ML20246D905
| ML20246D905 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/31/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20246D898 | List: |
| References | |
| NUDOCS 8908280321 | |
| Download: ML20246D905 (30) | |
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. COMANCHE PEAX PROJECT DIVISION STAFF EVALUATION OF DISPUTE Between CASE and TU Electric on'
. Acceptability of July 1982 RCS Cold Hydrostatic Test 4
August 1989 8908280321 890818 g
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Table of Contents
.P, age 1.
INTRODUCTION........................................................ 1 2.
DISPUTE............................................................. 2 3.
DESCRIPTION AND EVALUATION OF ISSUES AND............................ 3 SUPPORTING POINTS 3.1 Background..................................................... 3 3.2 Code and Regul ato ry Requi rements............................... 6 3.3 Description and Evaluation of Dispute Issues................... 7 3.3.1 Issue I, Sufficiency of Objective Evidence.............. 7 3.3.2 Issue II, Completeness and Accuracy.................... 16 of Records 3.3.3 Is sue ' III, Competence of Ce rtai n Ins pectors............ 21 and Supervisors 4.
SUMMARY
EVALUATION AND CONCLUSION................................... 24 4.1 S u mma ry Eva l u a ti on............................................ 24 4.1.1 Issue I................................................ 25 4.1.2 Issue II............................................... 26 4.1.3 Issue III.............................................. 27 4.2 Conclusion.................................................... 28 4
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1.
INTRODUCTION Purpose The purpose of this report is to present the staff's determination regarding:
the first dispute raised in accordance with the June 30, 1988 Joint Stipulation between the applicant, the Citizens Association for Sound Energy (CASE), and the NRC. The subject of the dispute is the acceptability of the Reactor Coolant i
System (RCS) Cold Hydrostatic Test performed in July 1982.
Background
On July 1, 1988, the applicant, the intervenor-(CASE), and the NRC filed before the Atomic Safety and Licensing Board (ASLB) a Joint Motion for Dismissal of j
Proceedings based on a Joint Stipulation (dated June 30,1988) which was signed i
i by the three parties. ASLB Memorandum and Order dated July 15, 1988, ordered that the proceedings be dismissed. Among other considerations, as set forth in the Joint Stipulation, either TU Electric or CASE may seek' resolution, by the NRC staff, of disputed issues under the jurisdiction of the NRC pertaining to the design, construction, or operation of the Comanche Peak Steam Electric i
Statica (CPSES).
Details of the process for resolving disputes between TU Electric and CASE are contained in Section B of the Joint Stipulation. The process generally provides for:
the dispute (TV Electric or CASE)
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(1) Prompt notification by the party raising (Section B.1) as to the existence of any such dispute (2) Comitment by TU Electric and CASE to exercise best efforts to resolve the dispute (Section B.2) l (3) Submittal to the NRC, by the party raising the dispute, of a documented raquest for action (Section B.3)
(4) Submittal to the NRC, by the other party, of a response to the request for action (Section B.4)
(5) Determination by the Director, Comanche Peak Project Division (CPPD), of resolution to the dispute (Section B.5)
(6) Provisions for either CASE or TU Electric to appeal the decision of the Director, CPPD, to the Director, Office of Nuclear Reactor
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l Regulation (NRR) (Section B.5) l (7) Provisions for either party to concede the issue in question at any time during the process (Section B.6) j i
'} Dispute Chronology CASE's January 27, 1989 letter to W. G. Couns11, Vice Chairman of TU Electric, and C. I. Grimes, Director, Comanche Peak Project Division NRC, provided formal-notification that the acceptability of the RCS Cold Hydrostatic Test was in dispute in accordance with Section B.1 of the Joint Stipulation. CASE and TU Electric were unable to resolve the dispute (Section B.2 of the Stipulation) and on March 13, 1989, the dispute was submitted by CASE, on the docket, for NRC resolution (Section B.3 of the Stipulation). CASE's March 17, 1989 letter to the NRC forwarded a report that provided additional details supporting the CASE position on the dispute. TU Electric's May 9, 1989 letter to the NRC forwarded their response to the dispute in accordance with Section B.4 of the Joint Stipulation.
Report Organization This report contains 4 sections. Section 2 provides a sumary statement of the dispute. Section 3 references CASE and TU Electric's position and points supporting their position relative to the three major issues involved in the dispute. Section 3 also provides the staff's evaluation of each of the supporting points. Section. 4 provides the staff's evaluation of the three major issues, provides a collective evaluation for all the issues, and presents the staff's overall conclusion and resolution of the dispute.
2.
DISPUTE The dispute concerns the acceptability of the CPSES Unit 11982 RCS Cold Hydrostatic Test. The RCS Cold Hydrostatic Test is a pressure test of the reactor coolant system boundary using water during which the pressure boundary 1
is inspected to ensure its integrity.
CASE maintains that the 1982 RCS Cold Hydrostatic Test did not fully satisfy ASME Section III and other procedural and regulatory requirements and, as a result, NRC should either:
(1) require, as a condition of licensing, TU Electric to perform an ASME Section III Code Hydrostatic Test to the currently approved L
site code, standards, and legal requirements or, (2) directly or by imposition l
of a licensing condition, request the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Comittee, in effect, to issue a code case providing alternative rules which would satisfy the code through the alledgedly deficient process implemented by TU Electric in their 1982 test.
CASE supported their position in the dispute by elaborating on three issues.
In support of each of these issues CASE provided details on a number of specific points. Additional detail on the issues is provided in a report to. sed, " Evaluation of the Texas Utilities Comanche Peak Steam Electric Station Reactor Coolant System Primary Cold Hydrostatic Test," prepared for CASE by Quality Technology Company (QTC).
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' 1 A number of additional issues separate from the three which are part of the I
dispute were contained in the QTC report.
In CASE's March 17, 1989 letter forwarding the QTC report, these additional issues are identified as indeterminate issues and not ones in dispute. These issues are not addressed in this report.
TU Electric maintains that the 1982 RCS Cold Hydrostatic Test was acceptably j
conducted and satisfied ASME Code and NRC documentation requirements, with minor exceptions that do not affect the acceptability of the test. Therefore, TU Electric considers there is no substantive reason to repeat the 1982 test and there is no ASME Code violation for which a code case exception should be sought from the ASME.
TU Electric states that their position is supported by the results of an extensive assessment of the 1982 RCS Cold Hydrostatic Test. The results of this assessment are documented in Engineering Report No. ER-ME-01, " Reactor Coolant System Cold Hydrostatic Test Report," dated June 16, 1988, and TV Electric letter TXX-88575 dated July 15, 1988, and was presented in a number of public meetings on the topic. Additional infomation and detailed responses to CASE's three issues is provided in TU Electric's May 9,1989 response to the dispute.
3.
DESCRIPTION AND EVALUATION OF ISSUES AND SUPPORTING POINTS
3.1 Background
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The Reactor Coolant System Cold Hydrostatic Test was perfomed on July 30 and 31, 1982. The test was implemented by Brown and Root (B&R) and TU Electric Startup Department.
B&R, as the ASME Section III NA Certificate Holder, was responsible for installation, testing, inspection, and certification of the CPSES Code Class piping systems. TU Electric Startup Department was responsible for establishing the test boundary, test parameters, and achieving the required test pressures for the test inspection.
Prior to the RCS Cold Hydrostatic Test, the NRC resident inspector reviewed the system drawings which described the test boundary and the RCS Cold Hydro-static Test procedures. During the test, the resident inspector witnessed system pressurization and inspected portions of the test boundary. The inspector found that the test was performed in accordance with the procedures and that the test was controlled and conducted in a way to accomplish valid test results. The resident inspector's findings are documented in Inspection Report No. 50-445/82-16.
In connection with the staff's review of TU Electric's Corrective Action Program, in July 1987, the staff initiated a thorough overview of TV Electric's resolution of issues impacting compliance to the ASME Boiler and Pressure i
Vessel Codes. Review of the TU Electric ASME Code interface was initiated during the July 29, 1987 public meeting between the NRC and TU Electric in Dallas, Texas. This review included followup to an NRC unresolved item i
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( (445-8507-U-07; 446-8505-U-09). This unresolved item, which iraalved a concern that the documented rect,d of the hydrostatic test did not clearly demonstrate that certain required examination points had-been covered, was one finding of.
a routine inspection conducted by the resident inspector covering the period April-1,1985 through June 21, 1985. The staff review associated with compliance to the ASME Code also included followup to allegations about the RCS Cold Hydrostatic Test received by the NRC in November 1987.
In July 1987, the staff, with the ASME Code representative [the Texas Department of Labor and Standards (TDLS)],. began a comprehensive examination
'and re-evaluation of all aspects of the CPSES Unit 1 RCS Cold Hydrostatic Test and related ASME Code and other NRC regulatory compliance issues. On March 7, 1988, the staff issued Inspection Report No. 50-445/88-13; 50-446/88-13
=(IR 445/88-13; 446/88-13) covering the inspection period of July' 29,'1987 through February 12, 1988, which documents the first part of this reevaluation.
The inspection included a general assessment of TU Electric's implementation of the requirements of-the ASME Code, the status of unresolved issues with the TDLS, the activities of the third party inspection agents [the authorized nuclear inspectors (ANIS)] and the development of the Memorandum of Under-standing titled " Comanche Peak Steam Electric Station - Unit 1 ASME Activities and Responsibilities," dated December 14, 1987, which was signed by the TDLS and TU Electric. The December 14, 1987 Memorandum of Understanding between
-TDLS and TU Electric was developed to describe the CPSES activities associated with the execution of the Unit 1 ASME Code N-5 and N-3 data reports.
On June 23.'1988, the staff issued Inspection Report No. 50-445/88-24; 50-446/88-21 (IR 445/88-24; 446/88-21) which documents a joint inspection by staff and the TDLS covering the period of March 8 through June 3, 1988. This inspection focused on the conduct of the Unit 1 RCS Cold Hydrostatic Test as completed on July 31, 1982 and the associated technical and quality documenta-tion. Within the areas inspected, two apparent violations were identified:
(1) failure to provide adequate procedures and failure to follow procedures regarding the Unit 1 primary system hydrostatic test activities (445/8824-V-01; 446/8821-V-01), and (2) failure to maintain quality related records of Unit 1 primary system hydrostatic test activities (445/8824-V-02).. Based on the two apparent violations and other inspection findings, the staff and TDLS concluded that "the acceptability of the cold hydrostatic test of the Unit 1 primary system is considered indeterminate as documented in Documentat. ion Package No.. PT-55.01, including the Pressure lest Data Sheet dated July 31, 1982."
The staff's finding about the indeterminate status of the hydrostatic test was identified as an unresolved item (445/8824-U-03).
TU Electric responded to the identified violations and unresolved item by their letters, TXX-88575, dated July 15, 1988 and, TXX-88529, dated June 17, 1988, which transmitted Engineering Report No. ER-ME-01 " Reactor Coolant System Cold Hydrostatic Test Report" dated June 16, 1988. On June 16, 1988, a meeting was held at CPSES wherein TU Electric presented the results of their assessment of the Unit 1 cold hydrostatic test. As a result of this meeting i
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.and subsequent discussions TU Electric by letter, TXX-88363, dated August 23, 1988, submitted Revision 1 to Engineering Report No. ER-ME-01. Subsequently, in response to a need for further clarification and/or correction of the cold -
hydrostatic test records (by' letter, TXX-89129, dated March 15, 1989 and letter.
TXX-88130, dated March 15,1989), TU Electric revised its response to NRC Item No. 445/8824-U-03 and submitted Revision 2 to Engineering Report ER-ME-01..
respectively.- Neither of these last changes impacted the technical and quality-conclusions previous _1y established.
On December 5; 1988,,the staff issued NRC Inspection Report No. 50-445/88-61;
.I 50-446/88-57 (IR 445/88-61;.446/88-57) which documents an NRC inspection conducted in conjunction with the ASME representative (TDLS). This report, which covers the inspection period of June 24, through October 14, 1988, documents, among other matters, the closure of violations 445/8824-V-01; 446/8821-V-01 and 445/8824-V-02, closure of unresolved item 445/8824-U-03, and the results of the joint review of.the open issues involved with the CPSES Unit-1 RCS Cold Hydrostatic Test as documented in Documentation Package No. PT-55-01 and Engineering Report No. ER-ME-01.
Based primarily on this inspection, the staff concluded that, despite the discrepancies and weaknesses in procedures and records associated with the RCS Cold Hydrostatic Test, including the recordkeeping violations previously. identified, there was sufficient information available in test records to adequately demonstrate that the applicable requirements of Section III of the ASME Code were satisfied.
Based on their independent inspection activity, CASE informed TU Electric and l
NRC by-letter dated January 27, 1989, that the acceptability of the Unit 1 RCS l
Cold Hydrostatic Test was in dispute. By letter dated March 13, 1989 the dispute was submitted by CASE to NRC for resolution. CASE letter to NRC dated March 17, 1989, supplemented their details of the dispute.
TU Electric by letter, TXX-89179, dated May 9, 1989 responded to CASE's " Request for Action" as referenced above.
As. documented in NRC IR 445/88-61; 446/88-57, on August 4, 1988, the staff and TDLS requested that TV Electric document their connitment to perform an ASME Section XI hydrostatic test of the Unit 1 primary system during hot functional testing. This test was to provide additional assurance that ASME Section XI modifications and repairs and the long time period since completion of the cold hydrostatic test (1982) had not resulted in unacceptable degradation of system integrity. By letters TXX-88709, dated September 28, 1988, TXX-89007, dated January 11, 1989, and TXX-89150, dated April 10, 1989, TU Electric established the hydrostatic test connitment, acceptance criteria, and test scope. The specified Section XI hot hydrostatic test of the Unit 1 primary system was conducted on May 24, 1989. This test was observed and evaluated by the staff and CASE and has been accepteo by TDLS. As is documented in part by NRC Inspection Report No. 50-445/89-22; 50-446/89-22, no items of noncompliance or unresolved matters were identified by NRC during the performance of thisSection XI VT-2 Qdrostatic test.
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' 3.2 Code and Regulatory Requirements The RCS Cold Hydrostatic Test substantially involves reactor coolant system boundary components.. These components are required to be designed and fabricated
-in accordance with 10 CFR 50 Section 50.55a, " Codes and Standards." CPSES-FSAR 5.2.1, Compliance With Codes and Code Cases,' specifies the actual. addenda of the ASME Code applied in the design of the Reactor' Coolant System Components..
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Applicable Code Addenda for reactor coolant-system components are presented in FSAR Table 5.2-1..
FSAR 3.9N.1, Special Topics.for Mechanical Components, presents specific TU Electric commitments for the' primary side hydrostatic test.
As allowed by the Code and consistent with FSAR commitments, the RCS Cold i
Hydrostatic Test was performed to the requirements of ASME Section III, Division 1, 1980 Edition through the Summer 1982 addenda.
L The RCS cold hydrostatic test also falls within the scope of activities covered by 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. FSAR 17.1, Quality Assurance During Design and Construction, presents TU Electric's quality assurance program commitments as they apply to construction activities.. FSAR 17.1 and FSAR Appendix 1A(N),
Discussion of Regulatory Guides, discusses CPSES positions on, and compliance with, Division 1 regulatory guides as they apply to Nuclear Steam Supply System scope of equipment and services. CPSES commitments to NRC Regulatory Guides q
applicable to the construction QA program are identified in these FSAR sections.
The following TU Electric procedures governed the implementation of the Unit 1 Cold Hydrostatic Test.
CP-CPM-6-9I, Rev. 5, DCN 2, " Pressure Testing" CP-QAP-12.1, Rev. 3, " Inspection Criteria and Documentation Requirements d
Prior To Release for ASME Pressure Testing" I
CP-QAP-12.2, Rev. 3. " Inspection Procedure and Acceptance Criteria for ASME l
Pressure Testing"
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CP-QAP-18.2, Rev. 2, " Quality Assurance Review of ASME III Documentation" ICP-PT-55-01, Rev. O,." Reactor Cuolant System Cold Hydrostatic Test" J
With respect to CASE's characterization of codes and standards appJicable to
.the RCS hydrostatic test, there are three instances where TU Electric main-g tains that the codes and standards referenced by CASE are in error, as follows:
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- 1 ITEM CASE Reference-
.TU Position on Correct Reference
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~ASME-Section III Procedure CP-QAP-12.2 l
paragraph NX-6224 B.
ANSI'N45.2.6
' ANSI N.45.2.8 (N/A to Comanche Peak)
- Sections 2.1
'and 2.3.
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ANSI N45.2.9 (Rev. 3, 1973)
Appendix A'..
Appendix A, Section A.5 Sections A.3 and A.6.1 4
- The staff has examined the three instances wherein TU' Electric has indicated that l CASE has; incorrectly applied or misquoted codes and standards and concludes that' i
TU Electric-is correct in each of these three instances. Appropriate designa-tion of.these codes and standards'is important^1n considering whether or not.
applicable ASME and NRC requirements were met during conduct of.the RCS Cold Hydrostatic Test.
3.3 Description and Evaluation of Dispute Issues
-3.3.1 Issue I, Sufficiency of Objective Evidence
- 3.3.1.1 CASE and TV Electric Positions CASE CASE asserts that TU Electric cannot provide objective evidence that all weload joints, welded connections, base metal repairs involving welding, and all regions of high stress (such as elbows, tees, reducers, flanges, fittings, etc.)
were inspected to ASME Section III and associated standards, and that these locations and components will withstand normal and postulated accident stresses when the plant becomes operational.
TU Electric TU Electric asserts that their 1988 technical assessments (as reported in TU Electric' ER-ME-01 and TXX-88575) confirm that the 1982 RCS Cold Hydrostatic Test was implemented, inspected and documented in accordance with the requirements of the ASME Code, NRC requirements and governing CPSES procedures, with minor deviations that did not affect the acceptability of the 1982 test.
TU. Electric maintains that the process used by them in 1988 to assess the technical' validity of the 1982 RCS Cold Hydrostatic Test and the bases for determining the technical validity of the test relied on objective evidence h--._.__-_.__.__.___-...____.-
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. produced when the test was conducted. The documentation reviewed as part of L
TU Electric'sf assessment included flow diagrams, piping isometrics, fabrication spool sketches. applicable spool weld documentation, hanger drawings, RCS
' Cold Hydrostatic Documentation, and component and N-5 code. data reports.
3.3.1.2 CASE Supporting Points. TV Electric Response,:and Staff Evaluation-
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Issue I. Point I' CASE CASE asserts that although TU Electric's applicable-governing documents correctly stipulated.that no leakage was allowed from the required areas and items of inspections, no additional proceduralized instruction criteria were'provided to any of.the Quality Control (QC) Inspectors by way of on-the-job' training, inspection check lists, walkdown inspection sheets, or other specified documentation.
'TU Electric TU Electric's self assessment of the RCS Cold Hydrostatic Test concluded that the test was completed utilizing procedures which complied with the requirements of ASME Section III and therefore were adequate to control.
the activity. The hydrostatic test procedures required that the specific test boundary be examined by appropriately qualified and certified Quality Control Inspectors for the absence of leakage of the test medium at welded connections, base metal repairs involving welding and regions of high stress. TU Electric maintains that acceptance of the hydrostatic test was. documented on the applicable flow. diagrams, Pressure Test Data Sheet and Quality Checklist as required by CP-CPM-6.9I and CP-QAP-12.2. These procedures provide the necessary acceptance criteria and test acceptance
-guidelines as required by the ASME Code.
TU Electric described the use of another document, the Pressure Data Sheet Attachment, used by TU' Electric inspectors to facilitate test completion.
TU Electric states that this' document was not required by procedure or necessary to fulfill an ASME Code requirement, but documented in a more complete and auditable fashion the manner in which the inspections were conducted. TU Electric asserts that ASME Code does not require additional direction to QC Inspectors.(i.e., additional inspection or instruction criteria and inspection checklists) than what was developed and used at CPSES to inspect and subsequently to accept the RCS Cold Hydrostatic Test.
With respect to training of OC Inspectors whn participated in the test, TU Electric states that all were certified Level II MIFI inspectors and that completion of the certification requirements for these inspectors was, in itself, sufficient to assure that the inspectors were properly trained for the 1982 RCS Cold Hydrostatic Test. TV Electric further states that a number of dry runs of the test were held to familiarize inspectors with their assigned inspection areas.
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I CPPD Evaluation l
L In regard to CASE's contention that "no additional proceduralized instruction criteria was provided to any of the QC Inspectors by way of on-the-job training...", the staff reviewed procedures CP-CPM-6.9I
" Pressure Testing" and CP-QAP-12.2 " Inspection Proce6re and Acceptance Criteria for ASME Pressure Testing" and found that these procedures acceptably met ASME requirements in regard to provid;ng instructions to qualified QC Inspectors.
Instructions to QC Inspectoa beyond those contained in CP-CPM-6.91 and CP-QAP-12.2 are not required by the code.
With regard to QC Inspector training, satisfaction of the ASME Code requirements for qualification of QC Inspectors is all that is required to be in compliance with the code and this qualification demonstrates that the inspectors were properly trained to participate as inspectors in the RCS Cold Hydrostatic Test. The staff and TDLS reviewed, in detail, the personnel qualification and certifkation records of the inspectors identified by the hydrostatic test record and those identified additionally by TU Electric as potential participants in the 1962 hydrostatic test. The staff and TDLS also conducted interviews with a number of these inspectors.
As is documented in NRC irs 445/88-24; 446/88-21 and 445/88-61; 446/88-57, all of these inspectors were demonstrated to have met the qualification and certification requirements of the ASME Code.
Further, those who were interviewed were noted to be verbally knowledgeable in their description of activities during the RCS Cold Hydrostatic Test. The staff and TDLS also reviewed documentation demonstrating that " dry runs" of the examina-tions required during hydrostatic test were conducted prior to the actual test. Moreover, the conduct of the " dry runs" was verbally confirmed to the staff and TDLS during interviews with some of the subject QC Inspectors interviewed during the staff and TDLS inspection.
CPPD Conclusion The staff concludes that the TU Electric procedures CP-CPM-6-9I and CP-QAP-12.1 provided, by themselves, adequate instruction to QC Inspec-tors regarding the conduct of the cold hydrostatic test.
The staff also concludes that the TU Electric QC Inspectors involved in the conduct of the July 1982 Unit 1 cold hydrostatic test were properly qualified in accordance with the applicable requirements of the ASME Code and related NRC regulations to perform the cold hydrostatic test. The staff notes that, while it was not a requirement of the code nor NRC regulations, j
TU Electric conducted fully simulated training (dry runs) for the RCS Colo Hydrostatic Test prior to the actual conduct of the test and these dry runs provided additional preparational aid to the QC Inspectors.
Therefore, although the "proceduralized instruction criteria" as char-acterized by CASE in this point were not all used, the staff finds that this did not represent a noncompliance with the code or NRC requirements,
- nor did this detract from the proper conduct of the test or the ability to assure that there is reasonable assurance that the plant can operate safely.
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Issue I, Point 2 CASE CASE asserts that no inspection data is available that ascertains how the requirements of ASME,Section III, associated standards, and other
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regulatory requirements were actually met.
TU Electric TU Electric disagrees with this point. TU Electric maintains that the documentation contained on the Pressure Test Data Sheet, Quality Checklist, and the corresponding Pressure Data Sheet Attachments and respective Test Isometrics demonstrates that the requirements of ASME Section III are satisfied.
CPPD Evaluation The staff found substantial inspection data a nilable related to the 1982 RCS Cold Hydrostatic Test. The staff' considers CASE's point, more properly put, is whether or not the available data is sufficient to document that the applicable code and regulatory requirements were met.
As is documented in NRC IR 445/88-24; 446/88-21, paragraph 3, the staff and TDLS had specific findings of weaknesses in the procedures and records associated with the Unit I cold hydrostatic test. Paragraph 3.D of the inspection report states on page B-7 that " Based on this review, the staff and Chief Inspector TDLS concluded that, while these records and procedures were substantial, in the specific areas identified below, important activities affecting quality apparently were not conducted in acccrdance with adequate and comprehensively documented procedures...." The staff's issues were specifically documented in two violations and one unresolved item.
In response to the staff's concern about the adequacy of documentation, TU Electric performed an in-depth evaluation of the Unit 1 RCS Cold Hydrostatic Test and documented the results of this evaluation in Engineering Report No. ER-ME-01 dated June 16, 1988 and its subsequent revisions 1 and 2.
The objectives of TU Electric's evaluation were to determine whether the test successfully demonstrated system integrity, whether applicable ASME Code requirements were satisfied, whether procedures implemented during the test were adequate, and whether personnel performing acceptance inspections were qualified to conduct those inspections. The obiectives also included the identification and correction of discrepant conditions and detennination of where process enhancements could contribute to a more definitive and comprehensive test package. To accomplish their objectives, TV Electric compared ASME Section III. Hydrostatic Test requirements to TV Electric's hydrostatic test procedure requirements, reviewed documentation to identify required hydrostatic test inspection points and compared the qualifications of the s
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1 inspection personnel involved in the test to applicable requirements. :The results'of.TU Electric's evaluation, documented in ER-ME-01, were that the.
RCS Cold Hydrostatic Test demonstrated RCS integrity and satisified appli-cable-ASME Section III Code requirements, including documentation, and.the
. technical. procedures governing.the test contained the. applicable ASME a
Section'III technical requirements. TU Electric's-response to the two violations'and one unresolved. item, which reference ER-ME-01, provided-additional information on'the results of their assessments of the adequacyL of documentation associated with the hydrostatic-test..
The staff and TDLS' reviewed the information submitted by-TU Electric and found that a sufficient record had been developed and,' based on a
-detailed review of tnat record, found that the requirements.of the ASME Code'were met. The.results of the staff's evaluations are documented.in NRC IR 445/88-61; 446/88-57.
-CPPD Conclusion Based on the. staff review of this matter as presented here and historical review and examination of this issue by both. staff and TDLS. the staff' concludes that inspection data, acceptable to the requirements of the ASME Code and NRC regulations, are available for the CPSES. Unit 11982 RCS Cold Hydrostatic Test.
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Issue I, point 3 CASE.
CASE asserts that no individual QC Inspector's signature attests to his/her own are6s of inspection.
Instead, the Pressure Data Sheet Attachments (11) were signed by a QC Lead or Alternate Inspector or another QC Inspector, on behalf of all the team members. The typed names of the QC Inspecte s appearing on the Pressure Data Sheet Attachments are not necessarily those of the inspectors that were involved with the test.
TU Electric TU Electric maintains that the signatures on the Pressure Data Sheet Attachments are meaningful and support the validity of the RCS Cold Hydrostatic Test. The inspection areas assigned to each of the 11 teams were clearly defined, and the availability of certified QC Inspectors to perform such inspections. during the test is confirmed by time records.
. Thus, TU Electric asserts that the signatures on each Pressure Data Sheet Attachment provide meaningful supporting evidence that the inspections of 1
the 11 areas were properly performed. This conclusion is also supported I
by other factors, such as the relatively small area covered by each inspection team, the close proximity in which all inspections were performed, and the signatures of the authorized inspection agency representative on each Pressure Data Sheet Attachment.
TU Electric disagrees with the implication that each QC Inspector had to be identified on each Pressure Data Sheet Attachment and that each inspector should have signed some documentation attesting to his/her area of inspection.
CPPD Evaluation During the three joint inspections conducted by staff and TDLS as referenced in Section 3.1 of this report, the issue as raised here by CASE was inde-pendently discussed and addressed by the staff and the Chief Inspector, TDLS.
It was the staff and TDLS consideration then that the signature of one of the inspectors on behalf of the inspection team in conjunction with the signature of the authorized nuclear inspector on Pressure Data Sheet Attachments and Pressure Data Sheet, as complimented by marked-up isometric drawings and the related documentation in the test package, adequately demonstrated conformance to the ASME Code.
In view of CASE's concern about individual QC Inspectors not signing the Pressure Data Sheet Attachments attesting to their inspection activities during the test, the staff has reviewed its previous position on this matter. TU Electric states in their response to the dispute that the
" Pressure Data Sheet Attachment" was used to " facilitate test completion" and that it was not an ASME requirement for each inspector to sign the sheet.
In Engineering Report No. ER-ME-01 anc responses to NRC Unresolved Item 445/8824-U-03, TU Electric elaborates on the extensive documentation demonstrating that the RCS Cold Hydrostatic Test was conducted in accordance with ASME code and NRC requirements. The staff has reviewed this documen-tation and finds that the documentation (including the Pressure Data Sheet Attachment, the signatures on the Pressure Test Data Sheet by the TU Electric Test Engineer, Quality Control Quality Assurance, Brown &
Root Quality Control, and the witnessing Authorized Nuclear Inspector) adequately demonstrate, collectively hat the ASME Code was met. Use of the information from the Pressure Deta Sheet Attachments provides only one i
part of the infomation supporting the documented record. The staff finds that the signature by a lead QC Inspector on the Pressure Data Sheet Attachments attesting to the completion of the activities of the team of inspectors, in consideration of the backup documentation, to be an accept-
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able practice and in conformance with the test procedures, ASME Code j
requirements, and NRC regulations.
The qualification level of each of the QC Inspectors and the authorized 1
nuclear inspectors who signed the Pressure Data Sheet Attachments were verified by NRC and TDLS to have been in accordance with NRC regulations 1
and the ASME Code. Moreover, as documented in the inspection reports referenced in Section
',.1 of this report, a number of the QC Inspectors who participated in the 1982 hydrostatic test were interviewed during NRC and TDLS inspections in 1987 and 1988.
Based on these interviews and review of the records, the staff and TDLS established to their satisfaction that the lead QC Inspectors who signed the Pressure Data Sheet Attachment j
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.( on behalf of the inspection team directly participated in the inspectie and signed the document in accordance with the approved procedures as referenced by TU Electric (Brown and Root Quality Assurance Program, Section 11.0, Control of Inspections [Rev. 13,9/17/81],QI-QAP-2.1-5, CP-QAP-12.2).
l CPPD Conclusion The staff finds that, although each of the QC Inspectors who participated in the subject 1982 hydrostatic test did not sign the Pressure Data Sheet Attachment, a lead QC Inspector did sign on behalf of the designated inspection team. The staff finds that this action was in conformance with the TU Electric procedures and practices existing at that time.
Further, the staff finds that the inspection activities were accepted by signature of the authorized nuclear inspector. The staff therefore concludes that the practice of having the team leader or lead QC Inspector sign on behalf of the team's inspection effort sufficiently demonstrated, in conjunction with other documentation, that the require-ments by the ASME Code and NRC regulations were met and was consistent with the organization and implementation of the subject hydrostatic test.
(4)
Issue I, Point 4 CASE CASE questions whether all the activities involved with the hydrostatic test could have been adequately performed.
CASE identifies the following elements of the test conditions and nature of the task particularly persuasive in support of this position:
According to information provided verbally by TU Electric, an estimated 1,800 welds and a large, but undefined, number of other attributes required inspection during the RCS Primary Cold Hydrostatic lest.
i According to the official test record and subsequent engineering reports there is a conflict in the number of inspectors who actually participated in the July 1982 test.
According to information provided verbally by TU Electric, each inspector (or team of inspectors) carried the specific drawings fer their area of inspection responsibility into the' field as the source document to determine the specific attributes necessary for their inspection; no other checklists or criteria were provided.
During the test the reactor coolant test boundary was leaking large amounts of water from valve bonnets and seals, which, in CASE's view, contributed to making identification of leaks more difficult.
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According to review of the data, CASE concludes that even under the
.most' liberal consideration, the time at allowable inspection pressure could not have exceeded 50 minutes.
TU Electric-l TU Electric addressed each of the items as follows:
TU Electric agreed that an estimated 1800 welds plus a large number of attributes required inspection during the test. TU Electric maintains that the scope of the task did not detract either from their ability to perform the inspections or, in'1988, to reassess the adequacy of the performance.of the test.
TU Electric stated that initial reviews of the records identified a total of 34 individuals who may have been involved in the test. A further review of time records then determined that 30 of the 34 individuals were present during the early morning hours that the test was conducted..Accordingly. TU Electric considers that there is reasonable assurance that the QC inspectors who performed the inspections have been identified.
TU Electric maintains that the 1982 test package consistently identified all the areas within the test boundary that were required by ASME Section III to be inspected. TU Electric asserts that the QC Inspectors had ample information identifying the. specific attributes to be inspected and the criteria to be satisfied.
TU Electric noted that ASME Section III. NB-6215, and CP-QAP-12.2 specifically permit leakage from valve packing, seals, and mechanical seals. TU Electric agreed that leakage from valve bonnets and seals may make identification of leaks more difficult.
Recognizing this, TU Electric identified that QC Inspectors were trained in the appropriate inspection methods for the conduct of hydrostatic tests, including the potential for weeping or leakage of test medium at a mechanical joint.
The initial dry run of the RCS Cold Hydrostatic Test conducted on June 14, 1982, indicated that no more than 40 minutes were required for inspection of each area. TU Electric stated there was no arbitrary cut-off to the test (it was declared at an end when the inspections were completed and documentation was available) and there is no indication that the period of time it took to complete the test was not adequate.
CPPD Evaluation The staff notes that the point-raised here are more subjective, questioning the plausibility of adequate iiplenentation of the hydrostatic test rather than asserting violations of A3ME or NRC requirements.
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Beginning in 1987 the staff, in conjunction with TDLS, conducted a rigorous review of the cold hydrostatic test implementation and records. All of the elements associated with thir point were covered during these inspec-tions and were either directly answered by TU Electric, or they were well documented in the available records of the hydrostatic test implementation and the quality / technical documents associated with the subject test.
Specifically, this information is contained in the record of the subject hydrostatic test Documentation Package No. PT-55.01, the TU Electric procedures that governed the test as summarized by Engineering Report No.
ER-ME-01 and TV Electric letter TXX-88575, (TU's technical assessment of the RCS Cold Hydrostatic Test) and its subsequent revisions number 1 and 2, which served to clarify certain points.
During extensive reviews of issues associated with this point, neither the staff nor TDLS identified any basis for considering that the time frame for conducting the required examinations at the hydrostatic test pressure was inadequate for the scope of the test. Both TU Electric QC Inspectors and the authorized nuclear inspectors signatures on the records provide required and reasonable assurance that the test was conducted in accordance with TU Electric procedures and the code. Considering the number of qualified inspection teams and the preparations taken for this test, the staff considers that CASE's point about the limited time period for conduct of the test is judged to be insignificant.
CASE's concern about leaking valve bonnets and seals in the face of generally adequate procedures, qualified inspectors, participating authorized nuclear inspectors and staff overview, similarly is judged to be insignificant, The code recognizes the possibility of such leaks in the considerations of ASME Section III paragraph NB-6215. Minor and expected leaking did occur, but it should not have affected test results. This consideration was reflected in the training requirements for the QC Inspectors and the TU Electric procedures that govern their test activities.
As discussed in other sections of this report, TU Electric confirmed that all QC Inspectors participating in the hydrostatic test activities were properly qualified. This has subsequently been re-verified by the staff and the TDLS. The conflict in the number of QC Inspectors who participated in the test is addressed by TU Electric in their May 9,1989 response to the dispute. TU Electric's response states the record indicates that a total of 34 individuals were considered as potential participants in the hydrostatic test and all were qualified as at least Level II QC inspectors. TU Electric's review of time records show that 30 of those QC Inspetters were present when the test was conducted. The staff finds that TU Electric's response adequately responds to CASE's questions with respect to clarifying the number of participants in the tests and that the numDer of inspectors available could sufficiently support 11 inspection teams. As ciscussed previously, the staff notes that a lead QC Inspector signed for the inspe: tion team acti-vities on behalf of inspectors with whom he participated in the test, and the practice has been demonstrated to be acceptable to the staff and TDLS.
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I. CPPD Conclusion The staff concludes that the elements in this point raised by CASE have been acceptably responded to by TU Electric and that TU Electric is correct in concluding that for each element raised there is compelling TU Electric documentation demonstrating that the RCS Cold Hydrostatic Test was adequately performed. Moreover, the staff's independent assess-ment of the elements associated with this point, as documented collec-tively in NRC inspection reports, demonstrates that none of the elements were contrary to the requirements of the ASME Code and NRC regulations.
3.3.2 Issue II, Completeness and Accuracy of Records 2.3.2.1 CASE and TU Electric Positions CASE CASE esserts TU Electric cannot establish thorough, complete, accurate, and verifiable documentation that the 1982 Cold Hydrostatic Test of the reactor coolant pressure boundary was conducted in accordance with industry codes, standards and regulatory requirements.
TU Electric TU Electric asserts that, as demonstrated by their response to the individual points made by CASE, many of CASE's criticisms are mistaken and that none affect the technical validity of the 1982 RCS Cold Hydrostatic Test.
TU Electric considers that they have shown that the conduct and documentation
.:of the test were in conforrance with ASME Code requirements and, with minor exceptions that do not affect the technical acceptability of the test, to NRC documentation requirements.
3.3.2.2 CASE Supporting Points TU Electric Response, and Staff Evaluation (1)
Is::ue II, Point 1 CASE CASE asserts there are numerous differences between the verified drawing revision numbers of the plant drawings, flow diagrams, test procedures, Pressure Data Sheet, Preoperational Test Data Sheet, and the official Test Record and official Start Up Test Record. CASE provided two groups of examples to illustrate this point. The two groups were:
Seven drawings showing different revisions as being used for the test in three separate locations.
Four additional items identified as examples of problems associated with incorrect drawings being used.
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TU Electric TU Electric asserts that the documentation deficiencies noted by CASE pre-dominately relate to aspects of the test documentation that were not.
reviewed in TU Electric's 1988 technical assessment because they.were not a necessary'part of the' determination of the technical adequacy of the.
test. TU. Electric reviewed each of the items cited by CASE and detemined none had an effect on TU Electric's. conclusion regarding the technical adequacy of the RCS Cold Hydrostatic Test. A summary of the results of TU Electric's review for the two groups of examples is presented below:
TU Electric states that flow diagrams (such as' the seven drawings identified by CASE) were used in preparation for the test to delineate the test boundary as required by Startup procedures.
The adequacy of the test boundary was verified by TU Electric during their 1988 assessment by use of the 1CP-PT-55-01 valve lineup sheets 'and the test isometrics. Since the flow diagrams-were not used for the perfomance'of inspections, identification of inspection attributes or inspection acceptance. TU Electric asserts that reference to.various revision levels of the flow diagrams did 4
not affect the completicn or adequacy of the test.
TU Electric characterized the four additional items (examples of problems related to incorrect drawings) as miscellaneous and generally unrelated problems. TU Electric stated they were unable to specifically address the first item (related to CMCs) because of lack ~of specifics provided. TV Electric stated further that in their.1988 assessment no concerns were identified with CMCs with respect to the test boundary, and it was determined that the inspection areas were consistently defined. TU Electric stated that the second item, which applied to flow diagrams, represent potential minor discrepancies, which did not affect the adequacy of the test. TU Electric stated that the last two items, applicable to test isometrics,- refer to isometrics which do not identify pipino within the test boundary.
CPPD Evaluation In regard to discrepant revision levels on flow diagrams, the staff and TDLS noted during their inspections that flow diagrams were not used for the performance of hydrostatic test examinations or acceptance.
Isometric drawings, which were used during the hydrostatic test, were found to have t'een used in accordance with applicable requirements. TU Electric has
- acknowledged the deficiencies related to controls of flow diagram revisions and a deficiency report was issued. TU Electric, however, asserts that this deficienciy did not affect the completion or adequacy of the test. The staff agrees with TU Electric's assessment that discre-pancies in those revisions had no impact on the acceptability of the L
subject hydrostatic test.
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LThe staff has reviewed examples of incorrect isometric drawings identified by CASE -(BRP-MS-1-RB-005 and 'BRP-MS-1-RD-001) and confirined TU Electric's assessment that these drawings do not contain-piping within the-subject hydrostatic test boundary. As part of the staff's inspection activities described in Section 3.1 of this report, the staff reviewed the isometric drawings used in.the hydrostatic test and found them to be acceptably complete and accurate.
CPPD Conclusion The staff finds that the CASE' examples of use of incorrect drawing revisions for the most part apply to items that are not directly relevant to the acceptability of.the hydrostatic test. Also, a number of the P
examples represent minor discrepancies, similar to ones found by the staff during inspections, and have little impact on the overall adequacy of the record regarding the RCS Cold Hydrostatic Test.
Therefore, the staff considers that the examples illustrated in this point do not present a compelling argument that there is a breakdown in docu-mentation sufficient to constitute a reason for considering that the July 1982 RCS Cold Hydrostatic Test did not meet ASME and NRC requirements.
-(2)
Issue II, Point 2 CASE CASE identified ten examples of types of significant documentation discrepancies.
.TU Electric TU Electric characterized these ten examples as miscellaneous and generally unrelated problems. TV Electric found that none of the items affected the technical adequacy of the test.
CPPD Evaluation As presented below, the staff evaluated CASE's 10 examples of types of deficiencies individually and collectively.
It should first be made clear that the staff is concerned over any deficiencies found in TV Electric's documentation. However, while the staff would like TU Electric's docu-mentation to be error free, realistic expectations of the quality of documentation concede that some errors exist.
In this respect, the staff's evaluation of the examples of deficiencies identified by CASE focuses on both the individual significance of the 10 types of defi-ciencies and the collective implications of all or any group of the examples.
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. il With respect to the 10 examples of types of deficiencies, four of CASE's f
examples represent, in the staff's opinion, minor documentation errors.
q Two examples, those regarding BRP-FW-1-RB-004 and BRP-MS-1-SB-003, involve drawings that were not directly relevant to the hydrostatic test. Three examples concerning discrepancies in heat numbers are of only minor i
regulatory concern. One example, dealing with NPP-1 Code Data Reports
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for piping subassemblies, was assessed by TU Electric and they consioered that there was no deficiency. The staff agrees with TU Electric's assessment with respect to this example. The staff has reviewed each of the 10 examples and does not consider that any of them, taken individually or collectively, are of such significance as to question the adequacy of the hydrostatic test documented record.
Deficiencies similar to those exampled by CASE were noted by the staff and TDLS during their inspections. The staff and TDLS determined that these deficiencies, when compared to the overall documentation record, were of minimal importance and therefore concluded that the documented record of the hydrostatic test, as co piled and described in Engineering Report No. Ek-ME-01, was acceptably complete and accurate.
CPPD Conclusion Based on the review of CASE's examples in this point TU's response and the staff's and TDLS's previous examination of these issues, the staff finds that there is no significant difference (either in type or magnitude) between the issues identified by CASE and those considered previously by the staff and the ASME representative (TDLS). While the staff notes that some documentation discrepancies still exist, as is documented on the "ASME Open Items List," the staff considers that the comprehensive reviews conducted by TU Electric and the collation and collection of the related documents has provided substantial assurance of the overall adequacy of the documentation. To this extent, the CASE examples as summarized above do not demonstrate, to the staff, documenta-tion discrepancies sufficient to consider that the subject cold hydro--
static test did not meet ASME and NRC requirements.
The staff reviewed the examples of discrepancies identified by CASE for new information that would cause the staff to revise its previous position on the collective adequacy of the documented record. Based on this review, the staff considers that CASE's findings represent isolated examples of minor discrepancies, not inconsistent with the staff's and TDLS findings during their review of the same documents, and that the i
CASE examples do not support a finding that overall documented record is inadequate.
(3)
Issue II, point 3 CASE Five examples of documentation deficiencies with ICP-PT-55-01 were noted by CASE. These deficiencies, included fragmented and disjointed test
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documentation, lack of entries noting Steam Generator water level change, use of an outdated Pressure Test Data Sheet form, an improperly executed change to ICP-PT-55-01, and inaccurate data found on eleven Pressure Data Sheet Attachments.
TU Electric TU Electric's review of CASE's examples resulted in their determination that CASE's criticism of the documentation are mistaken (with minor exceptions that do not involve substance), and that none of the examples affect the technical validity of the 1982 test.
CPPD Evaluation In regard to documentation contained in and associated with ICP-PT-55-01, the staff and the Chief Inspector, TDLS, reviewed and examined these records in considerable detail. During the initial phases of the staff and TDLS inspections, the records as found in the CPSES permanent files and other areas were found to be somewhat disorderly. While the NRC IR-445/88-24; 446/88-21 discusses an as-found housekeeping condition, fragmented and disjointed documentation was not in evidence.
- Further, the staff found that the housekeeping problems identified by the staff were corrected subsequent to TU Electric's response to NRC IR 445/88-24; 446/88-21. The NRC found that related documentation was appropriately maintained by both the NA certification holder (Brown and Root) and TU Electric Startup.
As is documented in NRC IR 445/88-61; 446/88-57, the staff and TDLS examined record packages and related documentation associated with the
" Secondary-Side" Cold Hydrostatic Test of Unit 1 and no serious dis-crepancies involving the hydrotesting of the steam generators were identified by NRC and TDLS. Further, the RCS Cold Hydrostatic Test, as documented in test 1.og (record) number ICP-PT-5501 did not include use of the Steam Generetor water level monitors. Testing of the Steam Generators was documented in a separate test, as addressed in the NRC inspection report referenced above. To this extent, the staff concludes that, based on the requirements and available test records, the Steam Generator water level monitors did not have relevance to the subject RCS Cold Hydrostatic Test. The details of this finding were discussed with CASE representa-tives by TU Electric, TDLS, and NRC on several occasions.
In regard to the differences between the Pressure Test Data Sheet i
identified by CASE as attached to CP-CPM-6.9I and CP-QAP-12.2, both NRC and TDLS noted this difference during their inspections and concluded that
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it was minor and had no impact on the technical and documentation adequacy of the RCS Cold Hydrostatic Test.
It should also be noted that another i
aspect regarding an item missing in the Pressure Test Data Sheet was found by the staff and cited as a violation in NRC IR 445/88-24; 446/88-21.
This item was acceptably resolved by TU Electric and aid not impact the technical or quality documentation adequacy of the subject hydrostatic test.
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.[ l lI' In regard to CASE's contention that the eleven Pressure Data Sheet Attachments contain unacceptable.or significantly inaccurate data, each of the minor tracking deficiencies noted by CASE relative to uninitiated changes and. the addition of an ISO number to a document were noted by the staff. TDLS, and TU Electric during their respective extensive reviews of these documents. The staff and TDLS determined that these e ficiencies were minor and did not invalidate the record.
CPPD Conclusion The staff concludes that the identified deficiencies with ICP-PT-55-01 were either not correct, not relevant or minor and did not invalidate the test
' package.
3.3.3 Issue III, Competence of Certain Inspectors and Supervisors 3.3'3.1 CASE and TU Electric Fositions CASE The. failure of TU Electric to be able to demonstrate which inspectors and supervisors actually participated in the inspection of the welds, regions of
-high stress, etc.,.is compounded by the fact that several of the allegedly
- involved inspectors and supervisors have a personal history of actions which
.previously have.had a negative impact on project quality or have violated quality comitments.
TU Electric As discussed in Issue I. Point 4 TU Electric considers that they have adequately identified the inspectors and supervisors who participated in the inspection. With respect to the personal history of certain in-spectors and supervisors involved in the test, TU Electric asserts that CASE has presented no evidence substantiating that its stated concerns with respect to these individuals impacted the proper performance or validity of the test.
3.3.3.2 ~ CASE Supporting Points, TU Electric Response, and Staff Evaluation (1) ~ Issue III, Point 1 CASE 4
CASE asserts that TU Electric has not been able to demonstrate that the quality control supervisors exercised prucent judgement in regard to their supervisory responsibilities. Two examples of supervisors whose past actions displayed poor management judgement were cited.
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With respect to one of the supervisors referred to by CASE, TU Electric's review of the time records for the day when the test occurred determined that the supervisor was not present. Accordingly. TU Electric believes that this-portion of CASE's point is irrelevant.
With respect to the second' supervisor TU Electric states that CASE's' concern mlates to accusations made during the litigation at the CPSES hearings that in 1984 the supervisor was involved in harassment of a QC-Inspector.with regard to fuel liner documentation. TU Electric asserts that they strongly' disputed accusations made during the hearings con--
f.erning the 1984 incident. Also, although 01:and'the NRC staff reached negative conclusions concerning a supervisor involved in the 1984 incident, TU Electric notes that;the NRC did not specify which supervisor its conclusion addressed and did not require that any action be taken with mspect to that supervisor's past or future work. TU Electric asserts that
- in any event, ths supervisor's alleged actions in a single incident in 1984 can provide no bases for questioning.the validity of the RCS Cold
. Hydrostatic Test. TU Electric identified that.the. supervisor's role was peripheral and, in view of the activities taking place on a team basis, the presence of individuals fmn numerous other groups and the prepara-
. tions that had been made to cowfuct the inspections promptly and efficiently, it is unlikely that harassing or intimidating actions could have occurred and gone unreported. Also, TU Electric interviewed 21 test participants and found that these individuals reported no undue pressure had been imposed on the inspectors during the test.
CPPD Evaluation CASE's concerns about supervisces whose past actions displayed poor management judgement arises from the record on litigation of harassment
- and intimidation issues before the ASLB. CASE refers to the record concerning two supervisors to illustrate their point.
With respect to one of the supervisors, TU Electric's review of the records (subsequent to CASE's submitaal of the dispute) has determined that the individual did not participi ca in the July 1982 RCS Cold Hydrostatic Test.
CASE's concern about the second supervisor stems from that supervisor's involvemu t in a 1984 incident involving harassu nt and intimidation of a QC Inspector. Because of the involvement of numerous' interested parties in the hydrostatic test, including the NRC and independent authorized nuclear inspectors, and the nature and duration of the test, it would appear that poor management action (including intimidation of inspectors) would have Deen observed. Further, staff interviews of inspectors involved in the test did not detect any implications that the inspectors
- were improperly directed by supervisors during the 1982 RCS Cold Hydro-static Test. This observation is consistent with the infomation reported s
as a result of interviews conducted by the Manager, Quality Assurance, with inspectors involved in the hydrostatic test.
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The staff finds, lacking any evidence that inspectors were harassed or otherwise misdirected during the test, that CASE has not presented any basis to support their contention that QC supervisors conducted their responsibilities improperly during the hydrostatic test.
CPPD Conclusion The staff concludes that there is no basis to conclude that QC supervisors conducted themselves improperly or in any manner not in accordance with the ASME Code and NRC regulations.
(2)
Issue III, Point 2, CASE 1
CASE maintains that TU Electric cannot verify the quality or quantity of l
the inspections performed by individual inspectors and reliance is largely on the assumption that the individual inspectors performed the inspec-tions. One example of an inspector whose competency had been brought into question by TU Electric was identified.
TU Electric TU Electric responded to CASE's point about the quality and quantity of the inspections performed in their responses to earlier points in Issue I.
With respect to the one individual referred to by CASE, TU Electric states that the individual was qualified as a Level II MIFI Inspector and was rerertified on Juiv 22, 1982, based on " demonstrated technical competence."
TU E'lectric provided information on the reasons for the termination of this employee in the fall of 1982.
TU Electric concludes that it is apparent that the inspector was terminated for docurrentation difficulties, not for technical incompetence.
CPpD Evaluation The first part of this point involves concerns over the quality and quantity of the inspections performed by individual inspectors.
These concerns are, for the most part, addressed in the staff's evaluation of previous points associated with Issue I.
Specifically, Issue I, Point 1, addresses the topic of inspector instructions and Issue I,-Point 4, addresses both the aspects of quality and quantity of the inspections, including the time to conduct the test. The staff also notes that a March 13, 1989 report titled, " Technical Evaluation of CPSES 1982 Hydro Test and ASME Section XI VT-2 Test," prepared by a CASE consultant addressed it some detail the technical validity of the hydrostatic test.
In that report, the consultant found no problems of a technical nature.
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24 Since the issues of quality _and quantity of the inspections are addressed more specifically elsewhere, this evaluation focuses on the concern about the competency of the inspectors. The concern is based on one example of the questionable competency of an inspector who was involved in the test.
As presented in this report and in NRC inspection reports, the staff and the Chief Inspector, TDLS, conducted interviews with a number of the TU Electric QC Inspectors who participated in the July 1982 RCS Cold Hydrostatic Test. Based on the inspectors' responses. to NRC/TDLS questions, these inspectors demonstrated that they were very knowledgeable in their trade and appeared to be very capable inspectors. Moreover, the staff examined the qualification and certification records for all of the inspectors involved in the subject test and determined that all were qualified, including the one individual referred to in the example.
The staff finds it unreasonable to make any general extrapolation about the competency of inspectors involved in the hydrostatic test based on concerns about one inspector. This is particularly true given the staff's findings discussed previously as a result our examination of the training records and interviews with the inspectors involved in the test. Also, the staff. found no basis to question the competence of the inspector specifically identified by CASE nor any evidence that the inspector per-formed poorly during the hydrostatic test.
Further, the nature of the test, the number of intpectors involved in the test, and oversight of the test by independent observers, lessens significantly the likelihood of undetected poor performance by any one individual adversely impacting the test results.
CPPD Conclusions The staff concludes that inspectors involved in the RCS Cold Hydrostatic test were properly qualified and capable of performing their assigned tasks.
4
SUMMARY
EVALUATION AND CONCLUSION 4.1 Summary Evaluation As presented in Section 3 of this report, CPPD evaluated each of CASE's points in support of their three major issues that form the basis of the dispute and request for NRC action. CPPD also evaluated TU Electric's responses to each of the points and considered past NRC inspection activities, reports and related documentation, including the inspection activities and findings of the ASME representative (TDLS). The staff concluded that no point, by itself, justified the need for CASE's requested acticn. The following presents the staff's evaluation of points associated with each issue to determine if the points, when looked at in the aggregate, support a finding that the RCS Cold Hydrostatic Test was not acceptably. performed or documented.
Finally, the three issues are collectively evaluated to determine if further actions
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relative to the RCS Cold Hydrostatic Test are necessary.
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4.1.1 Issue 1 The core of CASE's issue is the contention that insufficient " objective" evidence is available to demonstrate that the hydrostatic test, as performeo and recorded, complied with applicable ASME and NRC requirements. As presented in Section 3.2.1, CASE provided four points in support of this issue.
The staff evaluated each of these points and found that the objective evidence relative to each point was sufficient to demonstrate that ASME and applicable' NRC requirements were met.
As documented in NRC IR 445/88-24; 446/88-21, NRC and TDLS rigorously examined-the records associated with the July 1982 perfonnance of the Unit I cold hydrostatic test. During these reviews, the staff identified issues very similar to those identified by CASE relative to the adequacy of the documented record. Upon completion of the inspection in June 1988, the NRC issued two violations related to apparent procedural inadequacies and one unresolved item. Based on the inspection findings, the staff considered the accept-ability of the cold hydrostatic test at that time was indeterminate. One element supporting the staff's conclusion was that it was unclear from the procedures and the records reviewed how TU Electric identified and controlled the examination of all field welds, vendor welds, shop welds and base metal repairs in the context of the " marked-up" isometric drawings.
In response to the staff's overall concern about the adequacy of documentation and the two violations, TU Electric performed an in-depth evaluation of the
-Unit l'RCS Cold Hydrostatic Test and documented the results of this evaluation in Engineering Report No. ER-ME-01. TU Electric's response to the two violations and one unresolved item provided additional information on the results of their assessments of the adequacy of documentation associated with the hydrostatic test. The staff and TDLS reviewed the information submitted by TU Electric and concluded that a sufficient record had been developed and, based on a detailed review of that record, concluded that the require-ments of the ASME Code were met.
The results of the staff's evaluation are documented in NRC IR 445/88-61; 446/88-57, and were based on a thorough assessment of the documented record.
The staff has reviewed CASE's points supporting this issue with respect to new information that had not been included in the staff's earlier reviews and findings. With respect to t!.e first point, concerning lack of additional proceduralized instructions to the QC Inspectors, CASE is correct in their assertion that some of the additional items they list (on-the-job training, inspection check lists, walkdown sheets) were not explicitly used. However, the staff found that the procedures used by TU Electric ano their preparations for the test, including training of the DC Inspectors, met the ASME Section III Code and NRC requirements and was therefore acceptable.
Regarding the second point, about the availability of inspection data, this point was evaluated in considerable detail by the staff, resulting in some significant inspection findings which, as discussed above, were subsequently addressed by TU Electric
n to the' staff's satisfaction. The staff similarly evaluated in great detail the elements surrounding CASE's third point that involved the practice used by
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TU Electric of having only one QC Inspector sign (representing the whole team of inspectors) the Pressure Data Sheet Attachments. As discussed earlier in this report, the staff found this practice adequately met ASME and NRC require-ments. CASE's final point with respect to this issue involved several items that raised questions in CASL's opinion about the adequate performance of this test. These were all items : hat the staff was aware of and took into censidera-tion during the inspections described in Section S.I.
The staff has reviewed each of the points and finds that, other than the one item about additional procedura11 zed instructions (Point 1), all the information i
contained in the points were pr3viously considered during staff and TDLS in-spections. The use of additional proceduralized instructions as characterized by CASE, although potentially an enhancing feature, were not, in the staff's opinion, required by ASME or NRC requirements or TU Electric procedures. Also central to this issue are CASE's concerns that objective evidence is not avail-i able to demonstrate that all welded joints, welded connections, base metal repairs involving welding, and all regions of high stress. The staff, during its initial inspections, had similar concerns which were subsequently resolved by TU Electric.
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It should be noted that the staff considered that a number of the practices used by TU Electric in conducting the 1982 hydrostatic test, although in compliance with the ASME Code and NRC requirements, were weak and could be enhanced. A number of TU Electric's practices were enhanced and used during the implementation of the recently completed ASME Section XI VT-2 Test.
In summary, the staff did not identify any new information relative to any of CASE's points that would cause the staff to change its previous findings about the sufficiency of the documented record of the RCS Cold Hydrostatic Test and its compliance with ASME and NRC documentation requirements.
4.1.2 Issue II Deficiencies perceived by CASE and their consultants during their review of records led them to the conclusion that documentation was not reliable in establishing that the test was conducted in accordance with ASME and regulatory requirements. As presented in Section 3.2.2, CASE provided three points in support of this issue. The staff has evaluated each of these points and found that the deficiencies identified by CASE are not of such significance and, in rome cases relevance, to impact the validity of the documented record of the hydrostatic test.
The three points raised by CASE involve revisions to plant drawings, an assortment of examples of miscellaneous documentation discrepancies, and examples of documentation deficiencies associated with ICP-PT-55-01.
In the staff evaluation of the deficiencies, most were considered minor documentation errors, several were found to be not relevant to the hydrostatic test and a few were found to be mistaken. As documented in NRC inspection reports, the
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.i staff found documentation errors similar to the types identified by CASE.
However, the staff did not identify any new information (either in type of or extent of documentation errors) that would cause the staff to change previous findings on the completeness or accuracy of the documented record of the hydrostatic test.
4.1.3 Issue III CASE maintains that certain inspectors and supervisors involved with the test had a history of actions which previously hac negative impact on project quality. CASE asserts that, in consideration of the weaknesses in the documented record of the hydrostatic test (Issue I and II), reliance on inspectors of questionable competency only exacerbates the dispute about a record that can be relied upon. As presented in Section 3.2.3, CASE provided two points (one involving two supervisors and one involving one inspector) in support of the issue. The staff has evaluated each of these points and found that all inspectors and supervisors involved in the RCS Cold Hydrostatic Test were properly qualified and certified and that there was no reasonable basis to challenge any individual's competency.
4.1.4 Collective Evaluation The primary thrust of CASE's issues are that the documented record of the RCS Cold Hydrostatic Test is not adequate because there is not sufficient
" objective" evidence to demonstrate that the test has been done in accordance with applicable requirements (Issue I) and the records that do exist are inaccurate and incomplete (Issue II).
Finally, CASE asserts that certain inspectors involved with the test were of questionable competence, and reliance on these inspectors to supplement documentation deficien:1es provides an inadequate basis for regulatory compliance (Issue III).
The three issues raised by CASE are directed primarily at the adequacy of documentation demonstrating that the RCS Cold Hydrostatic Test was adequately completed in accordance with ASME Section III and other procedural and regulatory requirements. CASE's issues, and points supporting the issues, do not directly challenge the technical adequacy of the test. The riport, 4
" Technical Evaluation of CPSES 198211ydro Test and ASME Section L VT-2 Test," prepared by a CASE consultant and submitted tu the NRC by CASE's q
March 13, 1989 letter contained the conclusion that, from that consultant's 1
perspective, no problems of a technical nature which could invalidate the test l
were found. NRC inspections and those of the ASME representative (TDLS) had similar findings with respect to the technical adequacy of the test.
As summarized in Section 4.1.1, 4.1.2. and 4.1.3 above, the staff does not 1
consider that any of the three issues, either by themselves or collectively, merits either of the actions requested by CASE. Other than some documentation I
deficiencies that are of minor regulatory concern, the staff found that TU Electric's implementation and documentation of the RCS Cold Hydrostatic Test I
was in conformance with ASME Section III Code requirements NRC regulations, I
and TU Electric l
k
4
~
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procedures. While CASE identified some weaknesses in the documentation of the test, these weaknesses were similar to those identified by the staff and do not provide cause for the staff to change its earlier position about the adequacy of the hydrostatic test documentation.
TU Electric separately and collectively in its responses to NRC and the ASME representative has addressed and, when required, remedied the adverse findings and/or compellingly demonstrated that the identified omissions, errors, and weaknesses, when considered singularly or collectively, do not adversely impact the conclusion that the July 1982 RCS Cold Hydrostatic Test adequately met the quality and technical requirements of the ASME Code and NRC regulations. The staff has reviewed and inspected TU Electric's responses and actions and has found them acceptable. The successful perfomance of the ASME Section XI VT-2 Hydrostatic Test requested by the TDLS and supported by NRC demonstrates an additional reason to place a high level of confidence in the acceptability of the reactor coolant system (see NRC Inspection Report 50-445/89-22).
4.2 CONCLUSION
In accordance with the Joint Stipulation between TU Electric, the Citizens Association for Sound Energy, and the NRC, dated June 30, 1988, the Comanche Peak Project Division has performed a detailed evaluation of each of the issues involved in the dispute as discussed above.
Basec on the staff's re-examinations and evaluations as outlined in this report, CPPD has determined that TU Electric has acceptably demonstrated adequate objective evidence that, with minor exceptions, the requirements of the ASME Code and NRC regulations were met during the conduct of the July 1982 Unit 1 Reactor Coolant System Cold Hydrostatic Test. The staff, therefore, concludes that there is no basis to repeat the RCS Cold Hydrostatic Test or request a ruling by the ASME Code Comittee regarding the hydrostatic test. Further, the staff concludes that there is a sufficient basis to conclude that the cold hydrostatic test was acceptably performed such that, when all other regulatory requirements are met, there is reasonable assurance that Comanche Peak Unit I can operate safely.
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