ML20206M441

Permittees Final Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence

ML20206M441
Person / Time
Site:	Comanche Peak
Issue date:	04/15/1987
From:	Eggeling W ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Gregory M GREGORY, M.
References
CON-#287-3121 CPA, NUDOCS 8704200111
Download: ML20206M441 (96)

Text

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3/z/ gELAT,ED CORRES10gDEf!C4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Of; HIE" C

before the 1R MR 15 N142 ATOMIC SAFETY AND LICENSING BOARD OFFICE C5 EtFtlAnY 00CKEiiH3 & SE8VICf SRANCH

)

In the Matter of )

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TEXAS UTILITIES GENERATING ) Docket No. 50-445-CPA COMPANY et al. )

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(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

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)

PERMITTEES' FINAL RESPONSES TO "MEDDIE GREGORY'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS (SET 5)"

Pursuant to 10 CFR $$ 2.740, 2.740b and 2.741, the Permittees respond herein to "Meddie Gregory's Interrogatories and Request for Production of Documents (Set 5)."

The Permittees have ignored the definitions and guidelines in the paragraphs labelled "a" through "e,"

inclusive, as contained in the document entitled "Meddie Gregory's Interrogatories and Request for Production of Documents (Set 5)," insofar as the same are contrary to the Rules of Practice.

8704200111 DR 870415 ADOCK 05000445 PDR h.

MOD

Interrogatory 1:

When did Applicants first receive notice of the issues identified by the NRC's TRT Reports and SSERs, and in what form did that notice come (i.e., NCR, IR, audit report, memorandum, consultant's report, etc.)?

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Interrogatory 2:

For each item identified in Interrogatory 1, identify what-response was taken to the problem and by whom.

Interrogatory 3:

If the answer to Interrogatory 2 is that no action was taken, explain the reason that no action was taken. If that reason is because Applicants relied on a "second opinion,"

identify the individuals or organizations who provided that opinion.

Interrogatory 4:

Identify how each " finding" identified in Interrogatory 1 was integrated into consideration of the subsequent findings by others. (For example, how were the findings by the NRC in 1978 and 1979 integrated into Applicants' response to the findings by the Management Analysis Corporation (MAC)?)

PERMITTEES' RESPONSES (TRT ISSUE: INSPECTION REPORTS ON BUTT-SPLICES)

At page J-29 of SSER 7, dated January 1985, the TRT stated:

... the TRT reviewed the QC Inspection Reports for 12 butt-splices and found the following:

• Nine of these splices were documented on the inspection form designated in paragraph 3.3 of the procedure for post-installation inspections instead of on the correct form designated for witnessing-type inspections. It should be noted that all splices were required to be witnessed by QC personnel per paragraph 3.1.d of the procedure

[QI-QP-11.3-28, Revision 21, " Class 1E Cable l Terminations"].

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• Six of the nine incorrect forms contained handwritten notes by the inspector indicating that '

l he had witnessed the splice; however, no reference was added to indicate that the installation of the heat-shrinkable sleeves was required to be witnessed.

• _The remaining three of the nine incorrect forms did not indicate that the splices had been witnessed.

• For three splices which were documented on the correct forms, the forms all contained an "N/A" (not applicable) handwritten by the inspector on the line indicating that the installation of the heat-shrinkable sleeve was witnessed.

Permittees believe that their first notice of this issue was the TRT letter of September 18, 1984. An understanding of events and procedures prior to this time is essential for any consideration of the issue identified by the NRC-TRT.

From late 1982 through mid-1983, while incorporating certain

" human factors" modifications and while completing various other rework on control panels, some conductors were found to be too short to be properly terminated at designated termination points. In lieu of repulling cables or redesigning cabinet internals, either of which would have involved significant disassembly and rework, the CPSES Project elected to add extensions to the subject conductors by using butt splices. The type of butt-splice used by the CPSES Project for splicing in panels was the AMP Pre-Insulated Environmentally Sealed (PIES) splice. IEEE 383-1974, "IEEE Standard for Type Test of Class 1E Electric Cables, Field Splices, and Connections for Nuclear Power l

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Generating Stations,"' recognizes that qualified field splicing is acceptable, and provides criteria for the qualification of such splices.

Originally, Section 8.1.5.2.4 of the FSAR committed CPSES to the provisions of Draft Standard IEEE 420-1973, "IEEE Trial-Use Guide for Class 1E Control Switchboards for Nuclear Power Generating Stations." This Standard states that splices are not allowed within control switchboards (including panels). Regulatory Guide 1.75, Rev. 1,

" Physical Independence of Electric Systems," states that splices in raceways should be prohibited. In July, 1983, TUGCO contacted the NRC staff (TCO #549 and TCO #550) to discuss the potential need to revise the FSAR to cover AMP PIES splices. Accordingly, FSAR Amendment 44 was issued in October, 1983, to' encompass the use of these splices in control panels. The TRT investigation occurred in July, 1984, which was subsequent to the submittal of this FSAR Amendment 44, but prior to the NRC's approval which was received by TUGCO on September 14, 1984.

Prior to TRT investigation, the craft Construction Procedure EEI-8, " Class IE and Non-Class 1E Terminations,"

did not contain specific instructions regarding the selection, installation or inspection of AMP PIES splices.

This procedure did indicate that manufacturers' instructions were to be used for installation of connectors, but no specific instructions with respect to selection of splice type or size, the correct tool to use, or accept / reject

l criteria for installation were included. Likewise, the QC i Inspection Procedure QI-QP-11.3-28, " Class 1E Terminations,"

did not contain specific instructions regarding the '

selection, installation or inspection of AMP PIES splices.

This procedure did contain some general statements about using manufacturers' instructions, but no specific instructions in the area of splicing.

Notwithstanding the lack of specific instructions regarding the installation or inspection of AMP PIES splices, existing procedures were adhered to by Permittees and should be noted in context of the TRT findings. Four inspection reports that were reviewed by TRT (IR ET-1-0005393, ET-1-0005394, ET-1-0005395, and ET-1-0005396) documented the splicing of cables on the inspection report normally used for post installation (verification) inspections. The inspector added a handwritten witness attribute to these inspection reports,

" Verify splicing (refer to QI-QP-11.3-28.13)." By adding this attribute, these inspection reports were converted to a form capable of documenting the required witness criteria of the splice installation. Authority for adding attributes to inspection reports is found in CP-QP-18.0 Rev.13, paragraph 3.1, "the attributes listed on the Inspection Report shall be predetermined although additional conditions may be noted."

Also, concerning the installation of heat-shrink sleeves, no reference was added regarding a heat-shrink

attribute since heat-shrink sleeves were not required for this splice installation as per Design Change Authorization (DCA) 7463 Rev.1 dated 05/29/80. (This DCA was later consolidated into DCA 9985 Rev.4 dated 08/17/82.)

Finally, in respect to an inspection report reviewed by the NRC (IR ET-1-OO14790) which did not indicate that the splice had been witnessed, research has revealed that this inspection was performed for the purpose of documenting the retermination of a cable after the installation of a cable grip. The witnessing of the splice had previously been documented on IR ET-1-OOO6776.

On July 13, 1984, the NRC issued a Special Review Team i Report (Letter Docket Nos. 50-445 & 50-446) to TUGCO that resulted from a special review conducted at CPSES during the period of April 3-13, 1984. At page 27 of this report, reference is made that "[d}uring the inspection for electrical separation in the above panels, it was noted that some cables in the panels were being spliced. This was determined to be satisfactory and meets FSAR commitments ...

Nevertheless, upon inspection of documentation associated with twelve of the control room splices, the NRC-TRT noted the concerns as listed in SSER 7. These concerns were transmitted to TUGCO by the 09/18/84 TRT letter. Subsequently, the Comanche Peak Response Team (CPRT) was formed and Issue-Specific Action Plan (ISAP)

I.a.2 (Inspection Reports on Butt-Splices) was issued to 6-

address the TRT findings regarding proper witnessing and documentation of inspections on butt-splices.

(TRT ISSUEi ELECTRICAL CONDUIT SUPPORT)

At page J-46 of SSER 7 dated January, 1985, the TRT found:

The installation of the nonsafety-related conduit in the control room appears to be inconsistent with the positions of Regulatory Guide 1.29.

In particular, the TRT expressed specific interest in documentation justifying the nonseismic installation requirements for the non-nuclear safety related conduit less than or equal to 2 inches in diameter.

Permittees believe that the TRT letter of 09/18/84 was their first notice of this issue. Prior to this date, Applicants had taken action in regard to seismic supports at CPSES. Specifically, on April 30, 1979, TUSI Systems Engineering Memo (CPPO1176) was issued to the TUSI Engineering and Construction Manager, recommending the seismic declassification of Class 5 piping and Train C conduits in the Auxiliary, Fuel and Electrical & Control (E&C) Buildings.

The subsequent issuance of DCA 4693 on July 20, 1979, allowed for Train C conduits (all sizes) to be e

non-seismically supported in seismic Category 1 buildings.

The DCA also stated that protective measures would be taken 1

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to protect cafety-related equipment where engineering analysis determines that failure of the conduit or supports could degrade that equipment or its operability. Shortly thereafter, memo CPPA-2142, from the TUSI Engineering and Construction Manager to the Brown & Root Project Manager, identified where Train C conduits larger than 2 inches will require seismic support and stated that elsewhere, support will be nonseismic. Train C conduits, 2 inches and smaller, were to remain nonseismically supported in all areas. A reiteration of this policy regarding nonseismic support of conduits 2 inches and under in the Containment and _

Safeguards Building was made on July 10, 1979 via memo k CPPA-2269 from the TUSI Engineering and Construction Manager to Brown & Root Company.

The generic issue of nonseismic support of Train C hardware has been addressed during the construction of CPSES through the CPSES Damage Study Program. In the summer of 1979, the Damage Study began to examine the effects of failure of nonseismic conduit supports on nearby equipmant.

This systematic study was performed for the interaction of all nonseismic piping and conduits greater than two inches in diameter, with equipment and structures with safety-related components in Category 1 buildings for Unit 1 -

and common areas. The support of conduits less than or equal to 2 inches in diameter was assumed to be adequate to assure that the conduit would not result in an adverse

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interaction during a seismic event. Accordingly, this interaction was not considered by the Damage Study.

During the time period of December, 1979 through September, 1984, various revisions were issued to the aforementioned DCA 4693. However, conduits two inches and smaller remained nonseismically supported in all areas except as identified on a case-by-case basis where seismic supports or seismic restraints were believed to be required.

During the same time span, namely, on March 10, 1980, a memo from Gibbs & Hill Manager of Projects (GTN-44706) to the TUGCO Engineering and Construction Manager elaborated on TUSI's nonseismic support criteria. This memo transmitted meeting minutues from a February 6 and 7, 1980 meeting between Gibbs & Hill and TUSI in which TUSI provided an explanation as to why the two inches and smaller conduit supports were specified as nonseismic. TUSI stated that the decision to allow nonseismic support of conduits two inches or smaller was based on NRC criteria for the damage potential for two inch diameter standard wall thickness i pipe. The NRC study for pipes was extrapolated by TUSI to include two inch diameter rigid steel conduits.

On 09/18/84, however, the NRC letter to TUGCO notified TUGCO of the TRT concern with electrical conduit supports.

Subsequently, the CPRT was formed and ISAP I.c (Electrical Conduit Support) was issued to address the TRT finding with regard to the adequacy of the seismic support system I

installation for non-safety related conduits.

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^ss (TRT ISSUE: QC INSPECTOR QUALIFICATIONS)

At pages J-56 and J-57 of SSER No. 7 dated January, 1985, the TRT stated as follows:

Training and Certification Files. The TRT examined in detail six electrical QC inspectors' training and certification files (two Level I and four Level II).

The examination revealed the following two instances where TUGCO Procedure CP-QP-2.1, Revisions 8 through 15, RG 1.58, Revision 1, and ANSI N45.2.6-1978 requirements for qualification were not being met:

(a) There was no documentation of a high school diploma or General Equivalency Diploma (GED) for one of the inspectors selected.

The file on this inspector contained only a telephone conference note that a call had been made in 1982 requesting information from a high school.

(b) There was no documentation to waive the remaining 2 months of the required 1 year of experience for a Level I technician before the individual became a Level II inspector after successfully passing the required examinations.

l The TRT also found one case where a Level I QC technician had not passed the required color vision examination, which was to be administered by an independent professional eye specialist. A makeup

.' test using colored pencils was l administered by a QC supervisor, was t passed, and then a waiver was given. A TUGCO procedure allowed for a waiver on

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a case-by-case basis. In addition to the above, the TRT staff also found two cases where the experience requirements to become a Level I technician were met only marginally. In one case, no documentation was found in the training and certification files substantiating that the person could, with reasonable i assurance, competently perform the particular task without having the required related experience.

Recertification Program Requirements.

The TRT examined the recertification program and found that there was no required documentation to assure that recertification requirements were being met. The present system only requires a simple "yes" or "no" answer from an inspector's lead QC inspector that the individual had been active in the area in the last 6 to 12 months and was knowledgeable about current procedure requirements. The lead QC inspectors did not maintain any written record of a subordinate inspector's activity.

Permittees believe that the TRT letter of September 18, 1984 was their first notice of a concern regarding QC inspector qualification issues for the six electrical QC inspector files examined by the TRT.

Electrical QC inspectors are classified as non-AGME.

Brown & Root was responsible for non-ASME site inspection activities prior to 1978. In 1978, TUGCO assumed responsibility for the non-ASME QA program and established a QC inspector certification program. The education and experience requirements and the records maintenance requirements for the various levels of inspectors (I, II and III) are detailed in Regulatory Guide 1.58, Revision 1,

" Qualification of Nuclear Power Plant Inspection, Examination, and Test Personnel for the Construction Phase

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of Nuclear Power Plants." The TRT examined the qualifications of the six QC inspectors to determine compliance'with the requirements of Reg. Guide 1.58 and ANSI Standard N45.2.6-1978. TUGCO was not committed to Reg.

Guide 1.58 and ANSI Standard N45.2.6-1978 until January 30, 1981 when Amendment 14 to the FSAR was issued. TUGCO Procedure CP-OP-2.1, " Training of Inspection Personnel,"

' Revision 8 (July 1981) met the requirements of Reg.

Guide 1.58 and ANSI Standard N45.2.6-1978.

Prior to receipt of the September 18, 1984 TRT letter,'

but after commitment to Reg. Guide 1.58 and ANSI Standard N45.2.6-1878 on January 30, 1981, there were issues raised regarding-the adequacy of QC inspector qualifications involving the overall functioning of the QC inspection qualification program and not merely the qualifications of QC inspectors. While such programmatic issues go beyond the scope of the above TRT finding, an adequate understanding of the TU's actions with regard to inspector qualifications is not complete without touching upon these tangential issues.

I The Lobbin Report of February 4, 1982, stated that interviews with various individuals at CPSES revealed a concern with regard to the level of experience of inspection i

. personnel. On February 23, 1982, the TUGCO QA Manager i.

l notified the TUGCO, Vice President Operations of QA's

responses to the Lobbin Report findings by memo QBC-18. The l specific response regarding the inspection program findings stated that inspection personnel were qualified as f

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appropriate to industry standards. The response also stated that personnel qualifications were routinely examined incidental to audits of safety related activities, but that an audit of inspection personnel training and certification had been scheduled for March, 1982.

TUGCO QA Audit Report TCP-36, which reported the results of the audit of Site QA/QC Personnel Training performed on March 8-12, 1982, was transmitted to the TUGCO Site QA Supervisor by memo QTQ-120 from the TUGCO QA manager. The scheduling of this audit was referenced in the February 23, 1982, TUGCO QA response to the Lobbin report findings. The Audit Report presented only one concern that was directly related to the TUGCO non-ASME QC inspector certification program procedures. However, this was a programmatic concern rather than a specific inspector qualifications concern as identified by TRT finding to which this answer is responsive. The report cited two deficiencies that were directly related to non-ASME inspection personnel qualifications. Deficiency No. 1 stated that formal training records within some non-ASME personnel certification training files did not contain complete instruction information. Deficiency No. 2 stated that inspector certification records did not reflect a certification in each given inspection function as required.

On December 21, 1982, the TUGCO Site QA Supervisor provided responses to the Audit Report TCP-56 deficiencies by memo TUQ-1497 to the TUGCO QA manager. The memo stated

4 that corrective actions for Deficiency Nos. 1 and 2 would

' consist of revisions to applicable procedures. On January 25, 1983, the TUGCO QA Manager provided an I evaluation of the December 21,~1982, responses to Audit Report TCP-56 deficiencies in memo QTN-623 to the TUGCO Site QA Supervisor. The response evaluation closed Deficiency

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No. 1 but requested specification of an implementation date

-for the Deficiency No. 2 corrective action. The requested information was provided on March 14, 1983, by memo TUQ-1583 from the TUGCO Site QA Supervisor to the TUGCO QA Manager.

! On April 11, 1983, the NRC transmitted to TUGCO the NRC

Construction Appraisal Team (CAT) Inspection Report. The inspection was conducted between-January 24 and March 3, 1983, at CPSES and at TUGCO's' Dallas Corporate office and consisted in part of review of the QA Program and i examination of procedures and records. Interviews with 1

! quality control inspectors and certification reviews

' revealed that some inspectors had been' certified without the required combination of education and experience as specified by ANSI Standard N45.1.6-1978. Additionally, interviews and document reviews revealed that-individuals not certified as Level II were evaluating the validity and acceptability of final inspections contrary to the i

i requirements of ANSI Standard N45.2.6-1978 as committed to

in the FSAR. On April 14, 1983, after evaluating the CAT i

i Report findings, the TUGCO-Site QA Supervisor stated by memo l

to the TI-086 file, that the NRC CAT inspector's i

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interpretation of the " inspector of record" concept was a matter of opinion and that this interpretation had not been imposed on the industry by NRC. He also stated that a review of ANSI Standard N45.2.6-1978 and Reg. Guide 1.58 supported the CPSES program and that no changes would be planned.

l On May 4, 1983, the TUGCO Mechanical / Civil QA/QC l Supervisor notified the TUGCO Site QA Supervisor by memo TUQ-1647 of his further evaluation of the CAT findings. He stated that the plant was in compliance with the intent of both Reg. Guide 1.58 and ANSI Standard N45.2.6-1978. On June 15, 1983, testimony was provided before the ASLB by various intervenor and TUGCO witnesses regarding CAT Report proposed enforcements. One of the specific subjects covered included qualifications of inspectors.

On August 25, 1983, the TUGCO QA Manager transmitted TUGCO QA Audit report TCP-78 by memo QTQ-430 to the TUGCO Site QA Supervisor. The' report provided the results of the audit of cable tray and conduit supports installation and

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inspection activities performed on July 11-15, 1983. The audit included a review of qualification and training of QC inspectors. Deficiency No. 2 stated that OJT Training Record Sheets from selected personnel files were reviewed and found to be inconsistent in documenting required I l

information. Deficiency No. 3 stated that a review of ]

selected qualification files indicated no documented

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i evidence that three individuals were qualified / certified to perform as instructors in the identified procedure / activity.

On September 22, 1983, the TUGCO Site QA Supervisor l

provided responses to the Audit Report TCP-1978 deficiencies by memo TUQ b 1807 to the TUGCO QA Manager. The response to Deficiency No'. 2 stated that the qualification files in question had been corrected so that the required information was documented. The response to Deficiency No. 3 provided the qualification informction for the three individuals in question. On December 8, 1983, the TUGCO QA manager notified the TUGCO Site QA Supervisor, by memo QTQ-520, that the responses to Deficiency Nos. 2 and 3 for Audit Report TCP-78wereconsiderbdunacceptablebecausetheywere directed toward the symptom of the problem and not the problem itself. On January 11, 1984, by memo TUQ-1903, the TUGCO Site QA Supervisor provided the TUGCO QA manager with the information believed to be adequate to close out Deficiency Nos. 2 and 3.

On October 3, 1983, the NRC Region IV Reactor Project Branch Chief transmitted to TUGCO the NRC Investigation Report Nos. 50-445/83-28, 50-446/83-14 for investigations conducted at CPSES on-June'27 to September 16, 1983. This inspection was a follow up to the earlier CAT inspection and consisted of a more in-depth review and evaluation of the CAT Report findings. The Inspection Report results stated that the certifications of the inspectors examined were generally consistent with the requirements of ANSI

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Standard N45.2.6-1978 and Reg. Guide 1.58. The Region IV inspectors also reviewed the CAT finding regarding the

" inspector of record" issue for Level 1 and Level II inspectors. They agreed with the TUGCO Site QA Supervisor's interpretation and concluded that the " inspector of record" and the level of review at CPSES was appropriate for the type of inspections in question.

Following notification by TRT of the QC inspector ,

qualifications issue on September 18, 1984, TUEC formed the CPRT and issued ISAP I.d.1 (QC Inspector Qualifications) to address the TRT finding as stated in SSER No. 7.

(TRT ISSUE: REINFORCING STEEL IN REACTOR CAVITY)

At page K-52 of SSER 8 dated February, 1985, the TRT found:

The reinforcing steel that was placed between the 812-foot and 819-foot, 1/2-inch elevations in the reactor cavity wall of the Unit 1 Reactor Building was completed and inspected to drawing 2323-S1-0572, Rev.2. After the concrete was placed, Brown & Root received Rev.3 to the drawing showing a substantial increase in reinforcing steel over that which was installed. G&H engineering was informed of the omission by Brown & Root nonconformance report C-669, which is referenced in the Brown & Root internal deficiency report CP-77-6. G&H engineering replied that the omission of this additional reinforcing steel did not in any way impair the structural integrity of the structure. G&H stated that the additional rebar was added as a precaution against cracking which might occur in the vicinity of the neturon detector slots should a loss of coolant accident (LOCA) occur. A portion of the omitted reinforcing steel 17 -

was placed in the next-concrete lift above the 819-foot, 1/2-inch elevation. G&H stated that this was done to partially compensate for the reinforcing steel omitted below and to minimize-the overall area subject to possible cracking.

The TRT requested documentation to indicate that an analysis was performed supporting this conclusion.

The TRT was subsequently informed that an analysis had not been performed.

e Permittees believe that their first notice of this issue was on June 22, 1977, in the form of Brown & Root nonconformance report C-669. In accordance with Gibbs &

Hill drawing No. 2323-S1-0572, Rev.2, concrete was placed in the Unit 1 reactor cavity between 812-foot and 819-foot, 1/2-inch elevations. This pour was made on May 25, 1977, eight days after Rev.3 of G&H drawing No. 2323-S1-0572 was transmitted to CPSES site, but 22 days prior to the drawing being issued for construction. The new drawing, Rev.3, showed additional rebar within the pour area which was not installed.

Accordingly, Brown & Root isssued NCR-C-669 on June 22, 1977, which described the omission of additional rebar to the reactor cavity wall. On June 23, 1977, a corresponding NCR (CP-77-6) was issued by TUGCO describing the omission of additional rebar to the reactor cavity wall.

Telex No. TWX-762 (06/23/77) from Gibbs & Hill Engineering (site) to Gibbs & Hill (New York) confirmed a telephone conversation concerning the omitted rebars. Gibbs

& Hill Telex No. GTT-1259 (06/27/77) responded to the site Telex No. TWX-762 and requested that the contractor be asked not to take any action that would preclude adding

reinforcing steel in the concrete placement above the'one where the rebar was omitted.

Gibbs & Hill (New York) followed-up on the subject on July 6, 1977, via letter GTN-19823 to TUGCO which stated that their analysis indicates the omitted rebars do not jeopardize _the-structural integrity of the reactor primary shield structure under any postulated loading condition.

The letter also referenced the previously mentioned G&H Telex No. GTT-1259 and reaffirmed the suggestion that stress distributing rebar be included in the next lift above 819-foot,-1/2-inch elevation. The letter noted that this action would serve two purposes, neither of_which is related to public safety. First, it would provide partial

, compensation for the rebar which was omitted below and, second, it would minimize the overall area subject to

possible cracking. The letter stated that drilling into the existing concrete would not be required. Upon receipt of f this information from Gibbs & Hill, Permittees believed any potential problems relating to the omission of reinforced steel in the reactor cavity had been adequately resolved.

On 09/18/84, the NRC letter to TUGCO confirmed the TRT's finding in regard to rebar in the reactor cavity.

Subsequently, the CPRT was formed and ISAP II.a (Reinforcing

! Steel'in the Reactor Cavity) was issued to address the TRT concern regarding an anlaysis to support the Gibbs & Hill ,

conclusion verifying the adequacy of the reinforcing steel  !

as installed.

(TRT ISSUE: POLAR CRANE SHIMMING)

At page K-181 of SSER 8 dated February, ~1585,- the TRT found with regard Unit 1 polar crane rail systems support:

The TRT investigated the installation of the polar crane rail support system by visual inspection, review of associated documentation, and discussions with TUEC representatives and their contractors.

Region IV Inspection Report 50-445/84-08; 50-446/84-04 and Notice of Violation, dated July 26, 1984, documented that gaps on the Unit 1 polar crane bracket and seismic connections exceeded design requirements . . .

During further investigation of the allegation that shims for the rail support system of the polar crane had been altered during installation, the TRT observed gaps which may have been excessive between the crane girder and the girder support bracket. Detailed specifications addressing the gap tolerance in the girder seat connections did not exist.

Permittees believe that the Region IV Inspection Report 50-445/84-08, 50-446/84-04 and Notice of Violation, dated July 26, 1984, documenting gaps on the Unit 1 polar crane bracket and seismic connections as exceeding design l requirements was their first notice of any concern regarding possible inadequacies in polar crane shimming. It can conceivably be urged, however, that the first indication of the potential for a problem with polar crane shimming was l

recognized in July, 1982, when the NRC issued Notice of

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Violation 50/445/82-11 citing that no inspections of the fabrication and installation of certain shim's, as specified in Design Change Authorization DEC-9872 R/O and sketch SK-82032 were performed. In response to the Notice of Violation, NCR M82-894 was generated by TUGCO on July 7, 1982. This 1982 NOV related to deficiencies in implementing inspection procedures and not the precise problems identified in the TRT findings.

Interoffice Memo of July 27, 1982, from Brown & Root to TUGCO Site QA Manager provided a corrective and preventive action response to NCR M82-894 and a date for compliance.

On August 2, 1982, TUGCO submitted a written response to the NRC's Notice of Violation citing the Brown & Root corrective action memo (TXX-3554, 8/2/82). Shortly thereafter on August 9, 1982, Design Change Authorization revisions, DCA-9872, R/1 and DCA-9872, R/2, were issued to clarify shimming and bolting requirements on the polar crane. These revisions recognized as acceptable occasional shim gaps of less than 1/16 inch.

During October, 1982, Operational Traveler CE-82-370-3104 was issued implementing QC requirements that "all gaps greater than 1/16" wide shall be shimmed."

The NRC conducted an on-site inspection of CPSES during the period 11/14/83 to 3/31/84 and expressed concerns regarding the as built shim gaps in the upper brackets of the polar crane. During the inspection, the Comanche Peak Plant Engineer requested a Gibbs & Hill analysis of the

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shim's "as built" on January 31, 1984. The Gibbs & Hill i response contained in a February 16, 1984, letter, (CPPA-36900) provided that as long as there is a positive contact at the girder top flange, the seismic loads will be transmitted directly into the containment wall through the horizontal stiffeners of the attachment and therefore the gaps at the periphery of the shims will be of no concern (GTN-68522, 2/25/84).

Site Quality Control originated NCR M 84-918, R/1 on 3/27/84 for loose bolts found on the polar crane support brackets. On April 2, 1984, NCR 84-918, R/1 was closed following efforts to tighten all bolts.

On 6/4/84 and 8/3/84 Gibbs & Hill provided evaluation of as-built gape in upper bracket supports of the polar crane and in each instance the analysis concluded, with small exception, that the as-built condition was considered acceptable. (GTT-10372; GTT-10457)

It was at this point, as noted previously, that NRC Region IV Inspection Reports 50-445/84-08, 50-445/84-04 and Notice of Violation dated July 26, 1984, were issued. In TUGCO's responses of August 23, 1984, and September '/, 1984, the gaps were attributed to crane and bolting i self-adjustment resulting from crane operation. A site Design Change Authorization, DCA-9872 R/4, dated August 24, 1984, was issued to document the acceptability of the gaps in excess of 1/16 inch which were identified in the NRC Inspection Report.

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i The NRC letter of November 29, 1984, informed TUGCO of l

the TRT's continuing concerns regarding polar crane shimming. Subsequently, the CPRT was formed and ISAP VI.b (Polar Crane Shimming) was issued to address the TRT concerns.

(TRT ISSUE: INSPECTION OF CERTAIN TYPES OF SKEW WELDS IN PIPE SUPPORTS)

At page N-327 and 328 of SSER 10 dated April 1985 the TRT finds:

The TRT investigated inspection procedures of Brown &

Root (B&R) for welds in pipe supports designed to ASME III Code, Subsection NF. The TRT found that no fillet weld inspection criteria existed for certain types of skewed welds. By definition, skewed welds are those welds joining (1) two non-perpendicular or non-colinear structural members, or (2) two members with curved surfaces or curved cross sections, such as a pipe stanchion (a section of pipe used as a structural member) welded to another pipe stanchion or to a curved pipe pad. Notice that for type-2, the effect of curvature at the weld connection induces skewed considerations, even though the two joining members are physically perpendicular. The B&R weld inspection procedures CP-QAP-12.1 and QI-QAP-11.1-28 for NF supports have addressed type (1) skewed welds; however, the TRT found that QI-QAP-11.1-28 did not include weld inspection criteria for type-2 skewed welds. Although I the TRT was told by Brown & Root personnel that i proceudre QI-QAP-11.1-26 for piping weld inspection was

! used, since such weld connections were similar in L configuration to a pressure boundary stanchion attachment weld, no evidence documenting the use of this inspection procedure was provided to the TRT. According to records reviewed by the TRT, these welds were actually categorized as "all other welds" rather than

" skewed welds" on the required QC checklist. Instead of using fillet weld gauges for measuring the size of nonskewed welds, welders were supposed to use a straight l

r edge and a steel scale for measurement of a type-2 skewed weld, as described in QI-QAP-11.1-28. In addition, due to the variable profile along its curved weld connection, the weld size should have been measured at several different locations. The lack of inspection criteria and lack of verification of proper inspection procedures being conducted for type-2 skewed welds are a violation of ASME Code for NF supports committed to by TUEC in FSAR Section 5.2.1 and a violation of Criterion XVII in Appendix B of lOCRF50. The TRT reviewed weld inspection procedures, weld data cards, and visually j inspected several type (2) skewed welds in randomly l sampled NF supports where pipe stanchions were used.  !

Although the small sample of welds inspected by the TRT are acceptable, due to deficiences in inspection records and the apparent lack of inspection criteria, the TRT is not certain whether other type (2) skewed welds were l inspected properly. This is a generic issue involving  ;

many NF supports in various safety-related systems. The lack of documented inspections and criteria for type (2) skewed welds in NF supports represents a safety concern regarding the possible existence of under-sized welds in supports which are required to resist various design loads.

Similar and related findings are referenced at pages N-202 through 205 of SSER 10.

Permittees believe that the Nonconformance Report (NCR M-81-01782) dated December 20, 1981, was their first notice of the issues concerning inspection of certain types of skewed welds. The NCR required clarification of the QC fit-up inspection procedures for skewed welds. The response from Permittees' Quality Engineering Department stated that fit-up inspection of skewed welds was not a code requirement, therefore, any fit-up inspection requirement had been removed from appplicable procedure. (QC Inspection Procedure QI-QP-11.16-1, Rev. 2 deleted the fit-up inspection criteria for skewed welds on January 8, 1982.)

Accordingly, the NCR was closed on 1/15/82.

In August, 1982, Charles A. Atchison, a CPSES QC employee, made a statement to an NRC investigator alleging that the Permittees QC inspection procedure for welding did not contain written instructions for examining skewed fillet welds. NRC review of the allegation confirmed the lack of written inspection procedure and in the NRC Inspection Report (IR82-14, November 8, 1982) it was further noted "the Licensing QA Supervisor has stated that appropriate QC procedures will be reviewed to address in detail the inspection techniques to be used both for the random inspection effort and for future inspections."

As a result of engineering reviews, on September 3, 1982, Revisions 12 and 13 of inspection procedure QI-QAP-11.1-28, " Fabrication and Installation Inspection of Safety Class Component Supports" were issued. These established inspection methodology and acceptance criteria for measurement of both type-1 and type-2 skewed welds.

On December 15, 1982 the type-2 skewed welds inspection methodology was moved from the pipe support procedure (QI-QAP-11.1-28, Rev. 16) to the piping procedure (QI-QAP-11.1-26, Rev. 9) on the basis that most of the type 2 skewed welds were attachment welds to the pipe and thur, fall within the scope of the piping procedure.

Brown & Root Instruction QCWI-1 wars issued on february 21, 1983 to inform inspectors to use the inspection methodology and acceptance criteria in the piping procedure

I l

(QI-QAP-11.1-26) when measuring type-2 skewed welds on pipe I supports which were not attachment welds to the piping. 1 i

On March 18, 1983, Revision 5 of inspection proceudre CP-QAP-12.1, "ASME Section III Installation Verification and N-5 Certification," was issued. A program was initiated to reinspect all accessible NF welds using a checklist created in the revision. The documentation for the reinspection was not specific to individual welds, instead it covered all the welds for a given support. The CP-QAP-12.1 checklist had two entries for the welds; one for skewed welds, another for all other welds. On the CPSES project, type-2 skewed welds were termed " stanchion welds"; therefore, supports with stanchion welds and no other skewed welds had no entry or "N/A" under the checklist item for skewed welds. Although the project intended that the reinspection program would ensure proper measurement of all the type-2 skewed fillet welds, the records did not provide conclusive evidence of this. The source of the ambiguity was in the terminology used in inspection procedures and documentation for skewed welds.

In August, 1983, the piping inspection procedure (QI-QAP 11.1-26) was reviewed (Revision 13) to add the profile technique for measurement of type-2 skewed welds. From this point on the piping inspection procedure included both the strike line and profile techniques for measurement of type-2 skewed welds. Inspection results indicate that most (72%)

r of the supports with' type-2 skewed. welds were inspected after this 7 date.

A routine NRC Region IV Inspection (conducted between of March 20, 1984, and May 18, 1984) alleged that "QC Inspection procedures for welding did not contain written instructions for examining skewed fillet welds." (Item 445/8214-02) In a July 23, 1984 NRC letter from the Director of Region IV, Comanche Peak Task Force unresolved Item 445/8214-02 was closed.

Subsequently, in January, 1985 the strike line technique for measurement of type-2 skewed welds was reincorporated in support inspection procedures. In addition, on April 25, 1985, the profile technique for measurement of type-2 skewed welds was added to the support inspection procedure. From this point on both piping and pipe support inspection procedures contained'the strike line and profile techniques for measurement of type-2 skewed welds.

Thereafter, the CPRT was formed and ISAP V.a (Inspection of Certain Types of Skewed Welds in NF Supports) was issued to address the TRT findings related to inspection of certain type of skewed welds.

(TRT ISSUE: DOCUMENT CONTROL) l On page 0-48 of SSER 11 dated May, 1985, the TRT found:

The portion of the allegation concerning the i

- - - _ . ., _ . . _ _ . . -r,,._-- - _ __-._ ,_. __._.._..._._ , . - .--_.__ ._ - .__. .__., _,._...._ _-.__ .- - - . . _ . . . . . _ . _ . . . .

. _ . - - . . ~ - -- . - - .. - ._

V document control system not. properly functioning in regard to drawings and specifications-was

. essentially substantiated for the period: prior to July,.1984. From September, 1981 until June, 1984, numerous internal and external audits-identified a recurring problem with document control. -It was not'until April, 1984 that CPSES management took effective correction action. Generically, the

_ present-program for controlling design documents,

( though cumbersome, is effective. The' significance of the document control deficiencies prior to July, 1984 is that these deficiencies had the potential I 'for contributing to problems in construction ,

installation, and inspection; l_

and on page 0-67:

The concern that the.DCC satellite supervisor took actions which resulted in procedural violations was substantiated . . . In the course of assessing this allegation, the TRT determined that the TUEC j definition of reportable deficiencies is too vague.

l TUEC's NCR procedure lacks references and does not i address correlation of NCR's to reportability under 10 CFR 50.55(e). The significant deficiency lL_

~

procedure lacks-specificity as to what is a significant breakdown-in any portion of the QA program or the mechanism for review of NCR's for potential reportability. This concern has generic implications in that significant quality program'

deficiencies could go unreported to the NRC; '

and on page 0-91:

There were deficiencies in the control of design l

document packages and that obsolete and/or partial

! documents were available to craft and QC personnel which could have been used in the fabrication, l

installation, and inspection'of safety-related

hardware from August, 1981 through June, 1984.

However, the-review of the complete safety-related i quality records in the PPRV indicated that drawings used for inspection and fabrication were performed

! to the latest revision; l

l and on page 0-99:

! The TRT evaluated TUEC's and B&R's procedures l governing permanent QA/QC records, accountability, i and preservation and found them to be in compliance

with the ASME Code, 10 CFR Part 50, Appendix B, and

!- ANSI N45.2 requirements. Procedure implementation l was verified by TRT reviews of documents and

! records supporting the construction and inspection 4

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w,r,.,-m,,a.- eamm~---n-,ve.m.vmm.,-m,.,---e+

activities for selected ASME hangers, components,

-and piping. Document deficiencies relating to the partial or complete loss of work packages were reported on NCR's for corrective action. In these cases, reconstruction or replacement of lost records was done in accordance with approved procedures. Such documentation was subject to the same review and approval as the original records received. Accordingly, an effective program exists for the accountability of permanent records supporting construction and inspection at CPSES.

The TRT found that the allegations that construction, fabrication, installation, and inspection records were lost have been substantiated. However, the losses were not of the magnitude first alleged, (i.e, " hundreds" of, entire documentation packages), nor vare losses attributable to the lack of co:cpetence of the PFG.

Ac Ordingly, these allegations do not have generic implications; and on page 0-113:

The TRT found no evidence of any type of formal training program for document control clerks prior to DCP-3, Rev.16 (August, 1983).

With respect to the foregoing TRT findings regarding document control, and except as hereinafter provided, Permittees are unable to identify a specific date or event which provides an accurate answer to Meddie Gregory Set 5, Interrogatory No. 1. In any construction project of the size, duration and magnitude of CPSES, document control needs and problems are constantly being identified and addressed. This process is dynamic and constantly evolving, therefore, attempts to focus on a "first notice" of document control issues defined as broadly as those identified by the TRT would of necessity be arbitrary and misleading.

Permittees believe, therefore, that the TRT letter of 1/8/85

was their first notice of the specific TRT findings related to document control.

As noted on page 0-48 of SSER 11, "from September, 1981 until June, 1984, numerous internal and external audits identified a recurring problem with document control."

During September, 1981 two separate documents identified l

discrepancies in the area of document control. Site Surveillance Report 150 (9/1/81) noted that a substantial number of drawings in the Unit 2 Control Room had discrepancies and TUGCO Audit 23, Deficiency No. 1.

(9/2581) specified concerns related to more than half the controlled drawings in one document center. By November, 1981, the' discrepancies noted in TCP 23 had been fully resolved and a commitment made to review identified documents for correctness on a monthly basis. (TUQ-1034, 11/23/81)

In a Dallas Surveillance Report (DSR 82-18) dated April 19, 1982, a review of drawings related to two types of tests records reverjed that controlled drawings were not being received from the document control center in a timely manner. Also in April, 1982, TUGCO Audit, TCP 40 (4/29/82) stated that document control centers did not have correct l revisions of Design Change Authorizations (DCA). In response to TCP 40, corrected revisions of DCA's were placed in document centers and file custodian's were given additional training as noted in a TUGCO response (CPPA) 20535, 6/23/82).

l

The INPO Self Evaluation of October, 1992 concluded that uncontrolled drawings were being used to perform some work and that illegible documents were in use. Included in the evaluation was a TUGCO response that all drawings were currently being reviewed for legibility prior to submittal to the Document Control Center and personnel using documents are charged with obtaining replacements for illegible drawings.

NRC Report 83-18 (3/3/83) noted that drawings with out-of-date revisions and drawings with damaged or unreadable title blocks were present in certain construction work areas. TUGCO memo of May 2, 1983 to Site QA Supervisor stated in response to NRC Report 83-18 that all out-of-date drawings had been replaced, a reproduction process to provide more durable filed drawings had been implemented and that preventive action would be institued through the establishment of satellite document control centers and by a new system of issuing work packages.

Phase I of the Cygna Report issued on 7/29/83'noted that logs of design changes and the design change tracking system were not accurate. The report concluded, however, that a document control satellite system and a computer listing of drawings and related changes were being established and that I

existing document control systems were being revised and redefined to provide better control. Additional document control problems were identified in ASME monitoring reports I

during August, 1983 (ASME SIS 361 and SIS 361 A).

s I

Permittee's response dated 8/16/83 (IM26015) stated that corrective actions include procedure changes, a review of all hanger packages and establishment of a document control satellite system.

In NRC Report 83-84 (8/24/83), Construction Appraisal Team (CAT) inspectors found a group of out-of-date and incomplete drawings, however, no Notice of Violation was issued.

Two Monitoring Discrepency Reports MDR 83-026 (10/12/83) and MDR 83-027 (10/12/83) noted that some personnel performing work in the Document Control Center lacked adequate training and that out-of-date drawings had been identified. Also in October, TUGCO Audit, TCP 84 (10/14/83), identified problems with signatures on document requests, obsolete drawings procedures and missing drawings.

On December 16, 1983, TUGCO responded to the audit TCP 84 findings indicating specifications or explanations for each audit concern. (CPPA 35871) on November 12, 1983, an INPO Self Evaluation followup stated that document management areas were found to be adequately controlled. The document management system was found to be sound and under good control.

TUGCO Audit (TCP 99) dated 3/26/84 reviewed document control deficiencies associated with proper usage of the control stamp, incorporation of design changes, use of obsolete drawings, revising drawings and inadequate quantity of drawings in the satellite. In CPPA 39201 dated 6/4/84,

=. _ _ _ - . _ - .

TUGCO made an individual response to each noted deficiency in TCP 99, including implementation of new procedures and additional training.

In April, 1984, the NRC sent a letter to TUGCO containing 24 allegations in the area of document control.

TUGCO's response was contained in two letters TXX-4180 (5/25/84) and TXX-4187 (6/1/84). In its responses, TUGCO discussed each allegation concluding generally that many of the allegations resulted from a lack of proper internal communication.

Cygna Memo (83090.013, 6/30/84) contained recommendations based on an unannounced review of the document control system, including better management of a particular satellite, better control of recipients of documents and improved procedures to assure that recipients of documents keep design change information current.

The NRC's Special Review Team (SRT) issued its findings on 7/13/84 noting weaknesses in the Component Modification and Design Change authorization procedures. The SRT also concluded that the use of a computer system versus stamped drawings referencing DCA's and CMC's was a strength and the use of the drawing control computer appeared to keep craft personnel up-to-date in an expeditious manner. In addition, NRC Inspection Report 84-12 (7/13/84) reviewed the improved process for reproducing drawings and determined that both quality and legibility had improved. Also, the inspector noted no out-of-date drawings were found in work areas.

On 1/8/85, the NRC letter to TUGCO identified the TRT concerns regarding document control. Following the formation of the CPRT, ISAP VII.A.3. (Document Control),

ISAP III.d (Preoperational Testing) and ISAP VII.c (Construction Reinspection / Documentation Review Plan) were

- issued to address the TRT findings.

(TRT ISSUE: MATERIAL TRACEABILITY)

At page 0-176 of SSER 11 dated May, 1985, the TRT stated:

Based on its review, the TRT concludes that the allegation that TUEC failed to maintain material traceability for safety-related material for numerous hardware components prior to October 1981, was substantiated. TUEC did have procedures for material traceability, as required by 10 CFR 50, Appendix B Criterion VIII; however, TUEC did not follow these procedures, resulting in a partial breakdown in the QA program.

Although corrective actions were taken and were documented (NCRs M-3303 and M-3258) in accordance with TUEC QA procedure CP-QAP-8,5, TUEC failed to report this partial breakdown to the NRC per 10 CFR 50.55(e) requirements.

4 Permittees believe that the issue of material traceability as identified by the TRT was first raised by Brown & Root QA in a Corrective Action Request, CAR S-41 dated 6/9/80. CAR S-41 identified significant generic problems in the implementation of procedural and i

A specification requirements for hangers, some of which involved inadequate traceability. This CAR resulted from Brown & Root QA Surveillance Report S-009, which also precipitated the issuance of two Nonconformance Reports (NCR's). NCR M-2325 involved hanger pipe, sleeves and stanchion material with identification and traceability problems. NCR M-2359 involved, in part, traceability of loose hardware. Both NCR's were closed after procedures were proposed and actions implemented to establish and maintain traceability. (NCR M-2325 closed on 8/15/80, NCR M-2359 closed 11/23/80). An analysis of the twenty-four hanger related NCR's listed in CAR S-41 revealed that approximately ten were due to inadeguate material traceability. CAR-41 was closed on 1/28/81 when Brown &

Root verified implementation of corrective and preventive actions which included segregation of ASME materials from other safety related materials and use of mechanically marked heat numbers. (Brown & Root Memo IM-19464, 12/17/80).

TUGCO issued Audit Report TCP-13 on July 25, 1980, in which several deficiencies in material traceability were noted,i.e., valve serial numbers being incorrectly listed on

(

l Weld Data Cards, incorrect identification band on pipe spool, missing heat numbers and incorrect marking of

hangers. On October 8, 1980, TUSI Memo CPPA-6787 proposed corrective and preventive action for the TCP-13 l

deficiencies. Proposed actions included revisions in l

u

procedures and personnel reinstruction. TUGCO considered the proposed corrective actions acceptable and in Memo QTN-329, dated 11/25/80, noted acceptance.

In another TUGCO Audit Report, TCP-15, issued on 10/23/80, TUGCO QA identified a deficiency involving the marking of miscellaneous structural steel. The TUGCO response included corrective action to properly identify and b

mark the steel and preventive action through employee instruction and revision of Construction Procedure CCP-21.

?- These responsive measures were approved in TUGCO Memo QTN-338 dated 12/8/80.

Brown & Root issued Nonconformance Report M-2762 on 4/16/81 governing the valve serial number problem identified in TCP-13. In order to resolve the incorrect installation of the valve, the incorrect valve was removed, the correct valve with proper serial number welded in place.

Additionally, Pipe Department personnel were provided further assistance to aid in identifying valve serial numbers which are assigned to specific locations. This NCR was closed on 6/9/81. TUSI memo CPPA-11363, of 7/17/81, also provided a follow-up response to TCP-13 and outlined specific control procedures and documentation to assure adequate positive identification in the designation, issuance and installation of valves.

The American Society of Mechanical Engineers (ASME) conducted a Boiler and Pressure Vessel Code survey of CPSES between October 12 and 14, 1981. ASME issued its report to

Brown & Root on 11/23/81. The ASME Survey Team noted many deficiencies in the area of material traceability including:

(1) inadequate control of material salvaged from vendor-supplied components; (2) survey and qualification of vendors was inadequate; (3) Brown & Root had divided materials and transferred the material identification incorrectly; and (4) Brown & Root had not verified the transfer of material identification. Because of the many deficiencies identified by the Survey Team in the Brown &

Root QA program, ASME delayed Brown & Root's recertification until appropriate corrective action was taken.

On 10/14/81, Brown & Root issued NCR M-2971 to address the inadequate identification of plate material noted by ASME. The ASME Survey prompted a written response to ASME in which both corrective and preventive action were proposed to address the deficiencies found (1/14/82). Receipt of this response from Brown & Root is noted in a 3/19/82 letter from ASME. The letter also confirmed ASME's resurvey during January 18-20, 1982, and recognized that deficiencies with respect to identification and control of materials were in programmatic control. The letter also reissued appropriate ASME Certificates of Authorization and Code Symbol Stamps.

j In a follow-up response dated 3/25/82, Brown & Root provided a time table for completion of responses to unclosed deficiencies specified in the ASME Survey. The letter stated that NCR M-3131 (1/15/82) addresses the deficiency i related to salvaging of component supports by establishing a l

I

procedural hold on all salvage material operations pending receipt of proper documentation and by developing QA Procedure QI-QAP-11.1-36 to control salvage material issuance. In addition, the response indicated that a Special Task Force was developed to review all component support packages to assure material identification and traceability of items actually installed with respect to the required vendor documentation.

On April 2, 1982, TUGCO QA issued a Monitoring Discrepancy Report (MDR 81-070) which involved an improper heat number being transferred and marked for hanger material. Corrective action involved removal of the unacceptably identified hanger material and replacement consistent with Procedural Requirement QI-QAP-11.1-28, Revision 9, paragraph 3.1.1. This corrective action was accomplished on 4/14/82.

TUGCO Audit Report TCP-63, issued on 2/8/83, observed that stamped steel marking of compressor units was inconsistent. In a 6/17/83 TUGCO Memo (TSU-83171),

corrective action was stated to be replacement of the incorrect identification. This response was determined to be acceptable per TUGCO Memo QTN-733 (7/19/83).

TUGCO QA issued Corrective Action Request CAR-20 on 3/18/83. Item No. 3 of the request involved Safeguard Sequence cards being received without serial number traceability. TUGCO office memo TUQ-1740 on 7/19/83 evaluated the CAR-20 response, finding TUGCO actions and

procedures to maintain unique identification of cards satisfactory. Accordingly, the CAR was closed.

l Brown & Root QA issued Corrective Action Request CAR-S-55 involving a missing hanger mark number on a seismic support for the fuel pool heat exchanger on 5/20/83. On 5/27/83 TUSI Memo CPPA-30,871 provided information on the cause of, and proposed corrective action for, CAR-S-55. On 8/2/82, both TUSI and Brown & Root proposed corrective action which included proper identification of the hanger part and entry of correct information into the ASME program designed to assist in material traceability.

T During TUGCO's Audit TCP-111, completed on 8/24/84, I TUGCO QA verified implementation of material traceability corrective actions related to the audits discussed herein, including TCP-13, TCP-15 and TCP-63. Their verifications are documented in TUGCO office memos QXX-2024, QXX-2023 and QXX-2017 respectively.

On 1/8/85, the TRT notified TUGCO of the TRT findings with regard to material traceability. Subsequently CPRT was formed and ISAP VII.a.1 (Material Traceability), ISAP VII.b.3 (Pipe Support Inspections), ISAP VII.a.2 (Nonconformance and Corrective Action Systems) and ISAP VII.c (Construction Reinspection / Documentation Review Plan) were issued to respond to the TRT findings.

(TRT ISSUE: PIPE SUPPORT INSPECTIONS)

At pages 0-282 and 0-293 of SSER 11 dated May, 1985, the TRT stated:

The TRT conducted a series of inspections encompassing as-built safety related pipe support . . .

installations. These inspections were of completed systems or components that had been previously inspected and accepted by TUEC QC as meeting the respective construction and installation requirements.

Pipe Support Inspections Of the 42 pipe supports inspected, 37 were randomly selected, while 5 originated from an alleger's list.

Fourty-six deficiencies were identified in the supports inspected.

Permittees believe that their first notice of any issue relating to pipe support inspections was on September 4, 1981 through the issuance of an advance report on NRC Inspection No. 81-83. During the course of NRC Region IV's inspection, an unresolved item was identified in that the 4

NRC inspector felt that there were a number of QC accepted supports (especially sway struts) that needed adjustment.

The sequence of events regarding pipe support inspections that confirmed as-built configurations starts with the development of the applicable inspection programs.

Procedure QI-QAP-11.1-28 Rev.O was issued on 09/08/80 to support the beginning phases of ASME Class 1, 2 and 3 component support fabrication, installation and inspection.

This procedure contained the basic criteria for inspection of all attributes regarding ASME component support installation and acceptance. Included was a configuration check, material verification, weld acceptance and nondestructive examination, as applicable.

Based on requirements set forth in NRC 1E Bulletin No. 79-14, Rev.1 to procedure CP-EI-4.5-1 (General Program for As-Built Verification) was issued on 04/27/81. This procedure was to establish methods for performance of As-Built Verification of all safety related piping 2-1/2 inches in diameter and greater, and to Seismic Category 1 piping, regardless of size which was dynamically analyzed by computer. Included in this verification was support location and type. The intent of this procedure was to provide a vehicle for verification of stress analysis based on the As-Built configuration. It was not intended to be a reverification of previous inspections performed during construction and final acceptance of the included pipe supports.

Following the NRC Region IV Inspection 81-13, procedure QI-QP-11.13-1 Rev. 1 (As-Built Piping Verification Instructions) was issued on 09/17/81. This procedure provided instructions to the Quality Assurance As-Built Coordinator for verification of stress problem packages per procedure CP-EI-4.5-1. The instructions also provided details on sway strut inspection.

On 10/22/81, procedure QI-QP-11.13-2 Rev.O (Installation Reinspection of Pipe Supports) was issued which committed CPSES to a reinspection program for all i

~ . _ _ . . . , _ _ _ _ __ _ __ _ _ _ .- _ _ _ _ _ _ _ _ . - _ _ _

Class 1, 2, 3, and 5 pipe supports. Based on the issuance of this procedure, the NRC Region IV closed Inspection Report 81-13 while performing a routine inspection under Inspection Report IR-81-18. (01/25/82).

During the course of ASME pipe support fabrication and installation, the Authorized Nuclear Inspector (ANI).

performed numerous audits on the CPSES ASME program to ensure compliance with all ASME requirements. On 10/14/82, SIS Report no. 314 was generated based on the ANI review of field assembly work which had been performed. Per this inspection, the ANI determined that the final review hanger packages being presented for his review and acceptance were deficient. They did not comply with NA-4540 of the ASME Code, the ANI stated, in that: "the status of material verification and visual examination of welds is indeterminate. The actual scope of rework performed is not defined or described by drawings, CMC, IRN or any other document within the package. Since all QC inspections are final there is not objective evidence available that the QC inspector was aware of the extent of examination and verfication to be performed."

Brown & Root Interoffice Memo No. 35-1195, dated 11/20/82, was issued by the Procurement / Surveillance Supervisor to the Lead Authorized Nuclear Inspector providing Brown & Root's response to SIS Report No. 314.

This memo proposed that: (1) the construction operation required and the work scope will be listed on the Weld Data

Card so that the ANI will_have an understanding of the extent of work involved; (2) effective 12/1/83, the QC inspector shall indicate the revision number of the drawing used for a hanger inspection; and (3) the Document Review Group (DRG) will assist the ANI in ascertaining the applicable revisions of the drawings used for past inspection. Subsequently, based on further review, SIS Report No. 314 was closed out by the ANI in SIS Report No.

314, Attachment 10 (acceptance dated 11/29/82).

Due largely to the multiple design reviews conducted on pipe supports, Engineering and QA determined that the most logical time for QA to evaluate the final acceptability of a pipe support, without a large probability of subsequent design change, was following the iterative design review process. As a result of a meeting held in January, 1983, Engineering and Quality Assurance implemented a Vendor Certified / Design Reviewed Drawing (VCD/DRD) program through the issuance of Revision 4 to procedure CP-QAP-12.1 (Inspection Criteria and Documentation Requirements Prior to System N-5 Certification). The VCD/DRD program resulted in a support drawing into which all design changes had been incorporated. Additionally, Engineering would annotate the drawing to show changes which had been made to the design which they wanted reverified by QA.

Within a few weeks of implementing the QA VCD/DRD inspection however, it was identified that Engineering Nas increasing the size requirements of many welds as a result

.I !

of final analysis and that some existing welds had been ground by the paint department to obtain a satisfactory coating profile, which reduced the weld below the acceptable level. Due to the determination that work being reviewed ,

under the VCD/DRD program was still "in-process," previously accepted items were not considered finally accepted, hence this was not considered a reportable condition under 10 CFR 50.55(e).

As a result, the QA checklist contained in Revision 5 of CP-QAP-12.1 was revised in March, 1983, to reinspect all accessible welds, including those on supports previously accepted under the VCD/DRD program. Additionally, the VCD/DRD flow was revised to require construction to verify support acceptability prior to submitting the support to QA-for final acceptance.

A construction appraisal inspection was performed by the NRC Region IV during the period of January 24 through February 4, and February 14 through March 3, 1983, for the purpose of evaluating management control of construction activities and the quality at CPSES. On 04/11/83, based on NRC Region IV Construction Appraisal Team Inspection 50/445/83-18 and 50/446/83-12, potential Notice of Violations were issued to TUGCO inclusive of issues 3 regarding pipe supports and their inspection.

In response to the Construction Appraisal Team i

inspection,Section III.B.2, Interoffice Memos from the Brown & Root Site QA Manager to the TUGCO Site QA Manager a

44 -

were generated (05/02/83). These memos related the Brown &

Root Site QA Manager's position relative to the items of deficiency alleged to have been found by the NRC. A follow-up inspection was performed by the NRC Region IV during the period of June 27 through September 16, 1983, for the purpose of assessing the " Potential Enforcement Findings" noted during the Construction Appraisal Team's inspection as documented in NRC Inspection Report 83-18 and 83-12. In the area of pipe supports and their inspections, the B&R and TUGCO review of the previously identified Construction Appraisal Team findings included discussions with the ANI. The fact that none of the supports had been finally inspected per CP-QAP-12.1 indicated to B&R and TUGCO that the program was functioning as intended. This item was subsequently considered to be closed per NRC Region IV Inspection Report 83-28/83-14 dated October 3, 1983.

During the months of May and June, 1983, a special NRC 3 inspection was conducted of the Fuel Building. During the O 't , course of this inspection several areas of concern were identified related to the inspection of pipe supports. The 4

results of Region IV's inspection was documented on Inspection Report 83-23 dated 07/27/83. Notice of Violations were cited in the area of both large and small bore ASME supports. Deviations from the VCD were noted on the large bore supports. Further deviation from the final design documents for small bore supports were also noted.

An open item was also noted regarding completed Class 5

support traveler packages whi~ch did not contain the current drawings, inspection reports and CMC's. An interoffice memo from the Brown & Root Site QA Manager to the TUGCO Site QA Manager (08/23/83) was generated regarding corrective actions taken for ASME components cited in NRC Inspection Report 83-23. Also, TUGCO letter TXX-4031 was issued on 08/24/83 to the NRC Region IV detailing actions taken on ASME large bore supports found to be in noncompliance during the NRC inspection documented per IR 83-23.

On 08/31/83, TUGCO letter TXX-4037 was issued to NRC Region IV regarding the remainder of the items cited in the Notice of Violation associated with IR 83-23. In this response, TUGCO stated their conclusion in that, per their estimate, there would have been no safety significance had 1 these items gone undetected. It was further stated that no improvements appeared necessary in the QA/QC program although minor changes to inspection procedures and checklists had been made based on the concerns noted in NRC IR 83-23. (Subsequently, based on inspections performed by NRC. Region IV during the period of August - October 1984, NRC Inspection Report 84-34/84-13 (dated 12/31/84) reviewed and documented the elesure of those violations regarding pipe supports as listed in IR 83-23.)

Prior to the closure of these issues, however, during the month of April, 1984, the NRC fielded a Special Review Team for the purpose of: evaluating current implementation of TUGCO's management control of construction, inspection 4

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and test programs; gaining an indepth understanding and obtaining background information regarding CPSES; and

, further obtaining information necessary to establish a management plan for resolution of all outstanding regulatory actions. During the course of this review, issues concerning discrepancies found on completed vendor certified pipe supports were again identified. On 07/13/84, NRC Regien IV issued these review findings to TUGCO and stated that the results had identified a number of actions which were to be followed-up by the Technical Review Team which had been established pursuant to the management plan.

Additional NRC inspections were performed during the period of May - July 1984 which identified problems in the pipe support area regarding as-built dimensions being out of tolerance. These findings were contained in NRC Region IV Inspection Report 84-22/84-07 dated 10/11/84. Also included was a Notice of Violation regarding several subjects inclusive of pipe support as-built configuration problems.

In response to IR 84-22/84-07, Interoffice Memo No. 27986 (11/07/84) was generated by the Brown & Root Site QA Manager to TUGCO QA relating their response to the finding of discrepant as-built dimensions (i.e., per support i

SI-1-071-002-532K). The response contained a history of drawing and procedural changes which had occurred relative to this particular support.

TUGCO letter TXX-4354 (11/09/84) was issued to the NRC Region IV providing responses to the Notice of Violation

issued with NRC IR 84-22/84-07. The response regarding the as-built dimension problems outlined the fact that one item (center line location of the I-beam) was causing the other aspects of the baseplate to be incorrectly identified as out of tolerance. TUGCO further identified issuance of NCR-M-14557N which had been reviewed by Engineering and accepted as is.

0n 01/08/85, the NRC letter to TUGCO provided written notification of the concerns of the TRT regarding inspections performed on pipe supports. Following the formation of the CPRT, Issue Specific Action Plan (ISAP)

VII,b.3 (Pipe Support Inspections) was issued to address the specified findings of the TRT in regard to inspections of pipe supports.

(TRT ISSUE: HILTI ANCHOR BOLT INSTALLATION)

The TRT inspected Hilti anchor bolt installation on pipe supports and electrical raceway supports for conformity to the requirements of QI-QP-ll.2-1, Installation of Hilti Drilled-In Bolts.

At pages 0-293 and 0-298 of SSER 11 dated May, 1985, the TRT found the following discrepancies during its inspection:

"Hilti Kwik" bolts (concrete expansion anchors) as installed did not meet the minimum embedment requirements. . . .

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Electrical Raceway Support Inspections CTS-6742 (Auxiliary Building) anchor bolt torque was not verified (paragraph 3.5 of the procedure).

Hilti bolts were not marked in accordance with Attachment 1 of the procedure, nor was the length of these bolts verifiable (paragraph 3.2).

CTS-5824 (Containment Building) base plate bolt holes had violated minimum edge, distance-edge distance cannot be less than 1 7/8" (Attachment 2 of the procedure). Actual distance was 1 5/8" to 1 3/8" from the nearest plate. This condition affected five of the eight Hilti anchor bolt holes in the base plates for this hanger.

One Hilti bolt was skewed to more than 15 degrees.

Maximum allowable skew was 6 degrees without corrective bevel washers (paragraph 3.1.2).

The Hilti bolt torque on this hanger CTS-6741 (Auxiliary Building) was not documented as being verified by QC (paragraph 3.5).

Permittees believe that their first notice of the potential for a systemic problem regarding Hilti anchor bolt installations occurred during the time period between November, 1979 and December, 1980. It was during this period of construction activity at CPSES that four (4)

SDAR's were issued by TUGCO identifying potential deficiencies involving Hilti bolts. These four SDAR's were documented as follows:

SDAR 79-08 November 11, 1979 Separation Between Embedded Anchors and Expansion Anchor Bolts SDAR 80-05 July 1, 1980 Hilti Bolts In Area With Two (2) Inch Topping SDAR 80-10 September 30, 1980 Hilti Bolts For Conduit Supports SDAR 80-12 December 16, 1980 Reduced Performance Of One (1) Inch Diameter Hilti Kwik Anchor Bolts .

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Through early 1978, the vast majority of expansion anchor applications at CPSES were temporary or for construction use only. Consequently, there were no comprehensive procedures or quality programs for these anchors and a variety of manufacturers' bolts were being used. On March 28, 1978, Gibbs & Hill issued Specification 2323-SS-29, " Installation and Testing of. Drilled-In Expansion Bolts," to TUSI for their review and comment.

Having reviewed this and other design documents, TUSI returned the specification and stated that expansion anchors would be furnished per the data in the design documents and procured from Hilti, Inc. as a sole source. Brown & Root then developed a quality control program and a procedure for the installation of the anchors in conjunction with the manufacturer instructions (Instruction 35-1195-CEI-20 dated.

06/01/78, " Installation of Hilti Drilled-In Bolts").

During the next six months, various correspondence was exchanged between Hilti, Inc., Brown & Root, Gibbs & Hill and TUGCO regarding specific aspects of Hilti bolt installations. Included in this exchange was information providing clarification on such items as torque values, anchor spacing, re-threading (Hilti Letter VBR-8962 dated 09/25/78); a general outline of Hilti bolt installation requirements (Hilti Letter of 09/25/78); request for clarification of information regarding installation of Hilti bolts (Brown & Root Letter, QCEE-37 dated 11/17/78); details for the spacing requirements of Hilti to Hilti and Hilti to

Richmond Insert (TUGCO Letter CPPA-00398 dated 12/01/78);

and request for confirmation of the guidelines to be used in installing Hilti bolts near unused holes (Brown & Root Letter BRV-8894 dated 01/1779).

On 01/18/79, TUGCO memo TUQ-595, generated the initial issuance of QI-QP-11.3-13, " Inspection of Hilti Drilled-In Bolts" which replaced the criteria in Brown & Root Instruction 35-1195-CEI-20 regarding inspection. Shortly thereafter, the issuance of the aforementioned SDAR's predicated specific action and response on behalf of various parties associated with the use of Hilti Bolts at CPSES.

Those actions, as per the respective SDAR, were provided as follows:

SDAR 79-08 This report was initiated (11/06/79) by TUGCO QA upon the discovery that the requirements pertaining to the minimum spacing of Hilti bolts to other concrete inserts was deleted from Specification 35-1195-CEI-20, (" Installation of Hilti Drilled-In Bolts"). This could cause a possible reduction in anchor bolt capacity. The procedural problem created by this deletion, however, had been corrected in June, 1979 as verified by transmittal TXX-3125 dated I 04/21/80 to the NRC from TUGCO. The procedural problem therefore applied to a time span of September, 1978 to June, 1979 with September, 1978 being the point in time at which Hilti, Inc. provided clarification on torque values, anchor spacing (i.e., subject in question for this SDAR),

i re-threading, etc. to Brown & Root (VGR-8962 dated 1 09/25/78).

A survey of all building areas at CPSES was performed to identify locations of Hilti bolts violating the revised separation criteria in accordance with Instruction 35-1195-CEI-20. The results of this survey were furnished to the design groups for their evaluation and action.

Rework "as-required" was to be implemented by these respective groups.

Subsequently, the final report on SDAR 79-08 was initiated by TUGCO (CPP-5150, dated 06/15/81). This report provided a description of the deficiency, its safety implication, corrective actions taken, and resolution of discrepancies.

SDAR 80-05 This report was initiated (07/01/80) by TUGCO QA and stated that the anchor bolt design as presented by Revision 5 to Instruction 35-1195-CEI-20 was inconsistent in accounting for the two (2) inch architectural concrete topping. (Revision 5 to the anchor bolt installation procedure was issued on 01/10/80 and added a section l addressing the embedment depth calculation in areas with two (2) inch concrete topping).

i CPP-273 (dated 07/03/80) documented pull-out tests of Hilti bolts installed in an area with two (2) inch topping.

I Likewise, a report on core drilling samples (CPP-277 dated 07/14/80) taken at the site of the pull-out tests (CPP-273) i

verified that topping / slab separation was apparent.

Accordingly, TUGCO issued TXX-3171, dated 08/08/80, to the NRC, which reported the deficiency as required by 10 CFR 50.55(e). On 08/22/80, CPP-291, was generated by TUSI Project Civil Engineering. CPP-291 requested a survey and evaluation, by all departments involved, of all Hilti bolts in areas with two (2) inch architectural concrete.

Following appropriate evaluations and revisions by the respective departments, the final report on SDAR 80-05 was issued by TUGCO (CPP-10950) on 06/26/81. Accordingly, on 01/25/82, the NRC responded to TUGCO that the item "Embedment of Anchor Bolts Through Floor Topping" was considered closed.

SDAR 80-10 This report was initiated (09/30/80) by TUGCO QA following notification from Brown & Root that an allegation and confession had been received from a site employee regarding the altering of Hilti Kwik bolts. Verbal notification of the issuance of this SDAR was provided to the resident NRC Inspector on 10/01/80.

In response to the SDAR, TUGCO submitted interim reports' to the NRC on October 21, 1980, January 12, 1981, April 15, 1981 and a final report on December 4, 1981. This final report, TXX-3442, provided a discussion of corrective actions that were developed as part of the evaluation of i deficiencies resulting from unauthorized field modifications of Hilti Kwik concrete anchor bolts during installation.

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The report provided a Summary of Ultrasonic Testing (UT) that was performed on Hilti bolts to establish that their actua1' installed lengths were consistent with a code letter designation on the end of the bolt and in compliance with design requirements. of the approximately 50 anchor bolts which were examined, two (2) were identified by UT as being shorter than required.

The report went further to explain that in order to ascertain whether additional problems existed with Hilti bolts, Brown & Root instituted a detailed UT program which was performed by the Brown & Root Quality Engineering Group.

The program consisted of a statistically sound sampling program for those Hilti bolts installed according to functional craft disciplines. In conclusion, the report stated that Brown & Root construction management, as part of their corrective action, emphasized to the craft personnel that any unauthorized modification or alteration to permanent plan components would result in disciplinary action. Accordingly, on 1/25/82, the NRC closed this SDAR.

SDAR 80-12 This report was initiated (12/16/80) by TUGCO QA following a change by Hilti, Inc. in the design values (tensile strength) of its one (1) inch diameter anchor bolt.

A subsequent review by all appropriate construction departments was initiated, including evaluation to determine if the deficiency (i.e., change in design values) was reportable under the provisions of 10 CFR 50.55(e). In i

addition, various communications were exchanged between TUGCO, Gibbs & Hill and Hilti, Inc. regarding this matter during the next two months, including a meeting on 01/15/81 between the three parties and TUSI. The results of this exchange was a transmittal by Gibbs & Hill (GTT-7748 dated 04/23/81) to TUGCO which provided a recommendation on the use of reduced capacities for one (1) inch diameter Hilti Kwik bolts.

Following this submittal, a response from TUGCO Project Engineer (CPPA-9678 dated 05/01/81) indicated that based on the input from Gibbs & Hill, closure of SDAR 80-12 is recommended, since designs completed to date are acceptable "as-is."

On 08/31/81, via letter TXX-3398, TUGCO notified the NRC that it had been concluded that the condition (i.e., design changes in the tensile strength of one (1) inch Hilti bolts) was not a significant deficiency under the provisions of 10 CFR 50.55(e) and therefore was not reportable. A response of the NRC was received by TUGCO (Region IV Inspection

! Report 445/81-14, 446/81-14) on October 30, 1981, stating that "the matter is considered closed."

On 01/08/85, however, following an on-site audit by the NRC TRT, TUGCO was advised by an NRC letter of specific deficiencies regarding Hilti anchor bolt installation.

l Following formation of the CPRT, an Issue-Specific Action Plan (ISAP) VII.b.4 (Hilti Anchor Bolt Installation) was i

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issued to address the TRT findings related to deficiencies in Hilti anchor bolt installations.

(TRT ISSUE: NONCONFORMANCE, CORRECTIVE ACTION AND 50.55(e) REPORTING At page 0-303 of SSER 11 dated May, 1985, the TRT made the following findings concerning the Permittees' Nonconformance System:

The-TUEC procedure for preparation and processing of NCRs did not contain explicit instructions for handling voided NCRs.

NCRs were used as a tracking document to record removal of a part from equipment on a permanent equipment transfer rather than for reporting a nonconforming condition; such usage of the NCR was not defined in procedures.

There was an inconsistency between paragraphs 2.1 and 3.2.1 in procedure CP-QP-16.0.

Paragraph 2.1 required all site employees to report nonconformances to their supervisor or to the Site QA supervisor, while paragraph 3.2.1 required persons other than QA or QC personnel to submit a draft NCR to the Paper Flow Group.

The NCR form had no form number or revision date to indicate that the form was being adequately controlled.

There were two versions of the TUEC NCR form, one with and one without a space for the Authorized Nuclear Inspection (ANI) review.

The NCR form had no space to identify the cause of the nonconformance and the steps taken to prevent its recurrence.

The NCR form has no provision for quality assurance review.

The TRT found approximately 40 different forms (other than NCRs) for recording deficiencies. Many of these forms and reports were not considered in trending nonconforming conditions; ano at page 0-287:

The TRT notes that TUEC did not initiate an NCR identifying the widespread problem of missing locknuts; only a Request for Field Information was generated; and at page 0-300:

Deficiency reporting procedure CP-EP-16.3 appeared to relate only to Craft and Engineering personnel and was not directed to noncraft and nonengineer personnel who may have had knowledge of reportable items.

Procedure CP-EP-16.3 indicated that the applicable manager was responsible for documenting and reporting Deficiency and Disposition Reports (DDRs); but there were no checks or balances to ensure that a manager or a designated substitute would process a DDR.

At page 0-279 of SSER 11, the TRT made the following findings regarding Permittees' Corrective Action programs:

Repetitive NCRs were issued that identified the need to retrain construction personnel in the requirements and contents of QA procedures. One corrective action request (CAR) dealing with inadequate construction training and records remained open for one year. The identical problem was identified in a subsequent CAR, which still had not been closed at the time of the TRT onsite review; and at Page 0-280:

l The Brown & Root corrective action system was generally ineffective and was bypassed by the Brown & Root QA Manager, as exemplified in the following instances:

There were no definitive instructions to describe the types of problems that required corrective action. Minimal

I procedural instructions resulted in corrective action decisions I frequently being left to the I judgment of the QA Manager.

l Since June 1983, Brown & Root had l issued no Corrective Action Requests (CARS), and was substituting memos and letters of concern for this function. This shortcut has become a regular method of operation and appeared to bypass the CAR system.

The TUEC corrective action system was poorly structured and ineffective in that:

Controlling procedures were brief and general.

There was no translation of FSAR requirements on trending and no details on how trend analysis were to be accomplished.

Quarterly reports were not issued in a timely manner.

The method of categorizing problems by building did not assure meaningful trend analysis.

A 1984 CAR report identified three items requiring action; however, none had been taken.

CAR 029 was used as a vehicle for a specific disposition rather than for generic action, as intended by the CAR system.

At page 0-279 and 280 of SSER 11, the TRT made the following findings concerning Permittees' 10 CFR 50.55(e)

Reporting System:

There were potential weaknesses in the TUEC 10 CFR 50.55(e) deficiency reporting system.

Applicable procedures did not identify what types of deficiencies constituted significant breakdowns in the QA program, nor how they should be evaluated for reportability to the

NRC. Evaluation guidelines for reporting hardware deficiencies lacked clarity and definitive instructions and the threshold for reporting deficiencies was too high; and at page 0-287:

The TRT found examples in Unit 1 where deficiencies existed so that TUEC was in potential violation of the codes, procedures, guidelines, and commitments concerning locking devices for threaded fasteners. In spite of the requirements pursuant to 10 CFR 50.55(e)(1), TUEC did not report to the NRC the omission of thread-locking devices in the Unit I nuclear safety systems and did not attempt corrective action until May 1984, when TUEC tested previously applied paint for thread-lock capability. That test was inconclusive, since it did not establish that the paint, an epoxy process, would reliably perform as an effective locking device under all service conditions throughout the expected lifetime of the plant. Further, TUEC could not identify to the TRT which paint was the subject of testing; and at page 0-300:

TUEC did not consider Cygna audit findings regarding the DCC as appropriate for formal reporting to the NRC pursuant to 10 CFR 50.55(e), as required by procedure CP-EP-16.3, " Control of Reportable Deficiencies;"

and at page 0-303:

TUEC failed to maintain material traceability for safety-related material and numerous hardware components. This QA breakdown was identified in an ASME Code survey in October, 1981 yet was not reported to the NRC in accordance with the requirements of 10 CFR 50.55(e).

The foregoing TRT findings, first specified in the TRT letter of January 8, 1985, were presented separately and may be grouped categorically as: Nonconformance Reporting System, Corrective Action Systems and 10CFR50.55(e) l i

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Reporting. The issues these findings raise regarding TUEC's method for documenting, correcting and reporting deficiencies are highly related and Permittees find it appropriate to answer the interrogatories for each finding

.under the heading of a single TRT issue. The-following responses have been prepared in accordance with the TRT's general identification of its findings.

Nonconformance Reporting Si n Permittees believe that they first received notice of the issues regarding systemic deficiencies in the nonconformance reporting system in the May 17, 1978 Management Analysis Company Report (MAC). The report, prepared for TUGCO, found that the dispositioning of nonconforming items did not always achieve the requisite review by appropriately qualified design personnel. In addition, MAC noted that the design change / design deviation program had been used to bypass the nonconformance reporting system. In an internal TUGCO response to management dated

, 5/17/78, the report's conclusions were reviewed and corrective action was deemed unnecessary.

On 8/25/78, NRC Inspection Report 78-12 noted that cable tray supports, identified on a Nonconformance Report (NCR),

were not adequately tagged and segregated. This was cited-as a violation of 10 CFR 50, Appendix B. TUGCO, in a 9/21/78 letter to the NRC (TXX-2881), outlined both corrective and preventive actions in response to IR 78-12.

These actions included a review with field supervisory

personnel of non-conformance reporting requirements found in CP-QAP-15.1 and additional training regarding the-procedure used in controlling nonconforming items at CPSES. On November 6, 1978, TUGCO provided a supplemental response (TXX-2901) to the NRC findings in IR 78-12 explaining in greater detail TUGCO actions to avoid further non-compliances which included enhanced surveillance by Site QA.

The NRC issued Inspection Report 79-19 and a Notice of Violation on 8/10/79 citing a failure to adequately disposition NCR E-1570 and to identify and segregate nonconforming electrical cable. TUGCO submitted a response to IR 79-19 on 9/27/79, (TXX-3049) citing amendments to instructions and procedures and correction of improperly installed cables. Also noted was that "added emphasis will be placed in the established ongoing site training program to assure that QC Supervisory personnel fully understand the need for proper identification of nonconforming conditions and have a basic understanding of applicable QA criteria..."

Brown & Root Quality Assurance Audit Report CP-16 (12/6/79) identified deficiencies in the NCR and Correction Action (CA) program related to inadequate procedure for reportin; nonconformances and to the apparent failure of person.. I to follow NCR/CA reporting procedures. In March, 1980, Brown & Root Memo IM-18790 responded to the Audit CP-16 concerns. While recognizing that the existing reporting system provided sufficient resolution,

identification, correction and prevention of deficient conditions, Brown & Root specified changes in procedures to more adequately provide both corrective and preventive action.

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In NRC Inspection Report 80-08 (4/13/80) and related Notice of Violation, Permittees were cited for failure to follow procedures for reporting and repair of damaged electrical cable (Brown & Root Procedure 35-1195-eel-13).

The original cable damage and repair should have been reported via a Field Deficiency Report but was not. On May 14, 1980, TUGCO submitted a response to NRC Inspection Report 80-08 (TXX-3142) in which it outlined the corrective action that had been taken through replacement of all damaged cable and additional training stressing procedure compliance. The NRC reported IR 80-08 closed on 6/17/80.

The NRC issued Inspection Report 80-22 on January 21, 1961, in which the results of its staff investigation during September and November, 1980, were released. One of the allegations reviewed was that the Brown & Root QA Department was not ensuring that corrective action was being taken regarding document nonconformances. The NRC in IR 80-22 found this allegation to be unsubstantiated, so also was an associated allegation that a TUGCO QA auditor had instructed that waivers be prepared on nonconforming components.

On June 19, 1981, in its First Quarter Corrective Action Report (TUQ-902), TUGCO Quality Engineering noted in this trend analysis report that they were observing

safety-related field requisitions ordering replacement materials which had been damaged in the field.

Investigation had determined that NCR's were not being issued in all cases.

TUGCO Audit TCP-25 identified one concern associated with a lack of procedures to resolve document deficiencies noted by a receiving inspector. In the TUSI response of 12/10/81 to TCP-25, it was observed that the informal methods effectively used in resolving document deficiencies would'be incorporated into written procedures (CP-EP-16.0).

This response was confirmed as satisfactory on 12/14/81 (QTN-461).

On 12/9/81, TUGCO Audit TCP-28 identified a deficiency

'in the nonconformance reporting system whereby temporary-waiver tags were not approved by appropriate personnel.

TUGCO's Audit Report TCP-28 dated 1/7/82 reviewed specific corrective action taken by TUGCO including a review of all NCR's requesting a temporary waiver. Preventive action was specified in TUQ-1027 to reorientate appropriate personnel with the nonconformance procedures concerning signature authority on temporary waiver tags.

Corrective Action Request S-46, dated 1/15/82, noted that Component Modification Cards had been incorrectly used to resolve deficiencies instead of as prescribed by Nonconformance Procedure QI-QAP-16.1-2 and 16.6.3. In response to CAR S-46, field engineering personnel were informed of the QA Manual requirements for the documenting 1

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of nonconforming items and this instruction was confirmed in writing on 2/11/82.

During June, July and September, 1982 ASLB hearing transcripts reveal that issues related to the NCR process were explored in testimony presented covering the area of Quality Control / Quality Assurance at CPSES.

Site Inspection Service 310 prepared.by Hartford Steam Boiler (9/15/82) identified the improper use of Field Deficiency Reports (FDR) to document nonconforming l

conditions. TUGCO's response of 10/7/82 included revising <

l CP-QAP-16 to delete the option of utilizing FDR's for the reporting of minor nonconforming conditions, a review of all FDR's for possible code violations and if required the issuance of NCR's. Site Inspection Service 310 was closed on 12/14/82.

On September 17, 1982, TUGCO Audit Report TCP-48 noted that QA Procedure CP-QAP-16.1., Rev. 11, " Control of Nonconforming Materials," did not provide for reporting of non-ASME related nonconformances, yet Brown & Root QC personnel were reporting some non-ASME nonconformances in accordance with the procedure. This inconsistency was addressed by Brown & Root on 10/20/82 through amendment of Procedure CP-QAP-16.1 to include nonconformances associated with safety related Class 1, 2 and 3 activities. This Audit was closed on 2/2/83 upon verification that corrective action was completed.

Brown & Root Correction Action Request S-50, dated 10/22/82, reviewed five NCR's which identified rework of nonconforming items prior to completion of their

^ disposition. TUGCO provided a response to CAR S-50 on 11/3/82 and the CAR was verified as closed on 11/21/82.

TUGCO Audit Report TCP-57 dated 11/1/82 observed that the as-built verification group was not utilizing the NCR form to identify inconsistencies between design requirements and as-built conditions. The auditors stated that their primary concern was the existence of technically inconsistant procedural requirements and not inadequate implementation of the NCR program. The TUGCO response advised that QI-QP-11.13-1 had been revised to resolve the auditors' concerns. The revision deleted the requirement that NCR's were to be generated during the QA as-built Survey and additional revisions provided for notation of inconsistencies in an alternative manner.

On 11/16/82 and 2/4/83, (TUQ-1472; TUQ-1546) TUGCO QA/QC provided direction to inspection personnel on documenting nonconforming conditions utilizing inspection reports.

Inspection personnel were required to report all discrepant conditions on an unsatisfactory Inspection Report in l

l accordance with CP-CP18.0 with the exception of material / items which are damaged after final QC acceptance.

Corrective Action Request CAR-20 issued on 3/18/83 identified numerous instances of defective circuit boards discovered during prerequisite or preoperational testing,

none of which had been documented by an NCR or Test Deficiency Report (TDR) (TUQ-1585). On March 20, 1983 TUGCO proposed corrective action through issuance of TDR-797 to evaluate all vendor repairs and modifications which may have been made on the defective boards and began immediately to document all circuit board failures in accordance with the TDR System specified in Procedure CP-SAP-16. Preventive action included additional training for all Startup Testing Engineers associated with circuit card testing and pursuant to Startup Memo SU-83186 (3/17/83) to more clearly define Test Deficiency Reporting of unidentifiable or defective circuit cards. Pursuant to TUGCO. Memo TUQ-1740, the CAR-20 response was deemed satisfactory and on 7/19/83 was closed.

On 6/9/83, Corrective Action Request CAR-029 was issued when rework on a nonconforming item (valve) was completed prior to disposition of the NCR and without removal of the hold tag by QC inspection prior to performance of rework.

Since CAR-029 identified discrepancies in violation of TUGCO quality assurance procedures for the control of nonconformances, the TUGCO response TSU-83174 (6/27/83) specified corrective action to properly document the disassembly, QC inspection and proper valve reassembly.

TSU-83174 also outlined preventive action involving i reinstruction of System Test Engineers in applicable nonconforming procedures. The CAR-029 response was considered satisfactory and. closed on 7/1/83 (TUQ-1723).

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The NRC sent a Notice of Violation to TUGCO on 7/11/83 arising out of NRC Inspection Report 83-15/83-09. The Notice of Violation resulted from an instance of base metal repair not having been documented on an NCR in violation of NCR procedure. TUGCO responded on July 29, 1983, (TUQ-1745) that the Notice of Violation had resulted in corrective action through the issuance of NCR-M-6611 (5/7/83) documenting the. base metal repair and that all applicable documents.have the NCR appropriately referenced. TUGCO outlined corrective measures resulting from the Notice of Violation in a letter to the NRC (TXX-4020).

Due to a trend analysis identifying 62 NCR's issued for procedural violations, i.e., failure to obtain authorization to perform work, failure to notify QC for hold points and for violation of QC hold tags, Corrective Action Request CAR-032 was issued on 8/17/83. Brown & Root's analysis of the violations noted in CAR-032 indicated that the problem l

was most prominent in the Electrical Department, therefore, 1

corrective and preventive action was focused primarily in that area. Other areas were identified as being affected only on an isolated basis. In a memo to TUGCO QA, the Brown

& Root General Electrical Superintendent stated that disciplinary action would be taken if procedures were intentionally ignored or ignored due to negligence.

I Further, supervisors were reminded of their responsibility to make sure personnel were properly indoctrinated in

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s

- procedural requirements. 'On 10/24/83 , CAR-032_ response was determied to be acceptable (TUQ-1839).

During'~the period 1/24/83 through 3/3/83, the NRC's Construction Appraisal Team (CAT) conducted its inspection of CPSES. On 4/11/83, CAT issued its findings. In the CAT Report it was noted that nonconforming conditions identified relative to some safety-related hardware installations were not being properly documented, evaluated and dispositioned-through the_ Corrective Action Program. The NRC's Region IV conducted a follow-up inspection to the CAT appraisal during the period June 27 through September 16, 1983. This

, inspection was documented in NRC Inspection Reports 50-445/83-16 and 50-446/83-12. In the.IR, the NRC inspector noted-that he was " unable to identify any area where a

- discrepancy, deviation, or nonconforming condition, once 4

identified, regardless of method of documentation, that was not properly tracked, corrected, and inspected." The NRC IR further stated that with respect to CAT potential findings regarding improper dispositions of nonconforming conditions, Lthis was addressed in the NRC follow-up inspection and was considered closed. (NRC letter, 10/3/83)

TUGCO Audit Report TCP-87 (12/27/83) was issued covering the construction /QC nonconformance and corrective action program. The audit identified several program deficiencies including: (1) an NCR procedure which did not adequately describe control of deviation forms with generic NCRs; (2) several hold tag identification problems; and (3) on r

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several instruments in the field, the actual installation was different than' identified on NCR's applicable to these instruments. TUGCO responded to TCP-87 on 1/31/84, (TUQ-1933) explaining the basis for audit conclusions and citing corrective action where appropriate. On May 3, 1984,  ;

l (QTO-708) the TUGCO responses were evaluated and accepted. I In TUGCO Audit TCP-103 dated 6/4/84, TUGCO QA identified an instance of failure to identify non-Class IE material as nonconforming in compliance with ANSI N45.2-1971,Section I

16, " Nonconforming Items" and further that improper documentation was used to allow installation of nonconforming items. TUGCO's response of 6/21/84 (CPPA-39,492) and 6/27/84, (TUQ-2254) noted that all nonconforming materials had been replaced and appropriate documentation provided.

-The NRC's Special Review Team (SRT) conducted a review of CPSES during the period April 3 through 13, 1984. One of the SRT findings (Item E.b(8)) identified two pipe supports which had not been installed as specified in detailed drawings, yet had been inspected by QC without identification of the nonconformance. The TUGCO response dated 9/7/84, (QBC 84) stated that appropriate NCR's had been issued following the SRT report (NCR 13,384 and NCR 13,349) and that corrective action resolving both NCR's had been completed. Additonal emphasis was also placed on complying with procedures controlling disassembly of component parts (Procedure CP-CPM-6.10).

During July, 1984, TUGCO QA issued Audit TCP-105 (7/20/84) citing an instance where a nonconforming material

, condition had not been identified on an NCR. The TUGCO letter TUQ-2298 (8/17/84) provided a QA response to TCP-105 NCR concerns which indicated an engineering evaluation had been performed and documented regarding the nonconformance, (CPP-2642) and that a Significant Deficiency Analysis Report (SDAR 80-1) had been prepared (QTN-984, 10/24/84).

The NRC issued Inspection Report 84-34/84-13 on 12/31/84 citing an SRT identified failure of QA inspection to identify nonconformances in support installations.

On 1/8/85, the TRT notified TUGCO of the TRT findings with regard to the Nonconformance Reporting System.

Subsequently CPRT was formed and ISAP VII.a.2 (Nonconformance, Corrective Action's and 10 CFR 50.55(e))

was issued to respond to the TRT findings.

Corrective Action Programs In order to properly assess and identify Permittees' first notice with respect to the TRT findings regarding Corrective Action programs as contained in the TRT letter of January 8, 1985, it should be noted that the CPSES Corrective Action Programs (CA) was actually composed of two systems: The TUGCO CA and the Brown & Root CA. The Corrective Action programs were used by Brown & Root and TUGCO to identify recurrent or significant conditions adverse to quality and to cause corrective and preventive actions to be initiated. The TRT review determined that the

CA procedures issued by Brown & Root and TUGCO to control their respective CA systems contained provisions for-performing both the trend analysis and the corrective action functions. The Brown & Root procedures extended from Mid-1975 to the present time. TUGCO procedures were first issued in 1980 and also extend to the present time period.

Prior to 1980, TUGCO utilized Brown & Root procedures for addressing corrective action concerns.

Permittees believe, in the context just reviewed, that the NRC's Construction Appraisal Team (CAT) Inspection Report of-4/11/83 was their first notice of the issues concerning Corrective Action Systems. However, it can conceivably be urged, based upon the evolutionary dichotomy of the two CA programs reviewed hereinabove, that first notice of the_TRT findings with respect to the Brown & Root CA Program came on November 18, 1977, with the issuance of Site Surveillance Report G-062-77. This report identified a number of deficiencies in compliance with the procedural requirements for Corrective Action Requests (CAR) including failure to follow up action and/or verification of I corrective action and failure to comply with CAR reply due dates. Brown & Root provided a response to the Site Surveillance Report on 12/9/77 (BRQ-0768) which included a reevaluation of the Brown & Root response to the potentially reportable event and instruction of personnel on nonconformance procedures. Site Surveillance Report G-06'2'-77 was closed on 12/30/77.

s .

On Decemb,er'6,' 1979, Brown'& Root Audit Report CP-16 identified several concerns in the area of corrective.

action. Specifically noted was a lack of site QA Manager review of numerous corrective action documents and a failure to comply with procedures which required reports that summarized'and trended nonconformance and corrective actions. Brown & Root provided response to CP-16 on 3/20/80-l which included changes in the recponibility of the QA Manager and improvements in the CA reporting process related to procedures QAM 15.11, QAM 16.3 and CP-QAP-15.1.3.6.

Audit CP-16 was closed on 11/5/81. (CPQ 0441)

' The June and July,'1982 ASLB Hearings transcripts reveal that issues'related to the nonconformance program and correctiveactionprogramwerediscussbd. (Transcript pp.

727, 1676-1680).

As previously noted, the CAT Inspection Report was issued on 4/11/82. (TUQ-1620, 4/10/83) The primary corrective action concern of CAT was that nonconforming. >

conditions'were being processed through various programs and cwere not being evaluated under the Corrective Action program. The Brown & Root Memo of 5/3/83 concluded hhat responsive measures to CAT had already been taken and that the CA programs were in compliance with FSAR commitments and regulatory requirements.

The NRC inspection conducted between May 23, 1983 and June 10, 1983,-(NRC Inspection 83-23) concluded with the issuance of a citation as a result of the alleged inadequacy r,

of procedures for the installation and inspection of NPSI

-c seismic sway strut jam nuts to insure snugness. A Brown &

Root memo dated 8/19/83 outlined the procedures applicable

'to tightening of jam nuts and concluded that revisions to s

procedural checklists QC N-5 of CP-QAP-12.1 and QC Component Support Checklist of CP-QAP-12.1 should adequately prevent recurrence of the problem noted in the citation. TXX-4031 dated 8/24/83 provided the TUGCO response to Inspection Report 83-23.

TUGCO Audit TCP-87 was issued on 12/27/83 and identified a deficiency in the Corrective Action program. The audit concluded that corrective action procedure did not adequately provide a mechanism to document corrective action related requests, responses, and follow-up. The audit report noted that documentation practice itself was in effect, but that the practice had nc ' ,een defined procedurally. On 1/31/84, TUQ-1933 provided the TUGCO comments on Audit TCP-87. This response was reviewed by TUGCO QA and accepted based on the review of CP-QP-17.01, Rev. 3 as adequately addressing TSAR requirements. On 3/14/84 this issue was closed. (QTQ-642, 3/14/84)

NRC Inspection 84-03/84-01 identified as an unresolved item " CAR procedure could be improved and better defined in the area of independent-reviews, immediate attention to specific matters, follow-up and distribution to upper management." In TUQ-1966, issued on 3/14/84, TUGCO states that revisions to CP-QP 17.0 will be made to improve

distribution of CAR documentation. Subsequent to this response, the NRC issued a letter on 4/23/84 cancelling NRC Inspection 84-03/84-01.

On 7/23/84, NRC Inspection Report 84-12/84-06 reviewed documentation associated with Significant Deficiency Analysis Reports including compliance with NRC requirements for reporting, corrective action, appropriate evaluation, timeliness for reporting and completion of documentation.

The documentation was found to meet all requirements.

On 1/8/85, the TRT notified TUGCO of the TRT findings with regard to Corrective Action Programs. Subsequently, CPRT was formed and ISAP VII.a.2 (Nonconformance, Corrective Actions and 10 CFR 50.55(e)) was issued to respond to the TRT findings.

10 CFR 50.55(e)-

Permittees believe that the NRC Inspection Report 80-08 and Notice of Violation issued on April 2, 1980, constitutes first notice of the 50.55(e) Reporting issues identified by the TRT. The NRC's Notice of Violation cited TUGCO's failure to report a significant construction deficiency in that they failed to provide interim or a final report on concrete honeycomb investigations and evaluations conducted during the period December, 1979 to April 1980. On April 21, 1980, TUCCO provided a response to the NRC (TXX-3129) in which it noted, contrary to the NRC's Notice statement, that the Resident Inspector (Region IV) had received information verbally during the period for which the deficiency had been identified. Corrective steps outlined in the letters included a review of 10 CFR 50.55(e) requirements for written reports, clarification of the requirement at a meeting with NRC personnel and discussion of the requirements with appropriate personnel. NRC Inspection Report 80-11 issued on 6/17/80 closed the Notice of Violation reported in IT 80-08.

On 6/16/80 TUGCO issued Memo TUQ-716 indicating a need for supervisory personnel to repeat indoctrination efforts on procedures followed in reporting significant construction deficiencies, CP-QP-16.1; Rev 3, with particular emphasis on timeliness of reporting.

The ASLB Hearing transcript of 7/27/83 notes testimony by the NRC touching upon the reporting of items under 10 CFR

l l

50.55(e). Related issues.were also noted in the ASLB transcript for hearings on 6/16/83.

The NRC Inspection Report 84-03/84-01 dated 2/14/84 noted as a finding that nonconformance reporting procedure did not discuss review of NCR's for possible escalation to 50.55(e). The TUGCO response of 3/14/84 (TUQ-1965) stated that CP-QP-16.0 would be revised to incorporate evaluation of NCR's for potential escalation to 50.55(e).

The NRC Inspection Report 84-22/84-07 (10/11/84) and related Notice of Violation cited the fact that between February and May, 1983, Permittees identified a common failure in three out of four of Unit 1 safety-related inverters that necessitated a modification to the ferroresonant output transformer in each of the inverters, but the failures were not reported to the NRC until February of 1984. TUGCO answered Notice of Violation 84-22/84-07 on November 11, 1984 (TXX-4354), the response contained a chronological schedule of the events explaining TUGCO's procedural response to the deficiency including the 1

January 16, 1984 Deficiency Report (SDAR-CR-84-04). It was represented that the particular issue identified in the Inspection Report was controlled in accordance with the CPSES program for identification and resolution of deficiencies observed in the construction and testing phase.

On 1/8/85, the TRT notified TUGCO of the TRT findings i

with regard to 50.55(e) reporting. Subsequently, CPRT was formed and ISAP VII.a.2 (Nonconformance, Corrective Actions

and 10 CFR-50.55(e)) was issued to respond to the TRT findings.

(TRT ISSUE: AUDIT PROGRAM AND AUDITOR QUALIFICATION):

At pages P-33 through P-34 of SSER 11, dated May, 1985, the TRT summarized its concerns in the area of Quality Assurance auditing. With regard to the audit program and auditor qualification the TRT concluded:

. . . the QA audit and reporting program has had and continues to exhibit deficiencies. Over a significant period of time, recurring deficiencies include:

inadequate staffing during peak periods; . . .

procedural and implementation inadequacies; questionable qualifications and capabilities; incomplete assessment of the QA program on an annual basis; inadequate corrective action to prevent recurrence of identified deficiencies . . . In summation, the [TRT) QA/QC Group finds the past audit and reporting system less than adequate, and the audit and reporting program at the time of TRT review was questionable.

The Permittees received first notice of the precise issues regarding deficiencies in the audit program during the conduct of a management evaluation of the TUGCO QA organization performed by an outside consultant, Fred Lobbin, during December 1981 and January 1982. This evaluation was initiated by the TUGCO Vice President, Nuclear to determine, through a qualified third party, the overall effectiveness of the QA department in carrying out its responsibilities on the CPSES project.

The report, issued 02/04/82, identified the Audit Program as one of five areas reviewed. Included were

findings concerning number and scope of audits, level of QA staff nuclear experience, staffing levels, procedure for audit planning and scheduling, and content of reports.

Upon receipt of the Lobbin report, TUGCO documented actions already underway to address the findings. With'the exception of a procedure revision to better define the. audit planning and scheduling process, actions were already underway prior to the Lobbin evaluation concerning increased staffing, obtaining nuclear experience, increasing the number and scope of audits and expanding report content.

(Interoffice memorandum QBC-18 dated 02/23/82).

Quarterly progress reports were provided to the Vice President, Nuclear from the Manager, Quality Assurance on the status of actions taken with regard to the Lobbin Report. The first progress report, dated 05/24/82, included the addition of four senior level auditors with forty-seven years of nuclear and QA experience, audit schedule implementation, procedure revisions, and audit report content changes. The second, and final, quarterly report was issued on 08/31/82, and contained closeout actions.

(Interoffice memorandum QBC-25 and QBC-29).

Prior to the Lobbin evaluation, review by the NRC and outside consultants found the audit program to be generally adequate with only minor exceptions. During AEC inspection 73-02 which was conducted in lieu of the standard pre-docketing inspection, the AEC noted that "[a]lthough TUSI has a viable audit program and two audits have already 78 -

i

been conducted, the implementing procedure in the CPSES Quality Assurance Plan (4.0) does not address" certain requirements of ANSI N45.2.12 (draft) concerning audit personnel qualifications / training. (AEC Inspection Report 73-02 dated 01/07/74).

In response, TUSI provided corrective action by revising the QA procedures to address the AEC's concerns. (TUSI letter TXX-174 dated 02/21/74). The AEC verified implementation and adequacy of the corrective actions and closed the item in Inspection Report 74-01 dated 03/19/74.

In May 1978, Management Analysis Corporation (MAC) noted in their report that 24% of TU audits were behind schedule.

They also stated in Section XVIII, Audits, that "the auditors consider the present program (audit) to be an effective tool which could be further improved. TUGCO should consider combining the audit and surveillance activities into a single, cohesive effort. Such an integrated effort could cover required areas more efficiently, without duplication and at a frequency that can be maintained. . . ." TU reviewed the MAC finding and determined no corrective actions were necessary. The changes in the audit schedule were appropriate to allow the audit schedule to be more responsive to changing equipment manufacturing status and to allow use of audits to investigate problem areas. (MAC Report dated 05/17/78 and TU Internal memorandum Gary & Fikar to Brittain dated 07/11/78).

x In December, ~978, the NRC conducted a midterm QA inspection of CPSES. The inspection included audits and concluded that "each of the eighteen quality assurance criteria of Appendix B were reviewed on an annual basis or more frequently." The report further stated that audit records reviewed indicated findings were consistently corrected and followed up. No adverse findings were identified. (NRC Inspection Report 78-23 dated 01/05/79).

Routine inspections performed during 1980 and 1981 by the NRC continued to find the TU audit program adequate.

(NRC Inspection Reports 80-04 dated 02/29/80, 80-09 dated 04/07/80, 80-17 dated 07/31/80 and 81-20 dated 04/09/82).

Subsequent to the Lobbin evaluation, TUGCO completed a self-initiated evaluation of the Design and Construction phase activities of CPSES. The evaluation, performed by Sargent & Lundy utilizing INPO criteria, included an assessment of the audit program. The evaluation concluded that the audit activity was "well staffed, well managad and well supported by management." Sargent & Lundy found no

" identifiable weaknesses" and that the " level of activity

[was] adequate to more -%an comply with regulatory requirements." (Self-Initiated Evaluation Report dated 12/02/82).

Also in 1982, during an inspection conducted November 22-24, 1982 of TUGCO vendor control activities, the NRC identified a violation concerning a lack of documented audit plans for four vendor audits and a lack of corrective action verification of two deficiencies during a subsequent vendor audit. (NRC Inspection Report 82-25/13 dated

, 02/28/83).

TUGCO responded to the NRC Inspection Report with appropriate corrective and preventive actions. The actions included a review and update of the files, performance of an audit and a procedure revision. (TUGCO Letter TXX-3650 dated 03/30/83).

TUGCO's actions were reviewed and the violation was closed by the NRC via Inspection Report 84-34/13 dated 12/31/84.

The NRC conducted a construction appraisal inspection at CPSES January 24 - March 3, 1983. The inspection was broad in scope and addressed construction phase activities, including the audit program. Two potential enforcement findings were identifed which concerned the audit program.

The findings were: (1) QA audits have not been conducted at a frequency or at sufficient depth to identify and correct significant problems in various areas (HVAC and electrical separation) and (2) audit findings related to maintenance identified in 1979, 1981 and 1982 were not resolved in a timely manner. In addition, one program weakness was noted concerning the audit program, which stated that the Permittees' QA program should have been more effective in detecting and obtaining correction of deficiencies in safety related work, such as HVAC, mechanical equipment and

r.

A, if

. electrical. components. (NRC Inspection Report 83-18/12 4

dated 04/11/83).

Upon receipt of the CAT report,.TUGCO QA prepared an internal evaluation and response to the findings. The response addressed specific actions with regard to the HVAC

. subcontractor findings, including increases in audit frequency (two audits had already been performed) and use of 4

t qualified weld inspectors on the audits. In addition, other subcontractors were audited with no similar problems

! identified. The response noted that electrical separation-had not been determined to be a significant problem. It had 4

previously been audited and found to be adequately addressed both programmatically and in implementation, therefore no further action was planned. With regard to the issue of timeliness of corrective action, the response stated that

' the three cited audits were of different organizations, during-different timeframes and that their only similarity was that of the subject: maintenance. TUGCO felt that contrary to the CAT statement, TUGCO's audit program had resulted in problems being identified and resolved and that audits in the maintenance area would continue to assess the adequacy and effectiveness of the maintenance program. The response went on to state that "no other examples were identified that would substantiate the conclusion stated in the CAT report that the corrective action system for audits is not effective." (emphasis added) No corrective or preventive action was determined to be appropriate.

4 '

l l

(Interoffice memorandums QTQ-298 dated 03/83, QTQ-331 dated 05/02/83 and QTQ-335 dated 05/05/83).

Upon initial evaluation of the CAT Report, NRC Region IV issued four notices of violation, including one on the HVAC issue. The violation, as cited by the Region included, along with the technical aspects of the deficiency, one item concerning the audit program. It stated that the permittees' audits and assessments of the subcontractor's control of quality failed to identify deficiencies with the HVAC hardware. TUGCO responded to the notice of violation and committed to the increased frequency of audits (on a quarterly basis), placing additional emphasis on welding activities and configuration control, and the use of certified welding inspectors as appropriate. The NRC determined these actions to be acceptable to resolve the deficiency. (NRC Letter dated 05/31/83, Interoffice memorandum QTQ-345 dated 06/02/83, TUGCO Letter TXX-3996 dated 06/28/83 and NRC Letter dated 07/11/83).

The NRC conducted the Region IV followup to the CAT inspection to further evaluate the potential enforcement findings. Within the scope of the inspection, no new violations or deviations were identified. In the area of the audit program, the Region IV inspector did not concur with the two potential findings concerning the audit program and determined the items to be closed with no further actions required. (NRC Inspection Report 83-28 dated 10/28/83).

The NRC performed a special inspection of the Fuel Building completion proc.ess from May 23 - June 10, 1983.

(Inspection Report 83-23 dated 07/27/83). This was the first inspection of the turnover / access control process and was'the NRC's initial effort with regard to construction completion. QA audit activities relating to the turnover process were included in the evaluation. The report included an unresolved item which noted that a general inspection of the Fuel Building had been performed by the QA Department, but that it was not documented as a formal audit. TUGCO resolved the item by performance of a formal audit of the Fuel Building. The NRC subsequently closed the item during an inspection (84-16 dated 10/04/84) in which they reviewed four audits which had been conducted of the room / area turnover process.

The NRC performed a special review at CPSES on April 4-13, 1984. The review was performed by NRC Region II personnel. The purpose of the review was to: 1) evaluate the current implementation of the applicant's management control of the construction, inspection and test programs;

2) provide an in-depth understanding and background information to the NRC management team established by the Executive Director of Operations; and 3) obtain information necessary to establAch a management plan for resolution of all outstanding regulatory actions. The overall conclusion was that TU's management controls were " generally effective" and that the programs were "being sufficiently controlled to m____ _ _-.--

allow continued plant construction while the NRC completes its review and inspection of the facility." The report identified three potential enforcement findings, one of which concerned a failure to perform vendor audits at a specified periodic frequency. Two specific examples were given. With regard to the Internal Audit Program, however, the report concluded that "TUGCO Corporate Management, site QA/QC and engineering audit activities are acceptable" based on a review of the implemented audit program to verify whether it meets the requirements of the accepted QA program and ANSI N45.2.12. The report also stated, "the qualifications of auditors and lead auditors were verified to be in accordance with the requirements of ANSI N45.2.23-1978." (SRT Report dated 07/13/84).

TUGCO addressed the potential enforcement finding by submitting an FSAR change request to establish an audit and evaluation frequency for vendors. This request utilized the guidance of NRC Regulatory Guide 1.144 concerning an acceptable method of vendor audit /evaulation frequency. In addition, all vendors were scheduled for evaluation, with audits scheduled as required in accordance with the change to the FSAR. (Interoffice memorandums QBC-84 dated 09/07/84 and QBC-102 dated 12/06/84).

As part of CYGNA's Design Assessment Program Phase 3, CYGNA evaluated the TUGCO audit activities as they relate to design. During the course of their evaluation, they reviewed 133 audits performed by TUGCO. Two observations,

T dated 07/16/84, were identified concerning: (1) a lack of objective evidence that TUGCO had received a corrective action response to two audit findings; and (2) a lack of objective evidence of the status of audit findings from six audits. Both findings were resolved and closed at the time of issuance of the Phase 3 report. (CYGNA Phase 3 Report).

During NRC inspection 84-32/11 conducted August 20 through September 20, 1984, the audit program was evaluated.

As a result of the inspection a notice of violation was issued on 02/15/85 concerning scheduling and performance of audits, staffing, and procedural inadequacies. The results of this inspection were also included in SSER 11.

On 01/08/85 the TRT notified TUGCO of the TRT findings with regard to the audit program. Subsequently, CPRT was formed and ISAP VII.a.4 (Audit Program and Auditor Qualification) was issued to respond to the TRT findings.

(TRT ISSUE: PERIODIC REVIEW OF QUALITY ASSURANCE PROGRAM)

At pages p-33-4 of SSER 11, dated May, 1985, the TRT found:

TUEC management had failed to periodically review the status and adequacy of their QA program. This was confirmed by Region IV (IR 50-445/84-32). TUEC representatives stated that there have been no regular assessments or reviews of the adequacy of the total QA program by upper management, as required in Criterion II of 10 CFR 50, Appendix B, and as committed in the ESAR;...

the QA audit and reporting program has had and continues to exhibit deficiencies. Over a significant period of time, recurring deficiencies include:... failure by mangement to review the QA program for effectiveness; procedural and implementation inadequacies;... and insufficient management direction and understanding.

and at page 0-234:

Based on interviews with TUEC QA management and reviews of QA audit reports, the TRT concludes with no independent management audits of TUEC's QA program at CPSES were conducted.

Permittees believe that the specific issue of periodic review of the QA Program, as discussed by the TRT, was first identified during the conduct of the NRC Region IV inspection undertaken in August and September, 1984, that resulted in the publication of Inspection Report IR 50-445/84-32 dated 2/15/85.

Prior to the formal publication of IR 50-445/84-32, the TRT published its finding's on periodic review of the QA Program in a 1/8/85 letter to TUGCO. On page 1 of an enclosure to the letter entitled " Technical Review Team Finding's Resulting From Quality Assurance / Quality Control Allegations" (also reference page 0-279 of SSER 11 dated May 1985) the TRT concludes:

That although the TUEC QA program documentation met NRC requirements, the weaknesses of its implementation in several aress demonstrate that TUEC lacked the commitment to aggressively implement an effective QA/QC program in several areas:

A. TUEC failed to periodically assess the overall effectiveness of the site QA program in that there have been no regular reviews of program

.i' adequacy by senior management.

Further, TUEC did:not. assess the effectiveness of its QC inspection program.

Permittees' response to the TRT findings regarding-management review of the QA Program was the: formation of CPRT and issuance ofLISAP VIII.a.5 (Periodic Review of QA-Program).

.In addition, Permittee's response to IR 50-445/84-32 was published on February 2, 1987, in a letter to the NRC (TXX-6144). Page 1 of the Attachment to TXX-6144, under the caption " Failure to Regulary Review the Status and Adequacy of The QA Program,". states in part as follows:

TUGCO acknowledges that procedures were not established for the regular review of the status and adequacy of the construction quality assurance (QA) program.

Notwithstanding this lack of procedures, it is TUGCO's view that managers and corporate officers'by virtue of their day to day involvement were aware of the status and adequacy of the construction QA program.

That awareness was based on various practices employed by TUGCO managers and officers during the history of CPSES to evaluate the QA program. Those practices included the use of quality' committees, documented management review, and independent evaluations. In addition, these' managers and officers routinely received a variety of reports concerning the adequacy of the construction QA program such as TUGCO QA internal audit

• reports and reports produced by independent personnel from outside of the TUGCO organization.

Management review of QA was an on-going and evolving program at CPSES. As early as 1973, the AEC evaluated CPSES' still unfinalized QA plan through a special, -

announced inspection of TUSI quality assurance activities.

i

l This' inspection took the place of t e standard pre-docketing inspection. The Inspection Report noted that "The CPSES )

Quality Assurance Plan requires the Manager, Quality Assurance to review the status of the quality assurance program with the TUSI President at least quarterly" and that the first review meeting was held on October 10, 1973 with the next meeting scheduled for January, 1974. The Inspection Report also contained two findings which pertained to periodic review of the QA program. The two findings dealt with a lack of procedures and written guidance for conduct of the management review process. (AEC IR 73-02 dated 01/07/74). While it can conveivably be urged that this AEC report was Permittees' first notice of any potential concern of issues regarding review of the QA program, Permittees note that this AEC inspection was prior to commencement of construction, and the findings were aimed at providing guidance to TUSI in its formulation of a final QA program.

During the next Quarterly Review held between the Manager, Quality Assurance and the TUSI President on 01/04/74, the findings from the AEC Incpection Report 73-02 were discussed, including analysis and schedule to accomplish corrective actions. Also discussed was the intent to change the charter of the existing Quality Surveillance Committee (QSC) to become reoriented as a TUSI management QA committee. (Interoffice memo dated 01/11/74, Manager, QA to President, TUSI).

6

TUSI's corrective action response to the AEC included changing QA program documents and procedures to revise the function of the Quality Surveillance Committee and provided procedural guidance for the conduct of the reviews. The AEC found the TUSI response adequate and closed the findings during subsequent inspections. (AEC IR 74-01 dated 03/19/74 1

and IR 74-02 dated 07/11/74). The Quality Surveillance Committee met regularly during 1974 through the first quarter 1978.

During the conduct of NRC Inspections 76-08 and 76-09 conducted in July and August, 1976, the NRC expressed ,

concerns with the functioning of TUSI management to resolve problems identified by site personnel. These concerns were discussed by TUSI management during two QSC meetings

(

(QPB-24, 8/27/76 and QPB-25, 9/2/76) and between NRC and TUSI management during a meeting at Region IV on 9/3/76. No specific violations were issued by the NRC, however, TU provided to the NRC actions taken to strengthen management control of the project, including better utilization of the QSC. No further required actions were identified by the NRC. (QPB-26 dated 10/12/76).

In May, 1978, a management audit was performed by the Management Analysis Corporation at TU's request. During the audit, Quality Surveillance Committee Activities were reviewed. No adverse findings were identified in the area of management review, however, under the heading of "potentially improved practice," Recommendation No. 3

\

concerned the Quality: Surveillance Committee. The report

-noted th at the Committee appeared to be functioning more in 1

the role of a task force or problem solving group and that management awareness of the QA program could be handled more-effectively and efficiently through a monthly QA progress report ~to management. (MAC-JPJ-471 dated 05/17/78).

Permittees understood the MAC findings not to be critical of the frequency or nonexistence of management overview of QA, but rather that MAC was recommending _ ways in which such ongoing review could be improved.

TU's internal response to the MAC Report dated July 11, 1978, stated that the Quality Surveillance Committee would be discontinued and a report issued quarterly by the TUGCO QA Manager to keep top management apprised of the status of QA matters. The'necessary changes were made to the QA Program documents and an FSAR change was submitted on 08/14/78. The NRC requested clarification regarding who would be handling the functions previously assigned to the QSC and the change in frequency from monthly to quarterly review with Senior Management. TUGCO responded by pointing out that the QA Manager would handle the QSC responsibilities and that his reviews with Senior Management would be on a regular basis, but not less than quarterly.

The NRC approved these changes on 11/03/78.

The management review of the QA program was not questioned again until the conduct of NRC Inspection 1

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Report 84-32 conducted between August 20 - September 20, 1984.

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William S. Eggel fg Ropes & Gray J - e.

225 Franklin ee Boston, MA 02110-(617)423-6100 i

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SIGNATURE I, L. Ed Powell, bei'ng first duly sworn, do depose and say Manager, Administration of the Generating that I am Division of TU Electric, that I am familiar with the information contained in the CPSES files, that I have assisted in the preparation of the foregoing answers, and that the foregoing answers are true, except insofar as they are based on information that is available to TU Electric but not within my personal knowledge, as to which I, based on such information, believe them to be true.

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Ed Powell Sworn to before me this 13th day, of April, 1987:

', h>= - =; .=J Notary Public

' My Commission Expires: 5//2./So

@ED CORRESPONDENCE DOLKETEC CERTIFICATE OF SERVICE USNPC I, William S.

Eggeling, herebycertifythatongr g, 9,g, I made service of the within document by mailing copies thereof, OFFIE DF -i.u:t! A h postage prepaid, to: 00CHETiHG c. 3ERV!CE BRANCW Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.

Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory P.O. Box 38 Commission Glen Rose, Texas 76043 Washington, D.C. 20555 Dr. Walter H. Jordan Ms. Billie Pirner Garde Administrative Judge Midwest Office 881 W. Outer Drive 3424 N. Marcos Lane Oak Ridge, Tennessee 37830 Appleton, WI 54911 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

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Lawrence J. Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20555

Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O. Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C. 20555 Anthony Roisman, Esquire Mr. Lanny A. Sinkin Suite 600 Christic Institute 1401 New York Ave., N.W. 1324 North Capitol Street Washington, D.C. 20005 Washington, D.C. 20002 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Esq.

Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O. Box X, Building 3500 U.O. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20555 Nancy Williams Cygna Energy Services, Inc.

101 California Street Suite 1000 San Francisco, California 94111

. T William S. gelipg

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