ML20237K987

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Revised Section 9.0, Identification & Control of Items, to QA Plan.Related Documentation Encl
ML20237K987
Person / Time
Site: Comanche Peak  
Issue date: 10/31/1984
From:
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20237J194 List: ... further results
References
FOIA-87-87, FOIA-87-A-14 NUDOCS 8708270373
Download: ML20237K987 (21)
v • d • e


Text

_ _ _ _.. _ _

ISSUED NO.

09/17/81 See, 9.0 IDENTIFICATION AND REVISED PAGE CONTROL OF ITEMS 007 91 !gga 1.of 4 i

9.1 SCOPE 3

4 5

This section establishes the controls for assuring that 6

items and materials, including partially fabricated 7

e subassemblies, retain their identification and required 8

traceability from time of receipt through installation.

10 11 12 9.2 METHOD OF IDENTIFICATION i

13 14 1s Materials an'd items shall be' 1'dentified by markings which '

v2.11 not ' result in harmful contamination or sharp 17 discontinuities.

Identification may be by stenciled', etched i

10 or indented markings, strip. markings, imprinrad. cape, color l

20 coding 'or tags. ' S t ampin'g, when used,.shall be done 'with 21

.e low stress stamps.

22 23 24 Such identification shall 'be legible and shall be located l

l 26 in areas that will not interfere with the function or l

I quality aspects of the item.

28 29 l

30 f

31 l

32 l

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.i 33 I

34 35 EXHIBIT 36 3e i.

37 s

38 l

39 40 Do Not REPRODUCE 8708270373 870819 PDR FOIA QA 022 0 02 8U BAUMAN87-A-14 PDR

esdad17/81 wo. Ss e. 9. 0.

IDENTIFICATION AND-CONTROL O'F ITEMS PAGE of 4 nbvistoCT 311984 1

2 3

9.3

, IDENTIFICATION DURING RECEIVING 5

6 7

During receiving inspection, the Receiving Inspection Group 8

(RIG) shall verify that the materials and items have identification markings io as required by the purchase order and/or appropriate receiving inspection instructions.

12 13 14 9.4

. MATERIAL ISSUANCE 15 16 17 All items and materials, except welding materials (See Sec. 10), shall be issued from storage by means of a 19 Material Requisition form,(MR; ' Exhibit 9.1) prepared by the j

2r craft superintendent.

The MR shall'.contain;.as a afinimum, 22 the following information:

as 24 a.

Item description; 25 b.

Quantity requested; and 26 27 c.

Intended use 28 29 Item identification (e.g. heat number or code, tag number, 30 or serial number); is entered'on MR by warehouse personnel.

at 32 as RIG shall verify that material is as specified on the 34 35 MR and acceptable for release to construction and shall se document the verification by dated initials / signature on 37 3a the MR.

39 40 1

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, OA 022 0 to.:

IISUEO

. No.

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09/17/81 Ssc. 9.0 IDENTIFICATION AND tF PAGE' CONTROL OF ITEMS-REyDgI.3 1 1984 3 of 4

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1 2

9.5 MARKING TRANSFER 3

4 s

Material shall carry identification markings which will remain distinguishable until the item is assembled or 7

installed.

Identificat1on of assembled or installed items.

1 8

requiring beat number / heat code traceability,- shall be 10 documented by the QC Croup on fabrication and/or inspection i

12 records.

13 14 If the original identification inarkings will.be i

7 cut.off or 33 j

16 the material is divided,, the markings. shall. be transferred 17 by construction prior to division.

The QC. Group shall 18 l

~

s.

se verify prior to the division.of material' that-the markings I

have been properly transferred.' This verification shall be 2:

l documented by the.QC' Group's dated signature on' the

-l 23 Manufacturing Record Sheet (MRS; Exhibit 10.13) or the 1

24 Material Identification Log (MIL; Exhibit 9.2), for piping 25 and component supports, respectively.

26 27 28 20 30 31 32 33 34 1

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36

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i 40

.r oo NoT REPRooUCE A

, CA.022 0 (12 81;

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6 IDENTIFICATION AND CONTROL OF ITEMS DbY 011984 " k of 4 '

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2 9.6-NAME PLATES FOR N-STAMPED COMPONENTS

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3

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4 At the time of fitup or mechanical. installation inspection, o

the QC Group shall verify that N-stamped items have ~ a Code 7

I name plate attached, and enter the serial number of the Code 8

name plate on the Weld Data Card or the Operational Traveler.

i If the Code name plate is missing the item shall be handled 11 in accordance with Section 16.0.

13 14

-1 9.7 LOSS OF IDENTIFICATION.

15

,l 16

'7 Materials or items for which the identification cannot be 18 i

established on the material, or documentation traceable to l

19 i

i the material, shall be considered noncon' forming and shall be 20 handled.in accordance with Section<16.0,'.

22 23 l

1 24 1

25 26 27 28 29 30 31 32 33 34 35 as

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37 36

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Do NoT REPRODUCE oA.022 0 (12 r.t O

Reactor conlant Prdssure Boundary Piping - Rsview of Quality Assurance Implementing Procedur:s Procedure No.: 490518

}

Issue Date:

4/077 SECTION II INSPECTION REQUIREMENTS 1.

For each onsite organization with QA (including QC) responsibilities relative to reactor coolant pressure boundary piping (except welding), ascertain whether quality assurance, plans, instructions,' procedures, and i

schedu.les have been established, and whether they conform to the facility QA program as described in Chapter 17 of the.SAR. Accomplish this by completing the inspection req 0irements of. Pro'cedure No. 351008 relative to reactor coolant. press.ure boun'dary pipini.

2.

Determine whether-appropriate and adequate procedures are included or ' referenced in the QA manual to assure that

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the following specific activities.are controlled and per-formed according to NRC' requirements and SAR comitm,ents:

j

'a.

Procedures which require th'at the purchase documents identify the appropriate material s' specifications i

and any special requirements,. aad that these doc-

.umen.ts requir.e material. test ' reports / certification of the follow'ing:

-(1)

Chemical. composition t

(2)

Physical characteristics (3) Nondestructive examination results (4) Heat treatment history (if applicable) i b.

Inspection procedures which cover receiving inspections l

and contain provisions for the following:

.(1)

Piping material in conformance with purchase specification i

i (2)

Marking and identification J

II-1 EXHIBIT 39

Rzactpr'. Coolant Pressure Boundary Piping - Review of Quality..

Assurance Implem nting Procedures Procedure No..:

490518 Issue Date:

03-31-75

(

(3)

Cleanliness at time of receipt (4)

Surface protection, closures and packaging c.

Inspection (QC) procedures which cover storage and l

issue of the piping and related appurtenances and ij materials, and contain requirements to verify the following:

(1) Segregation of sizes and materials (2) Storage identification (3) Storage conditions / protect. ion' U

(4). Confinnation of issu6 'of. 'specified material (5). Storage and'issuanc4 records d.

Procedures which cover handling of the piping and related appurtenances and materials,-and contain provisions.to assure prctection from physical damage.

{'

oi contamination while handling during ' receipt, storage, issue to 'the ' field,. and' installation.

e.

Inspection and/or wrk performance procedures which cover installation of.the piping and related ap-purtenances and materials, and contain provisions 1

for the following:

j (1) Location (2)

Clearances (3)

Type, size, location and adjustment of hangers, bellows, restraints, snubbers (4) Typeandthicknessofinsulationandcover15g (5)

Nondestructive examination.and inspections '(where l

applicable)

(6)

Hydrostatic testing i

(7)

Cold spring

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Rractar'Crolant Pr:ssura 8:undary, Piping - R view of Quality.

Assurance Implementing Procedures h,

Procedure No.:

490518

/

Issue Date:

4/1/7/

i

.(8)

Installation records generated during work performance f.

Inspection and work pwformance procedures for cleaning of the. reactor coolant pressure boundary piping systems during construction which contain provisions for the following:

/

(1)

Cleaning materials - conformance to specifications (2)

Cleanliness' e.rlteria and measurementemethods (3)' Use of cleanins materials ~ - concentration.and temperature.

4,

('4)

Record kee'>ing requirements.

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BROWil &' ROOT,' INC.

ISSUE I

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CPSES tlUMB ER.

REVISION DATE.

PAGc.

JOB 35-1195 I

I CP-CPM 6.9E 2

10/27/80 18 of.22 The MS shall disassemble all valves in accordance with the manu-

facturer's instructions. Where vendor manuals of instructions

'are not available, the MS shall request instructions from Engi-j neering.

t l

All parts removed from the valve shall be stored in a heavyduty plastic bag, or in the case of a large valve, a wooden or card-board box. The MS shall mark the box / bag with the valve number.

, Any valve that will remain dismantled for an extended period of time will have the bag / box of parts stored in a secure place in

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the. Millwright shop or wirehouse.

If the MS. estimates that.the

. valve 'will remain disassembled for only a short period or that it, is too large to be easil.y removed fr.cm. the' work ar.ea, then the

.]

bag / box may remain in the field.

New gaskets sha'll be used to reassemble valves.

If a new gasket' ic not available, the valve may be reassembled using the old j.

gasket, and the gasket shall be replaced when the new gasket is j

received onsite.

If the old gasket is reused, the bolts should '

I not be torqued.

Diaphragms may be reused.

The MS. shall reassemble _ all valves in accordance with the'manu -

i i

facturer's instructions.

j 3.14'.1

Vaiv'e'Replacemeitt Pa rts','

When replacement parts are to be installed on' valves, the craf't I

shall present a signed Material Requisition for the parts to the responsible OC Inspector.

i 3.15

~ MARKING j

i l

Pressure boundary parts shall be marked using the following l

l techniques except as stated below:

l MATERIAL NOMINAL MARKING j.

4 TYPE OD t'ARKIflG THICXNESS TECHNIOUE*

Spool Number h" and glreater S/V' Weld Number h" and gjreater S/V Radiography Bench Marks h" and areater-S/V Flow Direction h" and arenter S/V i Spool Number less than k" V

. Weld Number less thain k" V

' Radiography Bench Marks less tha'il h" V

. Flow Direction less than k" V

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EXHIBIT 37 i

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BROWN &' ROOT, INC.

ISSUE ~

.. ;i' CPSE!}-

? LUMBER

. REVISION DATE PAGE.

l l

JOB ?S-1195

.1 CP-CPM '.st 2

10/27/30 19 of 22 '

.s

' Piece Number All M

g

lieat number (See' Note).

All M

i t

3..

7' ASTH / ASME No. and Sched.

Al i H

In-Service inspection All 5;,

i 4.

E 6

NOTE:

' Pipe,12.- f aches. an'd less in lengtli-shcold have the heat l.

nun.ber stemped or vibroetched as above.

l

+Markino Technioues i

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Steel. Die-Stamp V'-

Vibro-fool l

l x,,

3 M p Nissen Ink Marker or Marsh, Marker,

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p S.

P! ding of thifollowfng categories'and sites shall be msked by vibrating mar'd, sng' tools instead of die stamp.

s t-CATEGC/.1Y JIZin y

60.1 12" 3

601 Gi s 6" and 16" 1501 G 16" i

2,501 G 4"

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4

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' The marking will be verified by the QC In's'pe.ctor for "0". piping.

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3 Pipe shall be marked by the craftsman prior to cuttinq< for fabr-

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~ ication as follows:.

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1.

"Q" Pipe-Heat. number, piece number,- spool number, ASME grade'

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3 number and schedule, 4

2.

"Non-Q" Process Pipe

- Piece number, spool number, color

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code 6r ASTM /ASME spec. and grade, j

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3.

Plunt!hg Pipe - Piece number, spool number.

1' 1

In-line compenents will qcrmally have a unique number.

If this 1

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number is not on the conconent, the item shall be identified with the unique nu:nber by marking with a Nissen Ink Marker. or by

?.agging,

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In-7(ne components which require a specific orientation (check vaives, filters, etc.) should have the flow direction indicated on their exterior with 3 Hissen ink Marker or the manufacturer's standard methods.

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r kI 3.15.1

'6di5a' tions On Marking Methods T i

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Electric are marking pencils shall not be used for cny marking I

\\s-applications.

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BROWN F ROOT. INC.

ISSUE CPSES NUMBER REVISION DATE PAGE I

JOB 35-1195 (Supplement 6.90-11)

QI-QAP-11.1-26 4

8-28-80 6 of 8 ccordance with QAP 8.1.

The OC Inspector shall verify that terial to be used is acceptable for the material type and' f

grade, piping specification category and Code Class.

For component supports, verification of traceability shall be made as required by Appendix 6.90 and, if acceptable, initialed and dated. The MR number may also be entered by the QC Inspector.

At the time of installation, the QC Inspector shall verify the h

unique designations of the components or items against applicable documentation.

4.2.2 Traceability Marking. Transfer

' uring construction activit'ies, maFkings".on bulk Jnaterial' such D

s as pipe or plate or relocated identification' bands, etc., shal.1' be transfered prior t6 the~ material being' cut or the designation (mechanically affixed tag) relocated on the component or item.

Verification shall also be made that marking is accomplished within the parameters of Appendix 6.9E, Section 3.15.

(

4.2.3 Prefabrication. (QCI-M)

The QC Inspector shall monitor prefabrcatio.n activities in i

_accordance with Appendix CPM-6.9D,. Sectic.n 2.5.6 and shall werify material traceability and marking transfer for materials to be.

._...uted on the ? Bill of Materials" of the MRS.'. Verification shall

~

also be made that end preparation and counterbore are checked to the requirements of Figure 6.9E-1.

This verification shall be made at' the cleanliness holdpoint.

NOTE All buttweld end preps for Class 1 and 2 piping that have a wall thickness of 2 inches or more shall be examined on the surfaces by the liquid penetrant or magnetic particle method prior to welding.

4.2.4 Procedure and Welder Qualification Verification At each visual examination holdpoint of the welding process, the QC Inspector sha11 ' verify that 'the correct procedure revision and

~

any WPS-ICNs to be used correspond with that specified in the documentation. Welder qualification shall be verified by consult-ing the " Welder Qualification Matrix" (see procedure WES-16).

NOTE:

QC surveillance of proper completion of the Weld Filler Material Log er.tries should be made at the time of each 4

inspection.

(Initial and Date)

______---_m-

4 BROWN & ROOT, INC..

B&R INSTRUCTION f

ffff f fMh QI-QAP-11.1-26 Rev. 18

_ ( ( ( ( Is[- L)))))

Page 6 of 72

- CPSES -

w-NOV 201985 as.iiss After grin' ding the area from which the nameplate was removed, the area shall be Liquid Peitetrant or Magnetic Particle examined in accordance with applicable requirements.

QCI shall assure that the minimum wall is not violated at ground areas.

3.1.3.7 Reclassification When a salvaged piping assembly.is to be used on a different ASME Code Class than it was, originally supplied for, it shall be l

evaluated in accordance with CP-QAP-8.5.

3.2 MATERIAL IDENTIFICATI0'N i

3'. '2. 1 "

Material Identification and Marking Requirements Material identification shall'be maintained on all items' during fabrication and installation activities.

The material identification shall be such that traceability is maintained between the item and its associated documentation.

s.

3.2.2 Maintenance of'Ma'teriali Identification'n durin'g Cutting. Operations.

When cutting' is performed 'in order, to ' modify a vendor-supplied piping spool, a B&R fabricated' piping spool', or'. cut, pro' cess bulk

'{

pipe for fabricatio,n; purposes, the QCI shall verify.the following is transferred legibly, and in accordance with paragraph' 3.2;5, to each cut piece prior to cutting:

N

' Vendor supplied piping spool - the spool number and drawing _

a.

number.

b.

Process bulk pipe - the-heat number, AS71/ASME type and

grade, schedule /vall thickness, spool
number, drawing number, and piece number.

c.

B&R fabricated piping spool - the spool number, piece number, and drawing number.

--J j

3.2.3 Field installation _ Material Acceptability Requirements i

The QCI shall assure acceptability by verifying that a Material Requisition for the material has been completed, approved, and verified by the cognizant receiving inspector, and the pipe spools have been properly identified by pipe spool number, and' drawing number where applicable.

Each FdR fabricated. spool shall be identified by a name tag attached Ly banding.

The band shall at a minimum, exhibit the' drawing number and spool number of the item to which.it is attached.

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BROWN & ROOT; INC.

B&R INSTRUCTION M irJkf M %

QI-QAP-11.1-26 Rev. 18

- CPSES -

)

Page 7 of 72 35-95 NOV 2 o 1995 c

The QCI shall verify that a nameplate is attached to N stamped items (i.e., valves, pumps, etc.) at time of fitup inspection or mechanical installation and enter the manufacturer's serial number from nameplate the WDC or the Operation Traveler.

If on the nameplate is missing at the time of fit-up a Non-Conformance Report shall be initiated (Ref. CP-QAP-16.1).

NOTE:

For Modification MRS the material traceability shall be provided by heat / code no.

or by piece and spool no.

This information may be obtained f tem the drawing and the original MRS.for the item.

3'.2.4 Shop Fabrication Materidl Acceptability Regtiirements.

Fabrication ' material' acceptability 'shall 'be. verified by the QCI through the use of material requisition.

The QCI shall verify that material to be used is acceptable for the material type and grade, and code' class.

After verification of the abcv,e, the QCI shall sign and.date the bill of materials on the MRS.

For Modific.ation..MRS, see note to p.aragraph 3.2'.3.

3.2.5-Matking' Requirements Pressure ' boundary. parts,lncluding vendor-supplied items if' necessary. shall be marked using the following techniques except as stated below:

MATERIAL NOMINAL

  • MARKING TYPE OD MARKING THICKNESS TECHNIQUE Spool Number k" and greater S/V Weld Number k" and greater S/V Radiography Bench Marks k" and greater S/V Flow Direction k" and greater S/V Spool Number Less than k" V

Weld Number Less than k" V

Radiography Bench Marks Less than k" V

Flow Direction Less than \\"

V Piece Number All M/V Heat Number All M/V ASTM /ASME No. and Sched. All M/V s..

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DROWN & ROOT. INC.

B&R INSTRUCTION mu ze x ww QI-QAP-11.1-26 Rev.'18

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- CPSE S -

Page 8 of 72 35-1195 NOV 2 01985 o

l 1

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  • Harking Techniques l

S -- Steel Die Stamp V

Vibro-Tool M - Nissen Ink. Marker or Marsh Marker Piping of the following categories and size shall be marked by vibrating tools instead of die stamping.

I

. CATEGORY SIZE 601 12" 601.G

,6".and 16" j

1501 G-16"'

2501 G 4 "'

j 3.2.5.1 Limitations On Marking Methods Electric are marking pencils shall not be used for.any marking applications.

3.2.5.2

. Marking' Techniques l

Die-stamping shall b'e ' done vich.. a round-nose die. stamp.-

Characters used shall hav'e filleted. corners.

The impressions produced" shall not exceed ' a depth of 1/32 inch and shall have rounded bottoms (0.021 inch radius minimum).

Vibro-tool marking shall be done with a tool fitted with a carbide marking point which has a minimum point radius of.005-inch. The impressions shall not exceed 0.010 inch.

Marsh metal markers shall be those having either T-21 or T-20 ink only.

All

markers, die
stamps, vibro-tools, etc.

may be used interchangeably on carbon' steel and stainless steel without being intermittently decontaminated.

3.3 MATERIAL DIMENSIONAL CONTROL 3.3.1

_ Fabrication Tolerances Completed piping spool shall be measured for final dimensional j

accuracy.by the Pipe Department Craf tsman and verified by QCI.

p When spools are joined with other spools, valves, in-line l

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of items; and.that as-built hardware was adequately marked and traceable.

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to records.

The following items we're randomly selected and inspected:

Pressurizer Safety Valve - Thils item was inspected to the commitment a.

stated-in FSAR, Table 5.2-1 which includes ASME Section III, 1971 edition through winter 1972 addenda. Valve S/N N56964-00-007 which-is installed in the B positioniwas inspected.

The'following records were reviewed:

QA Receiving Inspection Report No. 21211 o

o Code Data Report Form NV-1 o

Valve Body CMTR' The valve was in' place, however, installation had not been completed; therefore, the hardware installation inspection consisted of verifying that the item was traceable to the records.

F b.

CVCS Spool Piece 301 - Requirements for this item are stated in ASME,Section III,1974 edition through summer 1974 addenda, which is the commitment from the FSAR, Table 5.2-1.

The item was field fabricated from bulk material and installed in the CVCS with field welds number 1 and 3 (ref. BRP-CS-2-RB-076).. The following records I

l were reviewed:

i B&R Code Data Report o

o Field Weld Data Card o

NDE Reports QA Receiving Reports (for bulk order) o i

Certified Material Test Report (CMTR) o The installed _ spool piece was inspected for weld quality and to verify that marking and traceability requirements had been met.

The item had been marked with the spool piece number (3Q1) and the B&R drawing number, however, marking of the material specification number and type, heat code, or other means of traceability.could not be found.

In respect to material requiring a CMTR, (nominal pipe size greater than 3/4 inch) NA-3766 requires marking with the applicable specification and grade of material and heat number or heat code.. When material is divided, the identification marking is i

l required to be transferred to all pieces.

This failure to identify material marking is a violation 10 CFR 50, Appendix'8, J

Criterion VIII (446/8505-09).

Loop 3 RC Cold Leo - Requiremen$s for this ites are stated in ASME, c.

Section III,1974 edition through summer 1974' addenda, which is the commitment from the FSAR. Table 5.2-1.

This piping subassembly i

EXHIBIT 32 l

E

1

)

Ort \\1v4.( ['

d I i of items; and that as-built hardware was adequately marked and traceable to records.

The following items we're randomly selected and inspected:

Pressurizer Safety Valve - This item was inspected to the commitment a.

stated in FSAR, Table 5.2-1 which includes ASME Section III, 1971 edition through winter 1972 addenda. Valve $/N N56964-00-007, which is installed in the B position;was inspected.

The following records were reviewed:

o QA Receiving Inspection Report No. 21211 o

Code Data Report Form NV-1 o

Valve Body CMTR The valve was in place, however, installation had not been completed; the,refore, the hardware installation inspection consisted of verifying that the item.was traceable to the records.

' b.

CVCS Spool' P'iece 301 - Requirement.s. for.this item are stated in.

ASME,Section III,1974 edition ~ through summer:1974 addenda, which is the commitment from.the FSAR, Table 5.2 1.

The item was field 3

fabricated from bulk material' and installed in the CVCS with field welds number 1 and 3. (ref. BRP-CS '2-RB-076).

The following records were reviewed:

o B&R Code' Data. Report o

Field Weld Data Card o'

NDE Reports QA Receivi'ng Reports.(for bulk order) o Certified Material Test Report (CMTR) o The installed spool piece was inspected for weld quality and to verify that marking and traceability requirements had been met.

The item had been marked with the spool piece number (3Q1) and the B&R drawing number, however, marking of the material specification number and type, heat code, or other means of traceability could not be found.

In respect to material requiring a CMTR, (nominal pipe size greater than 3/4 inch) NA-3766 requires marking with the applicable specification ' nd grade of material and' heat number or a

heat code.

When material is divided, the identification marking is required to be transferred to all pieces.

This failure to identify.

material marking is a violation 10 CFR 50, Appendix 8, Criterion VIII (446/8505-09).

Loop 3 RC Cold leg - Requirements for this item are stated in ASHE, c.

Section III, 1974 edition through summer 1974 addenda, which is the commitment from the FSAR, Table 5.2-1.

This piping subassembly EXHIBIT 32

~

u

y J

1 of items; and-as-built hardware was adequately marked and traceable to records. The following items 'were randomly selected and inspected:

Pressurizer Safety Valve - This item was inspected to the connitment-

,l a.

stated in FSAR, Table 5.2-1 which includes ASME Section III,1971 i

Edition through. Winter 1972 Addenda. Yalve S/N N56964-00-007, which 1

is. installed in the B position was inspected. The following records were reviewed:

o QA Receiving Inspection Report No. 21211

)

i o

Code Data Report Form NY-1 o

Valve BoCr CMTR 1

W S

The valve was in place, however, installation had not been :

CJ completed;'therefore, 'the hardware installation inspection consisted 4

of. verifying.that the item was traceab1' to the, records.-

e b.

'CVCS Spoolf piece 301. Requirements for this item are' state'd in ASME,Section III,1974 Edition through Summer 1974 Addenda, which-is the commitment from the FSAR, Table 5.2-1. ' The item was field fabricated from bulk piping and purchased elbows and installed in the CVCS with field welds number 1 arid '6 (ref. BRP-CS.2-RB-076). The.

...following records 'were r.eviewed:

B&'R(Code' Data R,eport o

o Field Weld Data Card

~

o NDE Reports QA Receiving Reports for piping and elbows o

l o

Certified Material Test Reports (CMTR).

The installed spool piece was inspected.for weld quality and to verify that marking and traceability requirements had been met.

The item had been marked with the spool piece number (3Q1) and the B&R drawing number which provided traceability to the material certifications.

Loop 3 RC Cold ~ Leg.- Requirements for this item are stated in ASME, c.

section III,1974 Edition!through Sumer 1974 Addenda, dich is the conmitment from the FSAR, Table 5.2-1.

This piping subassembly.

e4 6 m s

  • P

e s

_l CPSES/FSnR components does not occur until receipt of objective evidence of the quality verification package.

The quality verification package is required to be on-site prior to relying on the related equipment to

~.

' M 'rform a safety function.

. 9) pe

",$er. & [YA:

/i.2L,-

. +.' ;,:l

. '. u,,.

A R S.'.

'17.1.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND

-gMQ.Mm.6 n.

' COMPONENTS v.

s.,

Appropriate requirements have been established to assure continuous I

and accurate identification and control of materials, parts, and components so that the use of incorrect or defective materials, parts, or components is prevented.

Contractors are-required to utilize procedures which e~stablish'and document a syst'em or method for 1dentifying,the material(e.g.,

13 physical marking, tagg'ing, labeling, color c. ode);..Upon rece'ipt of'Q Q421.82 material.and equipment OC inspections..are performed.and documented.

(

Items are then entered into the. program establishedcby site procedures

'~'

and instructions for the storage and. handling of'Q mate'ial.and' r

equipment.- Procedures and instiucti'ons require the status of-nonconforming items to be maintained 's required by Section 17.1.14.

a Up'n request for material and equipment, the status of the item o

50 requested is checked, and QC concurrence is required prior to release to construction.

Provisions are made for temporary wa'iver of the status of nonconformaning items under certain conditions.

Procedures outline the required identification, traceability, and controls, including TUGC0 QA approval that must be met before a temporary waiver 13 request can be issued.

If granted, the approval provides for further Q421.82 processing on a removal risk basis while the temporary waiver is in i

effect.

This system provides assurance that only acceptable items are

~

m ultimately used.

Material traceability is provided as specifically l

required by applicable codes and. procedures.

Material identification either on the item, or on records uniquely traceable to the item, will 50 be provided for other components except where specific categories of

~

EXHIBIT 33 s

17.1-25 AMENDMENT 50 jut.Y 13,- 1984

e 1

CPSES/FSAR

,l I

material are exempted. Where identification marking of an item is

\\

~

employed, the marking is clear, understandab1e and legible, and applied in such a manner as not to affect the function of the item.

The identification and control measures provide for relating the item of production (batch, lot, components, parti at.any stage, from materials receipt through fabrication, shipment, and installation, to an applicable drawing, specification, or other technical document.

50 TUGC0 requires its suppliers to establish and implement a documented program for inspecting, marking, identifying, and documenting the status of material prior to use or storage.

Hold. points are required where inspections must be made and certified complete before start.of next operation.

Inspection of materials 25 [

inc'udes~thefollowing';asapplicable:

l I

1.

Verification that identification and markings are in'accordance with applicable. codes, standards, specifications,. drawings, and

.urchase ord,ers.

p 2.

isual.exaniinatipn of ma' terials and components for p'hysical damage or contamination.

3.

Examination of quality. verification records to assure that' the material received was manufactured, tested and inspected prior to shipment in accordance with applicable requirements.

4.

Actual inspection as required of workmanship, configuration, and other characteristics.

These inspections are documented and verified as appropriate by vendor 25 and TUGC0 QA/QC organizations.

TUGC0 performs surveillance of vendor facilities to assure implementation of the program.

L AMENDMENT 50 JULY 13, 1984 17.1-26 4

m--

~..

~

CPSES/FSAR Items shipped to the site are normally identified by nameplate or other identification marking on the item.

In those instances when it i

'is not practical to provide identification markings on the individual I

"#'l' items, identification information is provided in shipping paperwork l

nw.:-.e...

that is transmitted with each shipment.

l

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pg,},.+ c fpf,1.c...

l

?;@&i.r.. :

l

.~

..TUGC0 requires that the prime contractors and subcontractors establish j

,'c "" :

specific measures to assure compliance with approved procedures for

]

identification and control of materials, parts, and components, j

including coatings and partially fabricated assemblies.

For subcontractors, the audit functions may be delegated to the responsible prime contractor.

TUGC0 QA verifies conformance by three 50 l

methods:

I 1.

Review and approval of prime contractors' quality' assurance-programs.

(

2.

Surveillance of selected manufac..turing, fabrication, construction,..

'and installation ac.tivities by qua.lity, assurance ~ personnel, i

1 3.

Auditing-l Of prime contractors for satisfactory performance of committed a.

quality actions.

b.

By review of documentary evidence of audits performed by prime contractors.

c.

Of subcontractors on a selected basis.

17.1.9 CONTROL OF SPECIAL PROCESS TUGC0 requires of its prime contractors that written procedures and ISO j

controls be prepared to assure that special processes including W

AMENDMENT 50 17.1-27 JULY 13, 1984

APPENDIX B U. S. NUCLEAR REGULATORY C0t941SSION REGION IV NRC Inspection Report: 50-445/85-07 Permit: CPPR-126 50-446/85-05 CPPR-127 Docket: 50-445; 50-446 Applicant: Texas Utilities Electric Company (TUEQ)

Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES)

I Units 1 and 2 Inspection At: Glen Rose, Texas i

Inspection Conducted: April 1,1985, through June 21, 1985 Inspectors:

ah N !/

f H. 5. Phillips, Senior Resident Date i

Reactor Inspector Construction (pars. 1, 2, 3, 8, 9, 10, 11, 15, 16, 17, 18, and 19)

~

h 4

  • fL*mb#

/96/ts a

J. E. Cununins, Senior Resident Reactor Date

)

Inspector Construction (April 1 - May 10,1985)

(pars. 1, 3, and 19)

, Reactor Inspectort&

sA W D. E. Norman Date (pars. 1, 12, 13, 14, and 19) dkW W.s/sr D. M. Kunnicutt, Section Chief gate Reactor Projects Branch 2 (pars. 1, 4, 5, 6, 7, and 19) g-O ggoM

I 2

)

@k

)

l Approved:

dbf#MM M1/85 D. M. Hunnicutt Section Chief, Da'te Reactor Project Section B Inspection Summary Inspection Conducted April' 1,1985, through June'21,1985(Report 50 445/85-07) 1 Areas Inspected: Routine, announced and unannounced inspections of Unit I which included plant tours and review of plant status, action on previous NRC inspection findings (violations / unresolved items), review of documentation for site dams, and review of 10 CFR Part 21 and 10 CFR Part 50.55(c) construction deficiency status, The inspection involved 77 inspector-hours pnsite by, four HRC inspectors.

Q ( f i,gsp v'

a Results: Within the areas inspected, f6 violations were identified: fail-k ure to promptly correct an identified problem with RTE - Delta Potential Transfomer Tiltout Subassemblies, paragraph 3.a.; commercial non-shrink grout was used to grout the Unit I reactor coolant pump and steam generator supports in lieu of Class *E" concrete, paragraph 3.b.; hydrogen recombiners out-of-specification voltage recorded on quality release document but QC receipt inspector accepted, paragraph 3.c; failure to provide objective evidence to show that central and truck mixer blades were inspected, paragraph 8; and failure to issue a deficiency report on cement scales that were out-of-calibra-tion, paragraph 9.c.

Inspection Summary Inspection Conducted April 1.1985, through June 21, 1985 (Report 446/85-05)

Areas Inspected: Routine, announced and unannounced inspections of Unit 2 which included plant tours and review of plant status, action on previous NRC inspection findings (violationt unresolved items), review of documentation for

/

site dams, review of documentation for voids behind the stainless steel cavity liner of reactor building, observation of NDE on liner plates, inspection of concrete batch plant, review of calibration laboratory records for batch plant, review of concrete laboratory testing, inspection of level C and D storage, review of reactor pressure vessel (RPV) and pip ng records / completed work, and review of 10 CFR Part 21 and 10 CFR Part 50.55 el construction deficiency status, and review of violation and unresolved items status. The inspection involved 335 inspector-hours onsite by four NRC inspectors.

Results: ilithin the sixteen areas inspected five violations were identified:

failure to correct RTE-Delta transfomer problem, paragraph 3.a; failure to provide objective evidence to show that concrete central and truck mixer blades were inspected, paragraph 8; failure to issue a deficiency report on cement scales that were out-of-calibration, para criteria into specifications, procedures, graph 9c; failure to translate design and drawings, paragraph 12a.; and failure to maintain RPV installation tolerances / document deviations in a nonconformance report, paragraph 12b.

_ l.

DETAILS l

1.

Persons Contacted Applicant Personnel f

M. McBay, Unit 2 Reactor Building Manager i

B. Ward, General Superintendent, Civil D. Chandler, QA/QC Civil Inspector 1

{

W. Croneans, QA/QC, TUGC0 Laboratory / Civil Supervisor

  • fJ. Merritt, Assistant Project General Manager
  • fP. Halstead, Construction Site QA Manager q

i

  1. C. Welch, QA Supervisor TUGC0 (Construction) i J. Walters, TUGC0 Mechanical Engineer K. Norman, TUGC0 Mechanical Engineer J. Hite, BAR Materials Engineer G. Purdy, B&R CPSES QA Manager
  • Denotes those present at May 10, 1985 exit interview.

fDenotes those present at June 10, 1985 exit interview.

{

~

k The NRC inspectors also interviewed other applicant employees during this inspection period.

2.

Plant Status Unit 1 At the time of this inspection, construction of Unit I was 99 percent q

complete.

The fuel loading date for Unit 1 is pending the results of ongoing NRC reviews.

Unit 2 At the time of this inspection, construction of Unit 2 was approximately 74 percent complete. Fuel loading is scheduled for approximately 18 months after Unit i fuel loading.

3.

Applicant Action on Previous WRC Inspection Findings a.

(Closed) Unresolved Item 445/8440-02: Potential Problem with Potential Transformer Tiltout Subassemblies.

By letter dated June 15, 1983, Transamerica Delaval notified the applicant of an RTE - Delta 10 CFR Part 21 report to the NRC reporting a potential problem with the primary disconnect clips of

- l the potential transformer tiltout assembly used in the emergency j

diesel generator control panels at CPSES. The Transamerica Delaval 1etter also provided instructions for correcting the problem.

However, the NRC inspector could not determine if the problem'had been corrected at CPSES and made this an unresolved item. The applicant determined that the problem had not been corrected and 1

subsequently performed the recommended corrective action. The Unit I corrective action work activities were documented on startup

{

work permits _Z-2912 (train A) and Z-291'4-(train B). The Unit 2 work activities are being tracked as master data base (MDB) item 3003-31.

The failure to promptly correct this identified problem is an apparent violation (445/8507-01; 446/8505-01).

l b.

(Closed) Unresolved Item 445/8416-03: Consnercial Grout Used in Lieu of class "E" Concrete

]

The applicant determined that the use of non-shrink commercial grout in lieu of the Class "E" concrete specified on drawing 2323-S1-0550 was acceptable. Design Change Authorization 21179 was issued to drawing 2323-S1-0550 accepting the use of the commercial non-shrink grout. However, the failure to grout with Class "E" concrete as specified on the drawing at the time the work was accomplished is an apparent violation (445/8507-02).

c.

(Closed) Unresolved Item 445/8416-04:

Hydrogen Recombiners -

Out-of-Specification Voltage Recorded on Westinghouse Quality Release Document Quality Release N-41424 was revised changing the specified voltage from 10+-2V to 12+-2V which put the questionable voltage within specification limits. However, the failure of receipt inspection to verify that the QRN-41424 was filled out accurately as required by l

Procedure QI-QAP7.2-8 is an apparent violation (445/8507-03).

j d.

(0 pen) Unresolved Item 445/8432-06; 446/8411-06: Lobbin Report Described Site surveillance Program Weaknesses During this reporting period the NRC inspector reviewed the status of this open ites several times and interviewed TUEC management and site surveillance personnel. The Lobbin report stated that the scope and objectives of the site surveillance program were unclear, lacking both purpose and direction.

There is no specific regulatory requirement to have a surveillance program; however, TUEC commiitted to have a surveillance program and has established procedures to implement such a program as a part of the 10 CFR Part 50, Appendix B, QA program. This extra effort is a strength; however, the NRC inspector also observed, as did the Lobbin

i l l Report, that the surveillance program lacks both purpose and direction.

to be-effective and complimentary to the audit and inspection programs.

Since the TUEC audit group is not located on site, the TUEC surveil-1ance program on site takes on added significance.

This item was discussed with the TUEC site QC manager who described a reorganized site surveillance function and chapges that have occurred.- New procedures which describe -this organization's duties and responsibilities are forthcoming.,,

TUEC has elected to defer responding to the violations pertaining to the audit function in NRC Inspection Report 445/84-32; 446/84-11, but rather to have the Comanche Peak Response Team (CPRT) respond to j

this report and other QA matters.. The surveillance issue is closely tied to the audit deficiencies in NRC Inspection Report No. 445/84-32; 446/84-11. This item will remain open pending the review and imple-t mentation of-the CPRT action plan. A special point of interest will be how audits and surveillance work together to evaluate the

~

control of all safety-related activities on site to assure quality, especially the overview of quality control effectiveness.

4.

Document Inspection of Site Dams The NRC inspector reviewed documents describing the inspection activities performed on the Squaw Creek Dam (SCD) and the safe shutdown impoundment (SSI) for impounu mg eno11ng water for the two units at CPSES. The purpose of the SCD it

.o impound a cooling lake for CPSES. A secondary reservoir (SSI) is fe:..ad by a channel connecting the SCD impoundment to the SSI.

Three documented inspections have been performed since 1980. The inspections were:

Relevant data for SCD is contained in Phase I Inspection, National a.

Dam Safety Program, Squaw Creek Dam, Somervell County. -Texas, Brazos River Basin, inspection by Texas Department of Water Resources.

Date of Inspection: June 10,1980.

j i

b.

Inspection on August 25, 1982, by registered professional engineers i

from Mason-Johnston & Associates, Inc., and Freese & Nichols, Inc.

l c.

Inspection on September 19, 1984, by a registered professional engineer from Mason-Johnston & Associates Inc.

t The inspection activities consisted of visual inspections by inspection teams that included accompanying Texas Utilities Service, Inc. (TUSI),

and Texas Utilities Generating Company (TUGCO) representatives.

Photographs were taken as a part of the documentation. The data for the

9.

piezometer observations and.the data for the surface reference monuments i

were reviewed by applicant personnel and Mason-Johnston engineers.

No items of significance were observed or reported by these inspection teams. Slight erosion areas were observed and reported. A cracked area-on the service spillway upstream right bridge seat was observed by the inspection teams and continued monitoring of this area was reconnended by 1

Mason-Johnston and Associates. No signs of cracks, settlements, or

]

horizontal :sovement at any location within the.SCD or the SSI were reported.

The NRC inspector reviewed the applicant's records and the Mason-Johnston.

I inspection reports. These documents indicated that the SCD and SSI were.

i structurally stable and that the applicant was performing inspection activities to maintain the structural integrity of these dams.

The state of Texas requires periodic inspections of these dans (principally the SCD) due to inhabited dwellings downstream. The applicant has met these inspection requirements.

No violations or deviations were identified.

5.

Voids Behind the Stainless Steel Cavity 1.iner in Unit 2 Reactor 8uildin~g The NRC inspector reviewed applicant records. including NCR G-82-01202; NCR C-1784, Rev.1; NCR C-1784, Rev. 2; NCR C-1766, Rev. '1; NCR C 1791, Rev.1; WCR C-1824, Rev.1; NCR C-1824, Rev. 2; Significant Deficiency Analysis Report (SDAR) - 26, dated December 12,.1979; DCA-20856; and Gibbs and Hill Specification 2323-SS-18. The review of records and documentation and discussions with various applicant personnel indicated-the following:

Structural concrete was placed in Unit 2 reactor building at elevation 819 feet 6-3/4 inches to 846 feet 6 inches on June 21, 1979. This concrete was placed adjacent to the stainless. steel liner walls. The concrete forms for this pour were not removed until October 1979 due to subsequent concrete placements for the walls to elevation 860 feet 0 inches. When the forms.were removed, honeycombs and voids were observed by applicant personnel. The.

applicant's review of the extent of unconsolidated concrete resulted in the issuance of SDAR-26 on December 12, 1979. Investigations' were begun and Meunow and Associates (M&A) of Charlotte, North Carolina, were contracted to perfom nondestructive testing on in-place concrete. M&A performed these tests on a two foot grid pattern on the compartment and liner sides of all four steam generator (SG) compartment walls. The selected test locations did not include the locations where the voids were later found to be located; therefore, the voids were.not detected during the M&A testing.

7-In August 1982, preparations were made to pour the concrete annulus around the reactor vessel. When the expanded metal formwork.was removed from the reactor side of the compartment walls, voids were observed and NCR C-82-01202 was prepared. DCA 20856 was prepared _as e

a procedure to. repair the void area.

DCA 20856 indicated-that the voids were not extensive (a surface area of about 28. square feet by 8 inches maximum depth)'and that the repair procedure assured that.

the total extent of voids had been identified. On'e half (0.5) of 'a cubic yard of concrete was used to complete the repairs as indicated' on grout pour card 261.

The applicant's review and evaluation of the gird pattern and a comparison of SG compartments 2 and 3 to 1 and 4 indicated that voids did not exist in SG compartments 2 and 3.

The review of test girds extended down to elevation 834 feet, which is the floor' elevation of the ifner. The liner walls of SG compartments 1 and 4 were not tested at elevation 834 feet, but at elevation 836 feet which is above the area of the identified voids. No testing was done on the liner side of the area of the voids below elevation 836 feet. The program also included removal of 2 inch x 2 inch plugs from the stainless steel liner at locations where test indications raised questions concerning the concrete. The inspections of the concrete by applicant personnel after the plugs were removed confirmed that there were no additiona1' unconsolidated concrete areas (voids).

The applicant re.noved stainless steel liner plates from three areas (one area about 1 foot by 1 1/2 feet and two areas about 3 feet by 1 foot, excavated or chipped to sound concrete, and cleaned the concrete surface area. One and one-quarter inch (1 1/4) diameter probe holes and grout access holes were drilled in the liner plates to determine the extent of and to assure full definition of the void '

area. Air access holes were drilled in the stainless steel liner plates to assure that grouting would be accomplished in accordance with the procedure.

The procedure (DCA-20856) specifed that the grout was to be cured for 28 days or until the grout reached a compressive strength of 4000 psi.

Repairs to the liner plates were specified in DCA-20856 and G&H Procedure 2323-SS-18.

DCA-20856 required that under no circumstances was cutting of the liner across weld seams, across embedded weld plates, or into leak chase seal welds or drilling through the liner at leak chase channels, embeds, or weld seams permitted. Documentation review indicated that DCA-20856 was adhered to and that no cutting or drilling occurred in prohibited locations.

No violations or deviations were identified.

i

~l.

6.

Nondestructive Testing Observations of Liner Plates in Fuel Transfer E~ anal The NRC inspector observed portions of non-Q liquid penetrant examinations (PT) being performed on liner plate welds following re-installation of the liner plates in the areas of the fuel transfer canal removed for inspection and repair of the concrete. The inspector performed the PT on the welds as required by the repair package and the procedure (QI-QP-11.18-1,

by the inspection. The porosity was ground o't and a repeat PT was u

performed.' The final inspection is scheduled to be perfomed by QC inspection personnel. The liner plate areas to be inspected by PT were identified in DCA 20856.

No violations or deviations were identified.

7.

Cadwell Splice Observations and Records a.

Calibration of Tensile Tester The NRC inspector observed the calibration of the Tinus-Olson Universal Testing Machine (Model Number 600-12 Identification Number MATE-784) on April 2 and May 7,1985. The machine was calibrated just prior to performing tensile testing of cadweld splices and subsequent to completion of tensile testing each day that tensile testing was performed. The machine calibration date for April 2, 1985, prior to start of tensile testing was observed by the NRC inspector and recorded as follows:

Nominal load Calibration Reading Error Error Remarks (1bs)

(1bs)

(1bs) 5 0

0 0

0 0 machine on 4/2/85 100,000 99,750

+250

+0.25 200,000 199,600

+400

+0.2 300,00 299,450

+550

+0.18 350,000 350,300

-300

-0.08 400,000 401,200

-1200

-0.03 500,000 501,350

-1350

-0.27 600,000 602,450

-2450

-0.40

-9

'The NRC inspector reviewed calibration data for March 4. March 8, April 2, April 3, April 30, and May 7,1985. All calibration data met within the +/- 15 accuracy requirement specified by Calibration Procedure 35-1195-IEI-37, Revision 3 dated March.11, 1982. The reference standards were identified as follows:

ID Wo.

Manufacturer Calibration Due Date RS-75 BLH Electronics January 27, 1987 RS-75.3 BLH Electronics January 27, 1987 b.

Observation of Cadweld Splice Tensile Testing (1) Qualification Tensile Testing On April 2,1985, the NRC inspector observed the following tensile testing of cadweld splices for cadwelder qualification:

EBD Q8, GBH Q1, GBH Q2, G8V Q1, BFD Q4, BFD Q3, BFH Q4, GAH Q1, GAV Q1,-and'G8V Q2.

Each of the above qualification cadweld splices was tensile tested to 400,000 pounds (100,000 psi) and met the requirements stated in the procedure.

(2) Production Tensile Testing

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The NRC inspector observed the tensile tester calibrations and the following production cadweld splices tensile testing on May 7, 1985: FXD 3P, FYD 4P, FYD 8P, FRD 87P, and FUD 6P.

Each of the above production cadweld splices was tested to

)

400,000 pounds (100,000 psi)and met the requirements stated in the procedure.

(3) Installation of Production Cadweld Splices The NRC inspector observed installation of rebar and cadweld splices at frequent intervals (five or more observations per week during the weeks of April 8 and 15; May 6, 13, 20, and 27; and June 3, 1985). The rebar installation for the Unit 2 closure was performed in the area identified as elevation 805 feei, to elevation 875 feet and azimuth 300 degrees to 335 degrees. The installation activities observed included rebar spacing, location of cadwelds, observation of selection and removal for testing of cadweld splices for testing, and determination of location of rebars and cadwelds for the as-built drawings.

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(4) Documentation Reviewed The NRC inspector reviewed the following documentation for the rebar placement and cadwelding for the Unit 2 containment (reactor building) closure area:

Drawings DCAs NCRS 2323-5-0785, Rev.7 22516, Rev. 1 C85-2002.oA 2323-S-0786, Rev.9 22728-C85-20029 Xev.1 2323-51-500, Rev.5 22737 C85-200M Rev.1 2323-51-506, Rev.5 22836 2323-S2-505, Rev.5 22878 (Sheets 1-7)

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2323-52-508, Rev.2 22772 2323-S2-506, Rev.3 No violations or deviations were identified.

8.

Concrete Batch Plant Inspection. Unit 1 and 2 i

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)plicable 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 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 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 He checked at a reasonable frequency. The Brown & Root (BAR) representative r'esponsible 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 and it was found that there was no record of such checks dating back to 1977 when they were initially checked.

Procebre 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

j mixing blades was not documented, although the B&R representative stated that the mixing blades were periodically irspected and laboratory testing l

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 wai satisfactory at l

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 l

B, Criterion V.

Subsequent to the identification of this violation, the blades were checked for wear and blade wear was presently within allowable limits (445/8507-04; 446/8505-02).

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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 frcm tags which indicated that the scales had been calibrated and were within the calibration frequency. Cement (MTE 779), Water (MTE 766), admixture scale (MTE 764), and aggregate (MTE 780) were reviewed. The scales had been periodically calibrated since the batch plant was activated. The l

records were adequate except as follows:

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a.

Scales MTE 766 records do not clearly differentiate between the l

required accuracy of the scale and the digital readout.

j 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 _15; report dated July 1976 gives 1% while the report dated October 1976 gives +/- 0.25.

The calibration appeared to be proper, however, the above items are unre-solved pending further review of the applicant's actions regarding the correction of these records (445/8507-05; 446/8505-03).

c.

Records for scales NTE 779 records contained B&R memo IM-1108 dated July 16,1975, which described a nonconforming condition. This condition affected the water and cement scales causing a 24-48 pound deviation during the calibration test. The meno stated that the condition was corrected and the scales 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.

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This failure to assure that a nonconforming condition was evaluated is a violation of Criterion XV of 10 CFR Part 50, Appendix B, I

(445/8507-06;446/8505-04).

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10. _ Concrete Laboratory Testing Units 1. and 2 i

TUGC0 procedure Q1-QP-11.1-1, Revision 6, was compar$ with ASME Section Ill, Division 2, Subsections 5222, 5223 and 5224 to assure that each ASTM testing requirement was incorporated into the procedure.

The NRC inspector inspected the testing laboratory equipment and found the test area and equipment were in good condition and each piece of equipment was tagged with a calibration sticker which showed.it to be within the required calibration frequency. Test personnel were knowledge-able of test requirements and equipment.

The NRC inspector witnessed field tests perfonned by laboratory personnel as follows:

Date Truck No. Mix No. Ticket No.

Air Content (%) Slump (in.) Temo(*F) 6/3/85 RT-41 925 64013 Req 8.2-10.3 NA 70 max

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Mea 8.7-9.1 NA 51 6/3/85 RT-35 128 64014 Req 5.0-7.0 5 max 70 max Mea 6.6 6.25*

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  • Truck was rejected by quality control but was later accepted when second slump reading came into required range.

The following laboratory equipment was checked and found to be within calibration:

Forney Compression Tester, MTE 3031; Temperature Recorder MTE 3013 and 3014; Unit Volume Scale, MTE 1053; Pressure Meters MTE 3000B, 3002 and 3004; Sieves MTE 1286, 1239, 1272, 1274, 1136A, 1156, 1094, 1093, 1095 and 1067; and 2", grout sold MTE 1111.1178,1179,1300 and 1180; Aggregate The following test records for placement number 201-5805-034 were reviewed: (1) concrete placement inspection (2) concrete placement summary and, (3) unit weight of fresh concre,te.

No violations or deviations were identified.

11.

Inspection of Level C and D Storage Unit 1 and 2 The NRC inspector inspected all laydown areas where piping, electrical condi.it, cable, and structural reinforcing steel were stored. These materials were neatly stored outside on cribbing in well drained areas l

1 which allowed air circulation and avoided trapping. water. This met the l

Level "0" storage requirements of R$1 N45.2.2.

The electrical warehouse contained miscellaneous electrical hardware.

This building was required to be fire and tear resistant, weathertight, and i

well ventilated in order to meet Level "C" storage requirements. This warehouse

was well kept and met all requiree.ents except for a lock storage area located upstairs at the rear of this building (electri' al termination c

tool room). Two minor problems wers identified and the warehouse personnel initiated action to correct th'em. '

j The first problem noted wa: that a box of nuclear grade cement was earked

" shelf life out of date" but it had no hold tag. The box was subsequently tagged with Wonconformance Report (NCR) E85-200453 after being identified by the NRC. During discussions with the warehouseman, the NRC determined that engineering told the warehouseman to mari! the material and lock it up, but did not tell him to apply an NCR or hold tag. TUEC should determine if engineering is aware of nonconforming material controls and provide training if this is other. than an isolated j

instance. Also, the NRC inspector noted a very small leak in the roof

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t above the electrical termination tool room. This leak was in an area that did not expose hardware to moisture. The roof is currently being repaired.

i The mi11 wright warehouse storage area was inspected; however, only a small number of items or materials were stored in this area. The overall storage conditions in this area met or exceeded Level "C" storage requirements.

No violations or deviations were identified.

12. Reactor Pressure Vessel and Internals Installation - Unit 2 This inspection was performed by an NRC inspector to verify final placement of the reactor pressure vessel (RPV) and internals by examining the completed installation and inspection records.

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a.

Requirements for Placement of W Y Requirements for placement of TIE RPY to ensure proper fit-up of all other major WSSS equipment are 'in Westinghouse Nuclear Services

. Division (VHSD) " Procedure for Setting of Major NSSS Components",

Revision 2, dated February 13, 1979, and " General Reactor Vessel Setting Procedure" Revision 2, dated August 30, 1974. The NRC.

inspector reviewed the following drawings, which were referenced in the RPV operation traveler, to verify implementation of WNSD recommendations:

WHSD drawing 1210E59 " Standard - Loop Plant RV Support Hardware o

Details and Assembly" WHSD drawing 1457F27 " Comanche Peak SES RCS Equipment Supports o

- Reactor Vessel Supports"

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o CE drawing 10773-171-004 "GeneraI Arrangement Elevation" o

CE drawing 10773-171-005 " General Arrangement Plan" Neither. site prepared installation. drawings nor specifications (which implemented the WNSD recommended procedures) were available and the drawings examined did not show certain specific installation criterion such as centering tolerances. -levelness tolerances and clearance between support brackets and apport shoes. The lack of

. engineering documentation did not provide full control. of the.

j action and would allow changes to installation criteria important to safety to be made without complying with established change procedures.

4 r,{ This is a violation of 10 CFR 50 Appendix B, Criterion III 1

i (446/8505-05).

b.

Document Review y~weg.

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The NRC inspector reviewed BAR Construction and Operation Traveler No. ME79-248-5500 which described the field instructions for installation of the Unit 2 RPV. Requirements recommended by WNSD procedures were implemented % the traveler. Worksheets attached to 7 l

the tr'aveler showed the RPY to be. centered and leveled within the 5

t established tolerances. - Travaler operation 19 required verification of a 0.020 to 0.005 inch clearance between the support bracket and support shoe, after applying the shim plates. Change 5 subsequently changed the clearance to a'0.015 to.025 inch clearance. The i

installation data reflected in attachment 38 of the traveler indicated an as-built clearance ofsc 012 to 0.026 inch which exceeds both the original and revised tolefances.

on the traveler based on Westinghouse concurrence, endinere wereThis c neither nonconformance reports nor documented engineering evaluations to determine if the condition was acceptable. This failure to document nonconforming conditions and engineering (deviations is violation of 10 CFR 50, Appendix B. Criterion XV 446/8505-06)

The NRC inspector reviewed the following receiving records for RPV hardware and found them to be in%fder:

l Report No'.14322 for 54 each closure studs, closure nuts, and o

closure washers Report No. 09507 for vessel S/N 11713, Closure Head 11713 and o

26 0-Rings o

Deviation notices and corrective action statements l

ts

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The NRC inspector reviewed the following completed travelers for internals installation and found them to be satisfactory:

o ME-84-4641-5500, " Assemble Upper Internals" o

ME-84-4503-4000, " Install and Adjust Roto Locks" ME-81-2145-5500, "Retorque UI Colum Extension" o

RI-80-385-5500, " Transport and Ins' tall Lower Internals" o

o ME-84-4617-5500, " Repair Lower Internals

  • o ME-84-4640-5500. " Assemble Lower Internals" c.

Visual Inspection At this time, visual inspection of the internals by the NRC inspector was not possible, and inspection was limited on the vessel placement to a walk-around beneath the vessel to inspect the azimuth markings and for q

construction debris between the vessel and cavity. No problems were l

identified in this area.

d.

Records of QA Audits or Surveillance The NRC inspector requested TUGC0 QA audits or surveillance performed by TUGC0 of the Unit 2 RPY installation. TUGC0 did not make available any documentation of an audit or surveillance which evaluated spect-fied placement criteria, placement procedures, hardware placement, or as-built records. This item is unresolved pending a more comprehen-

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sive review of these activities (446/8505-07).

No deviations were identified; however, two violations were identified-and are described in the above paragraphs.

13. Reactor Vessel Disorientation On February 20, 1979, the applicant reported to the NRC Resident Inspector that a design error had resulted in the reactor support structures being placed in the wrong position on the reactor support pedestal such that the reactor would be out of position by 45 degrees.

Initially, Unit 2 was to be a mirror image of Unit 1, however, a design change was initiated to permit identical components for both units. The i

design change was implemented for the reactor vessel, t>ut not for the pedestal support locations. The pNblem was not Considered by the applicant to be reportable under provisions of 10 CFR Part 50.55(e) since the error could not have gone undetected.

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J The deficiency w$s replrte&to tha WRC Office of Inspection and Enforce-

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mest on February Map land, the applicant praented the proposed r(edesign and rewo s

y dures for relocating the pekstal supports. No unresolved safety concerns

.x with the repair were identified at the meeting.

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During this inspection the NRC inspector reviewed vari 9us documentation j

relative to the disorientation problem, including design changes and the construction travelez which implemented the repair.,

j The folluing docurents were reviewed:

]

y o

NRC Inspection Reports 50-446/79-03; 50-446/79-07; 50-446/79-13 i

TUSI Conference Memo, dated March 1,1979, H. C. Schmidt to o

S. Eurwell (NRC Licensing PM)

TM,CO letter TXX-2fP>0, dated April 30, 1979, to W. C. Seidle o

o NRC letter to TUGC0 dated May 29, 1979 o

DCic 3G72, Revision 1,. dr.ted February 28, 1979,.

Subject:

Rework of -

Structure for Placement of thi RPV Support Shoes DCA'4122, dated March 22, 1979,

Subject:

Replacement of Rebar for

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o RPV Supports a

Construction Traveler CE79-018-5505, dcted March 14, 1979,

Subject:

i o

Rework of Reactor 30. 2 Civity - New RPV Support Locations l

o Grout Replaceme1t Cards No. 007, 008, 009, 010, 014, and 015, various dates,

Subject:

Replacement of Grout around Rebar for Repair of'RPV

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Support Shoes Various Inspection Reports for Grout Properties and Application for o

RPY Support Shoes j

No violations or deviations were idantified.

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14. Reactor Coolant _ Pressure Boundary (RCPB) Systems A

C' The hspection ws performed to verify: the applicants system for prtpwing, revitwing, and maintaining Pecords for the RCPB piping and cccponents; that selected records reflect.ed compliance with NRC reentrements and SAR comitamts for mawfacture, test and installation i

i i

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i c.

- i of items; and as-built hardware was adequately marked and traceable to records. The following items were randomly selected and inspected:

Pressurizer Safety Valve - This item was inspected to the connitment a.

stated in F5AR, Table 5.2-1 which includes ASME Section III,1971 Edition through Winter 1972 Addenda. Valve S/N N56964-00-007, which is installed in the B position was inspected. The following records were reviewed:

o QA Receiving Inspection Report No. 21211 i

o Code Data Report Form WY-1 l

o Valve Body CMTR 1,

The valve was in place, however, installation had not been completed; therefore, the hardware installation inspection consisted of verifying that the item was traceable to the records, b.

CYCS Spool Piece 301 - Requirements for this item are stated in A5ME,Section III, 1974 Edition through Sunner 1974 Addenda, which,

is the cosmitment from the FSAR, Table 5.2-1.

The item was field fabricated from bulk piping and purchased elbows and installed in the CVCS with field welds number 1 and 6 (ref. BRP-CS-2-RB-076). The-following records were reviewed:

o B&R Code Data Report o

Field Weld Data Card o

NDE Reports o

QA Receiving Reports for piping and elbows o

Certified Material Test Reports (CMTR)

The installed spool piece was inspected for weld quality and to verify that marking and traceability requirements had been met. The-item had been marked with the spool piece number (3Q1) and the BAR drawing number which provided traceability to the material I

2 certifications.

Loop 3 RC Cold Leg - Requirements for this item are stated in ASME, c.

5ection III, 1974 Edition through Summer 1974 Addenda, which is the connitment from the FSAR, Table 5.2-1.

This piping subassembly l

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consists of a 27.5 inch cast pipe with a 22 degree elbow on the reactor end, a 10 inch 45 degree nozzle, a 3 inch nozzle, and three 21/2 inch thermowell installation bosses. The following records were reviewed for the subassembly:

o QA Receiving Inspection Report No. 12389 o

Westinghouse Quality Release (QRN 47523) o Code Data Report Form NPP-1

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o 271/2 inch line CMTR o

3 inch nozzle CMTR I

o Field Weld Data Cards c

NDE Reports (1) Sandusky Foundary and Machine Company test report for the cold leg pipe certifies that material meets requirements of ASME Section II, 1974 editions through winter 1975. Southwest Fabrication and Welding Company code data report NPP-1 Form

)

certified that the cold leg subassembly met requirements of ASME Section III, 1974 edition through winter 1975. The FSAR comitment is ASME Section III,1974 edition through sumer i

1974. This discrepancy is unresolved pending the applicant's evaluation to determine if material nonconformances exist (446/8505-08).

(2) The NRC inspector reviewed the procedures and hydro test data applicable to Unit 1, since Unit 2 hydro had not been completed.

$Y,\\k Requirements for the tests were presented in Procedures bo#", i' CP-QAP-12.2, " Inspection Procedure and Acceptance Criteria for ASME Pressure Testing" and CP-QAP-12.1, "ASME Section III e

r Installation, Verification, and N-5 Certification." Procedure k pcgW CP-QAP-12.1 requires that a data package to be used in the test, (datashown:be prepared with the test boundary and the addit o

Base metal defects in which filler material has been added, and the depth of the base metal' defect exceeds 3/8 inch or 10% of the actual thickness, whichever is less.

o Untested vendor performed piping circumferential welds.

o Approximate location and material identification and description for permanent pressure boundary attachment with applicable support number referenced.

~y o

Weld history, which shall reflect weld removal and/or weld repair.

The completed hydro data package (PT-5501) for Unit 1, loop 3 cold leg was reviewed for compliance with the above requirements. Drawing No. BRP-RC-1-520-001 had been used to annotate the test boundary. A handwritten statement on the drawing indicated:

"No. major base metal repairs could be located" and "No hangers with weld attachments could be-located." Welds performed by the pipe subass'embly vendor, including the 22 degree circumferential weld and the penetration fittings had not been identified. The following items are unresolved' pending further review to deterstne:

o If "no major base metal repairs" was based on a visual inspection or on a review of vendor and site inspection and repair records.

I If the shop circumferential weld attaching the 22 degree I

o elbow to the pipe assembly was inspeted during the test.

}

If welds for penetrations into pipe assembly were inspected o

as procedure CP-QAP-12.1 does not require identification of such welds and they were not identified on the drawing.

The above issues will remain unresolved pending further evaluation by the applicant ~ (445/8507-07; 446/8505-09).

d.

Personnel Qualifications - Personnel who had performed selected tasks were identified during inspection of installation records. Training and experience records for the personnel were reviewed to verify that employee qualifications and maintenance of records were current 4

and met requirements. Names or codes for five welers rnf t'.;c NDi.

examiners, who had performed tasks during installation of the items being inspected, were identified and their qualification' records reviewed. There were no questions in this area of the inspection.

No violations or deviations were identified.

15. Special Plant Tours (Unit I and Unit 2)

On May 23, 1985, the NRC inspector conducted a tour of selected areas of Unit I and Unit 2.

The group consisted of one NRC inspector, two NRC Technical Review Team (TRT) representatives, two allegers, and several.

TUEC representatives. The TUEC representatives tagged each area where a deficiency was alleged. With the alleger's consent, a tape recorder was also used to note locations and describe any alleged deficiencies. The allegers indicated that they had identified all deficiencies during the tour and all other deficiencies that they had knowledge. The NRC TRT is analyzing this information and will decide what action, if any, should be taken.

/

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During this tour the NRC inspector independently identified a questionable practice in that the top of the the. pipe chase at the north end of room 88 in Unit 1, safeguards building had.two large stickers which stated that-areas on the wall were reserved for pipe hangers GHH-SI-1-SB-038-006 and

.j R1(?)1-087-X11. bese stickers were dated 1980.

It was not evident whether hangers were missing or none were needed in these locations and the reserve tags were not removed. TUEC representatives were unable to answer the question innediately. This item.is unresolved pending further j

review during a subsequent inspection. -(445/8507-08).

J No violations or deviations were identified.

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16. Routine Plant Tours (Units 1 and 2)'

J i

At various times during the inspection period NRC' inspectors conducted i

general tours of the reactor building, fuel building, safeguards building, _ electrical and control building, and the turbine building.

During the tours, the NRC inspector observed housekeeper,g practices,-

1 preventive maintenance on installed equipment, ongoing construction work, and discussed various subjects with personnel engaged in work activities.

No violations or deviations were identified.

17. Review of Part 21 and 10 CFR 50.55(e) Construction Reports Status The NRC inspector reviewed all reports issued to date to assure that NRC i

and TUEC status logs were complete and up to date. A total of 183 reports have been submitted to date. This' inspection period one Part 21 report on Diesel Generator Oil Plugs and two 10 CFR 50.55(e) reports on the Equipment Hatch Cover and SA106 Piping (light _ wall) were submitted.

3 l

No violations or deviations were identified.

18. Review of Violation and Unresolved Item Status The NRC inspector reviewed all violations and unresolved items reported to date to assure that NRC and TUEC status logs were complete 'and up to Two hundred nineteen items were reviewed.

In addition, a trend-date.

analysis of NRC findings was performed to generally determine how many findings could be broadly classified under each criterion of 10 CFR, Part 50, Appendix 8.

The frequency of. findings showed broad and general trends under the following criteria:

II. QA Program; III. Design Control; V. Instructions, Procedures and Drawings; VII. Control of Purchased Material, Equipment and Services; IX. Control of Special Processes; X.

Inspection; XI. Test control; XIII. Handling Storage and Shipping; XVII.

QA Records; and XVIII. Audits. The most significant trends were Criterion III V, VII, IX, X, and XVIII. Also, a number of violations-occurred with respect to 10 CFR 50.55(e) items.

8

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f These findings mainly pertained to Unit 1 and related closely to trends identified by the NRC Technical Review Team TRT. These trends will be considered during followup on TRT findings. Also, Unit 2 inspection i

emphasis will consider these trends during future inspections.

Wo violations or deviations were identified.

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19. Exit Interviews The NRC ins ectors met with members of the TUE'C staff (denoted in paragraph 1 on May 10 and June 10, 1985. The scope and findings of the inspection were discussed. The applicant acknowledged the findings.

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