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See also: [[see also::IR | See also: [[see also::IR 05000445/1985014]] | ||
=Text= | =Text= |
Latest revision as of 06:23, 3 January 2021
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: |
References | |
50-445-85-14-02, 50-445-85-14-2, 50-446-85-11, NUDOCS 8603180523 | |
Download: ML20141P077 (43) | |
See also: IR 05000445/1985014
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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G SM
I , Reactor Inspector, Region IV CPSES
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D(ite ' ' ~ ~
C.J.
Grou@p
(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 -
r/7/#6 .
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 ,
,
- 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
.
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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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.
,
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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M' A ' s u -
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
R . .
. Inspection'and Enforcement. ~
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- . 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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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
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original and revised sampling plans.
(d) Personnel Requirements: The resumes and signed objectivity
statements for the RTL and each of the three issue
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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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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
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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
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provide actual strengths as compared to the previously used predicted
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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. ,
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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
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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 ~
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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
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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
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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.
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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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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.
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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 ' '
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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
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.
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.
~
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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
.
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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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_ _ _ _ . . - . _ _ . _ . _ _ - . _ . _ _ _ - - _ _ _ - . _ _ _ . - _ _ - _ _ . . -_ - . . . _ . _
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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.
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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.
,
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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:
.
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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:
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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
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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
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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,
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