TXX-6656, Forwards Response to NRC Request for Addl Info on Issue Specific Action Plan Repts,Including Rev 1 to I.d.2, Guidelines for Administration of QC Inspector Tests & Rev 1 to VII.a.4, Audit Program & Auditor Qualifications
| ML20237K239 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/14/1987 |
| From: | Counsil W, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-6656, NUDOCS 8708190152 | |
| Download: ML20237K239 (13) | |
Text
{{#Wiki_filter:, I J Log # TXX-6656 J --L":l = File #.10010 1 h 5 10068 ) = = q l nlELECTRIC August 14, 1987 ,., g, Executive %ce President U. S. Nuclear Regulatory Commission { Attn: Document Control Desk I Washington, D.C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) DOCKET NOS. 50-445 AND 50-446 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION-ON ISAP RESULTS REPORTS
REFERENCE:
NRC letter from C. I. Grimes to W. G. Counsil-dated June 23, 1987' Gentlemen: This letter is submitted in response. to your request for additional- -{ information and clarification needed by the staff to complete its evaluation of Results Reports for ISAP I d.2, VII.a.4, and VII.4.3. On July 23, 1987, we received an extension in submitting this response until August 14, 1987. The requested information is attached. Very truly yours, &. G. W. G. Counsil i By: D. R. Woodlan ( Supervisor, Docket Licensing JCH/mgt Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) j 870819015;2 870814 p0 i PDR ADOCK 05000445 A PDR 400 North Olive Street LB 81 Dallas, Texas 73201
f a Attachment to TXX-6656 i l August 14, 1987 Page 1 of 12 l A. ISAP I.c.2 (Rev.11. Guidelines for Administration af OC Inspector Test: Reauest A.1.: On page 12 of ISAP I.d.2 it is stated that significant changes were made to the TV Electric QA/QC Review Team procedures and that another review was performed of work already completed by the TV Electric Special Evaluation Team (SET). However, page 9 of this Results Report stated that no specific procedures were developed to implement this ISAP. Further, in response to the ASLB Question #11 (TV Electric Answers of December 18, 1986 to Board's 14 Questions Regarding Action Plan Results Report I.d.2), it is stated that no unexpected difficulties were encountered. Describe in detail these apparent discrepancies.
Response
The initial work conducted by the Special Evaluation Team (SET) was conducted prior to the issuance of Revision 3 to the CPRT Program Plan. i This revision increased the scope of work, primarily in ISAP VII.c, for the QA/QC Review Team. In conjunction with the issuance of Revision 3 of the program plan, the ERC Management Program Plan and associated procedures and instructions (CPPs and QIs) were revised and expanded to cover this increased scope of work. Procedure CPP-023, " Project Procedure for QA/QC Category 1 Programmatic ISAP Instructions / Checklists," was one of the expanded procedures issued. CPP-023 required that the review of procedures, (e.g., the TV Electric QC inspector certification procedures and instructions being evaluated by ISAP I.d.2) be documented utilizing appropriate checklists. Also, departures from 10CFR50, Appendix B requirements were to be documented as QA/QC Program Deviations and Deficiencies. No specific QA/QC Review Team procedures were developed for ISAP I.d.2 because the existing generic procedures developed after the issuance of Revision 3 to the CPRT Program Plan were adequate to cover the work being conducted. j l The initial reviews conducted by the SET were somewhat informally documented. The Review Team Deputy Leader noted during preparation of the Result Report that there was not a clear and complete record identifying departures from Regulatory Guide 1.58 and Appendix B requirements for the procedures reviewed by the SET. In order to provide an adequate record, it was decided that the QA/QC Review Team would re-review the precedures reviewed by SET using the latest QA/QC Review Team requirements including documentation of QA/QC Program Deviations and Deficiencies and their resolutions. The results of these re-reviews were consistent with the I initial SET review results. Because the results of the initial SET reviews and the QA/QC Review Team i re-reviews were consistent, the QA/QC Review Team's assessment is that rio l unexpected difficulties were encountered during implementation of ISAP I.d.2. i l t
Attachment to TXX-6656 l August 14, 1987 Page 2 of 12 Reouest A.2.: On page 26 of ISAP I.d.2 it is stated that one of the generic implications j of ISAP I.d.2 is the possible certification of unqualified-inspectors. This is particularly true since the only historical files reviewed were for electrical inspectors (i.e., files of inspectors no longer at the site). You stated that ISAPs I.d.1 and VII.c are adequate in scope to i address this area. Provide a further explanation of how these ISAPs will l consider the other historical inspectors' qualifications and how or if the effectiveness of those inspectors that have been prope?ly qualified will be assessed. I Responsgi To provide additional confidence in the validity of the documentation being reviewed during implementation of ISAP VII.c., evaluations were conducted of QC inspectors identified as the preparer of the documentation being reviewed. QC inspectors identified during implementation of.ISAP's VII.b.1, VII,b.3, and VII a.8 were also evaluated. These evaluations were conducted in accordance with ISAP I.d.1 methodology. As a result, 268 inspectors (in addition to the 319 current and historical electrical QC l inspectors evaluated under the original ISAP I.d.1 scope) received ISAP l I.d.1 type evaluations. Most of the additional 268 inspectors evaluated i were Brown and Root or TV Electric historical QC inspectors. The total i number evaluated (587) comprised almost 70% of all construction QC l I inspectors employed on the project prior to April 1985. Preliminary results indicate that the evaluation of more QC inspectors is not warranted. The results of these 587 evaluations will be reported in the ISAP I.d.1 Results Report. l Root cause analyses of construction deficiencies, adverse trends, and j unclassified deviations and trends identified by ISAP VII.c and other ISAPs will indicate where inadequate or ineffective inspections I contributed to problems remaining undetected and uncorrected. This in t turn, will provide an indirect toasure of the effectiveness / ineffectiveness of properly qualified inspectors.
Attachment to TXX-6656 August 14, 1987 j Page 3 of 12 l B. ISAP VII.a.4 (Rev.1). Audit Proaram and Auditor Qualifications: Reauest B.1.: The Results Report on ISAP VII.a.4, as well as other Results Reports which the staff received, fails to clearly identify and describe the disposition of the numerous external source issues raised in documents such as those generated by the TRT, and in the reports by the Management Analysis Corporation (MAC), many of which are summarized by the staff in Appendix P of SSER 11 (May 1985). The CPRT Program Plan commits to fully resolve each of the external source issues. Accordingly, a clear identification J should be provided of each of those issues together with their resolution j as they relate to these and the other ISAP Results Reports. If the j Results Reports are not the mechanism TV Electric plans to use to accomplish this commitment, a description of the method should be providad l that will be used to implement this commitment and the schedule for its completion.
Response
Documents (as listed in the CPRT Program Plan) have been reviewed and the external source issues (ESIs) raised in these documents captured. An external source issue matrix identifies the source document, the external source issues, summaries of the issues, and the ISAPs that provide l information related to issue resolution. These matrix entries were considered during the ISAP investigation and, for me.ny (but not all) i issues, a report of the resolution was included in the ISAP. For other i issues, input from more than one ISAP is necessary to resolve the issue. l The Collective Evaluation Report will be the mechanism for the identification and resolution of external source issues. Each issue will be summarized and the resolution or disposition reported in a format that will facilitate review of this CPRT activity by other parties. The Collective Evaluation Report will resolve CPRT commitments related to external source issues and is expected to be issued in October 1987. Reauest B.2: On page 14 of ISAP VII.a.4 it is stated that additional rationale for the selection of vendors that were reviewed is contained in the working files for the ISAP. Clearly identify the " additional rationale" referred to. Resnonse: The rationale for the selection of vendor audit files for review is contained in the ISAP VII.a.4 working files at VII.a.4-78.008 as quoted below: "From vendors id u ified in conjunction with the Levin to Hansel memo, select approximately ten to provide a sample across the disciplines. Also, based on the audit index, tample from what appears to be good coverage and poor coverage based on number and frequency of audits.
Attachment to TXX-6656 August 14, 1987 Page 4 of 12 l If data ar. pears constant, additional reviews are not necessary. ITT Grinnell was added in an attempt to obtain data to support ISAP VII b.2." The following eleven vendors were selected. With the addition of ITT Grinnell, a total of twelve were reviewed. VENDOR PRODUCT AUDIT FRE0VENCY American Air Filter Fan, Coil Units Good Borg-Warner Valves Mixed Conax Thermocouple Poor Fisher Controls Valves Mixed Ingersoll Rand Pumps Poor Pacific Air Products
- Dampers Mixed Posi-Seal International Valves Mixed Power Conversion Battery Chargers Mixed Southwest Fab & Welding Piping Mixed f
Rockbestos Cable Mixed Rosemount Transmitters Poor
- Vendor with known problems:
l As can be seen, mechanical, electrical, and I&C disciplines are l represented. A " mixed" audit frequency refers to a vendor who was audited at least annually for a period, and also had excessive time spans between audits. The Levin to Hansel memo is contained in the working files at VII.a.4-9A.002. Reauest B.3: As stated on pages 24 and 25 of ISAP VII.a.4 the CPRT concluded that the Westinghouse site organization was not involved in safety-related activities, thus they would not be subject to periodic audits by TV Electric. The basis for this conclusion was that the primary function of this group was to provide liaison with other Westinghouse organizations, which agrees with the conclusions of two audits by TV Electric. While this may be generally true, of necessity, some of the Westinghouse site group functions involve activities subject to 10CFR Part 50, Appendix B (e.g., processing documentauon or information pertaining to design, changes, construction or erection). Accordingly, identify the QA programs that control these activities, and the organization responsible for. auditing these activities. Describe how TV Electric satisfies the audit requirements of ANSI N45.2.12.
Attachment to TXX-6656 August 14, 1987 Page 5 of 12 Resoonse: As stated in the Results Report, the Westinghouse site organization's scope of work did not include the categories of. safety-related activities requiring audits per ANSI N45.2.12 - 1973 (e.g., erecting,. installing, inspecting,etc.). However, further investigation has revealed that, during the time period under discussion (1977-1981), the Westinghouse site organization provided support to the Home Office through involvement in the transmittal of Field Change Notices (FCN) and engineering dispositions for Field Deficiency Reports (FDR) to the customer. Therefore, it is j concluded that the Westinghouse site organization did perform activities j subject to 10CFR50 Appendix B, Criterion VI, " Document Control." This activity was performed by Westinghouse personnel in accordance with procedures OPR 210-2(FDR) and OPR 305-4(FCN) in accordance with 1 requirements of the Westinghouse Nuclear Service Division Quality J Assurance Program Plan WCAP 9245. The Westinghouse site organization was. subject to audit by Westinghouse per WCAP 9245, and has been audited six I I times in the period from January 1978 to October 1986. ] For this activity, TUGC0 satisfies the audit requirements of ANSI N45.2.12 by auditing the Westinghouse parent organization for compliance with 10CFR50, Appendix B, Criterion XVIII. Recuest B.4.: On page 28 of ISAP VII.a.4 it is concluded that the failure to perform vendor audits on an annual frequency resulted in no adverse effect on the program because of additional activities implemented by the QA organization to supplement the audit activity. Provide the basis and accuracy of this conclusion in light of known problems with vendor supplied material (e.g., penetration assemblies problems whose root cause is as yet undetermined) and without the results of ISAP VII.a.9 being known. I Based on an evaluation of 29 internal audits conducted in 1983, the CPRT concluded that the audit program coverage during 1983 was adequate. The matrix CPRT developed for this evaluation revealed the audit program addressed the major ongoing site activities (but no statement that all-safety-related activities were audited), that all site organizations were audited, and that all program elements (Appendix B criteria) were addressed (but no statement that all program elements were audited in all site organizations). Provide a more complete basis for the conclusion that program coverage was adequate for 1983 audits. r t
1 Attachment to TXX-6656 August 14, 1987 j Page 6 of 12
Response
4 When the ISAP VII.a.4 Results. Report was prepared, the basis and accuracy j of the statement was as stated in the Results Report. At that time there were no "known problems with vendor supplied material" which were attributed to the failure to perform vendor audits on an annual basis. In other words, no procured hardware problems were known that could have been identified and corrected through audits or other vendor compliance activities. Subsequent to the issue of the ISAP VII.a.4 Results Report, the scope and methodology of ISAP VII.a.9 has been revised to include hardware inspections which may identify problems which might have been identified in an audit program. Information pertinent to the adequacy of the audit program that is gathered during implementation of ISAP VII.a.9 3 and other ISAPs will be evaluated during the collective evaluation process and described in the Collective Evaluation Report. As stated in the Results Report, it was concluded that the 1983 internal audit program addressed the major on-going site activities. No conclusion was drawn as to whether all safety-related activities were audited. The magnitude of the effort to research every record generated during the year to identify every safety-related activity performed was believed to not be meaningful in terms of evaluating the overall adequacy of the audit program. Instead, by focusing on the major, comprehensive activities, it was determined to be unnecessary to identify and evaluate each specific activity. The evaluation of the effectiveness of the QA program elements as determined during the audit of major activities is applicable to discrete activities not specifically audited in 1983. l l It is true that no statement was made that all program elements were audited in all site organizations. This was because it was concluded that not all elements of 10CFR50 Appendix B criteria are applicable to all organizations. The referenced matrix (at working file VII.a.4-78.006) indicates the following: --Audits in " Engineering" (this term was used when it was not easily discernible if the audited organization was TNE or CPPE) addressed parts or all of the criteria except IV, IX, X, XI, XII, XIV, and XVIII. --Audits in CPPE addressed parts or all of the criteria except VIII, IX, X, XI, XII, XIII, XIV, and XVIII. --Audits in TNE addressed parts or all of the criteria except IV, VIII, IX, X, XI, XII, XIII, XIV,.XV, and XVIII. --Audits in B&R QA/QC addressed parts or all of the criteria except I, III, and XII. --Audits in the construction organization addressed parts or all of the criteria except IV, X, XI, XV, XVI, and XVIII.
i Attachment to TXX-6656 August 14, 1987 .Page'7 of 12 ~! It is concluded that all applicable criteria were addressed in all appropriate organizations, with the exception of Criterion 1,= " Organization," in the B&R QA/QC organization. This one exception is not considered critical because the B&R QA/QC site organization functioned under the oversight of the TV Electric site QC supervisor. Therefore, l the B&R organization and its performance were under constant scrutiny by TV Electric. In addition, if significant problems occurred in the B&R QA/QC organization, they would be reflected in the performance of activities for which they were responsible, e.g., inspection of ASME code activities. Audits of such activities would likely identify significant organizational problems. Therefore, the. conclusion in the Results Report that "the audit program coverage of the Design / Construction phase of CPSES during 1983 was adequate" remains valid. l Reauest 8.5.: I l On page 29 of ISAP VII.a.4 it is concluded that the lack of a formalized methodology for internal audit planning and scheduling-resulted in no adverse effect on the audit program because it was established that audit planning was accomplished and audit schedules were prepared to implement the audit program. Explain why the audit program did not detect and correct those items, for example, which resulted in the need for the QA/QC l-ISAPs. The concern identified on page 0-234 of SSER 11 (May 1985) involved personnel performing audits from organizations other than the audit group, particularly groups outside the QA organization. Your assessment, as 1 stated on page 31 of ISAP VII.a.4, focused only on quality engineers or surveillance personnel participating in audits._ Provide your assessment of the independence / objectivity of personnel used on audit teams from all organizations and groups. Further, on page 0-211 of SSER 11 another instance was identified where an individual was inspecting his own work.. l Provide your assessment of this practice, including how widespread it was. I
Response
As stated in the ISAP VII.a.4 Results Report (page 26), the TU Electric-written program has always required that audit planning and scheduling activities be performed, and that audit schedules had been prepared. The fact that an audit program might not " detect and correct" specific items is a function of the preparation for, and performance of, a particular audit as well as corrective action identified and implemented by the audited organization, rather than a lack of a procedure to define the specific methodology of audit planning. I k
l l Attachment to TXX-6656 August 14, 1987 Page 8 of 12 This position is supported by Section 6.0, " Conclusions", of the Results Report which states on page 50 that the failure to identify and cause l corrective action for the two QA/QC ISAP topics mentioned was "due primarily to the practice of auditing to existing procedures while not performing verification of the adequacy of existing procedures to implement program requirements." It is further concluded on page 51 that "due to the lack of a procedure hierarchy which would provide a firm basis for the development of implementing procedures, the effectiveness of the audit program to determine the adequacy of the construction QA program was less than desirable." It is for these reasons that the referenced statement on page 29 of the Results Report is believed to be valid. In reference to page 0-234 of SSER 11, the Results Report focused on the area represented by the example in the SSER and the statement following it which indicated further TRT concern in this particular area. During the investigative phase of ISAP VII.a.4, no audit team personnel were i identified who were from outside the QA organization. Additionally, in-depth reviews, subsequent to the issue of the Results Report, identified no personnel from outside the QA organization who participated as an audit team member in any area where they had performed activities or held responsibility. In reference to pages 0-209 through 0-211 of SSER 11, these allegations (AQ-6 and AQ-126) do not pertain to the audit program and would not have been addressed in ISAP VII.a.4. The subject of these allegations is being l addressed in the discussion of SSER 11, Appendix P in the Collective Evaluation Program. Reauest B.6,: In Section 5.3, " Evaluation of Findings" on page 40 of ISAP VII.a.4, several recommendations are made and areas identified for program enhancement. Provide TU Electric's disposition of each of those findings.
Response
All items in Section 5.3 of the Results Report that require action have been entered into the CPRT Commitment Tracking System to provide visibility to TV Electric management. In accordance with the CPRT Program Plan, follow-up and closecut of these items are the responsibility of TU Electric and are not subject to tracking by the QA/QC Review Team. l Recommendations of Section 5.3 have all been evaluated by TV Electric I personnel. The appropriate procedures and programs were revised and implemented as a result of that evaluation. Supporting documentation is available on site for your inspectors to review. l l
Attachment to TXX-6656 August 14, 1987 Page 9 of 12 C. ISAP VII.a.8 (Rev.11. Fuel Pool Liner Documentation: I Reauest C.1.: As stated on page 5 of ISAP VII.a.8, the refueling cavity was not included in this ISAP. The refueling cavity is an extension of the area considered. Therefore, discuss the basis for its exclusion.
Response
The CPRT Program Plan was developed and implemented to investigate the adequacy of construction of safety-related items. The Unit I and 2 Reactor Building refueling cavities were downgraded to Non-Nuclear Safety Related (NNS) by revision 4 of Specification 2323-SS 18; therefore they were not included in the population from which the Action Plan samples were drawn. Additionally, as stated in the Results Report, the Review Team believed that inclusion of these areas would not provide information different from that gained by review of the safety-related liners. Reauest C.2.: In Section 4.4 of ISAP VII.a.8 (page 7) it is stated that matrices and data sheets were developed as part of this ISAP. In the TV Electric response to the " Opening Request" in " Answers to Board's 14 Questions Regarding Action Plan Results Report VII.a.8", dated January 21, 1987, it is stated that no checklists were generated for this ISAP. Provide the basis for not identifying the above ISAP sheets and explain the apparent l discrepancy between the ISAP and the response to the Board.
Response
In the context of QA/QC, checklist is a list of items / areas which are to be looked at, and implies that an evaluation of adequacy / acceptability be made. The matrices and data sheets developed as part of this Action Plan evaluation provided a means to collect, summarize and display data. Accordingly, they were not checklists in the sense of the ASLB question. Reauest C.3.: On page 12 of ISAP VII.a.8 it is stated that the Welder Qualification Matrix (WQM) was used to verify the qualification of welders. TV Electric performed a spotcheck to confirm the accuracy of the WQM. Since the WQM is not a document or record subject to 10CFR Part 50, Appendix B, further description should be provided on how the accuracy of the WQM is assured. In addition, provide the basis for reviewing only 160 weekly WQMs when the time of interest covered approximately 600 weeks.
Attachment to TXX-6656 August 14, 1987 Page 10 of 12
Response
The Welder Qualification Matrix (WQM) is an administrative tool used by B&R to communicate the qualification status of welders to supervision for i use in making work assignments. The WQM is based upon welder performance qualification records and upon weld rod issue records. It identifies welders who have qualifieo and maintained their qualification by use, as defined by the ASME Code. The accuracy of the.WQM was confirmed by i verifying, for a sample of welders, that weld rod issue records and 4 initial qualification forms through the week selected, supported the entries in the WQM. This covered time spans from about a year to a year j and a half. As stated in the Results Report, the qualification status of the fifty (50) welders who performed welding recorded on the sampled travelers was i verified. The welding dates recorded on the travelers selected as sample items represented approximately one hundred and sixty (160) weeks. Additionally, the Hartford Steam Boiler ANI was interviewed concerning the WQM. He stated that the site ANIS routinely monitor the WQM and have found no problems. The ANI Supervisor, from the Houston HSB office, also reviews welder qualification records during his scheduled site inspections. No problems with the WQM accuracy have been noted. This information was sufficient to establish the validity of the WQM and ) examination of additional data was determined to not be required. ] Reauest C.4.: The Gibbs & Hill Specification 2323-SS-18 specifies gas tungsten arc welding with deviations approved by the Architect-Engineer (AE). On page l 12 of ISAP VII.a.8 it is stated that welding procedures WPS 88031 and l 88032 for shielded metal arc welding (SMAW) were used also. Provide further information concerning the approval for use of the SMAW. Resoonse: Specification 2323-SS-18, paragraph 6.4, revisions 1, 2 and 3 state: "All welds shall be made by the inert-gas-shielded arc welding process unless otherwise approved by the Engineer." Welding procedure WPS 88031 was approved for welder performance qualification by G&H letter GHF-713 dated 06-28-76. Subsequent approval for production use on various non-seal weld configurations was made through ICNs #1, 5, 6, 7 and 8. Welding procedure WPS 88032 was approved for use by G&H letter GHF-1709 dated 06-10-77. Specification 2323-SS-18, paragraph 6.4 was char 49ed by revision 4 to allow the use of the shielded metal arc welding process for embedment and leak chase channel welding. This change is consistent with the earlier approvals for use of WPS 88031 and 88032. The Action Plan review of the traveler sample items found no cases in which these shielded metal arc welding procedures were used for seal welds between liner plates.
l l s 1 Attachment to TXX-6656 August 14, 1987 Page 11 of 12 I Reauest C.5 : l 2 1 On page 16 of ISAP VII.a.8 it is stated that records included in the TU J Electric review covered the time from January 1978 through April 1983. Based on dates elsewhere in this Results Report, it appears the activities l of interest ranged beyond these limits. Provide further information concerning the time boundaries of the total populath"), the time boundaries of the samples selected, and the actual times of construction and inspection. Justify any anomalies in ISAP VII.a.8 coverage which these various time periods indicate. I
Response
l l l l As stated in paragraph 4.1.2 of the VII.a.8 Results Report, sample items ) for this Action Plan review were randomly selected from the total ) population. The random sampling process would be expected to select j l sample items representative of the total time span of fabrication and l l erection. Because the population included the entire time period of the I work, the samples selected could also possibly have included the entire I time period. The travelers selected as sample items covered the time span from January 1978 through April 1983. This time span coincides with the majority of fabrication ant' erection activities. Hcwever, activities such as procedure approval occurred prior to January 1978; and activities such asrepairmayhayocCurredafterApril1983. Reauest C.6.: In Section 5.8 of ISAP VII.a.8 (page 20) it is stated that the liner construction prograr was unique and, therefore, the results would not be applicable to other site activities. Identify and describe those attributes that make this area of construction and inspection unique and how both construction and inspection in this area are so unique as to not apply elsewhere. 1
Response
The Results Report states that the established TU Electric AWS or the B&R ASME control programs weQ not implemented for the construction of the i fuel pool liners since the liners were not governed by these established codes; however, the prcoram implemented for liner construction contained some elements of each of those established programs. For this reason, the l fuel pool liner construction program was considered to be unique. l Although specific work activities such as welding or liquid penetrant examination were not in themselves unique, the methods for controlling and l recording the results of these activities were unique to the fuel pool liner fabrication and installation. Since other site activities were controlled by the TV E?ectric AWS program or the B&R ASME program, the QA/QC Review Team's as:;essmnt is that similar documentation problems l would not necessarily exi2t in those areas. j i l i
i 4 : Attachment to TXX-6655 August 14, 1987 Page 12.of 12 Reauest C.7.: As stated on page 21 of ISAP VII.a.8 corrective action is recommended to be taken by the Engineer, TV Electric Nuclear Engineering Department (TNE). Describe the action that TNE has taken or will take, the schedule for completion, and who will assure its proper conduct. Resoonse: As stated in paragraph 7.0 of the Results Report, the action recommended is not mandatory. However, the TU Electric Engineering Department has_ J l formally assigned responsibility for action to SWEC. Any actions to be 4 l-taken and the schedule for completion have not been determined at this l time. Proner conduct of action will be assured by TU Electric via the Corrective Action Program as supported by the QA Audit Program. Reauest C.8.: On page 23 of ISAP VII.a.8 it is stated that there is a substantial amount of information available that the liner system was properly constructed and inspected. Identify this information and describe.the basis for this conclusion.
Response
Although documentation irregularities were found in most of the sixty (60) sample documentation packages, they were primarily inconsequential paperwork problems. The documentation problems which were significant occurred in ten (10) traveler packages. These problems were missing Weld l Filler Material Logs (WFML) and lack of signoff.of hold points for vacuum box leak test or liquid penetrant examination. In the case of missing I l WFMLs, only six (6) were missing out of a total of approximately two hundred and fifty (2bO) listed on the travelers. All WFMLs reviewed reflected the issuance of acceptable filler metal and the use of acceptable procedures. It is considered unlikely that the six (6) missing WFMLs would indicate otherwise. In the case of lack of signoff of vacuum box leak test or liquid penetrant examination, which involved seven (7) welds, there were a significant number of other inspection signoffs (including completion of weld inspection ) to indicate a high probability that these hold points had been accomplished. E}}