ML20237L767
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[ % UNITEo STATES K d 1te r iT N O 3
} 2' . <; NUCLEAR REGULATORY COMMISSION
~ i REGION tv o p. h,. y I
5 611 AY AN PL AZ A oRivE. SulTE 1000 A RLINGTON. TE X AS 76011
% . . . * .8' i A:.1S '993 MEMORANDUM FOR: E. H. Johnson, Acting Director, DRSP ,
FROM: D. R. Hunters Chief, RSB
SUBJECT:
NRC INSPECTION PROGRAM AT COMANCHE PEAK STEAN ELECTRIC STATION (CPSES)
The CPSES group performed a quick review of the CPSES inspection program status including, implementation (Enclosure 1), inspection n;,0. :' .etween 1974-E2 (Enclosure 2), general review of the inspection program documentation (Enclosure 3), and a general review of the historical unresolved and noncompliance items (Enclosure 4). The details of the general program review (Enclosure 5) and the review of the historical unresolved and noncompliance items (Enclosure 6) are enclosed.
The reviews identified a number of items which should be given consideration by management regarding the inspection program implementation at CPSES, QA inspection at CPSES, inspection program documentation, and the handling of unresolved items at CPSES.
I' The enclosed information represents a number of hours work and was performed in ]
order to better understand the CPSES QA and technical problems, the inspection ]
program documentation and status, and the general handling and status of 1 previously identified findings. The information is being provided solely for l your information and consideration and includes some recommendations.
Consideration should be given to utilizing the enclosed information during the continuing inspections of the CPSES facility (TRT followup and routine !
inspection program). Consideration should also be given to evaluating the information relative to the IE inspection program and program implementation at !
CPSES to determine if IE program changes may be necessary to strengthen our inspection and followup of safety issues.
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l 8708200322 B70819 PDR ADOCK 05000445 G PDR , ,
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'l Memo for E. H. Johnson 1 If you have f urther Questions , please contact H. 5. Phillips (CPSE5 SRl-C at (817) 897-2201 or me (FT5 728-8103).
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D. R. Hunter, Chief, Reactor Safety i Branch
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- l. p . 5. Phillips !
T. F. Westerman D. M. Hunnicutt J. E. Gagliardo i
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- bi da ENCL 0SURE 1 7
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, NRC INSPECTION PROGRAM AT CPSES 1 - IMPLEMENTATION A quick review of the NRC inspection program at_CPSES relative to the activity implementing procedures and records revealed the possible need to address certain areas during the final inspections of CPSES 1.
NOTE: Also the review revealed the need to commence the required inspections of CPSES.2 expeditiously in order to adequately complete.the required.
inspection program.
The following areas may require additional emphasis _regadding 095ES 1:
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- Structural Steel Supports (480638 - report documentation weak)
- Safety Related Componepts (50073B - additional ..p. .
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- Instrumentation Components / Systems (52054B - report documentation weak)
- Containment Structural Steel (55063B - additional inspection needed):
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- Reactor Vessel (50055 - addi?ional inspection needed)-
- Safety - Related Structural Steel Welding _(55065 _ additional inspection-needed)
- Electrical Components and Systems (51055B - additional inspection needed) l l
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ENCLO5URE 2 l
l NRC ]NSPECTION PROGRAM Al CPSES 1 & 2 REGARDING OVERALL QA BETWEEN 1974-84 The quick review of the NRC inspection program implemented at CPSES 1 & 2 l regarding QA revealed that between 1974 and 1984 the RIV QA inspections were l weak at best. The following attributes did not appear to be adequately addressed in the routine inspection program:
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- Initial Corporate Office QA Program and Implementation (Once - 1984) l
- Mid-QA Inspection (36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />)
- Vendor QA Program (completed prerequisites only in 1978, but the inspection was not performed)
- Annual Construction QA Review Meeting (Once - 1980)
- Routine Review of QA Program Implementation and Effectiveness - Design, Procurement, and Construction (Once - 1984)
- Audit of Site QA/QC Work Activities (Once - 1983, CAT)
- Annual Prxurement, Receiving and storage (Once - 1983, CAT)
- Review of Contractor QA Manuals Notwithstanding, supplemental and additional NRC inspections were performed at CPSES which provided some assurance that the licensee's QA Program was acceptable, including the CAT in 1983, the SRI in 1984, the RIV inspection in 1984, and the TRT in 1984. These inspections did not identify an overall breakdown in the CPSES QA Program; and the specific areas of concern identified appear to be salvageable - at this time. The final word on QA should evolve from the full implementation of the CPRT Program Plan and other special inspection activities.
The QA Program inspections need to be performed, at this time, for CPSES 2 to ensure continuing acceptable QA practices.
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ENC!._05URE 3 1
GENERALREVIEW0FTHENRCINSPECTIONhROGRAMIMPLEMENTEDATCPSES In general, review of the NRC inspection program implemented at CPSES revealec some apparent' problems which may need. review,by management to provide inspection program improvements. The follosing ratters were noted during the l
j review of inspection reports and data:
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- In many instances, report documentatfpn'was not adequate to demonstrate l
L that the inspection procedore (lire items as a minimum) were inspected.
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- The percentage ccmptate determination, in some instances, was not fully supported by the' report _ documentation.
Additionally, the use 0,f unresolved and open items, .". . .
or violations should have/could have been utilized, degradad the Nf program to some degree. The NRC - and utility - management do _not roJtinely evaluate unresolved and open items; and therefore, are not aware of " findings" handled Further, the corrective action taken by the licens?e werc.
at that level.
generally specific to t')e identified issue, rather than_ generic to identify the cause and prevent recurrence of the problem. ,
NOTE: The NRC does not generally consider unresolved ard open ite'ms in SALP evaluations. -
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l ENCLOSURE 4 j
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J GENERIC TREND OF CPSES UNRESOLVED ITEMS AND VIOLATIONS I
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[ .A very general trend of the frequency of violations and unresolved items as they relate to Appendix B to 10 CFR 50 was performed by the CPSES project to identify any areas where additional inspection effort might be warranted. The attached trend identified two areas which are presently included in the CPRT Program Plan - 1) Design / Design Control (Criterion III), and 2) Inspection (Criterion X). The third area the trend identified was Purchasing (Criterion VII), and this area may need to be given additional consideration by l
the project to provide additional inspection effort.
i i It is noteworthy that a large number of issues were identified as unresolved in l
the area of purchasing and only a few findings were cited as violations. This l practice may indicate ineffective corrective actions - ' -, the licensee.
I The general trend also incl;ded a cursory review of the ' items to note whether l the unresolved item was prcbably a violation. Based on available information
! it was concludec that without a significant amount of additional effort it
! could not be determined Woich items were definitely violations. Those assignec to the project determined that the additional effort was not justified at this time, and also the data was not absolutely essential for the inspection of CPSES.
The review, both unresolved itemt and violations, revealed findings in the areas of design / design control, procedures, purchasing, special processes, inspections, and records. However, a definite lack of findings was noted in the areas of procurnent control, document control, material traceability, corrective actions, and audits. This matter, both in the areas where findings were identified and areas where findings were not identified, may be very important when the findings of the TRT are considered and may need evaluation and consideration.
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ENCLOSURE 5 l
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.o GFNERAL INSPECTION PROGRAM REVIEW
- 1. 'The NRC inspection program at Comanche Peak relative to quality assurance.
Lbetween 1974 and 1984 was weak. That is the IE inspection program to I inspect the applicant's QA program was less'than adequate based _on the.
following:
- a. After the construction permit was issued in December 1974, no comprehensive inspection of the corporate management was performed until August.1984. ' As a result, there was no evaluation at corporate l offices to determine how effectively the Comanche Peak QA Program has.
been implemented. Also, the applicant's QA Program and QA Audit 1 Program, which was implemented by corporate auditors only, were'in noncompliance with their commitments and Cr:D -VI! .(failure to audit) and Criterion II-(f ailure to assess the status and adequacy of the QA Program) from 1974-84, respectively.
- b. The mid-QA inspection, as required by Manual Chapter (MC) 2512 and Inspection Procedure 352008 was neither comprehensive nor in suf ficient depth to properly evaluate whether or_ not the applicaitt 's program was effectively implemented (when construction is about i 50-60% completed).
Usually, this inspection is performed by the project inspector and three discipline inspectors over several weeks (2 weeks preparation, one week inspection at site, followed by a final week of inspection at the corporate QA offices). The mid-QA inspection at Comanche Peak was conducted by two NRC inspectors during the period December 18-20, 1978, and 36 inspector hours were recorded under IP 35200B. Less than a manweek was expended versus the usual 5-8 manweeks; and further, it appears that the electrical discipline was not inspected adequately, l
- c. Audit of Applicant's Surveillance of Contractor QA/QC Activities 350208 - As a result of Vendor Branch IE Inspection Report 9990524/78-01 (which stated that the applicant's QA Program concerning vendor control activities appeared to be breaking down),
an inspection was conducted and documented in IR-78-07 by the resident inspector.
Other than reviewing a list of vendors and status of vendors' QA program and manufacturing (documented in IR 78-09), no further ;
i inspection occurred to assure that the applicant's control of vendors fully complied with Appendix B requirements. I l
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i In 1984 two NRC inspections identified potential, and subsequently upgraded, violations concerning control of vendors. The applicant's control of vendors has remained in question since 1978.
The Region IV inspection did not acertain whether the applicant's QA Program relating to surveillance of contractors assured proper control of vendor and corrective action concerning an apparent QA program breakdown.
- d. Management Meeting - Construction Quality Review IP 30051B - This annual requirement to discuss: (1) quality of construction, (2) QA program implementation, (3) QA/QC staffing, (4) preplanning for complex work activities was held in October 1980; however, it was not done and/or documented in 1981, 1982, 1983, and 1984.
- e. Audit of the Applicant's management of the QA Program 350608 - This inspection of the applicant's management was required every 18 months since August 1980. The purpose of inspection was to evaluate the effectiveness in. implementing the corperat< ?? ~ v 'or ongoing activities of design, procurement, and construction.
This inspection should have been performed twice between August 1980 and June 1983, but was not performed until August 1984.when the RIV Task Force performed the inspection.
- f. Audit of Site Work Activity and the QA/QC Program 35061B - This annual inspection of site work activity and the QA/QC program was to assure that safety related work was properly controlled. This inspection should have been accomplished in 1981, 1982, 1983, and 1984. The NRC CAT Team accomplished the equivalent of 30% in 1983 and the Region IV Task Force performed this inspection in mid-1984, but there was very little work in progress on Unit No.1. Unit No. 2 was not inspected.
The inspection of as built drawings versus plant configuration in one electrical and mechanical area identified violations; i.e., drawings did not match configuration and inspection did not identify these departures from drawings and specified tolerances.
- g. Procurement, Receiving, and Storage 35065B - This inspection (required by MC 2512 annually since 1980) of site procurement, receiving, and storage was not inspected under the routine-program in 1980-81, 1981-82, 1982-83, or 1983-84.
i The CAT team inspection in 1983 covered 30% of the required inspection and the Comanche Peak Special Review Team inspection may be counted toward the 1983-84 inspection of procurement,
- h. Review of QA Manuals 351008 - This inspection procedure requires that each contractor's QA/QC Manual be reviewed and evaluated once in I
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conjunction with NRC review of civil, electrical, and mechanical proce:.
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which control work activities. ;
IE inspection reports document such reviews for all contractors on site except Bahnson (reviewed selectively).
The above paragraphs descriue inspections that were missed for Unit No. 1 and the opportunity to inspect is lost; however, the following special, inspections have occurred and provide assurance that these or similar inspections were performed to assure that the applicant's QA program was and is adequate or identify deficiencies.
Special Inspection Construction Assessment IP 35061 - 30% per IE letter dated April 27, 1983 Team - January 24 through ID 35065 - 80% same letter February 4, 1983 NOTE: Not in 766 data Comanche Peak Special This report dated July 13. '? ". w ;;s an Review Team Report extensive review of QA/QC activities relating to April 3-13, 1984 design, procurement, and construction. The line items of IP 350618 and 35065B were inspected during this comprehensive inspection.
NOTE: Not recorded in 766 data Region IV Task Force Inspection Report 84-22/07 documents the inspection Inspection - July 9 of IP 350618. Also, a number of QA manuals were through Mid-October 1984 reviewed.
IR 84-32/11 documents the inspection of IP 35060B and 350208. The scope of 35020B was limited to site construction.
NRC Technical Review This inspection by over 100 engineers and technical-l Team - July 9 through specialist thoroughly covered the QA/QC. function and
- Mid-October 1984 may be counted toward and satisfy IP 30051B, 35061B, l 35065B, and 35100B inspection requirements for l present and past work.
l 2. Manual Chapter 2512 Inspection Program of Site Work Activities - This program requires NRC inspections to: (1) review specific QA/QC implementing procedures, (2) observe current /past work, and (3) review of records pertaining to civil, electrical, and mechanical work activities on site. The program accepts the premise that all inspection procedures may l not be completed. The 766 data run dated October 1984 was used to evaluate the inspection procedure line items inspected and documented in inspection reports. The following are the results:
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- a. RIV inspection reports document the review of inspection procedures such as safety related piping (490618) and other similar procedures; however, the following procedures reviewed were either not recorded 1 i
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in the 766 data system or were not completely inspected and/or documented in inspection reports:
(1) The October 1984 data run for 766 information did not include !
inspection procedures 450618, 46051B, 47051B, and 550518 but, reports were found indicating these inspections were performed .
but were not recorded on a 766 form or in one case the data !
group fai'ed to enter the item.
(2) The following review of procedures were either not completed or documented in inspection reports: 45051B, 50051B,'50061B, 500718 and 550818. Procedures 50051, 50061, and 50071B were reported 100% inspection of line items, but reports document inspection of 50% of line item procedures.
- b. RIV inspection reports document the observation of work activity on site for the following areas as follows:
(1) Site preparation - 766 data forrr., 'e' 30*J com;)1eted i
but the report does not document observeo work. Orily procedures and records inspected.
(2) Lakes, dams - inspection completed (IC)
(3) Foundations - IC l
(4) Concrete - 766 data run shows no entries for 47053B, yet, IR 76-06 shows 766 form - 100% and plant progress 11.7% Unit I and 1.5% Unit 2.
Also found documentation of inspection in RPT 75-12, 75-11, 75-10, but not in 766 data.
47054B - IC (5) Containment Steel - IC (6) Structural Steel. supports 48063B - Report 766 form reports 100%
but reports document 20%.
48064B - IC i
(7) Reactor Coolant Pressure Boundary Piping 49053B - IR 82-11 reports 100%, but all line items were not complete / documented in the report. IR 79-25 showed 90%
i 49054B - IR 80-19 and 82-11 report 30%.
(8) Safety Related Piping - 49063B - IR 80-26 reports 100% but I supports documents 80%.
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NOTE: Considering all resident inspection may consider 100%.
(9) Safety Related Piping. Welding - IC -
(10) Reactor Coolant Pressure Boundary Pipe Welding i
550738 - IC
- 55074B - 90% completed (11) Reactor Vessel - IC !
(12) Reactor Vessel Internals - IC (13) Safety Related Components 500738 - 60% completed 50074B - Approximately 80% completid l
(14) Pipe Supports - IC l
(15) Fuel Storage Racks 50095B - 60% but understand D. Hunnicutt recently completed.
l (16) Containment Penetrations - IC l
(17) Containment Penetrations - IC i
(18) Containment Structural Steel Welding 55063B - 100% reported but reports support document 20%.
i 55064B - Oitto above 100% vs. 70% completed / documented.
l l (19) Electrical Components / Systems 51053B - 70% completed. I j 51054B - 90% reported - 50% documented.
(20) Electrical Cables / Terminations IC ..
(21) Instrumentation (Components / Systems) 520538 - IC 52054B - 90% reported 766 - 50% documented.
i (22) Instrumentation Cables - IC i
(23) Preservice Inspection - IC i
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! 3. The overall observation of work appears to be adequate with a few exceptions. Not all of the inspection procedure line items were 100%
inspected and completed; however, the Manual Chapter recognizes and allows that all procedures may not be completed.
Considering this allowance the following percentage completed appears to be too low: (1) structural steel supports - 20%; (2) reactor coolant pressure boundary piping (49054B) - 30%; (3) containment structural steel (550638) - 20%.
The major problems found during this review were as follows:
- a. Reports in many instances failed to document the inspection to demonstrate that inspection procedure line items were inspected.
- b. The percentage complete determination requires some judgement; however, some judgements appear to have less basis than needed.
NOTE: This is also true of review of proceoures anc records.
These slight weaknesses appear to be well compensated for by work observed and documented in the special inspections previously referenced in paragraph 1 above.
- c. RIV inspection reports document the NRC review of QA records. The review of records for all discipline procedures was completed and adequate except as follows:
(1) The 766 data shows 0% complete for 45055B.
(2) For concrete 47055B, the 766 reports 100% but the reports do not document the inspection of line items. The same is true of 47056B i.e., the last accurate report was 70% but 79-04 report l of 100% was not documented.
I (3) Containment Steel - 100% inspection of line items reported e 70%
documentation (4) Structural Steel Supports - 100% reported - 10% documented.
(5) Reactor Coolant Pressure Boundary (55075) - 100% reported - line item on nonconformances only 10 of 14 nonconformances reported.
(6) Reactor Vessel 50055 - 100% reported - 60% documented (7) Safety Related Structural Steel Welding - 100% reported - 20% of line items inspected documented for 550658. 100% reported on 55066B - 70% documented. Nonconformances and audits line item not completed and/or documented.
i l (8) Electrical Components and Systems - 100% reported - 20%
documented for 510558.
90% reported - 20% documented for inspection of line items of l 51056B.
( The records review and review of procedures appear to be the weakest area I
i.e., NRC review of procedures, observation of work, and review of QA l records.
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- 8. Reactor vessei nstallati spuC%
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& S t.rr C u b ' S u.- % r Bu-2c 50051B RB/IBl 0; 00AllTY ASSUPANCE IMPLDENTING PR0rFD'JRES k/h Ch dac%6 te6%[3 . l l
- 1. Complete the inspection requirements of '
ProcedureNo.3510g5relativetoreactor vessel installation. fM/hIM$ %
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- 2. Determine whether appropriate and adequate procedures re included or I I
referenced in the QA manual for the following actiy ies:
- a. Receipt Inspection and Ecndling (1) Receipt inspections _ /'[ST
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l (2) Handling and storage (3) Record keeping i.
- b. Crane and Rieging Testing and Vessel Lifting (1) Crane and rigging testing and j
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vessel lifting procedures J
(2) Ersking and holding test procedures j'
- c. RPV Installation (1) Work procedures are established ,
for RPV installation activities [.d' l
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(2) Use of special, technical personnel ((#J ' !
(3) Record keeping ((-#1' )
(4) Installation records ff /S' 8-1
- d. lWV ittat al La t ton t in. pic c i.J2g i (1) Inspection activities cover pertinen #3' installation activities I
i (2) Inspection activities neet MY I established procedures ,
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- e. Post-Installation Activities ')'
4 (1) Vessel protection pro edures and ,
internal cleanliness preservation O2]- .. ."
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(2) Procedures established in (1) N58[ }
above are adhered to i
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- 8. Reactor Vessel Installation / f g p . ; (p 8 l-c) S I~ ' '
50353B OBSERVATIO10F hDPK A'S h0RK ACTIVITIES. fz-ok ## ^
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Determine whether requirements of applicable specifications, work proc dures /
and inspection (QC) procedures are being net in the following areas: '
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- 1. Stored Vessel Protection /J
- a. The reactor vessel is being stored in accordance with approved
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procedures ,
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- b. Seals and devices to identify vessel internal atmospheric conditions -
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- c. Condition of protective coating and/or protective covering -
- d. Determine whether protection from entry of dirt, water, flooding and strength of support is adequate l
l 2. Installation Techniques i 1 a. Lifting and handling cre consistent with established specifications and
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'7 b. Lifting equipment is as specified -
- c. Placecent is being, or has been, j
accomplished as specified '
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- d. Observe the installed reactor vessel !
and determine whether:
(1) Work procedures have been or are being followed g3~- f3" (2) Installation is in accordance with specifications and procedures f$~6S' '
(3) Inspection (QC) procedures are being followed f.6'W >
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- 3. Insta11od vesse1~ Protection
- a. Procedures for protection arc being (or were) followed / F #.5 "
- b. Protective devices are installed around top of open vessel. [N3' *
- c. Vessel side openings are blanked off ([-th .O
- d. Work platforms and scaffolding inside- )
. vessel are nonflammabic or treated -
- e. Access control activities meet re- '
quire =ents. F-d2f' i
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- 8. Reactor Vessel Installation /
500553 RE/1Bf C QUAL 1W PECORDS Review pertinent quality records in the following areas:
- 1. Storage Inspections Review 50% of QC inspection records. Ascertain whether:
- a. The stored vessel inspections.were made at the required frequency '-
- b. Protection requirements were main-tained ~~
- a. The established scope of quality assurance activities was accomplished , fJIL(T' b.
Installation of the reactor vessel was in accordance with specifications and work procedures 88~4[
- 3. Installed Vessel Protection Review 50% of the inspection records. Ascertain whether:
- a. Adequate access control was provided 72Ih63~ ,
- b. Required cleanliness of the vessel was maintained -
- 4. Ascertain whether the site records review-ed under this procedure reflect the obser-vations made under Procedure No. 500533 ( f 4
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5, QA Audits and QC Inspe'ctions Determine whether the required nu=ber (or frequency) of audits and inspections have been cade Yf"0S, I
'a Il de
Reactor Vesse 1er 9-( i Observation o Tan Work ActlyiQies )
ss ae b 5 Tk'3 Is bi d l f ro cSA w<..s .
SECTION I i
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INSPECTION OBJECTIVES I l
l By direct observation, and independent evaluation of work perfomance, work in progress.and completed work, ascertain whether activities relative to reactor vessel internals installation are being accomplished in accordance with NRC requirements and SAR comitments.
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Reactor Vcssel Interni 6-Observation of Work ano Work Activities Procedure No.: 50063B Issue Date: 03 31-75 '
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l SECTION III INSPECTION GUIDANCE General Guidance j i
Applicable portions of the SAR should be reviewed to determine l licensee comitments relative to storage, handling, installation f and post-installation protection of the reactor vessel internals -
prior to observing work activities / components in this area.
The inspector should make this determination during inspection i preparation. l If possible, arrange inspection schedule to coincide with vessel i internals placement activities. In this case, among other '
observations, detemine whether handling and placement procedures are at the work location and are being utilized.
References SAR, Chapters 1, 3, 4, 5 and 17, inc1,uding pertinent codes and standards referenced in these chapters Regulatory Guide 1.38, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power Plants l
Regulatory Guide 1.39, Housekeeping Requirements for Water-Cooled Nuclear Power Plants Regulatory Guide 1.65, Materials and Inspections for Reactor Vessel Closure Studs f
III-1
Reactor pssel Internals '
Observa..on of Work &
Work Activities -
Procedure No.: SC063C Issue Date: 10/1/77 (1) Work procedures have been followed (2) Installation is in accordance with specifications (3)- Inspection (QC) activities are in accordance with l
established procedures 3.. Installed Vessel Internals Protection Monthly, af ter " final" installation of vessel internals:
- a. Determine whether procedures for protection of the i installed vessel internals are being followed
- b. Determine whether cleanliness requirements are being met
- c. Observe whether protective devices are installed around top of open vessel to prevent entry of foreign objects and debris into the vessel internals.
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Reactor vessel Internals - 1 Observa bn of Work & l Work Activities Procedure No.: 50063C Issue Date: 10/1/77 SECTION III INSPECTION GUIDANCE !
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General Guidance I Refer to Section III of Procedure No. 500638 for additional guidance. I Specific Guidance 1.d -
Verify that installation is being accomplished in 1 conformance with NSSS requirements, and determine whether- l (1) Work procedures (site generated) incorporate require-ments of NSSS specifications.
(2) If assembly (field) work is being done by NSSS or subcontractor personnel, verify that QC responsibilities and duties as well as the frequency of licensee QA audits have been established and are idequate.
(3) Welding activies are in accordance with PSAR and NSSS specifications. (Use applicable portions of Procedure -
No. 55093B as guidance.)
(4) The trial fit up of PWR internals inside the reactor vessel is satisfactorily accomplished.
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In some cases, the int,ernals will be stored in the refueling canal until core loading. Observe protection and frequency of QC inspection during this interim.
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- 9. Reactor Vessels Internals f2 02-(bEf i " / 8 f()-l/g/(hh/Yemz 9/-09 i 50063B OBSERVATION CF WORK KO TORK ACTIVITIES l Ascertain whether requirements of applicable specifications, work and inspec-tion (QC) procedures are being =et in the following areas: I
- 1. Protection of Stored Vessel Internals '
- a. Internals storage , _6Ld-l b. Protection / protective coverings 1 i
- c. Storage supports '
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- 2. Installation Techniques
- a. Lifting and handling are consistent with established requirements and precautions
- b. Lifting equip =ent is as specified
- c. Place =ent is being (or has been) accomplished in confor=ance with requirements
- d. Installation is being (or has been) accomplished in conformance with require =ents. Ascertain whether:
(1) Work procedures have been '
followed (2) Installation is in accordance with specifications .
(3) Inspection (QC) activities in accordance with established procedures
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l 3. Installed Vessel Internals Protection l
- a. Procedures for protection are being
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- b. Protective devices are installed around top of open vessel
- c. Vessel side openings are blanked off
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- d. Access control is provided to assure j only authorized entry l
- c. Cleanliness requirements ure being tuet _ _, _ , _ , _ . . ,
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%, UNITED STATES f3- , e' g - NUCLEAR REGULATORY COMMISSION ~ ~-
5~ i REGION IV f 611 RYAN PLAZA DRIVE. SulTE 1000 o,,,,,*** ARLINoTON. TEXAS 76011 In Reply Refer To: December 23, 1980 ket No. 50-445/Rpt. 80-26 50-446/Rpt. 80-26 hahM dii
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Texas Utilities Generating Company m&
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t Attn: Mr. R. J. Gary, Executive Vice President and General Manager 2001 Bryan Tower Q o w v o- gy p ~3 b. .L ~</
Dallas, Texas 75201 4/ b. &N b ~ M Nq - :
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tQ a fInA.A.) ~7L (a S h o a.:) /O O] .
This refers to the inspection conducted by Mr. R. C. Stewart of our staff i during the periods November 5-7, 13-14, 18-20 and 24-25, 1980, of activities authorized by NRC Construction Permits No. CPPR-126 and 127 for the Comanche ,
Peak facility, Units No. I and 2, and to the discussion of our findings with Mr. R. G. Tolson of your staff at the conclusion of the inspection.
l Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector, i
Within the scope of the inspection, no violations were identified.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10 Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If the report contains any information that you believe to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the information is proprietary. The application should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
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Texas Utilities Generating Company 2 December 23, 1980
-l Should you have any questions concerning this inspection, we will be pleased.
to discuss them with you.
Sincerely,
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. C. Seidle, Chief Reactor Construction and l Engineering Support Branch
Enclosure:
IE Inspection Report No. 50-445/Rpt. 80-26 50-446/Rpt. 80-26 l
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE'0F INSPECTION AND ENFORCEMENT REGION IV I
Report No. 50-445/80-26; 50-446/80-26 Docket No. 50-445; 50-446 Category A2 Licensee: Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 Facility Name: Comanche Peak, Units 1 and 2 1 Inspection at: Comanche Peak Site, Glen Rose, Texas Inspection Conducted: November 5- -14, 18- , and 24-25, 1980 l
Inspector: .
. h4 /27 h/
R. C. Stewart, Re. actor Inspector Date Projects Section i
Approved: ,_ = /y/J4//g W. A. Crossman, Chief, Projects Section Date Inspection Summary Insoection on November 5-7, 13-14, 18-20, and 24-25, 1980 (Report No. 445/
80-26: 50-446/80-26)
Areas Inspected: Routine, unannounced inspection of construction activities includin l piping; g the review of QA implementing procedures relating to safety-related reactor vessel / internals; and instrumentation components and systems. '
In addition, the inspection included observation of work and work activities relative to instrumentation installations for components and systems, with a corresponding records review. The inspection involved seventy-five inspector hours by one NRC inspector.
Results: No violations or deviations were identified. '
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OETAILS
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- 1. Persons Contacted l
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Principal Licensee Personnel J. George, Texas Utilities Services, Inc. (TUSI) I J. Merrit, Manager, Engineering and Construction, TUSI i I
J. Ainsworth, QE Supervisor, TUGC0 Other Personnel T. Hawkins, Project QA Manager, Brown & Root (B&R) '
J. Henline, Supervisor, Instrumentation, B&R C. Osborn, Supervisor, QA/QC Records Vault, B&R G. Willis, Supervisor, ASME, B&R The IE ,ospector also interviewed other licensee and contractor employees during the course of the inspection.
- Denotes those attending the exit interview.
- 2. Site Tour The IE inspector toured the Units 1 and 2 Reactor Buildings and Auxiliary J Building to observe construction in progress and to inspect housekeeping.
No violation or deviations were identified, i
- 3. Oh/0C Implementing Procedures Review
- a. Safety-Related Piping The IE inspector conducted a follow-on review of the B&R " General
.i Piping Procedures," CP-CPM-6.7, Revision 2, dated November 7, 1980, in conjunction with a review of NRC Regulatory Guides and the Comanche Peak Steam Electric Station FEAR. .The purpose of the review was to ascertain the current status of the procedures and whether the licensee and contractors continue to meet QA program commitments for i piping receipt, fabrication, erection, inspection and testing of (
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safety related piping systems outside the reactor coolant pressure boundary. l t
NRC Regulatory Guides, B&R procedures and sections of the FSAR reviewed included the following:
NRC Regulatory Guide 1.26, " Quality Group Classifications" NRC Regulatory Guide 1.28, " Quality Assurar.ce Pro' gram Require-ments" i
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NRC Regulatory Guide 1.58, " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel" ]
l NRC Regulatory Guide 1.88, " Collection, Storage, and Maintenance of Nuclear Power Plant Ouality Assurance Records" ,
FSAR, Sections 1, 3, 5, 6 and 17 '
FSAR, Appendix 1A(B)
FSAR, Appendix 1A(N)
B&R, " General Piping Procedure, CP-CPM.6.9, Revision 2, November 7, 1980 -
B&R, " Drawings," CP-CPM 6.9A, Revision 1 March 31, 1980 B&R, " Weld Filler Material Control," CP-CPM 6.9B, Revision 1, October 17, 1980 B&R, " Material Control," CP-CPM 6.9C, Revision 1, July 21,1980 B&R, " Welding & Related Processes," CP-CPM 6.9D., September 23, 1980 B&R, "ASME Welding," CP-CPM 6.90-11, September 23, 1980 B&R, " Pipe Fabrication and Installation," CP-CPM 6.7E, Revision 2, October 27, 1980 '
B&R, "QC Instructions for Pipe Fabrication and Installation,"
RP-CPM 6.9E-1, Revision 2, August 28, 1980 No violations or deviations were identified.
- b. Reactor Vessel Internals Th'i>$ ktd k U pyo e 5 0 c) G (
The it. conducted a follow-on review of the B&R Procedure, 35-1195 MCP-10,
" Storage and Storage Maintenance of Mechanical and Electrical Equip-ment," dated May 21, 1980, relative to the storage and maintenance requirements for the reactor vessel internals. In addition, the following related procedures were reviewed: I CP-QAP-7.2, "QC Receiving Inspection" QI-QAP-7.2-8, " Receiving of Westinghouse Safety-Related Equipment" CP-QCP-1.2, "QC Surveillance of Storage, Warehousing and Material Control" No violations or deviations were identified.
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- c. Instrumentation - Components anct Systems The IE inspector conducted a folica..on review of the B&R/TUGO instr'u-ment inspection manual procedures in conjunction with a review of /
NRC Regulatory Guides and the Comanche Peak Steam Electric Statiorr" l l
FSAR. The purpose of the review was to ascertain the current status l of the procedures and whether the licensee contractor continues tb i meet, QA program commitments for instrumentation fabrication, erection, inspection and testing. j l
NRC Regulatory Guides, B&R/TUGC0 procedures and sections of the 1 FSAR reviewed included the following* .j l
NRC Reculatory Guide 1.26, " Quality Group Classifica*. ion" .
NRC Regulatory Guide 1.30, "QA Requirements for the Installation, Inspection, and Testing of Instrumentation cnd Electric Equipment" NRC Regulatory Guide 1.53 (1975), " Application of the Single-Failure Criterion to Nuclear Power Plant Protection Systems" 1 1
l NRC Regulatory Guide 1.75, Revision 1 (1975), " Physical Indepanoence of Electric Systems"
- - 1 IEEE 336 (1971), ^!nstalletion, Inspection and Testing Requirements ' I of Instruments and Electrical Equipment During the Construction or- I Nuclear Power Generating Stations" CPSES FSAR, Sections 1.7.1, 3.2.2. 7.1.2.7, 7.1.2.2.1, ?.1'.2.7, 17.1, 17.2, and Appendix 1A(N)
B&R/TUGC0 Procedures QI-QP-2.1-8, " Qualifications of Inspection and Testing Personnel," !'
dated Se,?tember 22, 1980 ~
CP-QP-11.8, " Instrumentation and Control Inspection Activities ,"
Revision 2, dated May 15, 1980 QI-QP-11.8-1, "Instrunrent Tubing and fittings Inspections," Revision ~ !
4, Dated August 25, 1980 ,
QI-QP-11.8-2, Instrument Supports and Rack Assembly inspection,"
Revision 4, dated June 19, 1980 QI.QP-11.8-3, " Instrument Installation Inspection," Levision 2, dated July 16, 1980 CP 'QP-15f, " Tagging System," Revis lon 1, dated September 3,1980 l l
No violations or deviations uru identified.
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. Observation of Work and Work Activities
- a. Esfety-Related Dipit;g During thu inspection, the IE inspector conducted a plant walk-throuct in buildings of Unit 1, Unit 2 and the pipe fabrication shop. The IE inspector observed that a very limited amount of stainless steel Class 2 piping installation was in progress during the inspection period. The lE inspector made a limited observation of handling and installation practices of safety-related piping in progress, including the practices being employed in positioning piping components, such as spool pieces and valves. The activities appeared to be con-sistent with B&R Constructing Procedure 35-1195-CPM 6.9.
- 3 No violations or deviations were , ,
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. eactor Vessel Internals '4 The IE ir,spector conducted a walk-through in Units 1 and 2 Containment Guildings to observe the practices being employed in the protection of the reactor vessel internals and in conjunction with the procedures outlined in 3.b above. The IE inspector observed that FO '
j portions of tractor vessel internals were contained in the Unit I reactor vessel and were well protected. The U Wt 2 reactor vessel internals were stored in well protec'ced storage enclosures.
No violations or deviations were identified.
- c. Installation of Locally Mounted Instruments and Tubino and Corresoondine DT Records Revision i
During this inspection, the IE inspector made a random selection of Unit 1 QA/QC records for comparison with completed ir.stallations of locally mounted instruments and tubing. Observations of records and installations were made in conjunction with Gibbs and Hill Drawing 2323-M-2100, " Instrument Installation Details " and procedures and documents outlined in 3.c above. The following installed instruments were selected:
Component Coolinc System 1-FT-4678 (Containment Building), el. 832'-6"
- 1-FT-4686 (Containment Building), el. 832'-6"
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1-FT-4704 (Containment Building), el. 808'-6" 1-PI-4516 (Auxiliary Building), el. 810'-6" 1-PI-4517 (Auxiliary Building), el. 810'-6" 1-PI-4522 (Auxiliary Building), el. 810'-6" 5
i 1-PI 4523 (Auxiliary Building), el. 810'-6" l
1-PS-4506 (Auxiliary Building), el. 873'-6" '
1-PI-4767, Safeguards Building Chemical Volume Control System 1-FT-136 (Auxiliary Building), el. 856'-6" 1-FT-183 (Auxiliary Building, el. 810'-6" 1-FT-108 (Auxiliary Building), el. 810'-6" 1-PI-109 (Auxiliary Building), el. 810'-6" 1-PI-113 (Auxiliary Building), el. 790'-6" i
1-PI-114 (Auxiliary Building), el. 790'-6" l i
1-PI-175 ( Auxiliary Building), el. 852'-6" l l
1-PI-176 (Auxiliary Building), el. 852'-6" 1-PI-141 (Auxiliary Building), el. 852'-6" No violations or deviations were identified.
- 5. Exit Interview ,
The IE1)inspector graph on November met with the licensee representatives (denoted in para-25, 1980, and summarized the purpose, scope and findings of the inspection.
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