ML20238A573
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~ CPR$ $- 4 y 4
February 12, 1987 (
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MEMORANDUM FOR:
Robert D. Martin, Regional Administrator I
\
FROM:
H. S. Phillips, Senior Resident insp1ctor 1 i
Comanche Peak Construction
!I 1
SUEJECT: IMPROPER CLOSURE OF OIA REPORT ISSUES i
I t
During the last year there have been many instances where Mr. 'Darnes, l RIV Comanche Peak Supervisor, has not informed me of inspections in Unit 2 for l
which I am responsible, general meetings with Texas Utilities, exit interviews (i.e., or inf orms se late leaving a short time to prepare) and other basic {
information, it is the supervisor's responsibility to coordinate all activities to prevent duplication of effort and misunderstandings and to give ,
j project information to 3 [1 empicyees. .
As I have been tracking the IE Manual Chapter 2512 inspections and open items, I it is necessary for Barnes to have each team leader and NRC consultants to provide such information. Except for Phil Wagner, RIV CPTG Leader, I have had j
no cooperation and it appears that I have been purposely isolated with no ;
resources. I have been largely ignored since Westerman and Barnes came to the !
site. Yesterday morning I had a discussion with a Texas Utilities representative who advised me that Mr. Barnes and a team leader knowingly 446/8505-U-05 and 446/8505-U-06 in NRC Inspection closed out unresolved items which concerned issues in the 01 A Report 86/07-05 dated December 22, 1986, Report; i.e., findings on the vessel installation. These items were on the RIV Comanche Peak Task Group tracking list assigned to Phil 2ps which Barnes and other team leaders have (see. attachment). t These findings have been the subject of disagreement since August 1985 and Barnes was well aware of the disagreement and who was responsible for f ollow-up inspection as he was in the February 1986 neeting where dif f erences on this report were discussed. Regardless, Barnes neither advised llllll[ and Phillips that he was assuming responsibility f or these items nor did he obtain As a result of this approach, Phillips has their concurrence on the closure.
unknowingly duplicated this effort during September through December 1986 I inspections, and has made statements to the Headquarters DIA 86-10 Review Phillips' additional f Group that do not reflect this further inspection. '
"" inspection identified other findings that are not reflected in Barnes' Report l 86/07-05 which closed these issues and these areas will have to be !
reinspected. 1 Barnes did not provide other information which is pertinent to the OlA Report issues and necessary to provide the 86-10 Review Broup my understanding of the 8708210013 B70312 l
PDR ADOCK 05000445 G PDR Rlt CF Phillips:ww 2 //3/ B7 . - . . .
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)k H. S. Phillips 2 February 12, 1987 issues. I wrote Barnes a memorandum dated December 17, 1986, in which I discussed this matter. With respect to another example, letters from Vince Nooman, NRR, to Texas Utilities concerning follow-up of OIA issues 85/07-05, 85/14-11 and 85/16-13 were brought to Barnes attention.about February 5, 1987 1 however, he has not mentioned them to me to date.
Similarly, packages furnished to Barnes by Texas Utilities in January 1987 were withheld and I had to go to the utility to get such information.
I do not know if these actions are purposeful or'just a result of his having very little construction inspection experience. Either way, it is unacceptable to close issues identified and assigned to others withoutE coordinating with the respective inspector to obtain his concurrence. .See the attached concurrence letter, paragraph 2 of Report B6/07-05, and RIV CPT6 open items list.
9' 9 H. S. Phillips Senior Resident inspector Comanche Peak Construction
Enclosures:
- 1. Report 86-07/05
- 2. CP Unit 2 Tracking
- 3. Phillips Memo 12/17/86
'ec w/ enclosures:
J. Davis, Chairman P',
,01A 86-10 Review Group V. Stello, EDO I. Barnes, RIV Chief, CPTG
. Resident File 1
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In Reply Refer to: .
Dockets: 50-445/86-07 DEC 2 21986 50-446/86-05 Texas Utilities Generating Company ATTH: Mr. W. G. Counsil
\ Executive Vice President 400 North Olive Street, L.B. 81 Dallas, Texas 75201 )
Gentlemen:
This refers to the inspection conducted by Mr. I. Barnes and other members of )
the Region IV Comanche Peak Group during the period April I through May 31, 1986, of activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for the Comanche Peak Steam Electric Station, Units 1 and 2, and to the discussions of our findings with you and other members of your staff during the inspection on May 8, 1986, and on June 3, 1986, at the conclusion of the inspection.
i Areas examined during the inspection included Comanche Peak Response Team activities and assessment of allegations. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspectors. These findings are documented in the enclosed inspection report.
aring this inspction, it was found that certain of your activities were in violation of HRC requirements. Consequently, you are required to respond to these violations, in writing, in accordance with the provisions of
' Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter.
Also during this inspection, it was found that certain of your activities appeared to deviate from commitments made to the NRC. These items and references to the commitments are identified in the enclosed Notice of Deviation. You are requested to respond to these deviations in writing. Your response should be based on the specifics contained in the Notice of Deviation enclosed with this letter.
Six unresolved items are identified in paragraphs 4.c, 5.a. 5.b. and 5.1 of the enclosed inspection report.
We have also examined actions you have taken with regard to previously identified inspection findings. The status of these items is identified in paragraph 2 of the enclosed report.
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5 Theinspection this NRC inspectors period. also contacted other CPRT and' applicant employees I 2.
Applicant Actions on Previous NRC Inspection Findings .
- a. (Gosed)a,Unresulved Item (445/8601-0-21):
seismic This item dealt with a l i
rrestor bracket being welded over raised cast identification i letters on an the actuator barrel assembly, resulting in a weld which exhibited incomplete fusion and overall poor workmanship.
During the review of this item, it was identified that TUGCo, by letter to the NRC dated April 21, 1983, had reported this condition i under 10 CFR Part 50.55(e) and had committed to immediately discarding and replacing the arrestor brackets. The failure to implement the committed corrective actions is a deviation I (445/8607-D-01).
- b. (Closed) Open Item (445/G516-0-11):
In November 1985, the NRC inspector ISAP III.d.attempted to review documentation related to commitments in Sections 4.1.1.3 and 4.1.1.4 of the ISAP committed the CPRT to review the CPSES document control program and to interview system test engineers (STEs) to help assess the adequacy of existing procedures and methods of obtaining current design information for testresults no procedure updates. There were only a few handwritten notes with indicated.
The CPRT indicated that the final results report was for ISAP published on III.d Marchwould address these items. The results report 13, 1986.
results report In Section 5.2.2 and 5.2.4 of the Startup Documen,t Control Center (DCC) satellite and the evo the methods by which the Startup and DCC organizations attempted to provide convenient STE access to current design documents. The results of this review, as indicated in the results report, revealed that prior to April 1983, the control and distribution of design documents was centralized in the main DCC facility. The STEs found the task of obtaining current design information time consuming, burdensome,'and the DCC was unresponsive to their specific needs. In April 1983, the first satellite of the DCC was established in the Startup facility. After about a year, a review was conducted to evaluate the control of design information. The review found tha't the system was working; however, it was cumbersome and continued to be a burden on the STEs. In April 1984, satellite libraries maintained areas. by the DCC were established for various key Startup office The CPRT concluded from (1) their review of the evolution of the document control program, and (2) the results of the ISAP random sampling and evaluation, that STEs, after April 1984 working with a burdensome system and could obtain cur, rent designwere no longe information in a timely manner. With regard to STE interviews, Section 5.2.3 of the results report documented the fact that eight 1
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- g. (Closed) Open Item (445/8516-0-31): The comparison of ERC's document review results for Verification Package R-E-ININ-016 with the NRC's :
results was completed during th a report period with no differences identified. This' item is closed. ,
I
- h. (closed) Open Item (445/8516-0-32):- Tre comparison of ERC's document review results for Verification Package R 4-ININ-072 with the NRC's results was completed during this report period with no differences identified. This item is closed.
- 1. (Closed) Open Item (445/8516-0-33): The comparison of ERC's document review results for Verification Package R-E-ININ-079 (for pressure transmitter IPT-4520) with the NRC's was completed during this report y riod. The ERC inspector had failed to identify an inspector who was not certified when he signed an Instrumentation Tubing Manufacturing Record Sheet. This item is a deviation (445/8607-D-03). -
j.
(Closed) Unresolved Item (446/8505-05): This ites dealt with the unavailability of a site prepared installation drawing and specification with respect to reactor pressure vessel (RPV) placement.
The NRC inspector performed a review of documentation associated with installation of the Unit 2 RPV. The governing irsta11ation was Brown & Root Procedura MCP-1 grocedure Installation for of 3 d
' echanical Equipment." Paragraph 4.1.1 in MCP-1 requires that equipment installation travelers be prepared in accordance with site Procedure CP-CPM 6.3, " Preparation, Approval, and Control of Operation Travelers. Operation traveler ME79-248-5500, Revision 0, was issued which described the field instructions for installation of '
the Unit 2 RPV. The operation traveler incorporated the requirements ;
recommended by Westinghouse Nuclear Services Division (WNSD) ~
procedures for this activity; i.e. , " 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. 2 These WNSD procedures were not made a part of the traveler package, in that they are generic and have been used by WNSD at several si.tes.
However, the specific guidelines were utilized during the traveler preparation. All of the necessary installation steps were reviewed and approved by site QA/QC personnel and by a site WNSD representative.
While there was no site specific installation procedure, an operation traveler was prepared, reviewed, approved, and issued; thus it became the controlling document.
k.
(closed) Unresolved Item (446/8505-06): This item dealt with no documented engineering evaluation onsite justifying the final l
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8 tolerances of Unit 2 RPV clearances between support brackets and !
support shoes. This item was considered unresolved pending receipt of documentation validating the final installation tolerances.
The original. tolerances specified on operation traveler ME79-248-5500, Revision 0,-were extracted from the WNSD generic procedures. The
.i operation traveler's installation tolerances were subsequently revised to reflect site specific field conditions. Westinghouse concurrence with the revised tolerances was documented by signature on the operution traveler. In addition, Westinghouse Water Reactors Division provided the basis for the Unit 2 RPV shim installation tolerances in letter WPT-8148 dated January 10, 1986,.which was in response to TUGCo's letter CPPA-48113. As a result of the receipt of documentation I i
validating the final installation tolerances. This item is resolved.
Concurrent with the evaluation of this unresolved item, the NRC inspector reviewed documentation for shims installed between the Unit 1, Loop 2, reactor coolant crossover . leg and crossover leg restraints.
Construction operation traveler ME84-4715-5500 references Design Change Authorization (DCA) 21,116 Revision 0. This DCA addresses a problem with respect to clearance,between interior shims and crossover piping that occurred during hot functional test. The-solution required the addition of shim stock as necessary to maintain zero clearance. The-listed supporting documentation shows the acceptance 1984. criteria to be a letter from Westinghouse dated April 26, Review of the Westinghouse letter revealed that it does not address the stated problem in the DCA. Paragraph 2.4.1 in Revision 6 of THE Procedure THE-DC-8-1, " Design Verification of Field Design Changes,"
states, in part, "If the field des!gn change, had been transmitted to Gibbs & Hill and Gibbs & Hill has steted that it is not within their .
scope as per of this work, then the field design change shall be design verified instruction. "If design verification can only be performed by the vendor . . . , the Verifier shall transmit the change to the vendor requesting the specific vendor action required. -
Resultant documentation from the vendor shall be included as a part of the design verification documentation prepared by the verifier." l The DCA was submitted to Gibbs & Hill (G&H) for review and approval.
Subsequently, September G&H responded on change verification checklist dated ,
4 28, 1984, for the above DCA, "G&H documents are not affected. Vendor review i: required." It was determined that the DCA was not routed to the vendor (Westinghouse) for review and approval.
While the required vendor review and approval was not performed, the DCA was implemented by traveler ME84-4715-5500. In
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9 addition, the traveler documented the need to shim two locations only. However, observation of the actual assembly revealed that all nine locations were shimmed.
The failure to acquire the responsible design organization's review and approval of changes is a violation (445/8607-V-04).
- 3. Assessment of Allegations a.
AQ-159 Staffs and A0-162 (4-85-A-31): Poor Communication Between OA and OC It was alleged that there were very few interfaces and little communication between the site surveillance group, the Dallas QA audit group, and the operations audit group, even though their functions are basically the same and such interfaces and communications would increase the effectiveness of each of the groups.
This allegation lacked any specifics or consequences resulting from this lack of interface and communication, but was' based on the alleger's subjective perception of conditions arising from contacts with Dallas audit personnel, operations audit personnel, and QA/QC management. 'The NRC assessment.of this allegation is based principally on an evaluation of NRC assessment of other allegations and recent inspections in the operations QA, Dallas QA, and surveillance areas. The following are items noted during these ,
i previous assessments and inspections that are related to this '
allegation.
During NRC assessment of allegations in the operations QA area, it was noted that the operations QA program is structured in a similar manner to other operations QA programs; however, with the CPRT and other similar efforts causing numerous modifications to equipment within the scope of operations responsibility, this QA program is being forced into functions and programmatic areas for which the program was not structured to operate in an efficient manner. As a result, these equipment modifications are being made by the site construction force, and in most cases the inspection function is' performed by the construction QC inspection group (both groups functioning according to the construction QA program), while overview is being provided by the operations QA group functioning to a different QA program. Even though both the cons operations QA programs may be in compliance with,truction and regulatory requirements, there is no assurance that these programs are ,
j compatible and they, of course, are not interchangeable. One example of incompatibility is the difference in construction's and :
l operation's treatment and processing of NCRs that was identified in NRC Inspection Report 50-445/86-01; 50-446/86-01. i
. #W onN
- Page No. 1 08/18/86 COMANCHE PEAK UNIT 2 --- NRC INSPECTIDN FINDINGS --- STATUS REPORT (WITH RESPONSIBILITY) -
TRACK NO. DESCRIPTION OF FINDING FINDING 10. RESPONSIBILITY REPORTS DUE UPDATE s
- a Broun & Root failed to develop an inspection procedure soils
[ (Report Part 75-05-V-00-50 Hedsett, s. L. Open: 75-05 1 86-02-12 1 RIV DRSP Closes
%F 1-0013_Environenntal ites 77-05-U-00-00 M lp Open: 77-05 1 86-02-12 iner [ Report Par: 1 RIV DRSP Close:
F 1-0142 Stability of box spring design / construction. 82-14-0-03 Westeraan,T. Open: 82-14 i 86-05-19 IReport Par: 1. RIV DRSP Close:
)F1-0054 TUSCO audits of NPS industries did not (!) follo.tp Cl plans 82-25 ','-00-St dst sar., T. Open: 82-25 1 86-02-12 IReport Par: 1 RIV DRSP Close:
F 1-0055 Correction of CC-2-008-709-A4!K 82-26-0-00-00 Westeraan, T. Open: 82-26 1 86-02-12 Unit 2 Specific itee [Repert Par: 1 FD-005 RIV DRSP Close: '3
.*b gn 1-0059 oa ing damaged or improper on itess supplied to Westinghouse 83-47-U-01-00HeakeEt,D. Opens 83-47 1 86-02-12
- ffect E ESF [ Report Par: 1 RIV DRSP Close:
\
F 1- 2 QA Mgt had not defined objectiv es & scope of QA Frogras. 84-!!-U-06 Hale, C. Opent 84-11 1 86-08-04 IReport Par: 1 RIV DRSP Close:
N F 1-0 9 Retraining of welding Superviso rs in Filler Material Control. 85-02-V-02 .b,h Open: 85-02 1 86-02-12
[ Report Par: 1 RIV DRSP Close F 1-0070 Unavailability of Meteorological 1 Data. 85-03-0-01 Murray Open: 85-03 1 86-02-12 (Report Par:
,,,p 1 RIV DRSP Close:
arrec:fon of records for scale calibration. . 85-05-U-03 Phillips,S. Open: 85-05 1 86-05-19 IReport Par: B.9. RIV DRSP 1
Q: p,.Q S 0108 Drawings and specs not availabt e on installation of RPV. 85-05-U-05 Phillips,S. Open: 85-05 1 86-05-19 D
[ Report Par: 8.)2.a. 1 RIV tiRSP Close:
h 109 Onsite evaluation justifying fi nal tolerances for installation 85-05-U-06 Phillips,S. Open: 85-05 1 86-05-19 W of Unit 1 RPV. [ Report Par: B.12.b. 1 RIV DRSP Close:
-0110 No aadits made of the Reactor V essel Placesent. 85-05-U-07 Phillips,S. Open: 85-05 1 86-05-19 (Report Par: B.12.d. ) RIV DRSP ,Close:
IFl-0!!! Evaluation of hyaro data pkg.fo r Unit 1, loop 3 cold leg i.e. 85 05-U-09 Phillips,S. Open: 85-05 1 86-05-19 setal repairs and welds.
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W (Report Par: 9.14.c(2). 1 7 1-0104 Failure to correct & identif t w ith RTE-DELTA Pot. Transformer 85-05-V-01-54 Phillips,S.
RIV DRSP Close l
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Tiltout Subassemblies.
Open: 85-05 1 86-05-19 D !
IReport Far: B.3.a. 1 RIV DRSP Close: g g F 1-01044 allure to document inspection of cement truct aising blades. 85-05-V-02-55 Phillips,S.
) , IReport Part B.B. en: 85-05 1 86-05-19) 1 RIV DRSP Close: y(,,, ,,,,j 1-0107 Failure to assure calibration o f mater & cesent scales. 85-05-V-04-54 Phillips,S.
[ Report Par: B.9.c. Open: 85-05 1 86-05-19 1
RIV DRSP Close:
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