ML20238A847
| ML20238A847 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/04/1986 |
| From: | Phillips H NRC |
| To: | Westerman T NRC |
| Shared Package | |
| ML20237F760 | List:
|
| References | |
| NUDOCS 8708210099 | |
| Download: ML20238A847 (21) | |
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"It s j#R%g UNITED STATES b
NUCLEAR MGutXTORY COMMISSION e,
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April 4,
1986 Docket Nos. 50-445 446 MEMORANDUM FOR:
T. F.
West erre an, Chief Comanche Pn3k Group i
FROM:
H.
S.
Phillips, Sennor Resident Ipspector Comanche Peak
SUBJECT:
NRC INSFECTIUN REPORT 85-16/13 AND RETENTIOW OF DRAFT REPORTS i
On April 1,
1986, I received the November 1985 inspection report l
for final review, signature, and concurrence.
I reviewed, l
signed and concurred ot. this report as an inspection team memberg however, my signature does not mean that I agree with the changes to Appendix C which management directed me to make; i.e.,
I was directed to drop violations from paragraphs 3 and 4 of this report.
I changed these findings f rom violations to unresolved or open items as directed but at that time I told you I still thought the findings were violations.
My signature means that I recognize that supervisors and managers have the authority to make such changes.
I signed the October 1985 report (85-14/11) and the April - June 1985 report (85-07/05) under similar c ondi t ixn s.
I verbally advised you in each instance that I disagreed aith violations being downgraded but would sign the reports only because I recognized management's authority to make changes.
I am retaining my original work as recorded in the draft reports except 85-07/05, 85-11/06, and 85-13/09 which I destroyed as directed; however, I have since regretted it because I needed to refer to them.
If management's position is correct, the differences in the final, interim, and initial draf t reports should be easily explained and it should make no difference that I am retalning my comp 1 tete inspection files for these and future reports.
I was an NRC Supervisor a couple of years and when I asked for or directed 8708210099 670G19 PDR ADOCK 05000445 i
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Phillips PAGE 2 4/4/86 l
I changes to reports I encouraged inspectors to keep their original work as I would take responsibility if I made changes that were not correct or appropriate.
cys H.
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Phillips Senior Resident Inspector l
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To mr* Q RA M s _ APPENDIX A O us ' ^ NOTICE OF VIOLATION Texas Utilities Electr.ic Company Docket: 50-445/85-07 Comanche Peak Steam Electric Station 50-446/85-05 1 Units 1 and 2 Permit: CPPR-126 l CPPR-127 During an NRC inspection conducted on April I through June 21, 1985, violations of NRC requirements were identified. The violations involved a failure to correct RTE Delta hardware problems; failure to use class "E" concrete (grout) as specified; failure to document unsatisfactory conditions during receipt inspection of the Hydrogen recombiners; failure to in?pect ) concrete mixer blades quarterly; failure to document cement scales which were out of calibration; failure to translate design criteria for reactor vessel installation into specifications, procedures, and drawings; failure to maintain stated tolerances and to report the failure on a runconfomance report; failure to audit RPV specifications / procedures, instq11ation, and as-built records; failure to properly identify a charging system spool piece; and failure to furnish or maintain records for reactor coolant systems materials. In accor-dance with the " General Statement of Policy and Procedures for NRC Enforcement Actions "10 CFR Part 2, Appendix C (1985)..the violations are listed below: 1. Failure to Promptly Correct an Identified Problem with RTE - Delta Potential Transformer Tiltout Subassee%11es 10 CFR 50, Appendix B, criterion XVI as implemented by the Texas Utilities Generating Company (TUGCO) Quality Assurance Plan, Section Revision , requires that measures shall be established to assure tE t conditions adverse to quality, such as failures, malfunctions, deficien-i cies deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, a potential problem with RTE - Delta potential transforiser tiltout subassemblies, which are used in the emergency diesel i generator control panels, was identified to the applicant via a letter, dated June 15, 1983, from Transamerica Delaval Inc. 'This letter also provided instructions for correcting the potential problem. However, the applicant did not perform the corrective action. The fEC initially i reported,this item as unresolved in NRC Inspection taport 445/84-40. This is a Severity Level V Violation. (Supplement II.E) (445/8507-01 446/8505-01). ) 2. Commercial Grout Used in Lieu of Class "E" Concrete - 1 10 CFR Part 50, Appendix 8, criterion V, as implemented tip'the,7000'0. 4 l 4 l Plan, Section 5.0, Revision _,, requires that activities affecting guelity 1 l shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall,be accomplished'in accordance with these instructions, procedures, or drawings. I
3d s" At h AS. T L Contrary to the above, commercial non-shrink grout was used to grout the j Unit 1 reactor coolant pump and steam generator supports in lieu of Class "E" concrete as specified in Section 6-6 of drawing 2323-51-0550, Revision 4. The NRC initially reported this item as unresolved in NRC i IR 445/84-16. l This is a Severity Level IV Violation. (Supplement II.E) (445/8507-02). 3. Hydrocen Recombiners - Out. of Specification Voltage Recorded on Westinghouse Quality Rele.2se Document 10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 QA Plan, Section 5.0., Revision 2, requires that activities affecting quality i shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Brown and Root Procedure QI-QAP-7.2-8, " Receiving of Westinghouse Safety Related Equipment", Section 3.1.d.1, required a QC inspector to verify 1 that the Westinghouse Quality Release (QR) document checklist items be filled out completely and accurately. Contrary to the above, the voltage recorded on Westinghouse QR 41424 checklist, attachment 1, step 4.1, was outside.the specified tolerance, but the QR was accepted as satisfactory by' quality control receipt inspection. The NRC initially reported this ites as unresolved in NRC IR No. 50-445/84-16. i I This is a Severity Level V Violation Supplement II.E (445/8505-03). 4. Failure to Provide Ob.iective Evidence (Records) to Show that Concrete Central and Truck Mixer Blades were Inspected 10 CFR Part 50, Appendix 8, criterion V, as implemented by the TUGC0 QA Plan, Section 5.0, Revision 2, dated May 21, 1981, requires.that activities affecting quality shall be prescribed by doctamented instruc-tions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, proce-dures, or drawings." l Brown & Root Procedure 35-1195-CCP-10, Revision 5. dated December 4. l 1978, requires that central and truck mixer. blades be;checkad! quarterly to assure 'that mixer blade wear does not exceed a lossief.15%f. original' blade height. 1-n1/ ' E,... ... ' q.Wf itkiet Contrary to the above, on May 31, 1985, the MC inspector.' there was no objective evidence (tscords) that the aim bl ?tind'heen. inspected quarterly since the trucks were placed in cg,1%# p p .m. !f ,......-.......,.-..,...w..,._,__.._ _.g.._.. -,,,_._?-_._-.- ,,.y
I' { AL " Ort A This is a Severity Level V Violation. 446/8505-02). (Supplement II.E) (445/8507-04; 5. Failure to Issue a Deficiency Report on Cement Scales That Were Out of Calibration 10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 QA Plan, Section 5.0, Revision 2, dated May 21, 1981, and Section 15.0, Revision 4, dated July 31, 1984,. requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be ac.:omplished in accordance with these instructions, procedures, or drawings. Brown & Root Procedure CP-QAP-15.1, " Field Control of Nonconforming Item, " states that nonconforming conditions shall be documented in a Deficiency and Disposition Report (DDR). Procedure CP-QCP-1.3, " Tool Equipment Calibration and Control," dated July 14, 1975, states that out of-calibration equipment shall be identified on a 00R. Contrary to the above, on May 31, 1985, the NRC inspector reviewed the calibration file for scale (MTE 779) used for weighing cement and found that difficulty was encountered with the water and cement scales during a 1975 calibration of the backup plant scales; however, no DDR was issued to identify this condition and require disposition of the scale and concrete (if any) produced. This is a Severity Level IV Violation. (Supplement II.E) (445/8507-06; 446/8505-04). 6. Failure to Translate Desion Criteria Into Installation M ifications. Frocedures, and Drawinos: and Failure to Control Deviations from These Standards 10 CFR 50, Appendix B, Criterion III, as implemented by TUGC0 QA Plan, Section 3, Revision 3, dated July 31, 1984, require that seasures shall be established to assure that applicable regulatory requirusents and the design basis, are correctly translated into specifications, drawings, procedures, and instructions. These measures shall include previsions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standar2s.are controlled. Contrary to the above, (a) Unit 2 reactor pressure vessel installation design criteria recommended by the MSSS vendor, such as centering tolerances, levelness tolerances, and shoe to bracket glearances. w;ere not included in installation specification, procedurespand ' drawings; and (b) the criteria were specified in Construction Operetten~ Tre^ve er. ' but were not treated as design ~angia' ering!critie)riai as ME-79-248-5500, o evidenced by an undocumented change of shoe to bracket.~ clearances. t w. %^ - ThisisaSeverityLevelIVViolation(SupplementII.EW44&B505-06')'. 7 W t =_
2 0 y' .Nb W.h r 7. Failure to Maintain Tolerances Stated and Failure to Report These Results on a Nonconformance Report 10 CFR 50, Appendix B, Criterion XV as implemented by the TUGC0 QA Plan, Section V, Revision 2 dated May 21, 1981, requires that measures shall be established to control materials, parts or components which do not conform to requirements; and nonconforming items shall be reviewed and accepted, I rejected, repaired; or reworked in accordance with documented procedures. Brown and Root Quality Assurance Manual, Section 16, dated Marca 27, 1985, requires that unsatisfactory conditions identified on pro:ess i control documents shall be identified on an Nonconforming Report. Contrary to the above, clearances between the reactor vessel support brackets and support shoes were not within the tolerance stated in Construction Operation Traveler ME-79-248-55 and the condition was not reported on a Nonconformance Report. 1 This is a Severity Level IV Violation. (Supplement II.E) (446-8505-07) 8. Failure to Audit RPV Specifications / Procedures, Installation and As-built Records i 10 CFR 50, Appendix B, Criterion XVIII as implemented by the TUGC0 QA Plan, Section 18.0,-Revision 2, dated July 31, 1984, requires that a / c - rehensive system of4 Cplanned and per,1 odic audits be carried out to verify compliance with all tv aspects of the quality assurance program. .k~ " ['9) \\ Contrary to the above, there was no evidence that TUGC0 had audited /. 3 either Unit 2 reactor vessel installation specifications, placement
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procedures, actual hardware placement, or as-built records. l /' f This is a Severity Level IV Violation. (Supplement II.E) (446/8505-08). 9. Failure to Properly Identify a Spool Piece 10 CFR 50, Appendix B, Criterion VIII, as implemented by the TUGC0 QA Plan, Section 8.0, Revision 0, dated July 1, 1978, requires that measures be established for the identification and control of materials, parts, and components, including partially fabricated assemblies. These measures shall assure that identification of the item is maintained by heat numbe,r, part number or other appropriate means.- o. Article-NA3766.6 of ASIE, Section III,1974 Edition. requires. -the identification of material consist of marking the asterial wl applicable material specification and grade of asterial.. heat'
- or heat code of the material, and any additional marking requirsid,t%%is r section to facilitate traceability of the reports'of the results.oflall tests and examinations ~ performed on the material.
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3UN'*% ~CKL M 7 Contrary.to the above, spool piece 3Q1 (DWG No. BRP-CS-2-RB-76) had i neither been marked with the material specification and grade, heat number or heat code of the material. This is a Severity Level IV Violation (Supplement II.E) (446/8505-09) 10. Failure to Furnish or Maintain Records for Material 10 CFR 50, Appendix B, Criterion XVII, as implemented by the TIGC0 QA Plan, Section Revision , requires that' sufficient records be maintained to furnish evidence of activities affecting quality. The records shall include at least the following: operating logs, and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses. Articles N8-2130 and NA3767.4 of ASME Section III, 1974 Edition requires a Certified Material Test Report for all pressure retaining material over 3/4 inch nominal size. Contrary to the above, certified Material Tgst Reports were not available for the 22 degree elbow, 10 inch 45 degree nozzle, and three thernowell bosses, which were a part of the loop 3 cold leg piping subassembly. This is a Severity Level IV Violation (Supplement II.E) (446/8505-10) Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is hereby required to submit to this office, within 30 dayr of the date of this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and l (3) the date when full compliance will be achieved. Consideration may be l given to extending your response time for good cause shown. Dated: i e i 9 --=. = -
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APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Repo.: 50-445/85-07 Permit: CPPR-126 50-446/85-05 CPPR-127 Docket: 50-445; 50-446 Applicant: Texas Utilities Electric Company (TUEC') Skyway Tower i 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES) Units 1 and 2 Inspection At: Glen Rose, Texas Inspection Conducted: April 1,1985, through June 21, 1985 l Inspectors: H. S. Phillips, Senior Resident Date Reactor Inspector Construction (pars. 1, 2, 3, 8, 9, 10, 11, 15, 16, l 17, 18, and 19) J. E. Cummins, Senior Resident Reactor Date Inspector Construction (April 1 - May 10,1985) , (pars. 1, 3, and 19) l I D. E. Norman, Reactor Inspector Date l (pars.1,12,13,14, and 19) D. M. Hunnicutt, Section Chief Date Reactor Projects Branch 2 f:. 1 (( (pars.1, 4, 5, 6 '7, and 19) PIf ' Approved: ,.y D. M. Hunnicutt, Section Chief, Date e' Reactor Project Section 8 s. .&s' p emes-rae,p.w-
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'[ylWDMW Y.. \\ . been corrected at CPSES and made this an unresolved item. The " applicant determined that the problem had not been corrected and subsequently performed the recommended corrective action. The Unit I corrective action work activities were documented on startup work permits Z-2912 (train A) and Z-2914 (train 8). The Unit 2 work activities are being tracked as master data base (28) item 3003-31. The failure to promptly correct this identified problem is an apparent violation (445/8507-01; 446/8505-01). b. (Closed) Unresolved Item 445/8416-03: Commercial Grout Used in Lieu of Class "E" Concrete The applicant detenmined that the use of non-shrink commercial grout ^ in lieu of the Class "E" concrete specified on drawing 2323-51-0550 was acceptable. Design Change Authorization 21179 was issued ti drawing 2323-S1-0550 accepting the use of the commercial non-sht nk 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-S> edification Voltaae Recorded on Westinghouse Quality 1 Release )ocument Quality Release N-41424 was revised changing the specified voltage from 10v-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 Procedure QI-QAP7.2-8 is an apparent vi'lation (445/8505-03). o d. (0 pen $ Unresolved Item 445/8432-06: 446/8411-06: Lobbin Reoort 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 i site surveillance personnel. The Lobbin report stated that the { scope and objectives of the site survelliance program were unclear, lacking both purpose and direction. There is.no specific regulatory requirement to have's survei.11aace program; however, TUEC committed to have a. surveillance.progree and has established, procedures to implement such a prograntes 4.4mrt'of the 10 CFR Part 50, Appendix B, QA program. Thig'extrait#ert strength; however, the NRC inspector also observedi$sMidWe'9sa. Anbbin s - Report,thatthesurveillanceprogramlacksbothpurpose?.land# direction to be effective and complimentary to the audit and inspection. Since the TUEC audit group is not located on site,' the.7UEC:ise? programs.1..g rve11-9
- q lance program on site takes on added significance.
IL-This item was discussed with the TUEC site QC manager who described ~ a reorganized site surveillance function and changes that have occurred. New procedures which describe this organization's duties and responsibilities are forthcoming. we, ev y e- - =my y- ,e- .ye e.,f qw q., e .e. y,esee,e w..- w +--.,. - y, + - n-_ een .--e_.e-e<-,er 3 -
~ ~ (. a-3 The following laboratory equipment was checked and found to be within calibration: Forney Compression Tester, MTE 3031; Temperature Recorder MTE 30L1 and 3014; Unit Volume Scale, MTE 1053; Pressure Meters MTE l j 3000B, 3002 and 3004; Steves NTE 1286, 1239, 1272, 1274, 1136A, 1156, 1094, 1093, 1095, 1178, 1179, 1300 and 1180;. Aggregate scales, MET 1058 and 1067; and 2" grout sold MTE 1111. The following test records for placement number 2 1-5805-034 were reviewed: (1) concrete placement inspection, (2) concrete placement summary and, (3) unit weight of fresh concrete. No violations or deviations were identified. 11. Inspection of Level C and D Storaae The NRC inspector inspected all laydown areas where piping, electrical I conduit, cable, and structural reinforcing steel were stored. These materials were neatly stored outside on cribbing in well drained area's which allowed air circulation and avoided -trapping water. This met the Level "0" storage requirements of ANSI N45.2.2. The electrical warehouse contained miscellaneous electrical hardware. This bu'1 ding was required to be fire and tear resistant, weathertight, and well ventilated in order to meet Level "C" storage requirements. This warehouse l was well kept and met all requirements except for a lock storage area located upstairs at the rear of this building (electrical termination ( l tool room). Two minor problems were identified and the warehouse l personnel initiated action to correct them. l The first problem note'd was that a box of nuclear grada cement was marked " shelf life out of date" but it had no hold tag. The box was subsequently tagged with Nonconformance Report (NCR) E85-20C453 after being identified by the NRC. During discussions with the warehouseman, the NRC deterwined that engineering told the warehouseman to mark the material and lock it up, but did not tell him to apply an NCR or hold tag. TUEC should determine if engineering is aware of nonconforming material controls and provide training if this is other than an isolated instance. Also, the NRC inspector noted a very small leak in the roof above the electrical termination tool room. This leak was in an area that I l did not expon,e hardware to moisture. The roof is currently being repaired. The millwright warehouse storage area was inspected; however,.only a small number of items or materials were stored in this area. The overall storage conditions in this area met or exceeded Level "C" storage requirements. No violations or deviations were identified. M 12. Reactor Pressure Vessel and Internals Installation - Unit 2 l This inspection was performed by an NRC inspector to verify final i' placement of the reactor pressure vessel (RPV) and internals by examining the completed installation and inspection records. 97%= e4e-et w a** =- er = de .m g -o g.g a g wvg a-v i eg g a,me+ep % g.ey --c.=ogs me,9 e.
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D l'P D.M ~ l ( m.-3 a. Requirements for Placement of RPV Requirements for placement of the RPV to ensure proper fit up of all other major NSSS equipment.are in Westinghouse Nuclear Services Division (WNSD) " Procedure for Setting of Major NSSS Components", Revision 2, dated February 13, 1979, and " General Reactor Vessel Setting Procedure" Revision 2, dated August' 3,0, 1974. The NRC inspector reviewed the following drawings, which were referenced in the RPV operation traveler, to verify implementation of WNSD t recommendations: WSD drawing 1210E59 " Standard - Loop Plant RV Support Hardware o Details and Assembly" WNSD drawing 1457F27 " Comanche Peak SES RCS Equipment Supports o - Reactor Vessel Supports" 1 o CE drawing 10773-171-004 " General Arrangement Elevation" o CE drawing 10773-171-005 " General Arrangement Plan" Neither site prepared installation drawings nor specifications (which implemented the WSD 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 support shoes. lack of N[ engineering documentation did not provide full control (The of the action and would allow changes to installation criteria important to p%j safety to be made without complying with established change procedures. 7 This is considered a violation of 10 CFR 50, Appendix 8, d' Criterion III (446/8505-06). e /, (4dL/tsoc Og-) l l b. Document Review I l l I The NRC inspector reviewed B&R Construction and Operation Traveler j l No. ME79-248-5500 which described the field instructions for installation of the Unit 2 RPV. Requirements recommended by 40t$0 ' procedures were implemented in the traveler. Worksheets attached to the traveler showed the RPV to be centered and. level'od.within-the:. established tolerances. Traveler operation 19. required verification. of a 0.020 to 0.005 inch clearance between the sgport bracket)and-support shoe, after applying the shin plates. Change.~5dM = ; lyj,... changed the clearance to a 0.015 to.025' inch x1
- 5 installation data reflected in attachment as of the"
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- 1-indicated an as-built clearance of 0.012 to 0.0tEff
'n, both the original and revised tolerances. Thisf ~ 1 on the traveler based on Westinghouse concurrence-wp n$t neither nonconfomance reports nor documented anslmser as e' &1 ons'. v to determine if the condition was acceptable. IInis raiture to .4 documentnonconformingconditionsandengineeringdeviationsisa'h MM. violation of 10 CFR 50, Appendix 8, Criterion XV (446/8505-07) .'F The NRC inspector reviewed the following receiving records for RPV hardware and found them to be. in order: ( 4 /psdf'. 4 ) 1 i .n -._,n . +.: =
DM j* l-TfLv*ee f i 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 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" ME-84-4503-4000. " Install and Adjust Roto Locks o ) o ME-81-2145-5500, "Retorque UI Column Extension" o RI-80-385-5500, " Transport and Install Lower Internals" o ME-84-4617-5500, " Repair Lower Internals" o ME-84-4640-5500, " Assemble Lower Internals" c. Visual Inspection At this time, visual inspection of the internals by the NRC inspector was not possible, and inspection was limited on the vessel placement to a walk-around beneath the vessel to inspect the azimuth markings and for construction debris between the vessel and cavity. No problems were identified in this area. d. Records of QA Audits or Surveillance The NRC inspector requested TUGC0 QA audits or surveillance performed by TUGC0 of the Unit 2 RPV installation. TUGC0 did not make available any audit or surveillance reports of specifications for placement criteria, placement procedures. hardware olacement. or as-built records, rTanure to perform auc1ts or surve111ances of RPV specifications, procedures and installation is a violation of .0 d 1 10 CFR 50, Appendix 8, criterion XVIII (446/8505-08). 4 re 'W. y Nodeviationswereidentified;however,@reeviolati { identified and are described in the above p.r 13. Reactor Vessel Disorientation %id. 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 "g' 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 =-_=--, = _ m n_- m_=- - - = ~ ~r--~ ~~
T,j,,,, p. - lum (-l b d design change was implemented for the reactor vessel, but not for the 4 pedestal support locations. The problem was not considered by the j applicant to be repo'rtable under provisions of 10 CFR Part 50.55(e) since i the error could not have gone undetected.' ] The problem was reported to the NRC Office of Inspection and Enforcement on February 22, 1979, and during a March 27, 1979, meeting in Bethesda, Maryland, the applicant presented the proposed redesign and rework procedures for relocating the pedestal supports. No unresolved safety concerns with the repair were identified at the meeting. l During this inspection the NRC inspector reviewed 'various documentation relative to the disorientation problem, including design changes and the construction traveler which implemented the repair. The following documents were reviewed: o NRC Incpection Report 50-446/79-02 o NRC Inspection Report 50-446/79-07 o NRC Inspection Report 50-446/79-13 o TUSI Conference Memo, dated March 1,-1979, H. C. Schmidt to S. Burwell (NRC Licensing PM) o TUGC0 letter TXX-2980, dated April 30, 1979, to W. C. Seidle o NRC letter to TUGC0 dated May 29, 1979 o DCA 3872, Revision 1, dated February 28, 1979,
Subject:
Rework of Structure for Placement of the RPV Support Shoes o DCA 4122, dated March 22, 1979,
Subject:
Replacement of Rebar for RPV Supports o Construction Traveler CE79-018-5505, dated March 14, 1979,
Subject:
Rework of Reactor No. 2 Cavity - New RPY Support Locations o Grout Replacement Cards No. 007,008, 009, 010, 014 and 015, various dates,
Subject:
Replacement of Grout around Robar for Repair of RPV Support Shoes o Various Inspection Reports for Grout Properties and Application for RPV Support Shoes No violations or deviations were identified. / 14. Reactor Coolant Pressure Boundary (RCPS) Systems The inspection was performed to verify: the applicants system for preparing, reviewing, and maintaining records for the RCPS piping and compenents; that selected records reflected compliance with NRC requirements and SAR commitments for manufacture, test and installation
T P 8"T' y ~~T>OW (._ i 6-3 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 2 1/2 inch thermowell installation bosses. The following records were reviewed for the subassembly: QA Receiving Inspection Report No. 12389 ^ o d ----"tI Westinghouse Quality Release (QRN 47523) o Code Data Report Form NPP-1 o 27 1/2 inch line CMTR o 3 inch nozzlo CMTR o Field Weld Data Cards o NDE Reports (1) The NRC inspector determined that CMTR's were required by the ~ code but were not available for the following items: 22 degree elbow [* 10 inch 45 degree nozzle b 2 1/2 inch thernowell bosses p. Y This failure to maintain retrievable records is a violation of 10 CFR 50, Appendix B, Criterion XVII (446/8505-10). ~ l (2) Sandusky Foundary and Machine Company test report for the. cold (g 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 Fom certified that the cold leg subassembly met requirements of _ ASMF hption IMI.1974 edition th wtwiDter_1975.Jne.rsAf f ( ommitment is hSME Section III, lue esmon snrough summer 7 e 1974. q This discrepancy is. unresolved pending the applicant's f, 7 evaluation to determine if material nonconformances. exist j (446/8505-11). 5 ._ / L-(3) The cold leg NPP-1 Form stated that no hydrostatic '(%) ta'sto ~ ~.. had been performed. In discussions with Westinghouse and 88A
- personnel, the statement was made that it is normal practice to defer the partial hydro test until the whole system is hydro e
i tested. MR Procedures CP-QAP-12.1 and CP-QAP-12.2 describe - requirements for the test. [E, g 1 ASME, Section III, (NB-06114(a)) states in respect to the time A.1,, oftestingpiping' subassemblies,thatthecomponenttest,when$ conducted in accordance with the requirements of IS-6221(a) shall be acceptable as a test for piping subassemblies. Q l M8-6221(a) states that completed components shall be sub,fected T ( to a hydrostatic test prior to installation in the system. ._.y.__ __.,y
) 7V hA t, ph,M (-t9 Paragraph (b) of N8-6221 requires pressure testing of all pressure retaining components that are within the boundary i protected by overpressure protection devices and paragraph (c) l permits substitution of the system test for component test. It is not evident that the system test substitution was permitted for pipe subassembly since NA-1200 makes a distinction in the definition between components and piping subassemblies. NB-6115 states that pressure testing of components shall be performed prior to initial operation of a system and that the Data Report Form shall not be completed nor signed by the code inspector and the component shall not be stamped until the component manufac: turer has conducted the hydrostatic pressure test. Additionally, NA-8231 prohibits the application of a Code stamp prior to hydrostatic test regardless of whether the test was performed prior to or after installation of the ites. The NPP-1 Form for the cold leg had been completed and signed by the manufacturer and Authorized Nuclear Inspector (ANI). An ASME Code Stamp had also been applied to the ites. The NRC inspector observed that a hydrostatic test had not been performed and was noted on the NPP-1 form. The above items are unresolved pending clarification of code requirementsbyNRCheadquarters(446/8505t-12). u (4) Since the cold leg pipe subassembly had not been pressure (2) tested prior to installation, the NRC inspector reviewed the procedures and hydro test data applicable to Unit 1, since Unit 2 hydro had not been completed. Requirements for the tests - were presented in Procedures CP-QAP-12.2, " Inspection Procedure and Acceptance Criteria for ASNE Pressure Testing" and CP-QAP-12.1, "ASNE Section III Installation, Verification, am N-5 Certifi-cation." Procedure CP-QAP-12.1 requires that a data package to l be used in the test, be prepared with the test boundary and the additional following data shown: o Base metal defects in which filler material has been added, and the depth of the base metal defect exceeds 3/8 inch or 105 of the actual thickness, whichever is less. o Untested vendor perfomed piping circumferential welds. o Approximate location and material identification and description for pemanent pressure boundary attachment with applicable sipport number referenced., fi. o Weld history, which shall reflect weld removal and/or weld k repair. 1 _.-~~r.,-_ m-- 3.-._~t--_ r_ wr r--r -,.. I
GN1 m%,, M _ The completed hydro data package (PT-5501) for Unit 1, loop 3 cold leg was reviewed for compliance with the above l requirements. Drawing No. BRP-AC-1-520-001 had been used to l . 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 subassembly vendor, including the 22 degree circumferential weld and the penetration fittings had not.been identified. The following items were unresolved regarding the adequacy of the hydre test: Was the determination of no major base metal repairs based o on a visual inspection or on a review of vendor and site inspection and repair records? Was the shop circumferential weld attaching the 22 degree o elbow to the pipe assembly inspected during the test?- If i l so, where is the inspection identified? Procedure CP-QAP-12.1 does not require identification of o welds for penetrations into the pipe assembly and they were not identified on the drawing. Were those welds inspected? If so, where is the inspection documented? l The above issues will remain unresolved pending further i evaluation by the applicant (445/8507-07; 446/8505-13)D. (44MFarbey 44/$sur e l d. Personnel Qualifications - Personnel who had perfomed selected tasks t 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 and met requirements. Names or codes for five welders and two NDE i 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. i 15. Special Plant Tours (Unit I and Unit 2) On Ney 23, 1985, the NRC inspector conducted a tour of selected areas of Unit 1 and Unit 2. The group consisted of one NRC inspector, two NRC Technical Review Team (TRT) representatives, two allegers, and several TUEC representatives. The TUEC representatives tagged each area where a deficiency was alleged. With the alleger's consent, a tape recorder was also used to note locations and describe av alleged deficiencies. The allegers indicated that they had identified all deficiencies during the, tour and all other deficiencies that they had knowledge The IRC TRT is analyzing this infomation and will decide what action, if av, should be p" " taken. During this tour the NRC inspector independently identified a 1 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
I 1' WNN ~CXLA F C t 16-(.17.) of items; and that as-built hardware was adequately marked and tract.able ) to records. The following items were randomly selected and inspecteo: l /a. Pressurizer Safety Valve - This item was inspected to the commitment 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 position was inspected.. The following records l were reviewed: o QA Receiving Inspection Report No. 21211 ) o Code Data Report Form MV-1 o Valve Body CMTR The valve was in place, however, installation had not been completed; tharefore, the hardware installation inspection consisted of verifying that the item was traceable to the records. /b. CVCS Spool Piece 301 - Requirements for this item are stated in AShE, Section III, 1974 edition through summer 1974 addenda, which is the cosmitment from the FSAR, Table 5.2-1. The item was field fabiicated 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 i o Field Weld Data Card i o NDE Reports o QA Receiving Reports (for bulk order) o Certified Material Test Report (CMTR) I 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 ntauber (3Q1) and the B&R drawing., number, however, marking of the material specification j number and type, heat code, or other means of traceability could not be found. In respect to material requirfng a CMTR,'(nominal.M# ;V N pipe size greater than 3/4 inch) NA-3766 recuires marking with:the I# [ ') applicable specification and grade of material and heat number or I heat code. When material is divided, the identification marking is #48 required to be transferred to all pieces. This failure to identify jh material marking is a violation 10 CFR 50, Appendix 8, ~ l Criterion VIII (446/8505-09). i 4. Loop 3 RC Cold Leg - Requirements for this item are stated in ASPE, j Section III, 1974 edition through summer 1974 addenda, which is the j commitment from the FSAR, Table 5.2-1. This piping subassembly l \\ .}}