ML20141P077

Response Team Activities Insp Repts 50-445/85-14 & 50-446/85-11 on 851001-31.Violations Noted: Drawings Revised W/O Required Review & Approval Actions & Insp Repts Signed by Noncertified Electrical Inspector

ML20141P077
Person / Time
Site:	Comanche Peak
Issue date:	03/03/1986
From:	Barnes I, Ellershaw L, Hale C, Jhnson A, Andrea Johnson, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20141P047	List: ML20141P046 ML20141P053 ML20141P054 ML20141P063 ML20141P072 ML20141P077 ML20141P083
References
50-445-85-14-02, 50-445-85-14-2, 50-446-85-11, NUDOCS 8603180523
Download: ML20141P077 (43)

See also: IR 05000446/1985011

Text

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APPENDIX E

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c- - U. S. NUCLEAR REGULATORY COMMISSION

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,r REGION IV

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COMANCHE PEAK RESPONSE TEAM AC1IVITIES INSPECTION REPORT ,

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NRC Inspection' Report? 50-445/85-14 Permit: CPPR-126

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,' s  : 50-446/85-11 CPPR-127

, Docket's: 50-445 Category: A2

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50-446' ,

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!~ . Applicant: -Texas Utilities Electric Company v

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. Skyway Tower

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400 North Olive ~ Street

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Lock Box 81

[' Dallas, Texas 75201 ,

I Facility Name: Comanche Peak Steam' Electric Station (CPSES), Units 1 and 2

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l Inspection At: Glen Rose, Texas

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l Inspection Condu t d: October 1-31, 1985

Inspectors: b [ c fN

L. E. Ellershaw, Reactor Inspector, Region IV 'DaYe

CPSES Group

(paragraphs 1, 2.a, 3, 6.b, 6.e-6.g, 6.j, 7.e-7.u)

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I , Reactor Inspector, Region IV CPSES

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(paragraphs 1, 2.b, 4, 5, 6.c-6.d, 6.h-6.1)

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R. Johnson, Reactor Inspector, Region IV

&. $/7/8G,

Date

3 CPSES Group

(paragraphs 1, 6.a, 7.s-7.e)

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. Consultants: EG&G - R. Bonnenberg, J. Dale, L. Jones, A. Maughan, W. Richins,

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R.-VanderBeek

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an____ - ' * * _.__________A_ __ i______ _ _ -_ _ _ . _ . . _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ . _ _ _ _ _ _ _ _________________._____.;

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Parameter - J. Birmingham, D. Brown, J. Gibson, K. Graham,

D. Jew,

Reviewed By: 8w -

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I. Barnes, Group Leader, Region IV CPSES Group Date

Approved: l' f h F

T. F. Westerman, Chief, Region IV CPSES Group

3h/%

Date /

Inspection Summary

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Inspection Conducted: October 1-31, 1985 (Report 50-445/85-14; 50-446/85-11)

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, Areas Inspected: Nonroutine, unannounced inspection of applicant actions on .

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previous inspection findings, followup on alleged contractor improprieties,

Comanche Peak Response Team (CPRT) procedures and instructions, and CPRT issue 1

- specific action plans (ISAPs). The inspection involved 2363 inspector hours

onsite by 5 NRC inspectors and 11 consultants. A summary of NRR and IE audit

activities is provided in paragraph 4.  ;

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Results: Within the four areas inspected, two violations (revision of drawings

without required review and approval actions, paragraph 2.a; signing of

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inspection reports by a noncertified electrical inspector, paragraph 8.c) and

four deviation (ERC equipment / service requests not controlled as committed,

paragraph 6.a; inadequate ERC document review and procedure criteria with *

. respect to nonrecreatable and inaccessible inspection attributes, paragraphs

8.c and 8.e; failure of ERC document reviewers to detect a lapsed electrical

inspector certification and to record required information in a verification

i package, paragraph 8.c; and in>pection attributes being attested to as

acceptable by ERC inspectors which were found by subsequent NRC inspection to

be unacceptable, paragraphs 8.e, 8.1, and 8.u) were identified.

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L DETAILS

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1. ,* Persons Contacted ,

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~ ~D.: L Andrews, TUSI Director of Corporate Security

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J. Arros, TERA Civil / Structural Issue Coordinator ' - -

C. I..Browne, Project Manager, R. L.' Cloud & Associates,.Inc.

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^R. E. Camp,' Assistant Project General Manager, Unit 1 (Impe11

scorp.) -

, J..Finneran, TUGC0 Lead Pipe Support Engineer ,

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• S. M. Franks, Special Projects and Technical Support Lead (Impe11

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. Corp.)

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• J. B. George, TUGC0 Vice President, Plant General Manager

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• P. E. Halstead, TUGC0 Site QC Manager

J. L. Hansel, ERC QA/QC Review Team Leader _ .

C. K. Moehlm6n, TUGC0 Project Mechanical Engineer

• C. Killough,' TUGC0 Supervisor, Operations Quality .

M. Obert,.ERC TRT Issue Coordinator

A. Patterson, ERC Engineering Supervisor

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C. Spinks, ERC Inspection Supervisor

• i. G. Tyler, TUGC0 CPRT Program Director

• C. H. Welch, TUGC0 QC Services-Supervisor

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R. Werner, Manager,. Safeteam  :

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• P. B. Stevens, TUGC0 Project Electrical Engineer

G. Benfer, Bahnson Services Co. Site QA Manager ,

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D. W. Snow, Brown & Root (B&R) QA/QC Coordinator

T. Wright, TUGC0 civil Engineer

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• G. W. Ross, ERC Onsite QA Representative

J. Adam, ERC Supervisor, Safety. Significance Evaluation Group

D. M.. Kim, Principal Mechanical Engineer, Gibbs & Hill (G&H) l

T. Brandt, TUGC0 Quality Engineering Supervisor

J. R Honekamp, TRT Issues Manager, TERA ,

P. Turi, TERA Issue Coordinator i

G. Purdy, B&R QA Manager '

J. E. Young, ERC Issue Coordinator

J. R. Gelzer, ERC Issue Coordinator

S. L. Crawford, ERC Issue Coordinator - ,

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P. Thomas,.ERC Supervisor, Inspection Group Services  ;

D. Alexander, ERC Supervisor, Herdware Issues

J. P. Amoroso, ERC Supervisor, Eardware Collective Evaluation

R. Melton, TERA Documentation Coordinator *

J. Ma11anda, CPRT Electrical Review Team Leader *

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• Denntes those persons who attended the exit interview.

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The NRC inspectors also contacted other CPRT and appitcant employees l

during this inspection period.

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2. Applicant Actions on Frevious Inspection Findings

a. (0 pen) Open Item (445/3511-0-04): This item remains open pending the

review and assessmant of the dispositions relating to the 12

, deviatir.g skewed welus in NF supports.

Further review with respect to the status of this item has resulted

in the NRC's identification of a violation.

During ERC's reinspection of skewed welds in Unit 1, unde. size

conditions were identified and documented on B&R nonconformance

reports (NCRs) as early as June 1985. CPSES Station Administration

Manual Procedure No. STA-405 requires that all documented

nonconformances, in which "use-as-is" dispositions are recommended,

be forwarded to TUGC0 Operations Results Engineering Group for review

to determine if as-built documentation changes are needed. Further,

CPSES Nuclear Operations Engineering Manual Instruction No. N0E-201-5

requires that proposed drawing changes be submitted to Operations for

review, approval, and authorization to distribute the revised

drewing.

The NCRc associated with the undersize skewed welds are identified as

XI-2, -3, -4, -5, -6, -7, -8, -10 and -11. The applicable pipe

support drawings were resised by TUGC0 Nuclear Engineering (TNE) to

reflect the undersize weld conditions. Recalculations were performed

to support the use of the welds without rework or repairs. While the

NCRs were not formally dispositioned, this action, in effect,

provided a "use-as-is" disposition. However, TUGC0 Operations did

not review and approve the drawing revisions. In fact, in most cases

TUGC0 Operations did not initiate their own NCR to address these

conditions until after INE had' revised and distributed the drawings.

As of the end of this report period, TUGC0 Operations NCRs have not

been dispositioned. The NRC inspector was informed by TUGC0

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Operations personnel that their review has found a number of

mathematical errors in the TNE recalculations, thus precluding a

dispositioning of the TUGC0 NCRs.

! The failure of TNE to acquire TUGC0 Operations review and approval

prior to initiating drawing revisions is a violation

(445/8514-V-03). ,

b. (Closed) Open Item (445/8513-0-06): Pecvisions for familiarizing QC

inspectors with changes in QC inspection procedures. Details on this

subject are contained in paragraph 7.d of this appendix.

3. Followup On Alleged Contractor Improprieties

The NRC inspector performed a followup inspection with respect to the

identification by a local newspaper of alleged contractor improprieties.

The inspection was_ performed to ascertain whether the alleged  ;

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improprictles, if substantiated, could adversely affect safety-related

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, components and systems. NRC review of this subject revealed that the

. alleged improprieties, which consisted of eight specific items, had been

reviewed by the TUGC0 Safeteam and by the TUSI Director of Coroorate

Security. NRC examination of the items, certain of which were

substantiated, resulted in a determination that there was no instance

whers any substantiated item had any impact with respect to safety-related

components or systems.

The NRC considers this item to be closed. ,

. 4. NRR and IE Audit / Inspection Activities

4. NRR; A site inspection was performed during October 10-11, 1985,

pertaining to civil / structural issues. Audits were performed on

October 25, 1985, at Ebasco and Stcne and Webster, New York,

pertaining, respectively, to cable tray / conduit supports and small

bore piping review. A site audit was performed of homogeneity of

construction processes during October 9-10, 16-18, and 28-31, 1985.

b. IE: An inspection of Design Adequacy Review was initiated at TERA.

Bethesda, Maryland, during October 28 through Nover.ber 4,1985. A

site inspection of QA program procedures was performed on

October 20-24, 1985.

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Copies of reports for these activities will be placed in the Public

Document Room upon completion.

5. CPRT Procedures and Instructions

a. Implementaticn of ERC Procedures and Instructions

(1) Audit of_CPP-012 (QA/QC Interface with Constructor /TUGCO)

The TUGC0 interface consists of three systems used to request

equipment or services, copies of documents, or technical

information. Each is handled by a differer,t process, as defined

in CPP-012.

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(a) Written requests for equipment and services are used by the

QA/QC inspectors to recuest from TUGC0 or B&R any equipment ,

or services needed to perform an inspection. These  ;

requests are included in the completed inspection package. -

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An NRC inspection of CPP-012 implementation showed that the

requests for equipment and services were being processed in

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accordance with CPP-012 requirements, with the exception

that the QA/QC Records Administrator was not controlling

these requests as required by Section 4.4.6 of the

procedure. No logs or files were maintained by +.he QA/QC

Records Administrator. This item is an NRC deviation

(445/8514-D-01). During this inspection, the NRC inspector

concluded from information provided by ERC personnel that a

log of requests was not being naintained by the QA/QC

Inspection Supervisor, as required by Section 5.1.3 of

CPP-012. Subsequent to this report period, the NRC was

inforn:ed by ERC management that this understanding was

incorrect and that the required log was, in fact, being

maintained in accordance with CPP-012 requirements.

Followup inspection confirmed that the ERC clanagenent

information was correct. It was ascertained, however,

during this followup inspection that verification package

numbers were being used to identify requests in the log.

This practice permits more than one request to have the

same identification number and is ccntrary to procedural

requirements for use of unique identification numbers.

TUGC0 has been requested by the transmittal letter for this

inspection report to include this subject in their response

to deviation 445/8514-D-01.

l (b) Document requests are used to request copies of TUGC0 or

Cid documents required by the ERC inspectors. Section 5.2.2

of CPP-012 requires that the QA/QC issue coordinators

maintain a file of these requests. The files of two issue

coordinators were inspected by the NRC, and found to be

satisfactory.

No NRC deviations were identified.

(c) Technical information requests are prepared by a member of

the QA/QC Review Team when a request for clarification or

additional information is required. These, after

supervisory approval, are sent to the responsible TUGC0

liaison engineer by the QA/QC Records Administrator, who

also log and files the requests. The logged item is

closed and the request filed when the information arrives

from the TUGC0 liaison er.gineer. Two specific requests

were traced t;y the HRC inspector through the Construction

Sampling Reinspection Engineering Group and Recoros

Administration, and found to have been satisfactorily

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processed and routed.

No hRC deviations were identified.

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(2) CPP-018(QA/QC Interface with the Design Adequacy ProgramJ

An NRC inspection confirmed that documents transmitted from ERC ,

. to TERA for infermation only were transmitted by the QA/QC

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Records' Administrator. Documents requiring feedback from TERA

are logged and transmitted by the ERC Hardvare Isay s

Supervisor.

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The TERA Design Adequacy Program Interface Coordinator receives -

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the ERC domments, distributes them and files one copy. Items '

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requiring feedback to ERC are logged in and the date of reply is.

also logged. .The HRC inspector selected four documsats from the .

ERC log and was able to satisfactorily trace them through the

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ERC and TERA logging and filing systems.

No NRC deviat, ions ~were identifled.

- (3).CPP-010(PreparationofDeviationRNports)andCPP-016'(Safety

Significance Evaluations of Deviation Reports)

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' Deviation Reports (DRs) are generated during thekardware and

documentation inspection process. These DRs are' assessed <for

validity then forwarded for further processing to the Safety- '

Significance Evaluation Group (SSEG) and'TUGCO.

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1he NRC inspector confirmed that the process,(which is described

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'in CPP.010 and CPP-016, is being'followed. A sample of twenty

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,0Rs was' selected from the SSEG tracking systenc ~ Each OR was

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' verified to be correctly processed and documented by checking

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each'for: (a) signatures of' originator, first reviewer, and  ;

second reviewer; (b) transmission of the DR to MUGC0 and SSEG,

(c) transmission cf the DR to the proper distribution;

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(d) filing of the DR in the verification package; and' '

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, (e) onfirmation from TUGC0 or B&R that they had assigned an NCR

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- nut.oer to the DR. ; Revision 3 to CPP-010, which was released on

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<' October 11, 1985, incorporates provisions'.for revision,.

cancellation, or; invalidation of a DR.

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No NRC. deviations were identified.

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(4) CPP-020 (Out-of-Scope Observations) '

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, apparent out-of-scope observation %by three part memorandum to '

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TUGCO. In the NRC inspection cf this subject, it was' determined

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that the ERC Supervisor, Hardware CollecWve Evaluation,

assigned a serial number on receipt-of the three part memorandum

and sent two of the copies to TUGCO. _The remaining copy is-

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filed and logged, with identification made of the record

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receiving date, date sent to TUGCO, and date of TUGC0 feedback.

Six memoraida were reviewed by the NRC inspector to verify

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implementat, ion of this process.

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No NRC' deviations were identified.  !

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(5) Inspection of ERC-QA-15 (Performance of Project Surveillance),

ER-QA-18 (Administration of Quality Assurance Auditina), and

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ERC-QA-20 (Conduct of Programmatic Audits)

. -The ERC Project Assurance Manager was contacted in an NRC -

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~ Jinspection of these procedures. The following documents were '

. produced: (a) surveillance plan for QA/QC Review Team ^ dated ,

Septeater 14,.1985; (b) surveillance status report dated

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October 21, 1985; and (c) a' surveillance schedule. -

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The Project Assurance Manager maintains an active file and

.1 status log of surveillance reports from the planning stage until '

M tne recommendations are implemented. The' surveillance reports  ;

are distributed to the corporate' office, to the QA/QC Review-

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Team Leader-(RTL), the Hardware Issues Supervisor, and the

j organization being surveyed. The reports are maintained as

open items until'all recommendations are implemented. At that

time, the report files are closed and transmitted to the Records -

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Ada;inistrator.

Ttn NRC inspector reviewed four surveillance reports of which

three were closed (no deficient items) and one was still open

with one deficiency being processed. Each report file contained .

a three part memo to the QA/QC RTL, a surveillance checklist ,

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report, and K surveillance checklist.

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No NRC deviations were identified.  ;

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The NRC reviewed the first quarterly corporate audit of the CPRT

activities. The audit was performed September 23 through 26,

1985, and the report was issued October 15, 1985. This

corpcrate audit identifisd one deficiency. A response to the

audit was issued on October 21,.1985, providing -

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corrective / preventive actions. The second quarterly audit is '

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being planned at this time, but a specific date has not been

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No NRC deviations were identified.

b. TERA Procedures and Instructions

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TERA has issued 16 of the 19 planned design adequacy procedures

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(0APs). Review of these procedures indicates'that six apply, in

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[ jd N . tw6cleorpart,toi.heilShPsdefininhTERAonsiteactivity .I. L

'; ' (civil-structural,' mechanical, and silscellaneous); :These ?.re DAP-2,

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J" Documentation and Tracking of' Issues &nd Discrepancies"; DAP-14,

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f, f e "DesignLAdequacy Program ~ Records"; DAP-15, " Training and

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Qualification"; DAP-16,." Audits"; DAP-17, " Corrective Actions"; and

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'DAP-19, " Processing and Review.of Information'Between Quality of

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. Constructions.QA/QC Adequacy Program and Design; Adequacy Program."'

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A, DAP-14'and DAP-15 were. audited by the NRC inspector'and found to

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comply with,the applicable CPRT Policies and Guidelines.

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The NRC has inspected the implementation ,in this area and the results

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of implementation:of UAP-2 is reported in NRC Inspection Report

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.No. 50-445/85-13; 50-446/85-09.

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<  % TDAP-16 and.DAP-17'are applicable to the onsite TERA effort; however,:

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ithese~ procedures are implemented by offsite personnel' reporting to

, . .the Design Adequacy Program Quality' Assurance Manager. 'This offsite

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TERA'activityJis being inspected. and reported by the NRC Office of

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. Inspection'and Enforcement. ~

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1. . DAP-19 applies to the information: interfaces between the Design

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Adequacy Program and ERC Qual _ity of Construction and QA/QC Adequacy i

', Program groups. This DAP was audited by the NRC inspector in

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,', . il conjunction with the implementation audit oftERC-Procedure CPP-018,

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3. . as; described in paragraph 5.a.(5)'above.

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1 'c. Implementation of CPRT Policies and Guidelines

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..(1). Electrical Issues: .The electrical issues in the ISAPs are the

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(.a 1,., 0 responsibility of'one RTL. The CPRT Policies and Guidelines

Mr,,4 <;/, .h establish the methods for accomplishing'these tasks.

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'1 he T purpose _' o f the NRC inspection pas to determine if the 1-

.gprocessi'ng of the electrical issues complied with,the

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N ' rf h . ll , l* - requirements set by the CPRT Policies and Guidelines. The,

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inspection covered.four of the guidelines; i.e., (a)' central and

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- working' files, (b)~ safety significance evaluations :(SSEc),

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"t f(c). developing campling plans and random samples for TRT, issues, ~

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3 . #and-(d) policy on testing and inspection personnel used'in third <

'? perty verification activities. This report completes the NRC's '

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l _. .; initial inspection'of programmatic implementations in the area of' ~

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.<u -h ,. electrical' issues;, ~

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(a) Working Files: ,The working files system and subject matter

breakdown being used is as described in the CPRT

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-guidelines. A file index_is available for each ISAP which

j defines the contents of each file folder. A computer based

O data system is being established for these files. Two'

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files were che'ck'd

e for compliance with the CPRT Policies

and Guidelines.

. No NRC deviations were identified.

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(b) SSE: -The NRC inspector reviewed the. processing of ISAP

No. I b.1 that resulted in one item which will require a

SSE. 'This'SSE'will be. included in the review process for

all-SSEs generated by the CPRT e

No NRC deviations were identified.

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(c) ' Sampling Plan: The sampling plan used on ISAP No. I.a.1

T- was reviewed by the NRC inspector. It complied with the

guidelines and was well; documented. Inspection confirmed

that the information on the random sampling selection was

turned over to ERC, who prepared the inspection packages,

performed the inspections, wrote inspection, reports (irs)

for satisfactory and unsatisfactory conditions, and after

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checking and signoff by two levels of supervision transmitted

the irs to the electrical issues RTL.

.The RTL sent unsatisfactory irs to TUGCO, who evaluated the

irs and sent a memorandum back detailing the disposition of

each IR. NCRs were written by TUGC0 on those where

discrepancies existed. Memoranda were sent explaining why

each of the remainder were not considered as discrepancies.

The NRC inspector also reviewed implementation of the

random sampling system used for ISAP Nos. I.a.2 and I.a.3.

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No NRC deviations were identified.

-(d) Personnel Requirements: Qualification requirements for

RTLs and issue coordinators are defined in Section VII of

.the CPRT Program Plan, "CPRT Objectivity Guidance." The ,

primary requirements are: (1) experience and knowledge in '

the review subject matter, (ii) experience in managing 1

technical projects and reviews, and (iii) integrity and

objectivity based on lack of previous involvement in the

CPSES project activities.

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- The resumes and signed objectivity statements for the

principal individuals involved in the electrical ~ issues

were: reviewed.

No NRC deviations were identified.

(2)-Testing' Issues: The purpose of the NRC inspection was to

determine if the disposition of testing concerns complied with

the CPRT, Policies and Guidelines. The four guidelines discussed

"

in paragraph 5.c.(1) above were used to perform this inspection.

This report; completes the NRC's initial inspection of

programmatic implementation in this area.

~

(a) Working Files: The file system and subject matter

breakdown in,use were reviewed. A file index was available

for each ISAP which defined the contents of the file

,.

folder. The file index was checked against the contents of

l the file for these files.

No NRC deviations were identified.

(b) SSE: One DR has been written and an SSE completed. The

NRC inspector reviewed the processing of this DR.

,

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No NRC deviation: were identified.

(c) Sampling Plan: The sampling plan described in the program

plan was not found to be feasible,.so an alternate plan was

~ developed. This revised plan was described in an appendix-

to the results report. This pract1ce is permitted by

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Appendix D of the CPRT Program Plan.

No-NRC deviations were identified during a review of the

,,

original and revised sampling plans.

(d) Personnel Requirements: The resumes and signed objectivity

statements for the RTL and each of the three issue

,

coordinators were reviewed. ,

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No additional NRC deviations to that noted in NRC

Inspection Report No. 50-445/85-11, 50-446/AS-06 were

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identified.

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6. CPRT ISAPs (Excluding ISAP No. VII.c)

a. Inspection Reports on Butt Splices (ISAP No. I.a.2) and Butt Splice

Qualification (ISAP No. I.a.3)

Status of CPRT Activity

Phase II of ISAP No. I.a.2 has been completed with the following

findings:

(1) No undocumented butt splices were identified during the

,

inspection of 38 cabinets which were supposed to be free of

splices;

(2) A total of 603 butt splices were identified during the

inspection of 26 cabinets and 25 motor control centers, which

from documentation were supposed to contain 648 splices. This

difference resulted because 149 of the documented splices were

not installed, but 104 undocumented splices were discovered;

(3) A total of 168 of the above 603 butt splices were found to be

unsatisfactory, either by physical inspection or as a result of

being undocumented;

(4) A total of 80 unsatisfactory butt splices were removed for

testing and replaced; and

'

(5) A review was performed of 341 irs which were applicable to 286

butt spliced cables. This review identified deficiencies in 294

irs; e.g., failure to identify which conductors were spliced,

and after the fact verification of a splice rather than the

required witness. In addition to finding some unacceptable

splices during the Phase II inspections, some splices documented

in records were found to not be installed. TUGC0 submitted a

report in accordance with 10 CFR Part 50.55(e) dated

September 26, 1985, concerning the identified deficiencies. An

interim Corrective Action Report, CAR-050, has been issued.

Status of NRC Inspection Activity

The NRC inspector is continuing to review CPRT ISAP Nos.l.a.2,

Revision 3;-I.a.3, Revision 3; and CPRT Quality Instruction (QI)

QI-002, Revision 4.

"

No NRC violations or deviations were identified.

b. Electrical Conduit Supports (ISAP No. I.c)

Status of CPRT Activity

TUGC0 has completed an engineering cher:k of as-built drawings for 257

1 1/2-inch and 2-inch conduit runs in the combined random and

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- engineered' samples; i.e., 126 random and 131 engineered. These-

'- drawings have been transmitted to TERA for third party review and to

G&H for seismic analysis. Seismic analysis has been completed for

- . all runs in the random sample and for 128 runs in the engineered

! sample. Fifteen conduit runs have been identified, to date, as

' c-

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'having the potential for interaction with safety related components.

, TUGC0 has initiated a dynamic test program at Corporate Consulting

'

r ' .and Development (CCL) in North Carolina. The dynamic testing will

.;

provide actual strengths as compared to the previously used predicted

'

values. TUGC0 will also conduct a damage study walkdown of all

conduit runs currently determined to have potential interactions with

'

l safety-related components. Evaluation of potential interactions for

safety significance will utilizo preestablished criteria to be

specified in a walkdown procedure. This procedure is currently being

prepared by Ebasco.

<

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Third party review of the Unit 1 damage study resolution for greater

than 2-inch conduit in Train C is being addressed in ISAP.No. II.d.

.

Status of NRC Inspection Activity

A. preliminary review of the Unit 1 large conduit damage study

procedure and related as-built drawings has been conducted.

Resolution of interactions predicted in this study will be reviewed

as part of the NRC inspection program for ISAP No. II.d. A review of

the CCL test procedure has been conducted.

,

No NRC violations or deviations were identified.

c. _C

Q Inspector Qualifications (ISAP No. I.d.1)

Status of CPRT Activity

Phase II evaluation of ASME inspector qualifications has not been

completed. Status of non-ASME inspector qualifications was sent to

the TUGC0 QC Manager by ERC Letter QA/QC-RT-681 on October 4,1985.

Further review by the Special Evaluation Team (SET) has resulted in

some changes to the original' transmittal. Reinspection is underway

for a seventh inspector p10ced into Phase III. Package preparation

is complete for an eighth i.1spector. ,

l

Status of NRM spection Activity )

l

During this reporri tg period, the NRC inspector witnessed 24 l

Phase III reinspections cu ducted by ERC inspectors and also l

, performed 10 reinspections independent of ERC personnel. No l

deficiencies were identified in these.reinspections by either ERC l

inspectors or the NRC inspector.

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A concern that the reinspection attributes were very basic in nature

and may not have accurately reflected the work performed originally

by the project inspector was reviewed with the issue coordinator.

This review found that the reinspection did reflect the activity

associated with the inspector's earlier certifications.

No NRC violations or deviations were identified.

d. Guidelines for Administration of QC Inspector Tests (ISAP No. I.d.2)

Status of CPRT Activity

The SET has completed review of prior revisions to TUGC0 Procedure

CP-QP-2.1, " Training of Inspector Person el." Comments from their

review have been given to the QA/QC RTL and presented to TUGC0 for

resolution and/or incorporation into CP-QP-2.1. Revision 19 to

CP-QP-2.1 was issued October 4, 1985, and incorporates these

comments. Inspector cercification examinations have also been

revised to meet the requirements of Revision 19 of CP-QP-2.1.

Review of B&R Procedure ECP-19, " Exposed Conduit / Junction Box and

Hanger Fabrication and Installation," and other procedures affecting

craft training will be conducted under ISAP No. I.d.3. This issue

was previously included in ISAP No. I.o.2.

Status of NRC Inspection Activity

The NRC inspector reviewed Procedure CP-QP-2.1, Revisions 18 and 19,

to determine if concerns of the NRC Technical Review Team (TRT) were

satisfactorily addressed. Revision 19 of CP-QP-2.1 was found to

address the TRT concerns noted in ISAP No. I.d.2, including inspector

familiarization or training for changes in QC inspection procedures.

This action closes open item 445/8513-0-06.

The NRC inspector reviewed five recently administered QC inspector

examinations. These were found to comply with the requirements of

CP-QP-2.1 for written examinations.

No NRC violations or deviations were identified.

e. Inspection for Certain Types of Skewed Welds in NF Supports

(ISAP No. V.a) >

Status of CPRT Activity

Reinspection of the random sample of 60 ASME Section III, Subsection

NF pipe supports containing 99 type 2. skewed welds has been

completed. Disposition of the 12 TUGC0 NCRs associated with the

undersize type 2 skewed field welds has not been made.

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Status of NRC Inspection Activity

,

The NRC' inspector. witnessed'a total.of nine reinspections and

performed three independent inspections of NF supports containing

.

type _2 skewed welds. -The< results 'of NRC Region I inspections of

skewed welds are documented in NRC Inspection Report ~

'

No. 50-445/85-13; 50-446/85-09. The planned NRC physical inspections

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for this ISAP have now'been completed. NRC evaluation of TUGCO's

~ dispositions of 12 undersize type 2Lskewed field ~ welds is dependent

-

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upon the processing of;the associated NCRs. This remains an open '

item (445/8511-0-04).

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, One violation waslidentified in this subject area which'is identified 7

in paragraph 2.'a of this-appendix.

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f. - Plua Welds (ISAP No. V.d) .  !

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. Status of CPRT Activity

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Reinspection has been completed for the presence of plug welds. in two '

random samples of' cable tray hangers, consisting of 60 from Unit-1 l

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and 61 from Unit 2. The reinspection resulted in the identification u '

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of 23 plug welds in 14 cable tray hangers. Documentation was

, . reviewed for all cable' tray hangers containing plug welds. The

resultslof this re'iew

v showed that'all of the plug welds were

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d. .- authorized and documented. Due to a mix of non-ASME component supports  ;

^ - with'ASME Section III NF component supports in the two original -

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random samples (see item A,, Notice of Deviation, NRC Inspection l

< 9 j_ Report No.'50-445/85-13, 50-446/85-09), a new random sample of 57 NF

'* ' *

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component supports has been created and reinspection has I,een

initiated.

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'- Status of NRC Inspection Activity

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Th'e NRC' inspector witnessed 23 reinspections and performed 6

. - ' independent. inspections of cable tray hangers. With respect to NF  :

J component supports, the NRC inspector has witnessed'a total of 23

.reinspections and performed a total of 4 independent inspections.

' ;L Eight of.the witnessed reinspections and one independent inspection

occurred in this report period and were from the new random sample.  ;'

Indications of possible plug welds were identified in two component

, support base plates during-the witnes:;ed inspections. The NRC-

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inspector will witness the macroetching and inspection of these t

baseplates to determine whether or not plug welds exist.

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No NRC violations or deviations were identified. l

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.g. Installation of Main Steam Pipes (ISAP No. V.e)

Status of CPPT Activity- +

4 'The specific engineering investigation of the main steam line

installation is, complete and is undergoing review. The report

describing the ' analytical evaluation of stresses and support load

changes has been issued by R. L. Cloud & Associates (RLCA) and has

t,een reviewed by TERA. Review and revision of pipe procedures for

pipe erectior. and placement of temporary and permanent supports, as

'

well_as engineering significance of these procedures, is also

complete.~ The TERA draft results report is still being reviewed.

.

Status of NRC Inspection Activity .

The RLCA report addressing the installation of main steam pipes has

been reviewed for adequacy with respect to the methods of analysis.

The review included supporting computer output, calculations, piping

models, and assumptions made. During this review the following

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conditions were noted:

(1) While the use of a "come-along"' for horizontal adjustment is

mentioned in Section 1.3, " Additional Background," it is not

addressed in the analytical portion of the report.

(2) The 18-inch bypass line is modelled in as a schedule 60 pipe,

but drawing FSM-00165 specifies a schedule 40 pipe.

Documentation was not available to substantiate that a schedule

60 pipe was used. Even though the schedule 60 piping is

conservative as far as stress is concerned, it will have some

impact or, other conclusions made in the report such as vertical

displacements.

(3) Figure 3-12 in the analysis does not represent computer output

No. RLCA P142-1-551-018, in that the node numbers do not

correspond.

(4) The NRC TRT identified that sagging occurred during flushing

operations. RLCA states that sagging occurred before flushing.

The date of the flushing should be established.

The above conditions constitute an unresolved item (445/8514-U-13).

No NRC violations or deviations were identified.

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h. Material Traceability (ISAP No. VII.a.1)

'

< ' Status of CPRT Activity

'

The issue coordinator is receiving input from ISAP Nos. VII.c and '

VII.b.3. This information aids in the assessment of the overall

material traceability control systems. Heat numbers on steel items

such as supports and piping are being checked as part )f the

reinspections to establish traceability.

Status of NRC Inspection Activity

The NRC inspector has reviewed ISAP No. VII.a.1. This review found

that the overall material traceability control system was to be

evaluated for adequacy. Preliminary results of ISAP No. VII.c

reinspections indicate that data on material traceability in areas

other than steel is not being compiled. This lack of data could

adversely affect the assessment of the material traceability control

systems. This matter is considered to be an unresolved item

(445/8514-U-14).

No NRC violations or deviations were identified.

i. Housekeeping and System Cleanliness (ISAP No. VII.a.7)

Status of CPRT Activity

This ISAP addresses two specific TRT concerns and performs an

overview of the program on housekeeping and system cleanliness.

Eleven plant surveys conducted by TUGC0 and overviewed by ERC

inspectors have been completed. The issue coordinator has reviewed

the procedural controls to de~cermine if requirements of

Criterion XIII of Appendix B to 10 CFR Part 50 and the FSAR are

included. Inputs from ISAP Nos. II.c, V.b, VI.a, and recent

TUGC0/B&R audit reports, surveys, and other quality documents are

being reviewed to evaluate the effE;tiveness of the current program.

. Specific TRT concern on the number of chloride residue. swipes made on

the wall and bottom of the reactor vessel has beerr investigated. Tha.

procedure controlling this activity required two swipes to be made,

.

but the file documentation shows that eight swipes were made and

. found acceptable. Flush plan.FP-55-08, the controlling procedure, is

, a specific one-time procedure. Ther fore, no revision to this

, procedure is being made. Comments on the adequacy of the number of

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'

swipes made will be~in the results report.

Specific TRT concern o'n lack of protective covering on equipment near

'

welding activities will be addressed by reviewing the results of I

. plant surveys. *

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Status of NRC Inspection Activity

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The NRC inspector has witnessed plant surveys of the safeguards

'

building, Unit 2 reactor area, millwright shop, and ironworkers shop.

During these surveys, items.such as trash or unidentified material

were found in laydown areas where Quality (Q) material was stored.

These items were noted by TUGC0 and ERC personnel. . An independent

NRC resurvey of these areas found that the noted discrepant

conditions had been restored to requirements.

The NRC inspector reviewed the file for FP-55-08' to verify that the

eight chloride residue swipes had been taken for the reactor vessel

wall and bottom. These swipes were found to be documented as

,

performed and acceptable. In addition, numerous swipes had been

taken on reactor internals and the hot and cold legs. These were

also acceptable.

No NRC violations or deviations were identified.

j. Valve Disassembly (ISAP No. VII.b.2)

Status of CPRT Activity

p A second reinspection of seven Borg-Warner (8-W) valves was conducted

using B-W serial numbers for body and bonnet identification. This

reinspection was necessitated by the fact that identification numbers

used in the initial reinspection were traceable to material heat

numbers, but were not necessarily unique to each valve bonnet or

body. No DRs were issued as a result of the second reinspection.

All reinspections are now complete. Of a total of four valid DRs

issued for this ISAP, three SSEs have been completed. The fourth DR

(VALV-9-1) identifies a mismatch between the identification numbers

observed on the valve bonnet and that which is listed in the QA/QC

documentation package for the valve. QA/QC documentation for the

actual installed bonnet has not been located to date.

A difference was identified by the SSE engineer between the

respective design temperature and pressure listed by G&H and those

listed by Westinghouse for the Chemical Volume Control system. '

Specifically,theg&Hlinedesignationtableliststhedesign l

temperature as 250 F and the design pressure as 300 psi, while the i

correspondingWestinghousedgsigntemperatureandpressureare

listed, respectively, as 150 F and 150 psi.

The NRC inspector was informed by the SSE~ engineer that disposition

of the remaining SSE is pending receipt of information from TUGC0

regarding valve temperature / pressure. ratings and TUGC0 resolution of ,

the above described difference in design conditions. I

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Status of NRC Inspection Activity

A total of eight reinspections have been witnessed by the NRC

inspector, one of which was a reinspection of a B-W valve during this

report period. Independent NRC inspections have also been performed

on five valves in the combined random and engineering samples.

The NRC inspector was informed by TUGC0 Field Mechanical Engineering

personnel that: (1) the previously described differences between G&H

and Westinghouse design conditions had also been identified by TUGCO,

'

and (2) a comparison of G&H and Westinghouse design conditions for

' mechanical equipment had been conducted by TUGC0 which resulted in

the identification of several. design pressure and temperature

differences.

The NRC inspector also noted that NCRs have.been written by TUGC0 for

several valves having temperature and/or pressure ratings listed on

the Code Data Log that are different from those listed in the G&H

line designation table. It was not immediately apparent whether or

not the Westinghouse /G&H comparison study had also identified these

differences.

"

Verification of the adequate resolution of differences identified in

, the Westinghouse /G&H comparison study and those identified in NCRs is

considered unresolved and will be evaluated further during a

subsequent reporting period (445/8514-U-15).

No NRC violations or deviations were identified.

7. ISAP No. VII.c

a. Electrical Cable

Status of CPRT Activity

ERC has completed 85 reinspections and 71 documentation reviews of

sampled electrical cable as of October 30, 1985.

Status of NRC Inspection Activity

(1) The following eight ERC reinspections of sampled electrical

cable were witnessed by the NRC during this report period:

Verification Package No. Cable No.

I-E-CABL-078 EG113538

I-E-CABL-084 EG104608

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I-E-CABL-086 E0121816Z

I-E-CABL-088 E0124088

I-E-CABL-089 EG123639Z

I-E-CABL-098 E0145694

I-E-CABL-101 E0122951

I-E-CABL-102 EG139519

' (2) Ouring the above reinspections, ERC identified the following

conditions to the NRC inspector as subject to evaluation as

potential deviations:

(a) I-E-CABL-037: Two through-the-wall sleeves had identical

identification tag number TWS-E-010. The cable run also

deviated from the cable run schedule.

(b) I-E-CABL-084: Cable run deviated from the cable run

schedule and cable was routed through C13G06325 instead of

C13G06324.

(c) I-E-CABL-098: There was no identification tag on the

conduit nipple. Cable E0145694 was found to not have the

required 2 inches of slack in free air as it exited conduit

C13016044 into cable tray. A hold tag with NCR

E85-101141SX had been placed on the conduit as a result of

a prior inspection identifying the same condition.

Dispositions of the above findings are open items (445/8514-0-03

through 445/8514-0-05).

(3) ERC also noted the following deficiencies outside the defined

inspection scope:

I-E-CABL-086: Conduit was 1 1/2 inches instead of the 2-inch

size specified and a loose conduit coupling was'noted where

conduit penetrated a wall.

Dispositions of the above findings are an open item

(445/8514-0-06). .

(4) NRC inspectors did not identify any additional discrepancies

with respect to the above eight packages.

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(5) Independent documentation reviews were performed of 10

verification packages comprising 22 cables. The results of the

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,, independent reviews are an open item pending NRC review of ERC

results (445/8514-0-07).

(6) The NRC inspector noted that NCRs have been written by TUGC0

QA/QC personnel in regard to potential electrical cable damage

'

resulting from installation practices used for cable support

grips. TUGC0 engineering has provided information to assist in

the disposition of the NCRs. This matter is considered

unresolved pending review of supplemental information from TIIGC0

and will be evaluated further in a subsequent report

(445/8514-U-16).

b. Cable Trays

'

Status of CPRT Activity

ERC has completed 84 reinspections and 78 documentation r views of

sampled cable trays as of October 30, 1985.

Status of NRC Inspection Activity

, (1) The following two ERC reinspections of sampled cable trays were

witnessed by the NRC in this report period:

'

Verification Package No. Cable Tray No.

I-E-CATY-201 T220SBC89

I-E-CATY-247 TBGCCM62

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No deficiencies were noted by ERC or NRC inspectors during these

. inspections.

(2) The NRC performed independent reinspections of two electrical

cable trays. The results of these inspections are open-items

pending NRC review of ERC inspection results and documentation

'

reviews (445/8514-0-08) and (446/8511-0-12).

(3) The NRC performed independent documentation reviews of seven

verification packages for seven cable trays. The results of

these reviews are an open item pending NRC review of ERC review

results (445/8514-0-09). j

No NRC violations or deviations were identified. '

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c. Electrical Conduit

Status of CPRT Activity

, ERC has completed 79 reinspections and 76 documentation reviews of

sampled electrical conduit as of October 30, 1985.

Status of NRC Inspection Activity

(1) _The following two ERC reinspections of sampled electrical

conduit were witnessed by the NRC in this reporting period:

Verification Package No. Conduit No.

I-E-COUT-089 C13G07757

I-E-CDUT-098 C12020693 .

No deficiencies were noted by ERC or NRC inspecturs during these

inspections.

(2) The NRC inspectors performed independent documentation reviews

of the following verification packages for sampled electrical

conduits:

Verification Package No. Conduit No.

R-E-CDUT-007 C13010190

R-E-C00T-051 EAB1-1

R-E-CDUT-064 C13016037

R-E-CDUT-070 C14R13047

R-E-CDUT-076 C12008750

R-E-CDUT-077 C13005532

R-E-COUT-086 C13030044

R-E-CDUT-089 C13G07757

R-E-CDUT-098 .C12020693

During the above documentation reviews the NRC inspectors

observed the following deficiencies:

(a) Lighting conduit EAB1-1 was physically reinspected by ERC

and witnessed by NRC. ERC subsequently discarded this item

from the sample of conduit population,.because not enough

attributes were accessible for inspection. The NRC

inspector performed an independent documentation review of

this field witnessed activity and noted that the TUGC0

electrical inspector, who signed the final irs E-1-0027419

and E-1-0024951 for conduit EAB1-1, was not certified to

Procedure QI-QP-11.3-25. TUGC0 Procedures CP-QP-2.1 and

QI-QP-2.1-3 require that inspection personnel be certified

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for a given inspaction function / activity as being qualified

to perform their assigned tasks. The lack of certification

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of the ThiC0 electrical inspector performing the inspection

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of record for conduit EAB1-1 is a violation

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(445/8514-V-04).

(b) ISAP No. VII.c requires original documentation review for

attributes deemed to be inaccessible. A portion of conduit

C13616037 was found to be inaccessible during reinspection

, as a result of being covered with separation barrier

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material (SBM). There was no evidence in ERC's

,

Verification Package No. R-E-CDUT-064 that a check was made

'

for attributes which were not accessible due to SBM

installation. This is an NRC deviation (445/8514-0-02).

(c) QI-009, Revision 0, " Document Review of Conduit /R-E-CDUT,"

requires the reviewer to record the SBM IR and/or latest

-construction operation traveler number at the bottom of the

checklist. The checklist for conduit C13016037 in

Verification Package No. R-E-CDUT-064 did not contain this

required documentation. This item is an NRC deviation

(445/8514-0-03).

(d) QI-009, Revision 0, " Document Review of Conduit /R-E-CDUT,"

also requires the ERC inspector to verify that irs signed

by electrical inspectors were " dated after their date of

certification and prior to their date of expiration."

ERC Verification Package No. R-E-CDUT-070 for conduit

C14R13047 failed to indicate that the ERC inspector

observed that the electrical inspector signing IR-E-46087

was not certified to QI-QP-11.3-23 on the date of

inspection. This item is an NRC deviation (445/8514-0-03).

(e) During this review, the NRC inspector observed that TUGC0

inspection procedures (i.e., QI-QP-11.3-23 and

QI-QP-11.3-23.11) for conduit did not require inspection

for separation between approximately September 1979 and

November 1983. The NRC inspector was informed that a

decision was made to inspsct conduit for separation af ter

construction completion, on a room-by-room basis. The NRC

inspector was also informed that this activity is

prescribed in QI-QP-11.3-29 and that documentary evidence

is available in the Permanent Plant Records Vault (PPRV),

filed by area or room " turn over" numbers.

This item is considered unresolved pending review of this

documentation (445/8514-U-17).

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(f) The NRC inspector observed during documentation review of

conduit C13016037 that the ERC inspector did not review

construction operation traveler EE83-0997-8904 for other

than inspector certification and correct QI reference on

the traveler, it was also noted that construction

operation travelers EE84-10324-8904, EE84-10505-8904,,and

'EE85-11255-8904, in response to Item Removal Notices (IRNs)

for SBM removal and replacement, were not reviewed to

ascertain the certification status of any additional

inspectors that had been used to those that signed the

applicable irs. This item is unresolved pending NRC review

of construction operation traveler documentation in the

PPRV (445/8514-U-18).

(g) The NRC inspector reviewed documentation for six other

conduits. ERC reviews were scheduled but had not been

completed. The results of these review:; will be reported in

a subsequent report after comparison of NRC review results

with the completed ERC results. This is an open item

(445/0514-0-10).

(h) The NRC inspector observed that documentation reviews for

lighting conduits could not be performed by ERC because

QI-009, Revision 0, does not address the relevant QIs;

i.e., QI-QP-11.3-25 and QI-QP-11.3-9. This is an open item

pending the issuance of new instructions or a subsequent

revision to QI-009 (445/8514-0-11).

d. Electrical Equipment Installation

,

Status of CPRT Activity

ERC has completed 20 reinspections and 19 documentation reviews of

sampled electrical equipment installations as of Octouer 30,

1985. This reinspection total is lower than the number (i.e.,21)

reported in NRC Inspection Report No. 50-445/85-13, 50-446/85-09 as

being performed by September 20, 1985. The difference arose as a

result of revision to QI-010 and institution of re-review of

previous.j completed packages for compliance to the revised QI.

Status of NRC Inspection Activity

(1) The following ERC reinspection of, sampled electrical equipment

installation was witnessed b/ the NRC:

)

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Verification rackage No. Equipment No.

I-E-EEIN-059 CP1-ECDPEC-12

No deficiencies were noted by ERC or NRC inspectors during this

inspection.

(2) The NRC performed an independent documentation review of one

l sampled electrical equipment installation. The results of this

review are an open item pending comparison with ERC results when

i available (445/8514-0-12).

No NRC violations or deviations were identified.

e. Instrumentation Equipment Installation

l

Status of CPRT Activity

l

l ERC has completed 75 reinspections and 75 documentation reviews of

l sampled instrumentation equipment installations as of October 30,

l 1985.

'

<

Status of NRC Inspection Activity

(1) To date, eight reinspections have been witnessed by NRC

inspectors with the following five reinspections witnessed in

this report period:

Verification Package No. Unit No.

!

l

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I-E-ININ-072 1

I-E-ININ-079 1

I-E-ININ-069 1

I-E-ININ-076 1

I-E-ININ-066 1

(2) During the above reinspections, ERC identified the following

conditions as subject to evaluation as potential deviations:

I-E-ININ-072:

,

(a) G&H Specification 2323-MS-625 and QI-012, Revision 0, ,

require a slope for process wetted lines of 1 inch per foot

minimum, except that where physical layout is a problem the

minimum slope may be reduced to 1/4 inch per foot. The

tubing line from the root valve to the instrument was found

to only have a slope of 1/2 inch on 9 inches and physical

layout did not appear to be a problem.

'

(b) Drawing 2323-M1-2613, Revision 2, shows instrument

1-P15-4251 as being located 6 feet 0 inches off the wall.

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-- - _ _ _ _ --.--- - - _ _ _ _ . - --_ - _ _ - - _ _ - - - - _ - - _ -_ - - - - . _ _ _ - . -

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This instrument was actually.Incated 5 feet 0 inches off

the wall.

. <

A" . I-E-ININ-079: The tubing line from the component cooling water

' " ' pump 1A to !nstrument 1-PT-4520 had reverse slope where it

passed under the discharge line.

,

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I-E-ININ-066: Required color code was missing and maximum

allowable distance between color code marks' was exceeded.

'

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I-E-ININ-069: Sending units 1-LS-6712 and 1-LS-6717 were found

to be "eversed.

s.

Dispositions of the above findings are open items (445/8514-0-13

through 445/8514-0-16).

(

, No NRC violations or deviations were identified.

t

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(3) ERC also noted the following deficiency outside of the defined

inspection scope:

l. I-E-ININ-079: C1413591 was damaged at the connection to the

j instrument 1-PT-4520.

Disposition of the :above finding'is an open item

l- (445/8514-0-17). .

No NRC violations or deviations were identified.

(4) The following independent ddcumentation reviews of sampled

instrumentation equipment installations were made by the NRC

inspectors: '

l

,

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Verification Package No. Instrument No.

'

R-E-ININ-005 1-LS-4795

- , R-E-ININ-060 1-LS-3376

l

(a) During the review of these packages, the NRC inspector

'

noted that the procedure used (i.e., QI-013, Revision 4)

did not provide detailed instructions for checking original ~ ,

".

' '

documentation for attributes which were inaccessible or '

nonrecreatable during the physical inspections of these i

instrument installations. According to paragraph 4.1 of ' '

-

ISAP No. VII.c Revision 0, documentation reviews will be

s

utilized to supplement reinspections for attributes which

Pre nonrecreatable or inaccessible. Paragraph 4.1.3 of the )

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same ISAP requires procedures to have detailed instructions ,

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for the document reviewers. QI-013, Revision 4, " Documentation.

Review for Instrumentation Equip R-E-ININ," did not list

specific attributes to be verified during documentation

review, but rather required verification of installation in

accordance with one or more of a listing of TUGC0 procedures.

Applicable procedure revisions were not defined. The

number of inaccessible and/or nonrecreatable attributes may

vary between different revisions of a procedure. As an

example, Revision 1 of QI-QP-11.8-8 adds to Revision 0

requirements an inspection checklist addressing verification

of: (i) color codes for nuts; (ii) flange face cleanliness;

(iii) gasket size, rating, and material type; (iv) nuts

being tightened in a diametrically opposite sequence; (v)

studs being the sane length; (vi) proper alignment and

fitup of flange and gasket; and (vii) sufficient gasket

compression. The absence of instructions to the document

reviewer on procedure revisions to be used can thus result

in insufficient guidance with respect to inaccessible and

nonrecreatable attributes. This is an NRC deviation

(445/8514-D-02).

'

~(b) In the review of Verification Package No. R-E-INIh-060, the

NRC inspector noted that the original inspection was

performed by a TUGC0 inspector whose certification to

QI-QP-11.8-7 could not be verified. TUGC0 is currently

investigating the missing certification documents. This

matter is an unresolved item (445/8514-U-19).

(5) Independent reinspections were performed by the NRC inspector on

Verification Package Nos. I-E-ININ-04 and I-E-ININ-026, with the

following results:

I-E-ININ-04: Required bend radius verification was not

performed by ERC inspectors.

I-E-ININ-026: ERC inspectors did not idantify that: (a)

required color coding on six sections was missing, (b) incorrect

slope was present, and (c) an incorrect air gap condition was

. present.

H The failure of ERC inspectors to identify the above conditions

is an NRC deviation (445/8514-D-04).

f. HVAC Ducts and Plenums

.

Status of CPRT Activity

As of October 25, 1985, reinspections have been completed for 62 of

95 random items in the HVAC ducts and plenums samples. The

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reinspections have identified conditions which necessitated the

issuance of 75 ors, 38 of which have been validated. Twelve DRs have

been ovaluatea by ERC and were found to be'nonsafety significant. A

number of deviations dealt with companion angle welds and include

insufficient weld length,' undersized welds, excessive stitch weld

spacing, weld cracks, and incomplete weld fusion. Other deviations

involved seal weld undercuts, lack of full face connecting

flange / gasket contact, level 3 flanged joint installed instead of the

specified level 2 (as defined by G&H specification 2323-MS-85), loose

vent lock caps, level 2 construction instead of the specified level 3,

lock washers not installed on vent lock mounting screws, deteriorating

connecting flange gasket, and seal weld not touched up with paint. .

! Status of NRC Inspection Activity

(1) ERC methods and related documents used in establishing the

-

population items list were reviewed for population

inclusiveness. Completed SSE reports are cur *ently being

reviewed by the NRC inspector. As of October 25, 1985, eight

,

reinspections have been witnessed by the NRC inspector, of which

the following four were witnessed during this report period and

are listed below by Verification Package No.:

Verification Package No. r No.

Ur,t

'I-M-DU'.-021 1

I-M-DUPL-073 1

I-M-DUPL-084 2

I-M-DUPL-086 1

(2) During the'above reinspections, ERC identified the following

conditions to the NRC inspector as subject to evaluation as

'

potential deviations:

I-M-DUPL-021: Some duct connecting flange bolts were bent. No

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corner welds existed on duct connecting flanges and a connecting

flange bolt hole was excessively large.

, I-M-DUPL-073: All vent lock caps were loose and companion angle

bolt hole center-to-center distance was excessive on both ends

of the duct section.

I-M-DUPL-084: Duct connecting flange corner weld lengths were

less than the specified dimension.

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I-M-DUPL-086: Approximately 4 inches of duct seam were not

welded.

Dispositions of the above findings are open items (445/8514-0-18

,

and 445/8514-0-19, 446/8511-0-03, and 445/8514-0-20).

,

(3) The following potential out-of-scope deviation was also

,

< identified by ERC:

.

.

I-M-DUPL-073: An additional hole was drilled in the companion

angle flange and this hole was partially filled with sealant.

Disposition of the above finding is an open item

(445/8514-0-21).

(4) For all witnessed reinspections, the ERC inspector did not

measure duct gage thickness which was a required attribute. The

NRC inspector was informed by ERC that such measurements were

not possible due to inaccessibility to the inside of the duct.

,

The NRC inspector concurred with this position.

No NRC violations or deviations were identified.

g. HVAC Equipment Installation

,

Ststus of CPRT Act*vity

As of October 25, 1985, reinspe-tions have been completed for 38 of

89 random items in the HVAC equ v.t.ent installation samples. The

reinspections have identified conditions which necessitated the

issuance of 68 DRs, none of which have been currently vr.lidated.

Reinspection was on hold for approximately one week, pending a change

notice.to QI-023, Revision O. This change notice involved changes in

. the following areas: (1) the method of verifying companion flange

bolt tightness and gasket compression, (2) inclusion of verification

of full thread engagement between companion flange bolts and nuts,

(3) companion flange bolt centerline to flange edge distance

requirements, and (4) the mtthod of certification of gravity damper

counterweighc balance. Previously reinspected items will require a

followup reinspection, where apslicable, as a result of this

revision.

The NRC inspector was informed by the ?opulation en0i neer that the

HVAC equipment installation plan will be revised to incorporate two

distinct populations, each requiring a minimum sample size of 60.

l . One population will include all HVAC equipment installed by Bihnson

Services. Inc., while the others will include all HVAC equipment

installed by B&R. This change will not necessarily invalidate any

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reinspections conducted to date, but could effectively double the

total number of items to be reinspected in the initial sample.

Status of NRC Inspection Activity

(1) As of October 25, 1985, a total of four reinspections have been

witnessed by the NRC inspector, all of which were witnessed

during this report period and are listed below:

Verification Package No. Unit No.

I-M-HVIN-017 1

I-M-HVIN-038 2

I-M-HVIN-040 1

I-M-HVIN-043 1

(2) During the above reinspections, ERC' identified the following

conditions to the NRC inspector as subject to evaluatien.as

. potential deviations:

I-M-HVIN-017 (Filter): Three bolts on the. inlet duct connection

did not have lock washers installed.

I-M-HVIN-038 (Fan): (a) The exhaust flange gasket did not cover

.the entire flange area, (b) the gasket was also unevenly

compressed, and (c) some lockwashers on exhaust connecting

flange bolts did not have full contact with the flange. Similar

conditions were identified by the ERC inspector for the inlet

duct connection.

I-M-HVIN-040 (Fan): (a) Inlet and c,utlet duct connection gaskets

had low and uneven compression, (b) diameters for foundation

anchor bolts and duct connection bolts were 11'iegible in

drawings provided in the inspection package, and (c) exhaust

duct connection bolts did not have full thread engagement with

r.uts .

I-M-HVIN-043 (Motor Operated Dawer): (a) A nameplate was not

observed on the equipment, and (b) the actuator spring could not

be located which is required for vertfication of fail closed or

fail open positions.

Dispositions of the above findings are open items

(445/8514-0-22, 446/8511-0-0A, 445/8514-0-23 and 445/8514-0-24).

(3) The following potential out-of-scope deviation was also

identified by ERC-

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I-N-HVIN-043: Some of the bolts attaching the actuator to the

mounting bracket did not have full thread engagement.

'

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Disposition of the above finding is an open item

(445/8514-0-25).

'

No NRC violations or deviations were identified.

h. Large Bore Piping Configuration

Status of CPRT Activity

As of October 25, 1985, reinspection was complete for 65 of the 99

random sample large bore piping configuration items. The

reinspections identified conditions which resulted in the issuance of

34 DRs,18 of which, to date, have been validated and are undergoitig

an evaluation by ERC for safety significance.

Tiie NRC inspector was informed by the population engineer that the

population items list is currently being revised to exclude all items

not having an "N-5" designation on the piping isometric drawings.

One exception will be certain safety-related piping in Unit 1 that 4

has been exempted from "NA" code stamping requirements.

The NRC inspector was informed that the above' described revision to

the population items list is required in order to ensure that all

CPRT reinspection items had been previously inspected and accepted by

construction QC. Approximately 24 previously reinspected items will

i

be excluded from the reinspection samples as a result of this

revision.

Deviations have involved incorrect flow direction orientation of an

orifice plate, insufficient clearance with adjacent piping and

equipment, a different part number on a valve to that shown on the

isometric drawing, linear and location measurement differences,

insufficient sleeve clearances, missing code data plate, and flow

direction not marked on the valve.

Status of NRC Inspection Activity

ERC methods and related documents used in establishing the population

items list were reviewed for population inclusiveness. Completed S$F

reports are currently being reviewed by the NRC inspector. As of -

October 25, 1985, four reinspections have been witnessed by the NRC

inspector, with the following verification package reinspection being

witnessed during this report period: )

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I-M-lGCO-113 (Unit 2): During this reinspection, ERC identified one

-

.

coiidition as subject to evaluation as a potential deviation, f.e. ,

flanges tflat were identified as orifice flanges on the isometric

drawing did not have an identification tag or flow direction

indication.

Disposition of the above finding is an open item (446/8511-0-05).

No NRC violations or deviations were identified.

1. _ Piping Syster Bolted Joints / Materials

ERC has completed 73 reinspections of piping system bolted

joints /naterials as of October 26, 1985. However, on eight of these

reinspe.ctions the attribute dealing with flange rating could not be

inspected because the flange was painted. The paint will be scraped

off the eight flanges, thus allowing this attribute to be

reinspected,

ERC has also completed document reviews on 14 of the 73 packages.

The 73 packages represent 100% of the combined random and engineering

samples.

Status of NRC Intpection Activity

(1) The following ERC reinspecticn was independently inspected by

the NRC inspector:

Verification Package No. Drawing No. Flange lio. Unit No.

I-M-PB0H-34 BRP-SI-1-R8-048 1 1

With respect to the above inspection, the flRC inspector

concurred with the ERC inspector's finding that the flange type

was not hardstamped on'the flange as required by the inspect 1on

procedure, and that this condition is subject to evaluation as a

s potential deviation. Suosequently, the Inspection procedure was

revised to allow inspectors to visually identify the type of

flange ir 4

's tmt hardstamped with such information. The

,

above pill be reinigt'"1 hv +nr this particular attribute.

t

No W .iolations or 9 m were mont

O) The following conditi m wi were idntiflini uy itC in

Septenc er as subject to eva:. af.lon as potential deviatiotu s1

DRs o .tten for them: (a) I-M-P80M-46 - Flange W. J (Pra m g

f BRP W 1-$8-003) ha : a loose not, and (b) 1-WPB0.+ 5lange

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No. 3 (Dra.ving BRP-CH-1-EC-0048) had two studs without the

required one thread past the outer face of the nut.

Existing open items for these subjects (i.e., 445/8513-0-21 and

445/8513-0-22) will remain open pending review of the

applicant's completed disposition.

No flRC violations or deviations were identified.

j. Small Bore Piping and Instrumntation Tube Welds /K1terial

Status of CPRT Activity

Reinspection is in progress of small bore pipe and instrumentation

ub

welds and material present in a random sample of 60 weids from

Units 1 and 2. Forty-four small bore pipe and instrumentation tubing

welds have been visusily reinspected. Base riaterial heat codes and

welder identifications have been recorded and are undergoing

docurentation review. No deviations have been found.

Stat.us of NRC Inspection Activity

The following seven reinspections of snall-bore piping welds were

witnessed by the NRC inspector:

1erification Package No. Pipe No. & Weld No. DRP No.

I-M-SBWM-016 CH-2-216-152-3, Wold 11 CH-2-SB-009

I-H-SBWM-003 SW 2-368-105-3, Weld 23A SW-2-AB-027

I-H-58 4 013 CC-2-064-152-3, Weld 1-1 CC-2 SB-002

I-P-SBWM-040 C'i-1-220- 152-3 , Weld 37-2 CH-1-SB-024

I-H-5BWM-076 C5-1-905-250-R2, Weld 18 CS-1-RB-013

I-H-SBWM-054 CT-1-127-901-R2, Weld 56 CT-1-RB-031

1-H-SBWM-057 CT-1-127-301-R2 Weld 43 CT-1-RB-031

No conditions subject tu evaluation as potential deviations were

identified by ERC to the NRC inspector.

No NRC violations or deviations were identified.

k. targe Bore Pipir.g Welds / Material

Status of CPRT Activity

l

l Visual reinspection is in progress of a random sample of 60 ASME

l Section !!I large bore pipin0 welds and material from Units 1 and 2.

To date, 35 1arge bore piping velds have been reinspected. One

deviation has been identified which is currently being evaluated for

validity and safety significance by ERC.

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Status of NRC Inspection Activity ,

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'

As of October 25, 1985, the-following eight reinspections of sampled

,.

large_ bore piping welds were? witnessed by the NRC inspector:

Verification Package No. Pipe No. & Weld No. ,

BRP.'No.

~

I-M-LBWM-003 CS-2-250-301-R-3, Weld 6 CS-2-SB-020

I-M-LBWM-009 CS-2-309-301-R-3, Weld 8 CS-2-SB-030

,

I-M-LBWM-026 BR-X-056-151-R-3, Weld 7 BR-X-AB-048

I-M-LBWM-030 0D-1-18-151-3, Weld 16-1 00-1-AB-013

I-M-LBWM-084 FW-2-102-1303-2, Weld 1-3 FW-2-RB-022-

I-M-LBWM-078 CC-2-271-152-3, Weld 31 CC-2-RB-53

I-M-LBWM-001 CC-2-302-301-R3, Weld 7A' CS-2-AB-032

I-M-LBWM-060 CS-2-026-301-R3, Weld 11 CS-2-AB-065

No conditions subject to evaluation as potential deviations were

identified by ERC to the NRC inspector.

~

,

No NRC violations or deviations were identified.

1. Large Bore Pipe Supports - Rigid

Status of CPRT Activity

Reinspection / verification of pipe support installations by ERC is

approximately 94% complete. A total of 151 deviations have been

identified of which 98 have been determined to be valid. The

remainder are currently being reviewed for validity.

Status of NRC Inspection Activity

(1) The NRC inspector performed independent inspections on pipe

support Verification Package Nos. I-S-LBSR-013-and -023, in

order to assess the adequacy of the ERC reinspections. The ERC

. -reinspection of pipe support Verification Package No.

I-S-LBSR-013 was determined to be adequate, accurate, and

complete. However, during the independent inspection of

I-S-LBSR-023, one deviation from a commitment was identified

with respect to failure to identify discrepant dimensions.

Paragraph 5.3.4.c in QI-027 states with respect to dimensional

tolerances not shown on design drawings, " Component Member-

, Length +/- 1/2 inch." The Bill of Material on Revisicn 2 of '

drawing No. CT-1-097-402-C52R lists item No. 4 (2 pieces) as

.

, ~

being 7 3/4 inches long. Independent NRC inspection determined

the actual length dimensions to be, respectively, 6'5/8 inches

and 6 1/2 inches, both of.which are under the minimum indicated

,e. dimension of 7 1/4 inches (445/8514-0-04).

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(2) During inspection of the installation of box frame supports,

j which are a part of the Unit 1 containment spray system, t' e NRC

'

inspector observed that clearances exist between the botton: of

the pipe and the pipe support, and in some cases no clearance

exists between the top of the pipe and pipe support. The TUGC0

Engineering as-built piping verification supervisor was

contacted about the conflict between the as-built drawings for

these supports and the actual field configuration. The TUGC0

,

Engineering supervisor stated that their as-built piping

configuration program, TNE-DC-24-1, satisfies the requirements

, of NRC Bulletin 79-14 and that the as-built configuration

!. complied with installation tolerances. The conditions

identified above increase loading on adjacent pipe supports and

,

increase stresses on the piping system. The conditions listed

above are being referred to NRR for consideration when

'

, determining the accuracy and adequacy of Stone and Webster-

Engineering Corporation's stress analysis program for the

applicable design specific action plan.

,

m. Large Bore Pipe Supports - Non-Rigid

!

Status of CPRT Activity

Reinspection / verification of pipe support installations by ERC is

approximately 88% complete. A total of 217 deviations have been

identified of which, to.date, 162 have been determined to be valid.

Status of NRC Inspection Activity

(1) The NRC inspector witnessed ERC's reinspection of Verification

Package No. I-S-LBSN-249 to verify compliance with QI-029.

During the inspection, ERC identified the following conditions

to the NRC inspector as subject to evaluation as potential

deviations: (a) component member lengths out of tolerance, (b)

undersize welds, and (c) missing locking devices.

Dispositions of the above items are an open item

(445/8514-0-26).

No NRC violations or deviations were identified.

(2) The NRC. inspector performed independent inspections on pipe

support Verification Package Nos. I-S-LBSN-014, -025, -035, and

-052, in order to assess the adequacy of the ERC reinspections.

This effort revealed that ERC had performed their reinspections

in accordance with the requirements of QI-029.

No NRC violations or deviations were identified.

,

_ _ _ _ . . - . _ _ . _ . _ _ - . _ . _ _ _ - - _ _ _ - . _ _ _ . - _ _ - _ _ . . -_ - . . . _ . _

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n. - Small Bert Piping Configuration

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Status of.CPRT Activity

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p' As aof October ;25,1985, reinspection was complete for 64 of 95 random

sample small bore pipin'g configuration items. The reinspections

'

identified conditions which resulted in the issuance of 45 DRs, 25 of

which were validated and are being evaluated by ERC for safety

significance. '

i

I

The NRC inspector was informed by the population engineer that the

population items list'is currently being revised.to exclude all items

not having an "N-5" designation on the piping isometric drawings.

One exception will be certain safety related piping in Unit 1 that

has been exempted from "NA" code stamping requirements.

'

The NRC inspector was informed that the above described revision to

,

~ the population items list is required in order to ensure that all

'

CPRT reinspection items included those which had been previously

inspected and accepted by construction QC, Approximately 20

previously reinspected items will be excluded from the reinspection

samples as a result of this revision.

Deviations have involved out of tolerance linear and location

measurements, incorrect valve flow direction orientation, inadequate

clearances with adjacent piping and equipment, and the part number on

a valve differing from that on the isometric drawing.

Status of NRC Inspection Activity

(1) ERC methods.and related documents used in establishing the

population items list were reviewed for population

inclusiveness. Completed SSE reports are currently being

reviewed by the NRC inspector. As of October 25, 1985, six

reinspections have been witnessed by the NRC inspector, of which

'

the following three were witnessed during~this report period:

Verification Package No. Unit No.

I-M-SBC0-015 1

I-M-SBCO-061 1

1

I-M-SBCO-079 2 l

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(2) During the above reinspections, ERC identified the following

conditions to the NRC inspector as subject to evaluation as

potential deviations:

I-M-SBCO-061: There was insufficient clearance with three

adjacent pipes and a linear dimension measurement was out of

tolerance.

I-M-SBCO-079: Certain field survey elevation measurements were

not the same as the elevations shown on the isometric drawing.

Dispositions of the above findings are open items (445/8514-0-27

and 446/8511-0-06).

No NRC violations or deviations were' identified. i

o. HVAC Duct Supports

Status of CPRT Activity

Visual einspection of a random sample of 66 HVAC duct supports from

Units 1, 2, and common is in process. Twenty-five HVAC duct supports

have been reinspected by ERC with 18 deviations identified, mostly in

the areas of weld size and configurations. The deviations are

currently being evaluated for validity and safety significance by

ERC.

Status of NRC Inspection Activity '

(1) As of October 30, 1985, the following three reinspections of

sampled HVAC duct supports were witnessed by the NRC: '

f

t

Verification Package No. Unit No. Duct Support No.

'

p. , I-S-HVDS-023 1 CB-830-1N-1R

I-S-HVDS-041 1 AB-842-1L-1F

I-S-HVDS-005 2 CB-790-2N-1BF

>

(2) During the above reinspections, ERC identified the following

.

conditions to the NRC inspector as subject to evaluation as

'

potential deviations:

I-S-HVDS-023: Size of horizontal brace was not per the drawing

and several welds were undersize.

,

I-S-HV05-041: Undersize fillet welds.

_

, - _ __

7

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I-S-HVDS-005: Wrong weld location, undersize fillet welds, and

craters.

Dispositions of the above findings are open items

(445/8514-0-28,445/8514-0-29,446/8511-0-07).

No NEC violations or deviations were identified.

p. Containment Liner and Tank Stainless Steel Liner

Status of CPRT Activity

Ninety-one verification packages have been issued and reinspections

are approximately 96% complete using QI-031, Revision 0.

Documentation review of these packages using QI-032, Revision 0, is

approximately 45% complete. Eighty-three DRs relating to the

documentation review have been issued. These deviations are

currently being reviewed for validity and safety significance by ERC.

Status of NRC Inspection Activity

Review of NRC Inspection Report 50-445/85/13, 50-446/85-09 showed

that the number of inspections witnessed was incorrectly reported as

four rather that the actual number of nine. No additional NRC

inspection activity occurred during this report period.

q. Structural Steel

Status of CPRT Activity

A random sample of 60 structural steel members was selected from a

total population of approximately 1600 individual members.

Verification' packages are currently being prepared by ERC for each

'

member in the sample. QI-045, Revision 1, is being used for physical

reinspection. Fifteen packages have been issued to ERC inspectors

and inspection is approximately 5% complete based on a minimum sample

of 60. Several of the 15 issued packages require additional drawings

and clarification. Ten deviations have been identified, involving

primarily incorrect member size, undersized and missing welds,

inadequate bolt hole coverage, and inadequate Hilti bolt edge

distance. A second random sample of structural steel members related

to safe shutdown systems is scheduled to be selected and inspection

commenced by the end of November 1985.

,

'

Status of NRC Inspection Activity

(1) The NRC inspector has reviewed QI-045, Revision 1. The

following three inspections have been witnessed representing 5%

of the first random sample:

.

k --

.

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.

Verification Package No. Equipment No. Unit No.

I-S-STEL-120 MRB-0565-DCA-MK-A 1

I-S-STEL-88 AFC0-MK-C182-7-RB 1 ,

I-S-STEL-95 AFC0-MK-D180-1-RB 1

(2) During the above reinspections, ERC identified the following

conditions to the NRC inspector as subject to evaluation as

potential deviations:

I-S-STEL-120: Three attributes were rejected; i.e.,

(a) connection location, (b) connection size, and (c) bolt hole

edge distance.

I-S-STEL-88: Undersized welds and incorrect member size were

identified.

I-S-STEL-95: Exposed bolt holes and inadequate bolt tightening

were identified.

Dispositions of the above findings are open items (445/8514-0-30

through 445/8514-0-32).

No NRC violations or deviations were identified,

r. Concrete Placement

Status of CPRT Activity

Reinspection of the first random sample of 60 concrete placement

packages is approximately 92% complete. Twenty eight deviations have

been identified relating primarily to unfilled holes, voids, and

debris in the concrete surface. These deviations are currently being

reviewed for validity and safety significance by ERC. Documentation

review procedures have not yet been issued.

Status of NRC Inspection Activity

(1) The NRC inspectot has reviewed QI-043, Revision 0, and witnessed

9 reinspections representing 15% of the first random sample of

60 concrete placements. The following three ERC reinspections

were witnessed by the NRC inspector during this report period:

r. .

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Verification Package No. Concrete Placement No. Unit No.

I-S-CONC-40 CPC-105-6831-014 1

I-S-CONC-51 CPC-105-5865-012 1

I-S-CONC-11 CPS-101-2808-001 1

(2) During the above reinspections, ERC identified the following

conditions as potential deviations to the NRC inspector and

subsequently issued DRs:

I-S-CONC-40: The locations of concrete cast-in place inserts

(Richmond) were out of tolerance. DR I-S-CONC-40-DR1 was issued

subsequent to the inspection.

I-S-CONC-51: Voids were identified in the concrete surface.

DR I-S-CORC-51-DR1 was issued subsequent to the inspection.

Dispositions of the above findings are open items (445/8514-0-33

and 445/8514-0-34).

No NRC violations or deviations were identified.

s. Small Bore Pipe Supports

Status of CPRT Activity

A population of 7947 small bore pipe supports has been identified

from which a total of 76 support verification packages were randomly

selected for reinspection. The first 60 of the verification packages

make up the first random sample as defined by the CPRT Action Plan.

The second sample pertains to safe shutdown systems and consists of

44 from the first sample of 60 and an additional 16 packages. The

QIs used for reinspection and documentation review were QI-019,

Revision 2, and QI-020, Revision 0, respectively.

Physical reinspections are approximately 95% complete. A total of 65

deviations have been identified, relating primarily to Hilti bolt

embedment, hole spacing and edge distance in base plates, and pipe

clearances. Documentation review is approximately 82% complete with

51 deviations identified. All deviations are currently being

reviewed for validity and safety significance by ERC.

Status of NRC Inspection Activity

The NRC inspector has reviewed QI-019, Revision 2, and QI-020,

Revision 0. Six physical reinspections representing 10% of the first

,

'

.

'

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random sample were witnessed by the NRC inspector during September 1985.

No reinspections were witnessed during this report period.

No NRC violations or deviations were identified.

'

t. Reinspection of Pipe Whip Restraints

Status of CPRT Activity

,

ERC has completed 13 out of the planned 110 reinspections of pipe

whip restraints as of October 26, 1985.

Status of NRC Inspection Activity

(1) The following two ERC reinspections of pipe whip restraints were

witnessed by the NRC inspector:

Verification Package No. Support Identification Unit

I-S-PWRE-052 CP2-CSSSMR-05 2

I-S-PWRE-518 M40-52-0584 2

(2) During the above reinspections, ERC identified the following

i

conditions to the NRC inspector as subject to evaluation as

potential deviations:

I-S-PWRE-052: (a) The distance between two capture plates on a

,

moment restraint was 9 5/16 inches, which was less than the

! allowed distance of 9 1/2 +/- 1/8 inch; and (b) distance from

!

the centerline of one capture plate to the centerline of a weld

was 3 3/8 inches, which was greater than the allowed distance of

3 1/8 +/- 1/8 inch.

1

i I-S-PWRE-518: The grout did not completely cover the shim plate

l underneath the top baseplate.

,

I Dispositions of the above findings are open items (446/8511-0-08

and 446/8511-0-09).

(3) ERC also noted the following deficiencies outside of the defined

inspection scope:

I-$-PWRE-052: One of the Richmond inserts on concrete column

I No. 15 overlapped a Hilti bolt embedment for a pipe support on

! the adjacent face of the same column by approximately

l 2 3/4 inches. The Hilti bolt centerline was about 5 inches

i

l i

'

I

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above the Richmond insert centerline. The impact of this

condition was to be evaluated.

I-S-PWRE-518: There was a crater chipped out of the grout.

I

Dispositions of the above findings are open items (446/8511-0-10

and 44G/8511-0-11).

No NRC violations or deviations were identified.

!

u. Reinspection of Instrument Pipe / Tube Supports

Status of CPRT Activity

i

ERC has completed 42 out of the planned 102 rainspections of

instrument pipe / tube supports as of October 26, 1985.

Status of NRC Inspection Activity

(1) The following four ERC reinspections of instrument pipe / tube

( supports were witnessed by the NRC inspector during this report

period:

l

Verification Package No. Instrument Tag No. Unit No.

I-S-INSP-004 1-FT-156 1

I-S-INSP-017 1-FI-245-78 1

I-S-INSP-024 1-P15-3384 1

I-5-INSP-057 1-LT-459 1

(2) During the above reinspections, ERC identified the following

conditions to the NRC inspector as subject to evaluation as

potential deviations:

l I-S-INSP-004: (a) Support Nos. 48, 4C, 40, 4E, and 4K had bolts

without the minimum 70% of specified torque; and (b) support

No. 41 did not have the serrated groove of the spring nut

aligned with the channel ridge.

I-S-INSP-017: (a) Support No. 170 had a bolt without the

required one thread past the face of the nut; (b) support Nos. 171,

17K, 17L, 17M, 17N, and 17Q had bolts without the minimum 70% of

specified torque; (c) support No. 17K did not have the serrated

groove of the spring nut aligned with the channel ridge; and

1 1

1

,

l

l

l

,

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(d) support Nos. 17A, 17J, and 17K had different type instrument

tubing clamps than specified on the drawing. l

I-S-INSP-024: (a) Supp3rt No. 24H had an undersized weld; (b)

support No. 24H had no visible heat numbers on the baseplate;

(c) support No. 24H had a structural tubing length of

56 3/4 inches, which is 1/2 inch greater than the maximum

allowable length specified on the drawing; and (d) support No.

l 24H had a different type of instrument tubing clamp than

l specified on the drawing,

i I-S-INSP-057: (a) Support Nos. 57A and 57E did not have the

serrated grooves of the spring nut aligned with the channel

l ridge; (b) support Nos. 57N and 57P had spring nuts used in lieu

l of required hex nuts; and (c) support No. 57N had a bolt that

! did not have minimum 70% of specified torque.

l

l

Dispositions of the above findings are open items

(445/8514-0-35 through 445/8514-0-38).

,

(3) The following two ERC reinspections were independently inspected

by the NRC inspector:

l Verification Package No. Instrument Tag No. Unit No.

I-S-INSP-007 1-PT-405 1

I-S-INSP-028 1-PI-2467 1

l While performing the above independent inspections, it was noted

t

that on support Nos. 0070 and 028A, the serrated grooves on the

I spring nuts did not align with the channel clamping ridge. This

i is required by attribute 4.5 of QI-055, " Reinspection of

l

Instrument Pipe / Tube Supports." However, the ERC inspectors

! signed off this attribute as being acceptable. This is an NRC

deviation (445/8514-D-04).

8. Unresolved Items

Unresolved items are matters for which more information is required in

order to ascertain whether they are acceptable items, violations, or

deviations. Seven unresolved items disclosed during the inspection are

j discussed in paragraphs 6.g 6.h, 6.j, 7.a. 7.c, and 7 e.

9. Exit Interview

An exit interview was conducted on November 1, 1985, with the applicant

representativos denoted in paragraph 1 of this appendix. During this ,

interview, the NRC inspectors summarized the scope and findings of the '

inspection. The appilcant acknowledged the findings,

i

l