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=Text=
=Text=
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Copy No.
226
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COMANCHE PEAK STEAM ELECTRIC STATION QUALITY ASSURANCE PLAtt
?
TEXAS UTILITIES GENERATING COMPANY EXHIBIT 45 B708310235 870819" l
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PDR FOIA I
BAUMANB7-A-14 PDR t
 
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_ _v QUALITY ASSURANCE PLAN p+p y, %g SECTION : 17.1
# $N -,
DATE: 10-18-85 g
f, IITE CONSTRUCTION QUALITY CONTROL RECORDS REVISION : 2 PAGE 1 OF 1 17.1 Site Construction Quality Control Records
_ Quality Control documents are initiated, collected, and maintained in accordance with approved procedures.
These documents shall be filed and l
controlled. The procedures / instructions define the records required to be retained and define the provis' ions required for suitable protection of records. Upon completion of an activity, the documents initiated are reviewed and the completed QA records. are then transferred for retention at the plant site.
The responsibility for implementation of the on-site record control and filing system is identified in site procedures and is subject to audit by TUGC0 QA to assure compliance.
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9C h-7 4.
Aco11 cant Action on IE Bulletins (IE8s)
In response to discussions regarding the TUGCo profiram concerning.!E8s, h
e.
Circulars, and Infonnation Notices Region IV was 'nformed that TUGCo s
will perform a review of related procedures and records to determine the adequacy of procedures and the completeness of associated records.
The initiation of this effort will follow the task review of the 10 CFR Part 50.55(e) program which is presently in crogress.
,_ 4.
This item is unres'o1ved (445/8516-U-02, 446/8513-U-02).
b.
The TUGCo actions _on sd l.e., Nos. 79-14 an 8)were selectJ -to~rievi rdware evaluatlbns-cr_ repair /replac ts.
TUGCo d
10JR1.og Sh
, page 10. dated April 9, 1984 M as reviewed to 7
etermine dhe status of the IEBs.
y (1) IEB 79-14 was evaluated by TUGCo in 1983 an''was statused as d
/
closed. The.HRC inspector indh:sted that the closure of IEB 79-14
/
was premature since Stone & Webster is currently analyzing Unit 1 \\
seismic analysis versus as-built drawings, which directly relates i to this IEB. Unit 2 as-built work has also not been completed.
1 TUGCo stated that the IEB 79-14 file will be reopened and a supplemental report will be submitted upon completion of the ongoing project engineering work.
/
/
wThe above item (IEB No. 79-14) status is considered an openJttn (445/4516-0-03,446/8513-0-03).
(2)
IEB 79-28 identified deficiencies with certein manufactured lots of NAMC0 EA 180 limit switches. The gasket material of the faulty lots, when exposed to temperatures above 175'F. vaporized and emitted a yellow-brown crystal like resin that can cause these switches to fail. The NRC inspector found the TUGCo documentation to be complete with respect to the specified corrective action of replacing these switches with switches manufactured in acceptable lots.
Field verification of replacement of 14 switches identified, however, that the identity of 2 switches could not be traced to existing travelers.
Specifically, the replacement NAMCO limit
/ switches on residual heat ramoval valves 1-HCV-606 and 1-FCV-618 were identified on travelers EE 82-1415-5801 and EE 83-0373-5801 as EA 180-32302 and EA 170-31302, respectively.
The switches actually installed in the field were identified as EA 180-31302 and EA 180-31302, respectively.
TUGCo is evaluating this inconsistency to deteraire if there is other documentation to account for this.
This item is unresolved (445/8516-U-04, 446/C513-U-04).
 
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Addenda 1 to July 23, 1986 Testimony (page 583)
Phillips assigned McKluskey to inspect.IEB 79-14 without any considerations of.past inspections of IEB 79-14.
It is my understanding that he' assigned' McKluskey to inspect this Bulletin because he did not consider that Region IV-had looked at hardware associated with IE Bulletiscorrective action. The.
hardware associated with this Bulletin has..since the beginning, been inspected on numerous occasions ~includin 50-445/82-05 which
' looked at' the initial program. g NRC' Inspection Report In this first inspection of the TUGCo 79-14 verification program, R. Brickley
'(who was assigned out of the Vendor. Branch to the IEB 79-14 Task Force) was on i
site and looked at pipe support hardware.
C..E. Johnson inspected the TUGCo
. lEB 79-14 verification program.
The Special Inspection Team (SIT) was a full team inspection devoted to pipe and pipe supports issues. The CAT inspection inc %ded pipe and pipe supports.
Region IV performed a series of room turnover inspections which included pipe i
and pipe supports.
The Technical Review Team (TRT) inspected pipe and pipe supports.
At present, Stone.and Webster (S&W) has full responsibility for the pipe support issues at CPSES. A~whole new program is in progress and NRR has the oversight responsibility for both design and the pi The' third party, Energy Research Corporation (ERC) pe support inspections.
is, in addition to S&W
-walkdowns,. performing independent inspections. The third party. design-organization, TERA, is~also overseeing the S&W design' effort. The Region IV Comanche Peak Group is performing independent inspections of the ERC effort which includes independent inspections of the pipe supports. The Office'of Inspection and Enforcement has been requested by NRR to audit the S&W QA program associated with CPSES activities.
My point is that the Phillips' decision to inspect this Bulletin certainly wasn't coordinated with RIV management.
I believe the pipe and pipe support effort was already being adequately covered by RIV and NRR.
G7.s;n a
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j 5.
0A Records Retention l
The NRC. inspectors found that construction deficiency and IEB files were not stored in the QA records vaults.
Because such records have not been deposited in a central location, difficulties have been encountered in retrieval.
TUGCo is assessing this record file issue.
This item ~is open pending the completion of their review (445/8516-0-05,
'446/8513-0-05),
i 4
 
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(0 pen) Unresolved Item (445/8514-U-03, 446/8511-0-02):
Incomplete g.
TUGCo has' indicated ffgnificant deficiency analysis report files.
the.t actions are being taken to identify all records necessary to i
close out open files. This action is scheduled to be completed by March 1, 1986.
___m__
 
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}@[- Ib l}
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i
,(0 pen)UnresolvedItem.h445/8514-0-02,446/8511-U-01):
f.
Procedures do not address 10 CFR Part 50.55(e) file content or provide a method for completion /signoff for corrected construction deficitacies. The NRC inspector reviewed TUGCo Procedure NEO CS-1 entitled, " Evaluation of I
and Reporting of Items / Events Under 10 CFR Part 21 and 10 CFR Part 50.55(e)." The review revealed that the following procedures
]
were inconsistent with Procedure NEO CS-1:
CP-QP-16.1, Revision 6, dated January 16, 1985; TNE-AD-5, Revision 3, dated June 21, 1984; DQP-QA-12, Revision 2, dated September 9, 1985; and CP-QP-15.6, j
Revision 3 dated January 16, 1985.
The inconsistencies included conflicting responsibilities, method of evaluation, deportability criteria, notification policy, and reporting instructions.
TUGCo has committed to the resolution of file tracking problems and procedural inconsistencies by March 1,1986.
I
 
QdTHb/J
/
/ 7C k6-7
~ 4. -
Applicant Action on IE Bulletins (!EBs)
In response to discussions regarding the TUGCo program concerning IEBs,
'a.
Circulars, and Information Notices, Region IV was informed that TUGCo
/
will perform a review of related procedures and records to determine the adequacy of procedures and the completeness of associated records.
i The initiation of this effort will follow the task review of the j
10 CFR Part 50.55(e) program which is presently in progress.
Thisitemisunre'shved(445/8516-U-02,446/8513-U-02).
b.
The TUGCo actions on two IEBs (i.e., Nos. 79-14 and 79-28) were selected to review hardware evaluations or repair / replacements.
TUGCo 10ER I.og Sheet, page 10 dated April 9. 1984, was reviewed to l
detemine the status of the IEBs.
(1) IEB 79-14 was evaluated by TUGCo in 1983 and was statused as d
closed. The NRC inspector indicated that the closure of IEB 79-14 was premature since Stone & Webster is currently analyzing Unit 1 seismic analysis versus as-built drawings, which directly relates to this IEB. Unit 2 as-built work has also not been completed.
TUGCo stated that the IEB 79-14 file will be reopened and a i
supplemental report will be submitted upon completion of the l
1 ongoing project engineering work.
The above item (IEB No. 79-14) status is considered an open item (445/8516-0-03,446/8513-0-03).
(2) IEB 79-28 identified deficiencies with certain manufactured lots l
of NAMCO EA 180 limit switches. The gasket material of the faulty lots, when exposed to temperatures above 175'F, vaporized and emitted a yellow-brown crystal like resin that can cause these J
switches to fail. The NRC insp:ector found the TUGCo documentation
]
to be complete with respect to the specified corrective actiot Of replacing these switches with switches manufactured in accept # r lots.
Field verification of replacement of 14 switches irentified, however, that the identity of 2 switches could not be traced to existing travelers. Specifically, the replacement NAMCO limit
/ switches on residual heat removal valves 1-HCV-606 and 1-FC)'-618
]
4 were identified on travelers EE 82-1415-5801 and EE 83-0373-5801 as EA 180-22302 and EA 170-31302, respectively.
The switches l
actually installed in the field were identified as EA 180-31302
/
and EA 180-31302, respectively. TUGCo is evalu,4 ting this inconsistency to determine if there is other documentation to account for this.
i This item is unresolved (445/8516-U-04, 446/8513-U-04).
]
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627 c'
/
1 they made more chan'ges.
It's a matter of getting 2
the right paperwork.
3
: 0. -
But the paperwork reflects to get~back 4
to George's point yesterday or two weeks ago --
5 what the control is in the facility which reflects 6
upon the -- you're only doing a limited sample.
7 A.
That would be a work package issue.
If I 8
went looking for it, there should be a work 9
package issue th.at would cover replacement of
'10 these switches, probably identified which ones; 11 and there should haye been a' status of it.
12 Q.
Is this Mr. Wagner who closed this out?
13 A.
Yes.
I would only sample -- if the man 14 says, " Hey, we've done 79-28," I would go out.and 15 s a:nple that.
See AM 8ab 2 t
16 A.
Okay.
17 0-
'By Mr. Mulley) okay.
~' --
18 A.
The next one is -- the next two, I guess,
]k } L/ 19 a
really deal wi th "TUGCO's procedure for handling 20 IEB are deficient in that they do not describe how 21 construction management / personnel handle IEB 22 requiring IEB requiring action, especially
))
23 hardware repair, replacement, and modification,
~
y e - ---
24 Prior to write-up, I stated to management that r..
{
25 this is a violation; but management disagreed.
I 6
 
628 i
4 1
/
1 wrote it as unresolved."
2 Okay.
We're back at this status of 3
what's done in the IEB.
The utility gives you a
4 reply and tells what you they're going to do under 5.
the IEB.
Then we would normally go verify that.
4 6
For example, my prior experience has been 7
in Arkansas.
I don't recall having some status on B
each IEB kept at the site by the construction 9
folks that were putting in the IEB.
I don't know 10 that that was a necessary procedure.
l IN 11 There is,their procedure a man assigned 12 and they got two procedures, as a matter of fact, i
13 that cover that kind of arena.
Lo that when an IE 14 bulletin comes in, he then looks at it and assigns 15 it out or writes out correspondence internally to 16 folks within the company that certain actions have 17 to be taken; and they, in turn, provide him back 18 with the actions taken or being taken to comply 19 with the bulletin.
20 That reply is put into a reply draft and 21 sent back to the Commission.
Having the 22 construction site have a separate tracking and 23 status of of IEB, I couldn't see how that would be 24 a regulatory requirement placed on the utility 25 company.
1
 
62'9 j
l' They handled it consistent with where 1 2
had seen bulletins handled.
3 Q.
Doesn't this go back to the first 4
sentence in the whole issue?
5 A.
Yes.
6 Q.
You're going to review procedures and 7
* records to determine the adequacy of procedures?
8 A.
That's correct.
And we did provide them 9
that.
I didn't drop it.
I left the insert 10 says, " Management dropped and wrote insert No. 2 11 in Document No.
4,"
which is essentially the words 12 that we're.looking at there.
13 I think the next one is the same thing, 14 "No TUGCO construction focnl coint for tracking 15 IEB actions.
Prior to write-up, I stated to 16 man ag e me n t.. t h a W;his is a viel en; b u-t-17 management disagreed.
I wrote it as unresolved."
18 This is much of the same.
This is again 19 contrary to what any inspectors in the past had I
20 been able to do in closing out bulletins, l
l 21 including looking at hardware, looking at l
22 documentation and find'ing what they i. :$ed to 23 close it.
24 Q.
(By Mr. Mulley)
So, he's saying here 25 that he couldn't go to a central person to find
 
f _. (-
630 b
/\\
1 out how to track the paperwork on these bulletins?
l 2
A.
That's correct.
3 Q.
And you're saying that in the past 4
inspectors have been able to do that?
5 A.
Well, you got to taka what the utility 6
replied to in the bulletin ard said, "We are doing I
7 certain things."
s 8
If they say, for ex :mple, ' they are 9
replacing NAMCO switches, you should be able to go 10 find out if they're replacing NAMCO switches.
11 I don't have the exact piece of work 12 order down 02 each one that was listed to go out 13 and do that replacement.
I don't believe that 14 that is a requirement that has to be in an IEB 15 file.
16 Now, if I was going to do my druthers and 17 I'm the utility company, I would probably trace it 18 a lot further than what TUGCO has done; and that's 19 part of the reason Mr. Johnson and I had say the 20 discussion with them because, again, if they're t
21 leaving themsel,f open for material false Nees 22 statements, th y're going to come down with both 23 feet on them.
24 I don't know anybody that wants a 25 material false statement.
 
Log # TXX-4779 File # 10130 IR 85-14 85-11 TEXAS UTILITIES GENERATING COMPANT SKYW AY TOWER e 400 NORTH OIJVE FFREET, L.h. S R
* D ALLAB TEXAS 78301 May 16, 1986 fg
/
e Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012
 
==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NO.:
50-445/85-14 AND 50-446/85-11
 
==Dear Mr. Johnson:==
We have reviewed your letter ofcMarch 6, 1986,fconcerning the inspection by Mr. T. F. Westerman and others of-the-Region IV Comanche Peak Group during the period September 30 through October 31, 1985.
This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2.
We requested and received a four week extension in providing our response during a telephone discussion on April 7, 1986.
We requested and received an additional two week extension during a telephone discussion on May 2, 1986. We have provided our response to the Notice of Violation and the Notice of Deviation in the attachments to this letter. To aid in understanding our response, we have repeated the Notice followed by our response.
Very truly yours, 67' W. G. Counsil JWA/arh c-Region IV (Original + 1 copy)
Director, Inspection and Enforcement (15 copies)
U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. V. S. Noonan Mr. D. L. Kelley
> 2/ - n D & 2
[
%, c
.s y',J G A DEV152ON OF TEXAS UTTLITIES ELECTKJC COMPANY
 
1 c'._
NRC Notice of Violation 3
Item A (445/8514-V-01) 1 i
Criterion XVII of Appendix B to 10CFR Part 50, as implemented by Section i
3.8, Revision 4, of the Operations Administrative Control and Quality
)
Assurance Plan, requires that (1) sufficient records shall.be maintained to furnish evidence of activities affecting quality, end (2) that the records shall include the results and acceptability of tests and analyses, and the action taken in connection with any deficiencies noted.
Contrary to the'above:
1.
A significant number of instances of missing data entries was noted in water chemistry records covering the period March 1983 through September 1985, with respect to the chemistry sampling frequency requirements of Procedures CHM-501, " Chemistry Control of the Primary Cooling Water Systems." No annotations were made in the records to explain why the samples were not taken.
2.
Review of the water chemistry records showed instances of failure to make required entries to indicate when the Shift Supervisor was notified in regard to out-of-specification chemistry results.
3.
The records did not identify what corrective actions were taken after entry of out-of-specification results.
4.
Inadequate reviews were performed of the acceptability of water chemistry data, as evidenced by the presence of review and approval signatures on forms containing discrepant data results.
Response to Item A Notice of Violation 445/8514-V-01 is written in four parts, each of which is addressed separately.
Part 1 1.
Reason for Violation:
An investigation by the Chemistry and Environmental Engineer I
confirms instances of missing entries on Chemistry data sheets, with no explanation in some cases.
In many cases there are explanations on data sheets preceding the ones with missing data; explanations l
such as system drained, not in service, or problem with analytical equipment.
Chemistry personnel failed to document the continuing situation on subsequent data sheets when data was unavailable.
l 1
CHM-501 and CHM-508, the governing procedures cited in this part of the Violation, require the recording of data on appropriate data sheets.
However, no guidance is provided concerning documentatier of samples not taken, or there is no requirement to document the reason samples are not taken in the comments section of the data sheet.
i l
l
 
r V.
NRC Notice of Violation Item A (445/8514-V-01)
(Continued) 2.
Corrective Action Taken:
A.
Chemistry section forms have been evaluated.
The following-improvements were identified and will be incorporated:
All data sheets associated with the CHM-500 series proce-dures will have the same general lay-out; Parameter limits will be highlighted in red ink; Sample data and time columns will be clearly delineated; Where applicable, a chemical addition column will be included; and Each form will include the following note; " Circle out-of-specification parameters."
]
The following corrective actions are in progress or will be completed pending approval of. CHM-500 series procedures.
B.
Chemistry data sheets (forms) associated with the following procedures are being revised:
Procedure No.
Revision No.
Procedure Title CHM-501 1
Chemistry Control of the Steam Generr. tors CHM-502 1-Chemistry Control of.the i
Water Treatment System-CHM-503 1
Chemistry Control of the Condensate System CHM-504 1
Chemistry Control of the Feedwater System CHM-505 1
Chemistry Control of the Secondary Support System l
CHM-506 1
Chemistry Control of the Primary System CHM-507 1
Chemistry Control of the Residual Heat Removal System CHM-508 1
Chemistry Control of the Primary Support System
-j
 
}.. "
NRC Notice of Violation
)
Item A (445/8514-V-01) j (Continued) 1 i
1 CHM-509 1
Chemistry Control of the r
Primary Makeup System CHM-510 1
Chemistry Control of the l
Boron Recovery System l
1 CHM-511 1
Chemistry Control of the I
Safeguards System CHM-517 1
Sampling and Analysis of Liquid Waste Systems CHM-519 1
Chemistry Control of the Refueling Water 3.
Corrective Steps to Avoid Recurrence:
A.
The Chemistry section attended a training session on January 9, 1986, which addressed the following topics:
Procedure compliance; Problems associated with existing data sheets; Pending revisions to existing data sheets; Consequences of missing surveillance item; Consequences of not reporting an out-of-specification parameter; Proper routin; of data sheets; Corrective action recommendations; and Proper or key points to consider when filling out a data sheet. The following items were addressed:
1.
Ensure all data entries are clearly written; 2.
Circle all out-of-specification parameters; 3.
Ensure that data is reviewed against specified limits; I
4.
Ensure that all footnotes are used correctly; 5.
Fill in blanks; t
6.
Document systems that are not in service; L
 
F.
i
(
l' NRC Notice of Violation _
)
I l
Item A (445/8514-V-01)
(Continued) i 7.
Document reason for taking sample if not routine; 8.
Utilize standard nomenclature.
Additionally, Chemistry directive 86-001 was issued to address these Concerns.
B.
Upon approval of the above referenced procedures, implementation
)
training will be provided to familiarize all Chemistry section personnel with the new data sheets (forms).
4.
Date of Full Compliance:
A.
Chemistry data sheets (forms) associated with the referenced CHM-500 series procedures will be revised by June 1, 1986.
B.
Chemistry section personnel will receive additional training on the revised data sheet forms by June 1, 1986.
Part 2 1.
Reason for Violation:
There have been instances of failure to make required entries to indicate that the Shift Supervisor was notified in regard to out-of-specification Chemistry results.
Some of these instances are failure to notify the Shift Supervisor for each sample for a continuing condition, specifically the pH depression.
These deficiencies are procedurally related because CHM-508, Revision 0, required the notification of the Shift Supervisor but did not require documentation of this notification on the data sheet.
Also data sheet CHM-508-1 did not require identification of out-of-specification conditions or notification of the Shift Supervisor.
CHM-501, Revision 0, did not require immediate notification of the Shift Supervisor upon verification of an out-of-specification condition and the time of notification be recorded on the appropriate data sheet.
This problem is aggravated by the listing of Mode 1 limits on data sheet CHM-501-1 for steam generators so it is not readily apparent which values are out-of-specification. This is a contributing factor to personnel errors i
during shutdown conditions.
2.
Corrective Action Taken:
lhe data sheets are being revised to show the appropriate limits for j
'.he applicable condition.
l
 
NRC Notice of Violation Item A (445/8T14-V-01f (Continued)
CHM-508 has.been revised to include the requirement to insnediately notify the Shift Supervisor in the event of an out-of-specification conditian and to document this notification on the data sheets.
3.
Corrective Steps to Avoid Recurrence:
The corrective action, with Chemistry section personnel training, should prevent this part of the Violation from reoccuring.
4.
Date of Full Compliance:
CHM-508 was revised October 15, 1984.
Chemistry data sheets (fowis) will be revised by June 1, 1986.
Part 3 1.
Reason for Violation:
Investigation confirms that the Chemistry. data sheets do not typically indicate the corrective actions taken for out-of-specification chemistry.
This deficiency is procedurally related because CHM-501 and CHM-508 indicate that the Chemistry Supervisor will investigate out-of-specification chemistry and determine the corrective action to be i
taken. There is no guidance to document corrective actions in other administrative procedures or on the data sheets.
j l
i This deficiency was also identified in TUGC0 Corporate QA Audit TUG-76 as Deficiency No. 1.
2.
Corrective Action Taken:
l Guidance provided by the revised procedure CHM-104 provides necessary corrective action.
This corrective action was the result of TUGC0 QA Audit TUG-76.
i 3.
Corrective Steps to Avoid Recurrence:
The training provided under the Part 1 Preventive Action should prevent this deficiency from reoccurring.
4.
Date of Full Compliance:
Procedure CHM-104 was revised on May 2'4,,
1985.
Personnel training was completed on January 9, 1986.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ __ i
 
NRC Notice of Violation.
Item A (445/8514-V-01)
(Continued)
Part 4
.}
1.
Reason for Violation:
CHM-101, Revision 1.(5-12-82), " Chemistry / Radiochemistry Administrative Control," states that records produced by technicians shall be independently reviewed by a qualified person and forwarded I
to the Chemistry and Environmental Engineer or his designee for approval.
CHM-101, Revision 2 (12-8-83), states that Chemistry and Environmental Supervisors are responsible for reviewing data sheets and that Staff Chemists are responsible for approving data sheets.
2.
Corrective Action Taken:
A qualified person will review all past CHM-501-1 and CHM-508-1 data sheets.
This review will be performed to determine if there is any significant chemistry concern indicated which has not been identified and resolved. Also, a representative selection based on the number of records generated from other procedures utilized during the January 1983 to September 1985 time period will be reviewed.
If similar problems are found to exist in the selected records, then a full review will be conducted.
Deficient or nonconforming conditions discovered during these reviews will be documented in accordance with station procedures.
3.
Corrective Steps to Avoid Recurrence:
All Chemistry and Environmental Supervisors and Staff Chemists have been reminded of their administrative responsibilities.
4.
Date of Full Compliance:
All required document reviews will be complete by August 1, 1986.
J k
i
 
S Notice of Violation Item B ( W6/8511-V-01)
~
Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by j
documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
{
Par 6 graphs 2.3 and 3.1.1.1 of Brown & Root (B&R) Procedure CQ-QAP-16.2, Revision 25, require.that nonconformances be identified, documented by completing the NCR form, and dispositioned.
Paragraph 3.19.5.2 of B&R Procedure CP-CPM 6.90, Revision 6, states, in part, with respect to NCRs for minimum wall violations, ".
.. Welding engineering shall review the conditions stated on the NCR Contrary to the above, repair of a minimum wall violation associated with weld 21-2 in component CC-2-RB-053 was noted on October 9, 1985, from record review to have been performed without documenting the condition on an NCR form.
Response to Item B 1.
Reason for Violation:
A QC Inspector failed to follow QI-QAP-14 1-26 which requires the initiation of a Nonconformance Report (NRC) for minimum wall k
violation (MWV).
2.
Corrective Action Taken:
A review was conducted to determine the method used to identify and correct the MWV and concluded that the repair process used was technically adequate and would not have been altered regardless of the document used to record the MWV (i.e., Unsatisfactory IR attribute vs NCR).
While we believe that the violation is a iso-lated occurence we are confident that any other similar minimum wall violation would have been likewise adequately dispositioned.
3.
Corrective Steps to Avoid Recurrence:
All applicable QE's and QC Inspectors were retrained in the speci-fic QI-QAP-11.1-26 program requirements relative to welded repairs associated with MWV's.
Additionally, construction proce-dure CP-CPM-6.90 will be revised to clarify the requirement that an NCR must be generated whenever a MWV it identified.
Appropriate Weld Engineering personnel will be trained to the revised CP-CPM-6.90 requirements.
4.
Date of Full Compliance:
May 16, 1986.
1 f
l
-J
 
Notice o7 Violation Item C (446/8511-y-02)
Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type. appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Paragraphs 3.1:1.1 of B&R Procedure DCP-3, Revision 18, states, in part,
... Issuance and receipt of controlled design changes are documented on the Document Distribution Log...
by signature or initial of the file custodian and dated." Paragraph 3.2.2.5 of this procedure additionally requires that the face of a retained superseded document must be stamped "V0ID."
Contrary to the above:
1.
Satellite document control center 307 was noted on October 14,
'1985, to be in possession of a controlled copy of Component l
Modification Card 96181 for which receipt had not been signed for l
and dated on the Document Distribution Log.
2.
A copy of superseded Design Change Authorization (DCA) 21446, Revision 0, was noted on the same date to be present in two packages for Drawings 2323-El-1702, Sheet db2, Revision 2.
Both copies of DCA 21446, Revision 0, were not stamped " VOID" on the face of the document.
Response to Item C - No. I 1.
Reason for Violation:
Failure to properly implement procedure.
2.
Corrective Action Taken:
The Document Distribution Log was corrected by the inclusion of proper initial and date. The Document Distribution Log was reviewed and there were no other violations of this nature identified.
3.
Corrective Steps to Avoid Recurrence:
Appropriate DCC personnel were reinstructed in the proper receipt acknowledgement of design changes.
DCP-3 rev. 19 paragr:ph 3.1.1.1 includes verification responsibilities by DCC per sonnel to ensure acknowledgment of design changes is documented.
4.
Date of Full Compliance:
March 31, 1986.
 
t.
Notice of Violation Item C (446/8511-V-02)
(Continued)
Response to Item C - No. 2 4
1.
Reason for Violation:
Failure to pr.operly implement procedure.
2.
Corrective Action Taken:
The drawing package contents were immediately corrected.
It was determined that the drawing was not used in the performance of plant work. Monitoring a sample of drawing package contents revealed that no drawings or design changes were found to be out of revision.
3.
Corrective Steps to Avo'd Recurrence:
Personnel were reinstructed in the need to assure up-to-date contents in drawing packages, including ;5e marking of superseded drawings as " void".
4.
Date of Full Compliance:
April 1, 1986.
I I
1
 
Notice of Violation
!_ tem 0 (446/8511-V-03)
Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP, Section.5.0, Revision 3, dated July 31, 1984, requires tnat activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Section 17.1.17 of the Final Safety Analysis Report, Volume XIV, Amendment 50, dated July 13, 1984, commits to procedures requiring that records be controlled and accounted for during transfer between organizations.
Contrary to the above, original sole copy design records were ascertained on October 16, 1985, to have been shipped to Stone and Webster Engineering Corporation, New York, without the establishment and implementation of procedures that address required control and inventory j
measures.
Response to Item D 1.
Reason for Violation:
Conditions noted in the violation are the result of a f ailure to follow established procedures for control of engineering documents.
TUGC0 Nuclear Engineering (TNE) Procedure TNE-AD-4 specifies that duplicate copies of engineering documents prepared or processed by TNE shall be maintained at the site or Gibbs & Hill /New York, as applicable.
In 1985, Stone & Webster Engineering Corporation (SWEC) assumed des i gn. re spon s i b ilitylor_ pipe 3 upp or t s.
In order to consider and Incorporate, where possible, existing information into SWEC designs, TUGC0 initiated shipment of pipe support design records offsite.
2.
Corrective Action Taken:
Measures to establish compliance with TNE procedure TNE-AD-4 and
{
subordinate TNE instruction TNE-AD-4-6 (issued specifically for transmittal and duplicate retention of pipe support calculations) have been implemented for pipe support records previously forwarded to SWEC.
These efforts, involving the return of copies and complete accountability, were completed in February 1986.
3.
Corrective Steps to Avoid Recurrence:
I TNE-AD-4-6 was issued November 25, 1985, establishing a program for
)
transmittal requ.irements for pipe support design records.
In addition, TNE-AD-4 will be reviewed and revised, if required, to
)
assure the adequacy of measures prescribing the offsite transmittal l
of engineering documents.
__w
 
Notice of Violation Item D (446/8511-V-02)
(Continued) 4..
Date of Full Compliance:
As noted in items 2.'and 3, all measures have been completed with-the exceptio'n of the review / revision of Procedure TNE-AD-4. These measures will be accomplished no later than May 22, 1986.
)
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Notice of Violation Item E (446/8514-V-03) s Criterion VI of Appendix B to 10 CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative and Quality Assurance-Plan, regyires that (1) measures shall be established to control the issuance of documents such as drawings, including changes thereto; and (2) the measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel.
I Paragraphs 2 and 4 in Revisions 7 and 8 of Station Administration Manual Procedure No. STA-405 require that all documented nonconformances, in i
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.
Paragraph 4.0 in Revision 0 of Nuclear Operations Engineering Manual Instruction No. N0E-201-5 requires that proposed drawing changes be submitted'to the Operations Superintendent for review, approval, and authorization to distribute the revised drawings.
Contrary to the above, nine-as-built drawings were revised and distributed by TUGC0 Nuclear Engineering to reflect NCR identified undersize _ welds, without receiving TUGC0 Operations review, approval, and authorization to distribute the revised drawings.
Response to Item E 1.
Reason for Violation:
The condition noted in the violation is the result of the issue of pipe support drawings by TNE documenting acceptance of "Use-As-Is" conditions prior to the proper disposition of several TUGC0 Operations'.NCR's.
Prior approval of drawings which document the "Use-As-Is" disposition of NCR's by TUGC0 Operations is a requirement of Station Administration Manual Procedure STA-405.
Please note the following in regards to Appendix "A",
item E, third i
paragraph of the subject NRC Inspection Report.
Procedure N0E-201-5 does not require "non-vital" drawings, such as BRH (pipe j
support) drawings be submitted to the TUGC0 Operations Superintendent prior to issue by PSE (Pipe Support Engineering).
However, the generic issue of whether such drawings should be classified as " vital" and therefore be submitted to the TUGC0 Operations Superintendent is being processed by TUGC0 Deficiency j
Report (DR-86-007) whose disposition is yet outstanding.
2.
Corrective Action Taken:
Ine pipe support drawings noted in the findirg were subsequently reviewed by TUGC0 Operations.
Approval has been documented by closure of the corresponding TUGC0 Operations' NCR's, completed December 19, 1985.
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g__,___-
' Notice of Violation Item E (446/8511-V-02) n (Continued) 3.
Corrective Steps to Avoid Recurrence:
i As a re'sdit of this specific finding, TNE Procedure TNE-AD-4-5 Revision 1 was issued November 11, 1985. Procedures which describe THE and TUGC0 Operations interf ace arrangements applicable to pipe supports were reviewed to assure consistency.
No additional conflicts were noted.
Adherence to these interface requirements should preclude further violations of this nature.
4.
Date of Full Compliance:
As noted above, full compliance has been achieved.
(
 
Notice of Violation Item F (446/8514-V-04)
Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
I Paragraph 3.0 of Procedure CP-QP-2.1, Revision 14, dated October 17, 1983, states in part, "... inspection personnel... shall have experience in and shall have completed a technical training course and examination in the area of inspection responsibilities." Paragraph 3.7 of this procedure states, in part, "... Inspection personnel shall be certified by the TUGC0 site QA supervisor as being qualified to perform their assigned tasks."
Contrary to the above, it was noted on October 21, 1985, during review of documentation for Class 1E lighting system conduit EAB1-1 that the electrical inspector, who had signed inspection reports E-1-0024951 and E-1-0027419, had not been certified to the applicable Procedure QI-QP-11.2-25, Revision 17, dated February 13, 1984, " Inspection of New Installations for Class 1E Lighting Systems."
Response to Item F 1.
Reason fcr Violation:
Oversight by QC Supervision which allowed the inspector in question to inspect to QI-QP-11.3-25 prior to final sign-off of his certification.
2.
Corrective Action Taken:
NCR E-85-101639 was initiated to address this violation.
In addition, 800 Inspection Reports completed by 163 QC Inspectors I
during the past six months were reviewed to determine if further violations of this nature had occured.
All of the reports reviewed were completed by QC Inspectors certified to the activity inspected.
j l
3.
Corrective Steps to Avoid Recurrence:
j QC Supervision is issued a weekly list which identifies the certification capabilitiu and status of their personnel, for use in inspection assignments.
Based upon the above review results this action is sufficient to avoid recurrence of this violation.
Inspections performed prior to June 1985 are subject to CPRT action item Vll.d 7
)
4.
Date of et
.o rpl i ance :
May 5, In
 
Notice of Deviation Item A (445/8514-D-01)
Section 4.1.6 of ERC Comanche Peak Project Procedure (CPP) CPP-012, "QA/QC Interface with Construction /TUGC0" states, "The QA/QC Records Administrator controls requests for equipment / services and distributes and controls requests for technical information."
o Contrary to the above, the QA/QC Records Administrator does not receive copies of. requests to provide for control of these documents l
(445/8514-D-01).
With. respect to item A in the Notice of Deviation, the NRC has ascertained subsequent to this report period that ERC logs for tracking of equipment / service requests have not been utilizing procedurally required unique numbers for individual requests.
Accordingly, please address this as part'of your response to item A in the Notice of Deviation.
Response to Item A 1.
Reason for Deviation:
As the NRC identified, the QA/QC Records Administrator does not control requests for equipment / services from the Constructor /TUGCO.
Due to a misunderstanding of the NRC's concern at the time of the finding, it was not explained that such requests are tracked by a computerized log maintained by the Inspection Supervisor or his designee.
Subsequent NRC investigation confirmed the presence of this tracking mechanism. Consequently, the original NRC concern was resolved.
However, the NRC it3pector subsequently identified a related concern:
the log did not show a unique number for each equipment / services request as required by CPP-012.
The function of the equipment / services tracking mechanism is to ensure that all necessary equipment / services (i.e. scaffolding, painting or lagging removal, etc.) are installed or performed before inspection takes place and are maintained until inspection is completed.
All open equipment / services requests (ESRg) are maintained in a folder associated with the verification package with which they are identified.
The computer tracking mechanism tracks the status of the most recently opened ESR. This function is served satisfactorily by the mechanism currently in place (the same mechanism in place at the time of the NRC inspection).
Changes to the mechanism used to track open ESRs are not required since no failures to per*
' the intended function exist.
However procedure CPP-012.must r
..t current practice.
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Notice of Deviation item A (445/8514-D-01)
(Continued) 2.
Corrective Action Taken:
ERC Comanche Peak Project Procedure CPP-012 was revised March 11, 1986, to remove reference to the ESR log.
J3.
Corrective Steps to Avoid Recurrence:
The action to correct the reported condition serves as action to prevent recurrence.
4.
Date of Full Compliance:
i March 11, 1986.
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Notice of Deviation Item 8 (445/8514-0-02) j
~
Section 4.1 of CPRT Issue-Specific Action Plan (ISAP) No. VII.c Revision 0, dated June 21, 1985, states, in part,
... Where required, documentation reviews will be utilized to supplement the reinspection for attributes which are nonrecreatable or inaccessible...."
Section 4.1.3 of the ISAP states, in part,
{
)
.. The inspection procedure will provide detailed instructions j
to the inspectors and/or documentation reviewers for performing the reinspection and/or documentation reviews..."
]
Contrary to the above, the following examples were noted of inadequate procedural guidance and document reviewer performance in regard to nonrecreatable and inaccessible attributes:
1.
Quality Instruction (QI) 01-013, Revision 4, lists no specific attributes, but instead specifies that the inspector verify installations in accordance with one or more of a listing of TUGC0 procedures; i.e., QI-QP-11.8.1, -5, -6, and -8.
The list of appropriate procedures does not, however, indicate the applicable revision number of each procedure.
In that the number of nonrecreatable or inaccessible inspection attributes can vary from revision to revision of a procedure (e.g. Revisions 0 and 1 of TUGC0 Procedure 01-0P-11.8-8), the absence of guidance on applicable procedure revision numbers does not constitute detailed instructions.
2.
During the documentation review of Verification Package No.
R-E-CDUT-064, in accordance with Q1-009, Revision 0, there was no evidence that a documentation check was made of inaccessible attributes for conduit C13016037 that were caused by the installation of separation barrier material (445/8514-0-02).
Response to Item B 1.
Investigation:
QI-013 " Documentation Review for Instrumentation Equipment /R-E-ININ" does not, in fact, list specific atir autes for the inspector to verify.
The purpose of the documentet review governed by Q1-013 is to provide inspector qualification,
{
information as input to ISAP I.d.1.
The intent of QI-0;
.s to verify the inspector who signed the inspection report being i
reviewed was certified to the appropriate revision of uality l
Instruction (QI) that was in place at the time of the
: tion.
)
To do this the document reviewer records the inspect; e, the
(
QI number, and the revision of the procedure noted or Then the inspector certifications are reviewed to determi.
e Ne of j
I inspector was certified to the appropriate revision i
signing the IR.
1 y
 
Notice of Deviation p,,
Item B (445/8514-D-01)
(Continued)
This is an appropriate way to verify inspector certifications.
c Consequently, no deviating condition is believed to exist.
R'egarding use of document reviews tuupplement reinspe.clionslor e
inagsgssible atttibutest the NRC finding is correct, based on Revision 2.of the CPRT Program Plan.
However, in the ensuing time-i period, Revision 3 of the CPRT Program Plan, including a revised ISAP VII.c was issued.
ISAP VII.c as now written dictates that, after the.s.ixt ins n t_ tons _have been concluded for the population sample, any at r utes which were found to be inaccessible will cause additional samples to be selected from the population and j
inspected only for those attributes which were inaccessible-in preceding inspections.
Document review will only be used for non-recreatable attributes unless sixty occurrences of the attribute are not accessible from the population as a whole. Consequently, the programmatic change in: Revision 3 resolved this finding.
2.
Corrective Action Taken:
No corrective action for items 1 and 2 are planned.
3.
Corrective Steps to Avoid Recurrence:
No corrective steps for items 1 and 2 are applicable 4.
Date of Full Compliance:
February 24, 1986.
i l
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~
Notice of Deviation Item C (445/8514-D-03)-
j QI-009, Revision 0, '' Document Review of Conduit /R-E-CDUT", requires the j
ERC inspector to-verify that inspection reports signed by electrical inspectors were 4
dated after their date of certification and prior to their date of expiration, and, document the SBM inspection report (IR) and/or latest construction 1
operation traveler number at the bottom of the checklist.
Contrary to the above:
Review of ERC accepted documentation for conduit C14R13047 showed that the ERC inspector failed to identify that the certification to the applicable Procedure Ql-QP-11.3-23 had lapsed for the TUGC0 electrical inspector signing IR-E-46087.
The ERC completed inspection record checklist for conduit C13016037 in Verification Package No. R-E-CDUT-064 did not contain documentation of the SBM IR or latest construction operation traveler number (445/8514-D-03).
Response to Item C 1.
Reason for Deviation:
A review of verification Package No. R-E-CDUT-064 and R-E-CDUT-070 confirmed the NRC findings. This was determined to be an inspection error.
2.
Corrective Action Taken:
(DR) Deviation Report R-E-COUT-070-ORI was written by the inspector.
The number for the latest construction operation traveler was added to the applicable checklist on 11/21/85.
The inspector was given additional training on 11/8/85.
Reinspection of 25% of this inspector's work involved 28 verification packages and was completed before 11/21/85.
The results of the 25% reinspection has been evaluated and based upon the minor nature of the discrepancies identified, no further actions was deemed necessary on the Inspector's past performance.
3.
Corrective Steps to Avoid Recurrence:
An overview Inspection Program has been implemented to reinspect a sample of each Inspector's work on a continuing basis.
Action is ongoing to analyze results of the Overview Inspection program, gather pertinent inspector error data from other sources (NRC reinspection, etc.), and to effect required additional formal training of inspectors.
 
Notice of Deviation Item C (445/8514-0-01)
~~
(Confinued) 4.
Date of Full Compliance:
Corrective action was completed by November 21, 1985.
Preventive action involves an ongoing program.
e s
 
\\
Notice of Deviation
}
Item D (445/8514-D-01)
)
Section 4 of CPP-009, Revision 3, states, in part, with respect to ISAP No. VII.c, " Qualified QA/QC Review Team personnel perform field reinspection of specific hardware items and reviews of appropriate
]
documents in accordance with approved instructions...."
Contrary to the above, the following examples were noted where field i
reinspection of hardware items were not performed in accordance with approved instructions:
1.
Attribute 4.5 in Section 5.0 of Q1-055, Revision 0, states with respect to spring nuts, " Verify that the serrated grooves align with the channel clamping ridge." Checklists for support No. 0070 (Verification Package No. I-S-INSP-007) and support No. 028 (Verification Package No. I-S-INSP-028) were signed by two separate ERC inspectors that this attribute was acceptable. NRC inspectors showed, however, that the spring nut serrated grooves did not align with the channel clamping ridge on both of these supports.
2.
Section 5.3.4.C in Q1-027 states with respect to dimensional tolerances not shown on design drawings, " Component member length
+/-1/2 inch."
The bill of material on Revision 2 of drawing No. CT-1-097-402-C52R in Verification Package No. 1-S-LBSR-023 shows item No. 4 (2 pieces) to be 7 3/4 inches long. The applicable inspection checklist used during the ERC reinspection of this pipe s,upport shows the installed configuration to be acceptable. NRC inspect-tion determined, however, the actual length dimensions of the two pieces to be 6 5/8 inches and 6 1/2 inches, respectively, both of which are under the indicated minimum dimension.of 7.1/4 inches.
3.
Section 5.0 in 01-012 states, in part, " Verify that the piping / tubing and components... material agree with the Bill of Haterials shown on the Instrument Installation Detail drawing.
Tubing is marked with longitudinal color coded marks for traceability. Use applicable drawing to identify tubing...
Verify that the installed tubing has the, proper slope.
The required slope for process wetted lines is one11 Finch per foot minimum.
This slope requirement may be reduced to 1/4 inch per foot when physical layout is a problem.
Verify that the,re is a proper air gap. The minimum gap spacing shall always be 1/8 inch to allow each instrument sensing line to expand independently at all bends without striking adjacent sensing lines, other equipment, concrete or steel building members."
The applicable inspection checklist used during the ERC reinspection of instrumentation installation Verification Deckage No.
1-E-ININ-026 showed that the above attributes were inspected and_ accepted, as evidenced by the inspector's signoff (initiarsh a
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1
 
Notice of Deviation Item D (445/8514-D-01 (Continued) 4
'However, NRC inspection of the instrumentation installation revealed:
1 (a)
Six sections of tubing had no color coding for traceability; (b)
Ten sections of tubings, in which physical layout was not a problem, had slopes of 7/16 inch to less than 1/4 inch per 4
foot and one section had reverse slope; and (c)
Two tubing sections had zero gap spacing between the high pressure and low pressure legs and the concrete' penetration.
4.
Section 1.7 in 01-012 requires that: (a) tubing bend be verified to have a minimum radius of four times the normal tube size by using either a template, or by direct measurement calculations; and (b) the measured and calculated values be entered into the Minimum Bend Radius Record, with date and inspector's initials.
During NRC inspection of Verification Package No. I-E-ININ-04, equipment tag No. 1-FT-156, it was noted that the inspection checklist was dated and initialed, attesting to the fact that the tubing bends had been verified as having a minimum radius of four times the nominal tube size. However, review of the applicable Minimum Bend Radius Record'showed that the ERC inspector had neither measured and calculated, nor used a template to verify minimum bend radius.
In addition, the following notes had been entered by the ERC inspector:
"Ist 90' bend from instrument (hi &
lo side)... cannot be measured with existing tools. Four (4) other bends visually more than 90' to accommodate slope" (445/8514-D-04).
Response'to Item D 1.
Reason for Deviation:
Reinspection confirmed the NRC findings.
Item 1,and_2
'nspector error.
ftem 3
'nspector Error.
Ongoing adjacent construction and housekeeping
:tivities (i.e., wiping down, climbing, ongoing work in i
4 me
 
Notice o'f Deviation Item D (445/8514-D (Continued) surrounding areas, etc.) prevent a firm determination as to whether
-a or not the NRC identified findings existed at the time of the ERC inspection but, enough indication exists to justify retraining of
/
the. inspectors.as a step to assure decertification of those items which may well have been inspector error.
Item 4 Inspector error.
QI requires clarification to allow inspector to indicate inaccessible bends.
2.
Corrective Action Taken:
Item 1 Deviation Reports I-S-INSP-007-DR2 and DR3 dated November 18, 1985, and I-S-INSP-028-DR2 dated November 8, 1985, were written to document the misaligned spring nuts.
Twenty five percent of the work of both. inspectors was reinspected, The results of the reinspection were documented and evaluated by inspection supervision.
A decision was made to reinspect;IO0% of the spr_i_n_g.. nut _s previously inspected by the first inspector. The results of the reinspection indicated a_high_ error rate.
This inspector's services were discontinued and 100% of his work was reinspected.
The retained inspector was retrained on November 12, 1985.
All necessary reinspection were completed by December 5, 1985. -Deviating conditions identified by the reinspection have been documented in the applicable Verification Packages arid DRs initiated.
A general training session on Spring Nut inspection was given to all non-affected inspectors involved in the reinspection of this I
attribute. This retraining has been documented.
Item 2 Deviation Report I-S-LBSR-023-DR2 dated November 13, 1985, was written to document the dimensional deviations. The responsible inspector was the same one whose services were discontinued as indicated above.
Item 3 and The Verif0 R'6n Packaae documentation for ININ-026 has been
/
reinspetic E-ININ-004 was corrected, and DRs I-E-ININ-026-DR-2,
 
r a
1 Notice of Deviation L
Item D (445/8514-D-01 (Continued)
-4, nd -5 were issued.
In addition, revision 1 of QI-012 was issued January 30, 1986, and now provides a basis for the e
' inspectors to indicate inaccessible bends.
Due to problems noted by ERC and those identified herein by the NRC, all ININ Verification Packages issued prior to January 14, 1986, will be reissued for reinspection.
3.
Corrective Steps to Avoid Recurrence:
An Overview Inspection program has been implemented to reinspect a sample of each Inspector's work on a continuing basis.
Action is ongoing to analyze results of the Overview Inspection program, gather pertinent inspector error data from other sources (NRC reinspection, etc.) and to effect required additional formal training of inspectors.
4.
Date of Full Compliance:
Corrective action is complete with the exception of the total reinspection of the ININ packages.
Preventive action involves an ongoing program.
9
 
-In Reply Refer To:
Dockets:- 50-445/85-14 JUG '., ins 50-446/85-11 l
' Texas Utilities Generating Company ATTN: Mr. W. G..Counsil Executive Vice President 400 North Olive, L.B. 81 Dallas, Texas 75201 Gentlemen:
.Thank you for your letter of May 16, 1986, in response to our letter and Notice of Violation dated March 6,1986.
We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to -
determine that full compliance has been achieved and will be maintained.
Sincerely,
.ywn9 - ~ ~
. ;...::n E. H. Johnson, Director Division of Reactor Safety and Projects CC:
Texas Utilities Electric Company ATTN:
G. S. Keeley, Manager Licensing Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Juanita Ellis President - CASE 1426 South Polk Street Dallas, Texas 75224 RIV:D:DRSP C:RSBY EHJohnson:sj TFWest6' man r
4 /(:,/86 f/i3/86 I
-seem v_vas esess e,
/ro G-PDR
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.Te'xas Utilities Generating' Company '
Renes Hicks-Assistant Attorney General,
Environmental Protection Division L:
<P.O. Box'12548 Austin, Texas 76711 Texas Radiation Control Program Director-bec;to DMB (IE01) bec distrib. by RIV:
MIS System RPB
.RSTS Operator RRI-OPS RRI-CONST-R&SPB T. F. Westerman, CPTG DRSP V. Noonan, NRR R. Martin, RA
: 5. Treby, ELD RSB RIVLFile J. Taylor,-IE D. Weiss, LFMB (AR-2015)
R. Heishman IE i
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1 I
Log # TXX-4779 I
I File # 10130 IR 85-14 85-11 TEXAS UTILITIES GENERATING COMPANY SKYW AY TOWER e 400 NORTH OLIVE FrREET. L.B. St
* DALLAS. TEXA8 78301 May 16, 1986 L5 v 4:3._
.== :=.=
MAY E I 1966 I
L _
Mr..Eric H. Johnson, Director Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission l
611 Pyan Plaza Drive, Suite-1000 Arlington, Texas 76012
 
==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NO.:
50-445/85-14 AND 50-446/85-11
 
==Dear Mr. Johnson:==
We have reviewed your letter of March 6, 1986, concerning the inspection by Mr. T. F. Westerman and others of the Region IV Comanche Peak Group during the period September 30 through October 31, 1985.
This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2.
1 We requested.and received a four week extension in providing our response during a telephone discussion on April 7, 1986. We requested and received an additional two week extension during a telephone discussion on May 2, 1986.
We have provided our response to the Notice of Violation and the Notice of Deviation in the attachments to this letter.
To aid in l
understanding our response, we have repeated the Notice followed by our response.
Very truly yours, 7'
W. G. Counsil JWA/arh c-Region IV (Original + 1 copy)
Director, Inspection and Enforcement (15 copies)
U. S. Nuclear-Regulatory Commission Washini: Von, D.C.
20555 Mr i. 'i Noonan L. Kelley Me s.
N'
=
&MNrWON
., >e l e PDR A DC.
%O00445 G
PDR A omsson or rexAs tmtmES ELECTRIC COMPANY i
 
4 NRC Notice of Violation
{
Item A (445/8514.V-01)_
Criterion XVII of Appendix B to 10CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative Control and Quality t
Assurance Plan, requires that (1) sufficient records shall be maintained 1
to furnish evidence of activities affecting quality, and (2) that the
- records shall include the results and acceptability of tests and analyses, I
and the action taken in connection with any deficiencies noted.
]
Contrary to the above:
1.
A significant number of instances of missing data entries was noted in water chemistry records covering the period March 1983 through September 1985, with respect to the chemistry sampling frequency requirements of Procedures CHM-501, " Chemistry Control of the Primary Cooling Water Systems." No annotations were made in the records to explain why the samples were not taken.
2.
Review of the water chemistry records showed instances of failure to make required entries to indicate when the Shift Supervisor was notified in regard to out-of-specification chemistry results.
3.
The records did not' identify what corrective actions were taken after entry of out-of-specification results.
4.
Inadequate reviews were performed of the acceptability of water chemistry data, as evidenced by the presence of review and approval signatures on forms containing discrepant data results.
Response to Item A Notice of Violation 445/8514-V-01 is written in four parts, each of which is addressed separately.
Part 1 1.
Reason fur Violation:
An investigation by the Chemistry and Environmental Engineer confirms instances of missing entries on Chemistry data sheets, with no explanation in some cases.
In many cases there are explanations on data sheets preceding the ones with missing data; explanations such as system drained, not in service, or problem with analytical equipment. Chemistry personnel failed to document the continuing situation on subsequent data sheets when data was unavailable.
CHM-501 and CHM-508, the governing procedures cited in this part of the Violation, require the recording of data on appropriate data sheets. However, no guidance is provided concerning documentation of samples not taken, or there is no requirement to document the reason samples are nnt Yeken in the coments section of the data sheet.
 
NRC Notice of Violation
.~
Item A (445/8514-V-01)
(Continueo) l 2.
Corrective Action Taken:
i l
A.
Chemistry section forms have been evaluated. The following improvements were identified and will be incorporated
* i All data sheets associated with the CHM-500 series proce-dures will have the same general lay-out; Parameter limits will be highlighted in red ink; Sample data and titae columns will be clearly delineated; i
Where applicable, a chemical addition column will be included; and Each form will include the fc11owing note; " Circle out-of-specification parameters."
The following corrective actions are in progress or will be completed pending approval of CHM-500 series procedures.
4 B.
Chemistry data sheets (forms) associated with the following procedures are oeing revised:
Procedure No.
Revision No.
Procedure T'.tle CHM-501 1
Chemistry Control of the Steam Generators CHM-502 1
Chemistry Control of the Water Treatment System CHM-503 1
Chemistry Control of the Condensate System CHM-504 1
Chemistry Control of the Feedwater System CHM-505 1
Chemistry Control of the Secondary Support System CHM-506 1
Chemistry Control of the Primary System CHM-507 1
Chemistry Control of the Residual Heat Remova.
l System CHM-508 1
Chemistry Control of the Primary Support System i
p,
}
 
NRC Notice of Violation Item A (445/8514-V-01)
(Continued)
CHM-509 1
Chemistry Control of the-Primary Makeup System CHM-510 1
Chemistry Control of the
-Boron Recovery System CHM-511 1
Chemistry Control of the l
Safeguards System CHM-517 1
Sampling and Analysis of Liquid Waste Systems CHM-519 1
Chemistry Control of the Refueling Water 3.
Corrective Steps to Avoid Recurrence:
l A.
The Chemistry section attended a training session on January 9, 1986, which-addressed the following topics:
Procedure compliance; Problems associated with existing data sheets; Pending revisions to existing data sheets; Consequences of missing surveillance item; Consequences of not reporting an out-of-specification parameter; Proper routing of data sheets; Corrective action recommendations; and Proper or key points to consider when filling out a data sheet. The following items were addressed:
1.
Ensure all data entries are clearly written; 2.
Circle all out-of-specification parameters; 3.
Ensure that data is reviewed against specified limits; 4.
Ensure that all footnotes are useo correctly; 5.
Fill in blanks; 6.
Document systems that are not it:
'c;
 
4 NRC Notice Af Violation Item A-(445/8514-V-01)
(Cantinued) 7.
Document reason for taking sample if not routine; 8.
Utilize standard nomenclature.
Additionally, Cnemistry directive 86-001 was issued to address these Concerns.
.B.
Upon arproval of the above referenced procedures, implementation training will be provided to familiarize all Chemistry section persannel with the new data sheets (forms).
l 4.
Data of Full Compliance:
A.
Chemistry data sheets (forms) associated with the referenced CHM-500 series procedures will be revised by June 1, 1986.
B.
Chemistry section personnel will receive additional training on the revised data sheet forms by June 1, 1986.
Part 2 1.
Reason for Violation:
There have been instances of failure to make required entries to indicate that the Shift Supervisor was notified in regard to out-of-specification Chemistry results.
Some of these instances are failure to notify the Shift Supervisor for each sample for a continuing condition, specifically the pH depression.
These deficiencies are procedurally related because CHM-508, Revision 0, required the notification of the Shift Supervisor but did not require documentation of this notification on the data sheet. Also data sheet CHM-508-1 did not require identification of out-of-specification conditions or notification of the Shift Supervisor. CHM-501, Revision 0, did not require immediate notification of the Shift Supervisor upon verification of an out-of-specification condition and the time of notification be recorded on the appropriate data sheet. This problem is aggravated by the listing of Mode 1 limits on data sheet CHM-501-1 for steam generators so it is not readily apparent which values are out-of-specification. This is a contributing factor to personnel errors during shutdown conditions.
2.
Corrective Action Taken:
The data sheets are being revised to show the appropriate limits '
the applicable condition.
 
'NRC-Notice of Violation Item A (445/85A4-V-01)
-)
(Continued)
CHM-508 has been revised to include the requirement to immediately notify the Shift Supervisor in the event of an out-of-specification-condition and to document this notification on the data sheets.
3.
Corrective Steps to Avoid Recurrence:
J The corrective action,-with Chemistry section personnel training-should prevent this part of the Violation from reoccuring.
4.
Date of Full Compliance:
1 CHM-508 was revised October 15, 1984.
Chemistry data sheets (forms) will be revised by June 1, 1986.
1 Part 3 1.
Reatgn for Violation:
Investigation confirms that the Chemistry data sheets do not typically indicate the corrective actions taken for out-of,
specification chemistry.
i This deficiency is procedurally related because CHM-501 and CHM-508 indicate that the Chemistry Supervisor will investigate out-of-specification chemistry and determine the corrective action to be taken. There is no guidance to document corrective actions in other administrative procedures or on the data sheets.
This deficiency was also identified in TUGC0 Corporate QA Audit TUG-76 as Deficiency No. 1.
I 2.
Corrective Action Taken:
Guidance provided by the revised procedure CHM-104 provides necessary corrective action. This corrective action was the result of TUGC0 QA Audit TUG-76.
J 3.
Corrective Steps to Avoid Recurrence:
The training provided under the Part 1 Preventive Action should
)
prevent this deficiency from reoccurring.
4.
Date of Full Compliance:
1 Procedure CHM-104 was revised on May 24,, 1985. Personnel training was completed on January 9, 1986.
q
)
)
i
 
NRC Notice of Violation Item A (445/8514-V-01)
(Continued) l' Part,4 1.
Reason for Violation:
CHM-101, Revision 1 (5-12-82), " Chemistry / Radiochemistry Administrative Control," states that records produced by. technicians shall be independently reviewed by a qualified person and forwarded to the Chemistry and Environmental Engineer or his designee for approval.
CHM-101, Revision 2 (12-8-83), states that Chemistry and Environmental Supervisors are responsible for reviewing data sheets and that Staff Chemists are responsible for approving data sheets.
2.
Corrective Action Taken:
A qualified person will review all past CHM-501-1 and CHM-508-1 data sheets. This review will be performed to determine if there is any significant chemistry concern indicated which has not been 4
identified and resolved. Also, a representative selection based on the number of records generated from other procedures utilized during the Jcnuary 1983 to September 1985 time period will be reviewed.
If similar problems are found to exist in the selected records, then a full review will be conducted.
Deficient or nonconforming conditions discovered during these reviews will be documented in accordance with station procedures.
3.
Corrective Steps to Avoid Recurrence:
All Chemistry and Environmental Supervisors and Staff Chemists have been reminded of their administrative responsibilities.
i 4.
Date of Full Compliance:
l All required document reviews will be complete by August 1, 1986.
- - -. _. _ -. _-____-.i
 
Notice of Violation
~
Item B (446/8511-V-01)
Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0
~
Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Paragraphs 2.3 and 3.1.1.1 of Brown & Root (B&R) Procedure CQ-QAP-16.2, Revision 25, require that nonconformances be identified, documented by completing the NCR form, and dispositioned. Paragraph 3.19.5.2 of B&R i
Procedure CP-CPM 6.90, Revision 6, states, in part, with respect to NCRs for minimum wall violations, ".
.. Welding engineering shall review the conditions stated on the NCR...."
Contrary to the above, repair of a minimum wall violation associated with weld 21-2 in component CC-2-RB-053 was noted on October 9, 1985, from record review to have been performed without documenting the j
condition on an NCR form.
Response to Item B 1.
Reason for Violation:
A QC Inspector failed to follow QI-QAP-11.1-26 which requires the initiation of a Nonconformance Report (NRC) for minimum wall violation (MWV).
2.
Corrective Action Taken:
A review was conducted to determine the method used to identify and correct the MWV and concluded that the repair process used was technically adequate and would not have been altered regardless of the document used to record the MWV (i.e., Unsatisfactory IR attribute vs NCR).
While we believe that the violation is a iso-lated occurence we are confident that any other similar minimum wall violation would have been likewise adequately dispositioned.
j l
3.
Corrective Steps to Avoid Recurrence:
i
)
All applicable QE's and QC Inspectors were retrained in the speci-i l
I fic QI-QAP-11.1-26 program requirements relative to welded repairs associated with MWV's. Additionally, construction proce-
{
dure CP-CPM-6.9D will be revised to clarify the requirement that an i
NCR must be generated whenever a MWV is identified.
Appropriate
)
Weld Engineering personnel will be trained to the revised j
CP-CPM-6.9D requirements.
4.
Date of Full Compliance:
May 16, 1986.
_a
 
Notice of Violation j
Item C (446/8511-y-02)
Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that j
activities affecting quality shall, be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these l
instructions, procedures, or drawings.
{
Paragraphs 3.1.1.1 of B&R Procedure DCP-3, Revision 18, states, in part,
... Issuance and receipt of controlled design changes are documented on the Document Distribution tog...
by signature or initial of the j
file custodian and dated." Paragraph 3.2.2.5 of this procedure j
additionally requires that the face of a retained superseded document must be stamped "V0ID."
Contrary to the above: -
1.
Satellite document control center 307 was noted on October 14, 1985, to be in possession of a controlled copy of Component Modification Card 96181 for which receipt had not been signed for and dated on the Document Distribution Log.
2.
A copy of superseded Design Change Authorization (DCA) 21446, Revision 0, was noted on the same date to be present in two packages for Drawings 2323-El-1702, Sheet 002, Revision 2.
Both copies of DCA 21446, Revision 0, were not stamped " VOID" on the face of the document.
Response to Item C - No. 1 1.
Reason for Violation:
Failure to properly implement procedure.
2.
Corrective Action Taken:
The Document Distribution Log was corrected by the inclusion of proper initial and date. The Document Distribution Log was reviewed and there were no other violations of this nature identified.
3.
Corrective Steps to Avoid Recurrence:
1 Appropriate DCC personnel were reinstructed in the proper receipt acknowledgement of design changes. DCP-3 rev. 19 paragraph 3.1.1.1 includes verification responsibilities by DCC personnel to ensure acknowledgment of design changes is documented.
Date of Full Compliance:
March 31, 1986.
 
9-L l-r-
Notice of Violation Item C (446/8511-V-02)~
(Continued)
Response to Item C - No. 2 1.-
Re{sonforViolation:
' Failure to pr.operly implement procedure.
2.
Corrective Action Taken:
The drawing package contents were immediately corrected..It was determined that the drawing was not used in the performance of.
plant work. Monitoring a sample of drawing package centents revealed that no' drawings or design changes were.found to be out of revision.
3..
Corrective Steps to. Avoid Recurrence:
Personnel were reinstructed in the need to assure up-to-date contents in drawing packages, including the marking of superseded drawings as " void".
4.
Date of full Compliance:
April 1, 1986.
.)
'1 1
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. ; 8!
t-
.,n b n t s
 
l
~
Notice of Violation Item D (446/8511-V-03)
Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP, 2
Section 5.0, Revision 3, dated July 31, 1984, requires that activities f
affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Section 17.1.17 of the Final Safety Analysis Report, Volume XIV, Amendment 50, dated July 13, 1984, commits to procedures requiring that records be controlled and accounted for during transfer between organizations.
Contrary to the above, original sole copy design records were ascertained on October 16, 1985, to have been shipped to Stone and Webster Engineering Corporation, New York, without the establishment and implementation of procedures that address required control and intientory measures.
Response to Item D 4
1.
Reason for Violation:
Conditions noted in the violation are the result of a failure to follow established procedures for control of engineering documents.
TUGC0 Nuclear Engineering (TNE) Procedure THE-AD-4 specifies that duplicate copies of engineering documents prepared or processed by TNE shall be maintained at the site or Gibbs & Hill /New York, as applicable.
In 1985, Stone & Webster Engineering Corporation (SWEC) assumed design responsibility for pipe supports.
In order to consider and incorporate, where possible, existing information into SWEC designs, TUGC0 initiated shipment of pipe support design records offsite.
2.
Corrective Action Taken:
Measures to establish compliance with TNE procedure TNE-AD-4 and subordinate TNE instruction THE-AD-4-6 (issued specifically for transmittal and duplicate retention of pipe support calculations) have been implemented for pipe support records previously forwarded to SWEC. These efforts, involving the return of copies and complete accountability, were completed in February 1986.
3.
Corrective Steps to Avoid Recurrence:
THE-AD-4-6 was issued :Lvember 25, 1985, establishing a program for transmittal requirn;:,
for pipe support design records.
In be reviewed and revised, if required, to addition, TNE-AD-4 assure the adequac;.
lasures prescribing the offsite transmittal of engineering dom i
f
 
.j..
4 Notice of Violation-Item D (446/8511-V-02).
(Continued) l 4.
Date of Full Compliance:
As noted in items 2 and'3, all measures have been completed with the exception of the review / revision of. Procedure TNE-AD-4.
These measures will be accomplished no later than May 22,.1986.
I i
2 9
j
<,;cw -
1
 
Notice of Violation item E (446/8514-y-03)
Criterion VI of Appendix B to 10 CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative and Quality Assurance Plan, requires that (1) measures shall be established to control the
' issuance of documents such as drawings, including changes thereto; and j
(2) the measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel.
(
. Paragraphs 2 and 4 in Revisions 7 and 8 of Station Administration Manual Procedure No. STA-405 require 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.
Paragraph 4.0 in Revision 0 of Nuclear Operations Engineering Manual Instruction No.'N0E-201-5 requires that proposed drawing changes be submitted to the Operations Superintendent for review, approval, an(
authorization to distribute the revised drawings.
Contrary to the above, nine-as-built drawings were revised and distributed by TUGC0 Nuclear Engineering to reflect NCR identified undersize welds, without receiving TUGC0 Operations review, approval, and authorization to distribute the revised drawings.
Response to Item E 1.
Reason for Violation:
The condition noted in the violation is the result of the issue of pipe support drawings by TNE documenting acceptance of "Use-As-Is" conditions prior to the proper disposition of several TUGC0 Operations' NCR's.
Prior approval of drawings which document the "Use-As-Is" disposition of NCR's by TUGC0 Operations is a requirement of Station Administration Manual Procedure STA-405.
Please note the following in regards to Appendix "A", item E, third paragraph of the subject NRC Inspection Report.
Procedure N0E-201-5 does not require "non-vital" drawings, such as BRH (pipe support) drawings be submitted to the TUGC0 Operations i Superintendent prior to issue by PSE (Pipe Support Engineering).
However, the generic issue of whether such drawings should be classified as " vital" and therefore be submitted to the TUGC0 Operations Superintendent is being processed by TUGC0 Deficiency Report (DR-86-007) whose disposition is yet outstanding.
2.
Corrective Action Taken:
The pipe support drawings noted in the finding were subsequently reviewed by TUGC0 Operations. Approval has been C ated by closure of the corresponding TUGC0 Operations' NCr "capleted December 19, 1985.
 
.n Notice of Violation Item E (446/8511-V-02)
(Continued) 3.
Corrective ~ Steps to Avoid Recurrence:
As a result of this specific finding, TNE Procedure TNE-AD-4-5 Revision I was issued November 11, 1985. Procedures which describe
.TNE and TUGC0 Operations interface arrangements applicable to pipe supports were reviewed to assure consistency. No addit,ional conflicts.were noted. Adherence to these interface requirements should preclude further violations of this nature.
4.
Date of Full Compliance:
As noted above,. full compliance has been achieved.
r u-
 
Notice of Violation Item-F (446/8514-V-04)
Criterion V.'of Appendix B to 10 CFR Part 50. as implemented by TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed'by documented instructions, procedures, or drawings of:a type appropriate to the circumstances and
-shall-be. accomplished in accordance with these instructions, procedures, or drawings.
Paragraph 3.0 of Procedure CP-QP-2.1, Revision 14, dated October 17, 1983, states in part, "... inspection personnel.... shall have-
, experience in and shall have completed a technical training course and examination in the area of inspection responsibilities." Paragraph 3.7 of this procedure states,Lin part, "... Inspection personnel shall be certified by the TUGC0 site QA supervisor as being qualified to perform their assigned tasks.",
Contrary to the above, it was noted on October 21, 1985, during review of i
documentation for Class IE lighting system conduit EAB1-1 that the electrical. inspector, who had signed inspection reports E-1-0024951 and E-1-0027419, had not been certified to the applicable Procedure QI-QP-11.2-25, Revision 17, dated February 13, 1984, " Inspection of New Installations for Class IE Lighting Systems.''
Response to Item F 1.
Reason for Violation:
Oversight by QC Supervision which allowed the inspector in question to inspect to QI-QP-11.3-25 prior to final sign-off of his certification.
2.
Corrective Action Taken:
NCR E-85-101639 was initiated to address this violation.
In addition, 800-Inspection Reports completed by 163 QC Inspectors during the past six months were. reviewed to determine if further violations of this nature had occured. All of the reports reviewed were completed by QC Inspectors certified to the activity inspected.
3.
Corrective Steps to Avoid Recurrence:
QC Supervision is issued a weekly list which identifies the certification capabilities and status of their personnel, for use in inspection assignments. Based upon the above review results this action is sufficient to avoid recurrence of this violation.
Inspections performed prior to June 1985 are subject to CPRT action item VII.c.
4.
Date of Full Compliance:
May 5, 1986.
W
 
' 1 Notice of Deviation a-item A (445/8514-D-01)
Section 4.1.6.of ERC Comanche' Peak Project Procedure (CPP) CPP-012, "QA/QC _Interf ace with Construction /TUGC0" states,
~"The.QA/QC Records Administrator controls requests for equipment / services:and distributes and controls requests for technical information."
Contrary to the above, the QA/QC Records Admi_nistrator does not receive copies of requests to provide for control of these documents (445/8514-0-01).
With respect to item A in the Notice of Deviation, the NRC has ascertained subsequent to this report period that ERC' logs for tracking of equipment / service requests have not been utilizing procedurally required unique numbers.for individual requests. Accordingly, please i
address this as part of.your response to item A in the Notice of.
Deviation.
Response to Item A 1.
Reason for Deviation:
As the NRC identified, the QA/QC Records Administrator does not control requests for equipment / services from the Constructor /TUGCO.
Due to a misunderstanding of the NRC's concern at the time of'the finding, it.was not explained that such requests are tracked by a computerized log maintained by the Inspection Supervisor or his designee.
Subsequent NRC investigation confirmed the presence of this tracking mechanism. Consequently, the original NRC concern was i
resolved.
However, the NRC inspector subsequently identified a related concern: the log did not show a unique number for each equipment / services request as required by CPP-012.
The function of the equipment / services tracking mechanism is to ensure that all necessary equipment / services (i.e. scaffolding, l
l painting or lagging removal, etc.) are installed or performed before inspection takes place and are maintained until inspection is completed. All open equipment / services requests (ESRs) are maintained in a folder associated with the verification package with which they are identified. The computer tracking mechanism tracks the status of the most recently opened ESR. This function is served satisfactorily by the mechanism currently in place (the same mechanism in place at the time of the NRC inspection).
Changes to the mechanism used to track open ESRs are not required
[
since no failures to perform the intended function exist. However i
1 procedure CPP-012 must reflect current practice.
 
NoBice of Deviation Item A (445/8514-D-01)
(Continued) 2.-
Corrective Action Taken:
ERC Comanche Peak Project Procedure CPP-012 was revised March 11; 1986, to remove reference to the ESR log.
3.
Corrective Steps to Avoid Recurrence:
'The action to correct the reported condition serves as action to prevent recurrence.
4.
Date of. Full Compliance:
j March 11, 1986.
1 i
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Notice of Deviation Item B (445/8514-D-02)
Section 4.1 of CPRT. Issue-Specific Action Plan (ISAP) No. VII.c Revision 0, dated June 21, 1985, states, in part,
... Where required, documentation reviews will be utilized to supplement the reinspection for attributes which are nonrecreatable or inaccessible...."
l Section 4.1.3 of the ISAP states, in part,
... The inspection procedure will provide detailed instructions to the-inspectors and/or documentation reviewers for performing the reinspection and/or documentation reviews..."
Contrary to the above, the following examples were noted of inadequate procedural guidance and document reviewer performance in regard to nonrecreatable and inaccessible attributes:
.1.
Quality Instruction (QI) Q1-013, Revision 4, lists no specific attributes, but instead specifies that the inspector verify installations in accordance with one or more of a listing of TUGC0 procedures; i.e., QI-QP-11.8.1, -5, -6, and -8.
The list of appropriate procedures does not, however, indicate the applicable revision number of each procedure.
In that the number of nonrecreatable or inaccessible inspection dttributes can vary from revision.to revision of a procedure (e.g. Revisions 0 and 1 of TUGC0 Procedure QI-QP-11.8-8), the absence of guidance on applicable procedure revision numbers does not constitute detailed instructions.
2.
During the documentation review of Verification Package No.
R-E-CDUT-064, in accordance with 01-009, Revision 0, there was no evidence that a documentation check was made of inaccessible attributes for conduit C13016037 that were caused by the installation of separation barrier material (445/8514-0-02).
Response to Item B j
1.
Investigation:
QI-013 " Documentation Review for Instrumentation Equipment /R-E-ININ" does not, in fact, list specific attributes for the inspector to verify. The purpose of the documentation review governed by 01-013 is to provide inspector qualification information as input to ISAP I.d.1.
The intent of QI-013 is to verify the inspector who signed the inspection report (IR) being reviewed was certified to the appropriate revision of the Quality Instruction (01) that was in place at the time of the inspection.
To do this the document reviewer records the inspector's name, the QI number, and the revision of the procedure noted-on the IR. Then the inspector certifications are reviewed to determine if the inspector was certified to the appropriate revision at the time of s'igning the IR.
a
 
m i
Notice of Deviation Item B (445/8514-0-01)
(Continued)
This is an appropriate way to verify inspector certifications.
Consequently, no deviating condition is believed to exist.
Regarding use of document reviews to supplement reinspection for inaccessible attributes, the NRC finding is correct, based on Revision 2 of the CPRT Program Plan. However, in the ensuing time period, Revision 3 of the CPRT Program Plan, including a revised ISAP VII.c was issued.
ISAP VII.c as now written dictates that, after the sixty inspections have been concluded for the population sample, any attributes which were found to be inaccessible will cause additional samples to be selected from the population and inspected only for those attributes which were inaccessible in preceding inspections.
Document review will only be used for non-recreatable attributes unless sixty occurrences of the attribute are not accessible from the population as a whole.
Consequently, the programmatic change.in Revision 3 resolved this finding.
2.
Corrective Action Taken:
No corrective action for. items 1 and 2 are planned.
3.
Corrective Steps to Avoid Recurrence:
No corrective steps for items 1 and 2 are applicable 4.
Date of Full Compliance:
February 24, 1986.
9 sc
 
.~
Notice of Deviation Item C (445/8514-D-03)
J QI-009,. Revision 0, "Occument Review of Conduit /R-E-CDUT", requires the
-ERC inspector to:
verify that ~ inspection reports signed by electrical inspectors.were dated after their date of certification and prior to their date of i
expiration, and, l
document.the SBN inspection report (IR) and/or. latest construction operation' traveler number at the bottom of the checklist.
H Contrary to the above:
Review of ERC accepted dc, cementation for conduit _ C14R13047 showed that the'.ERC inspector failed to. identify that the certification to the applicable Procedure QI-QP-11.3-23 had lapsed for the TUGCO-electrical inspector signing IR-E-46087.
The ERC completed inspection record checklist for conduit C13016037 4
in Verification Package'No. R-E-CDUT-064 did not contain documentation of the SBM IR or latest construction operation traveler number (445/8514-D-03).
1 Response to Item C 1.
Reason for Deviation:
A review of verification Package No. R-E-CDUT-064 and R-E-CDUT-070 confirmed-the NRC findings. This was determined to be an inspection error.
2.
Corrective Action Taken:
(DR) Deviation Report R-E-CDUT-070-ORI was written by the l
inspector.
The number for.the latest construction operation traveler was added to the applicable checklist on 11/21/85.
j The inspector was given additional training on 11/8/85.
Reinspection of 25% of this inspector's work involved 28 verification packages and was completed before 11/21/85.
The results of the 25% reinspection has been evaluated and based upon the minor nature of the discrepancies identified, no further actions was deemed necessary on the Inspector's past performance.
3.
Corrective Steps to Avoid Recurrence:
An overview Inspection Program has been implemented to reinspect a sample of each Inspector's work on a continuing basis. Action is l
ongoing to analyze results of the Overview Inspection program.
l gather pertinent insco L.v error data from other sources (NRC reinspection, etc.).
< to effect required additional formal i
l training of inspecto:
l l
 
l''
No% ice of Deviation-Item C (445/8514-D-01)
~
(Confinued).
4.
Date'of Full Complihnce:
Corrective action was completed by November 21, 1985.
Preventive action involves an ongoing program.
e.
e 9
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Item D (445/8514-D-01)
Notice of Deeiation Section 4 of CPP-009, Revision 3, states, in part, with respect to ISAP No. VII'.c, " Qualified QA/QC Review Team personnel perform field reinspecti~ons of specific hardware items and reviews of appropriate documents"in accordance with-approved instructions...."
Contrary to.the above, the following examples were noted where field reinspection of hardware items were not performed in accordance with approved instructions:
1.
Attribute 4.5 in Section 5.0 of Q1-055, Revision 0, states with c
respect to spring nuts, " Verify that the serrated grooves align with the channel clamping ridge." Checklists for support No. 0070 (Verification Package No. I-S-INSP-007)-and support No. 028 (Verification Package No. I-S-INSP-028) were signed by two separate ERC inspectors that this attribute was acceptable. NRC inspectors showed, however, that the spring nut serrated grooves did not align with the channel clamping ridge on both of these supports.
2.
Section 5.3.4.C in 01-027 states with respect to dimensional tolerances not shown on design drawings, " Component member length
+/-1/2 inch."
The bill of material on Revision 2 of drawing No. CT-1-097-402-C52R in Verification Package No. I-S-LBSR-023 shows item No. 4 (2 pieces) to be 7 3/4 inches long. The applicable inspection checklist.used during the ERC reinspection of this pipe support shows the installed configuration to be acceptable.
NRC inspect-tion determined, however, the actual length dimensions of the two pieces to be 6 5/8 inches and 6 1/2 inches, respectively, both of which are under the indicated minimum dimension of 7 1/4 inches.
3.
Section 5.0 in Q1-012 states, in part, " Verify that the piping / tubing and components... material agree with the Bill of Materials shown on the Instrument Installation Detail drawing.
Tubing is marked with longitudinal color coded marks for l
traceability.- Use applicable drawing to identify tubing...
Verify that the installed tubing has the proper slope.
The required slope for process wetted lines is one (1) inen per foot minimum. This slope requirement may be reduced to 1/4 inch per foot when physical layout is a problem. Verify that there is a proper air gap.
The minimum gap spacing shall always be 1/8 inch to allow each instrument sensing line to expand independently at all bends without striking adjacent sensing lines, other equipment, l
concrete or steel building members."
The applicable inspection checklist used during the ERC reinspection of instrumentation installation Verification Package No.
1-E-ININ-026 showed that the above attributes were inspected and accepted, as evidenced by the inspector's signoff (initials).
l i
 
r Notice of Deviation Item D (445/8514-D-D1 (Continued)
However, NRC inspection of the instrumentation installation revealed:
(a)
Six sections of tubing had no color coding for traceability; (b)
Ten sections of tubings, in which physical layout was not a problem, had slopes of 7/16 inch to less than 1/4 inch per.
foot and one section had reverse slope; and l
(c)
Two tubing sections had zero gap spacing between the high pressure and low pressure legs and the concrete penetration.
4.
Section 1.7 in QI-012 requires that: (a) tubing bend be verified to have a minimum radius of four times the normal tube size by using either a template, or by direct measurement calculations; and (b) the measured and calculated values be entered into the Minimum Bend Radius Record, with date and inspector's initials.
During NRC inspection of Verification Package No. I-E-ININ-04, equipment tag No. 1-FT-156, it was ncted that the inspection checklist was dated and initialed, attesting to the fact that the tubing bends had been verified as having a minimum radius of four times the nominal tube size. However, review of the applicable Minimum Bend Radius Record showed that the ERC inspector had neither measured and calculated, nor used a template to verify minimum bend radius.
In addition, the following notes had been entered by the ERC inspector:
"Ist 90' bend from instrument (hi &
lo side)... cannot be measured with existing tools.
Four (4) other bends visually more than 90* to accommodate slope" (445/8514-0-04).
e Response to Item D 1.
Reason for Deviation:
Reinspection confirmed the NRC findings.
item 1_and_2 Inspector error.
Item 3 Inspector Error. Ongoing adjacent construction and housekeeping activities (i.e., wiping down, climbing, ongoing work in I
 
O T
j
.o Notice of Deviation e
-Item D (445/8514-D-01 (Continued) j i.
surrounding areas,'etc.) prevent a firm determination as.to whether-or not the-NRC identified. findings existed at the time of the ERC
'inspectionibut, enough.i.ndication exists to justify' retraining of the, inspectors as a step to assure decertification of those items-a
-which may well have been inspector error.
y L
Item 4 l
Inspector error.. QI requires clarification to allow inspector to:
L indicate inaccessible bends.
2.
Corrective Action Taken:
J te_m_1 Deviation Reports I-S-INSP-007-DR2 and DR3 dated November 18, 1985, and I S-INSP-028-DR2 dated November 8, 1985, were written to,
document the misaligned spring nuts.
Twenty five percent of the work of both inspectors was reinspected.
1 The results of the. reinspection were documented and evaluated by 1
inspection supervision.
A decision was made to reinspect 100% of the spring nuts previously inspected by the first' inspector. The results of-the reinspection indicated a high error rate. This c.
inspector's services were discontinued and 100% of.his work was i
reinspected. The retained inspector was retrained on November 12, 1985.
All necessary reinspection were completed by December 5, 1985.
Deviating conditions identified by the reinspection have been documented in the applicable Verification Packages and DRs initiated.
A general training session on' Spring Nut inspection was given to all non-affected inspectors involved in the reinspection of this attribute. This retraining has been documented.
Item 2 Deviation Report I-S-LBSR-023-DR2 dated November 13, 1985, was written to document the dimensional deviations. The responsible inspector was the same one whose services were discontinued as indicated above, f
f Item 3 and 4 The Verification Package documentation for ININ-026 has been reinspected, I-E-ININ-004 was corrected, and DRs I-E-ININ-026-DR-2, t
 
e o Notice of Deviation l
Item D (445/8514-D-01 (Continued) c In addition, revision 1 of QI-012 was
-4, and -5 were issued.
and now provides a basis for the issued January 30, 1986, Due to problems noted inspectors to indi'cate inaccessible bends.
by ERC and those identified herein by the NRC, all ININ Verification Packages issued prior to January 14, 1986, will be reissued for reinspection.
3.
Corrective Steps to Avoid Recurrence:
An Overview Inspection program has been implemented to reinspect a Action is sample of each Inspector's work on a continuing basis.
ongoing to. analyze results of the Overview Inspection program, gather pertinent inspector error data from other sources (NRC l
reinspection,-etc.) and to effect required additional formal training of inspectors.
4.
Date of Full Compliance:
Corrective action is complete with the exception of the total reinspection of the ININ packages.
Preventive action involves an ongoing program.
1
 
.In Reply Refer To:
MAR 06 5 Dockets:
50-445/85-14 50-446/85-11 Texas Utilities Generating Company ATTN: Mr. W. G. Counsil Executive Vice President 400 North Olive,.L.B. 81 Dallas. Texas 75201 l
Gentlemen:
This refers to the inspection conducted by Mr. T. F. Westerman and other members of the Region IV Comanche Peak Group during the period September 30 through October 31, 1985, of activities covered by NRC Construction Permits CPPR-126 and CPPR-127 for the Comanche Peak Steam Electric Station, Units 1 and 2, and to the respective discussions of our findings with Messrs. J. B. George and. J. C. Kuykendall, and other members of your staff at the conclusion of the inspection.
Areas examined during the inspection included operations, construction. and Comanche Peak Response Team activities. An inspection was also performed by Region IV staff of Unit 2 cable tray support modifications during thir report period. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspectors.
These findings are documented in the enclosed inspection report.
During this inspection, it was found that certain of your activities were in violation of NRC requirements. Consequently, you are required to respond to these violations, in writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2. Title 10, Code of Federal Regulations.
Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter.
During this inspection, it was found that certain of your activities appeared to deviate from commitments made to the NRC. These items and references to the commitments are identified in the enclosed Notice of Deviation. You are requested to respond to these deviations in writing.
Your response should be based on the specifics contained in the Notice of Deviation enclosed with this letter.
With respect to item A in the Notice of Deviation, the NRC has ascertained subsequent to this report period that ERC logs for tracking of equipment / service reouests have not been utilizing procedurally required unique numbers for individual requests. Accordinly, please address this as part of your response to item A in the Notice of Deviation.
Y DRSP r NRR RIV: CPG / SRI / CON b iwST CPG CPG
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ihv IBarnes TFWesterman EHJohnson VSNoonan SHPhillipsq 3/3/86
/16 3
/86 W 3/86 3/g/86
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p.9 3 Texas Utilities Generating Company Twenty unresolved items are identified as follows in the enclosed inspection report: Appendix C, paragraph 4; Appendix 0, paragraphs 3.a, 3.c, 4.g, 5, 5.a, 5.c, 5.d, and 6; Appendix E, paragraphs 6.g. 6.h, 6.j, 7 a, 7.c, and 7.e.
We have also examined actions you have taken with regard to previously identified inspection findings. The status of these items is identified in paragraph 2 of Appendix C, paragraph 4 of Appendix D, and paragraph 2 of Appendix E of the enclosed report.
The responses directed by this letter and the accompanying Notices are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
/
origiaa; sidd 6y
: r. 4 Johns 0n f
E. H. Johnson, Director Division of Reactor Safety and Projects
 
==Enclosures:==
1.
Appendix A - Notice of Violation 2.
Appendix B - Notice of Deviation 3.
Appendix C - NRC.0perations Inspection Report
' 50 445/95-14 4.
Appendix D - NRC Construction Inspection Report 50-445/85-14 50-446/85-11 5.
Appendix E - NRC Ccmanche Peak Response Team Activities Inspection Report 50-445/85-14 r 50-446/85-11 6.
Appendix F - NP.C Cable Tray Modifications Inspections Report 50-446/85-11 cc w/ enclosures:
(See page 3) f 4
l
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i 4
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u
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i
- Texas Utilities Generating' Company.q j
cc w/ enclosures:
Texas Utilities Generating Company
' ATTN:-
J. W. Beck, Vice President
. Licensing, Quality' Assurance, u
and Nuclear Fuels Skyway Tower 1
..400 North Olive Street-Lock Box 81.
Dallas, Texas 75201 Juanita Ellis President'- CASE' 1426 Polk Street Dallas, Texas 75224 Renea Hicks Assistant Attorney General Environmental Protection Division P. 0.' Box 12548 Austin, Texas 76711 TEXAS STATE DEPARTMENT OF HEALTH bectoDMB(IE01) bec distrib. by RIV:-
*RPB
* MIS System
*RRI-OPS-
'*RSTS Operator
*RRI CONST
*R&SPB
*T. F. Westerman, CPTG ORSP V. Noonan, NRR R. Martin, RA S. Treby,-ELD
*RSB
*RIV File J. Taylor, IE
*D.' Weiss, LFMB (AR-2015)
R. Heishman, IE
*w/766 i
9 i
 
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*4 l
1 APPENDIX A NOTICE OF VIOLATION j
Texas Utilities Electric Company Dockets: 50-445/85-14
)
50-446/85-11 1
Comanche Peak Steam Electric Permits: CPPR-126 Station, Units 1 and 2 CPPR-127 1
During an NRC inspection conducted on October 1-31, 1985, six violations of NRC requirements were identified.
The violations involved failure to maintain sufficient chemistry records, a minimum wall violation not being documented on a nonconformance report (NCR), inadequate issue control for design documents, absence of procedures for controlling offsite shipment of original design records, signing of inspection reports by a noncertified electrical inspector, and revision of drawings without required review and approval actions.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below:
A.
Criterion XVII of Appendix B to 10 CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative Control and Quality Assurance Plan, requires that (1) sufficient records shah be maintained to furnish evidence of activities' affecting quality, and (2) that the records shall include the results and acceptability of tests and analyses, and the action taken in connection with any deficiencies noted.
Contrary to the above:
1.
A.significant number of instances of missing data entries was noted in water chemistry records covering the period March 1983 through September 1985, with respect to the chemistry sampling frequency requirements of Procedures CHM-501, " Chemistry Control of the Steam Generators," and CHM-508, " Chemistry Control of the Primary Cooling Water Systems." No annotations were made in the records to explain why the samples were not taken.
2.
Review of the water chemistry records showed instances of failure to make required entries to indicate when the Shift Supervicor was notified in regard to out-of-specification chemistry results.
3.
The records did not identify what corrective actions were taken after entry of out-of-specification results.
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3 4.
Inadequate reviews were performed of.the acceptability of water chemistry data, as eviden ed by the presence of review and approval signatures on forms containing discrepant data results, This is a Severity Level IV violation (Supplement II) (445/8514-V-01).
1 g
B.
Criterion V 6f Appendix B to 10 CFR Part 50', as implemented by TUGC0 Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be i
prescribed by documented instructions, orocedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Paragraphs 2.3 and 3.1.1.1 of Brown and Root (B&R) Procedure CQ-QAP-16.2, l
Revision 25, require that nonconformances be identified, documented by completing the NCR form, and dispositioned. Paragraph 3.19.5.2 of B&R Procedure CP-CPM 6.9D, Revision 6, states, in part, with respect to NCRs for minimum wall violations, "... Welding engineering shall review the conditions stated on the NCR...."
Contrary to the above, repair of a ininimum wall violation associated with weld 21-2 in component CC-2-RB-053 was noted on October 9, 1985, from recoret review to have been performed without documenting the condition on an NCR form.
This is a Severity Level IV violation (Supplement II) (446/8511-V-01).
C.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, Section 5.0, Pevision 3, dated July 31, 1984, requires that activities affecting quaiity shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings, t
Paragraph 3.1.1.1 of B&R Procedure DCP-3, Revision 18, states, in part,
"... Issuance and receipt of cortrolled design changes are documented on the Document Distribution Log... by signature or initial of the file custodian and dated." Paragraph 3.2.2.5 of this procedure additionally requires that the face of a retained superseded document must be stamped j
" VOID."
Contrary to the above:
1.
Satellite document control center 307 was noted on October 14, 1985, to be in possession of a controlled copy of Component Modification Card 96181 for which receipt had not been signed for and dated on the Document Distribution Log.
4
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A',' copy of superseded Design Change Authorization (DCA) 21446, Re' vision 0, was noted on the same date to be present in two packages for Drawing 2323-El-1702, Sheet 002, Revision 2.
Both copies of l-DCA.21446, Revision 0,-were not stamped " VOID" on the face of the document.
This is a Severity Level IV violation (Supplement II)
(446/8511-V-02).
Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 Y QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or dra ings of a type appropriate to the circumstances and'shall be accomplished in accordance with these instructions, procedures, or drawings.
Section 17.1.17 of the Final Safety Analysis Report, Volume XIV, Amendmert 50, dated July 13, 1984, commits to procedures requiring that i
records be controlled and accounted for during transfer between
)
organizations.
Contrary to the above, original sole copy design records were ascertained
)
on October 16, 1985, to have been shipped to Stone and Webster Engineering Corporation, New York, without the establishment and implementation of j
procedures that address required control and inventory measures.
This is a Severity Level IV violation (Supplement II) (445/8514-V-02, 446/8511-V-03).
E.
Criterion VI of Appendix B to 10 CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative and Quality i
Assurance Plan, requires that (1) measures shall be established to control the issuance of documents such as drawings, including changes thereto; and (2) the measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel.
Paragraphs 2 and 4 in Revisions 7 and 8 of Station Administration Manual Procedure No. STA-405 require 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.
Paragraph 4.0 in Revision 0 of N nlear Operations Engineering Manual Instruction No. N0E-201-5 requires that proposed drawing changes be submitted to the Operations Superintendent for review, approval, and authorization to distribute the revised drawing.
i
 
j c.;
: Contrary to the above, nine as-built drawings were revised and. distributed I
by TUGC0 Nuclear Engineering to reflect NCR identified undersize welds, without receiving TUCG0 Operations review, approval, and authorization to distribute the revised drawings.
1 This is a Severity Level IV violation (Supplement II) (445/8514-Y-03).
F.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0
'QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Paragraph 3.0 of Procedure CP-QP-2.1, Revision 14, dated October 17, 1983, states, in part, "... inspection personnel... shall have experience in
.and shall have completed a technical training-course and examination in the area of inspection responsibilities." Paragraph 3.7 of this procedure states, in part, "... Inspection personnel shall be certified by the TUGC0 site QA supervisor as being qualified to perform their assigned tasks."
Contrary to the above, it was noted on October 21, 1985, during review of documentation for Class 1E lighting system conduit EAB1-1 that the electrical inspector, who had signed inspection reports E-1-0024951 and i
E-1-0027419, had not been certified to the applicable Procedure l
01-QP-11.2-25, Revision 17 dated February 13, 1984, " Inspection of New Installations for Class IE Lighting Systems."
This is a Severity Level IV violation (Supplement II) (445/8514-V-04).
Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric i
Company is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation:
(1) the reason for the violations if admitted (2) the corrective steps which have been taken and the results achieved. (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.
Dated at Arlington, Texas this 6th day of March, 1986.
 
_y u #1 y c
Y APPENDIX B NOTICE OF DEVIATION Texas Utilities Electric Company Dockets:- 50-445/85-14 50-446/85-11 Comanche Peak Steam Electric Permits: CPPR-126 CPPR-127 Station,-Units 1 and 2 Based on the results of an NRC' inspection conducted during.the period of October 1 through 31, 1985, of Comanche Peak Response Team (CPRT) activities, four deviations from commitments to the NRC were identified. The deviations involved ERC equipment / service requests not being controlled as committed, inadequate ERC document review and procedure criteria with respect to inspection attributes that are inaccessible or nonrecreatable, failure of ERC document reviews to both detect a lapsed electrical inspector certification and i
to record required information in a verification package, and inspection attributes being attested to as acceptable by ERC inspectors which were found
-by subsequent NRC inspection to be unacceptable.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"-
10 CFR Part 2, Appendix C.(1985), the deviations are listed below' t
- A.
Section 4.1.6 of ERC Comanche Peak Project Procedure (CPP) CPP-012, "QA/QC l
Interface with Constructor /TUGCO," states, "The QA/QC Records Administrator controls requests for equipment / services and distributes and controls requests for technical information."
Contrary to the above,.the QA/QC Records Administrator does not receive copies of requests to provide for control of these documents t
(445/8514-D-01).
B.
Section 4.1 of CPRT Issue-Specific Action Plan (ISAP) No. VII.C, Revision 0, dated June 21, 1985, states, in part, "... Where required, documentation reviews will be utilized to supplement the reinspection for attributes which are nonrecreatable or inaccessible...."
Section 4.1.3 of the ISAP states, in part, "... The inspection procedure will provide detailed instructions to the inspectors and/or documentation i
reviewers for performing the reinspection and/or documentation reviews Contrary to the above, the following examplis were noted of inadequate procedural guidance and document reviewer performance in regard to nonrecreatable and inaccessible attributes:
gDR ADOCR 05000445 PDR
_ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __j
 
't i
. 1.
Quality Instruction (QI) QI-013, Revision 4, lists no specific attributes, but instead specifies that the inspector verify installations in accordance with one or more of a listing of TUGC0 procedures; i.e., QI-QP-11.8-1, -5, -6, and -8.
The list of appropriate procedures does not, however, indicate the applicable revision number of each procedure.
In that the number of nonrecreatable or inaccessible inspection attributes can vary frv; revision to revision of a procedure (e.g., Revisions 0 an6 1 of 7t,Jr,U Procedure QI-QP-11.8-8), the absence of guidance on applicable procedure revision numbers does not constitute detailed instructn.71.
2.
During the documentation review of Verification Package No. R-E-CDUT-064, in accordance with QI-009, Revision 0, there was no evidence that a documentation check was made of inaccessible attributes for conduit C13016037 that were caused by the installation of separation barrier material (445/8514-D-02).
C.
QI-009, Revision 0, " Document Review of Conduit /R-E-CDUT," requires the ERC inspector to: (1) verify that inspection reports signed by electrical inspectors were dated after their date of certification and prior to their date of expiration, and (2) document the SBM inspection report (IR) and/or latest construction operation traveler number at the bottom of the checklist.
Contrary to the above:
l.
Review of ERC accepted documentation for conduit C14R13047 showed that the ERC inspector failed to identify that the certification to the applicable Procedure QI-QP-11.3-23 had lapsed for the TUGC0 electrical inspector signing IR-E-46087.
2.
The ERC completed inspection record checklist for conduit C13016037 in Verification Package No. R-E-CDUT-064 did not contain documentation of the SBM IR or latest construction operation traveler number (445/8514-0-03).
D.
Section 4 of CPP-009, Revision 3, states, in part, with respect to ISAP No. VII.c, " Qualified QA/QC Review Team personnel perform field reinspection of specific hardware items and reviews of appropriate documents in accordance with approved instructions...."
Contrary to the above, the following examples were noted where field reinspection of hardware items were not performed in accordance with approved instructions:
1.
Attribute 4.5 in Section 5.0 of QI-055, Revision 0, states with respect to spring nuts, " Verify that the serrated grooves align with the channel clamping ridge." Checklists for support No. 0070
 
t 3
. (Verification Package No. I-S-INSP-007) and support No. 028 (Verification Package No, I-S-INSP-028) were signed by two separate ERC inspectors that this attribute was acceptable.
NRC inspections showed, however, that the spring nut serrated grooves did not align j
with the channel clamping ridge,on both of these supports.
j 1
ect to dimensional Section 5.3.4.C in QI-027 states with resp' Component member length j
2.
tolerances not shown on design drawings,
+/-1/2 inch."
The bill of material on Revision 2 of drawing No. CT-1-097-402-C52R in Verification Package No. I-S-LBSR-023 shows item No. 4 (2 pieces) to be 7 3/4 inches long. The applicable inspection checklist used during the ERC reinspection of this pipe support shows the installed configuration to be acceptable.
NRC inspection determined, however, the actual length dimensions of the two pieces to be 6 5/8 inches and F 1/2 inches, respectively, bott of which are under the indicated minimum dimension of 7 1/4 inches.
3.
Section 5.0 in QI-012 states, in part, " Verify that the piping / tubing and components... material agree with the Bill of Materials shown on the Instrument Installation Detail drawing.
Tubing is marked with I
longitudinal color coded marks for traceability. Use applicable drawing to identify tubing... Verify that the installed tubing has the proper slope. The required slope for process wetted lines is one (1) inch per foot minimum.
This slope requirement may be reduced to 1/4 inch per foot when physical layout is a problem.
Verify that there is a proper air gap.
The minimum gap spacing shall always be 1/8 inch to allow each instrument sensing line to expand independently at all bends without striking adjacent sensing lines, other equipment, concrete or steel building members."
The applicable inspection checklist used during the ERC reinspection of instrumentation installation Verification Package No. 1-E-ININ-026 k
showed that the above attributes were inspected and accepted, as I
evidenced by the inspector's signoff (initials).
l l
However, NRC inspection of the instrumentation installation revealed:
(a) Six sections of tubing had no co.
aing for traceability; I
(b) Ten sections of tubings, in which phys'ical layout was not a problem, had slopes of 7/16 inch to less than 1/4 inch per foot and one section had reverse slope; and
{
(c) Two tubing sections had zero gap spacing between the high pressure and low pressure legs and the concrete pentration.
l l
 
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p,
4.
Section 1.7 in QI-012 requires that:
(a) tubing bends be verified to I
have a minimum radius of four times the nominal tube size by using I
either a template, or by direct measurement and calculations; and (b) the measured and calculated values be entered into the Minimum Bend Radius Record, with date and inspector's initials..
During NRC inspection of Verification Package No. I-E-ININ-04, equipment tag No.1-FT-156, it was noted that the inspection chec(list was dated and initialed, attesting to the fact that the tubing bends had been verified as having a minimum radius of four times the nominal tube size. However, review of the applicable Minimum Bend Radius Record showed that the ERC inspector had neither measured and calculated, nor used a template to verify minimum bend radius.
In addition, the following notes had been entered by the ERC inspector: "1st 90' bend from instrument (hi & lo side)... cannot be measured with existing tools. Four (4) other bends visually more than 90' to accommodate slope" (445/8514-0-04).
Texas Utilities Electric Company is hereby required to submit to this office, within 30 days of the date of this Notice of Deviation, a written statement or explanation in reply, including for each deviation:
(1) the reason for the deviations if admitted,- (2) the corrective steps which have been taken and the results achieved, (3) corrective steps which will be taken to avoid further deviation from commitments made to the Commission, and (4) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
Dated at Arlington, Texas, this 6th day of March, 1986 d
1 l
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'*g 1
J APPENDIX C
]
OPERATIONS INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION REGION IV i
NRC Inspection Report:
50-445/85-14 Permit: CPPR-126 Docket:
50-445 Category:
A2 Apolicant:
Texas Utilities Electric Company (TUEC)
Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES), Unit 1 Inspection At: Glen Rose, Texas Inspection Conducted:
October 1-31, 1985 Inspectors hs '
/Nu 7/7 PI D.
'. ' Kelley, Seqior R ent Reactor Inspector Date /
(SRRI), Region /IV C Group (paragraphs 1,5, 7,
)
i 2.fL f f6 8
W. F. Smith, Resident Reactor Inspector (RRI)
Fat'e
~
Region IV CPSES Group (paragraphs 1, 2, 3, 4, 5, 6, 7, 8)
Reviewed By:
[%
3/3/N I. Barnes, Group Leader, Region IV CPSES Group Date 1
7N 3/1/ F6 Approved:
6 T. F. Westerman, Chief, Region IV 6.U.S Group Date f
{
lsPiss#Im, j'if PDR 1
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Inspection Summary Inspection Conducted:
October 1-31,1985(Report 50-445/85-14)
Areas Inspected:
Routine, unannounced inspection of (1) applicant actions on previous inspection findings, (2) maintenance procedures, (3) preventive maintenance programs, (4) plant tours, and (5) plant status. The inspection involved 117 inspector-hours onsite by two NRC inspectors.
J t
Results: Within the five areas inspected, one violation (failure to maintain sufficient chemistry records, paragraph 4) was identified.
i I
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- - ~ - - ~
: a. _
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. DETAILS 1.-
Persons, Contacted Applicant Personnel
*A. B. Scott, Vice President Operations
*J. C. Kuykendall, Vice President
*C. H. Welch, Quality Control Services Supervisor
*R. B. Seidel, Operations Superintendent S. N. Franks, Special Project and Technical
' Support Lead i
*M. R. Blevins, Maintenance Superintendent D. E. Deviney, Operations QA Supervisor
*R. A. Jones, Manager, Plant Operations K. L. Luken, Lead Startup Engineer
*R. R. Wistrand, Administrative Superintendent
*D. W. Braswell, Engineering Superintendent
*J. C. Smith, Quality Assurance
*T. L. Gosdin, Support Services Superintendent
*G. M. McGrath, Licensing / Compliance Supervisor, Startup
*M. J. Riggs, Operations. Support Engineer D. M. Jones, Maintenance Engineering Technician L. Parr, Maintenance Engineer K. Stenburg, Maintenance Engineer T. Justis,. Maintenance Engineer H. Haby, Instrumentation & Controls Staff Engineer W. Jones, Instrumentation & Controls Staff Engineer B. Taylor, Instrumentation & Controls Engineer R. D.. Delano, Chemistry & Environmental Engineer G. B. Moore, Chemistry & Environmental Supervisor R. L. Theimer., Chemistry Supervisor
* Denotes applicant representatives present during exit interview of paragraph 8.
4 The NRC inspectors also interviewed other applicant employees during this inspection period.
i i
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- = - - - -
s 1
2.
Applicant Actions on Previous Inspection Findings a.
(Closed) Open Item 445/8436-05: Applicant to provide a response manual for the loose parts monitoring system.
In Section 5.4.3 of the Safety Evaluation Report (July 1981), the staff indicated acceptance of the applicant's loose parts monitoring system. The SRRI issued Open Item 445/8436-05 to track the applicant'c issuance of a response manual for the loose parts monitoring system.
On October 10, 1985, EDA-310, " Analysis of Loose Parts Monitoring System Data" was issued, which provides instructions for use of the system.
This item is closed.
b.
(Closed) Open Item 445/8502-01: Voiding of signatures in.
preoperational test data packages.
During routine i1spections of completed preoperational test data packages, the RRI noted inconsistencies in the methods used by System Test Engineers (STEs) to void or supersede previous signatures when test steps had to be repeated.
Section 4.8 of CP-SAP-21 required the STEs to void entries by lining through and signing (or initia111ng) the line-outs and l
dating them.
Sometimes the STE failed to sign and date the line-out, thereby casting doubt on the part of a reviewer as to whether the signature was for the line-out or for reperformance of the step.
The RRI suggested that a more straight-forward method of superseding such steps be considered. The applicant has since responded that the i
requirements of CP-SAP-21 will not be changed; thus the STEs will be expected to comply with Section 4.8 when voiding signatures.
This item is closed.
c.
(Closed).0 pen Item 445/8502-02:
Unclear justifications for test procedure deviations (changes). While reviewing completed preoperational test data packages, the RRI identified a number of cases where the STE did not enter a clear and concise reason or 1
justification for making minor changes to test procedures, which are l
called test procedure deviations (TPDs).
It appeared that if more specific direction was provided in Startup Administrative Procedure CP-SAP-12, " Deviations to Test Instructions / Procedures," this problem might not have existed. The applicant has since issued Revision 3 of CP-SAP-12 which directs the TPD author to enter a detailed justification for each change.
The RRI reviewed the re, vised procedure and is satisfied with the change.
This item is closed, d.
(Closed) Open Item 445/8502-03: Post-completion changes to test t
* documentation. During an inspection of completed preoperational test data packages, the RRI identified what appeared to be post-completion changes to test procedures using test deficiency reports (TDRs) as the authorizing document.
Although this practice did not have any adverse effects on the test records, administrative procedures did not provide for such changes. The applicant's response to this item
 
4 1
a g
{
i was that test data packages were not being " revised or changed" by TDRs, per se, but rather were being " annotated" to show the correct information found during the data package review which was in turn documented and evaluated by the TDR. This concern is being addressed i
by recent changes to the Startup Administrative Procedures Manual to
{
clarify the entry of corrections during completed test data reviews.
For example, on July 8,1985, Revision 6 to CP-SAP-11, " Review, Approval, and Retention of Test Results," was issued.
The revised administrative procedure now requires the Joint Test Group (JTG) to document test data review comments and resolutions, and to include this with the supporting documentation in the completed test data package. This will provide a means by which problems found during the JTG review of test data can be documented along with the JTG-approved disposition.
The TDR will still be utilized to document bonafide deficiencies and corrective actions (including retesting, if any); however, the applicant has indicated that changes or revisions will not be made against completed test procedures.
This item is l
closed.
.e.
(Closed) Unresolved Item 445/8502-08:
Discontinuity between reference drawing revisions in similar test procedures. While conducting an inspection of the completed preoperational test data package for 1CP-PT-29-03, Retest (RT)-2, the NRC inspector noted that the list of reference drawings contained later revisions of the same drawings referred to in 1CP-PT-29-03, RT-1, which was conducted later than RT-2.
The issue was whether or not failure to update the
]
references for ICP-PT-29-02, RT-1 had any affect on test performance.
After the question was raised, the applicant responded by explaining that RT-1 did not have the correct revision numbers; however, since
.the objective of both tests was to start and load test the emergency diesel generators, the revisions of the reference drawings had no significance and thus did not affect the outcome nor the objectives of the test.
The applicant filed a copy of the response and explanation as a supplement to the completed test data packages for ICP-PT-29-03, RT-1 and RT-2 for future reference. This item is
: closed, j
f.
(Closed) Open Item 445/8502-11: During an inspection of the completed preoperational test data package for ICP-PT-57-10, " Load Group Assignment," the SRRI noted that TOR-3676 had identified a failure to accomplish the slow transfer of train B bus 1EA2 when initiated by the test procedure.
Under corrective action, the TDR referenced Maintenance Action Request (MAR) 84-4036 to repair and/or adjust the auxiliary switches and actuating bar at a later date.
Meanwhile, per the TDR, the switches were placed in the required position manually so that the test could be resumed, including a repeat of the slow transfer test, which was successful. The MAR and MAR retest documents were not in the test data package.
Subsequent
 
n
. l RRI review of the completed MAR revealed that the actuating bar was in need of lubrication and operated freely once lubricated.
The applicant's representatives explained that the state of the auxiliary.
i
-switches was in a condition required for accomplishment'of the test i
l and that testing of this breaker was not an objective of the test; thus, it was not necessary to repeat the applicable section of 1CP-PT-57-10 after the actuating bar was lubricated and successfully
]
exercised. This item is closed.
g.-
(Closed) Open Item 445/8502-12:
Potential impact of reference drawing changes in preoperational test ICP-PT-57-10.
During the completed test data package review of ICP-PT-57-10 conducted by the applicant, TOR-3966 was issued identifying a failure to update the correct revision of 15 drawings referenced in the test procedure.
'The SRRI was concerned that no documentation existed in the completed test data package showing that an evaluation was made to determine the impact this might have on the test results. The RRI verified that the applicant had since conducted the evaluation, documented the results on letter TSU-85169 of October 14, 1985, and incorporated the letter into the completed test data package.
The evaluation did not identify any impact on test results.
This item is closed.
h.
(Closed) Open Item 445/8506-02: Open TOR in a completed preoperational test package.
During routine inspection of the completed preoperational test data package for ICP-PT-64-01, the RRI found TDR 3799 filed in the package with no evidence that it had been properly-dispcsitioned and closed.
Subsequently, the applicant's representative responded by explaining that this TDR was not wrftten against ICP-PT-64-01; however, it was filed in the package for information only.
Any testing issues associated with this TDR and the referenced containment spray valves have been deferred to the initial startup test program. The RRI found this to be adequately tracked by TUGC0 Operations under DPTR-85-002.
This item is closed.
3.
Maintenance Procedures The objective of this inspection was to confirm that plant maintenance procedures were prepared to adequately control maintenance and surveillance testing of safety-related systems within applicable regulatory requirements.
The inspection included verification that; o
Adequate procedures and processes were in place for control of measuring and test equipment (M&TE);
o Procedures had been published for performing preventive and selected corrective maintenance;
 
Adequate procedures and programs existed for the implementation of o
surveillance required by Technical Specifications (TSs);
All procedures were in the appropriate format as specified in the 1
o administrative control manual, and that they were technically adequate to accomplish their stated purpose; and i
Where appropriate, procedures prescribed steps important to the l
o protection of the health and safety of the workers and of the public.
j The maintenance procedure inspection commenced in September 1985 and continued through completion in October 1985. Details of the inspection conducted in September 1985 were reported in Appendix C of NRC Inspection Report No. 50-445/85-13.
The following procedures were reviewed by the NRC inspector which met a.
the objectives of this inspection and for which there were no comments or adverse findings:
o INC-101, Revision 4, "I&C Maintenance Program";
INC-109, Revision 1, I&C Preventive Maintenance Program";
o o
INC-7323A, Revision 1, " Analog Channel Operational Test and Channel Calibration - Steam Generator NR Level, Loop 1, Protection Set III, CH 0518";
INC-601, Revision 2, " Digital Multimeter Calibration";
o INC-624, Revision 2, " Pressure Test Gauge Calibration";
o INC-631, Revision 1, " Dial-Type Thermometer Calibration";
o MMI-302, Revision 0, " Reactor Coolant Pump Seal Replacement";
o MMI-320, Revision 0, " Pressurizer Spray Nozzle Inspection";
o o
EMI-313, Revision 1, " Centrifugal Charging Pump Motor Inspection"; and EMI-806, Revision 0, " Electric Penetration Removal, repair, and o
Installation."
b.
Procedures INC-2006X, Revision 0, " Filling and Venting Flow and Differential Pressure Transmitters (Water or Steam)," and INC-2007X, Revision 0, " Venting and Filling Pressurizer and Steam Generator Level Transmitters," were found to not meet the objectives of this inspection as identified below.
On March 21, 1985, Severity Level IV
 
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Notice'of Violation 445/8445-02 was issued citing the ' applicant for T
' failure to. provide adequate procedures appropriate to circumstances.
9 The circumstances involved an Instrumentation and Control (I&C)
J.!
technician who attempted to fill a pressurizer level detector reference leg while the plant was hot in accordance with an inadequate' procedure (i.e.,10I-2007), which led to errors and 'a-m';.
first degree thermal burn on his forearm.
One of the preventive.
Lp actions in the applicant's response to the violation dated April 15, 1985,'was to revise ICI-2007'which became INC-2007X.
1
'Another action was to review the remaining applicable procedures for JJ similar procedural problems. The applicant stated that there were no other procedura1' problems that would result in a similar incident.
y; ICI-2006 was among those reviewed and. it has since become INC-2006X.
1 In. light of'the problems found by the RRI when he reviewed these two
. representative' procedures, violation 445/8445-02 could not be closed, This was discussed with applicant management during the exit-i interview of November 1, 1985, and acknowledged.'
r The revised procedures (INC-2006X and INC-2007X) contained steps that were unnecessary, and contained instructions.to perform preparations q
(i.
e., assembling test equipment) in a radiation area when they 1
could have been done in a nonradiation area.
It was apparent to the.
j NRC inspector that ALARA program considerations were not incorporated
'F into the procedures.. The ALARA ("As Low As Reasonably Achievable")
Program is implemented by HPA-101, "ALARA PROGRAM," which requires procedures, planning, and training to ensure.all ionizing radiation exposure is reduced to as low as reasonably achievable on the basis of the state of technology and the economies of reducing exposure relative to the benefits realized.
4 Both of the above procedures-were inconsistent as to how to isolate
.i and equalize differential pressure detectors.
y l
Some steps were not flagged for radiological controls when l
potentially radioactive material was to be handled.
e Double valve isolation was not utilized as required by INC-101 to g
protect the I&C technicians from temperatures in excess of 200 F.
Filling and venting of differential pressure detectors should include sweeping air bubbles out through the equalizer valves.
INC-2006X did not provide for this.
)
INC-2007X had a caution note which stated that the reference legs are connected to the high pressure side of the sensors.
This is not true in the case of Rosemount Detector ILT-459F, thus the procedure does not accurntely reflect the equipment to which it is to be applied, I
 
3;
> indicating inadequate procedure reviews.
The above deficiencies were discussed in detail with the applicant's representative, who subsequently provided the NRC inspector with a sample mark-up of INC-2007X which reflected acknowledgement and correction of the deficiencies discussed.
Sin'ce correction of deficiencies such as the above is related to corrective actions associated with violation 445/8445-02, additional tracking of this issue is not necessary.
There were no additional violations or deviations identified.
4.
Preventive Maintenance Programs The RRI is conducting an on going inspection to verify that an adequate preventive maintenance program is scheduled and implemented, both from a routine equipment readiness standpoint, and in consideration of the length of shutdown time between Unit 1 preoperational testing and startup.
This inspection includes verification that adequate controls exist to ensure l
equipment maintenance will be followed by appropriate tracking and performance of retests prior to restoring the equipment to an operational i
status.
The NRC inspector interviewed applicant representatives responsible for j
the implementation and tracking of preventive maintenance and surveillance 4
testing.
Three groups have separate responsibilities in this area:
o Maintenance Engineering:
Mechanical and electrical maintenance, 1
including meter and relay maintenance.
o Instrumentation & Control:
Maintenance of plant system instrumentation and controls, o Results Engineering:
Surveillance tests and inspections required by TSs.
Maintenance Engineering has implemented a plant equipment preventive maintenance program in accordance with Mair.tenance Department Administration Procedure MDA-301, " Preventive Maintenance Program." The program was developed to satisfy the requirements of ANSI N18.7-1976 as well as the maintenance manuals furnished by Westinghouse and other vendors. The scope of the program encompasses all electrical and mechanical equipment that are not assigned specifically to the I&C group.
I&C implements an overall maintenance program on equipment within their cognizance in accordance with INC-101.
There are other subordinate implementing procedures, such as INC-107, which cover all scheduled calibrations and all required TS surveillance items that are assigned to I&C.
INC-109, for example, @ rs all preventive maintenance not alreaoy covered by INC-107.
 
a ]
~ Results Engineering'will implement the surveillance program in accordance with STA-702,." Surveillance Test Program." This provides for scheduling,.
J
' tracking, review and disposition of the records for all surveillance
)
required by the TSs..
j i
The RRI interviewed' representatives from each of the above groups, at j
which time the respective programs were explained. In general, it appears j
.that a comprehensive preventive maintenance program is in place, that is j
managed through computer scheduling and tracking programs.
During future i
NRC inspections, it will be determined if the programs are effective and the equipment is being maintained in a satisfactory state of readiness.
The RRI reviewed chemistry records for steam generators and primary fresh water cooling systems between January 1983 and September.1985 to ensure that required records were in place, that corrective measures were promptly taken when out-of-specification results were obtained, and that there was a full continuity of samples taken consistent.with frequency requirements. This review identified the concerns discussed below.
The primary fresh water cooling systems chemistry results were recor'ded on Form CHM-508-1,.which is required by CHM-508, " Chemistry Control of the Primary Cooling Systems." Systems under the purview of this procedure are Safety Chill Water, Non-Safety' Chill Water, Diesel Generator Water Jackets, Component Cooling Water, and BTRS Chill Water.
In general, a lack of data entry discipline existed, but with an improving trend, from January 1983 to present.
For example, in many cases sample results were i
not entered, but-there was no exp hnation.
Presumably, the systems were drained or otherwise not available for sampling.
Out-of-specification conditions were not flagged such that the RRI could determine that necessary notifications and corrective actions were implemented.
Specifically, weekly samples were taker: 10 to 12 days apart in November 1983. Sample data entries did not exist in the Records Center for the weeks of March 28, 1983; June 7, 1983; June 14, 1983; June 21, 1983; June 28, 1983; October 3, 1983; December 16, 1983; December 23, 1983; and December 30, 1983.
Steam generator chemistry results for No.1 and No. 2 steam generatocs were reviewed for the period between January 1984 and September 1985.
The data appeared on Form CHM-501-1 which is a requirement of CHA-502,
" Chemistry Control of the Steam Generators." In many cases, out-of-specification results were not flagged as required by CHM-501,to indicate that the shift supervisor was notified and at what time.
Some samples were not taken, but no explanation existed.
As was the case with j
primary cooling systems, the attention to detail expected to be seen on j
 
1 i
l
. l such records did not appear to exist, even though all the forms were reviewed and approved by supervision.
Specifically, pH for both steam generators was recorded as being out-of-specification low (i.e., as low as 9.0 when a range of 9.8 to 10.5 was required by CHM-501, Attachment 1) from June 20, 1984,through October 8, 1984, with no apparent explanation. When the RRI questioned this, the applicant's representative explained that there had been a considerable amount of discussion between the applicant and Westinghouse and that there had been no urgent need to correct the condition since the steam generators were in cold wet layup.
At the time, the applicant could not produce documentation supporting this information.
The RRI was presented with a copy of Problem Report PR84-361 which was originated on October 5, 1984; over three months after the problem of low pH became known. The report did not identify the pH as having been out of-specification low for over three months, but, rather, stated that the mechanical seals on the recently installed recirculation pumps were leaking, causing carbon dioxide entrainment, which in turn caused a
" depression" of pH in the steam generators. The engineering review did not evaluate the effects of the long-term pH depression on steam generators. The RRI was also presented with Independent Safety Engineering Group Report 84-03, which documented a review of steam generator water chemistry control.
The review included the period when pH was depressed, but stated that, "... Plant chemistry personnel report that the steam generators chemistry sample data is stable and no problem areas have been noted." There was no mention of the pH problem.
The report concluded, ".'.. prompt response to out-of-specification conditions indicate that no significant corrosion related damage has occurred in the Unit 1 steam generators." The applicant was requested to provide the RRI with documented evidence which proves that the quality of the primary and secondary boundaries of the steam generators had not been compromised as a result of over three months out-of-specification low pH.
This is an unresolved item (445/8514-U-01).
The concerns identified above with respect to what appears to be missed chemistry samples, f ailure to indicate when and if the Shift Supervisor was notified as out-of-specification results were obtained, a lack of records to indicate corrective actions taken, and inadequate reviews of data forms constitute a violation of Criterion XVII of Appendix B to 10 CFR Part 50 (445/8514-V-01).
5.
Plant Tours During this reporting period, the SRRI and RRI conducted inspection tours of Unit 1.
In addition to the general housekeeping activities and general cleanliness of the facility, specific attention was given to areas where safety-related equipment was installed and where activities 9 r in progress involving safety-related equipment. These areas were inspecc.d to ensure that
 
I 1
o-Work.in progress was being-accomplished using approved procedures; L:
=
Special precautions.for protection of equipment were. implemented,.and o'
additionalicleanliness requirements were being adhered.to for maintenance, flushing,.and welding activities;.
o' Installed safety-relatea equipment and components were being protected and maintained.to prevent damage and deterioration.
Also during these tours, the SRRI and RRI reviewed the control room and shift supervisors' log books.
Key items in the log review were:
o plant status,.
o changes in plant status,
.o o
-tests in progress, and documentation of problems which arise during operating shifts.
o I!
No violations or deviations were identified.
~
6.
Unresolved Items Unresolved items are matters for which more information is required in order to ascertain whether they are' acceptable items, violations, or deviations.
One unresolved item disclosed during the inspection is discussed-in paragraph 4.
- 7.
Plant Status as of October 31, 1985-
)
Unit No.1 is reported to be 99% complete; however, excavation is a.
underway to facilitate replacement of main condenser internals and a significant amount of rework continues on the control room ceiling.
1 b.
Unit No. 2 is reported to be 77% complete.
The preoperational test program'on systems associated with NRC inspections has_not yet l
started.
q 8.
Exit Interview An exit interview was conducted November 1, 1985, with the applicant representatives identified in paragraph 1 of this appendix.
During this t
interview, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the findings, i
l
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----__________.________________i__
 
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9 APPENDIX 0 CONSTRUCTION INSPECTION REPORT e
-U.
S. NUCLEAR REGULATORY COMMISSION i
REGION IV 1
NRC Inspection Report:
50-445/85-14 Permit:
CPPR-126 50-446/85-11 CPPR-127 Dockets: 50-445 Category: A2 L'
50-446 Applicant: Texas Utilities Electric Company (TUEC)
+
Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 Inspection At:
Glen Rose, Texas Inspection Conducted: October 1-31, 1985
/Mh 2-2 Y-W Inspectors:
'H. S. Phillips, Seniof Resident Reactor Dst.e i
Inspector (SRRI), Construction, Region IV CPSES Group (paragraphs 1,2,3,4,5,6,9,10) 1 D AS.
l d
2 h ?b D.L.Telley,SRRI,jUperattions,RegionIV Date CPSES Group (paragraph 8) f Wszw=_
2/22/f4 D. E. Norman, Reactor Inspector Date Region IV CPSES Group (paragraph 7) 1 6 3190517 860306
' h' '
i PDR ADOCK 05000445 G
PDR l'
 
7-lt 1 Consultants: EG&G - J. H. McCleskey l
Parameter - T. H. Young Reviewed By:
8e J/3/4's i.
: 1. Barnes, Group Leader, Region IV CPSES Group Date Approved:
7[
3/p/f4 T. F. Westeman, Chief, Region IV CPSES Group Date inspection Summary inspection Conducted: October 1-31, 1985 (Report 50-445/85-14)
Areas inspected:
Routine, unannounced inspections of Unit I which included plant tours, appilcant actions on construction deficiencies, applicant actions on previous NRC inspection findings, and storage and handling of QA records.
The inspection involved 204 inspector-hours onsite by two NRC inspectors and l
two consultants.
Results: Within the four areas inspected, one violation (failure to establish written procedures for control and accountability of the shipment of original design records to Stone & Webster Engineering Corporation (SWEC),
paragraph 5.b) was identified.
Inspection Conducted: October 1-31, 1985 (Report 50-446/85-11)
Areas Inspected:
Routine, announced and unannounced inspections of Unit 2 which included plant tours; applicant actions on construction deficiencies; applicant actions on previous inspection findings; storage, protection, and handling of QA records; audit of QA records; welding material control; and electrical cable tray / equipment walkdown. The inspection involved 227 inspector-hours by three NRC inspectors and two consultants.
Results: Within the seven areas inspected, three violations (a repeat failure to document minimum wall pipe violations on a nonconformance report (NCR),
i paragraph 4.c; a repeat failure to control issue of design documents, paragraph 4.g; failure to establish written procedures for control and accountability of shipment of design records to SWEC, paragraph 5.b) were identified.
i 1
 
DETAILS 1.
Persons Contacted Applicant Personnel-J. Merritt, Assistant Froject General Manager
'P. Halstead, Manager, Quality Control (QC)
C. Welch, QC Supervisor R. Spangler, Corporate Quality Assurance (QA) Supervisor i
J. Walker, Corporate QA Auditor J. Marshall, Licensing J. Hicks, Licensing M. Strange, Supervising Engineer, Support & Project, TUGC0 Nuclear Engineering (TNE)
J. Ryan, Technical Service, Supervisor S. Ali, THE QA Staff Engineer B. Jones, Unit 2 Supervising Engineer, Civil /btructural R. Hooten, Project Discipline Engineer, Civil / Structural J. Hodgson, Computer Operator Supervisor, PMCS.
Contractor Personnel W. Baker, Welding Engineer, Brown & Root (B&R) 1 W. Wright, Welding Engineer, B&R G. Purdy, Site QA Manager, B&R J. Gore, Subcontract Supervisor, B&R K. Thornton, Warehouse Superintendent, B&R C. Osborne, QA Vault Supervisor, B&R D. Leach, THE-QA-B&R K. Norman, Central Operations Supervisor, DDC-B&R D. Bleeker, DCTG Supervisor, B&R R. C. Iotti,. Project Manager, Ebasco A. Smithey, Supervisor IRV, B&R R. Walters, ASME QA Supervisor, B&R G. Maedgen, Welding Engineer, B&R T. Gray, Document Control Manager P. Patel, Unit 1 Civil Lead, TNE Design, Gibbs & Hill B. Jones, Expediting Supervisor, B&R L. Barnard, PMG File Clerk, B&R T. McCormack, Fire Protection Engineer, Impell S. Felman, Assistant Project Engineer, SWEC.
H. Moscow, Supervisor Projects & Services, NY, SWEC J. Tate, 304 DU Satellite Supervisor, B&R '
J. Junge, 311 DU Satellite Supervisor, B&R J. Womack, 300/301 DU Satellite Supervisor, B&R l
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i R. Flaherty, 307 DU Satellite Supervisor, B&R i
S. Hazle, 310 DU Satellite Supervisor, B&H J. Day, 308 DU Satellite Supervisor, B&R J. Dickey, DCC Area Supervisor, Engineer Satellites, B&R I
S. Bruce, DCC Area Supervisor, Craft Satellites, B&R 2.
Plant Tours At various times during the inspection period, NRC inspectors conducted j
general tours of the reactor building, safeguards building, and the electrical and control building.
During the tours, the NRC inspector observed ongoing construction work and discussed various subjects with personnel engaged in work activities.
3 No violations or deviations were identified.
I 3.
Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant a.
The applicant's procedures pertaining to Significant Deficiency Analysis Reports (SDARs) were reviewed to determine how the process of deficiency identification through completion and signoff is j
controlled.
Reviews were performed of site Procedures CP-QP-15.6, Revision 3, "SDAR Status Tracking"; CP-QP-16.1, Revision 6, "Significant Construction Deficiencies"; CP-QP-17.0, Revision 1, l
" Corrective Action"; and TUGC0 Procedures DQP-CQ-4, Revision 1,
" Reporting of Significant Deficiencies"; DQP-QA-12, Revision 2, i
" Administration and Tracking of Significant Deficiency Analysis Reports"; and DQP-QA-11, Revision 1, " Corrective Action."
Procedures CP-QP-15.6, CP-QP-16.1, DQP-CQ-4, etnd DQP-QA-12 do not i
address the SDAR file contents or provide a method for completion and signoff of the required corrective action.
Procedures CP-QP-17.0 and DQP-QP-15.6 address the documentation required for closing deficiencies, but there is no cross reference between SDAR/ corrective action with respect to SDAR file contents.
This is an unresolved item pending completion of NRC review of SDAR procedural adequacy (445/8514-U-02; 446/8511-U-01).
b.
The applicant classified the following reportable SDAR files as
" Licensee Action Complete": SDARs CP-84-27, CP-84-29, CP-85-04, CP-85-05, CP-85"11, CP-85-12, CP-85'13, and CP-85-14.
The above files did not document or reference the location of documentation which would support the reported status of corrective actions being i
complete.
Consequently, the NRC inspector did not perform a field verification for any of these files.
c.
The following nonreportable SDAR files were selected for review, s1nce the applicant classified these as " Licensee Action Complete":
1 i
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I (1) (Closed): The NRC inspector reviewed the following 50ARs:
CP-84-05, CP-84-22, CP-84-23, CP-84-24, CP-84-26, CP-84-32, c
f CP-85-02, CP-85-08, and CP-85-09.
The applicant's evaluation j
and decision that these SDARs are not reportable appeared to be Correct.
l (2) (0 pen): The NRC inspector reviewed SDARs CP-84-30, CP-84-34, and CP-85-06.
The files for these SDARs did not contain sufficient information or documentation to determine whether or not the 50AR was nonreportable.
The status of the files is an unresolved item pending the completion of a TUGC0 effort to make the files complete and subsequent NRC review (445/8514-U-03; 446/8511-U-02).
l l
4.
Applicant Action on Previous NRC Inspection Findings a.
(Closed) Unresolved Item (445/8422-U-02): Inverter transformer common failure. The NRC inspector reviewed the applicant's handling of the defective transformers and concluded that the actions taken to evaluate and correct the deficiency were correct and adequate.
The applicant's handling and reporting of significant deficiencies will continue.to be monitored by the NRC inspectors.
b.
(Closed) Violation (445/8307-V-01):
Excessive welding gap. In 1983, the NRC inspector identified an unacceptable fitting on pipe support l
Mark No. SW-1-102-106-Y33K.
Recently, the'NRC inspector followed up and reviewed NCR M5123-5, RPS 751947, WDC80668, related sketches, and inspection reports (irs).
Corrective work was accomplished and QC performed required inspections.
An engineering analysis of the installation which was performed in response to the violation showed strength was far in excess of minimum design requirements, even though it violated the procedure.
In B&R memo -IM 325,208 dated April 13, 1983, supervision reemphasized the requirement to follow procedures to all affected personnel.
c.
(Closed) Violation (445/8315-01): Failure to write an NCR on base metal repair.
This violation concerned an instance where the NRC I
inspector observed a minimum wall violation for which a NCR had not been written. On October 8 and 9, 1985, another NRC inspector reviewed this violation of paragraph 3.3.3 of site Procedure QI-QAP-16.1-2, Revision 4, dated May 20,.1982.
The scope of this procedure was changed to make further reference to system walkdown and the item in question was accomplished near this time frame.
However, the applicant responded by documenting the questioned minimum wa1U violation and the repair of the adjacent weld on a
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common NCR (M6611). These conditions had been found by separate NDE methods, one before and one after the base metal repair. The NRC inspector reviewed two more recent base metal repairs to verify that the problems had been corrected. One repair performed in 1984 was found to have,been in compliance with the then current procedures, j
The second repair was completed, reviewed, accepted, and i
documentation sent to the vault during September'and October of 1985.
This second report showed an original weld completed, reviewed, and
~;
accepted in January and February 1985. Rework was performed on this weld in September 1985 due to interference with a hanger installation which resulted in,a minimum wall violation.
Further work to repair the hanger was classified as a " Major Weld Repair" in accordance with I
paragraph 3.3 of B&R Procedure CP-CPM-6.9G; however, no NCR was i
generated. This failure to document a minimum wall violation on an NCR is a repeat violation of Criterion XV of Appendix B to 10 CFR Part 50(446/8511-V-01).
It was noted that the inspector and the preparer of the repair process sheet had recently received training on the newly revised procedures involved which required the NCR be generated. The Assistant Project Welding Engineer who reviewed the repair process sheet had not been so trained on'the procedure, as he had been exempted from the training by virtue of his position, d.
(Closed) Unresolved Item (446/8502-01): Responsible welding supervisors not familiar with welding rod control procedures.
In 1985, the NRC inspector interviewed supervisors who were not familiar with welding rod control procedures which their crew of welders were l
I responsible for implementing. The training program for supervisors was conducted in May 1985 and covered helpers through general
: foremen, l
In 1984/85, the NRC Technical Review Team (TRT) extensively reviewed
]
l and inspected weld rod control and documented their findings in NUREG-0797, Supplemental Safety Evaluation Report (SSER) 10, Category 9.
In addition, the RIV inspector inspected weld rod control during this inspection period and identified no violations or deviations, (Closed)UnresolvedItem(445/8323-07):
Incomplete Class V(5) pipe e.
supports record package.
In 1983, the NRC reviewed packages which had been combined into finalized packages.
In 1984, the TRT reviewed 8) a random sample of 11 Class V(5) support record packages. This review showed that packages with irs (by qualified inspectors) were in proper order. The TRT found the records satisfactory as reported on page N-252 of NUREG-0797, SSER 10 dated April 1985.
f.
(Closed) Unresolved Item '(44578347-01):
Containment surface area coating. This item addren ed sloughing of protective coatings on
 
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e ga g.
Westinghouse supplied items.
In SSER 9, NRR staff state they have re'hsonable assurance that debris generated by the failure of all coatings inside the containment building under design basis accident conditions will not unacceptably degrade the performance of post-accident fluid systems. This was based on TUGC0 and other studies referenced in NUREG-0797, SSER 9 on pages L-17 and L-18.
NRR 1
gy requires in SSER 9 that a preoperational and postoperational coatings i
program be proposed by TUGCO, but this specific issue of sloughing of j
coatings on Westinghouse items is closed based on the SSER 9 l
conclusions.
j g.
(Closed) Violation (445/8416-V-02): Failure to provide controlled issuance of design documents and changes thereto.
Between May and June 20, 1984, an NRC inspector found that design documents and changes were not controlled by Operations Document Control Center (DCC). On October 11 and 14, 1985, the NRC inspector confirmed that the computer system and terminals referred to in the TUGC0
. November 1, 1984, response were in place and in use.
i.
The NRC inspector reviewed 12 Design Change Authorizations (DCAs) and Component Modification Cards (CMCs) and followed the distribution of 25 packages to 9 locations for various disciplines and verified corrective action. These DCAs and CMCs were traced in their routing at the central DCC and then on to the Paperflow Group or satellite DCCs and a review performed of how they are distributed from those locations.
All items checked were distributed per DCP-3, Revision 18 (with Document Change Notices (DCNs) 1, 2, and 3), with the following exceptions:
I (1) CMC 96181, Revision 1, was issued on October 8, 1985, and satellite DCC 307 (craft) picked it up at central DCC. The CMC was not signed for as required by paragraph 3.1.1.1 of DCP-3, Revision 18, with DCNs 1, 2, and 3.
There was a similar occurrence on CMC 75003, Revision 2, as issued to satellite DCC 202/211 (TUGCO). Further, DCA 21446, Revision 1, was issued October 8,1985, and satellite DCC 307 was in possession of it on October 14, 1985. One of two packages for Drawing 2323-El-1702, Sht 002, Revision 2, had both Revision 0 and Revision 1 of DCA 21446 in it, with the other having only Revision 0 in it.
Both Revision Os were not stamped " VOID" as required in paragraph 3.2.2.5 of DCP-3.
On October 14, 1985, satellite DCC 307 issued Drawing 2323-El-1702, Sht. 002, Revision 2, to an electrician for Class IE field work with Revision 0 of DCA 21446, rather than the current Revision 1, which is contrary to the requirements of paragraph 3.2.1.2 of DCP-3 On October 14, 1985, TUGC0 and B&R supervision contacted the electrician who indicated he had l
; tee s.
 
j l
l
. gotten sheet 002 rather than sheet 001 by mistake and haa returned it immediately without installing anything to it.
These failures to follow design document control procedures are a violation of Criterion V of Appendix B to 10 CFR Part 50 (446/8511-V-02).
(2) The following examples were noted of practices being followed that were not covered in controlled procedures:
(a) The method used tc issue drawing packages from the satellites to the field (e.g., crafts and QC) was not addressed in DCP-3.
The actual practice is that a DCC person and the recipient sign for receipt of all the proper documents (e.g., DCAs) and the proper revisions on the computer printed "Open Design Change Log."
(b) Another practice of the DCC group is to log into the computer the status of the DCAs and CMCs. This status is classifed.as open, void, or not included (NI) and indicates whether e change is affecting all items built to a drawing, J
a single item utilizing the drawing, or no further use of the change.
Drawing 2323-5-0910, Sht. CSR-2A, Revision 12, had' CMC 75003 issued against it.
This CMC had status NI on Revisions 0 and 01 because it affected a single hanger utilizing the above drawing.
However, Revision 02 did not s
have NI input and it showed as open on the terminals.
This would require it to be included with the drawing package in error.
This was corrected on the terminal.
This process T
of statusing the computerized document information is not descrsbed in DCP-3.
DCC supervision stated and showed that the practices are described in internal uncontrolled guidelines.
This item is unresolved'pending incorporating the guidelines into a controlled procedure (44C/8511-U-03).
h.
(Closed) violation (84-08-01): Gms on Unit 1 polar crane bracket and seismic connections.
In November 1964, 6 NRC inspector found that the gaps between the bracket and connectors exceeded the design tolerance. This item is addressed in NUREG-0797, SSER 8, along with related prcolems with polar cranes.
Discussion, conclusions, and actions to be taken are included in pages K-14,15,18 and 121-123 of Appendix X to SSER 8.
Since these actions will address the specific conccens o.f' item 84-08-01, this item'is closed.
5.
QA RecordsJystem Review The N M inspector reviewed the applicant's record keeping e after ascerteNng that records were being shipped off site withs ecper
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. control and inventory.
In Appendix IA(N) and 1A(B) of Final Safety Analysis Report (FSAR) Volume 1, Section 1.0, the applicant commits to Regulatory Guide 1.88 (i.e., Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records) and to American National Standard, Institute (ANSI) N45.2.9, lith Draft, Revision 0, dated January 17, 1973. On page 1A(B)-36 in the Discussion, the applicant makes no exceptions to this standard.
A brief description of QA records is contained in FSAR Section 17.1.17 (Amendment 50 dated July 13,1984). The description does not address the current QA records facilities and storage; i.e., temporary storage of records for the Paper Flow Group, Interim Record Vault (IRV), Permanent Plant Record Vault (PPRV),
procurement records storage area (Warehouse A) and the TUGC0 Records Center.
The applicant has not revised FSAR Section 17.1.17 to describe and reflect the current QA record system. This is unresolved pending the applicant's actions on the item described in paragraph a below (445/8514-U-04; 446/8511-0-04).
a.
Review of Corporate QA Manuals and Implementing Construction Procedure:
The NRC inspector reviewed the TUGC0 Corporate QA Program Manual, Revision 14, dated April 30, 1985, and Quality Assurance Plan, Revision 14, dated August 30, 1984, to determine if ANSI N45.2.9 was referenced and if its requirements were translated into these documents. Only TUGC0 construction Procedure CP-QP-18.4, Revision 5, was found to reference ANSI N45.2.9.
Operations and TUGC0 Nuclear Engineering procedures were not included in the scope of this inspection.
Procedure CP-QP-18.4, Revision 5, does not address all aspects of ANSI N45.2.9 such as (1) definitions; (2) all facility locations; (3) method for maintaining control of and accountability for records removed from the site storage facility to organizations located on or off site; (4) temporary storage facilities (fire rated cabinets versus duplicates in remote, separated locations); and (5) special process records such as photographs, negatives, and microfilm.
The permanent facilities are discussed with respect to ANSI N45.2.9 requirements described in paragraph 5.6; however, the drain system and dry chemical / gas fire protection system is not
?
discussed.
The IRV system is a permanent records vault for Unit 2
~
records until such records can be transferred to the construction PPRV where Unit 1 records are now stored.
TUGC0 Procedure CP-QP-18.6, Revision 3, discusses records turnover from B&R IRV to TUGC0 PPRV but does not address the issues raised above. Also, these issues are not addressed in the B&R QA Manual, Section 17.0 dated October 31, 1984, or CP-QAP-18.1, Revision 3, dated July 11, 1984.
l
\\
 
. TUGC0 management stated that all of their QA manuals are in revision to improve their written program. This item is unresolved pending thecompletionofthatreview(445/8514-U-05;446/8511-0-05).
b.
Storage and Transmittal of Design Records to SWEC, New York: On October 16, 1985, an NRC inspector was inspecting an open item previously identified as unresolved item 8226-U-07. As a result, the requalification package for pipe support CC-1-107-008-E23R was requested and the NRC inspector was informed that this design records package had been included in a total of 5702 (4654 for Unit 1, 1048 for Unit 2) hanger packages that had been shipped to SWEC, New York, for a complete reevaluation.
The NRC SRRI interviewed the TUGC0 engineering supervisor who answered questions about whether procedures controlled such shipment, the number of records per package, and how the records were to be protected during shipment. He stated that a first transmittal was controlled by Procedure CP-El-18.0-4, Revision 0, dated July 25, 1985, until Comanche Peak Project Engineering became a part of TNE on September 1, 1985, at which time the procedure was deleted. The SWEC project manager stated that Procedure CPPP-3 covers the receipt and indexing of these packages; however, CPPP-11 that will control the distribution of these packages to SWEC offices at Cherry Hill, New Jersey; Boston, Massachusetts; Denver, Colorado; Houston, Texas; and Toronto, Csnada, will not be completed until late October or early November 1985, according to SWEC Supervisor Project Services, New York. The utility has taken corrective action that includes (1) making duplicate copies prior to shipping, and (2) all records initially sent to SWEC are being copied and a copy returned to the site. Region IV is pursuing with IE Headquarters, QA Branch the 3
minimum protection that should be afforded records in shipment. The 4
failure to have site procedures to maintain control and accountability of the shipment of records is a violation of Criterion V of Appendix B to 10 CFR Part 50 (445/8514-V-02; 446/8511-V-03).
c.
Storage and Transmittal of Construction Records to Chicago Bridge and Iron (CBI): As a result of knowledge of an earlier shipment of CBI records off site, the NRC inspector has asked the utility to orovide
~
records to demonstrate the CBI record controls that were implemented.
It is CBI practice to ship all records off site for copying.
Inis matter is considered unresolved (445/8514-U-06; 446/8511-U-06).
The utility has indicated that the receipt of records from CBI was handled in the same manner as the receipt of records from any vendor.
Region IV will inspect the receipt of vendor records and this matter is considered an open item (445/8514-0-01; 446/8511-0-01).
 
a
. d.
Inspection of Storage Facilities:
The NRC inspectors visited all site storage facilities to determine if storage, preservation, and safe keeping of records are as required by Criterion XVII of Appendix B to 10 CFR Part 50 and ANSI N45.2.9, Draft 11, Revision 0, paragraph 5, " Storage, Preservation and Safe Keeping." The facilities inspected included TUGC0 Records Center, which is cominitted by the FSAR to ANSI N45.2.9-1974 and not the Draft 11, I
Revision 0 version; PPRV; IRV; Paper flow Group storage areas for Unit 2 mechanical and electrical; and the procurement records storage area. The facilities for the Paper Flow Group and procurement records are not identified or described in TUGC0 or B&R procedures; however, these facilities and the PPRV and IRV were evaluated with the following results:
(1) TUGC0 Records Center - This vault is the final repository for:
(a) Unit 1 records which describe completed construction, and (b) Unit 2 record packages for systems that have been completed and turned over to operations.
This facility was completed about March 1983.
The NRC inspector found that this vault had access control and records were stored in closed conta,ners, open face shelves, or in binders on top of furniture.
Radiographs and other special process records are protected by controlling temperature and humidity.
The NRC inspectors noted that a water sprinkler system had been installed in this facility.
This presents a concern because those plant records which are stored in folders or binders in open faced cabinets will be deluged with water and will likely deteriorate.
An additional consideration is that records stored in a manila folder may be washed out and possibly clog the drain in this facility, leading
,j to flooding of the facility.
This itemJslonsideged unresolved
)I pending applicant review of the facility with respect to the
,.4 above observations (445/8514-U-07; 446/8511-U-07).
: 2) PPRV - This vault served as'~the sole permanent' vault from approximately 1975 until March 1983.
This permanent records facility has controlled access.
It meets the design features for a permanent facility, as described in Section 17.1.17 of the FSAR; however, the NRC inspector had the following comments:
(a) There is no fire suppression system inside this vault.
Two 1
hand-held extinguishers and a 2-inch fire hose are located outside the vault.
One hand-held extinguisher is locatud
 
i 1 inside the vault.
Fire detectors and alarms are inside to alert the onsite fire department if a fire occurs, l
(b) If the 2-inch fire hose is used to extinguish a fire, the vault may flood because there are no fire drains and the floor is not sloped. Therefore, water may potentially enter the bottom cabinet drawers.
(c) NCRs and corrective action reports were stored in binders in bookcases.
If fire hoses are use1, these documents would probably be subjected to the 'orce of water from the hose and damaged.
Therefore, it would be desirable to store these records in closed containers.
All other records were stored in nonfire r4ted cabinets which is acceptable if located in a percianent facility that meets ANSI N45.2.9 requirements.
The failure to install a fire suppression system, drains, and a sloped floor appears to be a dev'.ation from ANSI N45.2.9 requirements.
However, this item is unresolved because this facility is described in FSAR Section 17.1.17.
Region IV is forwarding this issue to IE Headquarters, QA Branch for clarification (445/8514-U-08; 446/8511-U-08).
(3) IRV - This area is not a separate building, but is actually part olf the permanent vault that has been set aside as an interim storage area prior to placing records in the area designated for permanent records. This area has an access point that is separate from the permanent area and is controlled.
The facility is the same as the permanent area, except a wall separates the two.
They share the same forced air system.
This facility generally meets the requirements of 10 CFR Part 50, Appendix B, and ANSI N45.2.9; however, the NRC inspector had the following comments:
(a) Water had been leaking through the forced air system and beside a support girder.
In a second location, approximately 2-3 gallons of water had leaked in through the forced air ventilation duct and was caught by a container placed under the duct. This is considered an open item (445/8514-0-02; 446/8511-0-02),
(b) The NRC inspector observed a coffee pot, sugar, and evidence of food on a table adjacent to the vault area.
b-These were immediately removed from the vault by the utility.
41
 
i
'+
r
. () Paper Flow Groups - The NRC inspectors visited trailers.where the electrical and mechanical Paper Flow Groups are located to determine if QA records are stored there.
(
In SSER No. 11, the TRT considered the documents in the paper flow groups to be inproceu.; however, SSER No. 11 also indicated that the records are maintained in fire proof cabinets. The NRC inspectors found that there are some records stored in
)
nonfire-rated file cabinets. This matter is considered unresolved (445/8514-U-09; 446/8511-U-09).
a 5
(5) Storace of Procurement Records - In Warehouse A, procurement recorc s were stored both in nonfire-rated and fire-rated L
cabinets. The NRC. inspector found no master index of these records and the facility is not described in the FSAR or procedures. There was no way to determine whether duplicates of these records exist and if they must be stored in fire-rated cabinets. This item is unresolved pending identification and j
description of this facility and indexing of records recently received from the TUGCO, Dallas, Texas, office to determine what records must be in fire-rated cabinets (445/8514-U-10),
i 446/8511-0-10).
6.
Audit of QA Record Systems / Facilities The NRC inspector asked if the unacceptable QA records storage and control conditions identified above in paragraphs 5.a and 5.d had been identified by TUGC0 or B&R audits. TUGC0 audited (TCP-85-20 dated January 16, 1985) the PPRV but failed to identify any of the problems noted above. Two auditors audited this area from December 17 through December 20, 1984, and their report did not identify any storage facility problems.
ANSI N45.2.9 requires that periodic audits shall be performed to assure facilities are
}
in good condition and temperature / humidity controls and protective devices are functioning properly.
An Ebasco review or study dated June 16,1981, page 4 of 25, item g, states with respect to the PPRV, "It is an established fact that the QAR vault does not meet the requirements for a single storage facility and that duplicate files are not maintained in lieu of single storage." On October 23, 1985, the NRC inspector requested documentation which would chow action taken in response to the Ebasco finding. TUGCO's Project and QC organizations had no such documentation.
This item is unresolved N nding review of the response to this audit finding (445/8514-U-11; i
446/8511-U-11).
The NRC inspector asked PPRV personnel if B&R had audited
@ record keeping / facility system and was informed that it has been uveral years since B&R had performed such audits.
This item is F,,".91ved pending the review of B&R audits (445/8514-U-12; M/G511-U-12).
 
..u.-
i, o'
I 7.
Control of Weld Filler Material This inspection was performed to determine whether safety-related weld filler material purchase, storage, and distribution are in accordance with the applicant's work and QA procedures, and applicable ASME code requirements.
Implementation of the following procedures was examined during the inspection:
CP-QAP-8.1, Revision 9, dated October 15, 1984, " Receiving Inspection";
CP-CPM-6.98, Revision 2, dated September 21, 1984, " Weld Filler Material Control"; and CP-CPM 8.1, Revision 3, dated July 2,1985, " Receipt, Storrge, and Issuance of Items."
The folicwing areas were examined:
a.
Procurement:
Four purchase order packages which consisted of the purchase order, procurement specification, and field requisitions were inspected to verify that orders were properly approved and included required technical, packaging, and documentation requirements as specified in site procedures pertaining to weld filler material purchases.
No violations or deviations were identified.
b.
Receiving Inspection:
Receiving inspection records, for the filler material purchased to the procurement documents inspected, were examined to verify that all items required by Attachment 11 (Receiving Checklist) to CP-QAP-8.1 had been inspected.
In each case, the checklist and a receiving inspection report had been completed and signed by a Level II QC inspector.
In several instances, NCRs had been completed and material returned to the vendor as required by procedures. Certified Material Test Reports (CMTRs) for each purchase were also reviewed to verify that required inspections and tests had been performed and that material had been purchased from a vendor with a current ASME certification.
It was also verified that heat codes and quantities of material shown on the Material Receiving Reports corresponded to what was shown on the CMTR.
No violations or deviations were identified, c.
Main Storage Areas:
Two filler material storage areas located in Warehouse S '!are inspected for compliance with the above listed procederns One area was designated as a Quality (Q) area and the
: r..
7., ;
i i
other.one was b9th a'.Q and'Non-Q area. The Non-Q material was
~ segregated as required from the Q material.- Procedures in the
-storage areas ~ appeared to be adequately. implemented;.however, the NRC had the following observation:-
Paragraph 3.2.1 of CP-CPM 6.9B requires that Q weld filler material original containers.be marked upon receipt and during storage with the material classification, size,. and heat / lot number.- In the Q area, labels on several containers of Sandvik welding products (weld rod) had fallen off and others were loose. 'The material was still identifiable, because of the storage bin marking,and marking on the shipping carton; however..a loss of identification is possible when material is removed from the storage area. There were also several unopened cartons of Sandvik material whose' status could not be determined. ' Loose or missing labels were identified on the following material; Lot 101172-2, 1/8 inch, AWS/ASME SFA 5.4; and Lot 10149-1, 5/32 inch AWS/ASME SFA 5.4.
This matter has been referred to B&R Welding Engineering for followup.
d.
Distribution Stations: Weld rods used in, safety-related applications i
are distributed from three areas (Rodhouse 2, 3, and 4).
Each distribution' station was inspected to verify compliance with requirements of CP-CPM 6.9B in the following areas:
Storage facility (Level B);
Identification of material; Controlled access into storage areas; Control of stationary and portable rod ovens; Issuance, return, and accountability of material; and
]
i
. Completion and control of records.
Label problems were also noted in Rodhouse 4 during this inspection.
8.
Cable Tray and Equipment Walkdown During this inspection period, the NRC inspector performed a walkdown inspection of selected electrical components and cables to determine the degree of protection of class IE items from surrounding construction activities. The general level of protection appears adequate with the exception of the B Safety Train Diesel engine control panel (2DG02A). The visqueen covering had come loose in several spots allowing concrete dust from above to filter into the,nnel and settle on some of the installed relays.
)
j
)
 
r.
. In the area of cables, it was noted that cable ends were neatly' coiled and the ends taped, cable tags were in place and cable jacket repairs were clearly marked. At.one point in the Safety Train B switchgear room, a cable. exiting a tray and entering the switchgear (cable No. C23G 06070 above the HVAC chiller No.14.) appeared to be bearing hard on the square section of the cable tray-side ladder at its exit point.
In other places where cable exits tray, a piece of discarded cable jacket is.used as a buffer. The observed point had no such buffer.
No violations or deviations were indentified.
9.
UnresobedItems Unresolved-items are matters for which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
Twelve unresolved items disclosed during the inspection are
' discussed in paragraphs 3.a, 3.c, 4.g, 5, 5.a, 5.c, 5.d, and 6.
10.
Exit Interview An exit interview was conducted November 1, 1985, with the applicant representatives identified in paragraph 1 of Appendix E.
During this interview, the NRC inspectors summarized the scope and findings of the inspection.
The applicant' acknowledged the findings.
i I
 
/
9 i
APPENDIX E U. S. NUCLEAR ~ REGULATORY COMMISSION REGION IV COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT NRC Inspection Report: 50-445/85-14 Permit: CPPR-126 446/85-11 CPPR-1;!7 Dockets:
50-445 Category: A2 50-446 Applicant:
Texas Utilities Electric Company Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 I
l Inspection At:
Glen Rose, Texas Inspection Condu t' d: October 1-31, 1985
[
d Inspectors:
c s
L. E. Ellershaw, Reactor Inspector, Region IV
'Dat'e CPSES Group (paragraphs 1, 2.a, 3, 6.b, 6.e-6.g, 6.j, 7.e-7.u)
T S
T C. J. @,' Reactor Inspector, Region IV CPSES D6te '' ~ ~
Group (paragraphs 1, 2.b, 4, 5, 6.c-6.d, 6.h-6.1)
Yf
~5/7/6 G-A. R. Johnson, Reactor Inspector, Region IV Date CPSES Group
.(paragraphs 1, 6.a, 7.a-7.e) l Consultants:
EG&G - R. Bonnenberg, J. Dale, L. Jones, A. Maughan, W. Richins, R. VanderBeek
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.g.
Parameter - J. Birmingham, D. Brown, J. Gibson, K. Graham, D. Jew, Reviewed By:
8-so 3/7/#6 I. Barnes, Group Leader, Region IV CPSES Group Date Approved:
7
[
"VJ /F6 T. F. Westerman, Chief, Region IV CPSES Group Date '
Inspection Summars Inspection Conducted: October 1-31, 1985 (Report 50-445/85-14: 50-446/85-1D Areas Inspected:
Nonroutine, unannounced inspection of applicant actions on previous inspection findings, followup on alleged contractor improprieties, Comanche Peak Response Team (CPRT) procedures and instructions, and CPRT issue
- 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 provideo in paragraph 4.
Results: Within the four areas inspected, two violations (revision of drawings without required review and approval actions, paragraph 2.a; signing of 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 package, paragraph 8.c; and inspection 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.
i
 
-)
DETAILS 1.
Persons Contacted D. L. Andrews, TUSI Director of Corporate Security J. Arros, TERA Civil / Structural Issue Coordinator C. I. Br wne, Project Manager, R. L. Cloud & Associates, Inc.
*R. E. Camp, Assistant Froject General Manager, Unit 1 (Impe11 Corp.)
J. Finneran, TUGC0 Lead Pipe Support Engineer
*S. M. Franks, Special Projects and Technical Support Lead (Impe11 i
Corp.)
*J. B. George, TUGC0 Vice President, Plant Seneral Manager
*P. E. Halstead, TUGC0 Site QC Manager J. L. Hansel, ERC QA/QC Review Team Leader C. K. Moehlman, TUGC0 Project Mechanical Engineer
*C. Killough, TUGC0 Supervisor, Operations Quality M. Obert, ERC TRT Issue Coordinator A. Patterson, ERC Engineering Supervisor C. Spinks, ERC Inspection Supervisor
*T. G. Tyler, TUGC0 CPRT Program Director
*C. H. Welch, TUGC0 QC Services Supervisor R Werner, Manager, Safeteam
*P. B. Stevens, TUGC0 Project Electrical Engineer G. Benfer, Bahnson Services Co. Site QA Manager D. W. Snow, Brown & Root (B&R) QA/QC Coordinator T. Wright, TUGC0 civil Engineer
*G. W. Ross, ERC Onsite QA Representative J. Adam, ERC Supervisor, Safety Significance Evaluation Group D. M. Kim, Principal Mechanical Engineer, Gibbs & Hill (G&H)
T. Brandt, TUGC0 Quality Engineering Supervisor J. R. Honekamp, TRT Issues Manager, TERA P. Turi, TERA Issue Coordinator G. Purdy, B&R QA Manager J. E. Young, ERC Issue Coordinator J. R. Gelzer, ERC Issue Coordinator S. L. Crawford, ERC Issue Coordinator P. Thomas, ERC Supervisor, Inspection Group Services D. Alexander, ERC Supervisor, Hardware Issues P. Amoroso, ERC Supervisor, Hardware Collective Evaluation R. Melton, TERA Documentation Coordinator J. Ma11anda, CPRT Electrical Review Team Leader
* Denotes those persons who attended the exit interview.
)
The NRC inspectors also contacted other CPRT and applicant employees during this inspection period.
 
. v
'e.
*?
l L
l l
l 2.
Applicant Actions on Previous Inspection Findings a.
-(0 pen) Open Item (445/8511-0-04): This item remains open pending the review and assessment of the dispositions relating to the 12 deviating skewed welds in NF supports.
Further review with respect to the status of this item has resulted l
in the NRC's identification of a violation.
During ERC's reinspection of skewed welds in Unit 1, undersize 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, 1
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 drawing.
The NCRs 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 revised by TUGC0 Nuclear Engineering (TNC) 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 TNE 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 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 THE 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):
Provisions for familiarizing QC i
inspectors with changes in QC inspection procedures.
Details on this subject are contained in paragraph 7.d'of this appendix.
l 3.
Followup On Alleged Contractor Improprieties The NRC inspectnr 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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improprieties,'if substantiated, could adversely affect safety-related components'and systems. NRC review of this subject' revealed that the alleged improprieties,'which consisted of eight specific items, had been i
I reviewed by the_TUGC0 Safeteam and by the'TUSI Director of Corporate Security. NRC examination of the items, certain of which were i
substantiated, resulted in a' determination that~there was no' instance.
i where 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
-]
a.
'NRR:
A site inspection:was performed during' October 10-11, 1985, l
jiiftainingtocivil/structuralissues. Audits were performed on October 25, 1985, at Ebasco and Stone and Webster, New York, j
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.
1 b.
IE:
An inspection of. Design Adequacy Redew was initiated at TERA,.
Fethesda, Maryland, during October.28 through November 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.
Implementation of ERC Procedures and Instructions (1) Audit of CPP-012 (OA/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 different process, as defined
~in CPP-012.
1 (a) Written requests for equipment and services are used by the QA/QC inspec. tors to request from TUGC0 or.B&R any equipment i,
or services needed to perform an inspection. These requests are included in the completed inspection package.
An NRC inspection of CPP-012 implementation showed that the requests for equipment and services were being processed in l
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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 the QA/QC L
Records Administrator.
This item is an NRC deviation.
1 (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 maintained by the QA/QC Inspection Supervisor, as required by Section 5.1.3 of CPP-012.. Subsequent to this report period, the NRC was informed by ERC management that this understanding was incorrect and that the required log was, in fact, being maintained in accordance with CPP-012 requirements.
L Followup. inspection confirmed that the ERC management 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 contrary 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 l
to deviation 445/8514-0-01.
(b) Document requests are used to request copies of TUGC0 or B&R 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 liaisen engineer by the QA/QC Records Administrator, who also logs atid files the-requests. The logged 4 tem is closed and the request filed when the information arrives from the TUGC0 liaison engineer. Two specific requests were traced by the NRC inspector through the Construction Sampling Reinspection Engineering Group and Records Administration, and found to have been satisfactorily processed and routed.
No NRC deviations were identified.
 
..~;.
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u
' 1-(2) CPP-018(QA/QC Interface with the Design Adequacy Program)
An NRC inspection confirmed that documents transmitted from ERC -
to TERA for information only were transmitted by the QA/QC Records Administrator.
Documents requiring feedback from TERA are logged and transmitted by the ERC Hardware Issues Supervisor.
The TERA Design Adequacy Program Interface Coordinator receives the ERC documents, distributes them and files one copy.
Items requiring feedback to ERC are logged in and the date of reply is also logged. The NRC inspector selected four documents from the ERC log and was able to satisfactorily trace them through the-ERC and TERA logging and filing. systems.
No NRC deviations were identified.
(3) CPP-010 (Preparation of Deviation Reports) and CPP-016 (Safety Significance Evaluations of Deviation Reports)
Deviation Reports (DRs) are generated during the hardware and documentation inspection process. These DRs are assessed for validity then forwarded for further processing to the Safety Significance Evaluation Group (SSEG) and TUGCO.
The NRC inspector confirmed that the process, which is described in CPP-010 and CPP-016, is being followed.
A sample of twenty DRs was selected from the SSEG tracking system.
Each DR was verified to be correctly processed and documented by checking each for: (a) signatures of originator, first reviewer, and second reviewer; (b) transmission of the DR to TUGC0 and SSEG, (c) transmission of the DR to the proper distribution; (d) filing of the DR in the verification package; and (e) confirmation from TUGC0 or B&R that they had assigned an NCR number to the DR. Revision 3 to CPP-010, which was released on October 11, 1985, incorporates provisions for revision, cancellation, or invalidation of a DR.
i No NRC deviations were identified.
(4) CPP-020 (Out-of-Scope Observations)
Review team personnel are instructed in CPP-020 to report apparent out-of-scope observations by three part memorandum to TUGCO.
In the NRC inspection of this subject, it was determined that tne ERC Supervisor, Hardware Collective Evaluation, assigned a serial number on receipt of the three-part memorandum and sent.two of the copies to TUGCO.
The remaining copy is filf
'sid' logged, with identification made of the record j
 
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, receiving date, date.sent'to TUGCO, and date_of TUGC0 feedback.
Six memoranda were reviewed by the NRC inspector to verify implementation of.this. process.
No NRC deviations were identified..
(5) Inspection of ERC-QA-15 (Performance'of Project Surveillance),
-l ERC-QA-18 (Administration of Quality Assurance Auditing), and ERC-QA-20 (Conduct of Programmatic Audits)
The ERC Project Assurance Mana'ger was contacted in an NRC inspection of these procedures..The following documents were produced:
(a) surveillance plan for QA/QC Review Team dated September 14,-1985;.(b) surveillance status report. dated
-October 21, 1985;.- and (c) a surveillance schedule.
The Project Assurance Manager maintains an active file and status log of'surveillcoce reports from the planning stage until the recommendations are implemented.
The surveillance reports are distributed to the corporate' office, to the QA/QC Review Team Leader (RTL), the Hardware Issues Supervisor, and the.
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 Administrator.
The NRC inspector reviewed fou,r 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 report, and a surveillance checklist.
No NRC deviations were identified.
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 corporate audit identified one deficiency.
A response to the audit was issued on October 21, 1985, providing corrective / preventive actions. The second quarterly audit is being planned at this time, but a specific date has not been set.
No NRC deviations were identified.
b.
TERA Procedures and Instructions l
TERA has issued 16 of the 19 planned design adequacy procedures l
(DAPs).
Review of these m n dures indicates that six apply, in l
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wIoleorpart,totheISAPsdefiningTERAonsiteactivity (civil-structural, mechanical, and miscellaneous). These are DAP-2,
" Documentation and Tracking of. Issues and Discrepancies"; DAP-14, i
" Design Adequacy Program Records"; DAP-15, " Training and i
Qualification"; DtP-16, " Audits"; DAP-17, " Corrective Actions"; and DAP-19, " Processing and Review of Information Between Quality of Construction,-QA/QC Adequacy Program and Design Adequacy Program."
DAP-14 and DAP-15 were audited by the NRC inspector and found to
~
comply with the applicable CPRT Policies and Guidelines.
The NRC has inspected the implementation in this area and the results of implementation of DAP-2 is reported in NRC Inspection Report No. 50-445/85-13; 50-446/85-09.
DAP-16 and DAP-17 are applicable to the onsite TERA effort; however, these procedures are implemented by offsite personnel reporting to the Design Adequacy Program Quality Assurance Manager.
This offsite TERA activity is being inspected and reported by the NRC Office of Inspection and Enforcement.
DAP-19 applies to the information interfaces between the Design Adequacy Program and ERC Quality of Construction and QA/QC Adequacy i
Program groups.
This DAP was audited by the NRC inspector in conjunction with the implementation audit of ERC Procedure CPP-018, as described in paragraph 5.a.(5) above.
1 No NRC deviations were identified.
c.
Implementation of CPRT Policies and Guidelines (1) Electrical Issues:
The electrical issues in the ISAPs are the responsibility of one RTL The CPRT Policies and Guidelines establish the methods for accomplishing these tasks.
The purpose of the NRC inspection was to determine if the processing of the electrical issues complied with the requirements set by the CPRT Policies and Guidelines. The inspection covered four of the guidelines; i.e., (a) central and working files, (b) safety significance evaluations (SSEs),
(c) developing sampling plans and random samples for TRT issues, and (d) policy on testing and inspection personnel used in third party verification activities.
This report completes the NRC's initial inspection of programmatic implementation in the area of
)
electrical issues.
l l
l
 
.L i
. (a) Working Files:
The working files system and subject matter breakdown being used is as described in the CPRT guidelines. A file index is available for each ISAP which defines the contents of each file folder. A computer based data system is being established for these files.
Two files were checked for compliance with the CPRT Policies
.and Guidelines.
No NRC deviations were identified.
(b) SSE: The NRC inspector reviewed the processing of ISAP i
E I.b.1 that resulted in one item which will require a i
SSE. This SSE will be included in the' review process for all SSEs generated by the CPRT.
No NRC deviations were identified.
(c) Sampling Plan: The sampling plan used on ISAP No. I.a.1 was reviewed by the NRC inspector.
It complied with the guidelines and was well documented.
Inspection confirmed i
that the information on the random sampling selection was I
turned over to ERC, who prepared the inspection packages, performed the inspections, wrote inspection reports (Iks) j for satisfactory and unsatisfactory conditions, and after i
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 writ, ten by TUGC0 on those where l
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.
No NRC deviations were identified, l
(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:
(i) experience and knowledge in i
the review subject matter (ii) experience in managing technical projects and reviews, and (iii) integrity and objectivity based on lack of previous involvement in the CPSES project activities.
j i
l I
l
 
f.
j The resumes and signed objectivity statements for the principal individuals involved in the electrical issues were reviewed.
No NRC deviations were identified.
4 (2) Testina Issues:
The purpose of the NRC inspection was to determine if the disposition of testing concerns complied with
.l the CPRT Policies and Gt M 11nes. 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 the file for these files.
No NRC deviations were identifigd.
(b) SSE:
One DR has been written and an SSE completed.
The hTC inspector reviewed the processing of this OR.
No NRC deviations were identified.
(c) Samplina Plan:
The sampling plan described in the program plan was not found to be feasible, so en alternate plan was developed. This revised plan was described in an appendix to the results report.
This practice is permitted by Appendix D of the CPRT Program Plan.
No NRC deviations were identified during a review of the original and revised sampling plans.
(d) Personnel Requirements: The resumes and signed objectivity statements for the RTL and each of the three issue coordinators were reviewed.
No additional NRC deviations to that noted in NRC Inspection Report No. 50-445/85-11, 50-446/85-06 were identified.
 
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. j i
6.
.CPRT ISAPs (Excluding ISAP No. VII.c)'
i Inspection Reports on Butt Splices (ISAP No. I.a.2) and Butt Splice
{
a.
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; l
(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 l
unsatisfactory, either by physical inspection or as a result of i
being undocumented; i
(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 i
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 i
The NRC inspe'ctor is continuing to review CPRT ISAP Nos.I.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 check of as-built drawings for 257 1 1/2-inch and 2-inch conduit runs in the combined random and i
 
I 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 j
all runs in the random sample and for 128 runs in the engineered j
sample.
Fifteen conduit runs have been identified, to date, as having the potential for interaction with safety-related components.
TUGC0 has initiated a dynamic test program at Corporate Consulting and Development (CCL) in North Carolina. The dynamic testing will l
provide actual strengths as compared to the previously used predicted values. TUGC0 will also conduct a damage study walkdown of all conduit runs currently determined to have potential interactions with safety-related components.
Evaluation of potential interactions for safety significance will utilize preestablished criteria to be specified in a walkdown procedure. This procedure is currently being prepared by Ebasco.
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.
QC Inspector Qualifications (ISAP No. I.d.1) c.
Status of CPRT Activity Phase 11 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 placed into Phase III.
Package preparation is complete for an eighth inspector.
I Status of NRC Inspection Activity During this reporting period, the NRC inspector witnessed 24 Phase III reinspection conducted by ERC inspectors and also performed 10 reinspection independent of ERC personnel.
No deficiencies were identified in these reinspection by either ERC inspectors or the NRC inspector.
 
?.
. -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 Personnel." 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 certification 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.S.
This issue was previously included in ISAP No. I.d.2.
RatusofNRCInspectionActivity t
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 Ty>es of Skewed Welds in NF Supports i
(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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. St tus of NRC Inspection Activity i
i:
The NRC inspector. witnessed a total of nine reinspection and performed three independent inspections of NF supports containing type 2 skewed welds. The results of NRC' Region I. inspections of skewed welds are documented in NRC. Inspection Report No. 50-445/85-13; 50-446/85-09. The planned NRC physical inspections for.this ISAP have now-been completed.
NRC evaluation of TUGCO's dispositions of 12' undersize type 2 skewed field welds is dependent upon the processing of the associated NCRs. This remains an open item (445/8511-0-04).
One violation was identified in this subject area which.is identified L
in paragraph 2.a of this-appendix.
f.
Plua Welds (ISAP No; V.'d)
Status of CPRT Activity
.i i
Reinspection has been completed for the presence of plug walds-in two random samples of cable tray hangers, consisting of 60 from Unit 1 and 61 from Unit 2. The reinspection resulted in the identification i
of-23 plug welds in 14 cable tray hangers.
Documentation was reviewed for all cable tray hangers containing plug welds. The results of this review showed that all of the plug welds were 3
authorized and documented.
Due to a mix of non-ASME component supports with ASME Section III'NF component supports in the two original i
. random samples (see item A, Notice of Deviation, NRC Inspection
]
Report No. 50-445/85-13,50-446/85-09), a new random sample of 57 NF component supports has been created and reinspection has been initiated.
Status of NRC Inspection Activity The NRC inspector witnessed 23 reinspection and performed 6 independent inspections of cable tray hangers.
With respect to NF component supports, the NRC inspector has witnessed a total of 23 reinspection and performed a total of 4 independent inspections.
Eight of the witnessed reinspection and one independent inspection occurred in this report period and were from the new random sample.
i Indications of possible plug welds were identified in two component support base plates during the witnessed inspections. The NRC inspector will witness the macroetching and inspection of these baseplates to determine whether or not plug welds exist.
No NRC violations or deviations were identified.
. j
 
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g.
Installation of Main Steam Pipes (ISAP No. V.e)
Status of CPRT Activity The specific engineering investigation of the main steam line installation is complete and is undergoing review.
The report i
describing the analytical evaluation of stresses and support load changes has been issued by R. L. Cloud & Associates (RLCA) and has been reviewed by TERA.
Review and revision of pipe procedures for pipe erection 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 NRCLInspection 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 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.
t (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 on 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.
a s
 
. 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 of the reinspection 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 reinspection indicate that data on material traceability in areas l
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 f
(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 l
the procedural controls to determine if requirements of I
Criterion XIII of Appendix B to 10 CFR Part 50 and the FSAR are i
l 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 effectiveness 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 been investigated.
The 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.
Therefore, no revision to this procedure is being made Comments on the adequacy of the number of swipes made will be in '.,he results report.
Specific TRT concern o'tPt of protective covering on equipment near welding activities wil N aidressed by reviewing the results of plant surveys.
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I e,
Status of NRC Inspection Activity L
l L
The NRC inspector has witnessed plant surveys'of the safeguards j
L building, Unit 2 reactor area, millwright shop, and ironworkers shop.
1 f
During these surveys, items such as trash or unidentified material p
were found in laydown areas where Quality (Q) material was stored.
These items were noted by TUGC0 and ERC personnel.
An independent I
/
l-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 A second reinspection of seven Borg-Warner (B-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 reinspection are now complete.
Of a total of four valid DRs issued for this ISAP, three SSEs have been completed. The fourth DR J
(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 temperature as 250 F and the design pressure as 300 psi, while the correspondingWestinghousedgsigntemperatureandpressureare listed, respectively, as 150 F and 150 psi.
The NRC inspector was informed by the % E engineer that disposition of the remaining SSE is pending rece:
of information from TUGC0 regarding valve temperature / pressure
'ings and TUGC0 resolution of the above described difference in der conditions.
i f
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u l' Status of NRC Inspection Activity.
A total of'eight reinspection 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 cnd Westinghouse design conditions had also been identified by TUGCO, and (2) e 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.
Ths 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 n1 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 i
/
a.
Electrical Cable Status of CPRT Activity 6
ERC has completed 85 reinspection and 71 documentation reviews of sampled electrical cable as of October 30, 1985.
Status of NRC Inspection Activity (1) The following eight ERC reinspection of sampled electrical cable were witnessed by the NRC during this report period:
Verification Package No.
Cable No.
I-E-CABL-078 EG113536 I-E-CABL-084 EG104608 s
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J 72q-I-E CABL-086 E01218162 I-E-CABL-088 E0124088 I-E-CABL-089 EG123639Z v.
I-E-CAB L-098 E0145694 '
T4 I-E-CABL-101 E0122951 1-E-CABL-102 1
EG139519 y
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(2) During the aboie reinspehtions,' ERC identified the following conditions to the NRC'Gsysctor as subject to. evaluation as potential deviations:
'(a) I-E-CABL-037: Two through-thr wall sleeves had identical identification tag number TWS-E-010.
The cable run also deviated from the cable run' schedule.
A (b) I-E-CABL-084:
Cable rLh deviated from the cable run schedule and cable was'r'c'uted through C13G06325 instead of C13G06324.
.s s
i
-(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:
j 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).
l (4) NRC inspectors did not identify any additional discrepancies with redect to the above eight packages.
 
(5) Independent documentation reviews were performed of 10 verification packages comprising 22 cables.
The results of the independent reviews are an open item pending NRC review of ERC results (44E/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 TUGC0 and will be evaluated further in a subsequent report (445/8514-U-16).
b.
Cable Trays Status of CPRT Activity ERC has completed 84 reinspection and 78 documentation reviews of sampled cable trays as of October 30, 1985.
Status of NRC Inspection Activity (1) The following two ERC reinspection of sampled cable trays were witnessed by the NRC in this report period:
Verification Package No.
Cable Tray No.
I-E-CATY-201 T2205BC89 I-E-CATY-247 TBGCCM62 No deficiencies were noted by ERC or NRC inspectors during these inspections.
l (2) The NRC performed independent reinspection 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 f
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).
No NRC violations or deviations were identified.
i
 
~'
1
~22-c, Electrical Conduit Status of CPRT Activity ERC has completed 79 reinspection and 76 documentation reviews of sampled electrical conduit as of October 30, 1985.
Status of NRC Inspection Activity (1) The following two ERC reinspection of sampled electrical conduit were witnessed by the NRC in this reporting period:
ic Verification Package No.
Conduit No.
I-E-CDUT-089 C13G07757 I-E-CDUT-098 C12020693 No deficiencies were noted by ERC or NRC inspectors during these iiispections.
(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-CDUT-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-CDUT-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 sn independent documentation review of i
this field witnessed activity and noted that the TUGC0 electr hal 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 inspsetion personnel be certified
 
1 l
l l l for a given inspection function / activity as being qualified i
to perform their assigned tasks. The lack of certification of the TUGC0 electrical inspector performing-the inspection of record for conduit EAB1-1 is a violetion (445/8514-V-04).
(b) ISAP No. VII.c requires original documentation review for attributes deemed to be inaccessible. A portion of conduit-C13916037 was found to be inaccessible during reinspection as a result of'being covered with separation barrier material (SBM). There was no ev.dence in ERC's Verification Package No. R-E-CDUT-064 that a check was made for attributes which were not accessible due to SBM installation. This is an NRC deviation (445/8514-0-02).
(c) QI-009, Revision 0, " Document Review of Conduit /R-E-CDUT,"
requires the reviewer to record the SBh 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 ifem 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-00VT-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-D-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 inspect conduit for separation after 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 availaole 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).
i i
w
 
I (f) The NRC inspector observed during documenta'. ion 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, EEB4-10505-8904, 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 reviews will be reported in a subsequent report after comparison of NRC review results with the completed ERC results. This is an open item (445/8514-0-10).
(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 reinspection and 19 documentation reviews of sampled electrical equipment installations as of October 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 previously 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 by the NRC:
t
- _ _ _ _ ~. _ _ _ _ _ _, _ _. _ _ _
 
~
' l,.
. Verification Package 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 sampled electrical equipment installation. The results of this review are an open item pending comparison with ERC results when available (445/8514-0-12).
No NRC violations or deviations were identified.
e.
Instrumentation Equipment Installation Status of'CPRT Activity ERC has completed 75 reinspection and 75 documentation reviews of sampled instrumentation equipment installations as of October 30, 1985.
. Status of NRC Inspection Activity (1) To date, eight reinspection have been witnessed by NRC inspectors with the following five reinspection witnessed in this report period:
Verification fackage No.
Unit No.
I-E-ININ-072 1
1-E-ININ-079 1
I-E-ININ-069 1
I-E-ININ-076 1
1-E-ININ-066 1
(2) During the above reinspection, 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) Orawing 2323-M1-2613, Revision 2, shows instrument
' PS-4251 as being located 6 feet 0 inches off the wall.
 
?
. This instrument was actually located 5 feet 0 inches off the wall.
I-E-ININ-079:
The tubing line from the component cooling water pump 1A to instrument 1-PT-4520 had reverse slope where it passed under the discharge line.
I-E-ININ-066:
Required color code was missing and maximum allowable distance between color code marks was exceeded.
I-E-ININ-069:
Sending units 1-LS-6712 and 1-LS-6717 were found to be reversed.
Dispositions of the above findings are open items (445/8514-0-13 through 445/8514-0-16).
No NRC violations or deviations were identified.
(3) ERC also noted the following deficiency outside of the defined inspection scope:
I-E-ININ-079: 01413591 was damaged at the connection to the instrument 1-PT-4520.
Disposition of the above finding is an open item (445/8514-0-17).
No NRC violations or deviations were identified.
(4) The following independent documentation reviews of sampled instrumentation equipment installations were made by the NRC inspectors:
Verification Package No.
Instrument No.
R-E-ININ-005 1-LS-4795 R-E-ININ-060 1-LS-3376 (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 instrument installations. According to paragraph 4.1 of ISAP No. VI).c, Revision 0, documentation reviews will be I
utilized to supplement reinspection for attributes which are nonrecreatchie or inaccessible.
Paragraph 4.1.3 of the same ISAP requires procedures to have detailed instructions
- - _ - ~ - _ _ _ _ _ _ _ _ _ _ _,
 
s
: f..
I '
4 for the document reviewers. QI-013, Revision 4, "Docume'ntation 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 i
vary between different revisions of a procedure. As an example, Revision 1 of QI-QP-11.8-8 adds to Revision 0 l
requirements an inspection checklist addressing verification j
of: (i) color codes for nuts; (ii) flange face cleanliness; 1
(iii) gasket size, rating, and material type; (iv) nuts being tightened in a diametrically opposite sequence; (v) studs being the same 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).
i (b)
In the review of Verification Package No. R-E-ININ-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 reinspection were performed by the NRC inspector on Verification Package Hos. 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 identify that: (a) required color coding on six sections was missing, (b) incorrect slope was present, and (c) an incorrect air gap condition was present.
The failure of ERC inspectors to identify the above conditions is an NRC deviation (445/8514-D-04).
*l f.
HVAC Ducts and Plenums Status of CPRT Activity As of October 25, 1985, reinspection have been completed for 62 of 95 random items in the HVAC ducts and plenums samples. The I
i I
 
'O reinspection have identified conditions which necessitated the l
issuance of 75 DRs, 38 of which have been validated.
Twelve DRs have l
been evaluated by ERC and were found to be nonsafety significant.
A i
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, j
lock washers not installed on vent lock mounting screws, deteriorating
)
connecting flange gasket, and seal weld not touched up with paint.
l
\\
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, eight reinspection 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 Packaae No.
Unit No.
I-M-DUPL-021 1
l I-M-DUPL-073 1
I-M-DUPL-084 2
I-M-DUPL-086 1
(2) During the above reinspection, 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 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.
 
. 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 445/9514-0-20).
(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 reinspection, the ERC inspector did not r.easure 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 5,tatus of CPRT Activity As of October 25, 1985, reinspection have been completed for 38 of 89 random items in the HVAC equipment installation samples.
The reinspection have identified conditions which necessitated the issuance of 68 DRs, none of which have been currently validated.
Reinspection was on hold for approximately one week, pending a change notice to QI-023, Revision 0.
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 method of certification of gravity damper counterweight balance.
Previously reinspected items will require a followup reinspection, where applicable, as a result of this revision.
The NRC inspector was informed by the population engineer that the HVAC equipment installation plan will be revised to incorporate two distinct populations, each requiring a minimum sample size of 60.
One population will include all HVAC equipment installed by Bahnson Services, Inc., while the others will include all HVAC equipment installed by B&R.
This change will not necessarily invalidate any
 
1, :
1
\\
i I reinspection conducted to date, but could effectively double the l
total number of items to be reinspected in the initial sample, i
Status of NRC Inspection Activity (1) As of October 25, 1985, a total of four reinspection 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 reinspection, ERC identified the following conditions to the NRC inspector as subject to evaluation 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 outlet duct connection gaskets had low and uneven compression, (b) diameters for foundation anchor bolts and duct connection bolts were illegible in drawings provided in the inspection package, and (c) exhaust duct connection bolts did not have full thread engagement with nuts.
I-M-HVIN-043 (Motor Operated Damper):
(a) A nameplate was not obterved on the equipment, and (b) the actuator spring could not be located which is required for verification of fail closed or fail open positions.
I Dispositions of the above findings are open items (445/8514-0-22, 446/8511-0-04, 445/8514-0-23 and 445/8514-0-24).
(3) The folleving potential out-of-scope deviation was also identified by ERC:
 
4h
. I-M-HVIN-043:
Some of the bolts attaching the actuator to the mounting bracket did not have full thread engagement.
Disposition of the above finding is an open item (445/8514-0-25).
No NRC violations or deviations were identified.
h.
Large Bore Pipino 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 reinspection identified conditions which resulted in the issuance of 34 DRs, 18 of which, to date, have been validated and are undergoing an evaluation by ERC for safety significance.
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 had been previously inspected and accepted by construction QC. Approximately 24 previously reinspected items will-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 HRC Inspection Activity ERC methods and related documents used in establishing the population i
items list were reviewed for population inclusiveness.
Completed SSE reports are currently being re ' wed by the NRC inspector. As of October 25, 1985, four reinspection have been witnessed by the NRC inspector, with the following verification package reinspection being witnesscd during this report period:
 
3 c.;
i I
' I-M-l.BCO-113 (Unit 2):
During this reinspection, ERC identified one condition as subject to evaluation as a potential deviation, i.e.,
flanges that 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.
i.
Piping System Bolted Joints / Materials ERC has completed 73 reinspection of piping system bolted i
joints / materials as of October 26, 1985.
However, on eight of these reinspection 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 alto completed document reviews on 14 of the 73 packages.
The 73 packages represent 100% of the combined' random and engineering samples.
Status of NRC Inspection Activity (1) The following ERC reinspection was independently inspected by the NRC inspector:
Verification Package No. Drawing No.
Flange No. Unit No.
I-M-PB0M-34 BRP-SI-1-RB-048 1
1 With respect to the above inspection, the NRC inspector concurred with the ERC inspector's finding that the flange type was not hardstamped on the flange as required by the inspection procedure, and that this condition is subject to evaluation as a potential deviation.
Subsequently, the inspection procedure was revised to allow inspectors to visually identify the type of i
flange if it is not hardstamped with such information.
The above will be reinspected by ERC for this particular attribute.
No NRC violations or deviations were identified.
(2) The following conditions which were identified by ERC in September as subject to evaluation as potential deviations had DRs written for them: (a) I-M-PBOM Flange No. 1 (Drawing BRP-SW-1-SB-003) had a loose nut, and (b) I-M-PB0M Flange l
I
 
/,.
d ~
No. 3 (Drawing BRP-CH-1-EC-004B) 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 NRC violations or deviations were identified.
j.
Small Bore Piping and Instrumentation Tube Welds / Material Status of CPRT Activity Reinspection is in progress of small bore pipe and instrumentation tube welds and material present in a random sample of 60 welds from Units 1 and 2.
Forty-four small bore pipe and instrumentation tubing welds have been visually reinspected.
Base material heat codes and welder identifications have been recorded and are undergoing documentation review.
No deviations have been found.
Status of NRC Inspection Activity i
The following seven reinspection of small-bore piping welds were witnessed by the NRC inspector:
)
Verification Package No. Pipe No. & Weld No.
BRP No.
I-M-SBWM-016 CH-2-216-152-3, Weld 11 CH-2-SB-009 I-M-SBWM-003 SW-2-368-105-3, Weld 23A SW-2-AB-027 I-M-SBWM-013 CC-2-064-152-3, Weld 1-1 CC-2-SB-002 I-M-SBWM-040 CH-1-220-152-3, Weld 37-2 CH-1-SB-024 I
j I-M-SBWM-076 CS-1-905-250-R2, Weld 18 CS-1-RB-013 I-M-SBWM-054 CT-1-127-901-R2, Weld 56 CT-1-RB-031 I
I-M-SBWM-057 CT-1-127-301-R2, Weld 43 CT-1-RB-031 No conditions subject to evaluation as potential deviations were identified by ERC to the NRC inspector.
No NRC violations or deviations were identified.
k.
Large Bore Piping Welds / Material Status of CPRT Activity l
Visual reinspection is in progress of a random sample of 60 ASME l
Section III large bore piping welds and material from Units 1 and 2.
l To date, 35 large bore piping welds have been reinspected. One deviation has been identified which is currently being evaluated for l
validity and safety significance by ERC.
l 1
l
 
__.a.
,s-g
. Status of NRC Inspection Activity As of October 25, 1985, the following eight reinspection 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 C5-2-58-030 I-M-LBWM-026 BR-X-056-151-R-3, Weld 7 BR-X-AB-048 I-M-LBWM-030 DD-1-18-151-3, Weld 16-1 DD-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
)
i No conditions subject to evaluation as potential deviations were identified by ERC to the NRC inspector.
No NRC violations or deviations were identified.
1.
Large Bore Pipe Supports - Rigid Status of CPRT Activity Reinspection / verification of pipe support installations by ERC is approximately 94% complete.
A total of 151 deviations have been identified of which 98 have been determined to be valid. The remainder are currently being reviewed for validity.
Status of NRC Inspection Activity (1) The NRC inspector performed independent inspections on pipe support Verification Package Nos. I-S-LBSR-013 and -023, in order to assess the adequacy of the ERC reinspection. 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-5-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 i
tolerances not shown on design drawings, " Component Member Length +/- 1/2 inch." The Bill of Material on Revision 2 of drawing No. CT-1-097-402-CS2R lists item No. 4 (2 pieces) as being 7 3/4 inches long.
Independent NRC inspection determined the actual length dimensions to be, respectively, 6 5/8 inches and 6 1/2 inches, both of which are under the minimum indicated dimension of 7 1/4 inches (445/8514-0-04).
 
.!I (2) During inspection of the installation of box frame supports, which are a part of the Unit 1~ containment spray system, the NRC inspector observed that clearances exist between the bottom 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 i
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.
ji (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 reinspection.
This effort revealed that ERC had performed their reinspection in accordence with the requirements of QI-029.
No NRC violations or deviations were identified.
* o s n.
Small Bore Piping Configuration Status of CPRT Activity As of October 25, 1985, reinspection was complete for 64 of 95 random sample small bore piping configuration items. The reinspection identified conditions which resulted in the issuance of 45 DRs, 25 of which were validated and are being evaluated by ERC for safety significance.
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 reinspection 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-SBCO-015 l
I-M-SBCO-061 1
I-M-SBCO-079 2
 
.i
. (2) During the above reinspection, ERC identified the following conditions to the NRC inspector as subject to evaluation as potentiel 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.
o.
HVAC Duct Supports Status of CPRT Activity Visual reinspection 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 reinspection of sampled HVAC duct supports were witnessed by the NRC:
Verification Package No. Unit No.
Duct Support No.
I-S-HV05-023 1
CB-830-IN-1R I-S-HVDS-041 1
AB-842-1L-1F I-S-HV05-005 2
CB-790-2N-1BF (2) During the above reinspection, ERC identified the following i
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-5-HVDS-041:
Undersize fillet welds.
1 i
 
,v
. 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 NRC violations or deviations were identified.
p.
Containment Liner and Tank Stainless Steel Liner Status of CPRT Activity Ninety-oneverif[cationpackageshavebeenissuedandreinspections are approximately 96% complete using QI-031, Revision O.
Documentation review of these packages using QI-032, Revision 0, is approximately 45% complete.
Eighty-three ors 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 samrle of 60 structural steel members was selected from a total population of approximately 1600 individual members.
l 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.
MatusofNRCInspectionActivity (1) The NRC inspector has reviewed QI-045, Revision 1.
The following three inspections have been witnessed representing 5%
of the first random sample-
 
A
.j, -
+
1
-39' l
I Verification Package No.
Equipment No.
Unit No.
I I-S-STEL-120 MRB-0565-DCA-MK-A 1
)
I-S-STEL-88 AFC0-MK-C182-7-RB 1
I-5-STEL-95 AFC0-MK-0180-1-RB 1
1 1
(2) During the above reinspection, 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).
i 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 inspector has reviewed QI-043, Revision 0, and witnessed 9 reinspection representing 15% of the first random sample of 60 concrete placements.
The following three ERC reinspection were witnessed by the NRC inspector during this report period:
l
 
4
_ _.s.
,,.,7 w.
. Verification Package No. Concrete Placement No.
Unit No.
1 I-S-CONC-40 CPC-105-6831-014 1
I-S-CONC-51 CPC-105-5865-012 1.
l I-S-CONC-11 CPS-101-2808-001
-1 (2) During the above reinspection, 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 j
(Richmond) were out of tolerance.
OR I-S-CONC-40-DR1 was issued
' subsequent to the inspection.
I-S-CONC-51: Voids were identified in the concrete surface.
DR I-5-CONC-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.
)
A total of 65 Physical reinspection are approximately 95% complete.
l deviations have been identified, relating primarily to Hilti bolt j
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.
l Status of NRC Inspection Activity The NRC inspector has reviewed QI-019, Revision 2, and QI-020, Revision 0, Six physical reinspection representing 10% of the first
 
k O6 -
41 random sample were witnessed by the NRC inspector during September 1985.
No reinspection were witnessed during this report period.
i 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 reinspection of pipe whip restraints as of October 26, 1985.
i Status of NRC Inspection Activity
. (1) The following two ERC reinspection 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 reinspection, ERC identified the following 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.
I-S-PWRE-518: The grout did not completely cover the shim plate underneath the top baseplate.
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 i-inspection scope:
I-S-PWRE-052:
One of the Richmond inserts on concrete column No.15 overlapped a Hilti bolt embedment for a pipe support on the adjacent face of the same column by approximately 2 3/4 inches. The Hilti bolt centerline was about 5 inches l
l-r I
 
,5 d
,.y ',N.
' 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.
Dispositions of the above findings are open items (446/8511-0-10 I
.and 446/8511-0-11).
No NRC violations or deviations were identified.
u.
Reinspection of Instrument Pipe / Tube Supports Status of CPRT Activity ERC has completed 42 out of the planned 102 reinspection of instrument pipe / tube supports as of October 26, 1985.
Status of NRC Inspection Activity
'(1) The following four ERC reinspection of instrument pipe / tube supports were witnessed by the NRC inspector during this report 1
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
l l
1-5-INSP-024 1-P15-3384 1
I-S-INSP-057 1-LT-459 1
(2) During the above reinspection, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations:
I-S-INSP-004: (a) Support Nos. 4B, 4C, 4D, 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 l
1
 
~
~
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43-
+
(d) support Nos.17A,il7J, and 17K had different type. instrument tubing clamps,than specified on the drawing.
I-S-INSP-024:
(a) Support No. 24H had.an undersized weld; (b) support No. 24H had no visible heat numbers'_on the baseplate; i
(c) support No. 24H had a structural tubing length of o
56 3/4 inches, which is.1/2 inch greater than the maximum-allowable length specified on the drawing; and:(d) support No.
24H had a different type of instrument tubing clamp than specified on the drawing.
-I-S-INSP-057: (a) Support Nos. 57A-and 57E did not have the-serrated grooves of the spring nut aligned with the channel ridge; (b) support Nos. 57N'and 57P had spring nuts'used in lieu of required hex nuts; and (c) support No. 57N had a bolt that did not have minimum 70% of specified torque.
Dispositions of the' above firidings are' open items (445/8514-0-35 through 445/8514-0-38).
(3) -The following two ERC reinspection were independently inspected by the NRC inspector:
o Instrument Tag No.
Unit No.
Verification Package No.
I-S-INSP-007 1-PT-405-1-
'I-S-INSP-028 1-PI-2467 1
While performing the above independent inspections, it was noted that on support Nos. 007D and 028A, the serrated grooves on the spring nuts did not align with the channel clamping ridge.
This is required by attribute.4.5 of QI-055, " Reinspection of Instrument' Pipe / Tube Supports." However, the ERC inspectors signed off this attribute as being_ acceptable. This is an NRC deviation (445/8514-0-04).
8.
Unresolved Items 1
Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable items, violations, or i
deviations.
Seven unresolved items disclosed during the inspection are 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 representatives denoted in paragraph 1 of this appendix. During this interview, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the finding.t.
 
.y,#
' ' o, I
APPENDIX F U. S. NUCLEAR REGULATORY-COMMISSION REGION IV.
CABLE TRAY SUPPORT MODIFICATIONS INSPECTIONS NRC-Inspection Report:
50-446/85-11 CP:
CPPR-127 Docket: 50-446 Category: A2
-Applicant:
Texas Utilities Electric Company 400 North Olive Street Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES), Unit 2
. Inspection At: Glen Rose, Texas Inspection Conducted:
Se tember 30 - October 2, 1985
(
3/pM6 Inspector L.V.ftflbeft,ReactorInspector Aa)4 Reviewed By: Ibe
.3/3/6'4 I. Barnes, Group Leader, Region IV Date CPSES Group Y Y/4 Approved:
T. F. Westerman, Chief, Region IV CPSES Group Date i
Yr/
~9/Y/PX y
R. E. Ireland, Chief, Engineering Section Date i
Reactor Safety Branch M 905 h 860306
/fft gDR ADOCK 05000445
/
PDR
 
s. ''
.sY*
'l
(
g.
Inspection 56mmary Inspection Conducted September 30 - October 2, 1985 (Report 50-446/85-11)
Areas Inspected:
Routine, unannounced inspection of cable tray support modifications. The inspection involved 24 inspector-hours onsite by one NRC inspector.
Results: Within the area inspected, no violations or deviations were l-identified.
1 s
e
 
n
- ~ Tn ?
o m
a y.
v3 Q' lM s DETAILS 1.
Persons Contacted Applicant Personnel
*P. Halstead, Site QC Manager Brown & Root (B&R) Employees W. E. Baker, Senior Project Welding Engineer D. Mantz, Cable Tray Hanger General Foreman D. Geeo, Cable Tray Hanger Foreman Other contractor personnel were also contacted during the course of this inspection activity.
* Denotes those present at the exit interview.
2.
Safety-Related Cable Tray Support Modifications The NRC inspector reviewed the documentation traveler packages and inspected the weldments for 12 cable tray supports that had been modified using tube steel in the new design. The following supports were inspected:
Support Classification CTH-2-11843 Class 1 CTH-2-11846 Class 1 i
CTH-2-11841 Class 1 CTH-2-11684 Class 1 CTH-2-10040 Class 1 CTH-2-9741 Class 1 CTH-2-11542 Class 1 CTH-2-11541 Class 1 CTH-2-11540 Class 1 CTH-2-9732 Class 1 CTH-2-9733 Class 1 CTH-2-10033 Class 1 e
In the areas inspected, the table tray support weldments complied with the requirements for welding in Weld Procedure. Specification No. 10046 and the requirements for visual weld inspection in Instruction QI-QP-11.21-1. The documentation for the supports was consistent with the status of the work.
I No violations or deviations were identified.}}

Latest revision as of 18:38, 22 May 2025

Rev 2 to Section 17.1, Site Const QC Records, to QA Plan. Related Info Encl
ML20238A826
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/18/1985
From:
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20237J194 List: ... further results
References
FOIA-87-87, FOIA-87-A-14 NUDOCS 8708310235
Download: ML20238A826 (30)
v • d • e


Text

,_. -.. - _ _ _ _.

c.

Copy No.

226

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COMANCHE PEAK STEAM ELECTRIC STATION QUALITY ASSURANCE PLAtt

?

TEXAS UTILITIES GENERATING COMPANY EXHIBIT 45 B708310235 870819" l

I

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PDR FOIA I

BAUMANB7-A-14 PDR t

- - ~. - -

_ _v QUALITY ASSURANCE PLAN p+p y, %g SECTION : 17.1

  1. $N -,

DATE: 10-18-85 g

f, IITE CONSTRUCTION QUALITY CONTROL RECORDS REVISION : 2 PAGE 1 OF 1 17.1 Site Construction Quality Control Records

_ Quality Control documents are initiated, collected, and maintained in accordance with approved procedures.

These documents shall be filed and l

controlled. The procedures / instructions define the records required to be retained and define the provis' ions required for suitable protection of records. Upon completion of an activity, the documents initiated are reviewed and the completed QA records. are then transferred for retention at the plant site.

The responsibility for implementation of the on-site record control and filing system is identified in site procedures and is subject to audit by TUGC0 QA to assure compliance.

~

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9C h-7 4.

Aco11 cant Action on IE Bulletins (IE8s)

In response to discussions regarding the TUGCo profiram concerning.!E8s, h

e.

Circulars, and Infonnation Notices Region IV was 'nformed that TUGCo s

will perform a review of related procedures and records to determine the adequacy of procedures and the completeness of associated records.

The initiation of this effort will follow the task review of the 10 CFR Part 50.55(e) program which is presently in crogress.

,_ 4.

This item is unres'o1ved (445/8516-U-02, 446/8513-U-02).

b.

The TUGCo actions _on sd l.e., Nos. 79-14 an 8)were selectJ -to~rievi rdware evaluatlbns-cr_ repair /replac ts.

TUGCo d

10JR1.og Sh

, page 10. dated April 9, 1984 M as reviewed to 7

etermine dhe status of the IEBs.

y (1) IEB 79-14 was evaluated by TUGCo in 1983 anwas statused as d

/

closed. The.HRC inspector indh:sted that the closure of IEB 79-14

/

was premature since Stone & Webster is currently analyzing Unit 1 \\

seismic analysis versus as-built drawings, which directly relates i to this IEB. Unit 2 as-built work has also not been completed.

1 TUGCo stated that the IEB 79-14 file will be reopened and a supplemental report will be submitted upon completion of the ongoing project engineering work.

/

/

wThe above item (IEB No. 79-14) status is considered an openJttn (445/4516-0-03,446/8513-0-03).

(2)

IEB 79-28 identified deficiencies with certein manufactured lots of NAMC0 EA 180 limit switches. The gasket material of the faulty lots, when exposed to temperatures above 175'F. vaporized and emitted a yellow-brown crystal like resin that can cause these switches to fail. The NRC inspector found the TUGCo documentation to be complete with respect to the specified corrective action of replacing these switches with switches manufactured in acceptable lots.

Field verification of replacement of 14 switches identified, however, that the identity of 2 switches could not be traced to existing travelers.

Specifically, the replacement NAMCO limit

/ switches on residual heat ramoval valves 1-HCV-606 and 1-FCV-618 were identified on travelers EE 82-1415-5801 and EE 83-0373-5801 as EA 180-32302 and EA 170-31302, respectively.

The switches actually installed in the field were identified as EA 180-31302 and EA 180-31302, respectively.

TUGCo is evaluating this inconsistency to deteraire if there is other documentation to account for this.

This item is unresolved (445/8516-U-04, 446/C513-U-04).

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Addenda 1 to July 23, 1986 Testimony (page 583)

Phillips assigned McKluskey to inspect.IEB 79-14 without any considerations of.past inspections of IEB 79-14.

It is my understanding that he' assigned' McKluskey to inspect this Bulletin because he did not consider that Region IV-had looked at hardware associated with IE Bulletiscorrective action. The.

hardware associated with this Bulletin has..since the beginning, been inspected on numerous occasions ~includin 50-445/82-05 which

' looked at' the initial program. g NRC' Inspection Report In this first inspection of the TUGCo 79-14 verification program, R. Brickley

'(who was assigned out of the Vendor. Branch to the IEB 79-14 Task Force) was on i

site and looked at pipe support hardware.

C..E. Johnson inspected the TUGCo

. lEB 79-14 verification program.

The Special Inspection Team (SIT) was a full team inspection devoted to pipe and pipe supports issues. The CAT inspection inc %ded pipe and pipe supports.

Region IV performed a series of room turnover inspections which included pipe i

and pipe supports.

The Technical Review Team (TRT) inspected pipe and pipe supports.

At present, Stone.and Webster (S&W) has full responsibility for the pipe support issues at CPSES. A~whole new program is in progress and NRR has the oversight responsibility for both design and the pi The' third party, Energy Research Corporation (ERC) pe support inspections.

is, in addition to S&W

-walkdowns,. performing independent inspections. The third party. design-organization, TERA, is~also overseeing the S&W design' effort. The Region IV Comanche Peak Group is performing independent inspections of the ERC effort which includes independent inspections of the pipe supports. The Office'of Inspection and Enforcement has been requested by NRR to audit the S&W QA program associated with CPSES activities.

My point is that the Phillips' decision to inspect this Bulletin certainly wasn't coordinated with RIV management.

I believe the pipe and pipe support effort was already being adequately covered by RIV and NRR.

G7.s;n a

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j 5.

0A Records Retention l

The NRC. inspectors found that construction deficiency and IEB files were not stored in the QA records vaults.

Because such records have not been deposited in a central location, difficulties have been encountered in retrieval.

TUGCo is assessing this record file issue.

This item ~is open pending the completion of their review (445/8516-0-05,

'446/8513-0-05),

i 4

,k ':'

-s J-/

AyC / && A l

M l

(0 pen) Unresolved Item (445/8514-U-03, 446/8511-0-02):

Incomplete g.

TUGCo has' indicated ffgnificant deficiency analysis report files.

the.t actions are being taken to identify all records necessary to i

close out open files. This action is scheduled to be completed by March 1, 1986.

___m__

')).

}@[- Ib l}

/'

i

,(0 pen)UnresolvedItem.h445/8514-0-02,446/8511-U-01):

f.

Procedures do not address 10 CFR Part 50.55(e) file content or provide a method for completion /signoff for corrected construction deficitacies. The NRC inspector reviewed TUGCo Procedure NEO CS-1 entitled, " Evaluation of I

and Reporting of Items / Events Under 10 CFR Part 21 and 10 CFR Part 50.55(e)." The review revealed that the following procedures

]

were inconsistent with Procedure NEO CS-1:

CP-QP-16.1, Revision 6, dated January 16, 1985; TNE-AD-5, Revision 3, dated June 21, 1984; DQP-QA-12, Revision 2, dated September 9, 1985; and CP-QP-15.6, j

Revision 3 dated January 16, 1985.

The inconsistencies included conflicting responsibilities, method of evaluation, deportability criteria, notification policy, and reporting instructions.

TUGCo has committed to the resolution of file tracking problems and procedural inconsistencies by March 1,1986.

I

QdTHb/J

/

/ 7C k6-7

~ 4. -

Applicant Action on IE Bulletins (!EBs)

In response to discussions regarding the TUGCo program concerning IEBs,

'a.

Circulars, and Information Notices, Region IV was informed that TUGCo

/

will perform a review of related procedures and records to determine the adequacy of procedures and the completeness of associated records.

i The initiation of this effort will follow the task review of the j

10 CFR Part 50.55(e) program which is presently in progress.

Thisitemisunre'shved(445/8516-U-02,446/8513-U-02).

b.

The TUGCo actions on two IEBs (i.e., Nos. 79-14 and 79-28) were selected to review hardware evaluations or repair / replacements.

TUGCo 10ER I.og Sheet, page 10 dated April 9. 1984, was reviewed to l

detemine the status of the IEBs.

(1) IEB 79-14 was evaluated by TUGCo in 1983 and was statused as d

closed. The NRC inspector indicated that the closure of IEB 79-14 was premature since Stone & Webster is currently analyzing Unit 1 seismic analysis versus as-built drawings, which directly relates to this IEB. Unit 2 as-built work has also not been completed.

TUGCo stated that the IEB 79-14 file will be reopened and a i

supplemental report will be submitted upon completion of the l

1 ongoing project engineering work.

The above item (IEB No. 79-14) status is considered an open item (445/8516-0-03,446/8513-0-03).

(2) IEB 79-28 identified deficiencies with certain manufactured lots l

of NAMCO EA 180 limit switches. The gasket material of the faulty lots, when exposed to temperatures above 175'F, vaporized and emitted a yellow-brown crystal like resin that can cause these J

switches to fail. The NRC insp:ector found the TUGCo documentation

]

to be complete with respect to the specified corrective actiot Of replacing these switches with switches manufactured in accept # r lots.

Field verification of replacement of 14 switches irentified, however, that the identity of 2 switches could not be traced to existing travelers. Specifically, the replacement NAMCO limit

/ switches on residual heat removal valves 1-HCV-606 and 1-FC)'-618

]

4 were identified on travelers EE 82-1415-5801 and EE 83-0373-5801 as EA 180-22302 and EA 170-31302, respectively.

The switches l

actually installed in the field were identified as EA 180-31302

/

and EA 180-31302, respectively. TUGCo is evalu,4 ting this inconsistency to determine if there is other documentation to account for this.

i This item is unresolved (445/8516-U-04, 446/8513-U-04).

]

i I

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1 they made more chan'ges.

It's a matter of getting 2

the right paperwork.

3

0. -

But the paperwork reflects to get~back 4

to George's point yesterday or two weeks ago --

5 what the control is in the facility which reflects 6

upon the -- you're only doing a limited sample.

7 A.

That would be a work package issue.

If I 8

went looking for it, there should be a work 9

package issue th.at would cover replacement of

'10 these switches, probably identified which ones; 11 and there should haye been a' status of it.

12 Q.

Is this Mr. Wagner who closed this out?

13 A.

Yes.

I would only sample -- if the man 14 says, " Hey, we've done 79-28," I would go out.and 15 s a:nple that.

See AM 8ab 2 t

16 A.

Okay.

17 0-

'By Mr. Mulley) okay.

~' --

18 A.

The next one is -- the next two, I guess,

]k } L/ 19 a

really deal wi th "TUGCO's procedure for handling 20 IEB are deficient in that they do not describe how 21 construction management / personnel handle IEB 22 requiring IEB requiring action, especially

))

23 hardware repair, replacement, and modification,

~

y e - ---

24 Prior to write-up, I stated to management that r..

{

25 this is a violation; but management disagreed.

I 6

628 i

4 1

/

1 wrote it as unresolved."

2 Okay.

We're back at this status of 3

what's done in the IEB.

The utility gives you a

4 reply and tells what you they're going to do under 5.

the IEB.

Then we would normally go verify that.

4 6

For example, my prior experience has been 7

in Arkansas.

I don't recall having some status on B

each IEB kept at the site by the construction 9

folks that were putting in the IEB.

I don't know 10 that that was a necessary procedure.

l IN 11 There is,their procedure a man assigned 12 and they got two procedures, as a matter of fact, i

13 that cover that kind of arena.

Lo that when an IE 14 bulletin comes in, he then looks at it and assigns 15 it out or writes out correspondence internally to 16 folks within the company that certain actions have 17 to be taken; and they, in turn, provide him back 18 with the actions taken or being taken to comply 19 with the bulletin.

20 That reply is put into a reply draft and 21 sent back to the Commission.

Having the 22 construction site have a separate tracking and 23 status of of IEB, I couldn't see how that would be 24 a regulatory requirement placed on the utility 25 company.

1

62'9 j

l' They handled it consistent with where 1 2

had seen bulletins handled.

3 Q.

Doesn't this go back to the first 4

sentence in the whole issue?

5 A.

Yes.

6 Q.

You're going to review procedures and 7

  • records to determine the adequacy of procedures?

8 A.

That's correct.

And we did provide them 9

that.

I didn't drop it.

I left the insert 10 says, " Management dropped and wrote insert No. 2 11 in Document No.

4,"

which is essentially the words 12 that we're.looking at there.

13 I think the next one is the same thing, 14 "No TUGCO construction focnl coint for tracking 15 IEB actions.

Prior to write-up, I stated to 16 man ag e me n t.. t h a W;his is a viel en; b u-t-17 management disagreed.

I wrote it as unresolved."

18 This is much of the same.

This is again 19 contrary to what any inspectors in the past had I

20 been able to do in closing out bulletins, l

l 21 including looking at hardware, looking at l

22 documentation and find'ing what they i. :$ed to 23 close it.

24 Q.

(By Mr. Mulley)

So, he's saying here 25 that he couldn't go to a central person to find

f _. (-

630 b

/\\

1 out how to track the paperwork on these bulletins?

l 2

A.

That's correct.

3 Q.

And you're saying that in the past 4

inspectors have been able to do that?

5 A.

Well, you got to taka what the utility 6

replied to in the bulletin ard said, "We are doing I

7 certain things."

s 8

If they say, for ex :mple, ' they are 9

replacing NAMCO switches, you should be able to go 10 find out if they're replacing NAMCO switches.

11 I don't have the exact piece of work 12 order down 02 each one that was listed to go out 13 and do that replacement.

I don't believe that 14 that is a requirement that has to be in an IEB 15 file.

16 Now, if I was going to do my druthers and 17 I'm the utility company, I would probably trace it 18 a lot further than what TUGCO has done; and that's 19 part of the reason Mr. Johnson and I had say the 20 discussion with them because, again, if they're t

21 leaving themsel,f open for material false Nees 22 statements, th y're going to come down with both 23 feet on them.

24 I don't know anybody that wants a 25 material false statement.

Log # TXX-4779 File # 10130 IR 85-14 85-11 TEXAS UTILITIES GENERATING COMPANT SKYW AY TOWER e 400 NORTH OIJVE FFREET, L.h. S R

  • D ALLAB TEXAS 78301 May 16, 1986 fg

/

e Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NO.:

50-445/85-14 AND 50-446/85-11

Dear Mr. Johnson:

We have reviewed your letter ofcMarch 6, 1986,fconcerning the inspection by Mr. T. F. Westerman and others of-the-Region IV Comanche Peak Group during the period September 30 through October 31, 1985.

This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2.

We requested and received a four week extension in providing our response during a telephone discussion on April 7, 1986.

We requested and received an additional two week extension during a telephone discussion on May 2, 1986. We have provided our response to the Notice of Violation and the Notice of Deviation in the attachments to this letter. To aid in understanding our response, we have repeated the Notice followed by our response.

Very truly yours, 67' W. G. Counsil JWA/arh c-Region IV (Original + 1 copy)

Director, Inspection and Enforcement (15 copies)

U. S. Nuclear Regulatory Commission Washington, D.C.

20555 Mr. V. S. Noonan Mr. D. L. Kelley

> 2/ - n D & 2

[

%, c

.s y',J G A DEV152ON OF TEXAS UTTLITIES ELECTKJC COMPANY

1 c'._

NRC Notice of Violation 3

Item A (445/8514-V-01) 1 i

Criterion XVII of Appendix B to 10CFR Part 50, as implemented by Section i

3.8, Revision 4, of the Operations Administrative Control and Quality

)

Assurance Plan, requires that (1) sufficient records shall.be maintained to furnish evidence of activities affecting quality, end (2) that the records shall include the results and acceptability of tests and analyses, and the action taken in connection with any deficiencies noted.

Contrary to the'above:

1.

A significant number of instances of missing data entries was noted in water chemistry records covering the period March 1983 through September 1985, with respect to the chemistry sampling frequency requirements of Procedures CHM-501, " Chemistry Control of the Primary Cooling Water Systems." No annotations were made in the records to explain why the samples were not taken.

2.

Review of the water chemistry records showed instances of failure to make required entries to indicate when the Shift Supervisor was notified in regard to out-of-specification chemistry results.

3.

The records did not identify what corrective actions were taken after entry of out-of-specification results.

4.

Inadequate reviews were performed of the acceptability of water chemistry data, as evidenced by the presence of review and approval signatures on forms containing discrepant data results.

Response to Item A Notice of Violation 445/8514-V-01 is written in four parts, each of which is addressed separately.

Part 1 1.

Reason for Violation:

An investigation by the Chemistry and Environmental Engineer I

confirms instances of missing entries on Chemistry data sheets, with no explanation in some cases.

In many cases there are explanations on data sheets preceding the ones with missing data; explanations l

such as system drained, not in service, or problem with analytical equipment.

Chemistry personnel failed to document the continuing situation on subsequent data sheets when data was unavailable.

l 1

CHM-501 and CHM-508, the governing procedures cited in this part of the Violation, require the recording of data on appropriate data sheets.

However, no guidance is provided concerning documentatier of samples not taken, or there is no requirement to document the reason samples are not taken in the comments section of the data sheet.

i l

l

r V.

NRC Notice of Violation Item A (445/8514-V-01)

(Continued) 2.

Corrective Action Taken:

A.

Chemistry section forms have been evaluated.

The following-improvements were identified and will be incorporated:

All data sheets associated with the CHM-500 series proce-dures will have the same general lay-out; Parameter limits will be highlighted in red ink; Sample data and time columns will be clearly delineated; Where applicable, a chemical addition column will be included; and Each form will include the following note; " Circle out-of-specification parameters."

]

The following corrective actions are in progress or will be completed pending approval of. CHM-500 series procedures.

B.

Chemistry data sheets (forms) associated with the following procedures are being revised:

Procedure No.

Revision No.

Procedure Title CHM-501 1

Chemistry Control of the Steam Generr. tors CHM-502 1-Chemistry Control of.the i

Water Treatment System-CHM-503 1

Chemistry Control of the Condensate System CHM-504 1

Chemistry Control of the Feedwater System CHM-505 1

Chemistry Control of the Secondary Support System l

CHM-506 1

Chemistry Control of the Primary System CHM-507 1

Chemistry Control of the Residual Heat Removal System CHM-508 1

Chemistry Control of the Primary Support System

-j

}.. "

NRC Notice of Violation

)

Item A (445/8514-V-01) j (Continued) 1 i

1 CHM-509 1

Chemistry Control of the r

Primary Makeup System CHM-510 1

Chemistry Control of the l

Boron Recovery System l

1 CHM-511 1

Chemistry Control of the I

Safeguards System CHM-517 1

Sampling and Analysis of Liquid Waste Systems CHM-519 1

Chemistry Control of the Refueling Water 3.

Corrective Steps to Avoid Recurrence:

A.

The Chemistry section attended a training session on January 9, 1986, which addressed the following topics:

Procedure compliance; Problems associated with existing data sheets; Pending revisions to existing data sheets; Consequences of missing surveillance item; Consequences of not reporting an out-of-specification parameter; Proper routin; of data sheets; Corrective action recommendations; and Proper or key points to consider when filling out a data sheet. The following items were addressed:

1.

Ensure all data entries are clearly written; 2.

Circle all out-of-specification parameters; 3.

Ensure that data is reviewed against specified limits; I

4.

Ensure that all footnotes are used correctly; 5.

Fill in blanks; t

6.

Document systems that are not in service; L

F.

i

(

l' NRC Notice of Violation _

)

I l

Item A (445/8514-V-01)

(Continued) i 7.

Document reason for taking sample if not routine; 8.

Utilize standard nomenclature.

Additionally, Chemistry directive 86-001 was issued to address these Concerns.

B.

Upon approval of the above referenced procedures, implementation

)

training will be provided to familiarize all Chemistry section personnel with the new data sheets (forms).

4.

Date of Full Compliance:

A.

Chemistry data sheets (forms) associated with the referenced CHM-500 series procedures will be revised by June 1, 1986.

B.

Chemistry section personnel will receive additional training on the revised data sheet forms by June 1, 1986.

Part 2 1.

Reason for Violation:

There have been instances of failure to make required entries to indicate that the Shift Supervisor was notified in regard to out-of-specification Chemistry results.

Some of these instances are failure to notify the Shift Supervisor for each sample for a continuing condition, specifically the pH depression.

These deficiencies are procedurally related because CHM-508, Revision 0, required the notification of the Shift Supervisor but did not require documentation of this notification on the data sheet.

Also data sheet CHM-508-1 did not require identification of out-of-specification conditions or notification of the Shift Supervisor.

CHM-501, Revision 0, did not require immediate notification of the Shift Supervisor upon verification of an out-of-specification condition and the time of notification be recorded on the appropriate data sheet.

This problem is aggravated by the listing of Mode 1 limits on data sheet CHM-501-1 for steam generators so it is not readily apparent which values are out-of-specification. This is a contributing factor to personnel errors i

during shutdown conditions.

2.

Corrective Action Taken:

lhe data sheets are being revised to show the appropriate limits for j

'.he applicable condition.

l

NRC Notice of Violation Item A (445/8T14-V-01f (Continued)

CHM-508 has.been revised to include the requirement to insnediately notify the Shift Supervisor in the event of an out-of-specification conditian and to document this notification on the data sheets.

3.

Corrective Steps to Avoid Recurrence:

The corrective action, with Chemistry section personnel training, should prevent this part of the Violation from reoccuring.

4.

Date of Full Compliance:

CHM-508 was revised October 15, 1984.

Chemistry data sheets (fowis) will be revised by June 1, 1986.

Part 3 1.

Reason for Violation:

Investigation confirms that the Chemistry. data sheets do not typically indicate the corrective actions taken for out-of-specification chemistry.

This deficiency is procedurally related because CHM-501 and CHM-508 indicate that the Chemistry Supervisor will investigate out-of-specification chemistry and determine the corrective action to be i

taken. There is no guidance to document corrective actions in other administrative procedures or on the data sheets.

j l

i This deficiency was also identified in TUGC0 Corporate QA Audit TUG-76 as Deficiency No. 1.

2.

Corrective Action Taken:

l Guidance provided by the revised procedure CHM-104 provides necessary corrective action.

This corrective action was the result of TUGC0 QA Audit TUG-76.

i 3.

Corrective Steps to Avoid Recurrence:

The training provided under the Part 1 Preventive Action should prevent this deficiency from reoccurring.

4.

Date of Full Compliance:

Procedure CHM-104 was revised on May 2'4,,

1985.

Personnel training was completed on January 9, 1986.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ __ i

NRC Notice of Violation.

Item A (445/8514-V-01)

(Continued)

Part 4

.}

1.

Reason for Violation:

CHM-101, Revision 1.(5-12-82), " Chemistry / Radiochemistry Administrative Control," states that records produced by technicians shall be independently reviewed by a qualified person and forwarded I

to the Chemistry and Environmental Engineer or his designee for approval.

CHM-101, Revision 2 (12-8-83), states that Chemistry and Environmental Supervisors are responsible for reviewing data sheets and that Staff Chemists are responsible for approving data sheets.

2.

Corrective Action Taken:

A qualified person will review all past CHM-501-1 and CHM-508-1 data sheets.

This review will be performed to determine if there is any significant chemistry concern indicated which has not been identified and resolved. Also, a representative selection based on the number of records generated from other procedures utilized during the January 1983 to September 1985 time period will be reviewed.

If similar problems are found to exist in the selected records, then a full review will be conducted.

Deficient or nonconforming conditions discovered during these reviews will be documented in accordance with station procedures.

3.

Corrective Steps to Avoid Recurrence:

All Chemistry and Environmental Supervisors and Staff Chemists have been reminded of their administrative responsibilities.

4.

Date of Full Compliance:

All required document reviews will be complete by August 1, 1986.

J k

i

S Notice of Violation Item B ( W6/8511-V-01)

~

Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by j

documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

{

Par 6 graphs 2.3 and 3.1.1.1 of Brown & Root (B&R) Procedure CQ-QAP-16.2, Revision 25, require.that nonconformances be identified, documented by completing the NCR form, and dispositioned.

Paragraph 3.19.5.2 of B&R Procedure CP-CPM 6.90, Revision 6, states, in part, with respect to NCRs for minimum wall violations, ".

.. Welding engineering shall review the conditions stated on the NCR Contrary to the above, repair of a minimum wall violation associated with weld 21-2 in component CC-2-RB-053 was noted on October 9, 1985, from record review to have been performed without documenting the condition on an NCR form.

Response to Item B 1.

Reason for Violation:

A QC Inspector failed to follow QI-QAP-14 1-26 which requires the initiation of a Nonconformance Report (NRC) for minimum wall k

violation (MWV).

2.

Corrective Action Taken:

A review was conducted to determine the method used to identify and correct the MWV and concluded that the repair process used was technically adequate and would not have been altered regardless of the document used to record the MWV (i.e., Unsatisfactory IR attribute vs NCR).

While we believe that the violation is a iso-lated occurence we are confident that any other similar minimum wall violation would have been likewise adequately dispositioned.

3.

Corrective Steps to Avoid Recurrence:

All applicable QE's and QC Inspectors were retrained in the speci-fic QI-QAP-11.1-26 program requirements relative to welded repairs associated with MWV's.

Additionally, construction proce-dure CP-CPM-6.90 will be revised to clarify the requirement that an NCR must be generated whenever a MWV it identified.

Appropriate Weld Engineering personnel will be trained to the revised CP-CPM-6.90 requirements.

4.

Date of Full Compliance:

May 16, 1986.

1 f

l

-J

Notice o7 Violation Item C (446/8511-y-02)

Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type. appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Paragraphs 3.1:1.1 of B&R Procedure DCP-3, Revision 18, states, in part,

... Issuance and receipt of controlled design changes are documented on the Document Distribution Log...

by signature or initial of the file custodian and dated." Paragraph 3.2.2.5 of this procedure additionally requires that the face of a retained superseded document must be stamped "V0ID."

Contrary to the above:

1.

Satellite document control center 307 was noted on October 14,

'1985, to be in possession of a controlled copy of Component l

Modification Card 96181 for which receipt had not been signed for l

and dated on the Document Distribution Log.

2.

A copy of superseded Design Change Authorization (DCA) 21446, Revision 0, was noted on the same date to be present in two packages for Drawings 2323-El-1702, Sheet db2, Revision 2.

Both copies of DCA 21446, Revision 0, were not stamped " VOID" on the face of the document.

Response to Item C - No. I 1.

Reason for Violation:

Failure to properly implement procedure.

2.

Corrective Action Taken:

The Document Distribution Log was corrected by the inclusion of proper initial and date. The Document Distribution Log was reviewed and there were no other violations of this nature identified.

3.

Corrective Steps to Avoid Recurrence:

Appropriate DCC personnel were reinstructed in the proper receipt acknowledgement of design changes.

DCP-3 rev. 19 paragr:ph 3.1.1.1 includes verification responsibilities by DCC per sonnel to ensure acknowledgment of design changes is documented.

4.

Date of Full Compliance:

March 31, 1986.

t.

Notice of Violation Item C (446/8511-V-02)

(Continued)

Response to Item C - No. 2 4

1.

Reason for Violation:

Failure to pr.operly implement procedure.

2.

Corrective Action Taken:

The drawing package contents were immediately corrected.

It was determined that the drawing was not used in the performance of plant work. Monitoring a sample of drawing package contents revealed that no drawings or design changes were found to be out of revision.

3.

Corrective Steps to Avo'd Recurrence:

Personnel were reinstructed in the need to assure up-to-date contents in drawing packages, including ;5e marking of superseded drawings as " void".

4.

Date of Full Compliance:

April 1, 1986.

I I

1

Notice of Violation

!_ tem 0 (446/8511-V-03)

Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP, Section.5.0, Revision 3, dated July 31, 1984, requires tnat activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Section 17.1.17 of the Final Safety Analysis Report, Volume XIV, Amendment 50, dated July 13, 1984, commits to procedures requiring that records be controlled and accounted for during transfer between organizations.

Contrary to the above, original sole copy design records were ascertained on October 16, 1985, to have been shipped to Stone and Webster Engineering Corporation, New York, without the establishment and implementation of procedures that address required control and inventory j

measures.

Response to Item D 1.

Reason for Violation:

Conditions noted in the violation are the result of a f ailure to follow established procedures for control of engineering documents.

TUGC0 Nuclear Engineering (TNE) Procedure TNE-AD-4 specifies that duplicate copies of engineering documents prepared or processed by TNE shall be maintained at the site or Gibbs & Hill /New York, as applicable.

In 1985, Stone & Webster Engineering Corporation (SWEC) assumed des i gn. re spon s i b ilitylor_ pipe 3 upp or t s.

In order to consider and Incorporate, where possible, existing information into SWEC designs, TUGC0 initiated shipment of pipe support design records offsite.

2.

Corrective Action Taken:

Measures to establish compliance with TNE procedure TNE-AD-4 and

{

subordinate TNE instruction TNE-AD-4-6 (issued specifically for transmittal and duplicate retention of pipe support calculations) have been implemented for pipe support records previously forwarded to SWEC.

These efforts, involving the return of copies and complete accountability, were completed in February 1986.

3.

Corrective Steps to Avoid Recurrence:

I TNE-AD-4-6 was issued November 25, 1985, establishing a program for

)

transmittal requ.irements for pipe support design records.

In addition, TNE-AD-4 will be reviewed and revised, if required, to

)

assure the adequacy of measures prescribing the offsite transmittal l

of engineering documents.

__w

Notice of Violation Item D (446/8511-V-02)

(Continued) 4..

Date of Full Compliance:

As noted in items 2.'and 3, all measures have been completed with-the exceptio'n of the review / revision of Procedure TNE-AD-4. These measures will be accomplished no later than May 22, 1986.

)

i 1

eh f

e I

Notice of Violation Item E (446/8514-V-03) s Criterion VI of Appendix B to 10 CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative and Quality Assurance-Plan, regyires that (1) measures shall be established to control the issuance of documents such as drawings, including changes thereto; and (2) the measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel.

I Paragraphs 2 and 4 in Revisions 7 and 8 of Station Administration Manual Procedure No. STA-405 require that all documented nonconformances, in i

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.

Paragraph 4.0 in Revision 0 of Nuclear Operations Engineering Manual Instruction No. N0E-201-5 requires that proposed drawing changes be submitted'to the Operations Superintendent for review, approval, and authorization to distribute the revised drawings.

Contrary to the above, nine-as-built drawings were revised and distributed by TUGC0 Nuclear Engineering to reflect NCR identified undersize _ welds, without receiving TUGC0 Operations review, approval, and authorization to distribute the revised drawings.

Response to Item E 1.

Reason for Violation:

The condition noted in the violation is the result of the issue of pipe support drawings by TNE documenting acceptance of "Use-As-Is" conditions prior to the proper disposition of several TUGC0 Operations'.NCR's.

Prior approval of drawings which document the "Use-As-Is" disposition of NCR's by TUGC0 Operations is a requirement of Station Administration Manual Procedure STA-405.

Please note the following in regards to Appendix "A",

item E, third i

paragraph of the subject NRC Inspection Report.

Procedure N0E-201-5 does not require "non-vital" drawings, such as BRH (pipe j

support) drawings be submitted to the TUGC0 Operations Superintendent prior to issue by PSE (Pipe Support Engineering).

However, the generic issue of whether such drawings should be classified as " vital" and therefore be submitted to the TUGC0 Operations Superintendent is being processed by TUGC0 Deficiency j

Report (DR-86-007) whose disposition is yet outstanding.

2.

Corrective Action Taken:

Ine pipe support drawings noted in the findirg were subsequently reviewed by TUGC0 Operations.

Approval has been documented by closure of the corresponding TUGC0 Operations' NCR's, completed December 19, 1985.

l

..l

g__,___-

' Notice of Violation Item E (446/8511-V-02) n (Continued) 3.

Corrective Steps to Avoid Recurrence:

i As a re'sdit of this specific finding, TNE Procedure TNE-AD-4-5 Revision 1 was issued November 11, 1985. Procedures which describe THE and TUGC0 Operations interf ace arrangements applicable to pipe supports were reviewed to assure consistency.

No additional conflicts were noted.

Adherence to these interface requirements should preclude further violations of this nature.

4.

Date of Full Compliance:

As noted above, full compliance has been achieved.

(

Notice of Violation Item F (446/8514-V-04)

Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

I Paragraph 3.0 of Procedure CP-QP-2.1, Revision 14, dated October 17, 1983, states in part, "... inspection personnel... shall have experience in and shall have completed a technical training course and examination in the area of inspection responsibilities." Paragraph 3.7 of this procedure states, in part, "... Inspection personnel shall be certified by the TUGC0 site QA supervisor as being qualified to perform their assigned tasks."

Contrary to the above, it was noted on October 21, 1985, during review of documentation for Class 1E lighting system conduit EAB1-1 that the electrical inspector, who had signed inspection reports E-1-0024951 and E-1-0027419, had not been certified to the applicable Procedure QI-QP-11.2-25, Revision 17, dated February 13, 1984, " Inspection of New Installations for Class 1E Lighting Systems."

Response to Item F 1.

Reason fcr Violation:

Oversight by QC Supervision which allowed the inspector in question to inspect to QI-QP-11.3-25 prior to final sign-off of his certification.

2.

Corrective Action Taken:

NCR E-85-101639 was initiated to address this violation.

In addition, 800 Inspection Reports completed by 163 QC Inspectors I

during the past six months were reviewed to determine if further violations of this nature had occured.

All of the reports reviewed were completed by QC Inspectors certified to the activity inspected.

j l

3.

Corrective Steps to Avoid Recurrence:

j QC Supervision is issued a weekly list which identifies the certification capabilitiu and status of their personnel, for use in inspection assignments.

Based upon the above review results this action is sufficient to avoid recurrence of this violation.

Inspections performed prior to June 1985 are subject to CPRT action item Vll.d 7

)

4.

Date of et

.o rpl i ance :

May 5, In

Notice of Deviation Item A (445/8514-D-01)

Section 4.1.6 of ERC Comanche Peak Project Procedure (CPP) CPP-012, "QA/QC Interface with Construction /TUGC0" states, "The QA/QC Records Administrator controls requests for equipment / services and distributes and controls requests for technical information."

o Contrary to the above, the QA/QC Records Administrator does not receive copies of. requests to provide for control of these documents l

(445/8514-D-01).

With. respect to item A in the Notice of Deviation, the NRC has ascertained subsequent to this report period that ERC logs for tracking of equipment / service requests have not been utilizing procedurally required unique numbers for individual requests.

Accordingly, please address this as part'of your response to item A in the Notice of Deviation.

Response to Item A 1.

Reason for Deviation:

As the NRC identified, the QA/QC Records Administrator does not control requests for equipment / services from the Constructor /TUGCO.

Due to a misunderstanding of the NRC's concern at the time of the finding, it was not explained that such requests are tracked by a computerized log maintained by the Inspection Supervisor or his designee.

Subsequent NRC investigation confirmed the presence of this tracking mechanism. Consequently, the original NRC concern was resolved.

However, the NRC it3pector subsequently identified a related concern:

the log did not show a unique number for each equipment / services request as required by CPP-012.

The function of the equipment / services tracking mechanism is to ensure that all necessary equipment / services (i.e. scaffolding, painting or lagging removal, etc.) are installed or performed before inspection takes place and are maintained until inspection is completed.

All open equipment / services requests (ESRg) are maintained in a folder associated with the verification package with which they are identified.

The computer tracking mechanism tracks the status of the most recently opened ESR. This function is served satisfactorily by the mechanism currently in place (the same mechanism in place at the time of the NRC inspection).

Changes to the mechanism used to track open ESRs are not required since no failures to per*

' the intended function exist.

However procedure CPP-012.must r

..t current practice.

I l

~]

Notice of Deviation item A (445/8514-D-01)

(Continued) 2.

Corrective Action Taken:

ERC Comanche Peak Project Procedure CPP-012 was revised March 11, 1986, to remove reference to the ESR log.

J3.

Corrective Steps to Avoid Recurrence:

The action to correct the reported condition serves as action to prevent recurrence.

4.

Date of Full Compliance:

i March 11, 1986.

a 1

i i

,e

<ua r

inspe

' : DB

. "i..*

'1 e 31 '

Notice of Deviation Item 8 (445/8514-0-02) j

~

Section 4.1 of CPRT Issue-Specific Action Plan (ISAP) No. VII.c Revision 0, dated June 21, 1985, states, in part,

... Where required, documentation reviews will be utilized to supplement the reinspection for attributes which are nonrecreatable or inaccessible...."

Section 4.1.3 of the ISAP states, in part,

{

)

.. The inspection procedure will provide detailed instructions j

to the inspectors and/or documentation reviewers for performing the reinspection and/or documentation reviews..."

]

Contrary to the above, the following examples were noted of inadequate procedural guidance and document reviewer performance in regard to nonrecreatable and inaccessible attributes:

1.

Quality Instruction (QI)01-013, Revision 4, lists no specific attributes, but instead specifies that the inspector verify installations in accordance with one or more of a listing of TUGC0 procedures; i.e., QI-QP-11.8.1, -5, -6, and -8.

The list of appropriate procedures does not, however, indicate the applicable revision number of each procedure.

In that the number of nonrecreatable or inaccessible inspection attributes can vary from revision to revision of a procedure (e.g. Revisions 0 and 1 of TUGC0 Procedure 01-0P-11.8-8), the absence of guidance on applicable procedure revision numbers does not constitute detailed instructions.

2.

During the documentation review of Verification Package No.

R-E-CDUT-064, in accordance with Q1-009, Revision 0, there was no evidence that a documentation check was made of inaccessible attributes for conduit C13016037 that were caused by the installation of separation barrier material (445/8514-0-02).

Response to Item B 1.

Investigation:

QI-013 " Documentation Review for Instrumentation Equipment /R-E-ININ" does not, in fact, list specific atir autes for the inspector to verify.

The purpose of the documentet review governed by Q1-013 is to provide inspector qualification,

{

information as input to ISAP I.d.1.

The intent of QI-0;

.s to verify the inspector who signed the inspection report being i

reviewed was certified to the appropriate revision of uality l

Instruction (QI) that was in place at the time of the

tion.

)

To do this the document reviewer records the inspect; e, the

(

QI number, and the revision of the procedure noted or Then the inspector certifications are reviewed to determi.

e Ne of j

I inspector was certified to the appropriate revision i

signing the IR.

1 y

Notice of Deviation p,,

Item B (445/8514-D-01)

(Continued)

This is an appropriate way to verify inspector certifications.

c Consequently, no deviating condition is believed to exist.

R'egarding use of document reviews tuupplement reinspe.clionslor e

inagsgssible atttibutest the NRC finding is correct, based on Revision 2.of the CPRT Program Plan.

However, in the ensuing time-i period, Revision 3 of the CPRT Program Plan, including a revised ISAP VII.c was issued.

ISAP VII.c as now written dictates that, after the.s.ixt ins n t_ tons _have been concluded for the population sample, any at r utes which were found to be inaccessible will cause additional samples to be selected from the population and j

inspected only for those attributes which were inaccessible-in preceding inspections.

Document review will only be used for non-recreatable attributes unless sixty occurrences of the attribute are not accessible from the population as a whole. Consequently, the programmatic change in: Revision 3 resolved this finding.

2.

Corrective Action Taken:

No corrective action for items 1 and 2 are planned.

3.

Corrective Steps to Avoid Recurrence:

No corrective steps for items 1 and 2 are applicable 4.

Date of Full Compliance:

February 24, 1986.

i l

)

~

Notice of Deviation Item C (445/8514-D-03)-

j QI-009, Revision 0, Document Review of Conduit /R-E-CDUT", requires the j

ERC inspector to-verify that inspection reports signed by electrical inspectors were 4

dated after their date of certification and prior to their date of expiration, and, document the SBM inspection report (IR) and/or latest construction 1

operation traveler number at the bottom of the checklist.

Contrary to the above:

Review of ERC accepted documentation for conduit C14R13047 showed that the ERC inspector failed to identify that the certification to the applicable Procedure Ql-QP-11.3-23 had lapsed for the TUGC0 electrical inspector signing IR-E-46087.

The ERC completed inspection record checklist for conduit C13016037 in Verification Package No. R-E-CDUT-064 did not contain documentation of the SBM IR or latest construction operation traveler number (445/8514-D-03).

Response to Item C 1.

Reason for Deviation:

A review of verification Package No. R-E-CDUT-064 and R-E-CDUT-070 confirmed the NRC findings. This was determined to be an inspection error.

2.

Corrective Action Taken:

(DR) Deviation Report R-E-COUT-070-ORI was written by the inspector.

The number for the latest construction operation traveler was added to the applicable checklist on 11/21/85.

The inspector was given additional training on 11/8/85.

Reinspection of 25% of this inspector's work involved 28 verification packages and was completed before 11/21/85.

The results of the 25% reinspection has been evaluated and based upon the minor nature of the discrepancies identified, no further actions was deemed necessary on the Inspector's past performance.

3.

Corrective Steps to Avoid Recurrence:

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

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

Notice of Deviation Item C (445/8514-0-01)

~~

(Confinued) 4.

Date of Full Compliance:

Corrective action was completed by November 21, 1985.

Preventive action involves an ongoing program.

e s

\\

Notice of Deviation

}

Item D (445/8514-D-01)

)

Section 4 of CPP-009, Revision 3, states, in part, with respect to ISAP No. VII.c, " Qualified QA/QC Review Team personnel perform field reinspection of specific hardware items and reviews of appropriate

]

documents in accordance with approved instructions...."

Contrary to the above, the following examples were noted where field i

reinspection of hardware items were not performed in accordance with approved instructions:

1.

Attribute 4.5 in Section 5.0 of Q1-055, Revision 0, states with respect to spring nuts, " Verify that the serrated grooves align with the channel clamping ridge." Checklists for support No. 0070 (Verification Package No. I-S-INSP-007) and support No. 028 (Verification Package No. I-S-INSP-028) were signed by two separate ERC inspectors that this attribute was acceptable. NRC inspectors showed, however, that the spring nut serrated grooves did not align with the channel clamping ridge on both of these supports.

2.

Section 5.3.4.C in Q1-027 states with respect to dimensional tolerances not shown on design drawings, " Component member length

+/-1/2 inch."

The bill of material on Revision 2 of drawing No. CT-1-097-402-C52R in Verification Package No. 1-S-LBSR-023 shows item No. 4 (2 pieces) to be 7 3/4 inches long. The applicable inspection checklist used during the ERC reinspection of this pipe s,upport shows the installed configuration to be acceptable. NRC inspect-tion determined, however, the actual length dimensions of the two pieces to be 6 5/8 inches and 6 1/2 inches, respectively, both of which are under the indicated minimum dimension.of 7.1/4 inches.

3.

Section 5.0 in 01-012 states, in part, " Verify that the piping / tubing and components... material agree with the Bill of Haterials shown on the Instrument Installation Detail drawing.

Tubing is marked with longitudinal color coded marks for traceability. Use applicable drawing to identify tubing...

Verify that the installed tubing has the, proper slope.

The required slope for process wetted lines is one11 Finch per foot minimum.

This slope requirement may be reduced to 1/4 inch per foot when physical layout is a problem.

Verify that the,re is a proper air gap. The minimum gap spacing shall always be 1/8 inch to allow each instrument sensing line to expand independently at all bends without striking adjacent sensing lines, other equipment, concrete or steel building members."

The applicable inspection checklist used during the ERC reinspection of instrumentation installation Verification Deckage No.

1-E-ININ-026 showed that the above attributes were inspected and_ accepted, as evidenced by the inspector's signoff (initiarsh a

l l

1

Notice of Deviation Item D (445/8514-D-01 (Continued) 4

'However, NRC inspection of the instrumentation installation revealed:

1 (a)

Six sections of tubing had no color coding for traceability; (b)

Ten sections of tubings, in which physical layout was not a problem, had slopes of 7/16 inch to less than 1/4 inch per 4

foot and one section had reverse slope; and (c)

Two tubing sections had zero gap spacing between the high pressure and low pressure legs and the concrete' penetration.

4.

Section 1.7 in 01-012 requires that: (a) tubing bend be verified to have a minimum radius of four times the normal tube size by using either a template, or by direct measurement calculations; and (b) the measured and calculated values be entered into the Minimum Bend Radius Record, with date and inspector's initials.

During NRC inspection of Verification Package No. I-E-ININ-04, equipment tag No. 1-FT-156, it was noted that the inspection checklist was dated and initialed, attesting to the fact that the tubing bends had been verified as having a minimum radius of four times the nominal tube size. However, review of the applicable Minimum Bend Radius Record'showed that the ERC inspector had neither measured and calculated, nor used a template to verify minimum bend radius.

In addition, the following notes had been entered by the ERC inspector:

"Ist 90' bend from instrument (hi &

lo side)... cannot be measured with existing tools. Four (4) other bends visually more than 90' to accommodate slope" (445/8514-D-04).

Response'to Item D 1.

Reason for Deviation:

Reinspection confirmed the NRC findings.

Item 1,and_2

'nspector error.

ftem 3

'nspector Error.

Ongoing adjacent construction and housekeeping

tivities (i.e., wiping down, climbing, ongoing work in i

4 me

Notice o'f Deviation Item D (445/8514-D (Continued) surrounding areas, etc.) prevent a firm determination as to whether

-a or not the NRC identified findings existed at the time of the ERC inspection but, enough indication exists to justify retraining of

/

the. inspectors.as a step to assure decertification of those items which may well have been inspector error.

Item 4 Inspector error.

QI requires clarification to allow inspector to indicate inaccessible bends.

2.

Corrective Action Taken:

Item 1 Deviation Reports I-S-INSP-007-DR2 and DR3 dated November 18, 1985, and I-S-INSP-028-DR2 dated November 8, 1985, were written to document the misaligned spring nuts.

Twenty five percent of the work of both. inspectors was reinspected, The results of the reinspection were documented and evaluated by inspection supervision.

A decision was made to reinspect;IO0% of the spr_i_n_g.. nut _s previously inspected by the first inspector. The results of the reinspection indicated a_high_ error rate.

This inspector's services were discontinued and 100% of his work was reinspected.

The retained inspector was retrained on November 12, 1985.

All necessary reinspection were completed by December 5, 1985. -Deviating conditions identified by the reinspection have been documented in the applicable Verification Packages arid DRs initiated.

A general training session on Spring Nut inspection was given to all non-affected inspectors involved in the reinspection of this I

attribute. This retraining has been documented.

Item 2 Deviation Report I-S-LBSR-023-DR2 dated November 13, 1985, was written to document the dimensional deviations. The responsible inspector was the same one whose services were discontinued as indicated above.

Item 3 and The Verif0 R'6n Packaae documentation for ININ-026 has been

/

reinspetic E-ININ-004 was corrected, and DRs I-E-ININ-026-DR-2,

r a

1 Notice of Deviation L

Item D (445/8514-D-01 (Continued)

-4, nd -5 were issued.

In addition, revision 1 of QI-012 was issued January 30, 1986, and now provides a basis for the e

' inspectors to indicate inaccessible bends.

Due to problems noted by ERC and those identified herein by the NRC, all ININ Verification Packages issued prior to January 14, 1986, will be reissued for reinspection.

3.

Corrective Steps to Avoid Recurrence:

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

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

4.

Date of Full Compliance:

Corrective action is complete with the exception of the total reinspection of the ININ packages.

Preventive action involves an ongoing program.

9

-In Reply Refer To:

Dockets:- 50-445/85-14 JUG '., ins 50-446/85-11 l

' Texas Utilities Generating Company ATTN: Mr. W. G..Counsil Executive Vice President 400 North Olive, L.B. 81 Dallas, Texas 75201 Gentlemen:

.Thank you for your letter of May 16, 1986, in response to our letter and Notice of Violation dated March 6,1986.

We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to -

determine that full compliance has been achieved and will be maintained.

Sincerely,

.ywn9 - ~ ~

. ;...::n E. H. Johnson, Director Division of Reactor Safety and Projects CC:

Texas Utilities Electric Company ATTN:

G. S. Keeley, Manager Licensing Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Juanita Ellis President - CASE 1426 South Polk Street Dallas, Texas 75224 RIV:D:DRSP C:RSBY EHJohnson:sj TFWest6' man r

4 /(:,/86 f/i3/86 I

-seem v_vas esess e,

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.Te'xas Utilities Generating' Company '

Renes Hicks-Assistant Attorney General,

Environmental Protection Division L:

<P.O. Box'12548 Austin, Texas 76711 Texas Radiation Control Program Director-bec;to DMB (IE01) bec distrib. by RIV:

MIS System RPB

.RSTS Operator RRI-OPS RRI-CONST-R&SPB T. F. Westerman, CPTG DRSP V. Noonan, NRR R. Martin, RA

5. Treby, ELD RSB RIVLFile J. Taylor,-IE D. Weiss, LFMB (AR-2015)

R. Heishman IE i

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Log # TXX-4779 I

I File # 10130 IR 85-14 85-11 TEXAS UTILITIES GENERATING COMPANY SKYW AY TOWER e 400 NORTH OLIVE FrREET. L.B. St

  • DALLAS. TEXA8 78301 May 16, 1986 L5 v 4:3._

.== :=.=

MAY E I 1966 I

L _

Mr..Eric H. Johnson, Director Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission l

611 Pyan Plaza Drive, Suite-1000 Arlington, Texas 76012

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NO.:

50-445/85-14 AND 50-446/85-11

Dear Mr. Johnson:

We have reviewed your letter of March 6, 1986, concerning the inspection by Mr. T. F. Westerman and others of the Region IV Comanche Peak Group during the period September 30 through October 31, 1985.

This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2.

1 We requested.and received a four week extension in providing our response during a telephone discussion on April 7, 1986. We requested and received an additional two week extension during a telephone discussion on May 2, 1986.

We have provided our response to the Notice of Violation and the Notice of Deviation in the attachments to this letter.

To aid in l

understanding our response, we have repeated the Notice followed by our response.

Very truly yours, 7'

W. G. Counsil JWA/arh c-Region IV (Original + 1 copy)

Director, Inspection and Enforcement (15 copies)

U. S. Nuclear-Regulatory Commission Washini: Von, D.C.

20555 Mr i. 'i Noonan L. Kelley Me s.

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&MNrWON

., >e l e PDR A DC.

%O00445 G

PDR A omsson or rexAs tmtmES ELECTRIC COMPANY i

4 NRC Notice of Violation

{

Item A (445/8514.V-01)_

Criterion XVII of Appendix B to 10CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative Control and Quality t

Assurance Plan, requires that (1) sufficient records shall be maintained 1

to furnish evidence of activities affecting quality, and (2) that the

- records shall include the results and acceptability of tests and analyses, I

and the action taken in connection with any deficiencies noted.

]

Contrary to the above:

1.

A significant number of instances of missing data entries was noted in water chemistry records covering the period March 1983 through September 1985, with respect to the chemistry sampling frequency requirements of Procedures CHM-501, " Chemistry Control of the Primary Cooling Water Systems." No annotations were made in the records to explain why the samples were not taken.

2.

Review of the water chemistry records showed instances of failure to make required entries to indicate when the Shift Supervisor was notified in regard to out-of-specification chemistry results.

3.

The records did not' identify what corrective actions were taken after entry of out-of-specification results.

4.

Inadequate reviews were performed of the acceptability of water chemistry data, as evidenced by the presence of review and approval signatures on forms containing discrepant data results.

Response to Item A Notice of Violation 445/8514-V-01 is written in four parts, each of which is addressed separately.

Part 1 1.

Reason fur Violation:

An investigation by the Chemistry and Environmental Engineer confirms instances of missing entries on Chemistry data sheets, with no explanation in some cases.

In many cases there are explanations on data sheets preceding the ones with missing data; explanations such as system drained, not in service, or problem with analytical equipment. Chemistry personnel failed to document the continuing situation on subsequent data sheets when data was unavailable.

CHM-501 and CHM-508, the governing procedures cited in this part of the Violation, require the recording of data on appropriate data sheets. However, no guidance is provided concerning documentation of samples not taken, or there is no requirement to document the reason samples are nnt Yeken in the coments section of the data sheet.

NRC Notice of Violation

.~

Item A (445/8514-V-01)

(Continueo) l 2.

Corrective Action Taken:

i l

A.

Chemistry section forms have been evaluated. The following improvements were identified and will be incorporated

  • i All data sheets associated with the CHM-500 series proce-dures will have the same general lay-out; Parameter limits will be highlighted in red ink; Sample data and titae columns will be clearly delineated; i

Where applicable, a chemical addition column will be included; and Each form will include the fc11owing note; " Circle out-of-specification parameters."

The following corrective actions are in progress or will be completed pending approval of CHM-500 series procedures.

4 B.

Chemistry data sheets (forms) associated with the following procedures are oeing revised:

Procedure No.

Revision No.

Procedure T'.tle CHM-501 1

Chemistry Control of the Steam Generators CHM-502 1

Chemistry Control of the Water Treatment System CHM-503 1

Chemistry Control of the Condensate System CHM-504 1

Chemistry Control of the Feedwater System CHM-505 1

Chemistry Control of the Secondary Support System CHM-506 1

Chemistry Control of the Primary System CHM-507 1

Chemistry Control of the Residual Heat Remova.

l System CHM-508 1

Chemistry Control of the Primary Support System i

p,

}

NRC Notice of Violation Item A (445/8514-V-01)

(Continued)

CHM-509 1

Chemistry Control of the-Primary Makeup System CHM-510 1

Chemistry Control of the

-Boron Recovery System CHM-511 1

Chemistry Control of the l

Safeguards System CHM-517 1

Sampling and Analysis of Liquid Waste Systems CHM-519 1

Chemistry Control of the Refueling Water 3.

Corrective Steps to Avoid Recurrence:

l A.

The Chemistry section attended a training session on January 9, 1986, which-addressed the following topics:

Procedure compliance; Problems associated with existing data sheets; Pending revisions to existing data sheets; Consequences of missing surveillance item; Consequences of not reporting an out-of-specification parameter; Proper routing of data sheets; Corrective action recommendations; and Proper or key points to consider when filling out a data sheet. The following items were addressed:

1.

Ensure all data entries are clearly written; 2.

Circle all out-of-specification parameters; 3.

Ensure that data is reviewed against specified limits; 4.

Ensure that all footnotes are useo correctly; 5.

Fill in blanks; 6.

Document systems that are not it:

'c;

4 NRC Notice Af Violation Item A-(445/8514-V-01)

(Cantinued) 7.

Document reason for taking sample if not routine; 8.

Utilize standard nomenclature.

Additionally, Cnemistry directive 86-001 was issued to address these Concerns.

.B.

Upon arproval of the above referenced procedures, implementation training will be provided to familiarize all Chemistry section persannel with the new data sheets (forms).

l 4.

Data of Full Compliance:

A.

Chemistry data sheets (forms) associated with the referenced CHM-500 series procedures will be revised by June 1, 1986.

B.

Chemistry section personnel will receive additional training on the revised data sheet forms by June 1, 1986.

Part 2 1.

Reason for Violation:

There have been instances of failure to make required entries to indicate that the Shift Supervisor was notified in regard to out-of-specification Chemistry results.

Some of these instances are failure to notify the Shift Supervisor for each sample for a continuing condition, specifically the pH depression.

These deficiencies are procedurally related because CHM-508, Revision 0, required the notification of the Shift Supervisor but did not require documentation of this notification on the data sheet. Also data sheet CHM-508-1 did not require identification of out-of-specification conditions or notification of the Shift Supervisor. CHM-501, Revision 0, did not require immediate notification of the Shift Supervisor upon verification of an out-of-specification condition and the time of notification be recorded on the appropriate data sheet. This problem is aggravated by the listing of Mode 1 limits on data sheet CHM-501-1 for steam generators so it is not readily apparent which values are out-of-specification. This is a contributing factor to personnel errors during shutdown conditions.

2.

Corrective Action Taken:

The data sheets are being revised to show the appropriate limits '

the applicable condition.

'NRC-Notice of Violation Item A (445/85A4-V-01)

-)

(Continued)

CHM-508 has been revised to include the requirement to immediately notify the Shift Supervisor in the event of an out-of-specification-condition and to document this notification on the data sheets.

3.

Corrective Steps to Avoid Recurrence:

J The corrective action,-with Chemistry section personnel training-should prevent this part of the Violation from reoccuring.

4.

Date of Full Compliance:

1 CHM-508 was revised October 15, 1984.

Chemistry data sheets (forms) will be revised by June 1, 1986.

1 Part 3 1.

Reatgn for Violation:

Investigation confirms that the Chemistry data sheets do not typically indicate the corrective actions taken for out-of,

specification chemistry.

i This deficiency is procedurally related because CHM-501 and CHM-508 indicate that the Chemistry Supervisor will investigate out-of-specification chemistry and determine the corrective action to be taken. There is no guidance to document corrective actions in other administrative procedures or on the data sheets.

This deficiency was also identified in TUGC0 Corporate QA Audit TUG-76 as Deficiency No. 1.

I 2.

Corrective Action Taken:

Guidance provided by the revised procedure CHM-104 provides necessary corrective action. This corrective action was the result of TUGC0 QA Audit TUG-76.

J 3.

Corrective Steps to Avoid Recurrence:

The training provided under the Part 1 Preventive Action should

)

prevent this deficiency from reoccurring.

4.

Date of Full Compliance:

1 Procedure CHM-104 was revised on May 24,, 1985. Personnel training was completed on January 9, 1986.

q

)

)

i

NRC Notice of Violation Item A (445/8514-V-01)

(Continued) l' Part,4 1.

Reason for Violation:

CHM-101, Revision 1 (5-12-82), " Chemistry / Radiochemistry Administrative Control," states that records produced by. technicians shall be independently reviewed by a qualified person and forwarded to the Chemistry and Environmental Engineer or his designee for approval.

CHM-101, Revision 2 (12-8-83), states that Chemistry and Environmental Supervisors are responsible for reviewing data sheets and that Staff Chemists are responsible for approving data sheets.

2.

Corrective Action Taken:

A qualified person will review all past CHM-501-1 and CHM-508-1 data sheets. This review will be performed to determine if there is any significant chemistry concern indicated which has not been 4

identified and resolved. Also, a representative selection based on the number of records generated from other procedures utilized during the Jcnuary 1983 to September 1985 time period will be reviewed.

If similar problems are found to exist in the selected records, then a full review will be conducted.

Deficient or nonconforming conditions discovered during these reviews will be documented in accordance with station procedures.

3.

Corrective Steps to Avoid Recurrence:

All Chemistry and Environmental Supervisors and Staff Chemists have been reminded of their administrative responsibilities.

i 4.

Date of Full Compliance:

l All required document reviews will be complete by August 1, 1986.

- - -. _. _ -. _-____-.i

Notice of Violation

~

Item B (446/8511-V-01)

Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0

~

Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Paragraphs 2.3 and 3.1.1.1 of Brown & Root (B&R) Procedure CQ-QAP-16.2, Revision 25, require that nonconformances be identified, documented by completing the NCR form, and dispositioned. Paragraph 3.19.5.2 of B&R i

Procedure CP-CPM 6.90, Revision 6, states, in part, with respect to NCRs for minimum wall violations, ".

.. Welding engineering shall review the conditions stated on the NCR...."

Contrary to the above, repair of a minimum wall violation associated with weld 21-2 in component CC-2-RB-053 was noted on October 9, 1985, from record review to have been performed without documenting the j

condition on an NCR form.

Response to Item B 1.

Reason for Violation:

A QC Inspector failed to follow QI-QAP-11.1-26 which requires the initiation of a Nonconformance Report (NRC) for minimum wall violation (MWV).

2.

Corrective Action Taken:

A review was conducted to determine the method used to identify and correct the MWV and concluded that the repair process used was technically adequate and would not have been altered regardless of the document used to record the MWV (i.e., Unsatisfactory IR attribute vs NCR).

While we believe that the violation is a iso-lated occurence we are confident that any other similar minimum wall violation would have been likewise adequately dispositioned.

j l

3.

Corrective Steps to Avoid Recurrence:

i

)

All applicable QE's and QC Inspectors were retrained in the speci-i l

I fic QI-QAP-11.1-26 program requirements relative to welded repairs associated with MWV's. Additionally, construction proce-

{

dure CP-CPM-6.9D will be revised to clarify the requirement that an i

NCR must be generated whenever a MWV is identified.

Appropriate

)

Weld Engineering personnel will be trained to the revised j

CP-CPM-6.9D requirements.

4.

Date of Full Compliance:

May 16, 1986.

_a

Notice of Violation j

Item C (446/8511-y-02)

Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that j

activities affecting quality shall, be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these l

instructions, procedures, or drawings.

{

Paragraphs 3.1.1.1 of B&R Procedure DCP-3, Revision 18, states, in part,

... Issuance and receipt of controlled design changes are documented on the Document Distribution tog...

by signature or initial of the j

file custodian and dated." Paragraph 3.2.2.5 of this procedure j

additionally requires that the face of a retained superseded document must be stamped "V0ID."

Contrary to the above: -

1.

Satellite document control center 307 was noted on October 14, 1985, to be in possession of a controlled copy of Component Modification Card 96181 for which receipt had not been signed for and dated on the Document Distribution Log.

2.

A copy of superseded Design Change Authorization (DCA) 21446, Revision 0, was noted on the same date to be present in two packages for Drawings 2323-El-1702, Sheet 002, Revision 2.

Both copies of DCA 21446, Revision 0, were not stamped " VOID" on the face of the document.

Response to Item C - No. 1 1.

Reason for Violation:

Failure to properly implement procedure.

2.

Corrective Action Taken:

The Document Distribution Log was corrected by the inclusion of proper initial and date. The Document Distribution Log was reviewed and there were no other violations of this nature identified.

3.

Corrective Steps to Avoid Recurrence:

1 Appropriate DCC personnel were reinstructed in the proper receipt acknowledgement of design changes. DCP-3 rev. 19 paragraph 3.1.1.1 includes verification responsibilities by DCC personnel to ensure acknowledgment of design changes is documented.

Date of Full Compliance:

March 31, 1986.

9-L l-r-

Notice of Violation Item C (446/8511-V-02)~

(Continued)

Response to Item C - No. 2 1.-

Re{sonforViolation:

' Failure to pr.operly implement procedure.

2.

Corrective Action Taken:

The drawing package contents were immediately corrected..It was determined that the drawing was not used in the performance of.

plant work. Monitoring a sample of drawing package centents revealed that no' drawings or design changes were.found to be out of revision.

3..

Corrective Steps to. Avoid Recurrence:

Personnel were reinstructed in the need to assure up-to-date contents in drawing packages, including the marking of superseded drawings as " void".

4.

Date of full Compliance:

April 1, 1986.

.)

'1 1

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. ; 8!

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l

~

Notice of Violation Item D (446/8511-V-03)

Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP, 2

Section 5.0, Revision 3, dated July 31, 1984, requires that activities f

affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Section 17.1.17 of the Final Safety Analysis Report, Volume XIV, Amendment 50, dated July 13, 1984, commits to procedures requiring that records be controlled and accounted for during transfer between organizations.

Contrary to the above, original sole copy design records were ascertained on October 16, 1985, to have been shipped to Stone and Webster Engineering Corporation, New York, without the establishment and implementation of procedures that address required control and intientory measures.

Response to Item D 4

1.

Reason for Violation:

Conditions noted in the violation are the result of a failure to follow established procedures for control of engineering documents.

TUGC0 Nuclear Engineering (TNE) Procedure THE-AD-4 specifies that duplicate copies of engineering documents prepared or processed by TNE shall be maintained at the site or Gibbs & Hill /New York, as applicable.

In 1985, Stone & Webster Engineering Corporation (SWEC) assumed design responsibility for pipe supports.

In order to consider and incorporate, where possible, existing information into SWEC designs, TUGC0 initiated shipment of pipe support design records offsite.

2.

Corrective Action Taken:

Measures to establish compliance with TNE procedure TNE-AD-4 and subordinate TNE instruction THE-AD-4-6 (issued specifically for transmittal and duplicate retention of pipe support calculations) have been implemented for pipe support records previously forwarded to SWEC. These efforts, involving the return of copies and complete accountability, were completed in February 1986.

3.

Corrective Steps to Avoid Recurrence:

THE-AD-4-6 was issued :Lvember 25, 1985, establishing a program for transmittal requirn;:,

for pipe support design records.

In be reviewed and revised, if required, to addition, TNE-AD-4 assure the adequac;.

lasures prescribing the offsite transmittal of engineering dom i

f

.j..

4 Notice of Violation-Item D (446/8511-V-02).

(Continued) l 4.

Date of Full Compliance:

As noted in items 2 and'3, all measures have been completed with the exception of the review / revision of. Procedure TNE-AD-4.

These measures will be accomplished no later than May 22,.1986.

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Notice of Violation item E (446/8514-y-03)

Criterion VI of Appendix B to 10 CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative and Quality Assurance Plan, requires that (1) measures shall be established to control the

' issuance of documents such as drawings, including changes thereto; and j

(2) the measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel.

(

. Paragraphs 2 and 4 in Revisions 7 and 8 of Station Administration Manual Procedure No. STA-405 require 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.

Paragraph 4.0 in Revision 0 of Nuclear Operations Engineering Manual Instruction No.'N0E-201-5 requires that proposed drawing changes be submitted to the Operations Superintendent for review, approval, an(

authorization to distribute the revised drawings.

Contrary to the above, nine-as-built drawings were revised and distributed by TUGC0 Nuclear Engineering to reflect NCR identified undersize welds, without receiving TUGC0 Operations review, approval, and authorization to distribute the revised drawings.

Response to Item E 1.

Reason for Violation:

The condition noted in the violation is the result of the issue of pipe support drawings by TNE documenting acceptance of "Use-As-Is" conditions prior to the proper disposition of several TUGC0 Operations' NCR's.

Prior approval of drawings which document the "Use-As-Is" disposition of NCR's by TUGC0 Operations is a requirement of Station Administration Manual Procedure STA-405.

Please note the following in regards to Appendix "A", item E, third paragraph of the subject NRC Inspection Report.

Procedure N0E-201-5 does not require "non-vital" drawings, such as BRH (pipe support) drawings be submitted to the TUGC0 Operations i Superintendent prior to issue by PSE (Pipe Support Engineering).

However, the generic issue of whether such drawings should be classified as " vital" and therefore be submitted to the TUGC0 Operations Superintendent is being processed by TUGC0 Deficiency Report (DR-86-007) whose disposition is yet outstanding.

2.

Corrective Action Taken:

The pipe support drawings noted in the finding were subsequently reviewed by TUGC0 Operations. Approval has been C ated by closure of the corresponding TUGC0 Operations' NCr "capleted December 19, 1985.

.n Notice of Violation Item E (446/8511-V-02)

(Continued) 3.

Corrective ~ Steps to Avoid Recurrence:

As a result of this specific finding, TNE Procedure TNE-AD-4-5 Revision I was issued November 11, 1985. Procedures which describe

.TNE and TUGC0 Operations interface arrangements applicable to pipe supports were reviewed to assure consistency. No addit,ional conflicts.were noted. Adherence to these interface requirements should preclude further violations of this nature.

4.

Date of Full Compliance:

As noted above,. full compliance has been achieved.

r u-

Notice of Violation Item-F (446/8514-V-04)

Criterion V.'of Appendix B to 10 CFR Part 50. as implemented by TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed'by documented instructions, procedures, or drawings of:a type appropriate to the circumstances and

-shall-be. accomplished in accordance with these instructions, procedures, or drawings.

Paragraph 3.0 of Procedure CP-QP-2.1, Revision 14, dated October 17, 1983, states in part, "... inspection personnel.... shall have-

, experience in and shall have completed a technical training course and examination in the area of inspection responsibilities." Paragraph 3.7 of this procedure states,Lin part, "... Inspection personnel shall be certified by the TUGC0 site QA supervisor as being qualified to perform their assigned tasks.",

Contrary to the above, it was noted on October 21, 1985, during review of i

documentation for Class IE lighting system conduit EAB1-1 that the electrical. inspector, who had signed inspection reports E-1-0024951 and E-1-0027419, had not been certified to the applicable Procedure QI-QP-11.2-25, Revision 17, dated February 13, 1984, " Inspection of New Installations for Class IE Lighting Systems.

Response to Item F 1.

Reason for Violation:

Oversight by QC Supervision which allowed the inspector in question to inspect to QI-QP-11.3-25 prior to final sign-off of his certification.

2.

Corrective Action Taken:

NCR E-85-101639 was initiated to address this violation.

In addition, 800-Inspection Reports completed by 163 QC Inspectors during the past six months were. reviewed to determine if further violations of this nature had occured. All of the reports reviewed were completed by QC Inspectors certified to the activity inspected.

3.

Corrective Steps to Avoid Recurrence:

QC Supervision is issued a weekly list which identifies the certification capabilities and status of their personnel, for use in inspection assignments. Based upon the above review results this action is sufficient to avoid recurrence of this violation.

Inspections performed prior to June 1985 are subject to CPRT action item VII.c.

4.

Date of Full Compliance:

May 5, 1986.

W

' 1 Notice of Deviation a-item A (445/8514-D-01)

Section 4.1.6.of ERC Comanche' Peak Project Procedure (CPP) CPP-012, "QA/QC _Interf ace with Construction /TUGC0" states,

~"The.QA/QC Records Administrator controls requests for equipment / services:and distributes and controls requests for technical information."

Contrary to the above, the QA/QC Records Admi_nistrator does not receive copies of requests to provide for control of these documents (445/8514-0-01).

With respect to item A in the Notice of Deviation, the NRC has ascertained subsequent to this report period that ERC' logs for tracking of equipment / service requests have not been utilizing procedurally required unique numbers.for individual requests. Accordingly, please i

address this as part of.your response to item A in the Notice of.

Deviation.

Response to Item A 1.

Reason for Deviation:

As the NRC identified, the QA/QC Records Administrator does not control requests for equipment / services from the Constructor /TUGCO.

Due to a misunderstanding of the NRC's concern at the time of'the finding, it.was not explained that such requests are tracked by a computerized log maintained by the Inspection Supervisor or his designee.

Subsequent NRC investigation confirmed the presence of this tracking mechanism. Consequently, the original NRC concern was i

resolved.

However, the NRC inspector subsequently identified a related concern: the log did not show a unique number for each equipment / services request as required by CPP-012.

The function of the equipment / services tracking mechanism is to ensure that all necessary equipment / services (i.e. scaffolding, l

l painting or lagging removal, etc.) are installed or performed before inspection takes place and are maintained until inspection is completed. All open equipment / services requests (ESRs) are maintained in a folder associated with the verification package with which they are identified. The computer tracking mechanism tracks the status of the most recently opened ESR. This function is served satisfactorily by the mechanism currently in place (the same mechanism in place at the time of the NRC inspection).

Changes to the mechanism used to track open ESRs are not required

[

since no failures to perform the intended function exist. However i

1 procedure CPP-012 must reflect current practice.

NoBice of Deviation Item A (445/8514-D-01)

(Continued) 2.-

Corrective Action Taken:

ERC Comanche Peak Project Procedure CPP-012 was revised March 11; 1986, to remove reference to the ESR log.

3.

Corrective Steps to Avoid Recurrence:

'The action to correct the reported condition serves as action to prevent recurrence.

4.

Date of. Full Compliance:

j March 11, 1986.

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Notice of Deviation Item B (445/8514-D-02)

Section 4.1 of CPRT. Issue-Specific Action Plan (ISAP) No. VII.c Revision 0, dated June 21, 1985, states, in part,

... Where required, documentation reviews will be utilized to supplement the reinspection for attributes which are nonrecreatable or inaccessible...."

l Section 4.1.3 of the ISAP states, in part,

... The inspection procedure will provide detailed instructions to the-inspectors and/or documentation reviewers for performing the reinspection and/or documentation reviews..."

Contrary to the above, the following examples were noted of inadequate procedural guidance and document reviewer performance in regard to nonrecreatable and inaccessible attributes:

.1.

Quality Instruction (QI) Q1-013, Revision 4, lists no specific attributes, but instead specifies that the inspector verify installations in accordance with one or more of a listing of TUGC0 procedures; i.e., QI-QP-11.8.1, -5, -6, and -8.

The list of appropriate procedures does not, however, indicate the applicable revision number of each procedure.

In that the number of nonrecreatable or inaccessible inspection dttributes can vary from revision.to revision of a procedure (e.g. Revisions 0 and 1 of TUGC0 Procedure QI-QP-11.8-8), the absence of guidance on applicable procedure revision numbers does not constitute detailed instructions.

2.

During the documentation review of Verification Package No.

R-E-CDUT-064, in accordance with 01-009, Revision 0, there was no evidence that a documentation check was made of inaccessible attributes for conduit C13016037 that were caused by the installation of separation barrier material (445/8514-0-02).

Response to Item B j

1.

Investigation:

QI-013 " Documentation Review for Instrumentation Equipment /R-E-ININ" does not, in fact, list specific attributes for the inspector to verify. The purpose of the documentation review governed by 01-013 is to provide inspector qualification information as input to ISAP I.d.1.

The intent of QI-013 is to verify the inspector who signed the inspection report (IR) being reviewed was certified to the appropriate revision of the Quality Instruction (01) that was in place at the time of the inspection.

To do this the document reviewer records the inspector's name, the QI number, and the revision of the procedure noted-on the IR. Then the inspector certifications are reviewed to determine if the inspector was certified to the appropriate revision at the time of s'igning the IR.

a

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Notice of Deviation Item B (445/8514-0-01)

(Continued)

This is an appropriate way to verify inspector certifications.

Consequently, no deviating condition is believed to exist.

Regarding use of document reviews to supplement reinspection for inaccessible attributes, the NRC finding is correct, based on Revision 2 of the CPRT Program Plan. However, in the ensuing time period, Revision 3 of the CPRT Program Plan, including a revised ISAP VII.c was issued.

ISAP VII.c as now written dictates that, after the sixty inspections have been concluded for the population sample, any attributes which were found to be inaccessible will cause additional samples to be selected from the population and inspected only for those attributes which were inaccessible in preceding inspections.

Document review will only be used for non-recreatable attributes unless sixty occurrences of the attribute are not accessible from the population as a whole.

Consequently, the programmatic change.in Revision 3 resolved this finding.

2.

Corrective Action Taken:

No corrective action for. items 1 and 2 are planned.

3.

Corrective Steps to Avoid Recurrence:

No corrective steps for items 1 and 2 are applicable 4.

Date of Full Compliance:

February 24, 1986.

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Notice of Deviation Item C (445/8514-D-03)

J QI-009,. Revision 0, "Occument Review of Conduit /R-E-CDUT", requires the

-ERC inspector to:

verify that ~ inspection reports signed by electrical inspectors.were dated after their date of certification and prior to their date of i

expiration, and, l

document.the SBN inspection report (IR) and/or. latest construction operation' traveler number at the bottom of the checklist.

H Contrary to the above:

Review of ERC accepted dc, cementation for conduit _ C14R13047 showed that the'.ERC inspector failed to. identify that the certification to the applicable Procedure QI-QP-11.3-23 had lapsed for the TUGCO-electrical inspector signing IR-E-46087.

The ERC completed inspection record checklist for conduit C13016037 4

in Verification Package'No. R-E-CDUT-064 did not contain documentation of the SBM IR or latest construction operation traveler number (445/8514-D-03).

1 Response to Item C 1.

Reason for Deviation:

A review of verification Package No. R-E-CDUT-064 and R-E-CDUT-070 confirmed-the NRC findings. This was determined to be an inspection error.

2.

Corrective Action Taken:

(DR) Deviation Report R-E-CDUT-070-ORI was written by the l

inspector.

The number for.the latest construction operation traveler was added to the applicable checklist on 11/21/85.

j The inspector was given additional training on 11/8/85.

Reinspection of 25% of this inspector's work involved 28 verification packages and was completed before 11/21/85.

The results of the 25% reinspection has been evaluated and based upon the minor nature of the discrepancies identified, no further actions was deemed necessary on the Inspector's past performance.

3.

Corrective Steps to Avoid Recurrence:

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

ongoing to analyze results of the Overview Inspection program.

l gather pertinent insco L.v error data from other sources (NRC reinspection, etc.).

< to effect required additional formal i

l training of inspecto:

l l

l

No% ice of Deviation-Item C (445/8514-D-01)

~

(Confinued).

4.

Date'of Full Complihnce:

Corrective action was completed by November 21, 1985.

Preventive action involves an ongoing program.

e.

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Item D (445/8514-D-01)

Notice of Deeiation Section 4 of CPP-009, Revision 3, states, in part, with respect to ISAP No. VII'.c, " Qualified QA/QC Review Team personnel perform field reinspecti~ons of specific hardware items and reviews of appropriate documents"in accordance with-approved instructions...."

Contrary to.the above, the following examples were noted where field reinspection of hardware items were not performed in accordance with approved instructions:

1.

Attribute 4.5 in Section 5.0 of Q1-055, Revision 0, states with c

respect to spring nuts, " Verify that the serrated grooves align with the channel clamping ridge." Checklists for support No. 0070 (Verification Package No. I-S-INSP-007)-and support No. 028 (Verification Package No. I-S-INSP-028) were signed by two separate ERC inspectors that this attribute was acceptable. NRC inspectors showed, however, that the spring nut serrated grooves did not align with the channel clamping ridge on both of these supports.

2.

Section 5.3.4.C in 01-027 states with respect to dimensional tolerances not shown on design drawings, " Component member length

+/-1/2 inch."

The bill of material on Revision 2 of drawing No. CT-1-097-402-C52R in Verification Package No. I-S-LBSR-023 shows item No. 4 (2 pieces) to be 7 3/4 inches long. The applicable inspection checklist.used during the ERC reinspection of this pipe support shows the installed configuration to be acceptable.

NRC inspect-tion determined, however, the actual length dimensions of the two pieces to be 6 5/8 inches and 6 1/2 inches, respectively, both of which are under the indicated minimum dimension of 7 1/4 inches.

3.

Section 5.0 in Q1-012 states, in part, " Verify that the piping / tubing and components... material agree with the Bill of Materials shown on the Instrument Installation Detail drawing.

Tubing is marked with longitudinal color coded marks for l

traceability.- Use applicable drawing to identify tubing...

Verify that the installed tubing has the proper slope.

The required slope for process wetted lines is one (1) inen per foot minimum. This slope requirement may be reduced to 1/4 inch per foot when physical layout is a problem. Verify that there is a proper air gap.

The minimum gap spacing shall always be 1/8 inch to allow each instrument sensing line to expand independently at all bends without striking adjacent sensing lines, other equipment, l

concrete or steel building members."

The applicable inspection checklist used during the ERC reinspection of instrumentation installation Verification Package No.

1-E-ININ-026 showed that the above attributes were inspected and accepted, as evidenced by the inspector's signoff (initials).

l i

r Notice of Deviation Item D (445/8514-D-D1 (Continued)

However, NRC inspection of the instrumentation installation revealed:

(a)

Six sections of tubing had no color coding for traceability; (b)

Ten sections of tubings, in which physical layout was not a problem, had slopes of 7/16 inch to less than 1/4 inch per.

foot and one section had reverse slope; and l

(c)

Two tubing sections had zero gap spacing between the high pressure and low pressure legs and the concrete penetration.

4.

Section 1.7 in QI-012 requires that: (a) tubing bend be verified to have a minimum radius of four times the normal tube size by using either a template, or by direct measurement calculations; and (b) the measured and calculated values be entered into the Minimum Bend Radius Record, with date and inspector's initials.

During NRC inspection of Verification Package No. I-E-ININ-04, equipment tag No. 1-FT-156, it was ncted that the inspection checklist was dated and initialed, attesting to the fact that the tubing bends had been verified as having a minimum radius of four times the nominal tube size. However, review of the applicable Minimum Bend Radius Record showed that the ERC inspector had neither measured and calculated, nor used a template to verify minimum bend radius.

In addition, the following notes had been entered by the ERC inspector:

"Ist 90' bend from instrument (hi &

lo side)... cannot be measured with existing tools.

Four (4) other bends visually more than 90* to accommodate slope" (445/8514-0-04).

e Response to Item D 1.

Reason for Deviation:

Reinspection confirmed the NRC findings.

item 1_and_2 Inspector error.

Item 3 Inspector Error. Ongoing adjacent construction and housekeeping activities (i.e., wiping down, climbing, ongoing work in I

O T

j

.o Notice of Deviation e

-Item D (445/8514-D-01 (Continued) j i.

surrounding areas,'etc.) prevent a firm determination as.to whether-or not the-NRC identified. findings existed at the time of the ERC

'inspectionibut, enough.i.ndication exists to justify' retraining of the, inspectors as a step to assure decertification of those items-a

-which may well have been inspector error.

y L

Item 4 l

Inspector error.. QI requires clarification to allow inspector to:

L indicate inaccessible bends.

2.

Corrective Action Taken:

J te_m_1 Deviation Reports I-S-INSP-007-DR2 and DR3 dated November 18, 1985, and I S-INSP-028-DR2 dated November 8, 1985, were written to,

document the misaligned spring nuts.

Twenty five percent of the work of both inspectors was reinspected.

1 The results of the. reinspection were documented and evaluated by 1

inspection supervision.

A decision was made to reinspect 100% of the spring nuts previously inspected by the first' inspector. The results of-the reinspection indicated a high error rate. This c.

inspector's services were discontinued and 100% of.his work was i

reinspected. The retained inspector was retrained on November 12, 1985.

All necessary reinspection were completed by December 5, 1985.

Deviating conditions identified by the reinspection have been documented in the applicable Verification Packages and DRs initiated.

A general training session on' Spring Nut inspection was given to all non-affected inspectors involved in the reinspection of this attribute. This retraining has been documented.

Item 2 Deviation Report I-S-LBSR-023-DR2 dated November 13, 1985, was written to document the dimensional deviations. The responsible inspector was the same one whose services were discontinued as indicated above, f

f Item 3 and 4 The Verification Package documentation for ININ-026 has been reinspected, I-E-ININ-004 was corrected, and DRs I-E-ININ-026-DR-2, t

e o Notice of Deviation l

Item D (445/8514-D-01 (Continued) c In addition, revision 1 of QI-012 was

-4, and -5 were issued.

and now provides a basis for the issued January 30, 1986, Due to problems noted inspectors to indi'cate inaccessible bends.

by ERC and those identified herein by the NRC, all ININ Verification Packages issued prior to January 14, 1986, will be reissued for reinspection.

3.

Corrective Steps to Avoid Recurrence:

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

ongoing to. analyze results of the Overview Inspection program, gather pertinent inspector error data from other sources (NRC l

reinspection,-etc.) and to effect required additional formal training of inspectors.

4.

Date of Full Compliance:

Corrective action is complete with the exception of the total reinspection of the ININ packages.

Preventive action involves an ongoing program.

1

.In Reply Refer To:

MAR 06 5 Dockets:

50-445/85-14 50-446/85-11 Texas Utilities Generating Company ATTN: Mr. W. G. Counsil Executive Vice President 400 North Olive,.L.B. 81 Dallas. Texas 75201 l

Gentlemen:

This refers to the inspection conducted by Mr. T. F. Westerman and other members of the Region IV Comanche Peak Group during the period September 30 through October 31, 1985, of activities covered by NRC Construction Permits CPPR-126 and CPPR-127 for the Comanche Peak Steam Electric Station, Units 1 and 2, and to the respective discussions of our findings with Messrs. J. B. George and. J. C. Kuykendall, and other members of your staff at the conclusion of the inspection.

Areas examined during the inspection included operations, construction. and Comanche Peak Response Team activities. An inspection was also performed by Region IV staff of Unit 2 cable tray support modifications during thir report period. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspectors.

These findings are documented in the enclosed inspection report.

During this inspection, it was found that certain of your activities were in violation of NRC requirements. Consequently, you are required to respond to these violations, in writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2. Title 10, Code of Federal Regulations.

Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter.

During this inspection, it was found that certain of your activities appeared to deviate from commitments made to the NRC. These items and references to the commitments are identified in the enclosed Notice of Deviation. You are requested to respond to these deviations in writing.

Your response should be based on the specifics contained in the Notice of Deviation enclosed with this letter.

With respect to item A in the Notice of Deviation, the NRC has ascertained subsequent to this report period that ERC logs for tracking of equipment / service reouests have not been utilizing procedurally required unique numbers for individual requests. Accordinly, please address this as part of your response to item A in the Notice of Deviation.

Y DRSP r NRR RIV: CPG / SRI / CON b iwST CPG CPG

?

ihv IBarnes TFWesterman EHJohnson VSNoonan SHPhillipsq 3/3/86

/16 3

/86 W 3/86 3/g/86

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ApocK o i

p.9 3 Texas Utilities Generating Company Twenty unresolved items are identified as follows in the enclosed inspection report: Appendix C, paragraph 4; Appendix 0, paragraphs 3.a, 3.c, 4.g, 5, 5.a, 5.c, 5.d, and 6; Appendix E, paragraphs 6.g. 6.h, 6.j, 7 a, 7.c, and 7.e.

We have also examined actions you have taken with regard to previously identified inspection findings. The status of these items is identified in paragraph 2 of Appendix C, paragraph 4 of Appendix D, and paragraph 2 of Appendix E of the enclosed report.

The responses directed by this letter and the accompanying Notices are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

/

origiaa; sidd 6y

r. 4 Johns 0n f

E. H. Johnson, Director Division of Reactor Safety and Projects

Enclosures:

1.

Appendix A - Notice of Violation 2.

Appendix B - Notice of Deviation 3.

Appendix C - NRC.0perations Inspection Report

' 50 445/95-14 4.

Appendix D - NRC Construction Inspection Report 50-445/85-14 50-446/85-11 5.

Appendix E - NRC Ccmanche Peak Response Team Activities Inspection Report 50-445/85-14 r 50-446/85-11 6.

Appendix F - NP.C Cable Tray Modifications Inspections Report 50-446/85-11 cc w/ enclosures:

(See page 3) f 4

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i

- Texas Utilities Generating' Company.q j

cc w/ enclosures:

Texas Utilities Generating Company

' ATTN:-

J. W. Beck, Vice President

. Licensing, Quality' Assurance, u

and Nuclear Fuels Skyway Tower 1

..400 North Olive Street-Lock Box 81.

Dallas, Texas 75201 Juanita Ellis President'- CASE' 1426 Polk Street Dallas, Texas 75224 Renea Hicks Assistant Attorney General Environmental Protection Division P. 0.' Box 12548 Austin, Texas 76711 TEXAS STATE DEPARTMENT OF HEALTH bectoDMB(IE01) bec distrib. by RIV:-

  • RPB
  • MIS System
  • RRI-OPS-

'*RSTS Operator

  • RRI CONST
  • R&SPB
  • T. F. Westerman, CPTG ORSP V. Noonan, NRR R. Martin, RA S. Treby,-ELD
  • RSB
  • RIV File J. Taylor, IE
  • D.' Weiss, LFMB (AR-2015)

R. Heishman, IE

  • w/766 i

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  • 4 l

1 APPENDIX A NOTICE OF VIOLATION j

Texas Utilities Electric Company Dockets: 50-445/85-14

)

50-446/85-11 1

Comanche Peak Steam Electric Permits: CPPR-126 Station, Units 1 and 2 CPPR-127 1

During an NRC inspection conducted on October 1-31, 1985, six violations of NRC requirements were identified.

The violations involved failure to maintain sufficient chemistry records, a minimum wall violation not being documented on a nonconformance report (NCR), inadequate issue control for design documents, absence of procedures for controlling offsite shipment of original design records, signing of inspection reports by a noncertified electrical inspector, and revision of drawings without required review and approval actions.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below:

A.

Criterion XVII of Appendix B to 10 CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative Control and Quality Assurance Plan, requires that (1) sufficient records shah be maintained to furnish evidence of activities' affecting quality, and (2) that the records shall include the results and acceptability of tests and analyses, and the action taken in connection with any deficiencies noted.

Contrary to the above:

1.

A.significant number of instances of missing data entries was noted in water chemistry records covering the period March 1983 through September 1985, with respect to the chemistry sampling frequency requirements of Procedures CHM-501, " Chemistry Control of the Steam Generators," and CHM-508, " Chemistry Control of the Primary Cooling Water Systems." No annotations were made in the records to explain why the samples were not taken.

2.

Review of the water chemistry records showed instances of failure to make required entries to indicate when the Shift Supervicor was notified in regard to out-of-specification chemistry results.

3.

The records did not identify what corrective actions were taken after entry of out-of-specification results.

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3 4.

Inadequate reviews were performed of.the acceptability of water chemistry data, as eviden ed by the presence of review and approval signatures on forms containing discrepant data results, This is a Severity Level IV violation (Supplement II) (445/8514-V-01).

1 g

B.

Criterion V 6f Appendix B to 10 CFR Part 50', as implemented by TUGC0 Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be i

prescribed by documented instructions, orocedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Paragraphs 2.3 and 3.1.1.1 of Brown and Root (B&R) Procedure CQ-QAP-16.2, l

Revision 25, require that nonconformances be identified, documented by completing the NCR form, and dispositioned. Paragraph 3.19.5.2 of B&R Procedure CP-CPM 6.9D, Revision 6, states, in part, with respect to NCRs for minimum wall violations, "... Welding engineering shall review the conditions stated on the NCR...."

Contrary to the above, repair of a ininimum wall violation associated with weld 21-2 in component CC-2-RB-053 was noted on October 9, 1985, from recoret review to have been performed without documenting the condition on an NCR form.

This is a Severity Level IV violation (Supplement II) (446/8511-V-01).

C.

Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, Section 5.0, Pevision 3, dated July 31, 1984, requires that activities affecting quaiity shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings, t

Paragraph 3.1.1.1 of B&R Procedure DCP-3, Revision 18, states, in part,

"... Issuance and receipt of cortrolled design changes are documented on the Document Distribution Log... by signature or initial of the file custodian and dated." Paragraph 3.2.2.5 of this procedure additionally requires that the face of a retained superseded document must be stamped j

" VOID."

Contrary to the above:

1.

Satellite document control center 307 was noted on October 14, 1985, to be in possession of a controlled copy of Component Modification Card 96181 for which receipt had not been signed for and dated on the Document Distribution Log.

4

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J,p 9 l 2.

A',' copy of superseded Design Change Authorization (DCA) 21446, Re' vision 0, was noted on the same date to be present in two packages for Drawing 2323-El-1702, Sheet 002, Revision 2.

Both copies of l-DCA.21446, Revision 0,-were not stamped " VOID" on the face of the document.

This is a Severity Level IV violation (Supplement II)

(446/8511-V-02).

Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 Y QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or dra ings of a type appropriate to the circumstances and'shall be accomplished in accordance with these instructions, procedures, or drawings.

Section 17.1.17 of the Final Safety Analysis Report, Volume XIV, Amendmert 50, dated July 13, 1984, commits to procedures requiring that i

records be controlled and accounted for during transfer between

)

organizations.

Contrary to the above, original sole copy design records were ascertained

)

on October 16, 1985, to have been shipped to Stone and Webster Engineering Corporation, New York, without the establishment and implementation of j

procedures that address required control and inventory measures.

This is a Severity Level IV violation (Supplement II) (445/8514-V-02, 446/8511-V-03).

E.

Criterion VI of Appendix B to 10 CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative and Quality i

Assurance Plan, requires that (1) measures shall be established to control the issuance of documents such as drawings, including changes thereto; and (2) the measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel.

Paragraphs 2 and 4 in Revisions 7 and 8 of Station Administration Manual Procedure No. STA-405 require 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.

Paragraph 4.0 in Revision 0 of N nlear Operations Engineering Manual Instruction No. N0E-201-5 requires that proposed drawing changes be submitted to the Operations Superintendent for review, approval, and authorization to distribute the revised drawing.

i

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Contrary to the above, nine as-built drawings were revised and. distributed I

by TUGC0 Nuclear Engineering to reflect NCR identified undersize welds, without receiving TUCG0 Operations review, approval, and authorization to distribute the revised drawings.

1 This is a Severity Level IV violation (Supplement II) (445/8514-Y-03).

F.

Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0

'QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Paragraph 3.0 of Procedure CP-QP-2.1, Revision 14, dated October 17, 1983, states, in part, "... inspection personnel... shall have experience in

.and shall have completed a technical training-course and examination in the area of inspection responsibilities." Paragraph 3.7 of this procedure states, in part, "... Inspection personnel shall be certified by the TUGC0 site QA supervisor as being qualified to perform their assigned tasks."

Contrary to the above, it was noted on October 21, 1985, during review of documentation for Class 1E lighting system conduit EAB1-1 that the electrical inspector, who had signed inspection reports E-1-0024951 and i

E-1-0027419, had not been certified to the applicable Procedure l

01-QP-11.2-25, Revision 17 dated February 13, 1984, " Inspection of New Installations for Class IE Lighting Systems."

This is a Severity Level IV violation (Supplement II) (445/8514-V-04).

Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric i

Company is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation:

(1) the reason for the violations if admitted (2) the corrective steps which have been taken and the results achieved. (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

Dated at Arlington, Texas this 6th day of March, 1986.

_y u #1 y c

Y APPENDIX B NOTICE OF DEVIATION Texas Utilities Electric Company Dockets:- 50-445/85-14 50-446/85-11 Comanche Peak Steam Electric Permits: CPPR-126 CPPR-127 Station,-Units 1 and 2 Based on the results of an NRC' inspection conducted during.the period of October 1 through 31, 1985, of Comanche Peak Response Team (CPRT) activities, four deviations from commitments to the NRC were identified. The deviations involved ERC equipment / service requests not being controlled as committed, inadequate ERC document review and procedure criteria with respect to inspection attributes that are inaccessible or nonrecreatable, failure of ERC document reviews to both detect a lapsed electrical inspector certification and i

to record required information in a verification package, and inspection attributes being attested to as acceptable by ERC inspectors which were found

-by subsequent NRC inspection to be unacceptable.

In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions,"-

10 CFR Part 2, Appendix C.(1985), the deviations are listed below' t

- A.

Section 4.1.6 of ERC Comanche Peak Project Procedure (CPP) CPP-012, "QA/QC l

Interface with Constructor /TUGCO," states, "The QA/QC Records Administrator controls requests for equipment / services and distributes and controls requests for technical information."

Contrary to the above,.the QA/QC Records Administrator does not receive copies of requests to provide for control of these documents t

(445/8514-D-01).

B.

Section 4.1 of CPRT Issue-Specific Action Plan (ISAP) No. VII.C, Revision 0, dated June 21, 1985, states, in part, "... Where required, documentation reviews will be utilized to supplement the reinspection for attributes which are nonrecreatable or inaccessible...."

Section 4.1.3 of the ISAP states, in part, "... The inspection procedure will provide detailed instructions to the inspectors and/or documentation i

reviewers for performing the reinspection and/or documentation reviews Contrary to the above, the following examplis were noted of inadequate procedural guidance and document reviewer performance in regard to nonrecreatable and inaccessible attributes:

gDR ADOCR 05000445 PDR

_ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __j

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. 1.

Quality Instruction (QI) QI-013, Revision 4, lists no specific attributes, but instead specifies that the inspector verify installations in accordance with one or more of a listing of TUGC0 procedures; i.e., QI-QP-11.8-1, -5, -6, and -8.

The list of appropriate procedures does not, however, indicate the applicable revision number of each procedure.

In that the number of nonrecreatable or inaccessible inspection attributes can vary frv; revision to revision of a procedure (e.g., Revisions 0 an6 1 of 7t,Jr,U Procedure QI-QP-11.8-8), the absence of guidance on applicable procedure revision numbers does not constitute detailed instructn.71.

2.

During the documentation review of Verification Package No. R-E-CDUT-064, in accordance with QI-009, Revision 0, there was no evidence that a documentation check was made of inaccessible attributes for conduit C13016037 that were caused by the installation of separation barrier material (445/8514-D-02).

C.

QI-009, Revision 0, " Document Review of Conduit /R-E-CDUT," requires the ERC inspector to: (1) verify that inspection reports signed by electrical inspectors were dated after their date of certification and prior to their date of expiration, and (2) document the SBM inspection report (IR) and/or latest construction operation traveler number at the bottom of the checklist.

Contrary to the above:

l.

Review of ERC accepted documentation for conduit C14R13047 showed that the ERC inspector failed to identify that the certification to the applicable Procedure QI-QP-11.3-23 had lapsed for the TUGC0 electrical inspector signing IR-E-46087.

2.

The ERC completed inspection record checklist for conduit C13016037 in Verification Package No. R-E-CDUT-064 did not contain documentation of the SBM IR or latest construction operation traveler number (445/8514-0-03).

D.

Section 4 of CPP-009, Revision 3, states, in part, with respect to ISAP No. VII.c, " Qualified QA/QC Review Team personnel perform field reinspection of specific hardware items and reviews of appropriate documents in accordance with approved instructions...."

Contrary to the above, the following examples were noted where field reinspection of hardware items were not performed in accordance with approved instructions:

1.

Attribute 4.5 in Section 5.0 of QI-055, Revision 0, states with respect to spring nuts, " Verify that the serrated grooves align with the channel clamping ridge." Checklists for support No. 0070

t 3

. (Verification Package No. I-S-INSP-007) and support No. 028 (Verification Package No, I-S-INSP-028) were signed by two separate ERC inspectors that this attribute was acceptable.

NRC inspections showed, however, that the spring nut serrated grooves did not align j

with the channel clamping ridge,on both of these supports.

j 1

ect to dimensional Section 5.3.4.C in QI-027 states with resp' Component member length j

2.

tolerances not shown on design drawings,

+/-1/2 inch."

The bill of material on Revision 2 of drawing No. CT-1-097-402-C52R in Verification Package No. I-S-LBSR-023 shows item No. 4 (2 pieces) to be 7 3/4 inches long. The applicable inspection checklist used during the ERC reinspection of this pipe support shows the installed configuration to be acceptable.

NRC inspection determined, however, the actual length dimensions of the two pieces to be 6 5/8 inches and F 1/2 inches, respectively, bott of which are under the indicated minimum dimension of 7 1/4 inches.

3.

Section 5.0 in QI-012 states, in part, " Verify that the piping / tubing and components... material agree with the Bill of Materials shown on the Instrument Installation Detail drawing.

Tubing is marked with I

longitudinal color coded marks for traceability. Use applicable drawing to identify tubing... Verify that the installed tubing has the proper slope. The required slope for process wetted lines is one (1) inch per foot minimum.

This slope requirement may be reduced to 1/4 inch per foot when physical layout is a problem.

Verify that there is a proper air gap.

The minimum gap spacing shall always be 1/8 inch to allow each instrument sensing line to expand independently at all bends without striking adjacent sensing lines, other equipment, concrete or steel building members."

The applicable inspection checklist used during the ERC reinspection of instrumentation installation Verification Package No. 1-E-ININ-026 k

showed that the above attributes were inspected and accepted, as I

evidenced by the inspector's signoff (initials).

l l

However, NRC inspection of the instrumentation installation revealed:

(a) Six sections of tubing had no co.

aing for traceability; I

(b) Ten sections of tubings, in which phys'ical layout was not a problem, had slopes of 7/16 inch to less than 1/4 inch per foot and one section had reverse slope; and

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(c) Two tubing sections had zero gap spacing between the high pressure and low pressure legs and the concrete pentration.

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p,

4.

Section 1.7 in QI-012 requires that:

(a) tubing bends be verified to I

have a minimum radius of four times the nominal tube size by using I

either a template, or by direct measurement and calculations; and (b) the measured and calculated values be entered into the Minimum Bend Radius Record, with date and inspector's initials..

During NRC inspection of Verification Package No. I-E-ININ-04, equipment tag No.1-FT-156, it was noted that the inspection chec(list was dated and initialed, attesting to the fact that the tubing bends had been verified as having a minimum radius of four times the nominal tube size. However, review of the applicable Minimum Bend Radius Record showed that the ERC inspector had neither measured and calculated, nor used a template to verify minimum bend radius.

In addition, the following notes had been entered by the ERC inspector: "1st 90' bend from instrument (hi & lo side)... cannot be measured with existing tools. Four (4) other bends visually more than 90' to accommodate slope" (445/8514-0-04).

Texas Utilities Electric Company is hereby required to submit to this office, within 30 days of the date of this Notice of Deviation, a written statement or explanation in reply, including for each deviation:

(1) the reason for the deviations if admitted,- (2) the corrective steps which have been taken and the results achieved, (3) corrective steps which will be taken to avoid further deviation from commitments made to the Commission, and (4) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

Dated at Arlington, Texas, this 6th day of March, 1986 d

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J APPENDIX C

]

OPERATIONS INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION REGION IV i

NRC Inspection Report:

50-445/85-14 Permit: CPPR-126 Docket:

50-445 Category:

A2 Apolicant:

Texas Utilities Electric Company (TUEC)

Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:

Comanche Peak Steam Electric Station (CPSES), Unit 1 Inspection At: Glen Rose, Texas Inspection Conducted:

October 1-31, 1985 Inspectors hs '

/Nu 7/7 PI D.

'. ' Kelley, Seqior R ent Reactor Inspector Date /

(SRRI), Region /IV C Group (paragraphs 1,5, 7,

)

i 2.fL f f6 8

W. F. Smith, Resident Reactor Inspector (RRI)

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Region IV CPSES Group (paragraphs 1, 2, 3, 4, 5, 6, 7, 8)

Reviewed By:

[%

3/3/N I. Barnes, Group Leader, Region IV CPSES Group Date 1

7N 3/1/ F6 Approved:

6 T. F. Westerman, Chief, Region IV 6.U.S Group Date f

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lsPiss#Im, j'if PDR 1

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Inspection Summary Inspection Conducted:

October 1-31,1985(Report 50-445/85-14)

Areas Inspected:

Routine, unannounced inspection of (1) applicant actions on previous inspection findings, (2) maintenance procedures, (3) preventive maintenance programs, (4) plant tours, and (5) plant status. The inspection involved 117 inspector-hours onsite by two NRC inspectors.

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Results: Within the five areas inspected, one violation (failure to maintain sufficient chemistry records, paragraph 4) was identified.

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. DETAILS 1.-

Persons, Contacted Applicant Personnel

  • A. B. Scott, Vice President Operations
  • J. C. Kuykendall, Vice President
  • C. H. Welch, Quality Control Services Supervisor
  • R. B. Seidel, Operations Superintendent S. N. Franks, Special Project and Technical

' Support Lead i

  • M. R. Blevins, Maintenance Superintendent D. E. Deviney, Operations QA Supervisor
  • R. A. Jones, Manager, Plant Operations K. L. Luken, Lead Startup Engineer
  • R. R. Wistrand, Administrative Superintendent
  • D. W. Braswell, Engineering Superintendent
  • J. C. Smith, Quality Assurance
  • T. L. Gosdin, Support Services Superintendent
  • G. M. McGrath, Licensing / Compliance Supervisor, Startup
  • M. J. Riggs, Operations. Support Engineer D. M. Jones, Maintenance Engineering Technician L. Parr, Maintenance Engineer K. Stenburg, Maintenance Engineer T. Justis,. Maintenance Engineer H. Haby, Instrumentation & Controls Staff Engineer W. Jones, Instrumentation & Controls Staff Engineer B. Taylor, Instrumentation & Controls Engineer R. D.. Delano, Chemistry & Environmental Engineer G. B. Moore, Chemistry & Environmental Supervisor R. L. Theimer., Chemistry Supervisor
  • Denotes applicant representatives present during exit interview of paragraph 8.

4 The NRC inspectors also interviewed other applicant employees during this inspection period.

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- = - - - -

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2.

Applicant Actions on Previous Inspection Findings a.

(Closed) Open Item 445/8436-05: Applicant to provide a response manual for the loose parts monitoring system.

In Section 5.4.3 of the Safety Evaluation Report (July 1981), the staff indicated acceptance of the applicant's loose parts monitoring system. The SRRI issued Open Item 445/8436-05 to track the applicant'c issuance of a response manual for the loose parts monitoring system.

On October 10, 1985, EDA-310, " Analysis of Loose Parts Monitoring System Data" was issued, which provides instructions for use of the system.

This item is closed.

b.

(Closed) Open Item 445/8502-01: Voiding of signatures in.

preoperational test data packages.

During routine i1spections of completed preoperational test data packages, the RRI noted inconsistencies in the methods used by System Test Engineers (STEs) to void or supersede previous signatures when test steps had to be repeated.

Section 4.8 of CP-SAP-21 required the STEs to void entries by lining through and signing (or initia111ng) the line-outs and l

dating them.

Sometimes the STE failed to sign and date the line-out, thereby casting doubt on the part of a reviewer as to whether the signature was for the line-out or for reperformance of the step.

The RRI suggested that a more straight-forward method of superseding such steps be considered. The applicant has since responded that the i

requirements of CP-SAP-21 will not be changed; thus the STEs will be expected to comply with Section 4.8 when voiding signatures.

This item is closed.

c.

(Closed).0 pen Item 445/8502-02:

Unclear justifications for test procedure deviations (changes). While reviewing completed preoperational test data packages, the RRI identified a number of cases where the STE did not enter a clear and concise reason or 1

justification for making minor changes to test procedures, which are l

called test procedure deviations (TPDs).

It appeared that if more specific direction was provided in Startup Administrative Procedure CP-SAP-12, " Deviations to Test Instructions / Procedures," this problem might not have existed. The applicant has since issued Revision 3 of CP-SAP-12 which directs the TPD author to enter a detailed justification for each change.

The RRI reviewed the re, vised procedure and is satisfied with the change.

This item is closed, d.

(Closed) Open Item 445/8502-03: Post-completion changes to test t

  • documentation. During an inspection of completed preoperational test data packages, the RRI identified what appeared to be post-completion changes to test procedures using test deficiency reports (TDRs) as the authorizing document.

Although this practice did not have any adverse effects on the test records, administrative procedures did not provide for such changes. The applicant's response to this item

4 1

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i was that test data packages were not being " revised or changed" by TDRs, per se, but rather were being " annotated" to show the correct information found during the data package review which was in turn documented and evaluated by the TDR. This concern is being addressed i

by recent changes to the Startup Administrative Procedures Manual to

{

clarify the entry of corrections during completed test data reviews.

For example, on July 8,1985, Revision 6 to CP-SAP-11, " Review, Approval, and Retention of Test Results," was issued.

The revised administrative procedure now requires the Joint Test Group (JTG) to document test data review comments and resolutions, and to include this with the supporting documentation in the completed test data package. This will provide a means by which problems found during the JTG review of test data can be documented along with the JTG-approved disposition.

The TDR will still be utilized to document bonafide deficiencies and corrective actions (including retesting, if any); however, the applicant has indicated that changes or revisions will not be made against completed test procedures.

This item is l

closed.

.e.

(Closed) Unresolved Item 445/8502-08:

Discontinuity between reference drawing revisions in similar test procedures. While conducting an inspection of the completed preoperational test data package for 1CP-PT-29-03, Retest (RT)-2, the NRC inspector noted that the list of reference drawings contained later revisions of the same drawings referred to in 1CP-PT-29-03, RT-1, which was conducted later than RT-2.

The issue was whether or not failure to update the

]

references for ICP-PT-29-02, RT-1 had any affect on test performance.

After the question was raised, the applicant responded by explaining that RT-1 did not have the correct revision numbers; however, since

.the objective of both tests was to start and load test the emergency diesel generators, the revisions of the reference drawings had no significance and thus did not affect the outcome nor the objectives of the test.

The applicant filed a copy of the response and explanation as a supplement to the completed test data packages for ICP-PT-29-03, RT-1 and RT-2 for future reference. This item is

closed, j

f.

(Closed) Open Item 445/8502-11: During an inspection of the completed preoperational test data package for ICP-PT-57-10, " Load Group Assignment," the SRRI noted that TOR-3676 had identified a failure to accomplish the slow transfer of train B bus 1EA2 when initiated by the test procedure.

Under corrective action, the TDR referenced Maintenance Action Request (MAR) 84-4036 to repair and/or adjust the auxiliary switches and actuating bar at a later date.

Meanwhile, per the TDR, the switches were placed in the required position manually so that the test could be resumed, including a repeat of the slow transfer test, which was successful. The MAR and MAR retest documents were not in the test data package.

Subsequent

n

. l RRI review of the completed MAR revealed that the actuating bar was in need of lubrication and operated freely once lubricated.

The applicant's representatives explained that the state of the auxiliary.

i

-switches was in a condition required for accomplishment'of the test i

l and that testing of this breaker was not an objective of the test; thus, it was not necessary to repeat the applicable section of 1CP-PT-57-10 after the actuating bar was lubricated and successfully

]

exercised. This item is closed.

g.-

(Closed) Open Item 445/8502-12:

Potential impact of reference drawing changes in preoperational test ICP-PT-57-10.

During the completed test data package review of ICP-PT-57-10 conducted by the applicant, TOR-3966 was issued identifying a failure to update the correct revision of 15 drawings referenced in the test procedure.

'The SRRI was concerned that no documentation existed in the completed test data package showing that an evaluation was made to determine the impact this might have on the test results. The RRI verified that the applicant had since conducted the evaluation, documented the results on letter TSU-85169 of October 14, 1985, and incorporated the letter into the completed test data package.

The evaluation did not identify any impact on test results.

This item is closed.

h.

(Closed) Open Item 445/8506-02: Open TOR in a completed preoperational test package.

During routine inspection of the completed preoperational test data package for ICP-PT-64-01, the RRI found TDR 3799 filed in the package with no evidence that it had been properly-dispcsitioned and closed.

Subsequently, the applicant's representative responded by explaining that this TDR was not wrftten against ICP-PT-64-01; however, it was filed in the package for information only.

Any testing issues associated with this TDR and the referenced containment spray valves have been deferred to the initial startup test program. The RRI found this to be adequately tracked by TUGC0 Operations under DPTR-85-002.

This item is closed.

3.

Maintenance Procedures The objective of this inspection was to confirm that plant maintenance procedures were prepared to adequately control maintenance and surveillance testing of safety-related systems within applicable regulatory requirements.

The inspection included verification that; o

Adequate procedures and processes were in place for control of measuring and test equipment (M&TE);

o Procedures had been published for performing preventive and selected corrective maintenance;

Adequate procedures and programs existed for the implementation of o

surveillance required by Technical Specifications (TSs);

All procedures were in the appropriate format as specified in the 1

o administrative control manual, and that they were technically adequate to accomplish their stated purpose; and i

Where appropriate, procedures prescribed steps important to the l

o protection of the health and safety of the workers and of the public.

j The maintenance procedure inspection commenced in September 1985 and continued through completion in October 1985. Details of the inspection conducted in September 1985 were reported in Appendix C of NRC Inspection Report No. 50-445/85-13.

The following procedures were reviewed by the NRC inspector which met a.

the objectives of this inspection and for which there were no comments or adverse findings:

o INC-101, Revision 4, "I&C Maintenance Program";

INC-109, Revision 1, I&C Preventive Maintenance Program";

o o

INC-7323A, Revision 1, " Analog Channel Operational Test and Channel Calibration - Steam Generator NR Level, Loop 1, Protection Set III, CH 0518";

INC-601, Revision 2, " Digital Multimeter Calibration";

o INC-624, Revision 2, " Pressure Test Gauge Calibration";

o INC-631, Revision 1, " Dial-Type Thermometer Calibration";

o MMI-302, Revision 0, " Reactor Coolant Pump Seal Replacement";

o MMI-320, Revision 0, " Pressurizer Spray Nozzle Inspection";

o o

EMI-313, Revision 1, " Centrifugal Charging Pump Motor Inspection"; and EMI-806, Revision 0, " Electric Penetration Removal, repair, and o

Installation."

b.

Procedures INC-2006X, Revision 0, " Filling and Venting Flow and Differential Pressure Transmitters (Water or Steam)," and INC-2007X, Revision 0, " Venting and Filling Pressurizer and Steam Generator Level Transmitters," were found to not meet the objectives of this inspection as identified below.

On March 21, 1985, Severity Level IV

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Notice'of Violation 445/8445-02 was issued citing the ' applicant for T

' failure to. provide adequate procedures appropriate to circumstances.

9 The circumstances involved an Instrumentation and Control (I&C)

J.!

technician who attempted to fill a pressurizer level detector reference leg while the plant was hot in accordance with an inadequate' procedure (i.e.,10I-2007), which led to errors and 'a-m';.

first degree thermal burn on his forearm.

One of the preventive.

Lp actions in the applicant's response to the violation dated April 15, 1985,'was to revise ICI-2007'which became INC-2007X.

1

'Another action was to review the remaining applicable procedures for JJ similar procedural problems. The applicant stated that there were no other procedura1' problems that would result in a similar incident.

y; ICI-2006 was among those reviewed and. it has since become INC-2006X.

1 In. light of'the problems found by the RRI when he reviewed these two

. representative' procedures, violation 445/8445-02 could not be closed, This was discussed with applicant management during the exit-i interview of November 1, 1985, and acknowledged.'

r The revised procedures (INC-2006X and INC-2007X) contained steps that were unnecessary, and contained instructions.to perform preparations q

(i.

e., assembling test equipment) in a radiation area when they 1

could have been done in a nonradiation area.

It was apparent to the.

j NRC inspector that ALARA program considerations were not incorporated

'F into the procedures.. The ALARA ("As Low As Reasonably Achievable")

Program is implemented by HPA-101, "ALARA PROGRAM," which requires procedures, planning, and training to ensure.all ionizing radiation exposure is reduced to as low as reasonably achievable on the basis of the state of technology and the economies of reducing exposure relative to the benefits realized.

4 Both of the above procedures-were inconsistent as to how to isolate

.i and equalize differential pressure detectors.

y l

Some steps were not flagged for radiological controls when l

potentially radioactive material was to be handled.

e Double valve isolation was not utilized as required by INC-101 to g

protect the I&C technicians from temperatures in excess of 200 F.

Filling and venting of differential pressure detectors should include sweeping air bubbles out through the equalizer valves.

INC-2006X did not provide for this.

)

INC-2007X had a caution note which stated that the reference legs are connected to the high pressure side of the sensors.

This is not true in the case of Rosemount Detector ILT-459F, thus the procedure does not accurntely reflect the equipment to which it is to be applied, I

3;

> indicating inadequate procedure reviews.

The above deficiencies were discussed in detail with the applicant's representative, who subsequently provided the NRC inspector with a sample mark-up of INC-2007X which reflected acknowledgement and correction of the deficiencies discussed.

Sin'ce correction of deficiencies such as the above is related to corrective actions associated with violation 445/8445-02, additional tracking of this issue is not necessary.

There were no additional violations or deviations identified.

4.

Preventive Maintenance Programs The RRI is conducting an on going inspection to verify that an adequate preventive maintenance program is scheduled and implemented, both from a routine equipment readiness standpoint, and in consideration of the length of shutdown time between Unit 1 preoperational testing and startup.

This inspection includes verification that adequate controls exist to ensure l

equipment maintenance will be followed by appropriate tracking and performance of retests prior to restoring the equipment to an operational i

status.

The NRC inspector interviewed applicant representatives responsible for j

the implementation and tracking of preventive maintenance and surveillance 4

testing.

Three groups have separate responsibilities in this area:

o Maintenance Engineering:

Mechanical and electrical maintenance, 1

including meter and relay maintenance.

o Instrumentation & Control:

Maintenance of plant system instrumentation and controls, o Results Engineering:

Surveillance tests and inspections required by TSs.

Maintenance Engineering has implemented a plant equipment preventive maintenance program in accordance with Mair.tenance Department Administration Procedure MDA-301, " Preventive Maintenance Program." The program was developed to satisfy the requirements of ANSI N18.7-1976 as well as the maintenance manuals furnished by Westinghouse and other vendors. The scope of the program encompasses all electrical and mechanical equipment that are not assigned specifically to the I&C group.

I&C implements an overall maintenance program on equipment within their cognizance in accordance with INC-101.

There are other subordinate implementing procedures, such as INC-107, which cover all scheduled calibrations and all required TS surveillance items that are assigned to I&C.

INC-109, for example, @ rs all preventive maintenance not alreaoy covered by INC-107.

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~ Results Engineering'will implement the surveillance program in accordance with STA-702,." Surveillance Test Program." This provides for scheduling,.

J

' tracking, review and disposition of the records for all surveillance

)

required by the TSs..

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The RRI interviewed' representatives from each of the above groups, at j

which time the respective programs were explained. In general, it appears j

.that a comprehensive preventive maintenance program is in place, that is j

managed through computer scheduling and tracking programs.

During future i

NRC inspections, it will be determined if the programs are effective and the equipment is being maintained in a satisfactory state of readiness.

The RRI reviewed chemistry records for steam generators and primary fresh water cooling systems between January 1983 and September.1985 to ensure that required records were in place, that corrective measures were promptly taken when out-of-specification results were obtained, and that there was a full continuity of samples taken consistent.with frequency requirements. This review identified the concerns discussed below.

The primary fresh water cooling systems chemistry results were recor'ded on Form CHM-508-1,.which is required by CHM-508, " Chemistry Control of the Primary Cooling Systems." Systems under the purview of this procedure are Safety Chill Water, Non-Safety' Chill Water, Diesel Generator Water Jackets, Component Cooling Water, and BTRS Chill Water.

In general, a lack of data entry discipline existed, but with an improving trend, from January 1983 to present.

For example, in many cases sample results were i

not entered, but-there was no exp hnation.

Presumably, the systems were drained or otherwise not available for sampling.

Out-of-specification conditions were not flagged such that the RRI could determine that necessary notifications and corrective actions were implemented.

Specifically, weekly samples were taker: 10 to 12 days apart in November 1983. Sample data entries did not exist in the Records Center for the weeks of March 28, 1983; June 7, 1983; June 14, 1983; June 21, 1983; June 28, 1983; October 3, 1983; December 16, 1983; December 23, 1983; and December 30, 1983.

Steam generator chemistry results for No.1 and No. 2 steam generatocs were reviewed for the period between January 1984 and September 1985.

The data appeared on Form CHM-501-1 which is a requirement of CHA-502,

" Chemistry Control of the Steam Generators." In many cases, out-of-specification results were not flagged as required by CHM-501,to indicate that the shift supervisor was notified and at what time.

Some samples were not taken, but no explanation existed.

As was the case with j

primary cooling systems, the attention to detail expected to be seen on j

1 i

l

. l such records did not appear to exist, even though all the forms were reviewed and approved by supervision.

Specifically, pH for both steam generators was recorded as being out-of-specification low (i.e., as low as 9.0 when a range of 9.8 to 10.5 was required by CHM-501, Attachment 1) from June 20, 1984,through October 8, 1984, with no apparent explanation. When the RRI questioned this, the applicant's representative explained that there had been a considerable amount of discussion between the applicant and Westinghouse and that there had been no urgent need to correct the condition since the steam generators were in cold wet layup.

At the time, the applicant could not produce documentation supporting this information.

The RRI was presented with a copy of Problem Report PR84-361 which was originated on October 5, 1984; over three months after the problem of low pH became known. The report did not identify the pH as having been out of-specification low for over three months, but, rather, stated that the mechanical seals on the recently installed recirculation pumps were leaking, causing carbon dioxide entrainment, which in turn caused a

" depression" of pH in the steam generators. The engineering review did not evaluate the effects of the long-term pH depression on steam generators. The RRI was also presented with Independent Safety Engineering Group Report 84-03, which documented a review of steam generator water chemistry control.

The review included the period when pH was depressed, but stated that, "... Plant chemistry personnel report that the steam generators chemistry sample data is stable and no problem areas have been noted." There was no mention of the pH problem.

The report concluded, ".'.. prompt response to out-of-specification conditions indicate that no significant corrosion related damage has occurred in the Unit 1 steam generators." The applicant was requested to provide the RRI with documented evidence which proves that the quality of the primary and secondary boundaries of the steam generators had not been compromised as a result of over three months out-of-specification low pH.

This is an unresolved item (445/8514-U-01).

The concerns identified above with respect to what appears to be missed chemistry samples, f ailure to indicate when and if the Shift Supervisor was notified as out-of-specification results were obtained, a lack of records to indicate corrective actions taken, and inadequate reviews of data forms constitute a violation of Criterion XVII of Appendix B to 10 CFR Part 50 (445/8514-V-01).

5.

Plant Tours During this reporting period, the SRRI and RRI conducted inspection tours of Unit 1.

In addition to the general housekeeping activities and general cleanliness of the facility, specific attention was given to areas where safety-related equipment was installed and where activities 9 r in progress involving safety-related equipment. These areas were inspecc.d to ensure that

I 1

o-Work.in progress was being-accomplished using approved procedures; L:

=

Special precautions.for protection of equipment were. implemented,.and o'

additionalicleanliness requirements were being adhered.to for maintenance, flushing,.and welding activities;.

o' Installed safety-relatea equipment and components were being protected and maintained.to prevent damage and deterioration.

Also during these tours, the SRRI and RRI reviewed the control room and shift supervisors' log books.

Key items in the log review were:

o plant status,.

o changes in plant status,

.o o

-tests in progress, and documentation of problems which arise during operating shifts.

o I!

No violations or deviations were identified.

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6.

Unresolved Items Unresolved items are matters for which more information is required in order to ascertain whether they are' acceptable items, violations, or deviations.

One unresolved item disclosed during the inspection is discussed-in paragraph 4.

- 7.

Plant Status as of October 31, 1985-

)

Unit No.1 is reported to be 99% complete; however, excavation is a.

underway to facilitate replacement of main condenser internals and a significant amount of rework continues on the control room ceiling.

1 b.

Unit No. 2 is reported to be 77% complete.

The preoperational test program'on systems associated with NRC inspections has_not yet l

started.

q 8.

Exit Interview An exit interview was conducted November 1, 1985, with the applicant representatives identified in paragraph 1 of this appendix.

During this t

interview, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the findings, i

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__________.________________i__

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9 APPENDIX 0 CONSTRUCTION INSPECTION REPORT e

-U.

S. NUCLEAR REGULATORY COMMISSION i

REGION IV 1

NRC Inspection Report:

50-445/85-14 Permit:

CPPR-126 50-446/85-11 CPPR-127 Dockets: 50-445 Category: A2 L'

50-446 Applicant: Texas Utilities Electric Company (TUEC)

+

Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:

Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 Inspection At:

Glen Rose, Texas Inspection Conducted: October 1-31, 1985

/Mh 2-2 Y-W Inspectors:

'H. S. Phillips, Seniof Resident Reactor Dst.e i

Inspector (SRRI), Construction, Region IV CPSES Group (paragraphs 1,2,3,4,5,6,9,10) 1 D AS.

l d

2 h ?b D.L.Telley,SRRI,jUperattions,RegionIV Date CPSES Group (paragraph 8) f Wszw=_

2/22/f4 D. E. Norman, Reactor Inspector Date Region IV CPSES Group (paragraph 7) 1 6 3190517 860306

' h' '

i PDR ADOCK 05000445 G

PDR l'

7-lt 1 Consultants: EG&G - J. H. McCleskey l

Parameter - T. H. Young Reviewed By:

8e J/3/4's i.

1. Barnes, Group Leader, Region IV CPSES Group Date Approved:

7[

3/p/f4 T. F. Westeman, Chief, Region IV CPSES Group Date inspection Summary inspection Conducted: October 1-31, 1985 (Report 50-445/85-14)

Areas inspected:

Routine, unannounced inspections of Unit I which included plant tours, appilcant actions on construction deficiencies, applicant actions on previous NRC inspection findings, and storage and handling of QA records.

The inspection involved 204 inspector-hours onsite by two NRC inspectors and l

two consultants.

Results: Within the four areas inspected, one violation (failure to establish written procedures for control and accountability of the shipment of original design records to Stone & Webster Engineering Corporation (SWEC),

paragraph 5.b) was identified.

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

Areas Inspected:

Routine, announced and unannounced inspections of Unit 2 which included plant tours; applicant actions on construction deficiencies; applicant actions on previous inspection findings; storage, protection, and handling of QA records; audit of QA records; welding material control; and electrical cable tray / equipment walkdown. The inspection involved 227 inspector-hours by three NRC inspectors and two consultants.

Results: Within the seven areas inspected, three violations (a repeat failure to document minimum wall pipe violations on a nonconformance report (NCR),

i paragraph 4.c; a repeat failure to control issue of design documents, paragraph 4.g; failure to establish written procedures for control and accountability of shipment of design records to SWEC, paragraph 5.b) were identified.

i 1

DETAILS 1.

Persons Contacted Applicant Personnel-J. Merritt, Assistant Froject General Manager

'P. Halstead, Manager, Quality Control (QC)

C. Welch, QC Supervisor R. Spangler, Corporate Quality Assurance (QA) Supervisor i

J. Walker, Corporate QA Auditor J. Marshall, Licensing J. Hicks, Licensing M. Strange, Supervising Engineer, Support & Project, TUGC0 Nuclear Engineering (TNE)

J. Ryan, Technical Service, Supervisor S. Ali, THE QA Staff Engineer B. Jones, Unit 2 Supervising Engineer, Civil /btructural R. Hooten, Project Discipline Engineer, Civil / Structural J. Hodgson, Computer Operator Supervisor, PMCS.

Contractor Personnel W. Baker, Welding Engineer, Brown & Root (B&R) 1 W. Wright, Welding Engineer, B&R G. Purdy, Site QA Manager, B&R J. Gore, Subcontract Supervisor, B&R K. Thornton, Warehouse Superintendent, B&R C. Osborne, QA Vault Supervisor, B&R D. Leach, THE-QA-B&R K. Norman, Central Operations Supervisor, DDC-B&R D. Bleeker, DCTG Supervisor, B&R R. C. Iotti,. Project Manager, Ebasco A. Smithey, Supervisor IRV, B&R R. Walters, ASME QA Supervisor, B&R G. Maedgen, Welding Engineer, B&R T. Gray, Document Control Manager P. Patel, Unit 1 Civil Lead, TNE Design, Gibbs & Hill B. Jones, Expediting Supervisor, B&R L. Barnard, PMG File Clerk, B&R T. McCormack, Fire Protection Engineer, Impell S. Felman, Assistant Project Engineer, SWEC.

H. Moscow, Supervisor Projects & Services, NY, SWEC J. Tate, 304 DU Satellite Supervisor, B&R '

J. Junge, 311 DU Satellite Supervisor, B&R J. Womack, 300/301 DU Satellite Supervisor, B&R l

i

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.8 - -}

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i R. Flaherty, 307 DU Satellite Supervisor, B&R i

S. Hazle, 310 DU Satellite Supervisor, B&H J. Day, 308 DU Satellite Supervisor, B&R J. Dickey, DCC Area Supervisor, Engineer Satellites, B&R I

S. Bruce, DCC Area Supervisor, Craft Satellites, B&R 2.

Plant Tours At various times during the inspection period, NRC inspectors conducted j

general tours of the reactor building, safeguards building, and the electrical and control building.

During the tours, the NRC inspector observed ongoing construction work and discussed various subjects with personnel engaged in work activities.

3 No violations or deviations were identified.

I 3.

Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant a.

The applicant's procedures pertaining to Significant Deficiency Analysis Reports (SDARs) were reviewed to determine how the process of deficiency identification through completion and signoff is j

controlled.

Reviews were performed of site Procedures CP-QP-15.6, Revision 3, "SDAR Status Tracking"; CP-QP-16.1, Revision 6, "Significant Construction Deficiencies"; CP-QP-17.0, Revision 1, l

" Corrective Action"; and TUGC0 Procedures DQP-CQ-4, Revision 1,

" Reporting of Significant Deficiencies"; DQP-QA-12, Revision 2, i

" Administration and Tracking of Significant Deficiency Analysis Reports"; and DQP-QA-11, Revision 1, " Corrective Action."

Procedures CP-QP-15.6, CP-QP-16.1, DQP-CQ-4, etnd DQP-QA-12 do not i

address the SDAR file contents or provide a method for completion and signoff of the required corrective action.

Procedures CP-QP-17.0 and DQP-QP-15.6 address the documentation required for closing deficiencies, but there is no cross reference between SDAR/ corrective action with respect to SDAR file contents.

This is an unresolved item pending completion of NRC review of SDAR procedural adequacy (445/8514-U-02; 446/8511-U-01).

b.

The applicant classified the following reportable SDAR files as

" Licensee Action Complete": SDARs CP-84-27, CP-84-29, CP-85-04, CP-85-05, CP-85"11, CP-85-12, CP-85'13, and CP-85-14.

The above files did not document or reference the location of documentation which would support the reported status of corrective actions being i

complete.

Consequently, the NRC inspector did not perform a field verification for any of these files.

c.

The following nonreportable SDAR files were selected for review, s1nce the applicant classified these as " Licensee Action Complete":

1 i

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I (1) (Closed): The NRC inspector reviewed the following 50ARs:

CP-84-05, CP-84-22, CP-84-23, CP-84-24, CP-84-26, CP-84-32, c

f CP-85-02, CP-85-08, and CP-85-09.

The applicant's evaluation j

and decision that these SDARs are not reportable appeared to be Correct.

l (2) (0 pen): The NRC inspector reviewed SDARs CP-84-30, CP-84-34, and CP-85-06.

The files for these SDARs did not contain sufficient information or documentation to determine whether or not the 50AR was nonreportable.

The status of the files is an unresolved item pending the completion of a TUGC0 effort to make the files complete and subsequent NRC review (445/8514-U-03; 446/8511-U-02).

l l

4.

Applicant Action on Previous NRC Inspection Findings a.

(Closed) Unresolved Item (445/8422-U-02): Inverter transformer common failure. The NRC inspector reviewed the applicant's handling of the defective transformers and concluded that the actions taken to evaluate and correct the deficiency were correct and adequate.

The applicant's handling and reporting of significant deficiencies will continue.to be monitored by the NRC inspectors.

b.

(Closed) Violation (445/8307-V-01):

Excessive welding gap. In 1983, the NRC inspector identified an unacceptable fitting on pipe support l

Mark No. SW-1-102-106-Y33K.

Recently, the'NRC inspector followed up and reviewed NCR M5123-5, RPS 751947, WDC80668, related sketches, and inspection reports (irs).

Corrective work was accomplished and QC performed required inspections.

An engineering analysis of the installation which was performed in response to the violation showed strength was far in excess of minimum design requirements, even though it violated the procedure.

In B&R memo -IM 325,208 dated April 13, 1983, supervision reemphasized the requirement to follow procedures to all affected personnel.

c.

(Closed) Violation (445/8315-01): Failure to write an NCR on base metal repair.

This violation concerned an instance where the NRC I

inspector observed a minimum wall violation for which a NCR had not been written. On October 8 and 9, 1985, another NRC inspector reviewed this violation of paragraph 3.3.3 of site Procedure QI-QAP-16.1-2, Revision 4, dated May 20,.1982.

The scope of this procedure was changed to make further reference to system walkdown and the item in question was accomplished near this time frame.

However, the applicant responded by documenting the questioned minimum wa1U violation and the repair of the adjacent weld on a

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common NCR (M6611). These conditions had been found by separate NDE methods, one before and one after the base metal repair. The NRC inspector reviewed two more recent base metal repairs to verify that the problems had been corrected. One repair performed in 1984 was found to have,been in compliance with the then current procedures, j

The second repair was completed, reviewed, accepted, and i

documentation sent to the vault during September'and October of 1985.

This second report showed an original weld completed, reviewed, and

~;

accepted in January and February 1985. Rework was performed on this weld in September 1985 due to interference with a hanger installation which resulted in,a minimum wall violation.

Further work to repair the hanger was classified as a " Major Weld Repair" in accordance with I

paragraph 3.3 of B&R Procedure CP-CPM-6.9G; however, no NCR was i

generated. This failure to document a minimum wall violation on an NCR is a repeat violation of Criterion XV of Appendix B to 10 CFR Part 50(446/8511-V-01).

It was noted that the inspector and the preparer of the repair process sheet had recently received training on the newly revised procedures involved which required the NCR be generated. The Assistant Project Welding Engineer who reviewed the repair process sheet had not been so trained on'the procedure, as he had been exempted from the training by virtue of his position, d.

(Closed) Unresolved Item (446/8502-01): Responsible welding supervisors not familiar with welding rod control procedures.

In 1985, the NRC inspector interviewed supervisors who were not familiar with welding rod control procedures which their crew of welders were l

I responsible for implementing. The training program for supervisors was conducted in May 1985 and covered helpers through general

foremen, l

In 1984/85, the NRC Technical Review Team (TRT) extensively reviewed

]

l and inspected weld rod control and documented their findings in NUREG-0797, Supplemental Safety Evaluation Report (SSER) 10, Category 9.

In addition, the RIV inspector inspected weld rod control during this inspection period and identified no violations or deviations, (Closed)UnresolvedItem(445/8323-07):

Incomplete Class V(5) pipe e.

supports record package.

In 1983, the NRC reviewed packages which had been combined into finalized packages.

In 1984, the TRT reviewed 8) a random sample of 11 Class V(5) support record packages. This review showed that packages with irs (by qualified inspectors) were in proper order. The TRT found the records satisfactory as reported on page N-252 of NUREG-0797, SSER 10 dated April 1985.

f.

(Closed) Unresolved Item '(44578347-01):

Containment surface area coating. This item addren ed sloughing of protective coatings on

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e ga g.

Westinghouse supplied items.

In SSER 9, NRR staff state they have re'hsonable assurance that debris generated by the failure of all coatings inside the containment building under design basis accident conditions will not unacceptably degrade the performance of post-accident fluid systems. This was based on TUGC0 and other studies referenced in NUREG-0797, SSER 9 on pages L-17 and L-18.

NRR 1

gy requires in SSER 9 that a preoperational and postoperational coatings i

program be proposed by TUGCO, but this specific issue of sloughing of j

coatings on Westinghouse items is closed based on the SSER 9 l

conclusions.

j g.

(Closed) Violation (445/8416-V-02): Failure to provide controlled issuance of design documents and changes thereto.

Between May and June 20, 1984, an NRC inspector found that design documents and changes were not controlled by Operations Document Control Center (DCC). On October 11 and 14, 1985, the NRC inspector confirmed that the computer system and terminals referred to in the TUGC0

. November 1, 1984, response were in place and in use.

i.

The NRC inspector reviewed 12 Design Change Authorizations (DCAs) and Component Modification Cards (CMCs) and followed the distribution of 25 packages to 9 locations for various disciplines and verified corrective action. These DCAs and CMCs were traced in their routing at the central DCC and then on to the Paperflow Group or satellite DCCs and a review performed of how they are distributed from those locations.

All items checked were distributed per DCP-3, Revision 18 (with Document Change Notices (DCNs) 1, 2, and 3), with the following exceptions:

I (1) CMC 96181, Revision 1, was issued on October 8, 1985, and satellite DCC 307 (craft) picked it up at central DCC. The CMC was not signed for as required by paragraph 3.1.1.1 of DCP-3, Revision 18, with DCNs 1, 2, and 3.

There was a similar occurrence on CMC 75003, Revision 2, as issued to satellite DCC 202/211 (TUGCO). Further, DCA 21446, Revision 1, was issued October 8,1985, and satellite DCC 307 was in possession of it on October 14, 1985. One of two packages for Drawing 2323-El-1702, Sht 002, Revision 2, had both Revision 0 and Revision 1 of DCA 21446 in it, with the other having only Revision 0 in it.

Both Revision Os were not stamped " VOID" as required in paragraph 3.2.2.5 of DCP-3.

On October 14, 1985, satellite DCC 307 issued Drawing 2323-El-1702, Sht. 002, Revision 2, to an electrician for Class IE field work with Revision 0 of DCA 21446, rather than the current Revision 1, which is contrary to the requirements of paragraph 3.2.1.2 of DCP-3 On October 14, 1985, TUGC0 and B&R supervision contacted the electrician who indicated he had l

tee s.

j l

l

. gotten sheet 002 rather than sheet 001 by mistake and haa returned it immediately without installing anything to it.

These failures to follow design document control procedures are a violation of Criterion V of Appendix B to 10 CFR Part 50 (446/8511-V-02).

(2) The following examples were noted of practices being followed that were not covered in controlled procedures:

(a) The method used tc issue drawing packages from the satellites to the field (e.g., crafts and QC) was not addressed in DCP-3.

The actual practice is that a DCC person and the recipient sign for receipt of all the proper documents (e.g., DCAs) and the proper revisions on the computer printed "Open Design Change Log."

(b) Another practice of the DCC group is to log into the computer the status of the DCAs and CMCs. This status is classifed.as open, void, or not included (NI) and indicates whether e change is affecting all items built to a drawing, J

a single item utilizing the drawing, or no further use of the change.

Drawing 2323-5-0910, Sht. CSR-2A, Revision 12, had' CMC 75003 issued against it.

This CMC had status NI on Revisions 0 and 01 because it affected a single hanger utilizing the above drawing.

However, Revision 02 did not s

have NI input and it showed as open on the terminals.

This would require it to be included with the drawing package in error.

This was corrected on the terminal.

This process T

of statusing the computerized document information is not descrsbed in DCP-3.

DCC supervision stated and showed that the practices are described in internal uncontrolled guidelines.

This item is unresolved'pending incorporating the guidelines into a controlled procedure (44C/8511-U-03).

h.

(Closed) violation (84-08-01): Gms on Unit 1 polar crane bracket and seismic connections.

In November 1964, 6 NRC inspector found that the gaps between the bracket and connectors exceeded the design tolerance. This item is addressed in NUREG-0797, SSER 8, along with related prcolems with polar cranes.

Discussion, conclusions, and actions to be taken are included in pages K-14,15,18 and 121-123 of Appendix X to SSER 8.

Since these actions will address the specific conccens o.f' item 84-08-01, this item'is closed.

5.

QA RecordsJystem Review The N M inspector reviewed the applicant's record keeping e after ascerteNng that records were being shipped off site withs ecper

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. control and inventory.

In Appendix IA(N) and 1A(B) of Final Safety Analysis Report (FSAR) Volume 1, Section 1.0, the applicant commits to Regulatory Guide 1.88 (i.e., Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records) and to American National Standard, Institute (ANSI) N45.2.9, lith Draft, Revision 0, dated January 17, 1973. On page 1A(B)-36 in the Discussion, the applicant makes no exceptions to this standard.

A brief description of QA records is contained in FSAR Section 17.1.17 (Amendment 50 dated July 13,1984). The description does not address the current QA records facilities and storage; i.e., temporary storage of records for the Paper Flow Group, Interim Record Vault (IRV), Permanent Plant Record Vault (PPRV),

procurement records storage area (Warehouse A) and the TUGC0 Records Center.

The applicant has not revised FSAR Section 17.1.17 to describe and reflect the current QA record system. This is unresolved pending the applicant's actions on the item described in paragraph a below (445/8514-U-04; 446/8511-0-04).

a.

Review of Corporate QA Manuals and Implementing Construction Procedure:

The NRC inspector reviewed the TUGC0 Corporate QA Program Manual, Revision 14, dated April 30, 1985, and Quality Assurance Plan, Revision 14, dated August 30, 1984, to determine if ANSI N45.2.9 was referenced and if its requirements were translated into these documents. Only TUGC0 construction Procedure CP-QP-18.4, Revision 5, was found to reference ANSI N45.2.9.

Operations and TUGC0 Nuclear Engineering procedures were not included in the scope of this inspection.

Procedure CP-QP-18.4, Revision 5, does not address all aspects of ANSI N45.2.9 such as (1) definitions; (2) all facility locations; (3) method for maintaining control of and accountability for records removed from the site storage facility to organizations located on or off site; (4) temporary storage facilities (fire rated cabinets versus duplicates in remote, separated locations); and (5) special process records such as photographs, negatives, and microfilm.

The permanent facilities are discussed with respect to ANSI N45.2.9 requirements described in paragraph 5.6; however, the drain system and dry chemical / gas fire protection system is not

?

discussed.

The IRV system is a permanent records vault for Unit 2

~

records until such records can be transferred to the construction PPRV where Unit 1 records are now stored.

TUGC0 Procedure CP-QP-18.6, Revision 3, discusses records turnover from B&R IRV to TUGC0 PPRV but does not address the issues raised above. Also, these issues are not addressed in the B&R QA Manual, Section 17.0 dated October 31, 1984, or CP-QAP-18.1, Revision 3, dated July 11, 1984.

l

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. TUGC0 management stated that all of their QA manuals are in revision to improve their written program. This item is unresolved pending thecompletionofthatreview(445/8514-U-05;446/8511-0-05).

b.

Storage and Transmittal of Design Records to SWEC, New York: On October 16, 1985, an NRC inspector was inspecting an open item previously identified as unresolved item 8226-U-07. As a result, the requalification package for pipe support CC-1-107-008-E23R was requested and the NRC inspector was informed that this design records package had been included in a total of 5702 (4654 for Unit 1, 1048 for Unit 2) hanger packages that had been shipped to SWEC, New York, for a complete reevaluation.

The NRC SRRI interviewed the TUGC0 engineering supervisor who answered questions about whether procedures controlled such shipment, the number of records per package, and how the records were to be protected during shipment. He stated that a first transmittal was controlled by Procedure CP-El-18.0-4, Revision 0, dated July 25, 1985, until Comanche Peak Project Engineering became a part of TNE on September 1, 1985, at which time the procedure was deleted. The SWEC project manager stated that Procedure CPPP-3 covers the receipt and indexing of these packages; however, CPPP-11 that will control the distribution of these packages to SWEC offices at Cherry Hill, New Jersey; Boston, Massachusetts; Denver, Colorado; Houston, Texas; and Toronto, Csnada, will not be completed until late October or early November 1985, according to SWEC Supervisor Project Services, New York. The utility has taken corrective action that includes (1) making duplicate copies prior to shipping, and (2) all records initially sent to SWEC are being copied and a copy returned to the site. Region IV is pursuing with IE Headquarters, QA Branch the 3

minimum protection that should be afforded records in shipment. The 4

failure to have site procedures to maintain control and accountability of the shipment of records is a violation of Criterion V of Appendix B to 10 CFR Part 50 (445/8514-V-02; 446/8511-V-03).

c.

Storage and Transmittal of Construction Records to Chicago Bridge and Iron (CBI): As a result of knowledge of an earlier shipment of CBI records off site, the NRC inspector has asked the utility to orovide

~

records to demonstrate the CBI record controls that were implemented.

It is CBI practice to ship all records off site for copying.

Inis matter is considered unresolved (445/8514-U-06; 446/8511-U-06).

The utility has indicated that the receipt of records from CBI was handled in the same manner as the receipt of records from any vendor.

Region IV will inspect the receipt of vendor records and this matter is considered an open item (445/8514-0-01; 446/8511-0-01).

a

. d.

Inspection of Storage Facilities:

The NRC inspectors visited all site storage facilities to determine if storage, preservation, and safe keeping of records are as required by Criterion XVII of Appendix B to 10 CFR Part 50 and ANSI N45.2.9, Draft 11, Revision 0, paragraph 5, " Storage, Preservation and Safe Keeping." The facilities inspected included TUGC0 Records Center, which is cominitted by the FSAR to ANSI N45.2.9-1974 and not the Draft 11, I

Revision 0 version; PPRV; IRV; Paper flow Group storage areas for Unit 2 mechanical and electrical; and the procurement records storage area. The facilities for the Paper Flow Group and procurement records are not identified or described in TUGC0 or B&R procedures; however, these facilities and the PPRV and IRV were evaluated with the following results:

(1) TUGC0 Records Center - This vault is the final repository for:

(a) Unit 1 records which describe completed construction, and (b) Unit 2 record packages for systems that have been completed and turned over to operations.

This facility was completed about March 1983.

The NRC inspector found that this vault had access control and records were stored in closed conta,ners, open face shelves, or in binders on top of furniture.

Radiographs and other special process records are protected by controlling temperature and humidity.

The NRC inspectors noted that a water sprinkler system had been installed in this facility.

This presents a concern because those plant records which are stored in folders or binders in open faced cabinets will be deluged with water and will likely deteriorate.

An additional consideration is that records stored in a manila folder may be washed out and possibly clog the drain in this facility, leading

,j to flooding of the facility.

This itemJslonsideged unresolved

)I pending applicant review of the facility with respect to the

,.4 above observations (445/8514-U-07; 446/8511-U-07).

2) PPRV - This vault served as'~the sole permanent' vault from approximately 1975 until March 1983.

This permanent records facility has controlled access.

It meets the design features for a permanent facility, as described in Section 17.1.17 of the FSAR; however, the NRC inspector had the following comments:

(a) There is no fire suppression system inside this vault.

Two 1

hand-held extinguishers and a 2-inch fire hose are located outside the vault.

One hand-held extinguisher is locatud

i 1 inside the vault.

Fire detectors and alarms are inside to alert the onsite fire department if a fire occurs, l

(b) If the 2-inch fire hose is used to extinguish a fire, the vault may flood because there are no fire drains and the floor is not sloped. Therefore, water may potentially enter the bottom cabinet drawers.

(c) NCRs and corrective action reports were stored in binders in bookcases.

If fire hoses are use1, these documents would probably be subjected to the 'orce of water from the hose and damaged.

Therefore, it would be desirable to store these records in closed containers.

All other records were stored in nonfire r4ted cabinets which is acceptable if located in a percianent facility that meets ANSI N45.2.9 requirements.

The failure to install a fire suppression system, drains, and a sloped floor appears to be a dev'.ation from ANSI N45.2.9 requirements.

However, this item is unresolved because this facility is described in FSAR Section 17.1.17.

Region IV is forwarding this issue to IE Headquarters, QA Branch for clarification (445/8514-U-08; 446/8511-U-08).

(3) IRV - This area is not a separate building, but is actually part olf the permanent vault that has been set aside as an interim storage area prior to placing records in the area designated for permanent records. This area has an access point that is separate from the permanent area and is controlled.

The facility is the same as the permanent area, except a wall separates the two.

They share the same forced air system.

This facility generally meets the requirements of 10 CFR Part 50, Appendix B, and ANSI N45.2.9; however, the NRC inspector had the following comments:

(a) Water had been leaking through the forced air system and beside a support girder.

In a second location, approximately 2-3 gallons of water had leaked in through the forced air ventilation duct and was caught by a container placed under the duct. This is considered an open item (445/8514-0-02; 446/8511-0-02),

(b) The NRC inspector observed a coffee pot, sugar, and evidence of food on a table adjacent to the vault area.

b-These were immediately removed from the vault by the utility.

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. () Paper Flow Groups - The NRC inspectors visited trailers.where the electrical and mechanical Paper Flow Groups are located to determine if QA records are stored there.

(

In SSER No. 11, the TRT considered the documents in the paper flow groups to be inproceu.; however, SSER No. 11 also indicated that the records are maintained in fire proof cabinets. The NRC inspectors found that there are some records stored in

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nonfire-rated file cabinets. This matter is considered unresolved (445/8514-U-09; 446/8511-U-09).

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(5) Storace of Procurement Records - In Warehouse A, procurement recorc s were stored both in nonfire-rated and fire-rated L

cabinets. The NRC. inspector found no master index of these records and the facility is not described in the FSAR or procedures. There was no way to determine whether duplicates of these records exist and if they must be stored in fire-rated cabinets. This item is unresolved pending identification and j

description of this facility and indexing of records recently received from the TUGCO, Dallas, Texas, office to determine what records must be in fire-rated cabinets (445/8514-U-10),

i 446/8511-0-10).

6.

Audit of QA Record Systems / Facilities The NRC inspector asked if the unacceptable QA records storage and control conditions identified above in paragraphs 5.a and 5.d had been identified by TUGC0 or B&R audits. TUGC0 audited (TCP-85-20 dated January 16, 1985) the PPRV but failed to identify any of the problems noted above. Two auditors audited this area from December 17 through December 20, 1984, and their report did not identify any storage facility problems.

ANSI N45.2.9 requires that periodic audits shall be performed to assure facilities are

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in good condition and temperature / humidity controls and protective devices are functioning properly.

An Ebasco review or study dated June 16,1981, page 4 of 25, item g, states with respect to the PPRV, "It is an established fact that the QAR vault does not meet the requirements for a single storage facility and that duplicate files are not maintained in lieu of single storage." On October 23, 1985, the NRC inspector requested documentation which would chow action taken in response to the Ebasco finding. TUGCO's Project and QC organizations had no such documentation.

This item is unresolved N nding review of the response to this audit finding (445/8514-U-11; i

446/8511-U-11).

The NRC inspector asked PPRV personnel if B&R had audited

@ record keeping / facility system and was informed that it has been uveral years since B&R had performed such audits.

This item is F,,".91ved pending the review of B&R audits (445/8514-U-12; M/G511-U-12).

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Control of Weld Filler Material This inspection was performed to determine whether safety-related weld filler material purchase, storage, and distribution are in accordance with the applicant's work and QA procedures, and applicable ASME code requirements.

Implementation of the following procedures was examined during the inspection:

CP-QAP-8.1, Revision 9, dated October 15, 1984, " Receiving Inspection";

CP-CPM-6.98, Revision 2, dated September 21, 1984, " Weld Filler Material Control"; and CP-CPM 8.1, Revision 3, dated July 2,1985, " Receipt, Storrge, and Issuance of Items."

The folicwing areas were examined:

a.

Procurement:

Four purchase order packages which consisted of the purchase order, procurement specification, and field requisitions were inspected to verify that orders were properly approved and included required technical, packaging, and documentation requirements as specified in site procedures pertaining to weld filler material purchases.

No violations or deviations were identified.

b.

Receiving Inspection:

Receiving inspection records, for the filler material purchased to the procurement documents inspected, were examined to verify that all items required by Attachment 11 (Receiving Checklist) to CP-QAP-8.1 had been inspected.

In each case, the checklist and a receiving inspection report had been completed and signed by a Level II QC inspector.

In several instances, NCRs had been completed and material returned to the vendor as required by procedures. Certified Material Test Reports (CMTRs) for each purchase were also reviewed to verify that required inspections and tests had been performed and that material had been purchased from a vendor with a current ASME certification.

It was also verified that heat codes and quantities of material shown on the Material Receiving Reports corresponded to what was shown on the CMTR.

No violations or deviations were identified, c.

Main Storage Areas:

Two filler material storage areas located in Warehouse S '!are inspected for compliance with the above listed procederns One area was designated as a Quality (Q) area and the

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other.one was b9th a'.Q and'Non-Q area. The Non-Q material was

~ segregated as required from the Q material.- Procedures in the

-storage areas ~ appeared to be adequately. implemented;.however, the NRC had the following observation:-

Paragraph 3.2.1 of CP-CPM 6.9B requires that Q weld filler material original containers.be marked upon receipt and during storage with the material classification, size,. and heat / lot number.- In the Q area, labels on several containers of Sandvik welding products (weld rod) had fallen off and others were loose. 'The material was still identifiable, because of the storage bin marking,and marking on the shipping carton; however..a loss of identification is possible when material is removed from the storage area. There were also several unopened cartons of Sandvik material whose' status could not be determined. ' Loose or missing labels were identified on the following material; Lot 101172-2, 1/8 inch, AWS/ASME SFA 5.4; and Lot 10149-1, 5/32 inch AWS/ASME SFA 5.4.

This matter has been referred to B&R Welding Engineering for followup.

d.

Distribution Stations: Weld rods used in, safety-related applications i

are distributed from three areas (Rodhouse 2, 3, and 4).

Each distribution' station was inspected to verify compliance with requirements of CP-CPM 6.9B in the following areas:

Storage facility (Level B);

Identification of material; Controlled access into storage areas; Control of stationary and portable rod ovens; Issuance, return, and accountability of material; and

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. Completion and control of records.

Label problems were also noted in Rodhouse 4 during this inspection.

8.

Cable Tray and Equipment Walkdown During this inspection period, the NRC inspector performed a walkdown inspection of selected electrical components and cables to determine the degree of protection of class IE items from surrounding construction activities. The general level of protection appears adequate with the exception of the B Safety Train Diesel engine control panel (2DG02A). The visqueen covering had come loose in several spots allowing concrete dust from above to filter into the,nnel and settle on some of the installed relays.

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. In the area of cables, it was noted that cable ends were neatly' coiled and the ends taped, cable tags were in place and cable jacket repairs were clearly marked. At.one point in the Safety Train B switchgear room, a cable. exiting a tray and entering the switchgear (cable No. C23G 06070 above the HVAC chiller No.14.) appeared to be bearing hard on the square section of the cable tray-side ladder at its exit point.

In other places where cable exits tray, a piece of discarded cable jacket is.used as a buffer. The observed point had no such buffer.

No violations or deviations were indentified.

9.

UnresobedItems Unresolved-items are matters for which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.

Twelve unresolved items disclosed during the inspection are

' discussed in paragraphs 3.a, 3.c, 4.g, 5, 5.a, 5.c, 5.d, and 6.

10.

Exit Interview An exit interview was conducted November 1, 1985, with the applicant representatives identified in paragraph 1 of Appendix E.

During this interview, the NRC inspectors summarized the scope and findings of the inspection.

The applicant' acknowledged the findings.

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APPENDIX E U. S. NUCLEAR ~ REGULATORY COMMISSION REGION IV COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT NRC Inspection Report: 50-445/85-14 Permit: CPPR-126 446/85-11 CPPR-1;!7 Dockets:

50-445 Category: A2 50-446 Applicant:

Texas Utilities Electric Company Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:

Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 I

l Inspection At:

Glen Rose, Texas Inspection Condu t' d: October 1-31, 1985

[

d Inspectors:

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L. E. Ellershaw, Reactor Inspector, Region IV

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

T S

T C. J. @,' Reactor Inspector, Region IV CPSES D6te ~ ~

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

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~5/7/6 G-A. R. Johnson, Reactor Inspector, Region IV Date CPSES Group

.(paragraphs 1, 6.a, 7.a-7.e) l Consultants:

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

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Parameter - J. Birmingham, D. Brown, J. Gibson, K. Graham, D. Jew, Reviewed By:

8-so 3/7/#6 I. Barnes, Group Leader, Region IV CPSES Group Date Approved:

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"VJ /F6 T. F. Westerman, Chief, Region IV CPSES Group Date '

Inspection Summars Inspection Conducted: October 1-31, 1985 (Report 50-445/85-14: 50-446/85-1D Areas Inspected:

Nonroutine, unannounced inspection of applicant actions on previous inspection findings, followup on alleged contractor improprieties, Comanche Peak Response Team (CPRT) procedures and instructions, and CPRT issue

- 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 provideo in paragraph 4.

Results: Within the four areas inspected, two violations (revision of drawings without required review and approval actions, paragraph 2.a; signing of 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 package, paragraph 8.c; and inspection 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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DETAILS 1.

Persons Contacted D. L. Andrews, TUSI Director of Corporate Security J. Arros, TERA Civil / Structural Issue Coordinator C. I. Br wne, Project Manager, R. L. Cloud & Associates, Inc.

  • R. E. Camp, Assistant Froject General Manager, Unit 1 (Impe11 Corp.)

J. Finneran, TUGC0 Lead Pipe Support Engineer

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

Corp.)

  • J. B. George, TUGC0 Vice President, Plant Seneral Manager
  • P. E. Halstead, TUGC0 Site QC Manager J. L. Hansel, ERC QA/QC Review Team Leader C. K. Moehlman, TUGC0 Project Mechanical Engineer
  • C. Killough, TUGC0 Supervisor, Operations Quality M. Obert, ERC TRT Issue Coordinator A. Patterson, ERC Engineering Supervisor C. Spinks, ERC Inspection Supervisor
  • T. G. Tyler, TUGC0 CPRT Program Director
  • C. H. Welch, TUGC0 QC Services Supervisor R Werner, Manager, Safeteam
  • P. B. Stevens, TUGC0 Project Electrical Engineer G. Benfer, Bahnson Services Co. Site QA Manager D. W. Snow, Brown & Root (B&R) QA/QC Coordinator T. Wright, TUGC0 civil Engineer
  • G. W. Ross, ERC Onsite QA Representative J. Adam, ERC Supervisor, Safety Significance Evaluation Group D. M. Kim, Principal Mechanical Engineer, Gibbs & Hill (G&H)

T. Brandt, TUGC0 Quality Engineering Supervisor J. R. Honekamp, TRT Issues Manager, TERA P. Turi, TERA Issue Coordinator G. Purdy, B&R QA Manager J. E. Young, ERC Issue Coordinator J. R. Gelzer, ERC Issue Coordinator S. L. Crawford, ERC Issue Coordinator P. Thomas, ERC Supervisor, Inspection Group Services D. Alexander, ERC Supervisor, Hardware Issues P. Amoroso, ERC Supervisor, Hardware Collective Evaluation R. Melton, TERA Documentation Coordinator J. Ma11anda, CPRT Electrical Review Team Leader

  • Denotes those persons who attended the exit interview.

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The NRC inspectors also contacted other CPRT and applicant employees during this inspection period.

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Applicant Actions on Previous Inspection Findings a.

-(0 pen) Open Item (445/8511-0-04): This item remains open pending the review and assessment of the dispositions relating to the 12 deviating skewed welds in NF supports.

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

in the NRC's identification of a violation.

During ERC's reinspection of skewed welds in Unit 1, undersize 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, 1

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 drawing.

The NCRs 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 revised by TUGC0 Nuclear Engineering (TNC) 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 TNE 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 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 THE 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):

Provisions for familiarizing QC i

inspectors with changes in QC inspection procedures.

Details on this subject are contained in paragraph 7.d'of this appendix.

l 3.

Followup On Alleged Contractor Improprieties The NRC inspectnr 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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improprieties,'if substantiated, could adversely affect safety-related components'and systems. NRC review of this subject' revealed that the alleged improprieties,'which consisted of eight specific items, had been i

I reviewed by the_TUGC0 Safeteam and by the'TUSI Director of Corporate Security. NRC examination of the items, certain of which were i

substantiated, resulted in a' determination that~there was no' instance.

i where 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

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a.

'NRR:

A site inspection:was performed during' October 10-11, 1985, l

jiiftainingtocivil/structuralissues. Audits were performed on October 25, 1985, at Ebasco and Stone and Webster, New York, j

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.

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IE:

An inspection of. Design Adequacy Redew was initiated at TERA,.

Fethesda, Maryland, during October.28 through November 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.

Implementation of ERC Procedures and Instructions (1) Audit of CPP-012 (OA/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 different process, as defined

~in CPP-012.

1 (a) Written requests for equipment and services are used by the QA/QC inspec. tors to request from TUGC0 or.B&R any equipment i,

or services needed to perform an inspection. These requests are included in the completed inspection package.

An NRC inspection of CPP-012 implementation showed that the requests for equipment and services were being processed in l

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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 the QA/QC L

Records Administrator.

This item is an NRC deviation.

1 (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 maintained by the QA/QC Inspection Supervisor, as required by Section 5.1.3 of CPP-012.. Subsequent to this report period, the NRC was informed by ERC management that this understanding was incorrect and that the required log was, in fact, being maintained in accordance with CPP-012 requirements.

L Followup. inspection confirmed that the ERC management 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 contrary 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 l

to deviation 445/8514-0-01.

(b) Document requests are used to request copies of TUGC0 or B&R 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 liaisen engineer by the QA/QC Records Administrator, who also logs atid files the-requests. The logged 4 tem is closed and the request filed when the information arrives from the TUGC0 liaison engineer. Two specific requests were traced by the NRC inspector through the Construction Sampling Reinspection Engineering Group and Records Administration, and found to have been satisfactorily processed and routed.

No NRC deviations were identified.

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' 1-(2) CPP-018(QA/QC Interface with the Design Adequacy Program)

An NRC inspection confirmed that documents transmitted from ERC -

to TERA for information only were transmitted by the QA/QC Records Administrator.

Documents requiring feedback from TERA are logged and transmitted by the ERC Hardware Issues Supervisor.

The TERA Design Adequacy Program Interface Coordinator receives the ERC documents, distributes them and files one copy.

Items requiring feedback to ERC are logged in and the date of reply is also logged. The NRC inspector selected four documents from the ERC log and was able to satisfactorily trace them through the-ERC and TERA logging and filing. systems.

No NRC deviations were identified.

(3) CPP-010 (Preparation of Deviation Reports) and CPP-016 (Safety Significance Evaluations of Deviation Reports)

Deviation Reports (DRs) are generated during the hardware and documentation inspection process. These DRs are assessed for validity then forwarded for further processing to the Safety Significance Evaluation Group (SSEG) and TUGCO.

The NRC inspector confirmed that the process, which is described in CPP-010 and CPP-016, is being followed.

A sample of twenty DRs was selected from the SSEG tracking system.

Each DR was verified to be correctly processed and documented by checking each for: (a) signatures of originator, first reviewer, and second reviewer; (b) transmission of the DR to TUGC0 and SSEG, (c) transmission of the DR to the proper distribution; (d) filing of the DR in the verification package; and (e) confirmation from TUGC0 or B&R that they had assigned an NCR number to the DR. Revision 3 to CPP-010, which was released on October 11, 1985, incorporates provisions for revision, cancellation, or invalidation of a DR.

i No NRC deviations were identified.

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

Review team personnel are instructed in CPP-020 to report apparent out-of-scope observations by three part memorandum to TUGCO.

In the NRC inspection of this subject, it was determined that tne ERC Supervisor, Hardware Collective Evaluation, assigned a serial number on receipt of the three-part memorandum and sent.two of the copies to TUGCO.

The remaining copy is filf

'sid' logged, with identification made of the record j

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, receiving date, date.sent'to TUGCO, and date_of TUGC0 feedback.

Six memoranda were reviewed by the NRC inspector to verify implementation of.this. process.

No NRC deviations were identified..

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

-l ERC-QA-18 (Administration of Quality Assurance Auditing), and ERC-QA-20 (Conduct of Programmatic Audits)

The ERC Project Assurance Mana'ger was contacted in an NRC inspection of these procedures..The following documents were produced:

(a) surveillance plan for QA/QC Review Team dated September 14,-1985;.(b) surveillance status report. dated

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

The Project Assurance Manager maintains an active file and status log of'surveillcoce reports from the planning stage until the recommendations are implemented.

The surveillance reports are distributed to the corporate' office, to the QA/QC Review Team Leader (RTL), the Hardware Issues Supervisor, and the.

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 Administrator.

The NRC inspector reviewed fou,r 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 report, and a surveillance checklist.

No NRC deviations were identified.

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 corporate audit identified one deficiency.

A response to the audit was issued on October 21, 1985, providing corrective / preventive actions. The second quarterly audit is being planned at this time, but a specific date has not been set.

No NRC deviations were identified.

b.

TERA Procedures and Instructions l

TERA has issued 16 of the 19 planned design adequacy procedures l

(DAPs).

Review of these m n dures indicates that six apply, in l

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wIoleorpart,totheISAPsdefiningTERAonsiteactivity (civil-structural, mechanical, and miscellaneous). These are DAP-2,

" Documentation and Tracking of. Issues and Discrepancies"; DAP-14, i

" Design Adequacy Program Records"; DAP-15, " Training and i

Qualification"; DtP-16, " Audits"; DAP-17, " Corrective Actions"; and DAP-19, " Processing and Review of Information Between Quality of Construction,-QA/QC Adequacy Program and Design Adequacy Program."

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.

The NRC has inspected the implementation in this area and the results of implementation of DAP-2 is reported in NRC Inspection Report No. 50-445/85-13; 50-446/85-09.

DAP-16 and DAP-17 are applicable to the onsite TERA effort; however, these procedures are implemented by offsite personnel reporting to the Design Adequacy Program Quality Assurance Manager.

This offsite TERA activity is being inspected and reported by the NRC Office of Inspection and Enforcement.

DAP-19 applies to the information interfaces between the Design Adequacy Program and ERC Quality of Construction and QA/QC Adequacy i

Program groups.

This DAP was audited by the NRC inspector in conjunction with the implementation audit of ERC Procedure CPP-018, as described in paragraph 5.a.(5) above.

1 No NRC deviations were identified.

c.

Implementation of CPRT Policies and Guidelines (1) Electrical Issues:

The electrical issues in the ISAPs are the responsibility of one RTL The CPRT Policies and Guidelines establish the methods for accomplishing these tasks.

The purpose of the NRC inspection was to determine if the processing of the electrical issues complied with the requirements set by the CPRT Policies and Guidelines. The inspection covered four of the guidelines; i.e., (a) central and working files, (b) safety significance evaluations (SSEs),

(c) developing sampling plans and random samples for TRT issues, and (d) policy on testing and inspection personnel used in third party verification activities.

This report completes the NRC's initial inspection of programmatic implementation in the area of

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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 guidelines. A file index is available for each ISAP which defines the contents of each file folder. A computer based data system is being established for these files.

Two files were checked for compliance with the CPRT Policies

.and Guidelines.

No NRC deviations were identified.

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

E I.b.1 that resulted in one item which will require a i

SSE. This SSE will be included in the' review process for all SSEs generated by the CPRT.

No NRC deviations were identified.

(c) Sampling Plan: The sampling plan used on ISAP No. I.a.1 was reviewed by the NRC inspector.

It complied with the guidelines and was well documented.

Inspection confirmed i

that the information on the random sampling selection was I

turned over to ERC, who prepared the inspection packages, performed the inspections, wrote inspection reports (Iks) j for satisfactory and unsatisfactory conditions, and after i

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 writ, ten by TUGC0 on those where l

discrepancies existed.

Memoranda were sent explaining why each of the remainder were not considered as discrepancies.

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The NRC inspector also reviewed implementation of the random sampling system used for ISAP Nos. I.a.2 and I.a.3.

No NRC deviations were identified, l

(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:

(i) experience and knowledge in i

the review subject matter (ii) experience in managing technical projects and reviews, and (iii) integrity and objectivity based on lack of previous involvement in the CPSES project activities.

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j The resumes and signed objectivity statements for the principal individuals involved in the electrical issues were reviewed.

No NRC deviations were identified.

4 (2) Testina Issues:

The purpose of the NRC inspection was to determine if the disposition of testing concerns complied with

.l the CPRT Policies and Gt M 11nes. 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 the file for these files.

No NRC deviations were identifigd.

(b) SSE:

One DR has been written and an SSE completed.

The hTC inspector reviewed the processing of this OR.

No NRC deviations were identified.

(c) Samplina Plan:

The sampling plan described in the program plan was not found to be feasible, so en alternate plan was developed. This revised plan was described in an appendix to the results report.

This practice is permitted by Appendix D of the CPRT Program Plan.

No NRC deviations were identified during a review of the original and revised sampling plans.

(d) Personnel Requirements: The resumes and signed objectivity statements for the RTL and each of the three issue coordinators were reviewed.

No additional NRC deviations to that noted in NRC Inspection Report No. 50-445/85-11, 50-446/85-06 were identified.

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6.

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

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

{

a.

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; l

(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 l

unsatisfactory, either by physical inspection or as a result of i

being undocumented; i

(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 i

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 i

The NRC inspe'ctor is continuing to review CPRT ISAP Nos.I.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 check of as-built drawings for 257 1 1/2-inch and 2-inch conduit runs in the combined random and i

I 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 j

all runs in the random sample and for 128 runs in the engineered j

sample.

Fifteen conduit runs have been identified, to date, as having the potential for interaction with safety-related components.

TUGC0 has initiated a dynamic test program at Corporate Consulting and Development (CCL) in North Carolina. The dynamic testing will l

provide actual strengths as compared to the previously used predicted values. TUGC0 will also conduct a damage study walkdown of all conduit runs currently determined to have potential interactions with safety-related components.

Evaluation of potential interactions for safety significance will utilize preestablished criteria to be specified in a walkdown procedure. This procedure is currently being prepared by Ebasco.

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.

QC Inspector Qualifications (ISAP No. I.d.1) c.

Status of CPRT Activity Phase 11 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 placed into Phase III.

Package preparation is complete for an eighth inspector.

I Status of NRC Inspection Activity During this reporting period, the NRC inspector witnessed 24 Phase III reinspection conducted by ERC inspectors and also performed 10 reinspection independent of ERC personnel.

No deficiencies were identified in these reinspection by either ERC inspectors or the NRC inspector.

?.

. -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 Personnel." 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 certification 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.S.

This issue was previously included in ISAP No. I.d.2.

RatusofNRCInspectionActivity t

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 Ty>es of Skewed Welds in NF Supports i

(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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. St tus of NRC Inspection Activity i

i:

The NRC inspector. witnessed a total of nine reinspection and performed three independent inspections of NF supports containing type 2 skewed welds. The results of NRC' Region I. inspections of skewed welds are documented in NRC. Inspection Report No. 50-445/85-13; 50-446/85-09. The planned NRC physical inspections for.this ISAP have now-been completed.

NRC evaluation of TUGCO's dispositions of 12' undersize type 2 skewed field welds is dependent upon the processing of the associated NCRs. This remains an open item (445/8511-0-04).

One violation was identified in this subject area which.is identified L

in paragraph 2.a of this-appendix.

f.

Plua Welds (ISAP No; V.'d)

Status of CPRT Activity

.i i

Reinspection has been completed for the presence of plug walds-in two random samples of cable tray hangers, consisting of 60 from Unit 1 and 61 from Unit 2. The reinspection resulted in the identification i

of-23 plug welds in 14 cable tray hangers.

Documentation was reviewed for all cable tray hangers containing plug welds. The results of this review showed that all of the plug welds were 3

authorized and documented.

Due to a mix of non-ASME component supports with ASME Section III'NF component supports in the two original i

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

]

Report No. 50-445/85-13,50-446/85-09), a new random sample of 57 NF component supports has been created and reinspection has been initiated.

Status of NRC Inspection Activity The NRC inspector witnessed 23 reinspection and performed 6 independent inspections of cable tray hangers.

With respect to NF component supports, the NRC inspector has witnessed a total of 23 reinspection and performed a total of 4 independent inspections.

Eight of the witnessed reinspection and one independent inspection occurred in this report period and were from the new random sample.

i Indications of possible plug welds were identified in two component support base plates during the witnessed inspections. The NRC inspector will witness the macroetching and inspection of these baseplates to determine whether or not plug welds exist.

No NRC violations or deviations were identified.

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g.

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

Status of CPRT Activity The specific engineering investigation of the main steam line installation is complete and is undergoing review.

The report i

describing the analytical evaluation of stresses and support load changes has been issued by R. L. Cloud & Associates (RLCA) and has been reviewed by TERA.

Review and revision of pipe procedures for pipe erection 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 NRCLInspection 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 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.

t (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 on 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.

a s

. 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 of the reinspection 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 reinspection indicate that data on material traceability in areas l

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 f

(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 l

the procedural controls to determine if requirements of I

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

l 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 effectiveness 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 been investigated.

The 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.

Therefore, no revision to this procedure is being made Comments on the adequacy of the number of swipes made will be in '.,he results report.

Specific TRT concern o'tPt of protective covering on equipment near welding activities wil N aidressed by reviewing the results of plant surveys.

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Status of NRC Inspection Activity L

l L

The NRC inspector has witnessed plant surveys'of the safeguards j

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

1 f

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

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

These items were noted by TUGC0 and ERC personnel.

An independent I

/

l-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 A second reinspection of seven Borg-Warner (B-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 reinspection are now complete.

Of a total of four valid DRs issued for this ISAP, three SSEs have been completed. The fourth DR J

(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 temperature as 250 F and the design pressure as 300 psi, while the correspondingWestinghousedgsigntemperatureandpressureare listed, respectively, as 150 F and 150 psi.

The NRC inspector was informed by the % E engineer that disposition of the remaining SSE is pending rece:

of information from TUGC0 regarding valve temperature / pressure

'ings and TUGC0 resolution of the above described difference in der conditions.

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_______._---,______u

u l' Status of NRC Inspection Activity.

A total of'eight reinspection 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 cnd Westinghouse design conditions had also been identified by TUGCO, and (2) e 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.

Ths 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 n1 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 i

/

a.

Electrical Cable Status of CPRT Activity 6

ERC has completed 85 reinspection and 71 documentation reviews of sampled electrical cable as of October 30, 1985.

Status of NRC Inspection Activity (1) The following eight ERC reinspection of sampled electrical cable were witnessed by the NRC during this report period:

Verification Package No.

Cable No.

I-E-CABL-078 EG113536 I-E-CABL-084 EG104608 s

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J 72q-I-E CABL-086 E01218162 I-E-CABL-088 E0124088 I-E-CABL-089 EG123639Z v.

I-E-CAB L-098 E0145694 '

T4 I-E-CABL-101 E0122951 1-E-CABL-102 1

EG139519 y

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(2) During the aboie reinspehtions,' ERC identified the following conditions to the NRC'Gsysctor as subject to. evaluation as potential deviations:

'(a) I-E-CABL-037: Two through-thr wall sleeves had identical identification tag number TWS-E-010.

The cable run also deviated from the cable run' schedule.

A (b) I-E-CABL-084:

Cable rLh deviated from the cable run schedule and cable was'r'c'uted through C13G06325 instead of C13G06324.

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-(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:

j 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).

l (4) NRC inspectors did not identify any additional discrepancies with redect to the above eight packages.

(5) Independent documentation reviews were performed of 10 verification packages comprising 22 cables.

The results of the independent reviews are an open item pending NRC review of ERC results (44E/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 TUGC0 and will be evaluated further in a subsequent report (445/8514-U-16).

b.

Cable Trays Status of CPRT Activity ERC has completed 84 reinspection and 78 documentation reviews of sampled cable trays as of October 30, 1985.

Status of NRC Inspection Activity (1) The following two ERC reinspection of sampled cable trays were witnessed by the NRC in this report period:

Verification Package No.

Cable Tray No.

I-E-CATY-201 T2205BC89 I-E-CATY-247 TBGCCM62 No deficiencies were noted by ERC or NRC inspectors during these inspections.

l (2) The NRC performed independent reinspection 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 f

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).

No NRC violations or deviations were identified.

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~22-c, Electrical Conduit Status of CPRT Activity ERC has completed 79 reinspection and 76 documentation reviews of sampled electrical conduit as of October 30, 1985.

Status of NRC Inspection Activity (1) The following two ERC reinspection of sampled electrical conduit were witnessed by the NRC in this reporting period:

ic Verification Package No.

Conduit No.

I-E-CDUT-089 C13G07757 I-E-CDUT-098 C12020693 No deficiencies were noted by ERC or NRC inspectors during these iiispections.

(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-CDUT-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-CDUT-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 sn independent documentation review of i

this field witnessed activity and noted that the TUGC0 electr hal 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 inspsetion personnel be certified

1 l

l l l for a given inspection function / activity as being qualified i

to perform their assigned tasks. The lack of certification of the TUGC0 electrical inspector performing-the inspection of record for conduit EAB1-1 is a violetion (445/8514-V-04).

(b) ISAP No. VII.c requires original documentation review for attributes deemed to be inaccessible. A portion of conduit-C13916037 was found to be inaccessible during reinspection as a result of'being covered with separation barrier material (SBM). There was no ev.dence in ERC's Verification Package No. R-E-CDUT-064 that a check was made for attributes which were not accessible due to SBM installation. This is an NRC deviation (445/8514-0-02).

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

requires the reviewer to record the SBh 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 ifem 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-00VT-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-D-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 inspect conduit for separation after 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 availaole 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).

i i

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I (f) The NRC inspector observed during documenta'. ion 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, EEB4-10505-8904, 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 reviews will be reported in a subsequent report after comparison of NRC review results with the completed ERC results. This is an open item (445/8514-0-10).

(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 reinspection and 19 documentation reviews of sampled electrical equipment installations as of October 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 previously 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 by the NRC:

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- _ _ _ _ ~. _ _ _ _ _ _, _ _. _ _ _

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. Verification Package 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 sampled electrical equipment installation. The results of this review are an open item pending comparison with ERC results when available (445/8514-0-12).

No NRC violations or deviations were identified.

e.

Instrumentation Equipment Installation Status of'CPRT Activity ERC has completed 75 reinspection and 75 documentation reviews of sampled instrumentation equipment installations as of October 30, 1985.

. Status of NRC Inspection Activity (1) To date, eight reinspection have been witnessed by NRC inspectors with the following five reinspection witnessed in this report period:

Verification fackage No.

Unit No.

I-E-ININ-072 1

1-E-ININ-079 1

I-E-ININ-069 1

I-E-ININ-076 1

1-E-ININ-066 1

(2) During the above reinspection, 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) Orawing 2323-M1-2613, Revision 2, shows instrument

' PS-4251 as being located 6 feet 0 inches off the wall.

?

. This instrument was actually located 5 feet 0 inches off the wall.

I-E-ININ-079:

The tubing line from the component cooling water pump 1A to instrument 1-PT-4520 had reverse slope where it passed under the discharge line.

I-E-ININ-066:

Required color code was missing and maximum allowable distance between color code marks was exceeded.

I-E-ININ-069:

Sending units 1-LS-6712 and 1-LS-6717 were found to be reversed.

Dispositions of the above findings are open items (445/8514-0-13 through 445/8514-0-16).

No NRC violations or deviations were identified.

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

I-E-ININ-079: 01413591 was damaged at the connection to the instrument 1-PT-4520.

Disposition of the above finding is an open item (445/8514-0-17).

No NRC violations or deviations were identified.

(4) The following independent documentation reviews of sampled instrumentation equipment installations were made by the NRC inspectors:

Verification Package No.

Instrument No.

R-E-ININ-005 1-LS-4795 R-E-ININ-060 1-LS-3376 (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 instrument installations. According to paragraph 4.1 of ISAP No. VI).c, Revision 0, documentation reviews will be I

utilized to supplement reinspection for attributes which are nonrecreatchie or inaccessible.

Paragraph 4.1.3 of the same ISAP requires procedures to have detailed instructions

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I '

4 for the document reviewers. QI-013, Revision 4, "Docume'ntation 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 i

vary between different revisions of a procedure. As an example, Revision 1 of QI-QP-11.8-8 adds to Revision 0 l

requirements an inspection checklist addressing verification j

of: (i) color codes for nuts; (ii) flange face cleanliness; 1

(iii) gasket size, rating, and material type; (iv) nuts being tightened in a diametrically opposite sequence; (v) studs being the same 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).

i (b)

In the review of Verification Package No. R-E-ININ-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 reinspection were performed by the NRC inspector on Verification Package Hos. 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 identify that: (a) required color coding on six sections was missing, (b) incorrect slope was present, and (c) an incorrect air gap condition was present.

The failure of ERC inspectors to identify the above conditions is an NRC deviation (445/8514-D-04).

  • l f.

HVAC Ducts and Plenums Status of CPRT Activity As of October 25, 1985, reinspection have been completed for 62 of 95 random items in the HVAC ducts and plenums samples. The I

i I

'O reinspection have identified conditions which necessitated the l

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

Twelve DRs have l

been evaluated by ERC and were found to be nonsafety significant.

A i

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, j

lock washers not installed on vent lock mounting screws, deteriorating

)

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

l

\\

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, eight reinspection 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 Packaae No.

Unit No.

I-M-DUPL-021 1

l I-M-DUPL-073 1

I-M-DUPL-084 2

I-M-DUPL-086 1

(2) During the above reinspection, 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 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.

. 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 445/9514-0-20).

(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 reinspection, the ERC inspector did not r.easure 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 5,tatus of CPRT Activity As of October 25, 1985, reinspection have been completed for 38 of 89 random items in the HVAC equipment installation samples.

The reinspection have identified conditions which necessitated the issuance of 68 DRs, none of which have been currently validated.

Reinspection was on hold for approximately one week, pending a change notice to QI-023, Revision 0.

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 method of certification of gravity damper counterweight balance.

Previously reinspected items will require a followup reinspection, where applicable, as a result of this revision.

The NRC inspector was informed by the population engineer that the HVAC equipment installation plan will be revised to incorporate two distinct populations, each requiring a minimum sample size of 60.

One population will include all HVAC equipment installed by Bahnson Services, Inc., while the others will include all HVAC equipment installed by B&R.

This change will not necessarily invalidate any

1, :

1

\\

i I reinspection conducted to date, but could effectively double the l

total number of items to be reinspected in the initial sample, i

Status of NRC Inspection Activity (1) As of October 25, 1985, a total of four reinspection 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 reinspection, ERC identified the following conditions to the NRC inspector as subject to evaluation 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 outlet duct connection gaskets had low and uneven compression, (b) diameters for foundation anchor bolts and duct connection bolts were illegible in drawings provided in the inspection package, and (c) exhaust duct connection bolts did not have full thread engagement with nuts.

I-M-HVIN-043 (Motor Operated Damper):

(a) A nameplate was not obterved on the equipment, and (b) the actuator spring could not be located which is required for verification of fail closed or fail open positions.

I Dispositions of the above findings are open items (445/8514-0-22, 446/8511-0-04, 445/8514-0-23 and 445/8514-0-24).

(3) The folleving potential out-of-scope deviation was also identified by ERC:

4h

. I-M-HVIN-043:

Some of the bolts attaching the actuator to the mounting bracket did not have full thread engagement.

Disposition of the above finding is an open item (445/8514-0-25).

No NRC violations or deviations were identified.

h.

Large Bore Pipino 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 reinspection identified conditions which resulted in the issuance of 34 DRs, 18 of which, to date, have been validated and are undergoing an evaluation by ERC for safety significance.

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 had been previously inspected and accepted by construction QC. Approximately 24 previously reinspected items will-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 HRC Inspection Activity ERC methods and related documents used in establishing the population i

items list were reviewed for population inclusiveness.

Completed SSE reports are currently being re ' wed by the NRC inspector. As of October 25, 1985, four reinspection have been witnessed by the NRC inspector, with the following verification package reinspection being witnesscd during this report period:

3 c.;

i I

' I-M-l.BCO-113 (Unit 2):

During this reinspection, ERC identified one condition as subject to evaluation as a potential deviation, i.e.,

flanges that 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.

i.

Piping System Bolted Joints / Materials ERC has completed 73 reinspection of piping system bolted i

joints / materials as of October 26, 1985.

However, on eight of these reinspection 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 alto completed document reviews on 14 of the 73 packages.

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

Status of NRC Inspection Activity (1) The following ERC reinspection was independently inspected by the NRC inspector:

Verification Package No. Drawing No.

Flange No. Unit No.

I-M-PB0M-34 BRP-SI-1-RB-048 1

1 With respect to the above inspection, the NRC inspector concurred with the ERC inspector's finding that the flange type was not hardstamped on the flange as required by the inspection procedure, and that this condition is subject to evaluation as a potential deviation.

Subsequently, the inspection procedure was revised to allow inspectors to visually identify the type of i

flange if it is not hardstamped with such information.

The above will be reinspected by ERC for this particular attribute.

No NRC violations or deviations were identified.

(2) The following conditions which were identified by ERC in September as subject to evaluation as potential deviations had DRs written for them: (a) I-M-PBOM Flange No. 1 (Drawing BRP-SW-1-SB-003) had a loose nut, and (b) I-M-PB0M Flange l

I

/,.

d ~

No. 3 (Drawing BRP-CH-1-EC-004B) 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 NRC violations or deviations were identified.

j.

Small Bore Piping and Instrumentation Tube Welds / Material Status of CPRT Activity Reinspection is in progress of small bore pipe and instrumentation tube welds and material present in a random sample of 60 welds from Units 1 and 2.

Forty-four small bore pipe and instrumentation tubing welds have been visually reinspected.

Base material heat codes and welder identifications have been recorded and are undergoing documentation review.

No deviations have been found.

Status of NRC Inspection Activity i

The following seven reinspection of small-bore piping welds were witnessed by the NRC inspector:

)

Verification Package No. Pipe No. & Weld No.

BRP No.

I-M-SBWM-016 CH-2-216-152-3, Weld 11 CH-2-SB-009 I-M-SBWM-003 SW-2-368-105-3, Weld 23A SW-2-AB-027 I-M-SBWM-013 CC-2-064-152-3, Weld 1-1 CC-2-SB-002 I-M-SBWM-040 CH-1-220-152-3, Weld 37-2 CH-1-SB-024 I

j I-M-SBWM-076 CS-1-905-250-R2, Weld 18 CS-1-RB-013 I-M-SBWM-054 CT-1-127-901-R2, Weld 56 CT-1-RB-031 I

I-M-SBWM-057 CT-1-127-301-R2, Weld 43 CT-1-RB-031 No conditions subject to evaluation as potential deviations were identified by ERC to the NRC inspector.

No NRC violations or deviations were identified.

k.

Large Bore Piping Welds / Material Status of CPRT Activity l

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

Section III large bore piping welds and material from Units 1 and 2.

l To date, 35 large bore piping welds have been reinspected. One deviation has been identified which is currently being evaluated for l

validity and safety significance by ERC.

l 1

l

__.a.

,s-g

. Status of NRC Inspection Activity As of October 25, 1985, the following eight reinspection 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 C5-2-58-030 I-M-LBWM-026 BR-X-056-151-R-3, Weld 7 BR-X-AB-048 I-M-LBWM-030 DD-1-18-151-3, Weld 16-1 DD-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

)

i No conditions subject to evaluation as potential deviations were identified by ERC to the NRC inspector.

No NRC violations or deviations were identified.

1.

Large Bore Pipe Supports - Rigid Status of CPRT Activity Reinspection / verification of pipe support installations by ERC is approximately 94% complete.

A total of 151 deviations have been identified of which 98 have been determined to be valid. The remainder are currently being reviewed for validity.

Status of NRC Inspection Activity (1) The NRC inspector performed independent inspections on pipe support Verification Package Nos. I-S-LBSR-013 and -023, in order to assess the adequacy of the ERC reinspection. 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-5-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 i

tolerances not shown on design drawings, " Component Member Length +/- 1/2 inch." The Bill of Material on Revision 2 of drawing No. CT-1-097-402-CS2R lists item No. 4 (2 pieces) as being 7 3/4 inches long.

Independent NRC inspection determined the actual length dimensions to be, respectively, 6 5/8 inches and 6 1/2 inches, both of which are under the minimum indicated dimension of 7 1/4 inches (445/8514-0-04).

.!I (2) During inspection of the installation of box frame supports, which are a part of the Unit 1~ containment spray system, the NRC inspector observed that clearances exist between the bottom 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 i

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.

ji (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 reinspection.

This effort revealed that ERC had performed their reinspection in accordence with the requirements of QI-029.

No NRC violations or deviations were identified.

  • o s n.

Small Bore Piping Configuration Status of CPRT Activity As of October 25, 1985, reinspection was complete for 64 of 95 random sample small bore piping configuration items. The reinspection identified conditions which resulted in the issuance of 45 DRs, 25 of which were validated and are being evaluated by ERC for safety significance.

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 reinspection 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-SBCO-015 l

I-M-SBCO-061 1

I-M-SBCO-079 2

.i

. (2) During the above reinspection, ERC identified the following conditions to the NRC inspector as subject to evaluation as potentiel 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.

o.

HVAC Duct Supports Status of CPRT Activity Visual reinspection 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 reinspection of sampled HVAC duct supports were witnessed by the NRC:

Verification Package No. Unit No.

Duct Support No.

I-S-HV05-023 1

CB-830-IN-1R I-S-HVDS-041 1

AB-842-1L-1F I-S-HV05-005 2

CB-790-2N-1BF (2) During the above reinspection, ERC identified the following i

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-5-HVDS-041:

Undersize fillet welds.

1 i

,v

. 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 NRC violations or deviations were identified.

p.

Containment Liner and Tank Stainless Steel Liner Status of CPRT Activity Ninety-oneverif[cationpackageshavebeenissuedandreinspections are approximately 96% complete using QI-031, Revision O.

Documentation review of these packages using QI-032, Revision 0, is approximately 45% complete.

Eighty-three ors 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 samrle of 60 structural steel members was selected from a total population of approximately 1600 individual members.

l 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.

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

The following three inspections have been witnessed representing 5%

of the first random sample-

A

.j, -

+

1

-39' l

I Verification Package No.

Equipment No.

Unit No.

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

)

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

I-5-STEL-95 AFC0-MK-0180-1-RB 1

1 1

(2) During the above reinspection, 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).

i 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 inspector has reviewed QI-043, Revision 0, and witnessed 9 reinspection representing 15% of the first random sample of 60 concrete placements.

The following three ERC reinspection were witnessed by the NRC inspector during this report period:

l

4

_ _.s.

,,.,7 w.

. Verification Package No. Concrete Placement No.

Unit No.

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

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

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

-1 (2) During the above reinspection, 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 j

(Richmond) were out of tolerance.

OR I-S-CONC-40-DR1 was issued

' subsequent to the inspection.

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

DR I-5-CONC-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.

)

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

l deviations have been identified, relating primarily to Hilti bolt j

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.

l Status of NRC Inspection Activity The NRC inspector has reviewed QI-019, Revision 2, and QI-020, Revision 0, Six physical reinspection representing 10% of the first

k O6 -

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

No reinspection were witnessed during this report period.

i 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 reinspection of pipe whip restraints as of October 26, 1985.

i Status of NRC Inspection Activity

. (1) The following two ERC reinspection 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 reinspection, ERC identified the following 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.

I-S-PWRE-518: The grout did not completely cover the shim plate underneath the top baseplate.

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 i-inspection scope:

I-S-PWRE-052:

One of the Richmond inserts on concrete column No.15 overlapped a Hilti bolt embedment for a pipe support on the adjacent face of the same column by approximately 2 3/4 inches. The Hilti bolt centerline was about 5 inches l

l-r I

,5 d

,.y ',N.

' 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.

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

.and 446/8511-0-11).

No NRC violations or deviations were identified.

u.

Reinspection of Instrument Pipe / Tube Supports Status of CPRT Activity ERC has completed 42 out of the planned 102 reinspection of instrument pipe / tube supports as of October 26, 1985.

Status of NRC Inspection Activity

'(1) The following four ERC reinspection of instrument pipe / tube supports were witnessed by the NRC inspector during this report 1

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

l l

1-5-INSP-024 1-P15-3384 1

I-S-INSP-057 1-LT-459 1

(2) During the above reinspection, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations:

I-S-INSP-004: (a) Support Nos. 4B, 4C, 4D, 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 l

1

~

~

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43-

+

(d) support Nos.17A,il7J, and 17K had different type. instrument tubing clamps,than specified on the drawing.

I-S-INSP-024:

(a) Support No. 24H had.an undersized weld; (b) support No. 24H had no visible heat numbers'_on the baseplate; i

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

56 3/4 inches, which is.1/2 inch greater than the maximum-allowable length specified on the drawing; and:(d) support No.

24H had a different type of instrument tubing clamp than specified on the drawing.

-I-S-INSP-057: (a) Support Nos. 57A-and 57E did not have the-serrated grooves of the spring nut aligned with the channel ridge; (b) support Nos. 57N'and 57P had spring nuts'used in lieu of required hex nuts; and (c) support No. 57N had a bolt that did not have minimum 70% of specified torque.

Dispositions of the' above firidings are' open items (445/8514-0-35 through 445/8514-0-38).

(3) -The following two ERC reinspection were independently inspected by the NRC inspector:

o Instrument Tag No.

Unit No.

Verification Package No.

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

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

While performing the above independent inspections, it was noted that on support Nos. 007D and 028A, the serrated grooves on the spring nuts did not align with the channel clamping ridge.

This is required by attribute.4.5 of QI-055, " Reinspection of Instrument' Pipe / Tube Supports." However, the ERC inspectors signed off this attribute as being_ acceptable. This is an NRC deviation (445/8514-0-04).

8.

Unresolved Items 1

Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable items, violations, or i

deviations.

Seven unresolved items disclosed during the inspection are 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 representatives denoted in paragraph 1 of this appendix. During this interview, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the finding.t.

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APPENDIX F U. S. NUCLEAR REGULATORY-COMMISSION REGION IV.

CABLE TRAY SUPPORT MODIFICATIONS INSPECTIONS NRC-Inspection Report:

50-446/85-11 CP:

CPPR-127 Docket: 50-446 Category: A2

-Applicant:

Texas Utilities Electric Company 400 North Olive Street Dallas, Texas 75201 Facility Name:

Comanche Peak Steam Electric Station (CPSES), Unit 2

. Inspection At: Glen Rose, Texas Inspection Conducted:

Se tember 30 - October 2, 1985

(

3/pM6 Inspector L.V.ftflbeft,ReactorInspector Aa)4 Reviewed By: Ibe

.3/3/6'4 I. Barnes, Group Leader, Region IV Date CPSES Group Y Y/4 Approved:

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

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~9/Y/PX y

R. E. Ireland, Chief, Engineering Section Date i

Reactor Safety Branch M 905 h 860306

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Inspection 56mmary Inspection Conducted September 30 - October 2, 1985 (Report 50-446/85-11)

Areas Inspected:

Routine, unannounced inspection of cable tray support modifications. The inspection involved 24 inspector-hours onsite by one NRC inspector.

Results: Within the area inspected, no violations or deviations were l-identified.

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v3 Q' lM s DETAILS 1.

Persons Contacted Applicant Personnel

  • P. Halstead, Site QC Manager Brown & Root (B&R) Employees W. E. Baker, Senior Project Welding Engineer D. Mantz, Cable Tray Hanger General Foreman D. Geeo, Cable Tray Hanger Foreman Other contractor personnel were also contacted during the course of this inspection activity.
  • Denotes those present at the exit interview.

2.

Safety-Related Cable Tray Support Modifications The NRC inspector reviewed the documentation traveler packages and inspected the weldments for 12 cable tray supports that had been modified using tube steel in the new design. The following supports were inspected:

Support Classification CTH-2-11843 Class 1 CTH-2-11846 Class 1 i

CTH-2-11841 Class 1 CTH-2-11684 Class 1 CTH-2-10040 Class 1 CTH-2-9741 Class 1 CTH-2-11542 Class 1 CTH-2-11541 Class 1 CTH-2-11540 Class 1 CTH-2-9732 Class 1 CTH-2-9733 Class 1 CTH-2-10033 Class 1 e

In the areas inspected, the table tray support weldments complied with the requirements for welding in Weld Procedure. Specification No. 10046 and the requirements for visual weld inspection in Instruction QI-QP-11.21-1. The documentation for the supports was consistent with the status of the work.

I No violations or deviations were identified.

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