures and Instructions a. Implementation of ERC Procedures and Instructions (1) Audit of CPP-012 (OA/QC Interface with Constructor /TUGCO) The TUGC0 interface consists of three systems used to request j equipment or services, copies of documents, or technical ) information. Each is handled by a different process, as defined in CPP-012. (a) Written requests for equipment and services are used by the QA/QC inspectors to request from TUGC0 or B&R any equipment i' or services needed to perform an inspection. These requests'are included in the completed inspection package. An NRC inspection of CPP-012 implementation showed that the requests for equipment and services were being processed in i I
~x+~~. J I, accordance with CPP-012. requirements, with the' exception that the QA/QC Records Administrator was not controlling these requests as required by Section 4.4.6 of the procedure. No logs or files were maintained by the QA/QC' Records' Administrator. This item is an NRC deviation I (445/8514-D-01)..During this inspection, the NRC inspector concluded from information provided by ERC personnel that a log of requests was not being maintained by the QA/QC Inspection Supervisor, as required by Section 5.1.3 of CPP-012. Subsequent to this report period, the NRC was informed by ERC management that this understanding was incorrect and that the required log was, in fact, being maintained in accordance with CPP-012 requirements. Followup inspection confirmed that the ERC management-l information was correct. It was ascertained, however, during this followup. inspection that verification package numbers were being used to identify requests in the log. I This~ practice permits more than one request to have the same' identification number and is contrary to procedural requirements for use of unique identification numbers. .TUGCO has been requested by the transmittal letter for this inspection report to include this subject in their response to deviation 445/8514-0-01. (b) Document requests are used to request copies of TUGC0 or ~ i B&R documents required by'the ERC inspectors. Section 5.2.2 of CPP-012 requires that the QA/QC issue coordinators maintain a file of these requests. The files of two issue coordinators were inspected by the NRC, and found to be: satisfactory. No NRC deviations were identified. (c) Technical information requests are prepared by a member of the QA/QC Review Team when a request for clarification or additional information is required. These, after supervisory approval, are sent to the responsible TUGC0 liaison engineer by the QA/QC. Records Administrator, who also logs.and files the' requests. The logged, item is closed and the request filed when the information arrives from the TUGC0 liaison engineer. Two specific requests were traced by the NRC inspector through the Construction Sampling Reinspection Engineering Group and Records Administration, and found to have been satisfactorily processed and routed. No NRC deviations were identified.
a,;...., . (2) CPP-018(QA/QC Interface with the Desian Adequacy Proaram) An NRC inspection confirmed that documents transmitted from ERC to TERA for information only were transmitted by the QA/QC Records Administrator. Documents requiring feedback from TERA are logged and transmitted by the ERC Hardware Issues Supervisor. { The TERA Design Adequacy Program Interface Coordinator receives the ERC documents, distributes them and files one copy. Items requiring feedback to ERC are logged in and the date of reply is also logged. The NRC inspector selected four documents from the ERC log and was able to satisfactorily trace them through the ERC and TERA logging and filing systems. No NRC deviations were identified. (3) CPP-010 (Preparation of Deviation Reports) and CPP-016 (Safety Significance Evaluations of Deviation Reports) Deviation Reports (DRs) are generated during the hardware and documentation inspection process. These DRs are assessed for validity then forwarded for further processing to the Safety Significance Evaluation Group (SSEG) and TUGCO. j The NRC inspector confirmed that the process, which is described i in CPP-010 and CPP-016, is being followed. A sample of twenty DRs was selected from the SSEG tracking system. Each DR was verified to be correctly processed and documented by checking each for: (a) signatures of originator, first reviewer, and second reviewer; (b) transmission of the DR to TUGC0 and SSEG, (c) transmission of the DR to the proper distribution; (d) filing of the DR in the verification package; and (e) confirmation from TUGC0 or B&R that they had assigned an NCR number to the DR. Revision 3 to CPP-010, which was released on October 11, 1985, incorporates provisions for revision, cancellation, or invalidation of a DR. No NRC deviations were identified. (4) CPP-020 (Out-of-Scope Observations) 'l Review team personnel are instructed in CPP-020 to report apparent out-of-scope observations by three part memorandum to TUGCO. In the NRC inspection of this subject, it was determined j l that the ERC Supervisor, Hardware Collective Evaluation, j assigned a serial number on receipt of the three part memoranium [ and sent two of the copies to TUGCO. The remaining copy is filed and logged, with identification made of the record
receiving date, dats sent to TUGCO, and date of. TUGC0 feedback. Six memoranda were reviewed by the NRC inspector to verify implementation of this process. No NRC deviations were identified. (5) Inspection of ERC-QA-15 (Performance of Project Surveillance), ERC-QA-18 (Administration of Quality Assurance Auditina), and. ERC-QA-20 (Conduct of Programmatic Audits) The ERC Project Assurance Manager was contacted in an NRC inspection of these procedures. The following documents were produced: (a) surveillance plan for QA/QC Review Team dated ~ September 14, 1985; (b) surveillance status report dated October 21,'1985; and (c) a surveillance schedule. The Project Assurance Manager maintains an active file and status log of surveillance reports from the planning stage until the recommendations are implemented. The surveillance > reports are distributed to the corporate office, to the QA/QC Review Team Leader (RTL), the Hardware Issues Supervisor, and the organization being surveyed. The reports are maintained as open items until all recommendations are implemented. At that, time, the report files are closed and transmitted to the Records Administrator. The NRC inspector reviewed four surveillance reports of which three were closed (no deficient items) and one was still open with one deficiency being processed. Each report file contained a three part memo to the QA/QC RTL, a surveillance checklist report, and a surveillance checklist. No NRC deviations were identified. The NRC reviewed the first quarterly corporate audit of the CPRT activities. The audit was performed September 23 through 26, 1985, and the report was issued October 15, 1985. This corporate audit identified one deficiency. A response to the i audit was issued on October 21, 1985, providing corrective / preventive actions. The second quarterly audit is being planned at this time, but a specific date has not been
~~set, i~~
No NRC deviations were identified. b. TERA Procedures and Instructions TERA has issued 16 of the 19 planned design adequacy procedures (DAPs). Review of these procedures indicates that six apply, in 1 i
..i~, ,,p. .,c 4- .g. whole or part, to the'ISAPs defining TERA onsite activity -(civil-structural, mechanical, and miscellaneous). These are DAP-2, " Documentation.and Tracking of Issues and Discrepancies"; DAP-14, " Design Adequacy Program Records"; DAP-15, " Training and Qualification"; DAP-16 " Audits"; DAP-17, " Corrective Actions";'and DAP-19, " Processing and Review of.Information Between Quality of Construction, QA/QC Adequacy Program and Design Adequacy Program." .DAP-14 and DAP-15 were audited by the NRC inspector and found to comply with the applicable CPRT Policies and Guidelines. The NRC has inspected the implementation in this area and the results of implementation of DAP-2 'is reported in NRC Inspection Report No. 50-445/85-13; 50-446/85-09. DAP-16 and DAP-17 are applicable to the onsite TERA effort; however, these procedures are implemented by offsite personnel reporting to the Design' Adequacy Program Quality Assurance' Manager. This offsite TERA activity is being inspected and reported by the NRC Office of Inspection and Enforcement. DAP-19 applies to the information interfaces between the Design Adequacy Program and ERC Quality of. Construction and QA/QC Adequacy Program groups. This DAP was audited by the NRC inspector in conjunction'with the implementation audit of ERC Procedure CPP-018, as described in paragraph 5.a.(5) above. No NRC deviations were identified. c. Implementation of-CPRT Policies and Guidelines (1) Electrical Issues: The electrical issues in the ISAPs are the responsibility of one RTL. The CPRT Policies and Guidelines-establish the methods for accomplishing these tasks. i The purpose of the NRC inspection was to determine if the processing of the electrical issues complied with the requirements set by the CPRT Policies and Guidelines. The inspection covered four of the guidelines; i.e., (a) central and working files, (b) safety significance evaluations (SSEs), (c) developing sampling plans and random samples for TRT issues. l and (d) policy on testing and inspection personnel used in third i party verification activities. This report completes the NRC's initial inspection of programmatic implementation in the area of electrical issues, j I l l
.;i a. . (a) Workina Files: The working files system and subject matter breakcown being used is as described in the CPRT l guidelines. A file index is available for each ISAP which defines the contents of each file folder. A computer based data system is being established for these files. Two files were checked for compliance with the CPRT Policies .g and Guidelines. No NRC deviations were identified. (b) SSE: The NRC inspector reviewed the processing of ISAP No. I,b.1 that resulted in one item which will require a SSE. This SSE will be included in the review process for all SSEs generated by the CPRT. No NRC deviations were identified. (c) Sampling Plan: The sampling plan used on ISAP No. I.a.1 was reviewed by the NRC inspector. It complied with the guidelines and was well documented. Inspection confirmed that the information on the random sampling selection was turned over to ERC, who prepared the inspection packages, performed tile inspections, wrote inspection reports (irs) for satisfactory and unsatisfactory conditions, and after checking and signoff by two levels of supervision transmitted the irs to the electrical issues RTL. The RTL sent unsatisfactory irs to TUGCO, who evaluated the irs and sent a memorandum back detailing the disposition of each IR. NCRs were written by TUGC0 on those where discrepancies existed. Memoranda were sent explaining why ecch of the remainder were not considered as discrepancies. The NRC inspector also reviewed implementation of the random sampling system used for ISAP Nos. I.a.2 and I.a.3. No NRC deviations were identified. (d) Personnel Requirements: Qualification requirements for RTLs and issue coordinators are defined in Section VII of the CPRT Program Plan, "CPRT Objectivity Guidance." The primary requirements are: (i) experience and knowledge in the review subject matter, (ii) experience in managing technical projects and reviews, and (iii) integrity and objectivity based on lack of previous involvement in the CPSES project activities. we
no t .Q-y jp- - j The. resumes and signed objectivity statements for the principal individuals. involved in the electrical issues were reviewed. j l No NRC deviations were identified. (2) Testina Issues: The purpose of the NRC inspection was to determine if the disposition of testing concerns complied with the CPRT Policies and Guidelines. The four guidelines discussed-in' paragraph 5.c.(1) above were used to' perform this inspection. This report completes the NRC's initial. inspection of programmatic implementation in this. area. (a) Workina Files: The' file system and subject matter breakdown in use were reviewed. A file index was available for each ISAP which defined the contents of the file, folder. The file index was checked against the contents of l the file for these files. NoNRCdeviationswereidentifjed. (b) SSE:.One DR has been written and an SSE completed. The N E inspector reviewed the processing of this DR. No NRC deviations were' identified. (c). Samplina Plan: The sampling plan described in the program plan was not found to be feasible, so an alternate plan was developed.- This revised plan was described in an appendix to the results report. This-practice is permitted by Appendix D of the CPRT Program Plan. No NRC deviations were identified during a review of the original and revised sampling plans. (d) Personnel Requirements: The resumes and signed objectivity statements for-the RTL and each of the three issue coordinators were reviewed. 'No additional NRC deviations to that noted in NRC Inspection Report No. 50-445/85-11, 50-446/85-06 were identified. i . P.! cf --1 -a
a. + [ l 6.. CPRT ISAPs (Excluding ISAP No. VII.c)' J a. Inspection Reports on Butt Splices (ISAP No. I.a.2) and Butt Splice Qualification (ISAP No. I.a.3)- ' Status of CPRT Activity e1 Phase II of ISAP No. I.a.2 has been completed with the following 'j findings: -) j (1) No undocumented butt splices were identified during the j inspection of 38 cabinets which were supposed to be free of J splices;- j (2) A total of 603 butt splices were identified during the l inspection of 26 cabinets and 25 motor control centers, which from documentation were supposed to contain 648 splices. This difference resulted because 149 of the documented splices were 1 not installed,'but 104 undocumented splices were discovbred; (3) A total of 168 of the above'603 butt splices were found to be unsatisfactory, either by physical inspection or as a result of being undocumented; (4)' A total of 80 unsatisfactory butt splices were removed for testing and replaced; and-(5) A review was performed of 341 irs which were applicable to 286 butt spliced cables. This review identified deficiencies in 294 irs; e.g., failure to identify which conductors were spliced, and after the fact verification of a splice rather than the required witness. In addition to finding some unacceptable splices during the Phase II inspections, some~ splices documented in records were found to not be installed. TUGC0 submitted a report in accordance with 10 CFR Part 50.55(e) dated' September 26, 1985, concerning the identified deficiencies. An interim Corrective Action Report, CAR-050, has been issued. f Status of NRC Inspection Activity 1 The NRC inspector is continuing to review CPRT ISAP Nos.I.a.2, Revision 3; I.a.3, Revision 3; and CPRT Quality Instruction (QI) QI-002, Revision.4. No WRC 'iolations or deviations were identified. l l b. Electric.ol Conduit Supports (ISAP No. I.c) State CPRT Activity l TUGC0 completed an engineering check of as-built drawings for 257 and 2-inch conduit runs in the combined random and 1 1;
engineered samples; i.e., 126 random and 131 engineered. These drawings have been transmitted to TERA for third party review and to G&H for seismic analysis. Seismic analysis has been comp 1,eted for all runs in the random sample and for 128 runs in the engineered sample. Fifteen conduit runs have been identified, to date, as having the potential for interaction with safety-related components. TUGC0 has initiated a dynamic test program at Corporate Consulting and Development (CCL) in North Carolina. The dynamic testing will provide actual strengths as compared to the previously used predicted values. TUGC0 will also conduct a damage study walkdown of all conduit runs currently determined to have potential interactions with safety-related components. Evaluation ce po'tential interactions for safety significance will utilize preestaoiished criteria to be specified in a walkdown procedure. This procedure is currently being prepared by Ebasco. Third party review of the Unit 1 damage study resolution for greater than 2-inch conduit in Train C is being addressed in ISAP No. II.d. Status of NRC Inspection Activity A preliminary review of the Unit 1.large conduit damage study procedure and related as-built drawings has been conducted. Resolution of interactions predicted in this study will be reviewed as part of the NRC inspection program for ISAP No II.d. A review of the CCL test procedure has been conducted. No NRC violations or deviations were identified. c. QC Inspector Qualifications (ISAP No. I.d.1) Status of CPRT Activity Phase II evaluation of ASME inspector qualifications has not been completed. Status of non-ASME inspector qualifications was sent to the TUGC0 QC Manager by ERC Letter QA/QC-RT-681 on October 4,1985. Further review by the Special Evaluation Team (SET) has resulted in i some changes to the original transmittal. Reinspection is underway for a seventh inspector placed into Phase III. Package preparation is complete for an eighth inspector. Status of NRC Inspection Activity During this reporting period, the NRC inspector witnessed 24 Phase III reinspection conducted by ERC inspectors and also performed 10 reinspection independent of ERC personnel. No 1 deficiencies were iiantVied in these reinspection by either ERC l inspectors or the !!P.C inspector. L
s.
l A concern that the reinspection attributes were very basic in nature and may not have accurately reflected the work performed originally by the project inspector was reviewed with the issue coordinator.
This review found that the reinspection did reflect the activity associated with the inspector's earlier certifications. No NRC violations or deviations were identified. d. Guidelines for Administration of QC Inspector Tests (ISAP No. I.d.2) Status of CPRT Activity The SET has completed review of prior revisions to TUGC0 Procedure CP-QP-2.1, " Training of Inspector Personnel." Comments from their review have been given to the QA/QC RTL and presented to TUGC0 for resolution and/or incorporation into CP-QP-2.1. Revision 19 to CP-QP-2.1 was issued October 4,1985, and incorporates these comments. Inspector certification examinations have also been revised to meet the requirements of Revision 19 of CP-QP-2.1. Review of B&R Procedure ECP-19, " Exposed Conduit / Junction Box and Hanger Fabrication and Installation," and other procedures affecting craft training will be conducted under ISAP No I.d.3. This issue was previously included in ISAP No. I.d.2. States of NRC Inspection Activity The NRC inspector reviewed Procedure CP-QP-2.1, Revisions 18 and 19, to determine if concerns of the NRC Technical Review Team (TRT) were satisfactorily addressed. Revision 19 of CP-QP-2.1 was found to-address the TRT concerns noted in ISAP No. I.d.2, including inspector r familiarization or training for changes in QC inspection procedures. This action closes open item 445/8513-0-06. The NRC inspector reviewed five recently administered QC inspector examinations. These were found to comply with the requirements of CP-QP-2.1 for written examinations. No NRC violations or deviations were identified. e. Inspection for Certain Types of Skewed Welds in NF Supports (ISAP No. V.a) j Status of CPRT Activity Reinspection of the random sample of 60 ASME Section III, Subsection l NF pipe supports containing 99 type 2 skewed welds has been completed. Disposition of the 12 TUGC0 NCRs associated with the undersize type 2 skewed field welds has not been made.
n d 1 - Status of NRC Inspection Activity L The NRC inspector witnessed a total of nine reinspection and performed three independent' inspections of HF supports containing type 2 skewed welds. The results of NRC Region I inspections of 3 skewed welds are documented in NRC Inspection Report i No. 50-445/85-13; 50-446/85-09. The planned NRC physical inspections 1 for this ISAP have now been completed.. NRC evaluation of TUGCO's dispositions of 12 undersize type 2 skewed field welds is dependent upon the processing of the associated NCRs. This remains an open item (445/8511-0-04). One violation was identified in this subject area which is identified in paragraph 2.a of this appendix. f. Plua Welds (ISAp No. V.d) J Status of CPRT Activity J ~ Reinspection has been completed for the presence of plug welds in two . random samples of cable tray hangers, consisting of 60 frsm Unit 1 and 61 from Unit 2. The reinspection resulted in the identification i of 23 plug welds in 14 cable tray hangers. Documentation was reviewed for all cable tray hangers containing plug welds. The results of this review showed that all of the plug welds were authorized and documented. Due to a mix of non-ASME' component supports 4 with ASME Section III NF component supports in the two original random samples (see item A, Notice of Deviation, NRC Inspection Report No. 50-445/85-13,50-446/85-09), a new random sample of 57 NF component supports has been created and reinspection has been initiated. 1 Status of NRC Inspection Activity .The NRC inspector witnessed 23 reinspection and performed 6 independent inspections of cable tray hangers. With respect to NF component supports, the NRC inspector has witnessed a total of 23 reinspection and performed a total of 4 independent inspections. Eight of the witnessed reinspection and one independent inspection occurred in this report period and were from the new random sample. l - Indications of possible plug welds were identified in two component support base plates during the witnessed inspections. The NRC inspector will witness the macroetching and inspection of these baseplates to determine whether or not plug welds exist. No NRC violations or deviations were identified. I l i
i g. Installation of Main Steam Pipes (ISAP No. V.e) Status of CPRT Activity The specific engi.neering investigation of the main steam line installation is complete and is undergoing review. The report describing the analytical evaluation of stresses and support load changes has been issued by R. L. Cloud & Associates (RLCA) and has been reviewed by TERA. Review and revision of pipe procedures for pipe erection and placement.of temporary and permanent supports, as well as engineering significance of these procedures, is also complete. The TERA draft results report is still being reviewed. Status of NRC Inspection Activity The RLCA report addressing the installation of main steam pipes has been reviewed for adequacy with respect to the methods of analysis. The review included supporting computer output, calculations, piping models, and, assumptions made. During this review the following conditions were noted: (1) While the use of a "come-along" for horizontal adjustment is mentioned in Section 1.3, " Additional Background,'! it is not addressed in the analytical portion of the report. (2) The 18-inch bypass line is modelled in as a schedule 60 pipe, but drawing FSM-00165 specifies a schedule 40 pipe. Documentation was not available to substantiate that a schedule 60 pipe was used. Even though the schedule 60 piping is conservative as far as stress is concerned, it will have some impact on other conclusions made in the report such as vertical displacements. (3) Figure 3-12 in the analysis does not represent computer output No. RLCA P142-1-551-018, in that the node numbers do not correspond. i (4) The NRC TRT identified that sagging occurred during flushing operations. RLCA states that sagging occurred before flushing. 1 The date of the flushing should be established. The above conditions constitute an unresolved item (445/8514-U-13). No NRC violations or deviations were identified. l l l \\ j r
, h. Material Traceability (ISAP No. VII.a.1) Status of CPRT Activity The issue coordinator is receiving input from ISAP Nos. VII.c and VII.b.3. This information aids in the assessment of the overall material traceability control systems. Heat numbers on steel items such as supports and piping are being checked as part of the reinspection to establish traceability. Status of NRC Inspection Activity The NRC inspector has reviewed ISAP No. VII.a.1. This review found that the overall material traceability control system was to be i evaluated for adequacy. Preliminary results of ISAP No. VII.c reinspection indicate that data on material traceability in areas other than steel is not being compiled. This lack of data could adversely affect the assessment of the material traceability control l systems. This matter is considered to be an unresolved item (445/8514-U-14). No NRC violations or deviations were identified. i. Housekeeping and System Cleanliness (ISAP No. VII.a.7) Status of CPRT Activity This ISAP addresses two specific TRT concerns and performs an overview of the program on housekeeping and system cleanliness. Eleven plant surveys conducted by TUGC0 and overviewed by ERC inspectors have been completed. The issue coordinator has reviewed the procedural controls to determine if requirements of Criterion XIII of Appendix B to 10 CFR Part 50 and the FSAR are included. Inputs from ISAP Nos. II.c, V.b, VI.a, and recent TUGC0/B&R audit reports, surveys, and other quality documents are being reviewed to evaluate the effectiveness of the current program. Specific TRT concern on the number of chloride residue swipes made on the wall and bottom of the reactor vessel has been investigated. The procedure controlling this activity required two swipes to be made, but the file documentation shows that eight swipes were made and found acceptable. Flush plan FP-55-08, the controlling procedure, is a specific one-time procedure. Therefore, no revision to this procedure is being made. Comments on the adequacy of the number of swipes made will be in the results report. Specific TRT concern on lack of protective covering on equipment near welding activities will be addressed by reviewing the results of plant surveys.
1 L L L ] l Status of NRC Inspection Activity j 1 1 The NRC inspector has witnessed plant surveys of the safeguards d building, Unit 2 reactor area, mi11 wright shop, and ironworkers shop. During these surveys, items such as trash or unidentified material j were found in laydown areas where Quality (Q) material was stored. o 1 These items were noted by TUGC0 and ERC personnel. An independent NRC resurvey of these areas found that the noted discrepant i conditions had been restored to requirements. The NRC inspector reviewed the file for FP-55-08 to verify that the eight chloride residue swipes had been taken for the reactor vessel wall and bottom. These swipes were found to be documented as performed and acceptable. In addition, numerous swipes had been taken on reactor internals and the hot and cold legs. These were also acceptable. No NRC violations or deviations were identified. j. Valve Disassembly (ISAP No. VII.b.2) -Status of CpRT Activity A second reinspection of seven Borg-Warner (B-W) valves was conducted using B-W serial numbers for body and bonnet identification. This reinspection was necessitated by the fact that identification numbers used in the initial reinspection were traceable to material heat numbers, but were not necessarily unique to each valve bonnet or body. No DRs were issued as a result of the second reinspection. All reinspection are now complete. Of a total of four valid DRs issued for this ISAP, three SSEs have been completed. The fourth DR 1 (VALV-9-1) identifies a mismatch between the identification numbers I I i observed on the valve bonnet and that which is listed in the QA/QC documentation package for the valve. QA/QC documentation for the actual installed bonnet has not been located to date. A difference was identified by the SSE engineer between the respective design temperature and pressure listed by G&H and those listed by Westinghouse for the Chemical Volume Control' system. Specifically,theg&Hlinedesignationtableliststhedesign l temperature as 250 F and the design pressure as 300 psi, while the correspondingWestinghousedgsigntemperatureandpressureare listed, respectively, as 150 F and 150 psi. l The NRC inspector was informed by the SSE engineer that disposition i of the remaining SSE is pending receipt of information from TUGC0 regarding valve temperature / pressure ratings and TUGC0 resolution of the above described difference in design conditions. 1
s. . Status of NRC Inspection Activity A total of eight reinspection have been witnessed by the NRC inspector, one of which was a reinspection of a B-W valve during this report period. Independent NRC inspe:tions have also been performed on five valves in the combined random and engineering samples. The NRC inspector was informed by TUGC0 Field Mechanical Engineering personnel that: (1) the previously described differences between G&H and Westinghouse design conditions had also been identified by TUGCO, i and (2) a comparisen of G&H and Westinghouse design conditions for mechanical equipment had been conducted by TUGC0 which resulted in s the identification of several design pressure and temperature differences. The 14RC inspector also noted that NCRs have been written by TUGC0 for several valves having temperature and/or pressure ratings listed on I the Code Data Log that are different from those listed in the G&H line designation table. It was not immediately apparent whether or not the Westinghouse /G&H comparison study had also identified these differences. Verification of the adequate resolution of differences identified in the Westinghouse /G&H comparison study and those identified in NCRs is considered unresolved and will be evaluated further during a subsequent reporting period (445/8514-U-15). No NRC violations or deviations were identified. 7. ISAP'No. VII.,c a. Electrical Cable 1 Status of CPRT Activitv ERC has completed 85 reinspection and 71 documentation reviews of sampled electrical cable as of October 30, 1985. Status of NRC Inspection Activity (1) The following eight ERC reinspection of sampled electrical cable were witnessed by the NRC during this report period: 'l Verification Package No. Cable No. I-E-CABL-078 EG113538 I-E-CABL-084 EG104608 I I
f .c L I-E-CAB L-086 E0121816Z 4 I-E-CABL-088 Es124088 I-E-CABL-089 EG123639Z I-E-CABL-098 Es145694 I-E-CABL-101 E8122951 I-E-CABL-102 EG139519 (2)' During the above reinspecticas, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations: (a): I-E-CAEL-037: Two through-the-wall sleeves had identical identification tag number TWS-E-010. The cable run also deviated from the cabic run schedule. 4 (b) I E-CABL-084: Cable run deviated from the cable run schedule and cable was routed through C13G06325 instead of C13G06324. (c) 1-E-CABL-098: There was no identification tag on the conduit nipple. Cable E0145694 was found to not have the required 2 inches of slack in free air as it exited conduit C13816044 into cable tray. A hold tag with NCR E85-101141SX had been placed on the conduit as a result of a prior inspection identifying the same condition. Dispositions of the above findings are open items (445/8514-0-03 through 445/8514-0-05). (3) ERC also noted the following deficiencies outside the defined inspection scope: I-E-CABL-086: Conduit was 1 1/2 inches instead of the 2-inch I I size specified and a loose conduit coupling was noted where conduit penetrated a wall. Dispositions of the above findings are an open item (445/8514-0-06). (4) NRC inspectors did not identify any additional discrepancies with respect to the above eight packages. i I
.Q so . h5) Independent documentation reviews were performed of 10 verification packages comprising 22 cables. The results of the independent reviews are an open item pending NRC review of ERC results (445/8514-0-07). (6) The NRC inspector noted that NCRs have been written by TUGC0 QA/QC personnel in regard to potential electrical cable damage resulting from installation practices used for cable support grips. TUGCO. engineering has provided information to assist in the disposition of the NCRs. This matter is considered unresolved pending review of supplemental information from TUGC0 and will be evaluated further in a subsequent report (445/8514-U-16). b. Cable Trays Status of CPRT Activity ERC has completed 84 reinspection and 78 documentation reviews of sampled cable trays as of October 30, 1985. Status of NRC Inspection Activity (1) The following two ERC reinspection of sampled cable trays were witnessed by the NRC in this report period: verification Package No. Cable Tray No. I-E-CATY-201 T220SBC89 I-E-CATY-247 TBGCCM62 No deficiencies were noted by ERC or NRC inspectors during these inspections. (2) The NRC performed independent reinspection of two electrical cable trays. The results of these inspections are open items pending NRC review of ERC inspection results and documentation reviews (445/8514-0-08) and (446/8511-0-12). (3) The NRC performed independent documentation reviews of seven verification packages for seven cable trays. The results of these reviews are an open item pending NRC review of ERC review results (445/8514-0-09). No NRC violations or deviations were identified. l )
. c. Electrical Conduit Status of CPRT Activity ERC has completed 79 reinspection and 76 documentation reviews of sampled electrical conduit as of October 30, 1985. Status of NRC Inspection Activity (1) The following two ERC reinspection of sampled electrical conduit were witnessed by the NRC in this reporting period: Verification Package No. Conduit No. I-E-CDUT-089 C13G07757 I-E-CDUT-098 C12020693 No deficiencies were noted by ERC or NRC inspectors during these inspections. (2) The NRC inspectors per#ormed independent documentation reviews of the following verification packages for sampled electrical i conduits: Verification Package No. Conduit No. R-E-COUT-007 C13010190 R-E-CDUT-051 EAB1-1 R-E-CDUT-064 C13016037 R-E-CDUT-070 C14R13047 R-E-CDUT-076 C12008750 R-E-CDUT-077 C13005532 R-E-CDUT-086 C13030044 R-E-CDUT-089 C13G07757 R-E-CDUT-098 C12020693 During the above documentation reviews the NRC inspectors observed the following deficiencies: (a) Lighting conduit EAB1-1 was physically reinspected by ERC and witnested by NRC. ERC subsequently discarded this item from the sample of conduit population, because not enough attributes were accessible for inspection. The NRC inspector performed an independent documentation review of j this field witnessed activity and noted that the TUGC0 electrical inspector, who signed the final irs E-1-0027419 and E-1-0024951 for conduit EAB1-1, was not certified to Procedure QI-QP-11.3-25. TUGC0 Procedures CP-QP-2.1 and QI-QP-2,1 : ' require that insp5ction personnel be certified i
s . for a given inspection function / activity as being qualified to perform their assigned tasks. The lack of certification of the TUGC0 electrical inspector performing the inspection of record for conduit EAB1-1 is a violation (445/8514-V-04). (b) ISAP No. VII.c requires original documentation review for attributes deemed to be inaccessible. A portion of conduit C13016037 was found to be inaccessible during reinspection as a result of being covered with separation barrier material (SBM). There was no evidence in ERC's Verification Package No. R-E-CDUT-064 that a check was made for attributes which were not accessible due to SBM installation. This is an NRC deviation (445/8514-D-02). (c) QI-009, Revision 0, " Document Review of' Conduit /R-E-CDUT," requires the reviewer to record the SBM IR and/or latest construction operation traveler number at the bottom of the . checklist. The checklist for conduit C13016037 in Verification Package No. R-E-CDUT-064 did not contain this required documentation. This item is an NRC deviation (445/8514-D-03). (d) QI-009, Revision 0, " Document Review of Conduit /R-E-CDUT," also requires the ERC inspector to verify that irs signed by electrical inspectors were " dated after their date of certification and prior to their date of expiration." ERC Verification Package No. R-E-CDUT-070 for conduit C14R13047 failed to indicate that the ERC inspector observed that the electrical inspector signing IR-E-46087 was not certified to QI-QP-11.3-23 on the date of inspection. This item is an NRC deviation (445/8514-D-03). (e) During this review, the NRC inspector observed that TUGC0 inspection procedures (i.e., QI-QP-11.3-23 and QI-QP-11.3-23.11) for conduit did not require inspection for separation between approximately September 1979 and November 1983. The NRC inspector was informed that a j decision was made to inspect conduit for separation after construction completion, on a room-by-room basis. The NRC inspector was also informed that this activity is prescribed in QI-QP-11.3-29 and that documentary evidence is available in the Permanent Plant Records Vault (PPRV), l filed by area or room " turn-over" numbers. This item is considered unresolved pending review of this documentation (445/8514-U-17). I l i
o (f) The NRC inspector' observed during documentation review of conduit C13916037 that the ERC inspector did not review construction operation traveler EE83-0997-8904 for other than inspector certification and correct QI reference on the traveler. It was also noted that construction operation travelers EE84-10324-8904, EE84-10505-8904, and EE85-11255-8904, in response to Item Removal Notices (IRNs) for SBM removal and replacement, were not reviewed r ascertain the certification status of any additional inspectors that had been used to those that signed the applicable irs. This item is unresolved pending NRC review i of construction operation traveler documentation in the PPRV (445/8514-U-18). (g) The NRC inspector reviewed documentation for six other conduits. ERC reviews were scheduled but had not been completed. The results of these reviews will be reported in a subsequent report after comparison of NRC review results with the completed ERC results. This is an open item (445/8514-0-10). (h) The NRC inspector observed that documentation reviews for lighting conduits could not be performed by ERC because QI-009, Revision 0, does not address the relevant QIs; i.e., QI-QP-11.3-25 and QI-QP-11.3-9. This is an open item pending the issuance of new instructions or a subsequent revision to QI-009 (445/8514-0-11). d. Electrical Equipment Installation Status of CPRT Activity ERC has completed 20 reinspection and 19 documentation reviews of sampled electrical equipment installations as of October 30, 1985. This reinspection total is lower than the number (i.e.,21) reported in NRC Inspection Report No. 50-445/85-13, 50-446/85-09 as being performed by September 20, 1985. The difference arose as a result of revision to QI-010 and institution of re-review of previously completed packages for compliance to the revised QI. Status of NRC Inspection Activity (1) The following ERC reinspection of sampled electrical equipment installation was witnessed by the NRC: { l q a L
. Verification Package No. Equipment No. I-E-EEIN-059 CP1-ECDPEC-12 No deficiencies were noted by ERC or NRC inspectors during this inspection. (2) The NRC performed an independent documentation review of one sampled electrical equipment installation. The results of this review are an open item pending comparison with ERC results when available (445/8514-0-12). No NRC violations or deviations were identified. e. Instrumentation Equipment Installation Status of CPRT Activity ERC has completed 75 reinspection and 75 documentation reviews of sampled instrumentation equipment installations as of October 30, 1985. Status of NRC Inspection Activity (1) To date, eight reinspection have been witnessed by NRC inspectors with the following five reinspection witnessed in this report period: Verification Package No. Unit No. I-E-ININ-072 1 I-E-ININ-079 1 I-E-ININ-069 1 I-E-ININ-076 1 I-E-ININ-066 1 (2) During the above reinspection, ERC identified the following conditions as subject to evaluation as potential deviations: I-E-ININ-072: (a) G&H Specification 2323-MS-625 and QI-012, Revision 0, require a slope for process wetted lines of 1 inch per foot minimum, except that where physical layout is a problem the minimum slope may be reduced to 1/4 inch per foot. The tubing line from the root valve to the instrument was found to only have a slope of 1/2 inch on 9 inches and physical layout did not appear to be a problem. (b) Drawing 2323-M1-2613, Revision 2, shows instrument 1-P15-4251 as being located 6 feet 0 inches off the
~ .o. . -This instrument was actually located 5 feet 0 inches off the wall. I-E-ININ-079: The tubing line from the component cooling water pump 1A to instrument 1-PT-4520 had reverse slope where it passed under the discharge line. I-E-ININ-066: Required color code was missing and maximum allowable distance between color code marks was exceeded. I-E-ININ-069: Sending units 1-LS-6712 and 1-LS-6717 were found to be reversed. Dispositions of the above findings are open items (445/8514-0-13 through 445/8514-0-16). No NRC violations or deviations were identified, (3) ERC also noted the following deficiency outside of theidefined inspection scope: I-E-ININ-079: C1413591 was damaged at the connection to the instrument 1-PT-4520. Disposition of the above finding is an open item (445/8514-0-17). No NRC violations or deviations were identified. (4) The following independent documentation reviews of sampled instrumentation equipment installations were made by the NRC inspectors: Verification Package No. Instrument No. R-E-ININ-005 1-LS-4795 R-E-ININ-060 1-LS-3376 (a) During the review of these packages, the NRC inspector noted that the procedure used (i.e., QI-013, Revision 4) did not provide detailed instructions for checking original documentation for attributes which were inaccessible or nonrecreatable during the physical inspections of these instrument installations. According to paragraph 4.1 of ISAP No. VII.c, Revision 0, documentation reviews will be utilized to supplement reinspection for attributes which are nonrecreatable or inaccessible. Paragraph 4.1.3 of the same ISAP reouires procedures to have detailed instructions
q . for the document reviewers. QI-013, Revision 4, "Docume'ntation Review for Instrumentation Equip R-E-ININ," did not list specific attributes to be verified during documentation review, but rathe'r required verification of installation in accordance with one or more of a listing of TUGC0 procedures. Applicable procedure revisions were not defined. The number of inaccessible and/or nonrecreatable attributes may vary between different revisions of a procedure. As an example, Revision 1 of QI-QP-11.8-8 adds to Revision 0 requirements an inspection checklist addressing verification of: (i) color codes for nuts; (ii) flange face cleanliness; (iii) gasket size, rating, and material type; (iv) nuts being tightened in a diametrically opposite sequence; (v) studs being the same length; (vi) proper alignment and fitup of flange and gasket; and (vii) sufficient gasket compression. The absence of instructions to the document reviewer on procedure revisions to be used can thus result in insufficient guidance with respect to inaccessible and nonrecreatable attributes. This is ca NRC deviation (445/8514-D-02). (b) In the review of Verification Package No. R-E-ININ-060, the NRC inspector noted that the original inspection was performed by a TUGC0 inspector whose certification to QI-QP-11.8-7 could not be verified. TUGC0 is currently investigating the missing certification documents. This matter is an unresolved item (445/8514-U-19). (5) Independent reinspection were performed by the NRC inspector on Verification Package Nos. I-E-ININ-04 and I-E-ININ-026, with the following results: I-E-ININ-04: Required bend radius verification was not performed by ERC inspectors. I-E-ININ-026: ERC inspectors did not identify that: (a) required color coding on six sections was missing, (b) incorrect slope was present, and (c) an incorrect air gap condition was present. The failure of ERC inspectors to identify the above conditions is an NRC deviation (445/8514-D-04). f. HVAC Ducts and Plenums Status of CPRT Activity l-1 As of October 25, 1985, reinspection have been completed for 62 of I 95 random items in the HVAC ducts and plenums samples. The I
g. ~ . reinspection have identified conditions which necessitated the issuance of 75 DRs, 38 of which have been validated. Twelve DRs have - been evaluated by ERC and were found to be nonsafety significant. A number of deviations dealt with companion angle welds and include insufficient weld length, undersized welds, excessive stitch weld spacing, weld cracks, and incomplete weld fusion. Other deviations involved seal weld undercuts, lack of full face connecting flange / gasket contact, level 3 flanged joint installed instead of the specified level 2 (as defined by G&H specification 2323-MS-85), loose vent lock caps, level 2 construction instead of the specified level 3, lock washers not installed on vent lock mounting screws, deteriorating connecting flange gasket, and seal weld not touched up with paint. Status of NRC Inspection Activity (1) ERC methods and related documents used in establishing the population items list were reviewed for population inclusiveness. Completed SSE reports are currently being reviewed by the NRC inspector. As of October 25, 1985, eignt reinspection have been witnessed by the NRC inspector, of which i the following four were witnessed during this report period and are listed below by Verification Package No.: Verification Package No. Unit No. I-M-DUPL-021 1 I-M-DUPL-073 1 I-M-DUPL-084 2 I-M-DUPL-086 1 (2) During the above reinspection, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations: I-M-DUPL-021: Some duct connecting flange bolts were bent. No corner welds existed on duct connecting flanges and a connecting flange bolt hole was excessively large. I-M-DUPL-073: All vent lock caps were loose and companion angle bolt hole center-to-center distance was excessive on both ends of the duct section. I-M-DUPL-084: Duct connecting flange corner weld lengths were less than the specified dimension.
j, o i I-M-DUPL-086: Approximately 4 inches of duct seam were not I welded. Dispositions of the above findings are open items (445/8514-0-18 and 445/8514-0-19, 446/8511-0-03, and 445/8514-0-20). l (3) The following potential out-of-scepe deviation was also j identified by ERC: 4 I-M-DUPL-073: An additional hole was drilled in the companion angle flange and this hole was partially filled with sealant. Disposition of the above finding is an open item (445/8514-0-21). (4) For all witnassed reinspection, the ERC inspector did not I measure duct gage thickness which was a required attribute. The NRC inspector was informed by ERC that such measurements were i not possible due to inaccessibility.to the inside of the duct. The NRC inspector concurred with this position. + No NRC violations or deviations were identified. g. HVAC Equipment Installation i Status of CPRT Activity I As of October 25, 1985, reinspection have been completed for 38 of 89 random items in the HVAC equipment installation samples. The reinspection have identified conditions which necessitated the issuance of 68 DRs, none of which have been currently validated. Reinspection was on hold for approximately one week, pending a change notice to QI-023, Revision 0. This change notice involved changes in the following areas: (1) the method of verifying companion flange bolt tightness and gasket compression, (2) inclusion of verification of full thread engagement between companion flange bolts and nuts, (3) companion flange bolt centerline to flange edge distance requirements, and (4) the method of certification of gravity damper counterweight balance. Previously reinspected items will require a followup reinspection, where applicable, as a result of this revision. The NRC inspector was informed by the population engineer that the HVAC equipment installation plan will be revised to incorporate two distinct populations, each requiring a minimum sample size of 60. One population will include all HVAC equipment installed by Bahnson ,' ~ Services, Inc., while the others will include all HVAC equipment 'E installed by B&R. This change will not necessarily invalidate any i t
.s, . reinspection conducted to date, but could effectively double the total number of items to be reinspected in the initial sample. Status of NRC Inspection Activity-(1) As of October 25, 1985, a total of four reinspection have been witnessed by the NRC inspector, all of which were witnessed du.'ing this report period and are listed below: Verification Package No. Unit No. f I-M-HVIN-017 1 I-M-HVIN-038 2 I I-M-HVIN-040 1 I-M-HVIN-043 1 (2) During the above reinspection, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations: I-M-HVIN-017 (Filter): Three bolts on the inlet duct connection did not have lock washers installed. I-M-HVIN-038 (Fan): (a) The exhaust flange gasket did not cover the entire flange area, (b) the gasket was also unevenly compressed, and (c) some lockwashers on exhaust connecting flange bolts did not have full contact with the flange. Similar conditions were identified by the ERC inspector for the inlet duct connection. I-M-HVIN-040 (Fan): (a) Inlet and outlet duct connection gaskets had low and uneven compression, (b) diameters for foundation anchor bolts and duct connection bolts were illegible in drawings provided in the inspection package, and (c) exhaust duct connection bolts did not have full thread engagement with nuts. I-M-HVIN-043 (Motor Operated Damper): (a) A nameplate was not observed on the equipment, and (b) the actuator sp, ring could not be located which is required for verification of fail closed or fail open positions. Dispositions of the above findings are open items (?45/8514-0-22, 446/8511-0-04, 445/8514-0-23 and 445/8514-0-24). (3)"'h.a following potential out-of-scope deviation was also nntified by ERC:
p,j 4 1 1 I-M-HVIN-043: Some of the bolts attaching the actuator to the mounting bracket did not have full thread engagement. ' Disposition of'the above finding is an.open item -(445/8514-0-25). No NRC violations or deviations were identified. h. Larce Bore Pipina Configuration Status of CPRT Activity As of October 25, 1985, reinspection was complete for 65 of the-99 random sample large bore piping configuration items. The i reinspection identified conditions which resulted in the issuance of 34 DRs, 18 of which, to date, have been validated and are undergoing an evaluation by.ERC for safety significance. ~ ~ The NRC inspector was informed by the population engineer that the population items' list is currently being. revised to exclude all items not having an "N-5" designation on the piping isometric drawings. One exception will be certain safety-related piping in Unit 1 that has been exempted from "NA" code stamping requirements. The NRC inspector was informed that the above described revision to the population items list is required in order to ensure.that all CPRT. reinspection items had been previously inspected and accepted by construction QC. Approximately 24 previously reinspected items will 'be excluded from the reinspection samples as a result of this revision. Deviations have involved incorrect flow direction orientation of an orifice plate, insufficient clearance with adjacent piping and equipment, a different part number on a valve to that shown on the isometric drawing, linear and location measurement differences, insufficient sleeve clearances, missing code data plate, and flow-direction not marked on the valve. Status of NRC Inspection Activity ERC methods and related documents used in establishing the population items list were reviewed for population inclusiveness. Completed SSE reports are currcntly being reviewed by the NRC inspector. As of October 25, 1985, four reinspection have been witnessed by the NRC inspector, with fly! following verification package reinspection being witnessed during fnis report period: i l j
,e . I-M-LBCO-113 (Unit' 2): During this reinspection, ERC identified one-condition as subject to evaluation as a potential deviation, i.e., flanges that were identified as orifice flanges'on the isometric drawing did not have an identification tag or flow direction indication. Disposition of the above finding is an open item (446/8511-0-05). No NRC violations or deviations were identified. i. Pipino System Bolted Joints / Materials ERC has completed 73 reinspection of piping system bolted joints / materials as.of October 26, 1985. However, on eight of these reinspection the attribute dealing with flange rating could not be inspected because the flange ~was painted.- The paint will be~ scraped off the eight flanges, thus allowing this attribute to be reinspected. ERC has also completed document reviews on 14 of the 73 packages. The 73 packages represent 100% of the combined random and engineering samples. Status of NRC Inspection Activity (1) The following ERC reinspection was independently inspected by l the NRC inspector: Verification Package No. Drawing No. Flange No. Unit No. I-M-PBOM-34 BRP-SI-1-RB-048 1 1 With respect to the above inspection, the NRC inspector concurred'with the ERC inspector's finding that the flange type j was not hardstamped on the flange as required by the inspection procedure, and.that this condition is subject to evaluation as a potential deviation. Subsequently, the inspection procedure was revised to allow inspectors to visually identify the type of ( flange if it is not hardstamped with such information. The q above will be reinspected by ERC for this particular attribute. .J j No NRC violations or deviations were identified. j (2) The following conditions which were identified by ERC in September as subject to eval % tion as potential deviations had l DRs written for them: (a) I-W PBOM Flange No. 1 (Drawing j BRP-SW-1-SB-003) had a loose nut, and (b) I-M-PBOM Flange i l l L
..) No. 3 (Drawing BRP-CH-1-EC-0048) had two studs without the required one' thread past the outer face of the nut. Existing open items for these subjects (i.e., 445/8513-0-21 and 445/8513-0-22) will remain open pending review of the applicant's completed disposition. 'No NRC violations or deviations were identified. j. Small Bore Pipina and Instrumentation Tube Welds / Material + Status of CPRT Activity Reinspection is in progress of small bore pipe and instrumentation tube welds'and material present in a random sample of 60 welds from i Units 1 and-2. Forty-four small bore pipe and instrumentation tubing welds have been visually. reinspected. Base material heat codes and welder identifications have been recorded and are undergoing -documentation review. No deviations have been found. t Status of NRC Inspection Activity The following seven reinspection of small-bore piping welds were witnessed by the NRC inspector: Verification Package No. Pipe No. & Weld No. BRP No. I-M-5BWM-016 CH-2-216-152-3, Weld 11 CH-2-SB-009 I-M-SBWM-003 SW-2-368-105-3, Weld 23A SW-2-AB-027 I-M-SBWM-013 CC-2-064-152-3, Weld 1-1 CC-2-5B-002 s I-M-SBWM-040 CH-1-220-152-3, Weld 37-2 CH-1-SB-024 I-M-SBWM-076 CS-1-905-250-R2, Weld 18 CS-1-RB-013 I-M-SBWM-054 CT-1-127-901-R2, Weld 56 CT-1-RB-031 4 I-M-SBWM-057 CT-1-127-301-R2, Weld 43 CT-1-RB-031 ) No conditions subject to evaluation as potential deviations were identified by ERC to the NRC inspector. No NRC violations or deviations were identified. k. Larce Bore Pipina Welds / Material Status of CPRT Activity Visual reinspection is in progress of a random sample of 60 ASME 4 Section III large bore piping welds and material from Units 1 and 2. To date, 35 large bore piping welds have been re.aspected. One deviation has been identified which is currently being evaluated for validity and safety significance by ERC. 4 l t
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i - Status of'NRC Inspection Activity 1 As of October 25, 1985, the following eight' reinspection.of sampled large bore. piping welds were witnessed by the NRC inspector: Verification Package No. Pipe No. & Weld No. BRP.' No. 1 I-M-LBWM-003-CS-2-250-301-R-3, Weld 6 CS-2-SB-020 4 I-M-LBWM-009' CS-2-309-301-R-3, Weld-8 CS-2-SB-030 I-M-LBWM-026 BR-X-056-151-R-3, Weld 7-BR-X-AB-048 .I I-M-LBWM-030 00-1-18-151-3, Weld 16-1 DD-1-AB-013 I-M-LBWM-084 FW-2-102-1303-2, Weld 1-3 FW-2-RB-022~ I-M-LBWM-078 CC-2-271-152-3, Weld 31 CC-2-RB-53 { I-M-LBWM-001 CC-2-302-301-R3, Weld 7A. CS-2-AB-032 I-M-LBWM-060 CS-2-026-301-R3, Weld 11 CS-2-AB-065 No conditir,ns subject to' evaluation as potential deviations were identified by ERC to the NRC inspector. 4 No NRC violations'or deviations,were identified. 1. Large Bore Pipe Supports - Riaid Status of CPRT Activity i Reinspection / verification of pipe support installations by ERC is approximately 94% complete. A total of 151 deviations have been identified of which 98 have been. determined to be valid. The remainder are currently being reviewed for validity. Status of NRC Inspection Activity (1) The NRC. inspector performed independent inspections on pipe i support Verification Package Nos. I-5-LBSR-013 and -023, in order to assess the adequacy of the ERC reinspection. The ERC reinspection of pipe support Verification Package No. 1 I-S-LBSR-013 was determined to be adequate, accurate, and complete. However, during the independent inspection of I-S-LBSR-023, one deviation from a. commitment was identified with respect to failure to identify discrepant dimensions. Paragraph 5.3.4.c in QI-027 states with respect to dimensional tolerances not shown on design drawings, " Component Member Length +/- 1/2 inch." The Bill of Material on Revision 2 of drawing No. CT-1-097-402-C52R ilsts item No. 4 (2 pieces) as being 7 3/4 inches long. Independent NRC inspection determined the actual length dimensions to be, respectively, 6 5/8 inches L and 6 1/2 inches, both of which are under the minimum indicateo j dimension of 7 1/4 inches (445/8514-D-04). l l t
r, .q _. 4, 4 ' (2) During. inspection of the installation of box frame supports, which are a part of the Unit 1 containment spray system, the NRC inspector observed that clearances exist between the bottom of the pipe and.the pipe support, and in some cases no clearance exists between.the top of the pipe and. pipe support. The TUGC0-Engineering as-built piping verification supervisor was contacted about the conflict between the as-built drawings'for these supports and the actual field configuration. The TUGC0 Engineering' supervisor stated that their as-built piping configuration program, TNE-DC-24-1,' satisfies the requirements of NRC Bulletin 79-14 and that the as-built configuration complied with installation tolerances.- The conditions-identified above increase loading on adjacent pipe supports and increase stresses on the piping system. The conditions listed above are being referred to NRR for consideration when determining-the accuracy and adequacy.of Stone and Webster Engineering Corporation's stress analysis program for the applicable design specific action plan. m. Large Bore Pipe Supports - Non-Rigid Status of CpRT Activity Reinspection / verification of pipe support installations by ERC is approximately 88% complete. A total of 217 deviations.have been identified of which, to date, 162 have been determined'to be valid. Status of NRC Inspection Activity (1) The NRC inspector witnessed ERC's reinspection of Verification Package No. I-S-LBSN-249 to verify compliance with QI-029. During the inspection, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations: (a) component member lengths out of tolerance, (b) undersize welds, and (c) missing locking devices. Dispositions of the above' items are an open item (445/8514-0-26). No NRC violations or deviations were identified. 4 (2) The NRC inspector performed independent inspections on pipe support Verification Package Nos. I-S-LBSN-014, -025, -035, and -052, in order to assess the adequacy of the ERC reinspection. This effort revealed that ERC had performed their reinspection in accordance with the requirements of QI-029. No NRC violations or deviations were identified. l
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. n. Small Bore Pipina Configuration ~ Status of-CPRT Activity As of October 25, 1985, reinspection was complete for 64 of 95 random sample small bore piping configuration items.. The reinspection .identi?ied conditions which resulted.in the issuance of 45 DRs, 25 of which were validated and are being evaluated by ERC for safety. significance. The NRC inspector was informed by the population engineer that the population items list is currently being revised to exclude all items not having.an."N-5" designation on the piping isometric drawings. One exception wil1 be'certain safety related piping in Unit 1 that has been exempted from "NA" code stamping requirements. The NRC' inspector was informed that the above described revision to the population items list is required in order to ensure that all 'CPRT reinspection items included those which had been previously . inspected and accepted by construction QC. Approximately 20 previously. reinspected items will be excluded from the reinspection samples as a result of this revision. Deviations have involved out of tolerance linear and location measurements, incorrect valve flow direction orientation, inadequate clearances with adjacent piping and equipment, and the part number on a valve differing from that on the isometric drawing. Status of NRC Inspection Activity (1) ERC methods and related documents used in establishing the population items list were reviewed for population inclusiveness. Completed SSE reports are currently being reviewed by the NRC inspector. As of October 25, 1985, six reinspection have been witnessed by the NRC inspector, of which the following three were witnessed during this report period: Verification Package No. Unit No. I-M-SBCO-015 'l I-M-SBCO-061 1 4 I-M-SBCO-079 2 1 L i 4 l
q t ] i - i i 1 (2) During the above reinspection, ERC identified the following d conditions to the NRC inspector as subject to evaluation as potential deviations: I-M-SBCO-061: There was insufficient clearance with three adjacent pipes and a linear dimension. measurement was out of tolerance. j I-M-SBCO-079: Certain. field survey elevation measurements were not the same as the elevations shown on the isometric drawing. f Dispositions of the above findings are open items (445/8514-0-27 and 446/8511-0-06). No NRC violations or deviations were identified. o. HVAC Dact Supports I Status of CPRT Activity i Visual reinspection of a random sample of 66 HVAC duct supports from Units 1, 2, and common is in process. Twenty-five HVAC duct supports have_been reinspected by ERC with 18 deviations identified, mostly in the areas of weld size and configurations. The deviations are currently being evaluated for validity and safety significance by ERC. Status of NRC Inspr i g Activity (1) As of October 30, 7'15, the following three reinspection of sampled HVAC duct supports were witnessed by the NRC: Verification Package No. Unit No. Duct Support No. I-S-HVDS-023 1 CB-830-1N-1R I-S-HVDS-041 1 AB-842-1L-1F I-S-HVDS-005 2 CB-790-2N-1BF (2) During the above reinspection, ERC identified the following conditions to the NRC inspector as subject to evaluation as '4 potential deviations: l I-S-HVDS-023: Size of horizontal brace was not per the drawing j and several welds were undersize. I-S-HVDS-041: Undersize fillet welds.
..fu s a. x - ,DE j i I-5-HV05-005: Wrong weld location, undersize fillet welds, and craters. Dispositions of the above findings'are.open items (445/8514-0-28,445/8514-0-29,446/8511-0-07). l l No NRC violations or deviations were identified. l p. Containment Liner and Tank Stainless Steel Liner Status of CfRT Activity Ninety-one verification packages have been issued and reinspection < are approximately 96% complete using QI-031, Revision 0. Documentation review of.these peckages using QI-032, Revision 0,'is approximately 45% complete. Eighty-three DRs relating to the documentation review have been issued. These deviations are currently being reviewed for validity and safety significance by ERC. Status of NRC Inspection Activity Review of NRC Inspection Report 50-445/85/13, 50-446/85-09 showed that the number of inspections witnessed was incorrectly reported as four rather that the actual' number of nine. No additional NRC inspection activity occurred during this report period. q. Structural Steel Status of CPRT Activity A random sample of 60 structural steel members was selected from a total population of approximately 1600 individual members. Verification packages are currently being prepared by ERC for each member in the sample. QI-045, Revision 1, is being used for physical reinspection. Fifteen packages have been issued to ERC inspectors and inspection is approximately 5% complete based on a minimum sample of 60. Several of the 15 issued packages require additional drawings and clarification. Ten deviations have been identified, involving i primarily incorrect member size, undersized and missing welds, j inadequate bolt hole coverage, and inadequate' Hilti bolt edge d distance. A second random sample of structural steel members related to safe' shutdown systems is scheduled to be selected and inspection i commenced by the end of November 1985. i Status of NRC Inspection Activity (1) The NRC inspector has reviewed QI-045, Revision 1. The following three inspections have been witnessed representing 5% of the first random sample: 4
m. 3.. -39' Verification Package No. Equipment No. Unit No. I I-S-STEL-120 MRB-0565-DCA-MK-A 1 i I-S-STEL-88 AFCO-MK-C182-7-RB 1 I-S-STEL-95 AFCO-MK-0180-1-RB 1 (2) During the above reinspection, ERC. identified.the following conditions to the NRC inspector as subject to evaluation as - t potential deviations: I-S-STEL-120: Three attributes were rejected; i.e., (a) connection location, (b) connection size, and (c) bolt hole edge distance. I-__S-STE L-88 : Undersized welds and incorrect' member. size were identified. I-S-STEL-95: Exposed bolt holes and inadequate bolt tightening were identified. Dispositions of the above findings are open items (445/8514-0-30 through 445/8514-0-32). No NRC-violations or deviations were identified. r.- Concrete Placement Status of CPRT Activity j Reinspection of the first random sample of 60 concrete placement packages is approximately 92% complete. Twenty eight deviations have been identified relating primarily to unfilled holes, voids, and debris in the concrete surface. These deviations are currently being reviewed for validity and safety significance by ERC. Documentation review procedures have not yet been issued.' Status of NRC Inspection Activity i (1) The NRC inspector has reviewed QI-043, Revision 0, and witnessed 9 reinspection representing 15% of the first random sample of 60 concrete placements. The following three ERC reinspection j were witnessed by the NRC inspector during this report period: j 'I l 1 l l P..
V .p.
~~3..~~
. Verification Package No. Concrete Placement No. Unit No. I-S-CONC-40 CPC-105-6831-014 1 I-S-CONC-51 CPC-105-5865-012 l' I-S-CONC-11 CPS-101-2808-001 1 (2) During the above reinspection, ERC identified the following conditions as potential deviations to the NRC inspector and subsequently issued DRs: I-S-CONC-40: The locations of concrete cast-in place inserts (Richmond) were out of tolerance. DR I-5-CONC-40-DR1 was issued subsequent to the inspection. I-S-CONC-51: Voids were identified in the concrete surface. DR I-S-CONC-51-DR1 was issued subsequent to the inspection. Dispositions of the above findings are open items (445/8514-0-33 and 445/8514-0-34). No NRC violations or deviations were identified, s. Small Bore Pipe Supports 4 Status of CPRT Activity l A populacion of 7947 small bore pipe supports has been identified from which a total of 76 support verification packages were randomly selected for reinspection. The first 60 of the verification packages make up the first random sample as defined by the CPRT Action Plan. The second sample pertains to safe shutdown systems and consists of 44 from the first sample of 60 and an additional 16 packages. The QIs used for reinspection and documentation review were QI-019, Revision 2, and QI-020, Revision 0, respectively, ] Physical reinspection are approximately 95% complete. A total of 65 deviations have been identified, relating primarily to Hilti bolt embedment, hole spacing and edge distance in base plates, and pipe j clearances. Documentation review is approximately 82% complete with j 51 deviations identified. All deviations are currently being
~~j reviewed for validity and safety significance by ERC.~~
Status of NRC Inspection Activity ) The NRC inspector has reviewed QI-019, Revision 2, and Ql-020, Revision 0. Six physical reinspection representing 10% of the first l 1 i )
4t.c.q - ) random sample were witnessed by the NRC inspector during September 1985. l No reinspection were witnessed during this report period. .No NRC violations or deviations were' identified. t. Reinspection of Pipe Whip Restraints Status of CPRT Activity ERC has completed 13 out of the planned 110 reinspection of pipe whip restraints as of October 26, 1985. Status of NRC Inspection Activity (1) The following two ERC reinspection of pipe whip restraints were witnessed by the NRC inspector: Verification Package No. Support Identification Unit I-S-PWRE-052 CP2-CSSSMR-05 2 I-S-PWRE-518 M40-52-0584 2 (2) During the above reinspection, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations: I-S-PWRE-052: (a) The distance between two capture plates on a moment restraint was 9 5/16 inches, which was less than the allowed distance of 9 1/2 +/- 1/8 inch; and (b) distance from the centerline of one capture plate to the centerline of a weld was 3 3/8 inches, which was greater than the allowed distance of 1 3 1/8 +/- 1/8 inch. I-S-PWRE-518: The grout did not completely cover the shim plate i underneath the top baseplate. j Dispositions of the above findings are open items (446/8511-0-08 and 446/8511-0-09). 4 (3) ERC also noted the following deficiencies outside of the defined i inspection trope: I-S-PWRE-052: One of the Richmond inserts on concrete column No. 15 overlapped a Hilti bolt embedment for a pipe suoport on j the adjacent face of the same column by approximately 2 3/4 inches. The Hilti bolt centerline was about 5 inches d .-_.__.-....._._._-______-._..-.____.__._,w
.d* + _j',' I q l above the Richmond insert centerline. The impact of this condition was to be evaluated. l I-S-PWRE-518: There was a crater chipped out of the grout. Dispositions of the above findings are open items (446/8511-0-10 and 446/8511-0-11). 'No NRC violations or deviations were identified. u. Reinspection of Instrument Pipe / Tube Supports Status of CPRT Activity ERC has completed 42 out:of the planned 102 reinspection of instrument pipe / tube supports'as of October 26, 1985. i Status of NRC Inspection Activity z '(1) The following four ERC reinspection of instrument pipe / tube supports were witnessed by the NRC inspector during this report l period: Verification Package No. Instrument Tag No. Unit No. I-S-INSP-004 1-FT-156 1 I-S-INSP-017 1-FI-245-78 1 I-S-INSP-024 1-P1S-3384 1 I-S-INSP-057 1-LT-459 1 (2) During the above reinspection, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations: I-S-INSP-004: (a) Support Nos. 48, 4C, 40, 4E, and 4K had bolts without the minimum 70% of specified torque; and (h) support No. 4I did not have the serrated groove of the spring nut aligned with the channel ridge. I-S-INSP-017: (a) Support No. 170 had a bolt without the required one thread past the face of the nut; (b) support Nos. 171, 17K, 17L, 17M, 17N, and 17Q had bolts without the minimum 70% of specified torque; (c) support No. 17K did not have the serrated groove of the spring nut aligned with the channel ridge; and i l l 1
F l;, y 3 l (d) support Nos. 17A, 17J, and 17K had different type instrument tubing clamps than specified on the drawing. I-S-INSP-024: (a) Support No. 24H had an undersized weld; (b)' support No. 24H had no visible heat numbers on the baseplate; (c) support No. 24H had a structural tubing length of 56 3/4 inches, which is 1/2 inch' greater than the maximum allowable _ length specified on the drawing;-and (d) support No. 24H had a different. type of instrument tubing clamp.than specified on the drawing. I-S-INSP-057: (a) Support Nos. 57A and 57E.riid not have the serrated grooves of the spring nut aligned with the channel-ridge; (b) support Nos. 57N and 57P had spring nuts used in lieu of required hex nuts; and (c) support No. 57N had a bolt that {. did not have minimum 70% of;specified torque. Dispositions of the above findings are open items .(445/8514-0-35 through 445/8514-0-38). (3).The following two ERC reinspection were independently inspected by the NRC inspector: Verification Package No. Instrument Tag No. Unit No. I-S-INSP-007 1-PT-405 1 I-S-INSP-028 1-PI-2467 1 'While performing the above independent inspections, it was noted that on support Nos. 0070 and.028A, the serrated grooves on the spring nuts did not align with the channel clamping ridge. This is required by. attribute 4.5 of QI-055, " Reinspection of Instrument Pipe / Tube Supports." However, the ERC inspectors signed off this attribute as being acceptable. This is an NRC deviation (445/8514-D-04). (, 8. Unresolved Items Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Seven unresolved items disclosed during the inspection are discussed in paragraphs 6.g, 6.h, 6.j, 7.a, 7.c, and 7.e. 9. Exit Intervief An exit interview was conducted on November 1, 1985, with the applicant representatives denoted in paragraph 1 of this appendix. During this interview, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the findings.
y 4 j ' 1 DETAILS 1. Persons Contacted q 1 Applicant Personnel ]
~~P. Halstead, Site QC Manager I~~
Brown & Root (B&R) Employees W. E. Baker, Senior Project Welding Engineer D. Mantz, Cable Tray Hanger General Foreman D. Geeo, Cable Tray Hanger Foreman Other contractor personnel were also contacted during the course of this ~ inspection activity. i.
~~Denotes those present at the exit interview.~~
1 i ~ 2. Safety-Related Cable Tray Support Modifications The NRC inspector reviewed the documentation traveler packages and inspected the weldments for 12 cable tray supports that had been modified using tube steel in the new design. The following supports were inspected: Support Classification CTH-2-11843 Class 1 l CTH-2-11846 Class 1 CTH-2-11841 Class 1 CTH-2-11684 Class 1 CTH-2-10040 Class 1 3 CTH-2-9741 Class 1 s CTH-2-11542 Class 1 CTH-2-11541 Class 1 CTH-2-11540 Class 1 CTH-2-9732 Class 1 CTH-2-9733 Class 1 l CTH-2-10033 C1 ass 1 In the areas inspected, the cable tray support weldments complied with the requirements for welding in Weld Procedure. Specification No. 10046 and the requirements for. visual weld inspection in Instruction QI-QP-11.21-1. The documentation for the supports was consistent with the status of the work. No violations or deviatiors were identified. i
~~g ;__ g';~~
+ ~ .; c ', i i [ .g. 3.- ExitInterview Th'e NRC. inspector met with the applicant representative denoted'in paragraph 1 on October 2, 1985, and summarized the ecope and findings of the inspection. j 4 i l 1 i}}

ML20237K575

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ML20237K575

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