ML20237K879
| ML20237K879 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/05/1979 |
| From: | BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.) |
| To: | |
| Shared Package | |
| ML20237J194 | List:
|
| References | |
| FOIA-87-87, FOIA-87-A-14 CP-CPM-6.3, NUDOCS 8708270330 | |
| Download: ML20237K879 (81) | |
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sw sn v IND EXED BROWN & ROOT, INC.
PROCEDURE ISSUE CPSES NUMBER REVISION i
n,#.TE PAGE OB 35-1 m CP-CPM-6.3 6
10-30-79 1 of 10 TITLE:
ORIGINATOR:
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PREPARATION, APPROVAL, AND CONTROL OF REVIEWED BY:
///t/77 OPERATION TRAVELERS"
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QA/QC
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APPROVLC BY:
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///wp, STRUCTION PROJECT MANAGER DATE CONTENTS CPSES i
1.0 REFERENCES
2.0 GENERAL i
2.1 PURPOSE AND SCOPE
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2.2 QUALITY ASSURANCE REQUIRE!1ENTS 1
2.3 AUTHORITY AND RESPONSIBILITY Q
2.4 DESCRIPTION
OF AN OPERATION TRAVELER CONBb 2.5 TITLES 3.0 PROCEDURE 3.1 BASIC PREPARATION SEQUENCE l
3.2 ENGINEERING REVIEW 3.3 QA/0C REY!EW 3.4 RECORD COLLECTION i
3.5 LOT RELEASE AND CONTROL 3.6 TRAVELER CHANGE CONTROL 3.7 TRAVELER "IN-PROCESS" AND " COMPLETE 0" CONTROL NOTE This docurnent has been completely retyped for convenience is issuing Revision 6.
Vertical lines (change bars) appear-ing in the margins indicate what infomation was actually changed, added or deleted by Revision 6.
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BROWN & ROOT, INC.
PROCEDURE l
ISSUE CPSES NUMBER REVISION DATE PAGE d-JOB 351195 CP-CPM-6.3 6
10-30-79 2 of 10
1.0 REFERENCES
1.1 B&R, CPSES Construction Procedure CP-CPM-6.1.
I "Preparat'.on and' Approval of Construction Procedures And Engineering Instructions".
1.2 B&R, CPSES Quality Procedure, CP-QAP-5.1,
" Preparation and Approval of Quality Precedures And Instructions".
1.3 B&R, CPSES Construction Procedure, 35-1195-SFP-2,
" BOP Records Filing".
1.4 B&R, CPSES Construction Procedure, CP-CPM-6.9.
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" General Piping and Inspection Procedure" 2.0 GENERAL 2.1 PURPOSE AND SCOPE q
V
'2.1.1 This nracedure describes the orapare*4m, cppr:vtl aad con-trel of pration travalart which may be tand at CSMS +n -
J contral activitiae effecting quality. The requirenants of i
this procedure are to be implemented by affected B&R Construc-tion and QA/QC personnel when the operation traveler system is implemented for a given safety-related ("Q") activity.
This procedure may also be used for Balance of Plant (Non "Q") con-struction operations.
If used for Balance of Plant work, state-ments in this procedure relating to QA/QC do not necessarily ap-ply and the functions relating to QA/QC may be accomplished by other B&R departments.
2.2 QUALITY ASSURANCE REQUIREMENTS 2.2.1 The operation traveler system has been designed to fulfill Quality Assurance criteria set forth in Regulatory documents and codes and standards applicable during the construction phase of CPSES.
V
i BROWN & ROOT, INC.
PROCEDURE ISSUE Q
CpSES NUMBER I
REVISION 0 ATE
-PAGE JOB 35-1195 j
10-30-79 3 of 10 2.2.2 When implemented as outlined in this procedure, the operation gg traveler system fully complies with the QA criteria and no
_,d-additional controls are required.
If only partially imple-m mented, then additional controls in the form.of supplementary M%3 instructions may be required to meet the applicable require-1 J0m ments. The provisions of References 1.1 and/or 1.2 may be i
dN utilized to supplement a partially implemented system.
2.3 AUTHORITY AND RESPONSIBILITY 2.3.1 Signature authority on a Construction Operation Traveler rests with either the Construction Superintendent (s) responsible for the work or with the Construction Engineer (s) responsible for technical uidance. The site QA Manager is responsible through l
the discip ine Quality representatives to assure that the system is effectively implemented for the selected activities.
2.4 DESCRIPTION
OF AN OPERATION TRAVELER-2.4.1 The Operation Traveler (Fiaurec 1 and 2) serves as a9abri-
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cation /im t m ation/inseer+4cn checklist describing operations necessary to achieve a quality end product in an efficient manner. Accordingly, the details required and included on the face of the traveler will vary depending on the complexity vf the operation.
2.4.2 General information included on the operation traveler is as follows:
a.
Part, serial or tag number and material descriptions (s),
where applicable.
b.
The department assioned the task to perform the operations (s). This is normally shown in the space provided on the traveler but may be documented in an alter-nate manner for simple operations.
j c.
Operation description, methods, procedures (instructions) by number and revision and other information as required to successfully complete the operation per applicable requirements.
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PROCEDURE ISSUE
{
y CPSES NUMBER I
REVISION DATE PAGE J08 35-1195 g
J CP-CPM-6.3 l
6' 10-30-79 4 of 10
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Al1 dimensions and tolerances necantary to assure com-
"g Mng' pliance to denian drawinas and enacifications. Thiis in-J formation may be given by Reference, provided persons per-g forming the work have access to the Reference.
add e.
Any r.eeded offsite operations or processing cited in the appropriate sequence with all other operations.
f.
Necessary instructions for handling, cleaning, storage and preservation of items.
g.
Required QC inspection, hold, or witness points.
h.
A bill of material for piping component supports.
2.5 TITLES 2.5.1 Titles, when used in this procedure apply to the specific person or his designee.
3.0 PROCEDURE 3.1 BASIC PREPARATION SEQUENCE 3.1.1 Samples of the Traveler forms are shown in Figures 1, and 2.
These forms may be obtained from the Construction Engineer.
. The operation sequence and necessary detailed information to be written on the traveler will be developed as a joint effort between the B&R construction craft personnel responsible for doing the work, construction engineering personnel re-sponsible for technical requirements, and QA/QC personnel responsible for Quality Assurance requirements.
It is desirable to include all required information (such as dimen-sions, specification data, and required supplementary instruc-tions) with the Traveler to make a complete " Traveler Package".
However, the inclusion of information routinely available to the persons serforming the work is not a requirement. The sequen-tial numars assigned to each operation on the traveler are for identification purposes and are not necessarily a sequential order of work progression.
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SROWN & ROOT, INC.
PROCEDURE ISSUE d
CPSES NUMBER REVISION DATE PAGE 4
JOB 35-1195
,' CP-CPH-6.3 6
10-30-79 5 of 10 3.1.2 Persons originating travelers are responsible to assign numbers to the travelers and to keep 100 book records of the numbers.
The traveler nuntering system is as follows:
/
Example, "MP79-001-5000" HP = Identification letters representing the craft department or engineering discipline originating the traveler.
79 = The calendar year in which the Traveler was written 001 = The individual sequence number identifying a particular Traveler.
5000 = The turnover (start-up) system number for the activity described on the Traveler.
Q NOTE For mechanical component supports the treveler number will be the component support identification number (if more than one traveler is required for a specific support, the mark number shall be suf-fixed by a -1 for the first additional traveler, etc.).
For electrical cable tray supports the traveler num-ber will be the support mark number prefixed by " Ele-79-CTH" (79 represents the year in which the traveler Was prepared).
3.1.3 When a traveler is prepared, it shall be submitted to the Quality Engineering Department for review and assignment of inspection criteria.
Review requirements for ASME related travelers are delineated in Reference 1.4.
NOTE When travelers are prepared for operations that are repetitive and the travelers are all identical from a working stand-point, review by Quality Engineering and ANI is requh'ed only on the first traveler in the repetitive series. On subsequent travelers that are not reviewed reference to the number of the traveler that was reviewed s, hall be entered on the " Reviewed by" signature Ifnes.
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4 BROWN & ROOT, INC.
PROCEDURE l
ISSUE CPSES NUMBER I
REVISION DUE PAGE i
JOB 35-1195 i
10-30-79 6 of 10 3.1.4 QE shall return the Traveler to the originator for distribution.
I All signoffs will be on the " original" making it the valid working document. Component support traveler packapes shall be controlled in accordance with Reference 1.4.
l RING REVI h - f v W sc U rt 3.2 3.2.1 At the request of the responsib1e General Superintendent, the l
Chief 'roject Engineer throunh the responsible Discipline Engi-neer sna11 complete reviews of applicable drawings, specifica-tions, procedures, and welding requirements to assure under-l standing of and compliance with applicable design and construc-i tion requirements.
l 3.3 QA/QC REVIEW 3.3.1 The Quality representative will perform a spot check of the com-plated forms for accuracy of information and will verify that required inspection, hold and witness points have been included.
He will assure that quality documents have been prepared per the-d provisions of Reference 1.2 and are referenced in the Operation Travelers as required to fully implement the QC functions.
3.4 RECORD COLLECTION 3.4.1 Traveler packages shall remain in the work area until the work described by the package has been completed and accept-ed by the responsible QC Inspectors. Component support travelers may be returned to the FWTC (in the same manner as WDC as stated in Reference 1.4) at the end of each work shift or when the final sign-off is completed.
3.5 LOT RP. EASE AND CONTROL l
i 3.5.1 Lot Release 3.5.1.1 Quantities of identical detail parts or items may be authorized by the Quality rapiesentative on one Traveler package release provided the parts or items are dimensionally identical and that material control and/or traceability requirements can be accomo-dated without creating an extensive and/or confusing record keep-l ing or material marking system. The quantity of parts or items to be included in one lot may be determined by the quantity of parts required to fabricate one assembly or sub-assembly, or a quantity of parts that could remain u one lot until all parts or items are completed without jeopardizing the production schedule.
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e BROWN & ROOT, INC.
PROCEDURE ISSUE
-Q CPSES NUMBER REVISION DATE PAGE J08 35-1195 1
' Cp-CPM-6.3 I
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6 10-30-79 7 of 10 3.5.2 Lot Control 3.5.2.1 A quantity of identical parts released as a lot /on a single Traveler package release shall remain.'together until all oper-ations have been completed and accepted by inspection,~ and the parts / items have been delivered to storage or to another Trav-eler release for subsequent assembly / installation.
If a non-conformance is detected on one or more parts / items of a lot dur-ing the operations, the conforming material and Traveler shall i
remain in a designated hold area until the nonconformance has been adequately dispositioned. The site QC Manager may author -
ire certain exceptions to _ this rule.
Such matters will be handled on a case basis.
1 1
3.5.2.2 If certain parts / items are dispositioned " Scrap" the quantity-of the lot on the Traveler shall be reduced to the quantity found to be acceptable by inspection.
Replacement items, when required, shall be issued on another Traveler, reflecting i
a new release number.
If an item or items in a lot requires repair, such as welding, the entire lot shall be serialized and appropriate records prepared to establish traceability for repairable items as required by applicable codes and specifica-tions.
3.6 TRAVELER CHANGE CONTROL 3.6.1 All changes, regardless of their significance, must be doc-umented on the Traveler, denoting the operations affected, description and authority for the required change, and the Quality representative's approval. _ The revision number and a description of the change will be noted on the traveler below the last traveler operation of the original issue.
If necessary the revision description may be continued on a; continuation sheet. The back side of the traveler.for piping component supports will also depict the revision in the re-vision block.
[n design chang 3 are received that affect issued and approv--
3.6.2 ed travelers, Ine applicable changes will be made to the traveler, and it will then be reviewed in the same manner as the original-issue. At the su (via 3 part memo)perintendent's discretion and with QE concurrence -
, work may. continue on _ the traveler operations not affected by the design cilange.
Changes to component support traveler packages will be routed in accordance with Reference 1.4.
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4 BROWN & ROOT, 2NC..
PROCEDURE ISSUE CPSES NUMBER REVISION DATE PAGE i
JOB 35-1195 i
' 10-30-79 8 of 10 1
t 3.7 TRAVELER "IN-PROCESS" AND " COMPLETED" CONTROL 3.7.1 Travelers shall. be maintained complete throughout the construc-tion process. Each QC Operation requires the i'nitials and date.
by QC denoting the inspection status. This shall be accomplished at the completion of each' operation a,nd prior to moving parts or assemblies to the next operation,. unless otherwise noted on the Traveler.
i 3.7.2 It is expressly prohibited to proceed beyond any hold point requested by the Quality. representative without his approval, reflected by his initials and date at the applicable operation I
on the Traveler.
3.7.3 The Quality Control supervisor is charged with the responsibility.
for assuring that all operation Traveler instructions have been complied with and all previous operations have been performed and accepted. The Discipline Inspection Supervisor is responsi-ble to the Quality Control Supervisor for the assurance that all -
completed items, assemblies or sub-assemblies meet the require-ments of the applicable dr~ awings and specifications - by it.spection and acceptance of all items denoted on the Traveler and associated check lists or instructions. After all operations listed on the traveler have been completed and appropriately I
signed, the department supervisor implementing the work will submit the. traveler to construction en FWTC for component support travelers. gineering, or to the The discipline con-structiori engineer will log such receipt of the traveler and in turn 1f "Q" related. submit it to the Quality Engineering Department for review and incorporation into the CPSES documen-i tation system. Travelers for Non "Q" items will be processed in accordance with Reference 1.3.
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BROWN & ROOT. INC.
PROCEDURE l
ISSUE CPSES NUMBER REVISION OATE PAGE JOB 35-1195 l
10-30-79 9 of 10 FIGURE 1 SAMPLE TRAVELER FIRST SHEET CONSTRUCTION Opf A Ata0N TAAvstem 35116s
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PROCEDURE ISSUE CPSES JOB 35-1195 NUMBER REVISION DATE PAGE-j 1
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APR 11 1983
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ocket i:os. 50 445 bN/ //.A M.,,z., t,.L
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Texas Utilities Generating Company i
AT'Ol: Mr. R. J. Gary, Executive Vice ? resident and General Manager 2001 Bryan Tower Callas, Texas 75201 Gentlemen:
SUBJECT:
Construction Appraisal Insoection 50-445/83-18, 50-446/83-12 This refers to the construction appraisal inspection conducted by the Office of Inspection and Enforcement (IE) on January 24 - February a,1983 and February 14 - March 3,1983, at the Comanche Peak Steam Electric Station and your Dai?.as corporate office.
The Construction Appraisal Team (CAT) was composed of members of IE and a number of consultants.
activities autnorized by NRC Construction Permit CPPR-126/127.The inspection covered cons This inspection is the second of a series of construction appraisal inspections being planned by the Office of Inspection and Enforcement.
The results of these inspections will be used to evaluate implementation of management control of construction activities and the quality of construction at nuclear plants.
The enclosed report identifies the areas examined during the inspection.
Witnin these areas, the effort consistee of detailed inspection of selected hardware subsequent to Quality Control inspections, a comprehensive review of your Quality Assurance Program, examination of procedures and records, observa-tion of work activities and interviews with management and other personnel Appendix A to this letter is an Executive Summary of the results of the inspec-tion and of conclusions reached by this Office.
Except for the area of the heating, ventilation and air conditioning (HVAC) system, deficiencies noted in installation requirements. installed hardware did not indicate pervasive failures to mee In the HVAC system, a breakdown.in work and quality control was identified.
it is our understanding that this matter received immediate' action by y your contractors to evaluate and correct these conditions. !NRC Region IV will continue to pursue this issue with you.
Prompt management attention to the resolution of other detailed deficiencies identified during.the inspection is needed.
in its. inspection of safety system piping.In contrast to the HVAC system ASME Code radiographs for this piping and samples inspected in this area showed evidence of good workmanship.
EXHIBIT 26 f
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APPENDIX B POTENTIAL ENFORCEMENT FINDINGS
. February 4,1983 and February 14 - March 3,1983, th referred to NRC Region IV as potential enforcement findings (Section references are to the detailed portion of the Inspection Report).
Miectrical ano Instrumentation Construction pgNJV t
1.
Contrary to 10 CFR 50, Appendix B, Criterion X and FSAR Sectiun 17.1.10 certain inspection activities were not executed to verify installation d
confonnance with procedures including cable spacing in trays, cable hend M i
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radii, cable fill, able suppe.ts and tray installation h~aWware (Sections j
II.E.1.a. b,c,d, and'II.B.4.b(1)).
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2.
Contrary to 10 CFR 50, Appendix B, Criterion XVI and FSAR Section 17.1.16 the established inspection program did not provide adequate controls to t
assure that deviations from electrical and electrical / mechanical separa 1
K rected (Sections II.8.1.f, II.B.4.a. andtion criteria as defined in the F
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34 Contrary to 10 CFR 50, Appendix 8, Criterion V, FSAR f
, and to certain aspects of battery maintenance have not been developed or
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implemented (Section II.B.3.0,).
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U Mechanical Construction r
1.
Contrary to 10 CFR 50, Appendix B, Criterion V, FSAR Section 1715 g.
net installed in accordance with the design docum supports / restraints were inspected (Secti::n III.B.2),
[t 2.
Sections 17.1.10 and 17.1.17, an inspection program k[g established to verify and document installation con ment installations (Section III.B.2 and 5).
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3.
Contrary to 10 CFR 50, Appendix B, Criteria V an
- . g conditioning (HVAC) duct, supports and equipment do not. conform 4
requirements.
In addition, inspection procedures have not been established or executed to verify conformance of HVAC supports to design drawings (Section III.B.4- ).
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1 iding and Nondestructive Examination
[k Contrary to 10 CFR 50, Appendix B, Criterion IX and FSAR Section 17.1.9,
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certain special processes relative to the HVAC system were not adequately controlled, V '>' y hgropenl-y..qualifiTe precederos; improperly qualified
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y inspectors; improper certification of NDE personnel (Section IV.B.3).
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Civil and Structural Construction Contrary to 10 CFR 50, Appendix B, Criterion V and FSAR Section 15.1.5, civil s
construction test procedures were inadequate to ensure that mixer uniformity tests as re y#hequency (quired by the ASME-ACI-359 Code were performed,M *e necribed Section V.B.2).
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- Procurement. Storace and Material Traceability Contrary to 10 CFR 50, Appendix B, Criterion XIII, F5AR Section 17.1.13, d
CP-QAP-8.1, Rev. 5, CP-CPM-8.1, Rev. 1, and MCP-10, Rev. 7, storage of certain safety-related equipment in outside lay-down areas and inszal-led-4n-the-ptant g
m avi propedy me.nMed (Section VI.B.2).
r Quality Control Inscector Effectiveness f
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.1.
Contrary to 10 CFR 50, Appendix B, Criterion II and FSAR Section 3.8, f
individuals were certified to levels of capability without the requisite M
experience described in Regulatory Guide 1.58 (Section VII.B.2.a.(2)).
2.
Contrary to 10 CFR 50, Appendix B, Criterion X and FS il
" inspector of record" rather than the required L-II " inspector of record" required by ANSI N45.2.6 (Section VII.B.2.b(1)).
_0uality Assurance 1.
Contrary to 10 CFR E0, Appendix B, Criterion XVIII and FSAR Section-depth to identify and correct significant problems in va 17' VIII.B.2.b.(5)(c)). construction; i.e., HVAC and el_ectrical sWarat$ (Section v
p'2.
Contrary to 10 CFR 50, Appendix B, Criterion XVI and FSAR Section 17.116 4DD audit findings related to maintenance instructions id (p4
'M 3.
Contrary to 10 CFR 50, Appendix B, Criterion VI and FSAR Section 17.1.6 drawings with out-of-date revisions and drawings with damaged or unread-able title blocks were present in construction work areas (Section VIII.B.2.e.).
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6 DesignChanceCondrolsandCorrectiveActionSystems 1
- Contrary to 10 CFR 50, Appendix B, Criterion V' and FSAR Section 17.1.5, procedures were not adequate to assure design changes were properly transmitted to the Quality Centrol organization such that an appropriate inspection could be performed (Sections IX.S,.A',1.
nd IX.B.l.c).
t2 Contrary to 10 CFR 50, Appendix B, Criteria II and X, and FSAR Sections.
17.1.2 and 17.1.15, nonconforming conditions identified relative to some' safety-related hardware installations are not being properly documented, i
evaluated, and dispositioned through the Corrective Action Program.
(Section III.B.8, IV.B.2 and IX.B.2)).
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QUALITY ASSURANCE A. Objective The objective of this review was to determine the adequacy of the licensee's Quality Assurance (QA) Program. The program was reviewed to determine if it was appropriately established in instructions and 1
manuals; and if the construction and quality assurance effort was monitored through audits and other management actions.
In addition, a sampling review of specific steps taken by the licensee regarding the oversight of contractors, control of measuring and test equipment, document control, and control of QA records was made to determine if specific parts of the program were implemented.
B. Discussion
- 1. Proaram Requirements The QA program is defined by a management endorsed hierarchy of general directives and implemented by procedures at the corporate and site levels to control construction activities. These procedures were implemented to satisfy the licensee's Final Safety Analysis Report (FSAR) commitments.
- 2. procram Implementation Implementation of this portion of the program was determined based on reviewing the organizational structure, input from other NRC CAT j
inspectors, the construction audit program, sampling drawing revi-sions in the construction work areas, and reviewing the control of
)
measuring and test equipment.
- a. Organization I
The QA organization includes the site construction quality control organization which is independent from the site construc-tion management. The quality assurance organization reports to the Vice President for Nuclear Operations, whose responsibilities include the construction and operation of the Comanche Peak Steam Electric Station (CPSES).
The auchority and duties of the positions involved were described in the FSAR and corporate manuals. The audit organization was located at the Corporate Headquarters in Gallas. The QA organization was found to be in accordance with NRC requirements and the description contained in the FSAR.
Organizational Charts indicated that a number of staff positions were vacant and had been for an extended period.
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- b. Audits
- The licensee's audit program was reviewed. At least'18 audits out of 60, performed between 1978 and 1983, were selected and reviewed with ecphasis on the! following major areas
auditor.
qualifications and certificat. ions; audit planning and scheduling; audit instructions and check sheets; audit reports; audit.v3ults and followup; and the overall effectiveness of the audit program.
(1) Auditor Qualifications and Certifications (a) The licensee qualification and certification program for
'uditors and lead ~ auditors.was established in QA a
Procedure DG1-QA-2.1 " Qualification of Audit Personnel".
(b) The certification records for ten' lead auditers-we.'e reviewed.
The lead auditors met the TUGC0 and ANSI N45.2.23 requirements.
The review revealed, however, that auditors not meeting.the experience requirements for the lead auditor position had been assigned as " Acting l
Lead Auditor", but the limits of an acting lead auditor's authority and the guidance provided was not defined.
(2) Audit Planning and Scheduling (a) Document reviews and interviews revealed thst.a~udit plans were developed and a system of check sheets were used as guides to the auditors to ensure that specific points were rqviewed.
Open audit findings were also' reviewed during the audit.
It was revealed that the check' sheets.
were developed by the auditor assigned the. audit or by the audit. group supervisor but were not approved by the QA Services Manager.
Interviews revealed that audit schedules.'were developed using previous audit findirgi, schedules, experience and discussions with const'ruction site supervisors concer,ning l
construction problems.' There were.no trend analyses or construction schedules!provided.to the QA organization by the site; therefore, these important sources of in-formation were 'not used' in developing. the audit schedule.
Also,.there was no QA procedure toLdescribe the~ method to be used to develop audit schedules or what management approvals the schedule!should receive.
(3) Audit Reports Audit reports _ provided a. description of the audit scope; identification of auditors; persons contacted; a summary of results ' and. a description o,f, any deficiencies or findings.
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Audit deficiencies were clearly written and required timely h
response by the management of the sudited organization. The completed deficiencies were reviewed by the audit team leader for adequacy. Deficiencies were reviewed in subsequent attdits for completeness.
Prompt corrective action was not always taken on audit 9ndings (See Paragraph B.2.b.(5) below).
(5) Frogram Effectiveness Although the audit program was in place, there were several weaknesses in the program that decreased its effectiveness.
(a) Audit Effort The audit organization is located at the TUJ:0 offices in Dallas.
All audits are performed from that location.
There are eight auditors in the audit section. Although audit teams are sometimes supplemented by personnel from other sections of the QA organization, the eight member audit section is assigned to perform audits of suppliers, subcontractors at the construction site, construction activities and startup.
Of the eight auditors in the audit c'eganization, four had technician background and 3
four had a general nontechnical background. None of the auditors assigned to the group had engineering background or experience.
Interviews revealed that approximately 1200 man days were spent preparing for, conducting and reporting audits at the site in 1982. A review of the 32 audits performed in 1982 revealed tiu t about 330 man days were spent on site performing these audits.
This appears to be a small percentage of the total audit effort considering the level of effort ongoing at the site.
Interviews re ealed that five additional auditor positions had been authorized for more than onc year but the positions were still vacant.
(b) Audit Frecuency Interviews ano document reviews revealed that:
Twelve audits of construction activities were performed in 1981. Of these, six were of engineering and adminis-trative areas such an audits of IE Bulletins, and pro-curement and six were of construction field activities.
Thirty-two audits were performed in 1982.
Only nine of the audits were of construction field activities, the VIII-3 O
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l and other support areas.other 23 audits were performed o field activities:
Of the audits of construction one audit was performed of mechanical piping activities, one of restraint and snubber instal-1ations, two of electrical work, one of civil work, one of instrument and controls, and three of protective 4
i
, coatings application.
The frequency of audits of construction activities has been very low and may have contributed to the problems in the of this report. technical disciplines identified in Sections II, III, and (c)AuditEffectiveness Areas of the construction activity were audited; however, the audits did not identify major construction program problems, for example:
Bahnson Services was audited yearly since 1980. The last audit was in April 1982.- Althougn fabrication and installation activities and personnel qualifications were in the scope of the 1982 audit, such NRC CAT dimensional characteristics, and an inadequa tural welding inspection program were not identified and resolved.
i The electrical area of construction was audited only four times since 1980.
The audits did not identify the cable
. separation issue as discussed in the Electrical Construction Section (Section II) of this report.
audit. findings; for example: Ineffective corrective actio number (TCP-5)). Equipment maintenance was audited in' A instructions were not beinAn audit finding. identified that vendor maintenance instructions. g incorporated into ongoing startup activities The July, 1981 QA audit of Surveillance Sumary(TUG-5) and the June 1982 Quality problems with ensuring that manufacturers require and qualification report requirements had been incor-porated'into the maintenance program audit (TUG-14) identified the concern. An October 1982 qualification reports were not reviewed during thethat equipme process of establishing maintenance requirements.
The VIII-4 9
0 W
4.
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~
i l
problem was identified in 1979, and it has not been resolved as evidenced by the 1982 audit. Thus, the effectiveness of the corrective action system for audits is not effective..
5:
~
- The NRC CAT inspector's conclusion is that weaknesses i
- exist in the established audit program. These weaknesses
. include the scheduling and frequency of audits, the lack of i
effective construction program monitoring, and in lack of
(
effective resolution of some audit findings.
I
- c. 0A Procram Interfaces The NRC CAT inspector reviewed the QA organizations' overview of documents that prescribe actions taken by engineering, construc-tion, and quality assurance personnel. A planned and systematic program is in place with one aspect being procedure review.
Interviews and document reviews revealed that:
(1) The QA/QC manager or a senior representative reviews all inspection procedures.
(2) The QA/QC manager or a senior representative reviews con-struction control procedures to ensure the proper construc-tion-inspection interft:e exists.
(3) Engineering control procedures are not reviewed by the QA/QC l
manager or a representative of the QA organization.
The lack of proper interface with engineering may have contri-buted to the issues discussed in Sections II, III, and IX of this l
j report. These issues rel2te to the final engineering design and the final inspection reports not being reflected in the hardware.
- d. Construction Monitorino
~
A prcgram of construction monitoring was established. The program consisted of: monitoring-the ASME construction and installation activities performed by Brown and Root (B&R), and i
surveillance of concrete anchor bolt installations.
The monitoring of ASME construction activities consisted of a systematic review by two individuals of B&Rs compliance to approved instructions, procedures and/or drawings that implement the requirements of the B&R ASME QA manual. The monitoring was scheduled in advance and provided a review, although less formal than audit, of ongoing ASME work activities. The surveillance of anchor bolt installation was performed in accordance with.TUGC0 procedure CP-QP-11.2 Rev. 4 which indicates that 10 i
VIII-5
~
e
m Failure to Provide Objective Evidence (Records) to Show that Concrete Central and Truck Mixer Blades were Inspected 10 CFR Part 50, Appendix B, Criterion V,. as implemented by the TUGC0 -
QA Plan, Section 5.0, Revision 2, dated May 21, 1981, requires that activities affecting quality shall be prescribed by documented instruc-tions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, proce-dures, or drawings."
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 3
(
\\
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.
1 l
1 l
I 4.
Failure to Provide Objective Evidence (Records) to Show that Concrete-Central and Tr;[. Mixer Blades were Inspected 10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 QAP, Section 5.0, Revision 2, dated by 21, 1981, requires that activities affecting quality shall be prescribed by documented instructions, g[
procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance'with these instructions, procedures,
\\[kp d
or drawings.
Brown & Root Procedure 2 M 195-CCP-10, Revision 5, dated December 4,
[1 1978, requires that centrki and truck mixer blades be checke to assure that mixer blada wear does not exceed a loss of 105 of original e
blade height.
Contrary to the above, on b y 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.
This is a Severity Level V Violation.
(Supplement II.E) (445/8507-04;'
446/8505-02).
M m.
C 4
L_
r 1
f h (psA i
During this inspection, it was found that certain of your activities were in violation of NRC requirements. Consequently, you are required to respond to A
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 sM 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 j
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 i
violation 2.c is required.
l l
N c.
Brown & Root Procedure 35-1195-CCP-10. Revision 5, dated December 4 1978, requires that central and tru.ck mixer blades be chercked quarterly to assure that mixer blade wear does not exceed a loss of,
10% of original blade height.
l 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)
8.
Concrete Batch Plant Inspection The NRC inspector used a nationally recognized checklist to inspect the concrete production facilities. This list included the specific characteristics for the following areas:
(1) material storage and handling of cement, aggregate, water and admixture, (2) batching equipment scales, weighing systems, admixture dispenser, and recorders, g
(3) central mixer (not applicable because it had been dismanteled), (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 dismanteled and removed from site two or three years ago when concrete placement was virtually completed.
Presently, the backup batch plan'. (which was a backup system for the central mixer) is in operation to complete the remaining concrete placements.
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 j
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 subject to wear and should be checked at a reasonable frequency.
The Brown & Rost (B&R) representative responsible for checking the blades in accord 6nce 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 and it was found that there was no record of such checks dating back to 1977 when they were initially checked.
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.
Sub equent 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.
V (4) Documentation Reviewed i
The NRC inspector reviewed the following documentation for the
{
rebar placement and cadwelding for the Unit 2 containment (reactor building) closure area.
4 i
Drawings DCAs NCRS 2323-5-0785, Rev.7 22616, Rev. 1 C85-200294 j
2323-5-0786, Rev.9 22728-C85-200339, Rev.1 1
2323-S1-500, Rev.5 22737 C85-200355, Rev.1 l
2323-SI-506, Rev.5 22836 i
2323-S2-505, 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 Batch Plant Inspection. Unit I and 2 4
fk The NRC inspector used a nationally recognized checklist to inspect the concrete production facilities. This list included the specific characteristics for the following areas:
(1) material storage and handling of cement, aggregate, water and admixture, (2) batching
)
equipment scales, weighing systems, admixture dispenser, and recorders, (3) central mixer (not ap
?
ticketing system, and (5)pitcable because it had been dismanteled), (4) delivery system.
The current batching is a manual operation since almost all concrete has been placed. The central mixer was dismanteled and removed from site two 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 i
placements. This batch plant is in good condition and complied with the j
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 six numbers and the truck i
then mixes the batch to be placed.) The blades inside the truck are subject to wear and should be checked at a reasonable frequency. The Brown & Root (B&R) representative responsible for checking the blades in accordance with B&R Procedure 35-1195-CCP-10, Revision 5, dated i
December 4,1978, was asked for evidence that the blades had been checked for wear on a quarterly basis and it was found that there was no record of
{
such checks dating back to 1977 when they were initially checked.
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 i
t
. l mixing blades was not documented, although the B&R representative stated that the mixing blades were periodically inspected and laboratory testing j
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 l
counter were in good condition.
l
~
This failure to follow procedures is a violation of 10 CFR 50, Appendix B, Criterion V.
Subsequent to the identification of this-violation, the i
blades were checked for wear and blade wear was presently within allowable limits (445/8507-04; 446/8505-02).
i No other violations or deviations were identified.
9.
Calibration Laboratory for Batch Plant Unit 1 and 2 The NRC inspector obtained batch plant scale numbers from tags which calibration frequency. Cement (MTE 779), Water (MTE 766), admixture
)
indicated that the scales had been calibrated and were within the-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 clearly 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 l
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 ?or scales MTE 779 records contained B&R memo IM-1108 dated July 16,1975, which described a nonconforming condition. This condition affected the water and ccment scales causing'a 24-48 pound deviation during the calibration test. The meno stated that the condition was corrected and the scaler were then calibrated; however, no deficiency report was written as required by BAR 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 corrective action included an evaluation to determine if concrete production was adversely affected.
s
. Drawings DCAs NCRs.k 2323-5-0785, Rev.7 22616, Rev. 1 C65-200294 2323-5-0786, Rev.9 22728 C85-200339, Rev.1 2323-S1-500,.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 Batch Plant Insoection. Unit I and 2 The NRC inspector inspected the concrete production facilities for the following specific characteristics for the following areas:
(1) material g
storage and handling of cement, aggregate, water and admixture, (2) batching equipment scales, weighing systems, admixture dispenser,'and recorders, S
(3) central mixer (not applicable because it had been dismantled),
l'\\
(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 _
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 placements. 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 f
l 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 subject to wear and should be checked at a reasonable frequency. The Brown & Root (BAR) representative responsible for checking the blades in accordance with BAR 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 by procedures and it was found l
that there was no record of such chec h oating 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 l
.I
,, -4 j
was not documented, although the BAR representative stated that the mixing blades were periodically inspected and laboratory testing wouid have probably indicated if there was a problem with the mixing blades.
Strength and uniformity tests have consistently been within the acceptable 3
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.
1 This failure to follow procedures is a violation of 10 CFR 50, Appendix B, l
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 I and 2 3
The NRC inspector obtained t'atch plant s'cale numbers from tags which
)
indicated that the scales had been calibrated and were within the y
calibration frequency. Cer.sent (MTE 779), Water (MTE 766), admixture scale j
(MTE 764), and aggregate (MTE 780) were reviewed. The scales had been j
periodically calibrated since the batch plant was activated. The records
)
were adequate except as follows:
u l
a.
Scales MTE 766 records do not diffeM f ete between the I
required accuracy of the scale and W d*ptal readout.
b.
Scales MTE 779 and 780 records show various accuracy ranges for the same scale; 1.e., MTE 779 (SN749687) records the following: report dated January 1976 gives 15; report dated July 1976 gives 15 while
)
the report dated October 1976 gives +/- 0.25, The calibration appeared to be proper, however,s actions regarding th the above items are unre-1 solved pending further review of the applicant correction of these records (446/8507-05; 446/8505-03).
c.
Records for scales MTE 779 records contained BAR 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 thp condition was corrected and the scales were then calibrated; however, no deficienc 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
g' 4
52 l
The following is the required response in the original draft report:
"During thir, inspection, it was found that certain at your activities were in violation of NRC requirements.
Consequently, you are required to respond to thi s vi ol ati on, in writing, in accordance wi th the prnvision ci 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."
l l
The following (paragraphs 3 and 4 from NRC letter of transmittal 3
dated February 3, 19851 show that the requirement to respond to the violation was dropped.
i "During thi s i nspecti on, it was found that certain of your activities were in violation of NRC requirements.
Consequently, you era required to respond to thi s vi ol ation, in writing, in ac. ordance 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-CFF-10 has been revised to provide documented inspection of truck mixer olades, there was no
)
I abnormal blade wear identified as a result of bl ade inspection, and j
there have been consistent concrete strength and uniformity tests, no reply to violation 2.c is required.
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l CFR..201, lexas Utilities Electric
" Pursuant to the provisions of 10 ~
Company is horeby required to submit to this off3ce within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation:
(2) 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, con si der a ti on will be given to extending the response time."
The details of this inspection aie described in Exhibit 11-13.
PHILLIPS' Understanding of Concern No. 5 Reovirements:
The requirements are described ir the Notice of j
Violation quoted above and in Exhibits 11-13.
)
i i
j Noncompliance:
The noncompliance is also adequately described in Exhibits 11-13.
P,HILLIPS' Understanding of Handlino/Mithandlino of Concern No. 5 Procer handlino:
Similar to Concern No. 1 and four other concerns, the findings were being properly handled by fndHUNNICUTT.
letter and Notice of Viol ation required a response to this J
h w em 6m Pml h WR ()([-lt; C f) M G ~ 1 /
(t b u,hd b ve vi n ds v
i
- V f p n ef /c)
In s:ac t i on Recort 3 0-4 4 5 / 9 5-0 7;_50- 4 4 d / 5 5-05 (85-07/05s Concern ho. 1 anc PHILLIPS were concerned tnat Region IV (R!V) canagement
'(downgraded the violation, concerntng fsilure to translate design criterta into specifications and drawings, to an unresolved item in the inspection report issued without giving sound NRC regulatory and tecnnical casts and unresolved items require no action.
=
In the Inspection repre t (signed on October 2, 1986, by the ois2te NRC supervisor and inspectors) the violation reads as fo' lows:
"6.
Failure to Translate Desion Criteria into Installation Soectil:ations, Procedures, and Drawinos; and Failure to Control Dev:strons fro,n These
{
e, t a n d a - d s i
"10 CFR 50, Appendix B, Craterion III. as implemented by TUGC0 CAP
{
3 Section 3, Revision ;, dated July 31, 1994, requires tnat measures shall be established to assure that applicable regulatory requirements and the design basis, are correctly translated into specifications, drawings, procedures, and instructions.
These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlleo.
" Contrary to the above, Unit 2 reactor pressure vessel installation criteria such as centering tolerances, levelness tolerances Csic], and shoe to bracket clearances were: (a) specifisc on Construction Operation Traveler ME-79-248-5500 based on NSSS vendor recommended criteria which.had not been translated into CFSES specifications, drawings, procedures, or instructions; and (b) changed on traveler dithout appropriately documenting j
such engineering changes.
"This is a Severity Level IV Violations (Supplement.II.E; 144w e505-05;.4 The downgradec item in the final inspection report reads as follows:
"12. Reactor Pressure Vesset and Internals Installation Unit 2 k
"This inspection was performed by an NRC Inspector to verify final placement of the reactor pressure vessel (RPV) and internals by exactning l
the completed installation and inspection records.
i "a.
Requirements +or Placement of RPV v
{
" Requirements for placement of the RPV to ensura proper fit-up of all other major NSSS equipment are in % stinghouse Nuclear Services j
Division (WNSD) ' Procedure f or Fet ti ng of Maj or NSSS Co,nponen t s. '
l Revision 2. dated February 13, 1979, and 'Seneral Reactor Vessel Setting Procedure,' Revision 2, cated August "O,
1974.
The.NRC inspector reviewed the following dr.dtngs, which were refsrencac in j
i
[,
1,' '
cO/MA-AickW P%c Mhs5kzeer
("(9/206 7hrK Grea f 2
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/?aavI Tibn8Aanr,,af pecca cCSf!jcv6 cRady Tss":2 A d*W 3
Que9Sy?
66acujaaQ%es 1 - l 8 M L7 ro w 1
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e 7.
Failure to Maintain Tolerances Stated and Failure to Repus t These Results on a Nonconform. ace Report 10 CFR 50, Appendix B, Criterion XV as implemented.by the TUGC0 QA Plan, l
Section V, Revision 2 dated May 21, 1981, requires that measures shall be
{
established to control materials, parts or components which do not conform
?
to requirements; and nonconforming items shall be reviewed and accepted, rejected, repaired; or reworked in accordance'with documented procedures.
Brown and Root Quality Assurance Manual, Section 15, dated March 27, 1985, requires that unsatisfactory conditions identified on process control documents shall be identified on-an Nonconforming Report.
4 Contraty to the above, clearances between the reactor w.;sel support brackets and support shoes were not within the tolerance stated in Construction Operation Traveler ME-79-248-55 and the condition was-not reported or, 5 Nonconformance Report.
l This is a Severity Level IV Violation.
(Supplement'II.E) (446-8505-07) i l
7.
Failure to Maintain Tolerances Required and Failure to Reoort Tolerance Deviations on a Montonformance Report
/
10 CFR 50, Appendix 8, Criterion XV as innlemented by the TUGC0 QAP, Section 15.0,~ Revision 2 dated May 21, 1931, requires that measures shall be 1
established to control amaterials, parts or components which do not conform j
l to requirements; and nonconforming items shall be reviewed.'and accepted, l
rejected, repaired; or reworked in accordance with documented procedures.
Brown and Root Quality Assurance Manual, Section 16, dated March 27, 1985, requires that unsatisfactory conditions identified on process control documents shall be identified on a nonconforming report.
Contrary to the above, clearances between the reactor vessel support brackets and support shoes were not within the original or revised permissible tolerance stated in Construction Operation Traveler ME-79-248-55 and the deviation was not reported on a nonconfomance report.
This is a Severity Level IV Violation.
(Supplement II.E) (446-8505-06) l 1
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vn CONSTRUCTION OPERATION TRAVELER 35 1195 g
@ME-79-248-5500
@ EQUIPMENT NO.
l@ NIT NO.QUANTITY ff)PAGE_lO[
TRAVELER NO.
t TCX-RCPCRV-01 l
2 1
M i1 l6 ACTIVITY DESCRIPTION 7 REFERENCE DRAWINGS eactor vessel Insta11stinn goo n 1 nw SPEC./ PROC./ENG. INSTR.
gLOCATION g SYSTEM MCP-1 hM Containment #2 M_r_
PREPARED BY YMA DATEMO M DEPT. Mb EUG-REVIEWED BY t 6O DATE Y~O
- O QA/OC ENG ANI
%I.1%94tE. & d n]as"Y00
<4 - \\ O ~ ~1'I ANI REVIEW WA O
DATE b
QA43C OP. NO.
DEPT.
OPERATION,,. ~
ENG ANI s
General Notes:
(1)
All support nuts and bolts shall be tightened to " snug tight" condition.
Snue tight shall be defined as the condition which insure that parts of the joint are brought into good contact with each other.
This can be attained-by a few impacts of an impact wrench or the full effort of a
)
man using an ordinary spud wrench.
Reference the appropriate.
Traveler for rigging and lifting require-ments of the reactor vessel.
(2)
Clean al$ R.V.
Support Shim with acetone prior to installation.
(3)
Reference Drawings:
8
- C W 1210E59--- R.V.
Support Hardware QA RECORD OCT 02 1979 y uS7r27--- Reactor vessel Supports
,,- n C-E 10773-171-004----R.P.V. General
~
' DLES NOTED ng, go, Arrangement g
y o UMI.H ASlsura NCE
""~
C-E 10773-171-00s----a.r.v, M
N4R - tem L
viu w
=
1 M/W Install the R.P.V.
Supports and Shoes per W Drawings 1210E59 and 1457F27.
The min.
6
~
engagement for the guide pins is 2 ". Therefore
}
- the following gaps between the Support Shoe and pin top surfaces are as follows:
h s.
l L
CONSTRUCTION OPERATION TRAVELER CONTINUATION TRAVELER NO.
ACTIVITY DESCRIPTION
{
pao (2,,OF[f ME-79-248-5500 Reactor Vessel Installation M EOM PREPARED BY b-DATE REVIEWED BY V"
DATE ANI REVIEW Mb DATE
/
QA/OC i
OP. NO.
DEPT.
OPE R ATION ENG ANI.
f 2./
Ifor. Leg--Shoe to pin = -2 3/8 to -7/8" b
I b
QCV' Pr Cold Leg--Shoe to pin = r3/8" to +1 1/8" W
I A
GAev
'Nu#
G
" chi.
t h e s i c.; ;'.i r.3 Le 1 S '.;
mn.
Pull
%<t 77 f
The side inbed restraints to the side shim and i
support colums prior to concrete' pour.
0" l
l clearance must be met after the pour.
0"
{
i clearance shall be less than.001"? The' side
'l I
kf
- shims are to also be modified per C"C-4260'. Af l
Weld the side shims to the R.P.V. Oupport per BRM-1457F27. QC to inspect welds and attach applica-j ble NDE Reports.
The optimum elevation to set the R.P.V.
j Support shoes is as follows (based on R.P.V.
i A
As-Builts):
l 6
67 -----824'-5.754" 0
158 ----824'-7.784" 0
247 ----824'-5.755" i
3,38 ----824'-7.777" i
The shoe bearing surface should be as level as possible, not be exceed + 1 must be within 1/8" vertIca/8".
The supports ll'y, h" radially,
" tangentially.
Record final readings on j
Attachment # 1. Obtain appropriate signatures, w
The Leveling screw.:shall be set as close as r'
feasibly possible to the following elevations:
0 67 ------824'-7.004" EDR EDRMAT g gQU 1580-----824'-9.034" 247 -----824'-7.005" 3380-----824'-9*.027" e-
' 'ghe leveling screws must project 1" min.--l "
. max. above the shoe bearing surface.
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i CONSTRUCTION OPERATION TRAVELER CONTINUATION l
TRAVELER NO.
ACTIVITY DESCRIPTION ME-7 9-24 8-5 500_ m Reactor Vessel Installation PAGL3 0 b Eb PREPARED BY-AA DATE REVIEWED BY DATE ANI REVIEW DATE l
l s'
GA/OC OP. NO.
DEPT.
OPERATION ENG ANI 2
M/W Lower the R.P.V.
The vessel should be level to +
1" while suspended from the crane.
The s
QCW vessel must be orientated such that the inner j
i i
and out monitor tubes straddle the 2700 azimuth.
Lower the vessel to the point of contact with the leveling screws, taking care that the vessel weight is fully imposed on all screws.
Raise any screws not in contact with the under -
side of the vessel support pads, l
1 3
M/W Level the vessel to within.0005" per foot
(.007" overall) on the internals seating flange thru the access covers in the shipping fixture.
Raise the vessel and adjust the l
leveling screws as necessary.
Top of the l
seating flange should be set at elevation 832'-10.058".
Maintain vessel orientation using W supplied instruments in the four keyways.
Align the i
vessel to + 1/64" of containment axis.
A worksheet Yor leveling readip s ;.4 4 tac 4
_g UN b+
for field use.
l 4
F.E.
After obtaining proper elevation, level and orientation, recheck the calibration of all instruments to be sure no errors have be introduced. afj ANecAm/.5-
% 5.7-5-79 5
M/W Take height measurements between the under-QCW side of the vessel support pads and the support shoe bearing surface at four points 7g l
and reco2.C on Attachment i 2.
These results l
must be no less than 1.90".
Also record the reactor cavity temperature. QC to initial and date Attaciument 2. g
,.4,- 9p o pj g, 6
M/W Machine the permanent bottom shims to Q[
QCW dimensions of Operation No.,_5_. Tolerance to be
~
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CONS 1RUCTION OPERATION TRAVELER CONTINUATION TRAVELER NO.
ACTIVITY DESCRIPT!ON 4
1 E-79-248-5500 Reactor Vessel Installation PAG u g j
m
^
L PREPARED BY k
DATE $\\ EDI%
N'#~
REVIEWED BY k
DATE f
ANI R8! VIEW
<.1 DATE l
/
QA/QC OP. NO.
DEPT.
OPERATION ENG ANI j
i.001" -
0",
temp. 1 5 F.
7 INSVL While bottom shims are being machined, apply gj/}
R.P.V.
insulation per manufacturers supplied
,g QCM drawings and instructions. QC to write inspection l
report as required.
8 M/W Raise the R.P.V.
and lower the leveling screWE QCV until they are.375" +.010" above the bearing surface of the support shoes.
Install the hold 7-$f down nuts.
9 M/W Insert the bottom shim plates.
Do not allow QCy the bottom shim plates to be held off the bearing surface of the support shoe by the leveling screws.
EDR liiEDRMAilBil DBu 10 M/W Coat the top surface of the vessel pads with prussian blue.
Lower the vessel monitoring the vessel axis to the containment axis.
4 11 M/W Lift the vessel and check for surface contact II QCW between the top of the shim plates and bottom
,9
/,
of the support pads.
75% surface contact is
$7 IO required.
Itsnd ;diesss eh jujl sap s et. Mtpe@ Mde s M-es etairnehmt sumsawen necomwary.
1 wcopt 3.zarpf
?
07.209-j ov 12 M/W After required contact area has bee.n met, pt
@M QCy remove prussian blue from the contact surfaces,'h 7
and coat the top surface of the shim plates F.2 n with "molykote type Z" dry film lubricant, eg.[3 Buff to improve finish.
13 M/W Lower the vessel onto the shim plates.
Check the leveliness and axis orientation.
I s
CONSTRUCTION OPERATION TRAVELER CONTINUATION TRAVELER NO.
ACTIVITY DESCRIPTION 9
ME-79-248-5500_
Reactor Vessel Installation PAGL5,g PREPARED BY DATE N0b M~N REVIEWED BY DATE ANI REVIEW N
DATE QA/OC OP. NO.
OEPT.
OPERATION ENG ANI 14 M/W Take gauge readings of the sptees on either 7[
QCW side of the vessel support peC :, and record on Attachment #
3.
Also recorded cavity 730'O, temperature.
gOf 15 M/W Machine the side shims to the thickness D.
QCW recorded in Operation # 14 minus
.020" for 7
59 cold clearance.
Tolerance is + 0, -.001" 0
temperature + 5 F.
gg og 16 M/W Coat the surfaces of the side shims which will%)
QCV be in contact with the vessel support pads with "molykote type Z" dry film lubricant.
y#g Buff to improve) finish.
17 M/W Install the side shim in the support shoes.
Raise the vessel to a height necessary for top
{
installation of the shims.
Bolt the shim i
keepers onto the support shoes.
EDUE0ilMAILD 1 Ok u 18 M/W Lower the vessel and check levelness and vessel axis for orientation with containment axis.
Record and obtain approvals on Attachment # 4 19 M/W Verify cold clearance of.020" to 0" -.005" QCV for each side shim.
Sec pe d u /33 af, 7,y7p her.TcOSI 9e 20 QA review of operation traveler.y[f 1
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CONSTRUCTION OPERATION TRAVELER CONTINUATION TRAVELER NO.
ACTIVITY DESCRIPTION M(. -79 24 S. 5S00
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pjpg PREPARED BY D DATE d'3*l?9 C
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REVIEWED BY DATE ANI REVIEW
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DEPT.
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PREPARED BY M
DATE h !O <
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DATE 73 7~ ES '" 2 f REVIEWED BY DATE v
ANI REVIEW DATE QA/OC OP. NO.
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B&R EOUIPMENT LEVEL / LOCATION / ELEVATION / ORIENTATION RECORD
- 35-1195 Traveler i twE'M 2.wB t;&oDAtt.f i Hs) 1 z.7 w 5
Item Description R.?d. 6,0PPoRIT 5 Ref: Equipment Dwg.W o E G's WRev. 2
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P.O. # C P Ooosso.seMOUnit# ?-
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- 3S-1195 Traveler f mEM-2*B Ceco Att.f_ 4 Item Description GEht: Tem VE%Eu Ref:
c.- c Equipment Dwg.10"nh-ni-co4tey._ 0 Item Spin / Tag i "TC x -9. CPc GV-o s Location Dwg. m2. Sto Rey,9 P.O. #,LP - 00 0 )
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Pmsburgh Pemsytvrua 15230 January 10, 1986 S.O., No: TXUJ-2004(Q)
^
Mr. J. T. Merritt, Jr.
Ref:
- 1) Comanche Peak Assistant Project General Manager Flei d Traveler #ME ~
Texas Utilities Generating Company 248-5500 (Unit 2)
P.O. Box 1002
- 2) CPPA-48113 Glen Rose, Texas 76043 l
TEXAS UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION Consideration for Acceptance of the, Comanche Peak Unit #2
Dear Mr. Merritt:
As requested in customer letter CPPA-48113, Westinghouse offers the following_
considerations that form the basis for acceptance of the Unit 2 Reactor Vessel Support Shoe Side Gaps:
1.
The reactor vessel support shoe grows (thermally) slightly less than the RV nozzle pad.
Therefore, the required 0.020" (cold) side gap closes slightly to provide a small hot clearance.
2.
The remaining hot gap is necessary to account for shim undulations (i.e.,
warping, etc.) due to machining, thus ensuring binding will not occur.
3.
Once shims are installed, an average of the (4) corner gaps is determined I
and is considered representative of the installation.
Past experience indicates that shim warping during machining and shim alignment on the shoe can cause gap measurement inaccuracies.
4.
Cold gaps which are slightly in excess of the 0.020" (cold) requirement have no effect on the design / analysis of the reactor vessel support / reactor coolant leo system.
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J. T. Merritt, Jr. WPT_8148 Based upon the above, and a review of the data presented by Reference #1, the Unij 2 reactor vessel show side shim installations are found to be acceptable.
If there are any further questions or comments, please advise.
Very truly yours.
WESTINGHOUSE ELECTRIC CORPORATION -
fMM 4:h R. S. Howard, Manager WRD Comanche Peak Projects M.Torcaso/jjs/8682d:1 cc:
J. T. Merritt 1L R. D. Cal der 1L J. W. Beck 1L C. B. Hartong 1L J. C. Kuykendall 1L ARMS 1L J. B. George 1L R. A. Jones 1L E
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ENCLOSURE 1 Inspection Report 85-07/05 Issue No.1 (Attachment 1 to Attachment M-M) 1.
Definition of Issue
"(a) Unit 2 reactor pressure vessel installation design criteria recommended by the nuclear steam supply (NSSS) vendor, such as centering tolerances, levelness tolerances, and shoe to bracket clearances, were not included in installation specifications, procedures, and drawings; and (b) the criteria were specified in Construction Operation Traveler ME-79-248-5500, but were not treated as design engineering criteria as evidenced by an undocumented change of shoe to bracket clearance."
2.
Understanding of Issue i
My undefstanding of this issue was based on information gathered at the time of the inspection ar<:! subsequent discussions with the license and his contre tors prior to the time of the CIA investigation. Inspection criteria and guidelines were based on the following:
a.
Regulatory Requirement - 10 CFR 50 Appendix B, Criterion III I
" Measures shall be established to assure that applicable regulatory requirements and the design basis... are corre'etly translated into -
specifications, drawings, procedures, and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standa-ds are controlled.... Measures shall be established for the identification and control of design interfaces-and for coordination among participating design organizations. These measures shall include the establishment of procedures among partici-pating organizations for the review, approval, release, distribution and revision of documents involving design interfaces.... Design changes, including field changes shall be subjected to design control measures commensurate with those applied to the ort inal design and be approved by the organization that performed the ori inal design unless the applicant designates another responsible organi ation."
b.
Licensee Coenitment - TUGCo QA plan, Section 3. Revision 3, dated July 31, 1984, requires the appropriate site engineering organization to prepare design specifications which are translated into instructions, procedures, drawings, or specifications, c.
NRC Inspection Guidance - IE Module 50053-02.b(4)ftheinstallation "0bserve the installed reactor vessel and, based on a review o specifications, drawings, and work procedures, identify a number of 1
requirements such as vessel support structures, vessel-to-support structure fittings, number and location of support structures and mounting pads, hold down devices, shimming. devices, and alignment requirement, and determine whether:
8 1
.,A.
2 l
I work procedures have been or are being followed, installation is in accordance with specifications and procedures, and inspection (QC) procedures are being followed."
At the time of this inspection, the RV was already in place, therefore, records of the placement were reviewed to verify proper placement. Construction and Operation Traveler No. ME-79-248-5500 which provided field instructions for installing the vessel was reviewed. Several drawings prepared by the site engineer and referenced by the traveler, were reviewed. None of the drawings included installation tolerances. A Westinghouse installation procedure referenced by the traveler was also reviewed.
The Westinghouse installation procedure raa+aiaad car + min (as+=11mtion tolerances wnicn were reconnended. hut i+=== ahwian=1v an uniontroiseo cocumant.which had no provisions or requirements for change control. Certain tolerances (support bracket to shoe) specified on the traveler complied with MSSS recommendations, but had been changed and established change control procedures had not been followed. It was my position that placement of the reactor vessel by the site construction contractor involved an interface between the site designed cavity and support structure and the NSSS contractor and that site specifications and drawings, prepared and controlled by change control procedures, should have been developed to im>1ement site engineering and NSSS contractor requirements. Any tecinict.1 changes would then require a coordinated engineerin would be implemented by the construction traveler. g change which 3.
Safety Significance This issue could result in a hardware problem because of the uncontrolled tolerance change. It was impossibic at the time of the inspection to make this determination and an analysis would be required by the licensee.
Equally at important is the generic implications of changing design or interface criteria with no documentation to support the change.
4 daderstanding of How Issue Was Mandled by Management L
This issue was documented as a violation by the inspector and changed to an unresolved item by management. Since an unresolved item requires no licensee response, it is not certain what will be involved in closing the 2
apptogriate engineering document and provided no further instructions to ites. Management stated to me that the considered the traveler to be an Since I am no longer invoTved with CPSES, I am not aware of any NRC me.
follow-up of this item.
ISSUE #8 FROM ATTACHMENT MM TO OIA REPORT 86-10' INSPECTION REPORT 50-445/85-16; 50-446/85-13 NAMC0 switches IEB-79-28 were not properly identified on travelers.
Issue As Understood by the Comanche Peak Report Review Group During a routine NRC inspection of Comanche Peak Steam Electric Station (CPSES) conducted in November 1985, the Senior Resident Inspector identified inconsistencies between certain NAMC0 switch model numbers identified on the i
installation instructions (travelers) and the model numbers on the installed hardwareintheplant.II) The concerns raised by the Inspector with respect f
to this issue include deficiencies in documentation and delay associated with [
t filing documents in the master data base and QA vault.
In addition, in documenting the results of its review, OIA raised a concern related to the i
adequacy of the hardware.(2)
DISCUSSION I
On December 7,1979, the NRC issued IEB 79-28, "Possible Malfunction of i
NAMCO Model EA 180 Limit Switches at Elevated Temperatures".. The purpose of l
the Bulletin was to alert the industry to a deficiency in certain manufactured l
lots of NAMC0 EA 180 limit switches. NAMCO CONTROLS, the switch manufacturer, had detennined that the switch top cover gasket would emit a resin vapor at I
temperatures above 175'F. This vapor could condense into deposits on the l
normally open contacts, possibly causing a switch malfunction.
By letter dated March 24, 1980, from R. J. Gary (TUGCO) to Karl V.
Seyfrit (NRC), the applicant for CPSES responded to IEB 79-28.
In this response, n
2 the applicant stated that fourteen EA-180 NAMC0 switches required replacement of the top cover gasket, none of the switches had been put 'in service or-exposed to ambient temperatures of more than 175'F, and that the replacement gaskets were being ordered from NAMC0 and would be installed by June 30, 1980.
Subsequently, by letter dated July 30, 1981, from R.
J-. Gary to Karl V. Seyfrit, the applicant revised its earlier response to IE8 78-28.
In its revised response, the applicant stated that due to difficulty experienced resolving environmental qualification concerns, all switches within the scope of IEB
,I 79-28 would be replaced prior te piant operation.
During a routine NRC inspection of CPSES conducted in November 1985, the Senior Resident Inspector focused his attention on the applicants actions in response to IEB 79-28. During the course of the inspection, the Inspector identified inconsistencies between certain NAMC0 switch rendel numbers identified on the installation instruction (travelers) and the model numbers f
on the installed hardware. Specifically, the NAMCO limit switches on residual heat removal (RHR) system valves 1-HCV-606 and 1-FCV-618 were identified on travelers EE 82-1415-5801 and EE 83-0373-5801 as EA 180-32302 and EA 170-31302, respectively. The switches actually installed in the field were identified as EA 180-31302 and EA 180-31302.
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I SAFETY SIGNIFICANCE A.
DOCUMENTATION DEFICIENCY I
J. Durr input on safety significance of master data base, travelers and TUGC0 inspection documentation not matching the NAMC0 switches installed in the field.
In addition, input on safety significance of not having the travelers in the master data base or QA vault for more than a year after the travelers were completed.
(See pages 16 and 17 of attachment iti).
V' j
B.
HARDWARE DEFICIENCY i
In assessing the safety significance, the Inspectors findings the CPRRG analysed the worst-case assuming that the wrong switches were installed and that this situation existed without correction or recognition. Based on this review, the CPRRG detennined that the worst-case scenarios are not safety significant.
In perfonning the worst-case assessment to determine the safety significance-associated with the NAMCO switch concern, the CPRRG reviewed the CPSES FSAR, information provided by the switch manufacturer, NAMCO CONTROLS, and TU ELECTRIC,
- and discussed the issue with their representatives.
As shown on Figure 5.4-6 of the CPSES FSAR (3} both valves 1-HCV-606 and 1-FCV-618 are located in the "A" train of the Unit 1 system. Valve 1-FCV-618 is on our diaphragm operated butterfly valve utilized to control by pass flow around the "A" RHR heat exchanger. Valve 1-HVC-606 is on air diaphragm operated butterfly valve utilized to control discharge flow from the "A" RHR heat exchanger.
The i
function of the NAMCO switches identified by the NRC Inspector is to provide remote valve position indication with readout in the control room.
4 B.
HARDWARE DEFICIENCY - CONTINUED l
In assessing the safety significance of an error involving the installation of the CPRRG evaluated the consequences of having switch model I
number EA 180-31302 on 1-FCV-618'in lieu of switch model number EA 170-31302.
3 Based on its review, the CPRRG detemined.that the switches differ in their construction and capability to function in a' hostile environment. I4)
Although both EA 180 and EA 170 switches are designed to function in a high
~
radiation field, the EA 180 series switches have been designed _to function in
[
/
i containment following a design bases accident under harsh environmental conditions with elevated temperatures,and pressures. Therefore, the consequence of the worst case is that a switch designed to withstand a harsh environment associated with past accident in-containment conditions was
\\
installed where only the capability to perform in a mild environment was required.
In assessing the safety significance of an error involving-the installation of switch model number EA 180-31302 on valve 1-HVC-606 in lieu of switch model number 180-32302, the CPRRG deterinined the worst-case result in a non-functional valve position indicator. Based on its review, the CPRRG determined that the switches differ in the internal return spring g
configuration. The EA 180-31302 switches are set up at the factory to operate in the clockwise directio' I4)
The consequence of this error, if not detected, would be a false indication of valve position in the control Although this false indication could be misleading to the plant room.
oporators, the CPRRG concluded that worst-case was not safety significant.
l i
6 i
REFERENCES 1,
Letter to Texas Utilities Generating Company from E. H. Johnson (NRC) dated April 4, 1986.
2.
01A Report 86-10, Attachment MM, Technical Review of PHILLIPS' Issues Contained in Comanche Peak Inspection Reports, prepared by Stephen GOLDBERG.
3.
Comanche Peak Steam Electric Station Final Safety Analysis Report, Units 1 and 2.
Docket Numbers 50-445 and 50-446.
4.
NAMC0 Limit Switches and Quick Connectors for Nuclear Environment, Series EA 180-302/602-Rev. and EA-170-302/602 Rev., 3M/5-85.
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March 23, 1987 Note to:
Robert Erickson From:
Lawrence J.
Chandler
SUBJECT:
DOCUMENTS RESPONSIVE TO GAP FOIA REQUEST 87-87 In accordance with Guy Arlotto's memorandum dated February 25, 1987 and our conversation of this date, attached are ' copies of the following documents in my files which appear to be responsive to the referenced FOIA request and which are not listed in your catalogue of documents collected or prepared by the CPRRG:
1.
Review Group Mailing List 1/13/87 2.
Listing of Documents Received by
- CPRRG, dated 1/.15/87 3.
Comanche Peak OIA Report 86-10 Review Group (CPRRG) and Principal Contact
- Persons, dated 12/19/86 4.
Memorandum, Davis to OGC,. undated
- draft, subject: Issues Raised by OIA Report 86-10 Having Broader Implications For Region IV In addition, it is not clear from your catalogue whether the following documents are included among the enclosures attached to item 2 of CPRRG ADMINISTRATIVE DOCUMENTS:
5.
Memorandum, Stello to Martin, subject:
OIA REPORT REVIEW OIA FILE
- 86-10, DRAFT 12/17/86-A 6.
Memorandum, Stello to Davis, subject:
DIA REPORT REVIEW:
OIA FILE
- 86-10 ESTABLISHMENT OF REVIEW
- GROUP, DRAFT 12/17/86-A 7.
Draft Press
- Release, NRC'S EXECUTIVE DIRECTOR APPROVES ACTIONS AT REGION IV 0FFICE IN COMANCHE PEAK MATTER, undated Copies of documents 5 - 7 are attached for your records.
hh&GQh.
/
Lawrence Chandler
, gi; Attachments: As stated 0
9 qQ#
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1
~
i
/
_ COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP (CPRRG) 5520 Local NAME TELEPHONE _
MAIL STOP _
Node Name Address John G. Davis, NMSS, Chairman 42-74063 958-SS ~~
NRCADMW BONNIEP Guy A. Arlotto, RES 44-37995 NL-005 NRCRES MCCAUSLA Clemens J. Heltemes, Jr., AE0D 49-24484 EWS-263 NRCIE AE00 Carl J. Paperiello, R-III FTS-388-5517 R-III NRCRIII LEAD 0P James Liebeman, OGC Legal Advisor 49-28679 9604 NRCELD CONNIET Robert A. Erickson, NMSS Coordinator 42-74194 881-SS NRCADHW BEVERLYC PRINCIPAL CONTACTS Robert D. Martin, R-IV FTS-728-8225 R-IV NRCRIV LEAD 0P Vince Noonan, NRR 49-27425 110 NRCDPLA SIMS j
James M. Taylor, IE 49-27397 EWW-322 NRCIE IEDIR OTHER CONTACTS AND INTERESTED PERSONS q
Eric Beckjord, RES 44-74341 NL-005 Lawrence J. Chandler, OGC 49-28658 9604 NRCELD ANNIEB Paul S. Check, R-IV FTS-728-8222 R-IV NRCRIV LEADOP Harold Denton, NRR 49-27691 P-433 Alexander W. Dromerick, IE 49-24784 EWW-507 Jack R. Goldberg, OGC 49-27619 9604 NRCELD CONNIET Ramon E. Hall, R-IV FTS-728-8182 R-IV NRCRIV LEAD 0P Eric H. Johnson, R-IV FTS-728-8106 R-IV NRCRIV LEAD 0P James G. Keppler, R-III FTS-388-5181 R-III NRCRIII LEAD 0P James E. Konklin, IE 49-29656 EWS-312 NRCIE VI George A. Mulley, Jr., OIA 49-24451 EWS-461 James G. Partlow, IE 49-24614 EWS-360 NRCIE EILEEN H. Shannon Phillips, R-IV (817) 897-2201 R-IV NRCRIV LEAD 0P Thomas A. Rehm. ED0 49-27781 6209 NRCRM EDO Ronald M. Scroggins, IRM 49-24750 12109 R. Lee Spessard, IE 49-28833 EWS-350 NRCIE EILEEN Annette Vietta-Cook, NRR 49-28525 110 NRCDPLA SIMS Thomas F. Westeman, R-IV FTS-728-8145 R-IV NRCRIV LEAD 0P REVIEW GROUP MAILING LIST 01/13/87
1 f
s 04u9):28+52/l H.
n o9 A
^
\\W t
m
c, 34 12/19/86 COMMANCHE PEAX OIA REPORT 86-10 PEVIEW GROUP (CPRRG)
I NAME
~
EXTENSION MAIL STOP John G. Davis, NMSS, Chairman 74063 958-5S Guy A. Arlotto, RES 37995 NL-005 Clemens J. Heltemes, Jr., AE00 24484 EWS-263 s
l Carl J. Paperiello, R-III 38-85517 R-III l
l James Liebernan, OGC, Legal Advisor 27486 9604 l
9 Robert A. Erickson, NMSS, Coordinator 74194 881-SS j
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PRINCIPAL CONTACT PERSONS l
Eric Beckjord, RES 74341 NL-005 t
Paul S. Check, R-IV 728-8222 R-IV Harold Denton, NRR 27691 P-433 j
Eric H. Johnson, R-IV 728-8106 R-IV James G. Keppler, R-III 388-5181 R-III i
Robert D. Martin, R-IV 728-8225 R-IV I
George A. Mulley, Jr. 0IA 24451 EWS461 Vince Noonan, NRR 27425 110 l
Harry Phillips, R-IV (817)897-2201 R-IV Ronald M. Scroggins, IRM 24750 12109 James M. Taylor, IE 27397 EWW-322 I
Thomas F. Westennan, R-IV 728-8145 R-IV l
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MEMORANDUM FOR:
OGC FROM:
John G. Davis, Chairman I
Comanche Peak Report Review Group SUBJEC7:
ISSUES RAISED BY OIA REPORT 86-10 HAVING BROADER IMPLICATIONS FOR REGION IV In the Chairman's January 15, 1987, memorandum to the EDO, the Commission requested the CPRRG to offer the EDO its judgement on whether the problems identified at Comanche Peak are isolated or there are broader implications in Region IV.
The CPRRG requests OGC assistance in addressing this issue.
Specifically, based on OGC's completed review of the OIA report, what issues, if any, are raised which the CPRRG should consider as potentially having
" broader" implications for Region IV?
OGC's suggestions, as well as those of others, will be valuable to the CPRRG in reaching its judgement on which issues, if any, have broader implications.
)
The CPRRG appreciates your assistance on this matter.
NOTE:
OGC's response will identify four issues:
1.
Regional management's interaction with inspectors and management's role in reviewing, revising, and approving inspection reports.
2.
Any identified failures of Region IV to carry out inspection modules.
I 3.
Whether Region IV treated Comanche Peak differently from l
other plants; if not, then broader implications are likely.
1 4.
The state of the NRC Form 766 system at Region IV.
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UNITED STATES 8
g NUCLEAR REGULATORY COMMISSION n
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WASHINGTON, D. C. 20066 DRAFT 12/17/86-A-1 MEMORANDUM FOR: Robert Martin Regional Administrator, RIV FROM:
Victor Stello, Jr.
Executive Director for Operations
'1
SUBJECT:
OIA REPORT REVIEW - OIA FILE #86-10 l
l I have reviewed your memo to me of December 17, 1986, which outlines your proposals for dealing with actions necessary to respond to the points raised in the subject report.
l l
By separate memo (see Enclosure 1) I have established a Review Group, with I
John Davis, Director, Office of Nuclear Material Safety and Safeguards as l
Chairman to conduct the review of technical issues as you recommended.
I approve your suggestion to detail T. Westennan and H. Phillips full-time to be at the disposal of the Review Group until their work is complete on or about January 30, 1987.
I approve the actions you recomend in regard to initiating remedial action wit.hin Region IV staff to assure a proper understanding of regional policies in regard to resolution of staff / supervisor problems, supervisory responsibilities and to develop an improved inspection report tracking l
system. -You will advise me separately of specifics of implementation of these actions.
I agree with your coments in regard to the OIA conclusions on Allegation III (Data documented in Inspectors Reports).
I am withholding a decision on Allegation I (Management issues) and Allegation II (the adequacy of the inspection program at CPES) until the completion of the Review Group's efforts.
Victor Stello, Jr.
Executive Director for Operations As stated i-
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ENCLOSURE 2
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%o UNITED STATES
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NUCLEAR REGULATORY COMMISSION o
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,I WASHINGTON, D. C. 20666
- OP. AFT 12/17/86-A MEMORANDUM FOR: John G. Davis, Director Office of Nuclear Material Safety and Safeguards FROM:
Victor Stello, Jr.
Executive Director for Operations
SUBJECT:
OIAREPORTREVIEW$OIAFILE#86-10-ESTABLISHMENTOF REVIEW GROUP In order to resolve issues which OIA Report 86-10 has raised, I am taking the following action:
1.
You are assigned as Chairman of a Review Group to resolve issues as described below.
G. Arlotto, J. Heltemes and C. Paperiello are assigned as members of the Group.
2.
The task of the Review Group is to review the technical issues identified in OIA report 86-10 and to determine and document in a report to me (1) the safety significance of those issues for Comanche Peak, i.e.,
whether actions should be taken to rectify any unsafe conditions;'
l (2) whether the issues when identified were appropriately handled as to process and disposition; and, (3) determine whether the current augmented review and inspection effort at Comanche Peak is sufficient to compensate for any identified weakness in Region IV's Q/A inspection programs.
3.
You may task other NRC staff or utilize contractors as required, although I recommend that you keep your requirements to the minimum possible.
Necessary funds will be made available at your request by RM.
T. Westerman and H. Phillips will be detailed to support your independent review on a full-time basis; other members of RIV are at your full disposal as you may require. Similarly, IE and NRR staff working on Comanche Peak are available to assist.
4 Copies of the report and enclosures will be provided to you by separate cover.
5.
I would like to have your report in my hands by January 30, 1987.
Victor Stello, Jr.
Executive Director cc:
_E. Beckjord R. Martin G. Arlotto R. Scroggins J. Taylor
}
H. Denton J. Keppler E: M M '
ENCLOSi1RE 3
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-DRAFT PRESS RELEASE-
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NRC'S EXECUTIVE DIRECTOR APPROVES ACTIONS-AT REGION IV 0FFICE IN COMANCHE. PEAK MATTER Victor Stello, Jr., Executive Director for Operations of the Nuclear Regulatory Commission, has approved a' series of actions to deal with the findings of a report from the NRC's Office of Inspector and Auditor on the l
performance of officials at the agency's Region IV Office at Arlington, Texas, concerning the handling _of safety issues involving the Comanche Peak Nuclear Powef Plant at Glen Rose, Texas. The Commission has approved these actions, and is continuing its review of the matter.
The Office of Inspector and Auditor completed its report on November 26.
It deals with allegations made by an NRC inspector at the Region IV offi A
sumary of this report, with deletions, was made public on December 11.
Mr. Stello has formed a special review group headed by John Davis, Director of NRC's Office of Nuclear Materials Safety and Safeguards, to review the technical details of the OIA report to determine (1) the safety I
significance of the issues for Comanche Peak and whether actions should be taken to rectify any uns'afe conditions; (2) whether the issues when identified by Region IV were appropriately handled; (3) whether the current augmented NRC l
review and inspection effort at Comanche Peak is sufficient to make a finding of reasonable assurance on the safety of construction without relying on -
Region IV's previous inspection program.
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The NRC inspector at Region IV and his supervisor have been detailed temporarily from their present duties ti be at the disposal of the review group until the work of the group is complete.
"I have appointed this specitl review group, headed by a senior NRC official, to get an independent view of the matters covered by the OIA re' port. 'I have requested a, report to me by January 30,1987," Mr. Stello said.
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In'. addition, Mrs Stello has approved recommendations from Robert Martin,
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Region IV Administrator, that regional technical staff and supervisors be retrained concerning regional policies which set out the obligation of both the staff and supervisors and management to escalate disagreements promptly so that they can be resolved. Mr. Martin also has directed that an improved inspection report tracking system be developed to identify those reports that are unacceptably delayed in the various stages of preparation, review, approval and distribution. This new system is to be in operation by February 15, and will alert senior regional management of possible instances of protracted review of reports.
Training will be conducted for all Region IV supervisors to remind them of their proper supervisory responsibilities, including the need to give adequate direction and guidance, and to identify and document weaknesses they discern in their subordinates.
Supervisors will be held accountable for developing suitable individual development plans to address any problems.
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PROCEDURE ISSUE l
h CPSES NUMBER REVISION DATE PAGE JOB 35-1196 CP-CPM-6.3 5
12/13/78 3 of 11 2.2.2 When implemented as outlined in this procedure, the operation traveler system fully complies with the QA criteria and no additional controls are required.
If only partially imple-mented, then additional controls in the form of supplementary instructions may be required to meet.the applicable require-ments. The provisions of References 1.1 and/or.1.2 may be utilized to supplement a partially implemented system.
2.3 AUTHORITY AND RESPONSIBILITY 2.3.1 Signature authority on a Construction Operation Traveler rests with either the Construction Superintendent (s) responsible for 1
the work or with the Construction Engineer (s) responsible for technical guidance. The site QC Manager is responsible through the discipline Quality representatives to assure that the system l
is effectively implemented for the selected activities.
2.4 DESCRIPTION
OF AN OPERATION TRAVELER-h 2.4.1 The operation Traveler (Figures 2 and 3) serves as a fabri-cation / installation / inspection checklist describing operations necessary to achieve a quality and product in an efficient manner. Accordingly, the details recuired and included on the face of the traveler will vary depencing on the complexity of 1
the operation.
2.4.2 General-information included on the operation. traveler is as follows:
a.
Part, serial or tag number and material description (s),
where applicable, b.
The department assigned the task to perform the operation (s). This is normally's'hown in the space provided on the traveler but may be documented in an alter-nate manner for simple operations, c.
Operation description, methods, procedures (instructions) by number and revision and other information as required to successfully complete the operation per applicable requirements.
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BROWN & ROOT, TNC.
PROCEDURE ISSUE
,G' CPSES NUMBER REY!SION DATE PAGE i
JOB 35-1195 CP-CPM-6.3 5
12/13/78 4 of 11 l
d.
All dimensions and tolerances necessary to assure com-I pliance to design drawings and specifications. "This in-formation may be given by Reference, provided persons per-forming the work have access to the Reference.
e.
Any needed offsite operations or processing cited in the appropriate sequence with all other operations.
i f.
Necessary instructions for handling, cleaning, storage and -
preservation of items.
9 Required QC inspection, hold, or witness points.
h.
A bill of material for piping component supports.
2.5 TITLES 2.5.1 Titles, when used in this procedure apply to the specific person or his designee.
3.0 PROCEDURE g
3.1 BASIC PREPARATION SEQUENCE 3.1.1 Samples of the Traveler forms are shown in Figures 1, and 2.
l These forms may be obtained from the Construction Engineer.
l The operation sequence and necessary detailed information to' be written on the traveler will be developed as a joint effort between the B&R construction craft personnel responsible for doing the work, construction engineering personnel re-i I
sponsible for technical requirements, and da/QC pernnnel responsible for Quality Assurance requirements.
It is desirable to include all required information (such as dimen-sions, specification data, and required supplementary instruc-tions) with the Traveler to make a complete " Traveler Package".
l However, the inclusion of information routinely available to the persons performing the work is not a requirement.
The sequen-l tial numbers assigned to each operation on the traveler are for identification purposes and are not necessarily a sequential order of work progression.
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PROCEDURE ISSUE f}
CPSES NUMBER REVISION DATE PAGE V
JOB 35-1195 i
l 12/13/78 5 of 11 l
3.1.2 The discipline construction engineer is responsible to assign numbers to Operation Travelers, and to keep a logbook record of the numbers. The traveler numbering system 1,s as follows:
Example, "MR79-001-5000" M = discipline (Mechanical, electrical, etc.)
l R = department (rigging, rebar, pipe, concrete,etc.)
1 79 = The calendar year in which the Traveler was written.
001 = The individu'al sequence number identifying a particular Traveler.
5000 = The turnover (start-up) system number for g
.the activity described on the Traveler.
NOTE For mechanical component supports the traveler number will be the component support identification number (if more than one traveler is required for a specific support, the mark number shall' be suf-fixed by a-1 for the first additional traveler, etc.).
For electrical cable tray supports the traveler num-ber will be the support mark number prefixed by " Ele-79-CTH" (79 represents the year in w11ch the traveler was prepared).
These are the only exceptions to the above numbering system.
3.1. 3 When a Traveler is prepared and ready for signature, it shall be submitted to QA/QC for review, the addition of inspection hold or witness points ANI review, and signature. QA/QC will not be required to review each cable tray hanger Traveler as each operational document will be identical except for the Tray-eier number.
3.1.4 After reviewing and signing, QA/QC shall return the Traveler to the originator for distribution to the fieldt except component support travelers shall be sent directly to weld-ing engineering to be distributed in the same manner as%C.:
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per Reference 1.4. All QA/QC/ANI/ Engr. signeffs will be on v
the " original" making it the valid working document. At the discretion of the QA Manager, a copy of the traveler may be j
filed in the QA vault for record retention. purposes.
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BROWN & ROOT, INC.
PROCEDURE ISSUE CPSES NUMBER REVISION DATE PAGE h
JOB 35-1195 CP-CPM-6.3 5
12/13/78 6 of 11 1
3.2 ENGINEERING REVIEW 3.2.1 At the request of the responsible General Superintendent, the Chief Project Engineer through the responsible'01scipline Engi-neer shall complete reviews of applicable drawfngs, specifica-l tions, procedures, and welding requirements to assure undtr-l standing of and compliance with applicable design and construc-tion requirements.
3.3 QA/QC REVIEW 3.3.1 The Quality representative will perform a spot check of the com-plated forms for accuracy of informelon and w111' verify that i
required inspection, hold and witness wints have been included.
l He will assure that quality documents save been prepared per the
- provisions of Reference 1.2 'and are referenced in the Operation Travelers as required to fully implement the QC functions.
3.4 RECORD COLLECTION 3.4.1 Traveler packages shall remain in the work area until the work described by the package has been completed and accept-ed by the responsible QC Inspectors. Component support travelers may be returned to the FWTC (in the same manner as WDC as stated in Reference 1.4) at the end of each work shift or when the final sign-off is completed.
3.5 LOT RELEASE AND CONTROL 3.5.1 Lot Release 3.5.1.1 Quantities of identical detail parts or items may be authorized by the Quality representative on one Traveler package release provided the parts or items are dimensionally identical and that material control and/or traceability requirements can be accomo-dated without creating an extensive and/or confusing record keep-ing or material marking system. The quantity of parts or. items to be included in one lot may be determined by the quantity of parts required to fabricate one assembly or sub-assembly, or a quantity of parts that could remain as one lot until all parts or items are completed without jeopardizing the production schedule.
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PROCEDURE ISSUE
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CPSES NUMBER REVISION DATE PAGE j
'd.-
J08 35-1195 l
12/13/78 7 of 11 3.5.2 Lot Control 3.5.2.1 A quantity of identical parts released as a lot on.a single Traveler package release shall remain together until all oper-ations have been completed and accepted by inspection, and the parts / items have been delivered to storage or to another Trav-4 eier release for subsequent assembly / installation.
If a non-conformance is' detected on one er mo're parts / items of a lot dur-
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ing the operations, the conforming material and Traveler shall remain in a designated hold area.until the nonconformance has been adequately dispositioned.
The site QC Manager may author-ize certain exceptions to this rule.
Sech matters will be handled on a case basis.
3.5.2.2
. If certain parts / items are.dispositioned " Scrap" the quantity of the lot on the Traveler shall be reduced to the quantity found to be acceptable by inspection.
Replacement items, when required, shall be issued on another Trt.veler, reflecting a new release number.
If an item or items _11 a lot requires repair, such as welding, the entire lot shall be serialized and appropriate records prepared to establish traceability for.
Q repairable items as required by applicable codes-and specifica-tions.
3.6 TRAVELER CHANGE CONTROL 3.6.1 All changes, regardless of their significance, must be doc-umented on the Traveler, denoting the operations affected, description and authority for the required change, and the Quality representative's approval. The revision number and a description of the change will be noted on the traveler below the last traveler operation of the original issue.
If necessary the revision description may be continued on a continuation sheet. -The back side of the traveler for piping component supports will also depict the revision in the re-vision block.
3.6.2 When design changes are received that affect issued and approv-ed travelers, construction engineering shell notify the superin-tendent immediately. The applicable changes will be made to the traveler and it will then be reviewed in the same manner as the original issue. At the superintendent's discretion, work may continue on the traveler operations not affected by the design change.
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PROCEDURE ISSUE CPSES NUMBER REVISION DATE PAGE JOB 35-1195 CP-CPM-6.3 5
12/13/78 8 of 11 3.7 TRAVELER "IN-PROCESS" AND " COMPLETED" CONTROL 3.7.1 Travelers shall be maintained complete throughout the construc-tion process.
Each QC Operation requires the initials and date' by QC denoting the inspection status.. This shall be accomplished at the completion of each operation and prior to moving' parts or assemblies to the next operation, unless otherwise noted on the Traveler.
l 3.7.2 It is expressly prohibited to proceed beyond any hold point requested by the Quality representative without his approval, reflected.by his initials and date at the applicable operation on the Traveler.
3.7.3 The Quality Control Manager is charged with the responsibility for assuring that all operation Traveler instructions have been complied with and all previous operations have been performed and accested. The Discipline Inspection Supervisor is responsi- -
ble to tie Quali'ty Control Manager for the assurance that all V
completed items, assemblies or sub-assemblies meet the require-ments of the applicable drawings and specifications - by inspection and acceptance of all items denoted on the Traveler and associated check lists or instructions. After all operations listed on the traveler have been completed and appropriately signed, the department supervisor implementing the work will submit the traveler to construction engineering, or to the FWTC for component support travelers.
The discipline con-struction engineer will log such receipt of the traveler l
and in turn if "Q" related, submit it to the QC Department l
for incorporation into the CPSES documentation system.
Travelers for Non "Q" items will be processed in accordance with Reference 1.3.
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PROCEDURE ISSUE CPSES NUMBER REVISION DATE PAGE h
408 35-1195 CP CPM-6.3 5
12/13/78 9 of 11 FIGURE 1A SAMPLE TRAVELER FIRST SHEET - Front Side -
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PROCEDURE ISSUE V
CPSES NUMBER REVIS!0H DATE PAGE JOB 35-1195 CP-CPM-6.3 5
12/13/78 10 of 11 l
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PROCEDURE ISSUE CP5ES NUMBER REVISION DATE PAGE JOB 35-1195 CP-CPM-6.3 5
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