TXX-4826, Responds to NRC Re Violations & Deviations Noted in Insp Repts 50-445/85-16 & 50-446/85-13.Corrective Actions:Design Change Authorization 13,349 Rereviewed & Results Documented in Calculations SRB-128C,Set 2,Rev 10

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Responds to NRC Re Violations & Deviations Noted in Insp Repts 50-445/85-16 & 50-446/85-13.Corrective Actions:Design Change Authorization 13,349 Rereviewed & Results Documented in Calculations SRB-128C,Set 2,Rev 10
ML20214J560
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/16/1986
From: Counsil W
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To: Johnson E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20214J555 List:
References
TXX-4826, NUDOCS 8608150072
Download: ML20214J560 (25)
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JUN 17 '87 8:05 TUGCO COMMUNICATIONS PAGE.02

, Log # TXX-4826 File # 10130 IR 85-16 85-13 TEXAS UTILITIES GENERATING COMPANY

.arway ww . rm osavn er r. i... n .DA12.A4.TSEAS Mee A June 16, 1986

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Mr. Eric H. Johnson, Director JUN 973 Division of Reactor Safety and Projects . _

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U. S. Nuclear Regulatory Commission I 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012

SUBJECT:

COMANCHEPEAKSTEAMELECTRICSTATION(CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION AND NOTICE OF DEVIATION INSPECTION REPO.RT NOS.: 50-445/85-16 AND 50-446/85-13

Dear Mr. Johnson:

We have reviewed your letter dated April 4,1986, concerning the inspection conducted by Mr. T. F. Westerman and other members of the Region IV Comanche Peak Group during the period November 1 - 30, 1985. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for the Comanche Peak Steam Electric Station Unit 1 and 2.

We requested and received a two week extension in providing our response during a telephone conversation on May 2,1986. We requested and received a second two week extension on May 19, 1986. We requested and received a third l

two week extension on June 2, 1986.

We have respunded to the Notice of Violation and Notice of Deviation in the attachments to this letter.

Very truly yours, W. G. Counsil RSB/gj l Attachments 1

c - NRC Region IV (Original + 1 Copy)

Director, Inspection & Enforcement (15 copies)

U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. V. S. Noonan Mr. D. L. Kelley i 8608150072 860012 5 PDR ADOCK 0500 I i 4 omaron or r=x4e vram== =z.scraic comer 4ur DM \

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. JUN 17 '87 8:06 TUGCO COMMUNICATIONS PAGE.03 NOTICE OF VIOLATION ITEM A (445/8516-V-08)

O A. Criterion III of Appendix B to CFR Part 50, as implemented by Section 3.0, Revision 4, dated November 20, 1985, of the TUGC0 Quality Assurance Plan (QAP), states, in part,". . . Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design . . ."

Contrary to the above, the Unit 1 field substitution of a grouted Richmond insert for a 11/4-inch diameter Super-Hilti bolt was authorized byDesignChangeAuthorization(DCA)13349withoutbeingsubjectto design control measures commensurate with those applied to the original design. Table I of Appendix 3 to Gibbs and Hill (G&H) S aecification 2323-SS-30, Revision 0, provides allowable loads for Ric1mond inserts which are cast in place in 4000 psi concrete. Allowable loads were not, however, provided by this specification for grouted Richmond inserts.

Calculation SRB-128C, Set 2, Sheets 168 and 169, which was referenced by DCA 13349, also did not address the shear capacity of the concrete-grout interface and thus did not establish the tensile capacity of the grouted Richmond insert.

RESPONSE TO ITEM A i

1. REASON FOR VIOLATION Design Change Authorization (DCA) 13,349 as issued allowed the substitution of a 1" diameter Richmond Insert (R.I.) for 1 1/4" diameter SHKB. The DCA made no mention that the substituted R.I. was to be grouted in previously placed hardened concrete. This was an engineering judgment on the part of the DCA originator. The design control and associated

! design review for the DCA did not receive the same design control measures l

commensurate with those applied to the original design that would require the addressing of the shear capacity of the concrete-grout interface.

2. CORRECTIVE ACTION TAKEN The contents of the DCA have been re-reviewed from the point of view of -

the shear capacity at the concrete-grout interface and was found to be acceptable. The results have been documented in calculations SRB-128C, Set. 2, Rev. 10.

Further calculations have been completed and shown that the support is acceptable assuming zero load resisting capacity of the R. I. The DCA has been revised to clarify that the R.I. was grouted versus poured in place.

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3. ACTION TO PREVENT RECURRENCE.

Based on personnel discussions this is the only known substitution of a grouted-in R.I. From engineering calculations, the DCA originator's judgment has been proven to be correct. No further corrective action is planned.

4. DATE OF FULL COMPLIANCE We consider this item was in full compliance as of June 2,1986, when the ,

review was completed.

, JUN 17 '87 8:06 TUGCO COMMUNICATIONS PAGE.04 NOTICE OF VIOLATION I !M B (445/8516-V-141 l B. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QAP states, in part,

" Activities affecting quality shall be prescribed by documented instructions, procedures or drawings . . . and shall be accomplished in

. accordance with these instructions, procedures, or drawings."

Attachment 1 in Revision 7 of Brown & Root, Inc. (B&R) Procedure CEI-20 uires a minimum center-to center spacing of 11 1/4 inches between req 11 /4-inch and 1-inch Hilti expansion bolts. Attachment I also indicates that this minimum spacing applies to Hilti bolts detailed on separate adjacent fixtures and that violation of minimum spacing must be approved by issuance of design change documents by the applicable Comanche Peak Project Engineering groups.

Contrary to the above, a center-to-center spacing of 10 1/2 inches i existed between a 1 1/4-inch Hilti bolt and a 1-inch Hilti bolt on adjacent fixtures of Support No. SI-1-039-044-S42R. This Unit I support was previously inspected and accepted on December 21, 1981, without evidence of any design change documents approving this condition.

RE_SPONSE TO ITEM B

1. REASON FOR VIOLATION The process for resolving separation violations are described in I engineering procedure D8D-05-15. The document generated as a result of these measures is an EESV (Engineering Evaluation of Spacing Violation) form.

In the instance cited, the apparant separation violation was noted by PSE Field Engineering and an EESV document generated. However, in document preparation, the engineer it. correctly recorded the support identification as SI-1-039-004-S42R instead of the proper SI-1-039-044-S42R. This error resulted in the EESV being incorrectly filed.

At the time of the inspection of this Unit 1 support (December 21, 1981),

the adjacent supports had not been instslled. The violation occurred in .

October 1982 when the adjacent class 5 support was installed and the EESV was issued. ,

2. CORRECTIVE ACTION TAKEN The EESV, #PSE637, was revised to reflect the correct number on April 30, 1986.

1 Pipe Support Engineering (PSE) has surveyed the PSE targe Bore EESV Log and numbered all EESV's against the applicable ASME support. There were 1213 ASME support-related EESV's noted in this survey. A sample of fifty (50) supports were randomly selected from the population of 1213.

. JUN 17 '87 8:07 TUGCO COMMUNICATIONS PAGE.05 RESPONSE TO ITEM B (Continued 1 PSE Field Engineering has subsequently verified the support's identification numbers are correct on each of the randomly selected EESV's through visual inspection of the affected pipe support installations. No other deficiencies of this nature were noted during the verification effort.

3. ACTION TO PREVENT RECURRENCE As a result of the above sampling and verification effort, this violation is considered to be an isolated case. No further corrective action is deemed necessary. As a precaution to preclude recurrence, this item has been discussed with the Field Engineering Group.
4. DATE OF FULL COMPLIANCE As noted above, corrective steps have been accomplished.

JUN 17 '87 8:08 TUGCO COMMUNICATIONS PAGE.06 NOTICE OF VIOLATION ITEM C (445/8516-V-131 C. Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section 10.0, Revision 1, dated July 31, 1984, of the TUGC0 QAP, states, in part, "A program for inspection of activities affecting quality shall be established and executed . . . to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."

Paragraph 5.1.2 in B&R Procedure CP-NDEP-200, Revision dated September 27, 1979, states, in part. "The final surface condition of plate and piping welds shall be visually inspected after completion of the weld for . . .

fillet size (as applicable)." Revision 4 of Drawing CC-1-131-010-S43R requires welds on two sides for item 8 to item 9, with a fillet size of 1/4 inch. A weld fillet size of 1/4 inch is also specified for items 9 and 10.

Contrary to the above, inspection of Unit 1 ASME Pipe Support No.

CC-1-131-010-S43R, which had been previously inspected and accepted by Quality Control, identified the presence of undersize welds. A total weld length of asproximately 20 inches was found to be undersize by a minimum of 1/16 inc1 with respect to the item 8 to item 9 fillet welds. A consecutive 2-inch segment was also present in these welds which was 1/8 inch undersize. The vertical welds on the outside of the wide flange joining items 9 and 10 were also found to be undersize by a minimum of 1/16 for more than 25% of the weld length.

RESPONSE TO ITEM C

1. REASON FOR VIOLATION Inadequate QC inspection of existing weld sizes against weld sizes required by the design.
2. CORRECTIVE ACTION TAKEN A nonconforrasnce report was issued under the Section XI Program on 11/14/65-NCR#X1-708;ThisNCRwassubsequentlytransferredtoa Section III NCR on 3/11/86 - NCR # H-25,650.
3. ACTION TO PREVI!LT RECURRENCE The support addressed was inspected in 7/83 in the earliest versions of the As-built inspection Program. Due to problems related to undersized welds, B&R Procedure QI-QAP-11.1-28 Rev. 24, issued 4/24/84, was revised to require the QC inspector to assign a weld number to each weld shown on the design drawing, and to document both the required size of the weld per design drawing and the actual deposited weld size. All QC personnel were trained in the procedure revision and inspection methodology, including ,

i the requirement that undersized welds required the initiation of an NCR.  !

Additionally, this procedure revision permitted auditing individual weld inspections and emphasized the necessity of inspecting each weld required ,

by design.

4. DATE OF FULL COMPLIANCE NCR # M-25,650 will resolve the specific welds identified.

. JUN 17 '87 8:08 TUGCO COMMUNICATIONS PAGE.07 NOTICE OF VIOLATION ITEM 0 (446/8513-V-10)

D. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QAP states, in part,

" Activities affecting quality shall be prescribed by documented instructions, procedures or drawings . . . and shall be accomplished in accordance with these instructions, procedures, or drawings."

I Appendix 7 to G&H Specification 2323-MS-85, Revision 3, states, in part, with respect to field fabricated ductwork, " Install in accordance with l 1

approved Traveler . . . Field modify as necessary and document modification . . ." Table 2.10-1 in the G&H specification states that the minimum acceptance criteria for visual inspection are "No Visible Defects."

Parag aph 6.2, in Bahnson Quality Field Procedure QFP 10.001 CPI, Revision 2, states, in part, " Inspection of . . . installation . . . shall be performed by inspection personnel in accordance with the requirements l established by the . . . Ductwork Installation checklist . . . and applicable QCIs." The Ductwork Installation checklist addresses visual damage. Paragraph 5.1.3 in Bahnson Procedure QCI-CPSES-003, Revision 6, states, "The Bahnson QC inspector shall verify that the duct joints are bolted together so that the gasket is compressed to a thickness of 1/8" plus or minus 1/32". Verification may be accomplished either at the time of installation or during final walk-thru."

Contrary to the above, observed damage to Unit 2 Battery Room Ventilation Exhaust Duct System EMD-3, which apparently occurred during installation as a result of force bending Flange Nos. 17 and 18 to preclude interference with an adjacent wall, was neither documented as being a field modification nor was it identified as visual damage on the Bahnson final inspection report dated April 1,1983. This report states, "END-3 Jts.1-18 (BRVE) have been inspected and are acceptable." Further, the force bending created a gasket gap of 1/4 inch in the trough of the bend which is in excess of the maximem allowable gap of 5/32 inch.

RESPONSE TO ITEM D

1. REASON FOR VIOLATION Field modification was performed without Engineering approval and inadequate QC inspection was performed.
2. CORRECTIVE ACTION TAKEN Deficiency and Disposition Report No. 0381 was written describing the bent flange. The disposition of the report was to leave duct joint "as is",

because

1. The duct is classified as Non-ESF duct on the discharge side of the fan.
2. The duct was tested and passed Leak Test #412 dated 8/27/85.

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JUN 17 '87 8:09 TUGCO COMMUNICATIONS PAGE.08 RESPONSE TO ITEjij2 (Continued)

3. The bent flange does not impair the duct's integrity and intended use.

If similar conditions of this nature exist, the final system walk-down using as built drawings will identify and resolve the condition.

3. ACTION TO PREVENT RECURRENCE Training has been given to instruct all craft supervision to present procedure DFP-TUSI-005, Rev. 5, " Duct Installation Procedure", addressing field changes, which should preclude recurrence of a similar situation during Unit 2 duct installation.

Additionally, appropriate QC inspectors will be instructed in the need for accurate and complete inspections in accordance with approved procedure requirements.

4. DATE OF FULL COMPLIANCE May 30, 1986.

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JUN 17 '87 8:09 TUGCO COMMUNICATIONS PAGE.09 N3TLCE OF DEVIATION I_TE4 n.1(445/8516-D-50)

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A. Section 4 in Revision 3 to CPRT Project Procedure CPP-009 for Issue -

Specific Action Plan VII.c states, in part, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions t I Contrary to the above, the following examples were noted where field l reinspections of hardware items were not performed in accordance with I approved instructions:

1. Attribute 4.5 in Section 5.0 of QI-055 Revision 0, states for saring nuts, " Verify that the serrated grooves align with the ciannel clamping ridge." For Verification Package No. I-S-INSP-033, Support No. 033A, the ERC inspector signed the checklist that this attribute was acceptable. However, an independent inspection showed that the spring nut serrated grooves did not align with the channel clamping ridge on this support (445/8516-0-50).

RESPohsE TO ITEM A.1 L, REASON FOR DEVIATION ERC investigatin confirmed the stated condition. Spring Nut misalignment was also an issue in NRC Findings 445/8514-D-04 and 445/8518-0-22.

Investigation is ongoing to determine if the error is conclusively attributable to inspector oversight or construction related rework subsequent to the ERC inspection. At the time this investigation is completed, corrective action will consist of integrating the finding into the Overview Inspection Program and/or appropriate actions within the applicable maintenance program to ensure channel clamping ridge / serrated grove alignment.

2. CORRECTIVE ACTION TAKEN DR number I-S-INSP-033-DR2 was written on November 14, 1985, to document the channel clamping ridge / spring nut misalignment. NCR I-86-100071SX was generated as a result of the DR to dispostion the above condition.

The failure to note the deviating condition was thoroughly discussed with the inspector by a Level III on the investigation. The discussion with the inspector was documented.

Since several DRs were generated as a result of NRC findings and the ISAp VII.c reinspections, TUGC0 has initiated Corrective Action Request 72X dated May 21, 1986, to disposition the condition on a generic basis.

3. ACTION TO PREVENT RECURRENC_E A general training session on spring nut inspection was given to all r

l inspectors involved in the reinspection of this attribute. This retraining was completed on November 12, 1985.

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JUN 17 '87 8:10 TUGCO COMMUNICATIONS PAGE.10 RESPONSE TO ITEM A.1 (centinued)

An Overview Inspection Program has been implemented to reinspect a sample of each Inspector's work on a continuing basis. Action is ongoing to analyze results of the Overview Inspection program, gather pertinent inspector error data from other sources (i.e., NRC reinspections, etc.)

and to effect required additional formal training of inspectors.

4. DATE OF FULL COMPLIANCE Corrective action will be completed comensurate with the final i disposition of CAR 72X, Investigation is anticipated to be completed by July 15,1986. The Overview Inspection Program consists of an ongoing program.

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JUN 17 '87 B:11 TUGCO COMMUNICATIONS PAGE.11

!0TICE OF DEVLATION ITE0 A.2 (446/85 3-D-11)

A. Section 4 in Revision 3 to CPRT Project Procedure CPP-009 for Issue -

Specific Action Plan VII.c states, in part, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews,of appropriate documents in accordance with approved instructions Contrary to the above, the following examples were noted where field reinspections of hardware items were not performed in accordance with approved instruction:

2. Section 5.lA3c of QI-031, Revision 0, states, in part, with respect to reinspection of containment liner and tank stainless steel liner, Verify that the height of the reinforcement on each face of the seam doesnotexceed3/32-inch." Section 5.1 addresses reinspection of the weld seam surface and states, "If the . . . weld seam surface does not meet the above criteria the checklist shall be marked reject and the weld and rejectable item shall be identified by a deviation report."

However, the ERC inspector did not identify excessive reinforcement for containment liner weld joint PS2, Verification Package No.

I-S-1.INR-61. An independent reinspection of this weld identified excessive reinforcement for approximately 807, of the weld length with reinforcement us to 7/32 inch when measured from the liner plate to the center of tte weld (446/8513-D-11).

RESPONSE TO ITEM A.2

1. REASON FOR DEVIATIQH Rainspection subs?quent to the above findir.g did not identify excessive reinforce:nent height fcr this weld using the acceptable measurement i

technique when measuring weld material between objects of unequal thickness. The proper method of measuring the reinforcement height is to measure the maximum rise (using the contour gauge) from a theoretical line drawn between the toes of the weld. A review of the results for attribute 5.1.A.3.c of QI-031 and discussions with the inspectors involved revealed that the method used to obtain a measurement to satisfy the requirements of this attribute was not clearly delineated in QI-031 Rev. 0 when the measurement is for weld material between objects of unequal thickness.

2. CORRECTIVE ACTION TAKEN In accordance with CAR 16, ten percent of the verification packages for this population have been reinspected.

Change Notice 001 to QI-031 Rev. 2 was issued on April 24, 1986, providing guidelines to measure the reinforcement of welds using a contour gauge when the weld is between materials of unequal thickness.

All sample packages consisting of weld seams between materials of unequal thickness, including I-S-LINR-061, have been reinspected for compliance with the new guidelines. This action has been completed.

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. JUN 17 '87 8:11 TUGCO COMMUNICATIONS PAGE.12 RESPONSE TO ITEM A.2.

(Continuedi.

L ACTION TO PREVENT RECURRENCE 1 Other QIs have been reviewed by engineering to determine areas of clarifications or technical revisions. Reinspections are being performed as necessary.

4. DATE OF FULL COMPLIANCE Corrective action has been completed. Preventive action involves an on-going program.

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JUN 17 '87 8:12 TUGCO COi1MUNICATIONS PAGE.13 NOTICE OF DEVIATION ITEM A.3'f445/9516-3-47)

A. Section 4 in Revision 3 to CPRT Project Procedure CPP-009 for Issue -

Specific Action Plan VII.c states, in part, "O,ualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews,of appropriate documents in accordance with approved instructions Contrary to the above, the following examples were noted where field reinspections of hardware items were not performed in accordance with approved instructions:

3. Section 5.3.A of QI-043, Revision 1, states with respect to concrete surface inspection, " Inspect all accessible surfaces for honeycombing and voids (Inaccessible surfaces are those cast against earth, backfilled, or coated)."

Review of Verification Package No.1-S-CONC-057 revealed that the ERC inspector entered "N/A" (for not applicable) on the checklist for attribute 3.A (surface inspection of walls, etc.), and " coated" in the remarks column. However, an independent inspection revealed that the surface was not coated. In addition, the NRC inspector identified a void with a depth of at least 1 1/2 inch and dirt in theconstructionjoint. These conditions were not identified by ERC (445/8516-D-47).

RESPONSE TO ITEM A.3

1. REASON FOR DEVIATION The original inspector and a lead inspector reviewed this reinspection.

After returning to the location of the original inspecticn, the original inspector was able to determine that the reinspection was made on a blockout immediately adjacent to the designated blockout.

2. CORRECTIVE ACTION TAKES The correct pour was reinspected on November 14, 1985 and documented accordingly.
3. ACTION T0 PREVENT RECURRENCE The inspector was cautioned to watch out for " mirror image" transpositions from the drawings. The discussion with the inspector was doc wented.

To provide reasonable assurance that other inspections of this attribute were properly accomplished, a historical review was conducted as part of the Overview Inspection Program and no instances.of the subject inspector's error were identified. Although the subject inspector's error appears to be an iso'ated case, the continued implementation of the Overview Inspection Program also includes reinspection of current inspection activities which verifies proper inspections of all attributes.

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JUN 17 '87 8:12 TUGC0 COMMUN! CATIONS PAGE.14 RESPONSE TO ITEM A.3 (Continued)

Action is ongoing to analyze results of the Overview Inspection Program, gather pertinent inspector error data from other sources (re. NRC reinspections, etc.) and to effect required additional formal . training of inspectors.

4. DATE OF FULL COMPLIANCE Corrective action has been completed Preventive action involves an ongoing program.

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JUN 17 '87 8:13 TUGCO COMMUNICATIONS PAGE.15 NOTICE OF DEVIATION IT EM A.4 (445/8516-D-42)

A. Section 4 in Revision 3 to CPRT Project Procedure CPP-009 for Issue -

Specific Action Plan VII.c states, in part " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews,of appropriate documents in accordance with approved instructions Contrary to the above, the following examples were noted where field reinspections of hardware items were not performed in accordance with approved instructions:

4. Section 5.1.Al of QI-031, Revision 0, states, in part, with respect to attribute A.I.a. "The following local contour deviations are to be verified: A maximum of 1-inch gap between the cylindrical liner or dome shell plate and a six feet long template curved to the required radius . . . ." This attribute applies to both the .

cylindrical and dome liners. However, the ERC inspector entered "N/A" for not applicable on the checklists and "(dome only)" in the remarks column for attribute A.1.a for Verification Package Nos.

I-S-LINR-08, I-S-LINR-12, and I-S-LINR-61. These verfication packages involved the cylindrical liner and attribute A.I.a did, in fact, apply (445/8516-D-42).

_ RESPONSE TO ITEM A.4

1. REASON FOR DEVIATION The investigation revealed an ambiguity between Paragraphs 5.1. A.1 and sub-paragraph 5.1.A.1.a leading to misunderstanding on the inspector's part.

! 2. CORRECTIVE ACTION TAKEN Procedure 01-031 was revised on January 15, 1986 to ruolve the identified ambiguity. The reinspection packages have been reviesed to determine the requirements of reinspection of this attribute.

3. ACTION TO PREVENT RECURRENCE The corrective action proposed above will also serve as preventive action.
4. DATE OF FULL COMPLIANCI Full compliance has been achieved.

JUN 17 '87 8:13 TUGC0 COMMUNICATIONS PAGE.16 NOTICE OF DEVIATIONS ITEMS A.5.a. A.S.bEA.5.c. and A.S.d (445/8516-D-30)

A. Section 4 in Revision 3 to CPRT Project Procedure CPP-009 for Issue -

Specific Action Plan VII.c states, in part, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews,of appropriate documents in accordance with approved instructions Contrary to the above, the following examples were noted where field reinspections of hardware items were not performed in accordance with approved instructions:

5. Section 1.3 of QI-012, Revision 0, states in part, " Verify that the tubing is correctly routed . . . check tag numbers of instruments and proper hook-up of high/ low pressure connections . . . ." Section 1.5 states, in part, " Verify that there is proper air gap. The minimum l

. . . adjacent sensing gap spy.cing shall always be 1/8 inch (between) lines, other equipment, concrete or steel buil ding members."

Section 1.7 states, in part, " Verify that bends have a minimum of four (4) times the nominal tube size by using a template or the following procedure: . . . Enter measured and calculated values on Attachment 6.1, Initial and date each entry." Section 2.3 states, in part,". . .

For differential pressure type instrument, verify the proper hook-up of high/ low pressure connections . . . ."

Contrary to the above, the following conditions were identified:

a. The installation identification tag showing the low pressure the root valve numbers and instrument number for equipment in Verification Package No.1-E-ININ-049 was incorrectly marked as follows:

l The tag on Valve No.1-RC-8061B, which was associated with Instrument No. 1-fT-425, was identified with Instrument No.

1-FT-424.

b. Less than the required minimum 1/8-inch air gap spacing was identified at the following location:
1. Verification Package No I-E-ININ-049 - Between the high pressure sensing line and a steel member adjacent to the isolation valve location.
2. Verification Package No I-E-ININ-059 - Between the tubing and header pipe routed through the same wall penetration at the inside face of the excess letdown heat exchanger orifice room. The swagelock fitting near Support No. C-24-04-51 was also touching the wall,
c. Verification of minimum bend radii for tubing was not performed on the following:
1. Bend No. 5 in Verification Package No. 1-E-ININ-051, which was accessible, was neither identified nor inspected by the ERC inspector.

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JUN 17 '87 TUGCO COMMUNICATIONS PAGE.17 8:14 NOTICE OF DEVIATIONS ITEMS A.5.a. A.5.b. A.S.c and A.5.d (445/8516-D-30)

(Continued)

2. Bend No. 5 in Verification Package No.1-E-ININ-041, which was accessible, was identified by the ERC inspector as being inaccessible and was thus not inspected.
d. An improper hook-up (i.e., loose bolt) was identified between the low pressure sensing line flange attachment and the differential pressure type instrument in Verification Package No.1-E-1NIN-049(445/8516-D-30).

RESPONSE TO ITEMS A 5.a. A.S.b. A.5.c. and A.5.d

1. REASON FOR DEVIATION
a. Investigation revealed that the tag on valve 1-RC-8059B showed instrument 1-FT-426 (should have been 1-FT-424), the tag on valve 1-RC-8060B showed instrument 1-FT-425 (should have been 1-FT-426),

and the tag on valve 1-RC-8061B showed instrument 1-FT-424 (should have been 1-FT-425). However, these tags also showed the proper root valve numbers. The assessment of the instrument designation number on each tag was not an attribute for the reinspection. Proper identification of the instrument tubing was made in accordance with attributes of QI-12.

Furthermore, starting in the later part of 1983, the TUGC0 Operations Department instituted a program to replace the existing construction valve tags, which were inadequate (these tags were made of foil coated paper with numbers hand written), with durable stainless steel valve tags. Precedure STA-618, " Installation and Control of Permanent or Temporary Signs and Identification Aids",

was written which included details of the requirements for this program. Ta0S for root valves 1-RC-8059B 1-RC-8060B, and 1-RC-8061Bwerepreparedandinstalleduslng2323-M1-0250,Rev.

CP-3.

In March 1984, drawing 2323-M1-0250, Rev. CP-4 was issued which

< rearranged the valve numbers of these valves, as well as all of the similar flow transmitter root valves. This change was identified and new valve tags were made and issued to operators to install. However, the subject valve tags were inadvertently rearranged instead of being replaced by new tags.

Although the tag nomenclature was inconsistent with the intent of the program, the tags did contain the proper component identification number for the root valves, which is the means used to identify valves for operation and maintenance. The tags remained in place untti early 1986 when, during performance of a valve lineup for RCP operation, operators identified the improper i

nomenclature and new tags were prepared and installed.

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. JUN 17 '87 8:15 TUGCO COMMUNICATIONS PAGE.18 RESPONSE TO ITEMS A.5.a~. A.5.b. A.5.c. and A.5.d (Continued)

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The instrument designation number is outside the scope of QI-12 because QI-12 requires that the identification of the proper instrument line sample be verified by using the tag number on the instrument against the root valve ID shown on the tabulation sheet.

Proper verification exists without the use of the identification tag number in question. The valve tags were identified as having incorrect nomenclature during routine operations activities and were replaced independently of the subject NRC finding, b.1. Reinspection confirmed the clearance deviation due to inspector error.

b.2. An investigatic6 in which ERC management and an NRC inspector participated confirmed the Swagelock fitting touching the wall.

Subsequent reinspection on or about March 7,1986, identified that the observed clearance violation between the tubing and header pipe routed through the same wall penetration at the insida face of the excess letdown heat exchanger orifice room no longer existad. however, the tubing upon which the clearance deviation was originally observed, was determined to be not firmly held in place by the mounting brackets. Consequently, the tubing could be easily moved (along its axis) such that the 1/8 inch clearance violation could be easily created or eliminated.

I

c. (Both I-E-ININO-041 and I-E-ININ-051) Investigation revealed that Bend number 5 in both of these packages is in ths vent or drain line segment, open to atmosphere, after the vent or drain valve.

The inspector did not measure these bends. Investigation further revealed that neither the Verification Package nor the QI identified this portion of the system to be Out of Scope.

The QI was not complete in that it did not adequately define the limit of the inspections to pressure boundary affected components.

The Inspector was in error for limiting the scope of inspection to pressure boundary affected tubing without written direction,

d. Reinspection identified a loose bolt connecting the process flange adapter to the process flange of the transmitter.

The loose bolt is not within the scope of the CPRT reinspections since the transmitter is an assembled vendor component. The proper hook-up requirement that the QI refers to pertains to the routing of tubing from the sensing point to the instrument.

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JUN 17 '87 8:15 TUGCO COMMUNICATIONS PAGE.19 RESPONSE TO ITEMS A.5a. A.5b. A.5c. and A.S.d (Continued)

2. C09RECTIVE ACTION TAKEN l
a. No further corrective action is planned.

b.1. The verification package documentation was corrected on March 14, 1986, and DRf I-E-ININ-049R-DR2 initiated.

b.2. DRf I-E-ININ-059R-DR1 was written on March 7, 1986, to document the Swagelock fitting touching the wall. An Out-of-Scope Observation was written on May 30, 1986, to document the concern regarding the recreatability or elimination of the clearance deviation on the instrument tubing in question.

c. Revision 1 of QI-12 was issued January 30, 1986, to state the following:

" Vent and drain lines do not have to be verified for the four diameter requirement since vents and drains are not (4)jecttoprocesssystemspressure."

sub

d. An Out-of-Scope Observation was written on May 29, 1986, to
  • document the loose bolt.
3. ACTION TO PREVENT RECURRENCE
a. In February 1986, TUGC0 Operations Department issued work instruction OWI-402, " Operations Department Labeling Control". This instruction details the method in which all equipment and structure labeling installed by the Operations Department will be installed, reviewed and documented. Valve tagging is included in this instruction. Prior to fuel load of Unit 1, all system valve tags will be checked and documented against the latest drawing revision.

bac. As a result of a generic reanalysis of the adequacy of inspection instructions, conducted in January 1986, a detailed review has been conducted of each ERC Quality Instruction (QI). This included a I

review for clarity of the QI in describing what is to be inspected and the clarity of accept / reject criteria.

Due to the number of discrepancies found in the original reinspection of the ININ population, a decision was made to do a 100% reinspection of all ININ samples. This 100% reinspection has been completed.

An Overview Inspection Program has been implemented to reinspect a sample of each Inspector's work on a continuing basis.

Action is i

ongoing to analyze results of the Overview Inspection Program, gather pertinent inspector error data from other sources (re. NRC reinspections,etc.) and to effect required additional formal

' training of inspectors.

d. No preventive action is planned.

t_

JUN 17 '87 8:16 TUGCO COMMUNICATIONS PAGE.20

" t RESPONSE TO ITEM A.S.a.A.5.b.A.5.c and A.5.d  !

(continued)

4. DATE OF FULL COMPLIANCE Corrective action has been completed. Preventive action for b&c involves an ongoing program.

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-- -..,... , ,~-----, , , , . , . , . . - - , - - - , ,- . ,.n, _., , - - , , - , , , . , . - , , . . , - , . . , , , - +

[,*, JUN 17 '87 8:16 TUGCO COMMUNICATIcNS PAGE.21 NOTLCE OF DEVIATIONS ITEM A.6 (445/8516-1-35)

A. Section 4 in Revision 3 to CPRT Project Procedure CPP-009 for Issue -

Specific Action plan VII.c states, in part " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews,of appropriate documents in accordance with approved instructions Contrary to the above, the following examples were noted where fiald reinspections of hardware items were not performed in accordance with approved instructions:

, 6. Section 5.6.1.A of QI-027. Revision 0, states, " Verify welds are located as shown on design drawings. Record any welds that are in

- addition to those specified on the drawings. (Attachment 6.6)."

Contrary to the above, the ERC inspector failed to record the presence of existing additional welds to those specified on the drawing for Verification Package No. 1-1-LBSR-041. Independent review of the original installation documentation package, Mark No.

CC-1-126-702-F43R, established from examination of " Vendor Supplied Component Records" that field welds, which were not identified on the drawings, had been performed on the two sway struts (445/8516-D-35).

RESPONSE TO ITEM A.6

1. REASON FOR DEVIATION Investigation confirmed that the additional welds noted by the NRC were field welds. The Quality Instruction did not cover the inspection of field velds used to modify vendor supplied components.
2. CORRECTIVE ACTION TAKEN Quality instructions QI-019, QI-027 and QI-029 were revised on or before March 4, 1986 to incorporate requirements from TUGC0/B&R Procedure CP-CPM-7.3 B on the modification of vendor supplied components. A review of hanger support packages was undertaksn and those packages of supports that were modified were reissued for reinspection of modifications.
3. ACTION TO PREVENT RECURRENCE QI-19 Rev. 3, QI-27 Rev. 2 and QI-29 Rev. 2 now contain adequate instructions to prevent recurrence, l

l 4. DATE OF FULL COMPLIANCE f Full compliance has been achieved.

)

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JUN 17 '87 8:17 TUGCO COMMUNICATIONS PAGE.22 NOTICE OF DEVLATION

YEM A.7,,j445/8U16-3-181

~

A. Section 4 in Revision 3 to CPRT Project Procedure CPP-009 for Issue -

Specific Action Plan VII.c states, in part, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions Contrary to the above, the following examples were noted where field reinspections of hardware items were not performed in accordance with approved instructions:

7. The cable tray configuration acceptance criteria contained in Section 5.3.6 of QI-016, Revision 1, required the inspector to verify that all bolts have a nut and a locking device. Independent inspection of Verification Package No. I-E-CATY-077 revealed that the ERC inspector did not identify a missing bolt and locking device on the splice plate joining tray section T148 REC 28 to T14BREC27 (445/8516-D-18).

RESPONSE TO ITEM A.7

1. REASON FOR DEVIATION Investigation revealed that a nut and locking device was missing from the splice plate indicated above.
2. CORRECTIVE ACTION TAKEN DR No. I-E-CATY-077-DR2 has been initiated to document the deviating condition and the Verification Package documents have been revised.
3. ACTION TO PREVENT RECURRENCE The finding was thoroughly discussed with the inspector on or about January 10, 1986. The discussion with the inspector was documented.

An Overview Inspection Program has been implemented to reinspect a sample of each Inspector's work on a continuing basis. Action is ongoing to analyze results of the Overview Inspection Program, gather pertinent i

inspector error data from other sources (re. NRC reinspections, etc.) and to effect required additional formal training of inspectors.

4. DATE OF FULL COMPLIANCE Corrective action was completed by January 13, 1986, preventive action involves a continuous program.

1

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JUN 17 '87 8:18 TUGC0 COMMUNICATIONS PAGE.23 NOTICE OF DEVIATION ITEM A.8 (445/8516- )-17)

A. Section 4 in Revision 3 to CPRT Project Procedure CPP-009 for Issue -

Specific Action Plan VII.c states, in part, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews,of appropriate documents in accordance with approved instructions Contrary to the above, the following examples were noted where field reinspections of hardware items were not performed in accordance with approved instructions:

8. Section 5.6 of QI-014, Revision 1. O, requires verification that the cable routing agrees with References 3.2 and 3.3; i.e., 2323-EI-1700, Cable and Raceway Schedule. Independent reinspection of Verification Package No. I-E-CABL-102 (Cable EG139517) revealed that ERC inspectors had failed to identify that the cable routing was not in agreement 1 with Cable and Raceway Schedule 2323-EI-1700, issue 334, page 720.354 dated November 21, 1984. The cable was noted to be physically routed  !

into tray T13GCCP80 and then tray T13GCCP81. The cable schedule routed the cable into T13GCCP81 and then T13GCCP80 (445/8516-D-17).

RESPONSE To ITEM A.8

1. REASON FOR DEVIATION Reinspection of the routing for cable EG139517 indicated that the ID tags for cable tray sections T13GCCP80 and T13GCCP81 were reversed.
2. CORRECTIVE ACTION T/43 The verification package documentation has heen corrected and DR No.

I-E-CABL-102-DR2 was initiated on January 14, 1986.

3. ACTION TO PREVENT RECURRENCE The deviation was thoroughly discussed with the affected inspector on or about January 10, 1986. The discussion with the inspector was documented.

To provide reasonable assurance that other inspections of this attribute were properly accomplished, a historical review was conducted as part of the Overview Inspection Program and no instances of the subject inspector's error were identified. A historical review of this inspector's work supports the fact that this error is an isolated case, however, the continued implementation of the Overview Inspection Program also includes reinspection of current inspection activities which verifies proper inspections of all attributes.

Action is ongoing to analyze results of the Overview Inspection Program, gather pertinent inspector error rate data from other sources (ie. NRC reinspections, etc.) and to effect required additional formal training of inspectors.

4. DATE OF FULL COMPLIANCE January 14, 1986 for corrective action. Preventive action involves a ongoing program.

. l JUN 17 'E7 8:18 TUGCO COMMUNICATIONS PAGE.24 NOTICE OF DEVIATION ITEMS B.1 and B.2 (445/8615-D-411 B. Section 5.1 of ERC Procedure CPP-001, Revision 1, states, in part, ". . . ,

Each Quality Instruction (QI) shall specify what is to be inspected or I reviewed and the associated accept / reject criteria based on appropriate specification, drawings, codes, procedures, etc. . . " This procedure also indicates with respect to QI format that Section 5.0 of a QI provides comprehensive instructions of what is to be done to fulfill the purpose of the document.

Contrary to the above:

1. The ERC Description Memorandum QA/QC-RT-293 lists Gibbs & Hill (G&H)

Containment Liner Specification 2323-55-14, Revision 4, as the reference for developing QI-031, Revision 0. Paragraph 8.2.2.1.2.b of the above G&H specification states, in part, "The following deviations are acceptable: . . . A 1 1/2 inch gap when the template . . .

foot long curved template) is placed across one or more welded (the 6 seams." This applies to both the cylindrical liner and the dome liner. However, Section 5.1.A.1 of QI-031, Revision 0, states, in part, with respect to surface contour attribute A.I.b, "The following local contour deviation are to be verified: . . . A maximum 1 1/2 inch gap when the six foot long template is placed across the dome weld seams when measuring horizontally or vertically." This applies only to the dome liner and does not include the cylindrical liner measurement requirement of the G&H specification.

2. Section 5.0 in Revision 0 to QI-031 does not provide comprehensive instructions of what is to be done with respect to reinspection of the containment liner. It states, in part, "The following local contour deviations are to be verified: . . . A maximum of 3/4 inch deviation from a 10 foot straight ed the horizontal weld seams.ge placedvalues Deviation in themeasured vertical direction using this between instruction can vary by as much as a factor of two depending on the method used to hold the straight edge against the cylindrical liner.

If the surface is convex, for example, the deviation could be measured with the straight edge touching at either the center of the liner

plate or at one of tlie edges resulting in differing measurements.

Section 5.0 of QI-031, Revision 0, does not clarify this situation (445/8516-D-41).

RESPONSE TO ITEMS B.1 AND B.2

1. REASON FOR DEVIATION I
1. The investigation confirms the stated condition. However, a discussion in September between the population engineer and ins)ectors using QI-031 confirmed that they have used the proper met 1od to measure contour using the template and straight edge on both the cylindrical and the dome liners, as was originally intended.
2. An investigation by the discipline engineer, in which a Level II and III ERC inspector and a NRC inspector participated, confirmed the stated condition.

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JUN 17 '87 8:19 TUGCO COMMUNICATIONS P A G E . P_5 l

RESPONSE TO ITEMS B.1 AND B.2 j IContinued)

2. CORRECTIVE ACTION TAKEN
1. QI-031 was revised and Revision i was issued on January 15, 1986. The l applicable paragraph was revised to assure that both the cylindrical and the dome liners are mentioned.
2. Although inspections to this QI have been performed correctly, in )

order to avoid ambiguity, QI-031 was revised and issued on January 15,  !

1986. The applicable paragraph was revised to prescribe a method for utilizing the 10 foot long straight edge.

3. ACTION TO PREVENT RECURRENCE 1 & 2. A detailed review has been conducted of each ERC Quality Instruction (QI) related to ISAPs VII.b.3 and VII.c. This ,

included a review with the inspectors for clarity of the QI in '

describing how and what is to be inspected and the clarity of accept / reject criteria. Review of QI-031 was completed and Revision 2 was issued on February 21, 1986.

4. DATE OF FULL COMPLIANCE l 1 & 2. Full compliance has been achieved.

JUN 17 '87 8:19 TUGCO COMMUNICATIONS PAGE.26 NOTICE OF DEVIATION ITEM C (445/8516-D-47)

C. Paragraph 5.2.4 of ERC Procedure CPP-009. Revision 1, requires the lead inspector (Level III) and lead discipline engineer to ". . . ensure that reinspection / documentation review results are clear, accurate, and complete."

Contrary to the above, attribute 3.A of the completed checklist for Verification Package No. I-S-CONC-015 was neither accepted nor rejected (i.e., not signed off), and thus actual reinspection for this attribute could not be verified. The checklist was approved and signed by both the leadinspectorandtheleaddisciplineengineer(445/8515-D-47).

RESPONSE TO ITEM C

1. REASON FOR DEVIATION The original inspector and lead inspector investigated and confirmed the above condition. The attribute was inadvertently left blank by the inspector. This omission was not noticed by the lead inspector.
2. [qRRECTIVE ACTION TAKEN The inspector reinspected this attribute and the verification package was revised accordingly on November 14, 1985.
3. ACTION TO PREVENT RECURRENCE As a result of an ERC QA Surveillance which identified similar errors, action was taken by ERC Management, meetings were held with all ERC inspectors and leads to re-emphasize the importance of providing complete and accurate information.

An Overview Inspection Program has been implemented to reinspect a sample of each inspector's work on a continuing basis. Action is ongoing to analyze results of the Overview Inspection Program, gather pertinent inspector error data from other sources (re. NRC reinspections, etc.) and to effect required additional formal training of inspectors.

4. DATE OF FULL COMPLIANCE Corrective action was completed by November 14, 1985. Preventive action involves a ongoing program.

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    • TOTAL,_P_gp h W$ ca
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