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| {{Adams
| | #REDIRECT [[IR 05000445/1987002]] |
| | number = ML20236M401
| |
| | issue date = 04/17/1987
| |
| | title = Package Consisting of 870417 Request for Premium Cost Mail Svc & Unsigned & Undated Ltr to Util Forwarding Draft Insp Repts 50-445/87-02 & 50-446/87-02 & Notice of Deviation
| |
| | author name =
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| | author affiliation = NRC
| |
| | addressee name =
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| | addressee affiliation =
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| | docket = 05000445, 05000446
| |
| | license number =
| |
| | contact person =
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| | case reference number = FOIA-87-446
| |
| | document report number = NUDOCS 8708110050
| |
| | package number = ML20236M375
| |
| | document type = ARCHIVE RECORDS, PACKAGE OF NONCODED MATERIAL
| |
| | page count = 73
| |
| }}
| |
| See also: [[see also::IR 05000445/1987002]]
| |
| | |
| =Text=
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| {{#Wiki_filter:_ _ _ _ _ _ _ _ _ _ _ _ - . . . _ _ _ _
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| U.S. NUCLEAR REGULATORY COMMIS$10N - RE0viRED DE Liv ERv O AYE
| |
| l ( NRC FORM 420 ' "'"
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| l I' (6 82)
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| g { NacM 0255 REQUEST FOR PREMlUM COST MAIL SERVICE
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| I
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| 4/17/87
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| ~
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| [ FROM:g IPgE ER l {ORbAN BON (Of fice. 06 vision, Brang
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| rn o...t uavic...ou reo l l ExPnESS l l ,R iO R ir y l l PRiv ATE DELivERv l IOTsER
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| l [
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| BRIEF DESCRIPTION OF ARTICLE
| |
| I Draft Inspection Report x
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| i MF."^f4?i fli&47'Chfef, Region IV, U.S. Nuclear Regulatory Coeurfssi$it Parkway Central
| |
| "
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| ; Plaza Building, 611 Ryan Plaza Drive, Suite 1000. Arlington, Texas 76011
| |
| JUSTIFICATION F OR SE RVICE REQUESTE D
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| Draft Report Corrections "
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| ai lDA
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| SIGN ATU R E-Oi C R
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| '"%. %n l D ATE
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| '' 8 '
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| '[ ! A lORG
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| DeputyANIZATION
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| Direct (Offhi r[' ivision)DD/CEP b 39
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| ! '
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| P. F. ,
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| ,
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| RETAIN THE REQUESTER COPY, AND M All THE BLUE COPY TO: CHIEF,M All AND MESSENGER BRANCH, FOS, ADM. FOR Mall ROOM USE ONLY.
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| APPROVE D-M AIL AND MESSENGE R AUTsORIZE D OF FICI AL lDATE
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| l
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| l
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| VENOOM l CALL NUMBER
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| Odl W.2 3 9 gy /
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| 6
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| OATE Sy/IPE9 l SIGN ATURE
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| Wil./5 7 6/,L kb d.lb
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| .,
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| REQUESTER CCfY
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| 8708110050 870007
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| PDR FDIA P'DR
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| BAUMAN87-446 ,
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| | |
| -_______ _ _ _ _ _
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| <
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| []
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| o
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| 0001.0.0
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| In Reply Refer To:
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| Dockets: 50-445/87-02
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| 60-446/87-02
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| {
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| TV Electric
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| ATTN: Mr. W. G. Counsil
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| Executive Vice President l
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| '
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| l
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| 400 North Olive Street, L.B. El
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| Dallas, Texas 75201
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| .
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| I
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| i
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| Gentlemen: 1
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| This refers to the inspection conducted by Mr. I. Barnes and other members of
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| the Regicn I" Comanche Peak Group curing the period January 1 through l
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| February 28, 1987, of activities authorized by NRC Construction Permits .
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| CPPR-126 and CPPR-127 for the Comanche Peek Steam Electric Station, Units 1
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| and 2, and to the respective discussions of our findings with you and other
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| members of your staff during and at the conclusion of the inspection. l
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| Arees examined during the inspection were principally Comanche Peak Response
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| Team activities. Within these areas, the inspection consisted of selective
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| examination of procedures and representative records, interviews with
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| personnel, and observations by the inspectors. These findings are docu.nented
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| in the enclosed inspection report.
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| | |
| - _ _ _ _ _ _ _ . ____
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| 0002.0.0
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| ]
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| During this inspection, it was found that certain of your activities appeared
| |
| to deviate from commitments made to the NRC. These items and references to the
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| comitments are identified in the enclosed Notice of Deviation. You are
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| requested to respond to these deviations in writing. Your response should be
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| based on the specifics contained in the Notice of Deviation enclosed with this
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| , letter. 1
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| l
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| I
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| 1
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| l
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| We have also examined actions you have taken with regard to previously j
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| i !
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| identified inspection findings. The status of these items is identified in i
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| il
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| l paragraph 2 of the enclosed report.
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| i
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| l -
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| 1
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| The responses directed by this letter and the accompanying Notice are not l
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| subject to the clearance procedures of the Office of Management and Budget as
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| 1
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| required by the Paperwork Reduction Act of 1980, PL 96-511. l
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| 0003.0.0
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| TU Electric -2-
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| Should you have any questions concerning this inspection, we will be pleased to
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| discuss them with you,
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| i
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| Sincerely,
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| E. H. Johnson, Director
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| Division of Reactor Safety and Frojects
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| Enclosures:
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| 1. Appendix A - Notice of Deviation
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| .
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| 2. Appendix B - NRC Comanche Peak Response Team Activities Inspection
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| 1
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| Report )
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| l
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| 50-445/67-02
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| 50-446/87-02
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| CC:
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| TV Electric
| |
| ATTN: G. S. Keeley, Manager,
| |
| Nuclear Licensing
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| Skyway Tower
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| 400 North Olive Street
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| Lock Box 81
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| Dallas, Texas 75201
| |
| _
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| ,
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| .
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| 0004.0.0
| |
| Juanita Ellis
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| President - CASE
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| 1426 South Polk Street
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| Dallas, Texas 75224
| |
| !
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| Renea Hicks
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| Assistant Attorney General
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| Environmental Protection Division
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| < P.O. Box 12548
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| l Austin, Texas 78711-2548
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| .
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| h
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| ______
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| - _ _ _ _ _ _ _ _ _ _ - _ _ .
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| 0005.0.0
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| TV Electric -3-
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| Administrative Judge Peter Bloch
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| U. S. Nuclear Regulatory Commission
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| Washington, D.C. 20555
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| Elizabeth B. Johnson
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| Administrative Judge
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| Oak Ridge National Laboratory
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| P.O. Box X, Building 3500
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| ! Cak Ridge, Tennessee 37830
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| l
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| l Dr. Kenneth A. McCollom l
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| l
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| 1107 West Knapp
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| '
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| Stillwater, Oklahoma 74075
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| l Dr. Walter H. Jordan
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| 881 Outer Drive
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| '
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| Oak Ridge, Tennessee 37830
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| ~
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| i
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| Anthony Roisman, Esq.
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| Executive Director
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| Trial Lawyers for Public Justice
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| 1000 P. Street, N.W., Suite 611
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| Washington, D.C. 20036
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| Texas Radiation Control Program Director
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| .
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| i
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| 0006.0.0 i
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| bec to DMB (IE01)
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| bec distrib. by RIV:
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| *RFB * MIS System
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| *RRI-OPS *RSTS Operator
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| *RRI-CONS *R&SPB
| |
| *T. F. Westerman, RSB DRSP ,
| |
| V.7.N00r,dn . -NRft--- R. Martin, RA l
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| -S -Trebyr ELD -- *RSB
| |
| *RIV File J. Taylor IE
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| *D. Weiss , LFMB ( AR-2015) 4.= Konkt s n;11E=-.
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| *I. Barnes, CPG
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| *w/766
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| 0007.0.0
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| l
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| APPENDIX A !
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| ;
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| 1
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| NOTICE OF DEVIATION
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| TU Electric Dockets: 50-445/87-02
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| 50-446/87-02
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| Comenche Peak Steam Electric Station, Permits: CPPR-126
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| Units 1 erd 2 CPPR-127
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| Based'on the results of an NRC inspection conducted on January 1 through
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| February 28, 1987, two deviations from commitments were identified. The
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| deviations consisted of several concrete pours not being identified on the
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| Population Items List and documents missing from the Issue-Specific Action Plan
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| (ISAP) VII.c project files. In accordance with the " General Statement of Policy
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| .
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| anc Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1986),
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| the deviations are listed below:
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| 1
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| A. ERC document QA/QC-RT-1628, Revision 1, " Population Items List Concrete
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| Placement." states, in part, that the list ". . . includes all
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| safety-related concrete pours in Unit 1, 2 and areas common to both units."
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| Attachment 6.3 of ERC Procedure CPP-005, Revisicn 3, states, in part, "The
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| responsible QA/QC Discipline Engineer . . . Provides the basis for
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| accepting the list as valid." In addition, "The QA/0C Lead Discipline
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| Engineer and the OA/QC Engineering Supervir,ar review Population Items Lists
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| ,
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| .-..._..-__.__--___._._..___Q
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| 1
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| 1 0008.0.0
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| to ensure that they are complete, accurate, and consistent with the
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| requirements of this procedure." .
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| I
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| In deviation from the above, NRC inspection of the Population Items List
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| for concrete placement revealed the followino discrepancies: l
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| l
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| 1. Pour Nos. 205-9810-039 through 205-9810-056 are shown as block-out
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| type pours in the east diesel generator foundation, Unit 2, on Drawing
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| i
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| SSB-20655, Sheet 1, Revision 5. Pour hos. 205-9810-040 and
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| j
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| 205-9810-048 through 205-9810-056 were not on the Population Items
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| ,
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| List and no corresponding pour cards could be obtained in the TV -
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| Electric Records Center. Pour hos. 205-9810-039 and 205-9810-041
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| through 205-9810-047 were on the Population Items List but were
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| assigned on drawings at least twice and are shown, for example, on
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| Drawings 55B-20605, Sheet 1, Revision 7, and 55B-20618, Sheet 1,
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| Revision 2 to be concrete curbs, removable slabs, etc.; not
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| .
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| block-outs.
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| 2. Pcur No. 205-4822-003 is shown as a shielding wall for the Primary
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| Sampling room on Drawings SSB-20605, Sheet 4A, Revision 0, and
| |
| SSB-20605, Sheet 4, Revision 0. This pour number was not on the
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| Population Items List.
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| The above discrepancies indicate that the Population Items List is not
| |
| entirely complete and accurate and does not include all safety-related
| |
| _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ . _ _ _ _ _ _
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| 0009.0.0
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| !
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| concrete pours. The ERC review of the Population Items List to ensure
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| l
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| accuracy and completeness was inadequate (445/8702-0-02; 446/8702-D-02). l
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| '
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| B. Section 5.3.1 of Revision 2 to ERC Procedure CPP-004, " Project Working
| |
| Files " dated December 17, 1985, for ISAP VII.c states, in part, "The
| |
| Records Administrator shall review each document received for filing fer
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| j
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| physical quality (e.g., reproducibility, legibility, condition) and !
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| l
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| completeness (e.g., number, file location, sequence of attachments, etc.)."
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| !
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| In deviation from the above, NRC inspection of the Population Items List
| |
| " for electrical cable, revealed that the records administrator failed to -
| |
| identify that pages 813 and 814 of the Electrical Management System cable
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| I
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| population listing and the list of Essential and Emergency Lighting
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| circuits were missing from the cable population listing (445/8702-D-03;
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| 446/8702-D-03).
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| .
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| TO Electric is hereby requested to submit to this office within 30 days ot' the
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| date of the letter transmitting this Notice, a written statement or explanation
| |
| in reply, including for each deviation: (1) the reasons for the deviations if
| |
| admitted, (2) the corrective steps which have been taken and the results
| |
| achieved, (3) corrective steps which will be taken to avoid further devi6tions,
| |
| and (4) the date when full compliance will be achieved. Where good cause is
| |
| shown, consideration will be given to extending the response time.
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| - _ _ _ _ _ _ - _ . _ __ _
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| .
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| .
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| 0010.0.0
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| Dated at Arlington, Texas
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| this _, day of . 1987
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| 0011.0.0
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| APPENDIX B
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| NPC COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT
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| U. S. NUCLEAR REGULATORY COMMISSION
| |
| REGION IV
| |
| NRC Inspection Report: 50-445/87-02 Permits: CPPR-126
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| 50-446/87-02 CPPR-127
| |
| , Dockets: 50-445 Category: A2 -
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| 50-446
| |
| .
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| Construction Permit j
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| Expiration Dates:
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| Unit 1: August 1, 1988 , ,
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| Unit 2: August 1, 1987
| |
| Applic6nt: .TV Electric
| |
| Skyway Tower
| |
| 400 North Olive Street
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| Lock Box 81 i
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| Dallas, Texas 75201
| |
| Facility Name: Comanche Peak Steam Electric Station (CPSES),
| |
| Units 1 & 2
| |
| Inspection At: Glen Rcse, Texas
| |
| Inspection Conducted: Jariuary 1 thrcugh February 28, 1987
| |
| ______________-__-_a
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| , ~.] 1
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| 0012.0.0
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| Inspectors: ,,
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| L. E. Ellershaw, Reactor Inspector, Region IV
| |
| CPSES Group
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| Date / '
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| ',
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| (paragraphs 2.a-h, 2.j-n, 2.p, 2.u, 3.b, 4.a. and 4.b)
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| s j '4
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| ,
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| j
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| C. J. Hule, Reactor Inspector, Region IV. Date
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| CPSES Group
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| (paragraphs 2.1, 2.c, 2.s-t, 3.a 3.c, and 5) '
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| '+
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| ,
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| .
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| :
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| E Wagner, Reactor Inspector, Region IV Date
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| CPSES Group
| |
| (paragraphs 2.q-r and 4.a)
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| '
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| ,
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| s
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| Consultants:
| |
| l
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| EG&GA. - J. Dale (paragraphs
| |
| Maughan (paragraphs 2.a.
| |
| 2.q-r2.d-h,
| |
| and 4.a2.j ,)2.1-n, and d.b)
| |
| W. Richins (paragraphs 2.p and 4.a)
| |
| V. Wenczel (paragraph 5.)
| |
| Parameter - J. Birmingham (paragraphs 2.i, 2.0, 2.s-t, 3.a. and'
| |
| 3.c) >
| |
| <
| |
| K. Graham (paragraphs 2.b-c, 2.k. 2.u, and 3.b) - '
| |
| D. Jew (paragraph 4.a)
| |
| ,
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| c
| |
| Feviewed By: *
| |
| R. L. Spessard, Deputy Director Division of Date
| |
| Inspection Programs, Office of,. Inspection and Enforcement
| |
| Approved:
| |
| I. Barnes, Chief, Region IV CPS $5 Group Date-
| |
| %
| |
| Inspection Sumary
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| t\
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| ~7- q
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| 4
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| 0013.0.0
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| '
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| '
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| ,
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| i.
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| -
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| Inspection Conducted: January 1 through February 28,1987 (Report 50-445/87-02;
| |
| 50-446/87-02)
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| '
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| i
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| l
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| '
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| Areas Inspected: Nonroutine, unannounced inspection of applicant actions cr.
| |
| p*evious jnspection findipgs, Comanche Peak Response Team (CPRT) Issue-Specific
| |
| ,
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| Action Plans (ISAPs), assessrnent of VII.c populations, and the ISAP sample
| |
| selection pr'ocess.
| |
| '
| |
| e
| |
| Pesults: Within the four areas inspecte.d. two dev1ations (several concrete
| |
| pours were not included on the Population Items List, aragraph4.a.[3]: and
| |
| documentsmissingfromthe'ISAPVII.cpro.jectfiles, paragraph 4.a.[43)were
| |
| -
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| ,
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| /.
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| identified.
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| l
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| 0014.0.0
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| 1
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| DETAILS
| |
| 1. Persons Contacted
| |
| ** J. M. Ayres, Quality Engineering (QE) Supervisor, TU Electric l
| |
| ***R. P. Baker, Regulatory Compliance Manager, TV Electric
| |
| ***J. L. Barker, Engineering Assurance Manager, TU Electric
| |
| ** J. W. Beck, Vice Frcsident, TU Electric
| |
| )
| |
| ** G. L. Bell, Nuclear Licensing, TU Electric j
| |
| P. Boortz, Engineering Assurance Supervisor, Evaluation Research
| |
| l
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| '
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| l
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| Corporation (ERC) -
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| I
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| ,
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| '
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| D. Boultan, Pcpulatior. Engineer, EP.C
| |
| D. Boydston, Issue Coordinator, ERC 1
| |
| 1
| |
| ** E. J. Brab6 Ion, Deputy Program Mar.eger, CPRT l
| |
| 1
| |
| '
| |
| * T. Braudt, CPRT, TO Electric
| |
| ** J. A. Buck, Senior Review Team (SRT), CPRT
| |
| .
| |
| ** F. G. Burgess, CPRT Project Manager, TV Electric
| |
| l
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| R. E. Camp, Unit 1 Froject Manager, TU Electric
| |
| ***W. G. Counsil, Executive Vice President, TU Electric
| |
| ***R. D. Delano, Nuclear Licensing Engineer, TV Electric
| |
| D. Ferguson, Results P.eport Review Committee Chairman, CPRT
| |
| ** J. R. Gelzer Issue Coordinator, ERC
| |
| ** M. R. Gross , Jr. , Staff Member, CPRT
| |
| ** J. Guibert, SRT, CPRT
| |
| ***P. E. Halstead, Site Quality Control (QC) Manager, TU Electric
| |
| _ - _ _ - _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _ - - - -
| |
| | |
| l
| |
| .
| |
| .
| |
| 0015.0.0
| |
| I
| |
| **J. Hansel,ReviewTeamLeader(RTL).ERC .
| |
| ***T. L. Heatherly, Regulatory Cornpliance Engineer, TV Electric
| |
| l ** G. S. Keeley, Nuclear Licensing Manager,~~ TU Electric
| |
| ]
| |
| ***J. E. Krechting, Director of Engineer 1 rig, TU Electric
| |
| l
| |
| * D. McAfee, Cuality Assurance (Qt.) Manager, TV Electric -)
| |
| , I
| |
| 'J. McNally, Populatiun Engineer, ERC
| |
| * J, R. r5ffett, Executive Assistant, Engineering & Construction, J
| |
| 'TU hiectric s
| |
| ***L. D. Nace, Vice President, TV ilectric
| |
| .
| |
| '
| |
| ** W. Nyer,'SRT, CPRT
| |
| i A. Pattersen, Issue Coordinator Eit '
| |
| , s j
| |
| ( ***D. M. Reynerson, Unit 2 Project Manager,,10 Electric l
| |
| 1
| |
| G. W. Ross, Issue Coordinator, ERC
| |
| :
| |
| !
| |
| '
| |
| R. K. Sanan Issue Coordinator, TERA )
| |
| i
| |
| J. Schauf, Construction Evaluation Engineering Group Supervisor, ERC
| |
| ***C. E. Scott, Startup Manager, TU Electric .
| |
| "* J. Smith, Operations Staff TU Electric
| |
| ***M. R. Steeln.an, CPRT Support, TU Electric j
| |
| ** J. F. Streeter, QA Director, TU Electric
| |
| J. Tableriou, Population Engineer, ERC
| |
| T: G. Tyler, CPRT P)ogram Director, TV Electric
| |
| C Vincent, Issue Coordinator, ERC 1
| |
| x
| |
| F. Webster, Engineering Statistics Advisor, CPRT
| |
| * D. R. Woodlan, Licensing Supervisur, TU Electric
| |
| ***J. E. Wren, QC Services Supervisor, TU Electric
| |
| | |
| i
| |
| o
| |
| e
| |
| 0016.0.0 i
| |
| i
| |
| !
| |
| J. E. Young, Issue Coordinator, EPC
| |
| P. 2111, QA & Personnel Supervisor, ERC
| |
| !
| |
| )
| |
| '
| |
| The NRC inspectors also interviewed other applicant employees during this
| |
| inspection period.
| |
| * Denotes personnel pre ent at the February 10, 1987, exit interview.
| |
| ** Denotes personnel present at the March 3, 1987, exit interview.
| |
| *** Denotes personnel present at both of the above exit interviews.
| |
| :
| |
| , 2. Applicant Actions on Previous Inspection Findings -
| |
| a. (0 pen) Open Item (446/8513-0-09): Potenti61 ceviations were
| |
| identified by ERC concerning: (1)weldlocation,(2)undersizewelds,
| |
| (3) welding not per weld symbol, and (4) violation of minimum thread
| |
| l
| |
| engagement. These conditions were documented on Deviation Reports , , )
| |
| (DRs) I-S-hVDS-109-DR-1, DR-2, DR-3, and CR-d and incorporated into
| |
| i
| |
| Nonconformance Report (NCR) M86-250134X. This item will remain oper '
| |
| pending disposition of the NCR.
| |
| b. (Closed)OpenItem(445/8513-0-45): ERC identified the following
| |
| conditions to the NRC as subject to evaluation as potential
| |
| deviations: (1) clamp bolts did not have locking devices, and
| |
| (2) paint was identified or. spherical bearings. The NRC inspector
| |
| verified thet a DR was written for each deviating condition. The DRs
| |
| were subsequently documented on NCR k-23284N. The NCR was
| |
| _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _
| |
| | |
| ;
| |
| . i
| |
| '
| |
| i
| |
| t I
| |
| 0017.0.0
| |
| dispositionec: "I-S-LBSN-037-DR-1 and 2 are not nonconforming
| |
| conditiens" for the following reasons: (1) Peint is an acceptable
| |
| locking device (reference NCR M-23216N R-1) and was verified to exist 1
| |
| on threaded connections of the subject support, and (2) paint on the
| |
| spherical bearings does not impair free gimbaling of the snubber which
| |
| is the ecceptance criteria defined by QI-QAP-11.1-28, Revision 34.
| |
| Since it was determined that these conditions are not nonconforming,
| |
| this item is closed,
| |
| i
| |
| *
| |
| i c. (Closed)OpenItem(44E/P513-0-47): During an NRC witnessec
| |
| i
| |
| inspection, ERC icentified the following ccnditions to the NRC
| |
| inspector as subject to evaluation as pctential deviations:
| |
| (1) missing locking devices, and (2) dimensional discrepancies were
| |
| icentified during reinspection of I-S-LBSR-029. The NRC inspector
| |
| verified that a DR was written for each deviating condition. The DRs ,
| |
| were subsequently doce . anted on NCR M-23135N which was dispositioned:
| |
| "I-S-LBSR-029 DR-16 2 are not nonconforming conditions" for the
| |
| following reasons: (1) paint is an acceptable locking device
| |
| (reference NCR M-23216N R-1) and was verified to exist on threaded
| |
| connections of the subject support, and (2) dimensional discrepancies
| |
| identified were not a valid deviation. * The note on the drawing
| |
| stating all dimer.sions plus or minus 1/4" is applicable for base
| |
| plates only; not the location of piping (which was the icentified
| |
| diirensionally aiscrepant condition).
| |
| _ _ _ _ ._-__-____ - _- _ -
| |
| | |
| 1
| |
| ,
| |
| 9
| |
| -
| |
| 0018.0.0
| |
| i
| |
| Since these conditions were determined to be not nonconforming, this
| |
| item is closed.
| |
| Potential deviations were l
| |
| d. (0 pen)OpenItem(445/8514-0-15):
| |
| identified by the ERC inspector concerning a missing color cooe and
| |
| 1 '
| |
| the allowable distance between color code marks was exceeded. These
| |
| were identified on DRs 1-E-IN1ti-066 DR 1 and CR 2 and subsequently on I
| |
| i
| |
| NCR I-85-102025SX. This populatfori was reinspected at a later date i
| |
| for additional attributes and the package designation changed from
| |
| I-E-ININ-066 to I-E-1NIN-066R. The reinspection generated one
| |
| - additional DR, DR I-E-ININ-066R-DR-3, which resulted in the issuance'
| |
| cf hCR I-86-101916X. This NCR also incorporated the previously
| |
| identified NCR. This item will remain open pending disposition of the
| |
| NCR.
| |
| 4
| |
| e. (0 pen)Openitem(445/8514-0-16): A potential desiation was ,
| |
| identified by the ERC inspector concerning location of sending Units
| |
| 1-LS-6712 and 1-LS-6717 being reversed on the tank for package
| |
| I-E-ININ-069. This was subsequently identified on DR
| |
| I-E-ININ-069-DR-1, and NCR I-85-101890SX. Because of added
| |
| attributes, this population was reinspected and the NCR superseded by
| |
| i;CR I-86-101915X. This item will rema'in open pending disposition of
| |
| the NCP.
| |
| !
| |
| f. (C1csed) Open Item (445/8514-0-24): A potential deviation was
| |
| identified by the ERC 1rispector concerning a missing nameplate and an
| |
| l
| |
| t
| |
| | |
| !
| |
| .
| |
| l
| |
| .
| |
| 1
| |
| 0019.0,0
| |
| I
| |
| l
| |
| actuator spring that could not be located on 1-H-HVIN-043. A J
| |
| I
| |
| i
| |
| subsequent inspection located the nameplate anc identified the fact !
| |
| that the damper is a fail-safe damper and does not require a spring. !
| |
| l
| |
| J
| |
| This item is closed. l
| |
| 1
| |
| (0 pen)Openitem(445/8514-0-28): A potential deviation was j
| |
| 9 )
| |
| identified by ERC concerning an undersize horizontal brace. This j
| |
| l
| |
| condition was identified in DR I-S-HVDS-023-DR-4 and incorporated into j
| |
| ,
| |
| hCR M-86-1003215XRI. This item will remain open pending disposition J
| |
| )
| |
| of the NCR.
| |
| h. (0 pen) Open Item (445/8514-0-29): A potential deviation was
| |
| identified by ERC concerning undersize fillet welds. This condition f
| |
| 1
| |
| was identified in DR I-S-HVDS-041-DR-4 and incorporated into NCR
| |
| M-85-101991XR2. This item will remain open pending disposition of the l
| |
| l
| |
| , ,
| |
| l NCR.
| |
| i. (Closed)OpenItem(445/8516-0-12;446/8513-0-08): The ERC l
| |
| ncnconformance evaluation checklists did not provide for the
| |
| evaluation of the technical adequacy of NCn dispositions.
| |
| This ERC CA/QC RTL and the VII.a.2 iss'ue coordinator has stated that
| |
| evaluation of the technical adequacy of NCR dispositions is outside
| |
| the scope of ISAP VII.a.2. The applicant has, however, initiated a
| |
| program (performed by Stone & Webster Engineering Corporation) to
| |
| evaluate the disposition of 300 NCRs with use-as-is or repair
| |
| | |
| - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _
| |
| ,
| |
| .
| |
| l
| |
| 0020.0.0 j
| |
| ;
| |
| dispositions for technical adequacy. The evaluations assessed the NCR
| |
| dispositions to determine: (1) if the disposition fully addressed the i
| |
| !
| |
| nonconformance; (2) if en adequate technical justification was
| |
| provided; and (3) whether the disposition block was correctly j
| |
| i
| |
| identified. To provide further assurance, the applicant has decided
| |
| to expand its program to assess the technical adequacy of the ;
| |
| i
| |
| remaining NCRs with these disposition categories. This activity will {
| |
| be overviewed by TERA as an independent third party. NRC inspectier,
| |
| 1
| |
| of this process will be reported in a subsequent inbptction period.
| |
| *
| |
| i j. (0 pen) Open Item (445/8516-0-15): Potential deviations were
| |
| identified by the ERC inspector concerning locknuts missing from clamp l
| |
| bolts and a bolt hole was incorrectly located. This condition was
| |
| subsequently identified in DRs I-S-0S42-25-DR-1 and CR-2 and
| |
| incorporated into NCRs M-25216HR1 and P-25338N, respectively. This
| |
| item will remain open pending disposition of the NCRs. ,
| |
| k. (Closed) Deviation (445/8516-D-35): The ERC inspector failed to
| |
| record the presence of eristing additional field welds to those
| |
| specified on the drawing for Verification Package I-S-LBSR-041 and did
| |
| '
| |
| not provide objective evidence of reinspection. The deviation
| |
| resulted from inspection personnel not'being able to distinguish
| |
| vendor welds from field welds on vendor supplied components. ERC
| |
| Qt.ality Instructions (QIs) QI-019, 01-027, and QI-029 were revised to
| |
| incorporate inspection requirements for these welds. Weld inspections
| |
| performed prior to the procedure change were reviewed and supplemental
| |
| !
| |
| l
| |
| 4
| |
| | |
| - - _ _ _ _ - __ _
| |
| .
| |
| '
| |
| i
| |
| 0021.0.0
| |
| i
| |
| inspection instructions were issued on a case-by-case basis to assure
| |
| compliance with revised procedural requirements. The NRC inspector
| |
| reviewed the corrective action taken and concluded that the revised
| |
| instructions should prevent recurrence.
| |
| ,
| |
| i
| |
| !
| |
| 1. (0 pen) Open Item (445/8516-0-38): Potential deviations were
| |
| identified by ERC concerning: (1)weldsymbolsandlocations,
| |
| i
| |
| (2) undersize welds, aho (3) a Hilti Kwik Bolt embed violation. These i
| |
| conditions were documented in DR I-S-HVDS-029-DR-1 and DR-2, and
| |
| incorporated inte NCR M-85-102014X. This item will remain open
| |
| '
| |
| ' pending disposition of the NCR.
| |
| m. (0 pen) Open Item (445/8516-0-39): Potential deviations were
| |
| identified by ERC concerning: (1)incorrectmemberdimensions,
| |
| (2) incorrect weld configuration, (3) incorrect weld size.
| |
| (4) incomplete fusion in welds, and (5) violation of weld undercut .
| |
| 1
| |
| criteria. These conditions were documented in DRs I-S-HVDS-089-DR-1,
| |
| DR-2, DR-3 DR-4, DR-5, and DR-6. These DRs were then incorporated
| |
| into NCR M85-102027X for DR-1 through DR-5 and NCR M86-103774X for
| |
| DR-6. This item will remain open pending disposition of the NCRs.
| |
| n. (0 pen)OpenItem(445/8516-0-40): Potential deviations were
| |
| identified by ERC concerning: (1) dimensior. violations, (2) incorrect
| |
| ductaimension,(3)incorrectorientation,(4)welaswereundersize,
| |
| and(5)incorrectweldprofile. These conditions were documented in
| |
| DRs I-S-HVDS-103-DR-1, DR-2, DR-3, DR-4 AND DR-5. These DRs were then
| |
| | |
| l
| |
| '
| |
| .
| |
| ,
| |
| 0022.0.0
| |
| incorporated into NCR M85 101991X. This iten will remain open pending
| |
| disposition of the NCR.
| |
| (Closed) Violation (445/8518-V-03; 446/8515-V-02): Item A.1, failure
| |
| o.
| |
| to certify an inspector in accordance with procedural requirements. I
| |
| '
| |
| s
| |
| As corrective action for this violation, the applicant committed to ,
| |
| revise Procedure CP-QP-2,1, aTraining of Inspection Personnel,'' with
| |
| date of full compliance by May 21, 1986. The procedural revision was l
| |
| to provide for identification of qualification responsibility and
| |
| i euthority of Level III personnel invclved in training and
| |
| certification activities including those areas where a cross-over of
| |
| qualification authority existed. The violation was issued due to the
| |
| failure to identify this cross-over authority. The NRC inspector
| |
| verified that CP-0P-2.1, Revision 21, dated May 8, 1986, and
| |
| essociated nuorandum TUQ 3748 dated May 12, 1986, provide for this .
| |
| identification of cross-over authority. This item is cicsed.
| |
| !
| |
| Item A.2, failure to follow procedures when justifying waivers of
| |
| on-job training (0JT) in the certification of four QC inspectors. , j
| |
| ~~
| |
| ~ ~ ~ ~ ~ ~ ~
| |
| _ . .
| |
| -
| |
| ;
| |
| U.1he NRC inspector has reviewed the information provided in the i
| |
| l
| |
| supplemental response to this violation. This review and reinspection j
| |
| i
| |
| '
| |
| of the files for the fcur QC inspectors verified that justification
| |
| l
| |
| other than ". . . I hours OJT and previous related inspection
| |
| 4
| |
| activity . . ." was included. The justification on the waivers
| |
| '
| |
| 1 !
| |
| l i
| |
| $
| |
| l l
| |
| | |
| . _ - _
| |
| 1
| |
| .
| |
| '
| |
| I
| |
| C023.0.0 l
| |
| i
| |
| included ". . . demonstration of practical field ability to the
| |
| satisfaction of a certified Level II." This demonstration provided O
| |
| #
| |
| " . . . assurance that the individual does have comparable' or e
| |
| / \
| |
| '
| |
| dequivalent' competence to that which would have been gained . . . ."
| |
| Therefore, specification on the waiver of the previous related
| |
| i
| |
| inspection activity was not required in these cases. Since the
| |
| required infonnation was included elsewhere in the certification
| |
| files, a violation did not occur in this example and this item is
| |
| closed.
| |
| l
| |
| l
| |
| l
| |
| '
| |
| '
| |
| p. (Closed) Open Item (445/8603-0-15): This open item addressed
| |
| I
| |
| inspector certification documentation for fill and backfill I
| |
| placements. ERC issued DR R-5-FILL-GEN-DR-1 regarding inspector
| |
| certification for the safe shutdown impoundment dam construction for
| |
| the period Apri's 24, 1976, through April 19, 1977. Inspector l
| |
| I
| |
| certification documentation for Freese & Nichols Consulting Engineers . .
| |
| (F&N) and Mason & Johnson Associates Inc. (M-JA) could not be located
| |
| during tFc initial ERC documentation reviews. l
| |
| l
| |
| TV Electric subsequently requested copies of certification records
| |
| from F&N and M-JA. These documents were obtained and are being
| |
| transmitted to the Permanent Plant Records Vault (PPRV). The NRC
| |
| inspector reviewed these inspector certification documents and found
| |
| that the inspection personnel were qualified to perform the
| |
| inspections and/or laboratory tests. This item is closed.
| |
| l
| |
| t
| |
| | |
| _ _ _ - _ - _ _ _ - _ - _ _ _ - - - - _ - _ _ - - . -
| |
| .
| |
| l
| |
| 1
| |
| '
| |
| 0024.0.0
| |
| ;
| |
| 1
| |
| q. (Closed)UnresolvedItem(445/8607-U-17): Incomplete craft
| |
| installat1cn procedure instruction. NRC inspector review of l
| |
| l
| |
| Revision 5 of construction Procedurc eel-8, " Class IE and non-Class
| |
| Cable Terminations," had identified the omission of inst 611ation I
| |
| i
| |
| requirements for uninsulated cable splices. This omission was noted
| |
| :
| |
| in NRC Inspection Report 50-445/86-07; 50-446/86-05 during the
| |
| evaluation of CPRT committ.ents related to preinsulated environmental
| |
| sealed (PIES) splices. During this report period, the NRC inspector
| |
| reviewec Eevision 6 of EEI-8 dated September 23, 1986, ano determined
| |
| that adequate provisions for all types of splices had been
| |
| ;
| |
| *
| |
| , incorporated therein. l
| |
| l
| |
| r. (Closed)UnresolvedItem(445/6607-U-18): Incomplete inspection ,
| |
| 1
| |
| procedure instructions. In addition to revising eel-8, the CPR1 also
| |
| cormitted to having certain inspection requirements for PIES splices
| |
| irstalled in control beards incorporated in the QC inspection , ,
| |
| procedure, Ql-QP-11.3-28. " Class 1E Cable Terminations." The NRC
| |
| inspector review of Revision 28 of this procedure had indicated that
| |
| other types of splices and PIES splices installed in locations other
| |
| than control panels were not subjected to the same requirements as the
| |
| PIES splices in control panels. Further NRC inspector review of the
| |
| applicable facility commitments and of Revision 31 to QI-QP-11.3-28
| |
| found that all of the applicable provisions not previously included
| |
| had been incorporated into the procedure.
| |
| <
| |
| | |
| .
| |
| .
| |
| 0025.0.0
| |
| s. (Closed) Violation (445/8615-V-06): Failure of the Unit 1 PFG to
| |
| provide specific instructions for the control of design cocuments
| |
| issued for exterded time periods.
| |
| The NRC inspector verified that Procedures CP-CPM-7.4 and CP-CPit-7.4A
| |
| were revised July 25, 1986, te provide instructions for the control of
| |
| design dccuments issued for extended time periods. As stated in the
| |
| response, these two procedures were superseded by issuance of
| |
| Revision 3 of Procedures CP-CPM-7.1 and CP-CPM-7.1A on December 15,
| |
| 1986. The NRC inspector verified that a daily review of the Package
| |
| ,
| |
| Inventory Card for document packages issued for extended time periods
| |
| was required in these procedures and that the requirement applied to
| |
| j both 011ts 1 and 2. These procedural revisions provide the requireo
| |
| controls. This 4 tem is closed.
| |
| , I
| |
| t. (Closed) Viciation (445/8615-V-07; 446/8612-V-07): Failure to control
| |
| .
| |
| the activity by which the onsite fabrication shop provides inspection
| |
| traceability of idertical shcp fabricated items.
| |
| .
| |
| NRC review of Procedures CP-CPM-7.2A, " Material Storage / Identification
| |
| for Structural Steel Fabrication," Revision C, LCN #2, dated
| |
| August 12, 1986, and QI-CP-11.14-1, Revision ?d, dated July 28, 1936,
| |
| '
| |
| verified that these procedures were revised to incorporate methods to
| |
| control inspection traceability of identical shop fabricated items.
| |
| Since the violation was issued for failure to procedurally control the
| |
| activity and no hardware deviaticns were noted during the previous ,
| |
| u
| |
| | |
| .
| |
| .
| |
| CC26.0.0
| |
| inspet. tion, the above revisions to the applicable procedures close
| |
| '
| |
| this item.
| |
| l
| |
| l
| |
| u. (0 pen) Open Item (445/8615-0-11): During inspection of Verification
| |
| Package I-M-MEIM-035, the NRC inspector identified that an equipment ;
| |
| i
| |
| foundation anchor bolt nut was not bearing load and that a 1/4" gap i
| |
| existed between the anchor nut and the load bearing mating surface. l
| |
| Subsequent NRC review of ERC overview inspection documentation
| |
| revealed that an ERC overview inspector had already identified the
| |
| 1
| |
| 1
| |
| deviating condition and that DR I-M-MEIN-035-DR2 had been issued and
| |
| validated, resulting in the issuance of NCR M-23094 NR-2. This item
| |
| ,
| |
| remains open pending disposition of the NCR.
| |
| 3. CPRT ISAPs (excluding ISAP VII.c) l
| |
| a. OC Inspector Qualifications (ISAP I.d.1) ,
| |
| .
| |
| During this inspection period, the NRC inspector inspected tha
| |
| processing of DRs and the verification of inspector qualifications
| |
| hep u a s gcC.
| |
| performedg .1dAP I.<171, personnel for inspectors whose certifications
| |
| were not found acceptable during ISAP.VII.c review. This inspection
| |
| yb
| |
| was accomplished by first reviewing the controlling Procedures
| |
| d] CPP-025, "QC Inspector Qualification Evaluation," and CPP-010.
| |
| 1y ~
| |
| " Preparation of Deviation Reports," and then performing a detailed
| |
| review of DRs related to inspector certification that were generated
| |
| | |
| !
| |
| '
| |
| ..
| |
| .
| |
| 0027.0.0
| |
| :
| |
| during the VII.c review process. The DR processing was reviewed by
| |
| the NRC inspector for the following attributes: .
| |
| !
| |
| l
| |
| I
| |
| (1) Inspector certific.ation related DRs were forwarded to the
| |
| ISAP I.d.1 1ssue coordinator in accordance with CPP-10.
| |
| (?) The validity of DRs was properly evaluated by the ISAP I.d.1
| |
| issue coordinator.
| |
| 1
| |
| *
| |
| t3) The transmittal of CRs was in accordance with (,PP-10.
| |
| l
| |
| .
| |
| >
| |
| (4) The determinations of inspector qualification for the uncertified
| |
| 1
| |
| CC inspectors was proper and the determinations were documented ,
| |
| onthefnspectorfertificationfvaluationfmmary(ICES) form.
| |
| (5) The determinations to reinspect any previous work of unqualified
| |
| inspectors were proper and documented on a memorandum addresse.d
| |
| . .
| |
| to the ISAF VII.c file as required by procedure.
| |
| (6) Reinspection of any previous work performed by the unqualified
| |
| OC inspectors were accomplished in accordance with QI-005,
| |
| !
| |
| " Evaluation of Inspector Performance."
| |
| 1
| |
| (7) Validated CRs were transmitted to TV Electric for documentation
| |
| on an NCR/OR.
| |
| 1
| |
| ;
| |
| l
| |
| I
| |
| | |
| -- . .
| |
| . ---- _-
| |
| .
| |
| 1
| |
| -
| |
| 1
| |
| 0028.0.0
| |
| t
| |
| I
| |
| The above procedures were determined by the NRC inspector to provide
| |
| the necessary controls for evaluation and processing of the DRs. The
| |
| proceduras specified the personnel responsible for performing the
| |
| DR evaluations and the actions required for documenting the
| |
| evaluations. The procedures also prcvided guidance for the l
| |
| j
| |
| DR evaluations by reference to ISI.P I.d.1 "QC Inspector J
| |
| l
| |
| Qualifications," and Q1-005, "Evalustion of Inspector Performance,"
| |
| <
| |
| which detail the methods to conduct evaluation of QC inspector )
| |
| certification and qualification.
| |
| The process by which ERC performs en analysis of file docurrentation to
| |
| s
| |
| evaluate the qualifications of QC inspecto,rs is being inspected by the .,
| |
| c. c' 7/c EC C 1
| |
| hRC under its WpertiorCof ISAP 1.d.1. ,Th&t process is identical to l
| |
| E~ the process utilized for evaluation of inspectors identified by
| |
| .
| |
| '
| |
| .;y d g ISAP VII.c, with the exception that proper QC inspector certification
| |
| f
| |
| b is determired by the ERC VII.c inspectors in accordance with VII.c
| |
| l
| |
| j
| |
| j
| |
| inspection / documentation review required in 28 of the 75 QIs used for
| |
| reinspection. l
| |
| l
| |
| During sample inspection of the document review packages, the NRCet(as_
| |
| ed i
| |
| 6 den verifytT@ whether a certification exists for the inspector of
| |
| record, where required. , l
| |
| To evaluate the system by which inspector certification / qualification
| |
| ,
| |
| is evaluated, the NRC selected a sample of 32 DRs concerning inspector
| |
| certifications that were identified during the VII.c document reviews.
| |
| | |
| l 1
| |
| L
| |
| , j
| |
| ,
| |
| 0029.0.0
| |
| All 32 DRs were found to have been transmitted, processed for
| |
| validation, and maintained as specified by CPP-10 and CFF-025. The
| |
| NRC inspector verified that the results of the I.d.1 issue
| |
| coordinator's review of the certifications in question were documented
| |
| on inspector certification summary forms and that justification for
| |
| the results was provided.
| |
| The NRC inspector found that of the 32 DRs selected. 28 were
| |
| determined by the issue coordinator to be valid and 4 were determined
| |
| to be invalid. NPC review of the packages for the four invalid DPs
| |
| '
| |
| ,
| |
| found tt.st the certifications had existed for the certifications
| |
| questioned by the VII.c DRs and that documentation existed to support
| |
| i
| |
| the certifications.
| |
| NRC review of the packages for the 28 valid DRs found that l
| |
| 2 inspectors were determined by the I.d.1 issue coordinator to be
| |
| unqualified for the inspections performed. Therefore, a I.d.1 .
| |
| Phase III reinspection was specified as corrective action. The
| |
| 26 remaining inspectors were determined by the I.d.1 issue coordinator
| |
| to have been qualified for the inspections performed. The basis for
| |
| the disposition of the 28 valid DRs is shown in the following table:
| |
| '
| |
| Inspector ovalified under equivalent
| |
| brown & Root (B&R) certification. 9
| |
| Inspector ou61ified under Level II
| |
| and all dauchter certifications. I
| |
| | |
| .
| |
| .
| |
| 0030.0.0 ]
| |
| Inspector qualified under contractor
| |
| certification other than B&R
| |
| (e.g., R. W. Hunt). 4
| |
| -Inspector qualified as determined
| |
| by Special Evaluation Team /RTL review. 2
| |
| Inspector qualified but
| |
| administrative / clerical errors
| |
| I require DR. 5
| |
| Inspector qualified under previous
| |
| similar certification. 5
| |
| *
| |
| ,
| |
| Total determined qualified. 26
| |
| Total determined not qualified and sent
| |
| to Phase III for Reinspection. 2
| |
| l
| |
| l
| |
| . .
| |
| The NRC inspector verified during review of the validated VII.c DRs
| |
| that the I.d.1 determinations of qualifications were supported by
| |
| cocumented evidence of comparable prior certification, sufficient
| |
| training and examination for the inspection activity, or in the case
| |
| of the two inspectors determined by the issue coordinator's review to
| |
| be qualified, that previous training and inspection activity was
| |
| sufficient and applicable for the certification in question. ,
| |
| The NRC inspector verified that the 28 valid DRs were transmitted to
| |
| TU Electric and NCRs were prepared.
| |
| _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ - _ _ -
| |
| | |
| .
| |
| *
| |
| 4
| |
| l
| |
| 0031.0.0
| |
| l
| |
| As reported in NRC Inspection Report 50-445/86-22; 50-446/86-20, the
| |
| NRC inspector reviewed four reinspection matrices utilized for the
| |
| ISAP I.d.1 Phase III reinspection of construction inspectors whose
| |
| qualifications were determined to be unsupported by file
| |
| documentation. The four matrices were found to be in compliance with
| |
| QI-005, " Evaluation of Inspector Performance." Additionally, the NRC
| |
| '
| |
| inspector witnessed two field reinspection which were satisfactorily
| |
| performed by ERC inspectors in accordance with these matrices.
| |
| flo violations or deviations were identified. The evaluation of DRs
| |
| ,
| |
| pertaining to inspector qualifications generated by ISAP VII.c or .
| |
| other ISAPs will cortinue to be inspected by the NRC.
| |
| b. Inspection for Certain Types of Skewed Welds in NF Supports (ISAP V.a)
| |
| Status of NRC Inspection Activity
| |
| '
| |
| I
| |
| l'. ts 1
| |
| The NRC inspector verified compliance with the following ISAP g activity
| |
| connitments:
| |
| Chronolooy of Inspection Methods (NRC Reference 05.a.01.00)
| |
| .
| |
| The methods for QC inspection of type-2 skewed welds and the written
| |
| procedures describing the methods and means of documenting the
| |
| inspections have changed during the construction of the CPSES project.
| |
| /
| |
| \,a
| |
| The technical focus of thiTAP is the inspection of the geometric
| |
| | |
| . ___ ._ --_
| |
| s
| |
| . ,
| |
| 0032.0.0
| |
| and dimensional characteristics of skewed welds at locations where
| |
| '
| |
| sirrple fillet gauge measurement was not possible.
| |
| In order to determine what inspection instructions were applicable for
| |
| specific time frames, a chronology of inspection methods documented in
| |
| QC procedures was developed to correlate the period of time and
| |
| i
| |
| l specific procedure revisions for inspection of type-2 skewed welds.
| |
| The inspection techniques used and the methods of documenting the
| |
| inspections of type-2 skewed welds involved the following procedures:
| |
| .
| |
| , l
| |
| QI-QAP-11.1-26: which addressed the fabrication, installation and
| |
| 1
| |
| inspection of ASME pipe and attachments welded to the pipe.
| |
| I
| |
| Ql-QAP-11.1-28: which addressed the fabrication, installation and
| |
| inspection of ASME pipe supports except for attachments welded to the ,
| |
| pipe.
| |
| CP-QAP-12.1: which addressed the final verification of ASME pipe
| |
| supports prior to certification (preparation of the ASME N-5 form).
| |
| Relevant historical changes affecting these quality procedures are as
| |
| follows:
| |
| QI-QAP-11.1-28: Revision 12 dated September 3, 1982, and Revision 13
| |
| dated September 21, 1982 - Specific criteria for the measurement of
| |
| | |
| i
| |
| 1 1
| |
| .
| |
| 0033.0.0
| |
| I
| |
| type-2 skewed welds using the scribe line technique was incorporated l
| |
| into the procedure at that time. .
| |
| 1
| |
| Ql-QAP-11.1-28: Revision 16 dated December 15, 1982 - The type-2
| |
| skewed wsld inspection methodology was deleted from the pipe support
| |
| procedure.
| |
| 1
| |
| CP-QAP-11.1-26: Revision 9 dated December 16, 1982 - The type-2
| |
| skewed weld inspection methodology was incorporated into the piping
| |
| procedure. j
| |
| .
| |
| i
| |
| QCWI-1: Dated February 21, 1983 - This B&R instruction was issued to
| |
| inform inspectors to use inspection methodology and acceptance
| |
| criteria in piping Procedure QI-QAP-11.1-26 when measuring type-2 l
| |
| I
| |
| skewed welds on pipe supports. l
| |
| - j
| |
| CP-QAP-12.1: Revision a dated February 2, 1983, and Revision 5 dated
| |
| March 18, 1983 - These revisions were issued to initiate reinspection
| |
| of all accessible structural welds on ASME pipe supports.
| |
| QI-QAP-11.1-26: Revision 13 dated August 4, 1983 - The profile
| |
| technique for measuring size of type-2cskewed welds was added to the
| |
| piping procedure.
| |
| 1
| |
| l
| |
| l
| |
| [
| |
| _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ -
| |
| | |
| - ..
| |
| _ __
| |
| ,
| |
| . J
| |
| 0034.0.0
| |
| QI-0AP-11.1-28: R rision 29 dated January 25, 1985 - The scribe line f
| |
| technique for measurement of type-2 skewed fillet welds was
| |
| l reincorporated into the support procedure,
| |
| ,
| |
| 01-0AP-11.1-28: Revision 30 dated April 15, 1985 - The profile
| |
| technique for measurement of type-2 skewed welds was incorporated into
| |
| the support procedure,
| |
| i
| |
| Six different methods of documenting the results of type-2 skewed weld
| |
| inspections were permitted by procedure at various times. These
| |
| methods were: .
| |
| .
| |
| (1) HIR Hanger Inspection Report
| |
| (2) CSC Component Support Checklist
| |
| (3) bWDC Multiple Weld Data Card
| |
| (4) WICL Weld Inspection Checklist
| |
| (5) CSF/SWIR Component Support Fillet and Skewed Welo
| |
| Inspection Report ,
| |
| N (6) COT Construction Operation Traveler l
| |
| p-g , ,",/ This activity is complete. NRC inspection of activities listed above
| |
| -
| |
| !
| |
| I
| |
| also provide a basis for completion of activities required by NRC
| |
| Reference 05.a.01.01 and 05.a.01.02.
| |
| No violations or deviations were identified.
| |
| Third-party to Evaluate the Physical significance of any Procedural
| |
| Changes (NRC Reference 05.a.02.04)
| |
| | |
| .
| |
| .
| |
| . . . . . . . . . . . . . . . .. . . . . . . . . ..
| |
| .
| |
| .
| |
| >
| |
| 0035.0.0
| |
| Ntew/>a1.Titzt$5dbt
| |
| The NRC inspector questioned ngineering personnel from TERA as to
| |
| i
| |
| -fielho L
| |
| what was the ir. tent of this-(ey.nreme ntsand what actions Wre taken.
| |
| TERA persunnel stated that their review of procedure changes indicated
| |
| that an overall improvement with respect to inspection methodology had
| |
| .
| |
| :tla ba wul 1
| |
| I
| |
| occurred. This trend resulted in improved performance by inspection 1
| |
| A
| |
| personnel.
| |
| .
| |
| NRC review of data presented in the results report for this ISAP-
| |
| confirms this conclusion. This activity is complete,
| |
| , ho violations or deviations were identifiec. ,
| |
| c. Cocument Centrol (ISAP VII.a.3)
| |
| During this report period, the activities identified by NRC Reference
| |
| 07.a.03.04 and the closecut of related external issues were inspected
| |
| ..
| |
| as follows:
| |
| Procedure Evaluation (NRC Reference 07.a.03.04)
| |
| This ISAP required an evaluation of the current CPSES document control
| |
| procedures. The issue coordinator performed the evaluation, conducted
| |
| and documented the results of the interviews, and completed a
| |
| procedure checklist, which in total formed the basis for the
| |
| evaluation.
| |
| | |
| _ _ _ _ _ - - _ _ _
| |
| ,
| |
| .
| |
| 0036.0.0
| |
| The NRC reviewnd the procedure checklist and compared it to the
| |
| requirements in Criterion VI of Appendix B to 10 CFR Part 50, and to
| |
| the commitments in the CPSES FSAR. The procedure checklist was found
| |
| to address the requirements and commitments concerning distribution
| |
| and control of documents affecting quality. Utilizing thic checklist,
| |
| the NRC inspected the current controlling Frocedure DCP-3,
| |
| Revision 19 "CPSES Document Control Program," to verify that ERC had
| |
| implemented the checklist properly and that the procedure met the
| |
| above requirements and commitments. The procedure was found to
| |
| properly contain the following attributes: measures to assure that all
| |
| documents, and changes to documents, were reviewed and appruved by
| |
| *
| |
| ,
| |
| authorized personnel prior to distribution; and measures to assure
| |
| that all documents used for construction or inspection activities were
| |
| maintained current and in a controlled status. Additionally, the
| |
| procedure provided for retrieval or identification of superseded
| |
| documents and for an ongoing monitoring of document control , ,
| |
| performance of all controlled document files by an independent
| |
| monitoring team. No differences between the NRC and ERC results were
| |
| noted in the completed checklists.
| |
| In addition, the NRC inspected the implementation of DCP-3 by
| |
| requesting a sample of 20 drawings and 10 procedures from the document
| |
| control center (DCC) and one satellite. These documents were found to
| |
| be at their current revision with all design changes entered when
| |
| '
| |
| compared to the DCC master list of controlled documents.
| |
| ,
| |
| _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _
| |
| | |
| __ _ _ _ _ _ _ - _ _ - - _ - _ _ - _ _ _ _ _ _ _ .
| |
| '
| |
| !
| |
| '
| |
| 0037.0.0
| |
| !
| |
| The implementation of the independent monitoring team was inspected by j
| |
| the NRC inspector by interviewing the head of the monitoring tebm,
| |
| l
| |
| '
| |
| reviewing monitoring reports and executive suninary reports, and
| |
| reviewing the report distribution which included the vice-president,
| |
| engineering and construction. The nionitoring team's reports indicated ,
| |
| I
| |
| that the document control groups were achieving an error rate of less
| |
| than 0.1L . ~
| |
| l
| |
| I
| |
| h ,.4, H ;,
| |
| ,
| |
| 1
| |
| .~
| |
| TheNRCinterviewedtheERCengineersresponsibfefor11ofthe
| |
| 32 populations in ISAP VII.c to obtain(similar information from the
| |
| ,
| |
| implementation of the VII.c ISAP. These engineers stated that of the
| |
| 4,000 drawings utilized during inspection of the 11 populations, they
| |
| found 6 document control errors or a 0.15% error rate.
| |
| Based on the foregoing NRC inspections and the favorable comparison
| |
| with the results of the ERC inspections, this item has been properly
| |
| ..
| |
| implemented. No violations or deviations were noted during the
| |
| inspection of this area of the document control program.
| |
| Closecut of Related External Issues
| |
| Two external issues related to document control were identified in
| |
| ISAP VII.a.3. The issue of unauthorized procedures used for
| |
| cold-springing of piping was addressed in ISAP V.e and was not
| |
| considered further in this ISAP. The issue that a " Controlled Copy"
| |
| stamp was improperly used by B&R ASME QA personnel was addressed.
| |
| L----------- _ -_ _---- _ ------ _ _ _-- ---_--_--__- -_- _ - - _ _ _ . _ - - - - - . . - - _ _
| |
| | |
| _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ - _ _
| |
| .
| |
| 0038.0.0 {
| |
| I
| |
| i
| |
| l
| |
| The NRC interviewed the current B&R document review supervisor who l
| |
| stated that the document review group does not currently use a ontrolf,A[
| |
| ~~'
| |
| Cc'opy" stamp; however, this supervisor did state that for a short time,a
| |
| stamp was used to mark drawings prior to presentation to the
| |
| Authorized Nuclear Inspector (ANI) for review. The NRC also
| |
| interviewed the B&R QE group supervisor that was involved when this
| |
| stamp was used. This individual indicated that the stamp was used on
| |
| copies of small bore typicals before presentation to the ANI for
| |
| review. The practice was stopped and the stamp defaced after'irsuance
| |
| of Special Inspection Services (SIS) Report 355, which documented the
| |
| ANI's concern about the use of the stamp. Evidence of the stamp -
| |
| i
| |
| defacing was provided by a memo to the QA file dated August 10, 1984,
| |
| bearing an imprint of the stamp before and after defacing. The
| |
| corrective actions taken appear sufficient to prevent recurrence. The i
| |
| improper use of the " Controlled Copy" stamp had been previously ,
| |
| 1
| |
| determined by the NRC Technical Review Team (TRT) in SSER 11 to have
| |
| . .
| |
| had no adverse safety implications. No further NRC inspection of this '
| |
| ,
| |
| item is planned.
| |
| 1
| |
| 1
| |
| 4 Construction / Reinspection (ISAPVII.c)
| |
| l
| |
| '
| |
| a. Establishing Populations ,
| |
| Section 4.3.1 of ISAP VII.c, Pevision 1, required safety-related
| |
| hardware to be categorized into populations with homogenous work
| |
| l
| |
| _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
| |
| | |
| ,
| |
| .
| |
| 0039.0.0
| |
| activities (HWAs) and associated quality characteristics (attributes)
| |
| from which the required random samples were selected. It also
| |
| required that a description and justification for hornoeneity be
| |
| prepared for each population. Finally, each population was to have a
| |
| list of all final CC accepted safety-related items. The CPRT
| |
| guidelines for establishing homogenous populations were contaired in
| |
| the project procedure for ISAP VII.c. Procedure CPP-005, Revision 3.
| |
| This procedure required the discipline engineers to review equipment
| |
| lists from CPSES in order to subdivide the plant into homogeneous
| |
| i populations that have been constructed using reasonable horrogeneous-
| |
| l
| |
| work processes. The equipment reviewed was limited to that which was j
| |
| safety related, construction complete and final QC accepted. The l
| |
| i
| |
| equipment would be inspected for attributes selected after a corrplete ;
| |
| I
| |
| review of engineering documents pertaining to the individual
| |
| populations. ,
| |
| The generation of a Population Description, Master Population List,
| |
| Population Items List, and a Work Process Memorandum are also
| |
| procedurally required along with adequate control of subsequent
| |
| revisions to each of these documents.
| |
| '
| |
| The NRC inspectors reviewed tha following six ISAP VII.c populations;
| |
| V
| |
| [(Large Bore Supports Rigid, large Bore Supports Nonrigid, Small Bore
| |
| l
| |
| Pipe Supports, Pipe Welds / Material, Concrete Placement, and Electrical
| |
| Cable) ensure that the homogenous populations were correct and
| |
| .
| |
| - - - - _ _ -
| |
| | |
| -
| |
| (
| |
| ,
| |
| 1 8
| |
| s
| |
| 1 0040.0.0 ;
| |
| adequate and that ERC procedures, primarily CPP-005, were being ]
| |
| adhered to.
| |
| ,
| |
| \ ]
| |
| j
| |
| (1) Large Bore Supports Rigid (LBSR), large Bore _ Supports Nonrigid
| |
| (LBSN), and Small Bore Pipe Supports (SBPS),
| |
| ,
| |
| 1 .
| |
| The NRC inspector's review of these three populations was
| |
| performed concurrently because the population descriptions are j
| |
| l
| |
| similar except for the population boundaries (large bore rigio,
| |
| large bore nonrigid, or small bore) and the Population Items
| |
| .
| |
| ' Lists were all derived from the same source document; the Hanger- I
| |
| l
| |
| installation Tracking System (HITS) list. / ,
| |
| -
| |
| '
| |
| s
| |
| (a) Population Descriptions
| |
| NRC inspection verified that the systems listed by the CPRT ~
| |
| :
| |
| for inclusion in these three populations were designated in
| |
| Section 17A of the FSAR as safety related, either Safety
| |
| Cross checking
| |
| Class 1, 2, or 3, and Seismic Category I.
| |
| from FSAR Table 17A to the three populations, however,
| |
| identifiedthattheChilledWaterSystem(CWS)wasomitted
| |
| s
| |
| from the CPRT populations. Subsequent review of the
| |
| Population Items Lists did reveal that this CWS was included
| |
| in the population; it was only inadvertently left off the
| |
| The NRC inspector
| |
| Pcpulation Description lists of systems.
| |
| t
| |
| concurred with the listed population boundaries and the
| |
| - _ - - _ - _ - _ -
| |
| | |
| - ,
| |
| '
| |
| o
| |
| '
| |
| 0041.0.0
| |
| s
| |
| items not to be_ included within the scope of the
| |
| 7
| |
| >
| |
| populations. All CPRT sign-offs for review and approval as
| |
| % well as control and vaulting cf the population descriptions
| |
| were performsc per procedure.
| |
| l
| |
| l
| |
| l
| |
| '
| |
| (b) Master Population List
| |
| l
| |
| NRC inspector review of the original Master Population List
| |
| and all subsequent revisions. (one through five) verified
| |
| thattheabovethreepopulati$nswereincludedonthelist
| |
| < >
| |
| ,
| |
| and that review, approval, and control of the documents are
| |
| per procedure.
| |
| 1
| |
| (c) Population Items List
| |
| Each of the three Population Items Lists were derived from -
| |
| ..
| |
| .- -
| |
| ,
| |
| the{ame. Source-document _;;t[e7HITSlist. The CPRT initially
| |
| established the validity and accuracy of the HITS list and
| |
| '
| |
| then segregated out the three homogenous pipe support
| |
| 1
| |
| populations (LBSR,LBSN,andSBPS). To establish validity
| |
| and accuracy of the HITS list, the CPRT randomly selected
| |
| 60 B&R Hanger Location (BRHL) drawings out of the listed
| |
| total of 2013 and manually checked to see that all supports
| |
| 4 listed on the 60 BRHLs were also listed on the HITS list.
| |
| To verify the accuracy of the support status listed on the
| |
| (
| |
| HITS list, 60 supports were re.ndomly selected from the
| |
| <
| |
| 6
| |
| _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _
| |
| | |
| .
| |
| 4
| |
| 0042.0.0
| |
| 60 BRHLs and their status individually verified by checking
| |
| records in the various vaults and processing areas. This
| |
| was required because only final QC accepted pipe supports
| |
| were to be reinspected under the VII.c program. No
| |
| discrepant conditions were detected by the CPRT.
| |
| To assess validity and accuracy of the CPRT verification of
| |
| the HITS list, the NRC inspector selected 10 out of the
| |
| 60 BRHLs that the CPRT had reviewed, and verified that all
| |
| supports shown on the BRHLs were included on the HITS list.
| |
| .. To further assess the HITS list, ten additional BRHLs not *
| |
| l selected by the CPRT were selected by the NRC inspector and
| |
| l
| |
| l checked against the HITS list for support inclusion. These
| |
| ten BRHLs were selected such that a wide variety of
| |
| ! safety-related systems were included in the review.
| |
| Finally, the NRC inspector reviewed the support status of ,,
| |
| 10 of the 60 supports that the CPRT had verified by
| |
| .. ?
| |
| researching the various records in the various vault j[9idtct d> ,
| |
| locations.
| |
| (d) Work Process Memoranda
| |
| .
| |
| Revision 3 to Procedure CPP-005 dated May 28, 1986, required
| |
| all ISAP VII.c populations to have a Work Process
| |
| Memorandum. This memorandum was to identify safety-related
| |
| _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
| |
| | |
| _
| |
| _ - _ _ -- --_ ,
| |
| .
| |
| -
| |
| ,
| |
| , .
| |
| 0043.0.0- h-
| |
| l
| |
| construction work processes and attributes that can be
| |
| j
| |
| Reinspected and/or ver'ified by document review.
| |
| *
| |
| l .
| |
| .
| |
| ,
| |
| ~ t j
| |
| :,
| |
| '
| |
| During this report period, the Work Proc 0ss Memoranda were
| |
| v 3
| |
| ~
| |
| in the final draft stages; therefore, they will be reviewed
| |
| at a later date. This is an open item pending completion of
| |
| the Work, Process Memoranda (445/8702-0-01: 446/8702-0-01).
| |
| O .
| |
| (e) Revisi ns ]
| |
| , NRC review of all revisions to the Master Population Listi
| |
| ; Populat?on Descriptions, and the Population Items L"ist for
| |
| the three populations revealed'that the criteria' of
| |
| . Section5.5ofProcedureCPP-0UPwere~beingadheredtoas i
| |
| far as sign-offs for review and approval,' and control and ,
| |
| !
| |
| '
| |
| ,
| |
| thaultinooftheLubsequentrevisions .
| |
| ~
| |
| '
| |
| . 3
| |
| ; ;" ,
| |
| _ 't
| |
| h to violatidono*r deviations were identified.
| |
| ,
| |
| 1
| |
| .%
| |
| (2) Pipe Welds /Matefial (PIWM) ,
| |
| l
| |
| '
| |
| , :3 ;'- 4
| |
| s !
| |
| This population was created by combining the two populations
| |
| 1 a .
| |
| ; which were previously titled Largg* Bore Pipe Welds /Materiale
| |
| %.
| |
| '
| |
| (LBWM) and Small Bore Pipe WeldssNaterial (SBWM).
| |
| ,
| |
| In addition to
| |
| n .
| |
| 's"
| |
| '
| |
| this combination, mechanical equipment," site-made, pressure >
| |
| '
| |
| l
| |
| r ,
| |
| * t- .e4
| |
| 5 :y,
| |
| -
| |
| g
| |
| '
| |
| s1 , 1
| |
| 4 g 'g .4 \'
| |
| | |
| .
| |
| .
| |
| 0044.0.0
| |
| boundary welds were added to the PlWM population, and tubing
| |
| welds were organized into a separate pcpulation (TUWM).
| |
| (a) Population Description
| |
| NRC inspection verified that the systems listed by the CPRT
| |
| for inclusion in this population were designated in
| |
| Section 17A of the FSAR as safety related, either Safety
| |
| Class 1, 2, or 3, and Seismic Category I. In reviewing
| |
| Table 17A, bewever, it was observed that the Boron Thermal
| |
| ' Regeneration System, Combustible Gas Control System, Post -
| |
| l
| |
| Accident Sample System, and the Plant Gas System were.not i
| |
| listed in the CPRT Population Description, though they ;
| |
| should have been. Subsequent review of the Population items
| |
| List, however, verified that these systems were included in
| |
| the population; they were, apparently. inadvertently left , ,
| |
| out of the Population Description.
| |
| The hRC inspector cor. curs with the population boundaries,
| |
| items not included in the population, and specific
| |
| interfaces as listed in the Population Description.
| |
| .
| |
| (b) Master Population List .
| |
| NRC review of the original Master Population List and all
| |
| subsequent revisions (one through five) verified that this
| |
| - _ - _ _ _ _ _ _ _ - _ _ _ _ _ - - _ _ _ _ _
| |
| | |
| 4
| |
| .
| |
| 0045.0.0 ,
| |
| population was included on the list and that review,
| |
| approval, and control of the documents were per procedure.
| |
| (c) Population Items List
| |
| The source document for the Population Items List was the
| |
| B&R Comanche Peak Craig Computer Tracking System (CCTS) i
| |
| Report WEC-C-WE-REPORT issued June 12, 1985. This report
| |
| was a computer sort listirg all safety-related and QC'
| |
| accepted large and small bore pipe welds and instrument
| |
| ,
| |
| tubing welds. The weld was considered QC accepted when -
| |
| construction was complete and inspection holdpoints had been
| |
| accepted by QC as documented by QC signatures on the B&R
| |
| Weld Data Card (WDC).
| |
| !
| |
| 1he WEC-C-WE-REPORT included a total of approximately 66,000 .
| |
| )
| |
| . .
| |
| safety-related and construction-complete site-made welds. ]
| |
| To establish validity of the source document, the CPRT
| |
| performed the following reviews:
| |
| (1) Verified that the 591 site-made welds listed on the
| |
| ASME III N-5 Data Repor.t Index for the Unit 1 Auxiliary
| |
| Feed Water system were on the Population Items List.
| |
| l
| |
| i
| |
| ____ _ ___._________________m___ _ _ _ _ _ _ _ . _ _ _ _ _ . . _ _ _ _ _ __ _ _ _ _ _ . _ . . _ _ . _ _ _ _ _ _ . . _ . _ _ _ _ _ .
| |
| | |
| :
| |
| .
| |
| .
| |
| 0046.0.0
| |
| I
| |
| l (2) Reviewed all 26 Unit 1 BRP drawings for tie Residual l
| |
| l
| |
| Heat Removal system and 26 randomly Folmeted Unit 2 BRP l
| |
| drawings were listed on the Population items List.
| |
| l
| |
| f
| |
| (3) A review of 675 WDCs from several Unit 2 systems for
| |
| instrument piping welds was performed ano all welds'
| |
| were included.
| |
| (4) A review of the construction complete (C/I) status of I
| |
| the source document and the review showed that most of
| |
| ,
| |
| thedieselgenerator(Unit 1andUnit2)pipesite-made
| |
| welds had not been assigned a complete / incomplete
| |
| status under the C/I column. These welds were added to l
| |
| I
| |
| the source document to complete the Population Items j
| |
| l
| |
| !
| |
| List.
| |
| I
| |
| l
| |
| . . !
| |
| The NRC inspector initially compared the systems listed in
| |
| FSAR Table 17-A to the source document to assure !
| |
| consistency. Next, the NRC inspector randomly selected
| |
| i
| |
| 23 BRP drawings for Unit 1 and Unit 2 not previously
| |
| selected by the CPRT and verified that the 416 site-made
| |
| welds were included on the Population Items List. No
| |
| 4
| |
| omissions were noted, j
| |
| j
| |
| l
| |
| l
| |
| 1
| |
| | |
| .
| |
| .
| |
| 0047.0.0
| |
| l
| |
| To further verify accuracy of the CPRT approach,10 of the
| |
| 52 BRP drawings reviewed t'y the CPRT were compared to the
| |
| source document. No discrepancies were found. ,
| |
| (d) Work Process Memorandum
| |
| Revision 3 to Procedure CPP-005 dated May 28, 1986, required
| |
| all ISAP VII.c populations to have a Work Process
| |
| Herrorandum. This memorandum was to identify safety-related
| |
| construction work processes and attributes that could be
| |
| -
| |
| ' reinspected and/or verified by document review.
| |
| The Work Process Memorandum for PIWM was in draft form;
| |
| therefore, it will be reviewed at a later time. This is
| |
| another part of open item (445/8702-0-01; 446/8702-0-01).
| |
| .
| |
| (e) Revisions
| |
| NRC review of all revisions to the Master Population List.
| |
| Population Descriptions and the Population-Items List for
| |
| the PIWM population revealed that the criteria of
| |
| ;
| |
| Section 5.5 of Procedure CPP-005 were followed.
| |
| l
| |
| No vio'.etions or deviations were identified.
| |
| ,
| |
| (3) Concrete Placement (CONC)
| |
| | |
| _
| |
| .
| |
| i
| |
| .
| |
| 0048.0.0 ;
| |
| I
| |
| The concrete placement population contained 7617 concrete pours
| |
| l identified on a computer printout generated by B&R from concrete
| |
| ! pour cards.
| |
| )
| |
| l
| |
| (a) Population Descriptions
| |
| l
| |
| l
| |
| The NRC inspector reviewed ERC document QA/QC-RT-328,
| |
| Revision 0, " Population Description for Concrete Placement."
| |
| The population boundary included all Categcry I concrete
| |
| construction that had been completed and approved as of
| |
| i August 1, 1985. The Category 1 structures were listed in'
| |
| 1
| |
| Attachment A of the Population Description. The NRC
| |
| inspector verified that Attachment A agrees with the FSAR,
| |
| Section 3.2.1.1.1, which also lists Category 1 structures.
| |
| AsubsequentreviewofthePopulationItemsList(seebelow)
| |
| verified that the list contained concrete pours from each of , , j
| |
| the Category 1 structures listed in Attachment A. The NRC
| |
| inspector concurred with the population boundary and the
| |
| items not included within the scope of the population. The
| |
| CPRT review and approval as well as the filing of the
| |
| Population Description were performed per Procedure CPP-005.
| |
| .
| |
| (b) Master Population List
| |
| NRC review of the Master Population List, Revision 5, ,
| |
| ,
| |
| verified that the concrete placement population was included
| |
| | |
| .
| |
| .
| |
| 0049.0.0
| |
| on the list. Review, approval, and control of the Master
| |
| Population List was per Procedure CPP-005.
| |
| (c) Population Items List
| |
| The NRC inspector reviewed ERC document 0A/QC-RT-1628,
| |
| Revision 1, " Population Items List Concrete Placement." The
| |
| population source was a 254 page computer printcut generated )
| |
| {
| |
| from individual concrete pour cards by B&R. 1his list j
| |
| i
| |
| included the ennerete pour number, date poured and a brief
| |
| '
| |
| ,
| |
| description of the area poured for each of the 7617 concrete
| |
| pours in the population. According to this document, the
| |
| population list " . . . includes all safety-related concrete l
| |
| pours in Unit 1, 2 and areas conrnon to both units."
| |
| l
| |
| Attachment 6.3 of ERC Procedure CPP-005, Revision 3, states, .
| |
| in part, "The Responsible QA/QC Discipline Engineer . . .
| |
| Provides the basis for accepting the list as valio." In
| |
| addition, "The QA/QC Lead Discipline Engineer and the QA/QC l
| |
| l
| |
| '
| |
| Engineering Supervisor review Population Items Lists to
| |
| ensure that they are complete, accurate, and consistent with
| |
| the requirements of this procedure." ERC stated on the
| |
| i
| |
| Population Items List that the following three steps were
| |
| taken to validate the list:
| |
| l
| |
| | |
| 1
| |
| -
| |
| )
| |
| i
| |
| !
| |
| 0050.0.0
| |
| 1
| |
| 1) Twenty arbitrarily chosen pour numbers identified on
| |
| B&R drawings were found to be on the population list. )
| |
| l
| |
| 2) An arbitrary selection of concrete pours from
| |
| Inspection Report Logs were reviewed against the
| |
| population list and no discrepancies were identified.
| |
| 1
| |
| 3) A review of the population list confirmed that no time ;
| |
| I
| |
| gaps were apparent in the pour dates.
| |
| ,
| |
| The NRC inspector reviewed the steps taken by ERC to -
| |
| validate the population list for concrete placement. Only )
| |
| l
| |
| step 1 above was documented. A handwritten, unsigne.1 and
| |
| undated memo describes the 20 concrete pours (10 from the ,
| |
| !
| |
| random sample and 10 from the safe shutdown sample) that
| |
| were verified by ERC to be on the population list. This
| |
| . .
| |
| represents only 0.26% of the total population of 7617. The !
| |
| NRC inspector verified that the 20 concrete pours selected 1
| |
| !
| |
| by ERC were on the population list. j
| |
| The NRC inspector prepared a randomly selected list of
| |
| 134 concrete pours from 17 B&R drawings and compared this ]
| |
| q
| |
| list with the Population Items List to determine if the 1
| |
| 134 concrete pours were included. The following j
| |
| discrepancies were discovered:
| |
| i
| |
| | |
| .
| |
| 9
| |
| i
| |
| 0051.0.0
| |
| 1) Pour Nos. 205-9810-039 through 205-9810-056 are shown
| |
| as block-out type pours in the east diesel generator l
| |
| foundation, Unit 2, on Crawing 558-20655, Sheet 1, l
| |
| Revision 5. Pour Nos. 205-9810-040 and 205-9810-048
| |
| through 205-9810-056 were not on the Population Items
| |
| List and no corresponding pour cards could be obtained
| |
| in the TU Electric records center. Pour
| |
| Nos. 205-9810-039 and 205-9810-041 through 205-9810-047
| |
| were assigned on drawings at least twice and are shown,
| |
| for exaniple, on Drawings 558-20605, Sheet 1,
| |
| Revision 7, and 5S8-20618, Sheet 1, Revision 2, to be-
| |
| f
| |
| i
| |
| concrete curbs, removable slabs, etc.; not block-outs.
| |
| Pour Nos. 205-9810-039 and 205-9810-041.through
| |
| 205-9810-047 were on the Population Items List. They
| |
| did not, however, represent the block-out pours in the
| |
| diesel generator foundation as determined by checking , ,
| |
| the concrete pour cards. The NRC inspector verified by
| |
| field inspections that the block-out pours had been
| |
| ir.s talled.
| |
| 2) Pour No. 205-4822-003 is shown as a shielding wall for
| |
| ~
| |
| the Primary Sampling room on Drawings $58-20605,
| |
| Sheet 4A, Revision 0, and SSB-20605, Sheet 4,
| |
| Revision O. This pour number was not on the Population
| |
| Items List. A pour card for this pour was located in
| |
| the TV Electric Records Center. The NRC inspector
| |
| 1
| |
| | |
| l
| |
| .
| |
| !
| |
| '
| |
| i
| |
| 0052.0.0 )
| |
| i
| |
| !
| |
| !
| |
| J
| |
| verified by field inspection thet the shielding wall '
| |
| had been installed.
| |
| .
| |
| The above discrepancies indicate that the Population Items
| |
| List is not entirely complete and accurate and does not
| |
| include ". . . all safety-related concrete pours in
| |
| Unit 1, 2 and areas common to both units," as stated. The
| |
| ERC review of the Population Items List to ensure accuracy
| |
| and completeness was inadequate. This is a deviation I
| |
| (445/8702-D-02;446/8702-D-02). f
| |
| *
| |
| a
| |
| I
| |
| j
| |
| (d) Work Process Memorandum
| |
| 1
| |
| P.evision 3 to Procedure CPP-005 dated May 28, 1906, required
| |
| all ISAP VII.c populations to have a Work Process i
| |
| Memorandum. This memorandum was to identify safety-related
| |
| _
| |
| construction work processes and attributes that could be i
| |
| reinspected and/or verified by document review.
| |
| ]
| |
| The Work Process Memorandum for concrete placement was in
| |
| draft form; therefore, it will be reviewed at a later time.
| |
| This is another part of opencitem (445/8702-0-01; l
| |
| 446/8702-0-01).
| |
| !
| |
| '
| |
| (e) Revisions
| |
| .
| |
| !
| |
| l
| |
| 1
| |
| | |
| _ _ _ - - _ _ ___ __ - _ __ _
| |
| .
| |
| .'
| |
| 0053.0.0
| |
| NRC review of all revisions to the Master Population List,
| |
| Population Descriptions and the Population Items List for
| |
| the concrete placement' population revealed that the criteria-
| |
| of Section 5.5 of Procedure CPP-005 were followed.
| |
| !
| |
| No other violations or deviations were identified. !
| |
| (4) Electrical Populations
| |
| .
| |
| The NRC inspector reviewed the Population Items List
| |
| ,
| |
| docurrentation for each of the electrical populations to determine
| |
| which sources were used to develop the population and the basis l
| |
| 1
| |
| for the CPRT determination that th'e developed popu.lation was
| |
| accurate.
| |
| l
| |
| The NRC inspector found that the conduit, cable, cable tray, , ,
| |
| electrical equipment and NIS cable termination (CDUT, CABL, CATY,
| |
| EEIN, and NIST) population lists were generated'using the
| |
| TV Electric Electrical Management System (EMS) as a source. EMS ;
| |
| was a computerized cable and raceway schedule developed by site
| |
| personnel to track the status of Unit 1. Unit 2, and Common i
| |
| cables and raceways. Cable and receway changes authorized by
| |
| designchangeauthorizations'(DCAs)wereenteredintoEMSona
| |
| daily basis. The EMS then provided a printout of these daily
| |
| changes on a Daily Activities Report. Since EMS was neither a
| |
| required document nor controlled by procedures, the previous EMS :
| |
| ,
| |
| | |
| _ _ _ . . _ .
| |
| .
| |
| n i
| |
| .
| |
| l
| |
| 0054.0.0
| |
| 1
| |
| 1
| |
| revisions and Daily Activity Reports had not been retained as
| |
| permanent plant records. The NRC inspector observed that copies i
| |
| of the EMS printouts which had been used by ERC for population
| |
| list development, were retained in the QA/QC Review Team fi?es in
| |
| the CPRT document control center.
| |
| I
| |
| ;
| |
| The electrical cable (CABL) population was selected for a more
| |
| detailed NRC inspection to evaluate the implementation of the
| |
| appropriate precedures for establishing and accepting the
| |
| population.
| |
| l
| |
| .
| |
| ,
| |
| (a) Population Description
| |
| I
| |
| The NRC inspector's review of the Population Description for
| |
| cables identified that the population was to include all
| |
| l
| |
| Class 1E, safety-related power, control and instrument , ,
| |
| cables. The population boundary for samples selected for
| |
| reinspection / documentation reviews was restricted to those
| |
| cables which had been installed, terminated on both ends and
| |
| QC accepted. Excluded from the population were electrical
| |
| l
| |
| conductor seal assemblies, NIS cable connectors, and
| |
| unscheduled lighting (except for separation barrier material
| |
| inspections). These three groups were excluded from the
| |
| cable population because they were included in other
| |
| t populations. The NRC inspector concurred with the
| |
| population boundary and the items not included within the
| |
| i
| |
| | |
| .
| |
| 0055.0.0
| |
| scope of the population. The CPRT review and approval as
| |
| i
| |
| well as the filing of the Population D3scription was
| |
| performed per Procedure CPP-005.
| |
| l
| |
| (b) Master Popula' tion List
| |
| ;
| |
| !
| |
| NRC review of the Master Population List, Revision 5,
| |
| verified that the electrical cable population was included i
| |
| on the list. Review, approval, and control of the Master
| |
| Population List was per Procedure CPP-005. -)
| |
| -
| |
| !
| |
| , 1
| |
| 1
| |
| (c) Population Items List !
| |
| :
| |
| f
| |
| A comparison of the items documented in the Cable Population l
| |
| Items List to the items required by CPP-005 was perforrred.
| |
| The list was divided into three parts: Population List , ,
| |
| Source; Basis for Accepting the List; and Basis for
| |
| Accepting any Additional Items. The NRC inspector
| |
| determined that the provided information met the
| |
| requirements of CPP-005.
| |
| ~
| |
| The Population List Source contained the listing and
| |
| description of the documents used to develop the listing of
| |
| applicable electrical cables. The sources referenced were
| |
| '
| |
| the EMS cable report (ELE SAFETY RPT) dated June 17, 1985,
| |
| and the Gibbs & Hill (G&H) Lighting Panel Schedule, Drawings
| |
| l
| |
| l
| |
| | |
| .
| |
| '
| |
| i
| |
| 0056.0.0
| |
| 2323-El-0942-01 through -05 and E2-0942-01 through -03. NRC
| |
| inspector review of these documents disclosso that Drawing
| |
| 2323-E2-0942-03 does not exist. The NRC inspector then
| |
| reviewed the file applicable to the Basis for Accepting the
| |
| List. While no problems were identified with this file, the
| |
| NRC inspector questioned how the EPS was validated es a
| |
| complete source of applicable electrical cables. The NRC
| |
| inspector was informed that the QA/QC discipline engineer
| |
| '
| |
| responsible for the cable population had selected 30 cables j
| |
| aach from the raceway schedules for Unit 1 and Unit 2 u
| |
| (2323-El-1700 and 2323-E2-1700) and then compared these - i
| |
| i
| |
| cables to the EMS listing he had used. The NRC inspector
| |
| noted that the population included cables whi.ch were
| |
| deleted, spared, not yet QC accepted, not yet installed, and
| |
| those which may not be accessible, and that the validation
| |
| process was not a procedurally required formal process nor , ,
| |
| was it documented. The NRC inspector determined, however,
| |
| that the requirements of CPP-005 had been fulfilled in ,
| |
| i
| |
| establishing this population.
| |
| In an effort to evaluate the acceptability of the cable
| |
| population (which containedi over 14,000 cables) the NRC
| |
| inspector chose an arbitrary sample of affected cables. 'l
| |
| Between 1 and 6 cables from each safety-related plant system f
| |
| !
| |
| from the Unit I and the Unit 2 raceway schedules and
| |
| 14 cables from the unscheduled lighting panel drawings were $
| |
| I
| |
| | |
| .
| |
| .
| |
| I
| |
| 0057.0.0
| |
| selected. This resulted in a sample which contained
| |
| i
| |
| 125 cables from 55 systems in Unit I and 122 cables from
| |
| 51 systems in tinit 2. These cables were then compared to
| |
| the cable population list obtained from the QA/QC Review
| |
| Team Records Control Vault to provide assurance that the
| |
| population list used by ERC was complete. The comparison of
| |
| l these lists produced the following findings:
| |
| 1) The list of Essential and Emergency Lighting cables was
| |
| }
| |
| rot in the file, ,
| |
| '
| |
| i
| |
| l
| |
| l 2) Pages 813 and 814 of the EMS listing were missing from
| |
| i the file,
| |
| i
| |
| 3) Cable E0000425 was not included in the file list, and
| |
| 4) Cable E0135036 was shewn as EG135036 in the file list. f
| |
| The NRC inspector then determined that: a copy of the list
| |
| of Essential and Emergency Lighting cables was available in
| |
| the electrical conduit population files; the missing EMS
| |
| pages were available from working copies; DCAs 18,100
| |
| and 10.547 authorized a designation change for cable
| |
| E0000425 to A0000425; and the improper separation train
| |
| designation (G vs. 0) for cable E0135036 was a data entry
| |
| error. The NRC inspector found that the population list was
| |
| | |
| - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _
| |
| .
| |
| 4
| |
| 0058.0.0
| |
| acceptable. However, the condition of the record files net
| |
| being complete as evidenced by 1) and 2) above is a
| |
| deviation from ERC Procedure CPP-004, " Project Working
| |
| Files," Revision 2, dated December 17, 1985 (445/8702-D-03;
| |
| 446/8702-0-03).
| |
| (d) Work Process Memorandum
| |
| Pevision 3 to Procedure CPP-005 dated May 28, 1986,' required
| |
| all ISAP VII.c populations to have a Work Process
| |
| .
| |
| Memorandum. This memorandum was to identify safety-related
| |
| i
| |
| I
| |
| construction work processes and attributes that could be
| |
| reinspected and/or verified by document review.
| |
| )
| |
| The Work Process Memorandum for cable was only in draft
| |
| form; therefore, it will be reviewed at a 16ter date. This .
| |
| is another part of open item (445/8702-0-01; 446/8702-0-01).
| |
| (e) Revisions
| |
| NRC review of all revisions to the Master Population List,
| |
| Population Descriptions and the Population Items List for
| |
| the cable population revealed that the criteria of
| |
| Section 5.5 of Procedure CPP-005 were followed.
| |
| . . .. . .
| |
| _. . .. . .
| |
| .
| |
| .. _ . .. .
| |
| .
| |
| | |
| 1
| |
| '
| |
| l
| |
| *
| |
| l
| |
| !
| |
| 0059.0.0
| |
| No violations or deviations other than as discussed in (c),
| |
| above, were identified. ;
| |
| '
| |
| b. Reinspection of HVAC Equipment Installation (HVIN)
| |
| l
| |
| Status of CPRT Activity l
| |
| l
| |
| A total of 181 HVAC equipment packages were randomly selected and
| |
| inspected from a population of 604 packages representing Units 1,
| |
| 2 and common. A total of 331 DRs were written with 187 determined to
| |
| i be valid. ERC has completed all planned HVAC equipment installation'
| |
| reinspection.
| |
| ,
| |
| Status of NRC Inspection Activity
| |
| The NRC inspector reviewed the HVIN population with respect to HVAC ,
| |
| fire dampers and their inclusion in the population. The NRC inspector
| |
| identified that approximately 30% of the first and second sample were
| |
| fire dampers that were statused as " Abandoned In Place." This raised
| |
| a question with respect to the inclusion of nonsafety-related
| |
| eouipment in the population. This was discussed with the population
| |
| engineer who provided the following inf'ormation. Fire dampers are not
| |
| required for a safe shutdown but were included in the HVIN population
| |
| as an accessory connection and were reinspected to verify proper-
| |
| mounting and bolting, but not operability. A visual inspection was
| |
| 1
| |
| !
| |
| J
| |
| .-_ _D
| |
| | |
| . - -- -
| |
| _ _ _ _ _ _ ,
| |
| I
| |
| ,
| |
| .
| |
| 0060.0.0
| |
| l
| |
| also performed for configuration. This information was subsequently l
| |
| included in a letter to file No. QA/QC-RT-5584 dated February 2,1987.
| |
| The NRC inspector found this to be consistent with ISAP VII.c
| |
| regarding population items list development.
| |
| The NRC inspector has previously witnessed four inspections and
| |
| performed five inspections, with no further inspection activity
| |
| planned for this population.
| |
| 1
| |
| No violations or deviations were identified.
| |
| 1
| |
| .
| |
| ,
| |
| 5. ISAP Sample Selection Process
| |
| '
| |
| The purpose of this NP.C inspection was to determine whether the methods
| |
| used to select items and related documentation for reinspection or review
| |
| was performed in accordance with the requirements of the CPRT Program Plan, .
| |
| Appendix 0, Revisions 0 and 1 "CPRT Sampling Policy Applications and
| |
| Guidelines." Appendix D prescribes the various applications of sampling
| |
| within the CPRT program and defines guidelines for selecting samples
| |
| whenever random sampling techniques are used in ISAPs and Design Specific
| |
| ActionPlans(DSAPs). This inspection was restricted to the review of ISAP
| |
| sample selections. The scope of the inspection covered electrical,
| |
| mechanical and piping, QA/QC, and the Quality of Construction ISAPs. The
| |
| preoperational and testing ISAP sample selection was reviewed in a previous
| |
| inspection with results documented in NRC Region IV Inspection Report
| |
| 50-445/85-18; 50-446/85-15. Another activity previously inspected by the
| |
| (
| |
| | |
| i
| |
| <
| |
| l
| |
| l
| |
| l
| |
| l
| |
| 0061.0.0
| |
| l
| |
| '
| |
| NRC fur compliance to Appendix D was the ERC Overview Inspection Program's
| |
| sample selection. Results of this inspection were documented in NRC
| |
| ]
| |
| Region IV Inspection Report 50-445/86-22; 50-446/86-20.
| |
| !
| |
| l
| |
| The NRC approach used to review ISAP documentation and the inspection of )
| |
| samples selected was: (1) to review the requirements identified in
| |
| 1
| |
| Appendix 0 and the applicable procedures, and (2) to verify implementation )
| |
| 1
| |
| of the sample selection prccess by comparing the samples selected to the i
| |
| controlling commitments. Samples were then reviewed to assure that: rancom
| |
| number selection and item number calculations were correct; items
| |
| '
| |
| identified for inspection had a valid sample number and a random number
| |
| assignment; errors in the selection of items for inspection had been
| |
| resolved; departures from the sampling process had been identified;
| |
| 1
| |
| ,
| |
| populations were clearly defined and segregated; acoitional sampling
| |
| required to achieve minimum sample size (based on population size increase)
| |
| was correct and documented; expansion of sample size, based on identified
| |
| ~
| |
| l
| |
| l
| |
| hardware deficiencies, conformed to requirements; and the sample selection
| |
| 1
| |
| process w6s suitably documented to provide an auditable trail, j
| |
| l
| |
| 1
| |
| Of the 19 external source issue ISAPs considered for inspection,
| |
| '
| |
| 5 completed and 1 inprocess ISAP were inspected. From ISAP VII.c, 5 of
| |
| 31 inprocess populations were inspected. The following are the results of
| |
| this NRC inspection.
| |
| a. QA/QC ISAPs
| |
| l
| |
| _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ - _ _ _ _ - _ - _ _ _ _ _ _ - _ _ _ . _ _ .
| |
| - _ ,
| |
| | |
| ,
| |
| .
| |
| ,
| |
| ,
| |
| 0062.0.0
| |
| l i
| |
| !
| |
| (1) ISAP VII.a.2: Nonconformance and Corrective Action (inprocess).
| |
| j
| |
| J
| |
| I
| |
| This ISAP contained six populations, each requiring a separate
| |
| sample selection that would provide a 95/5 screen to detect
| |
| ,
| |
| l programmatic or systematic deficiencies. (The 95/5 screen or
| |
| sampling plan provides a 95% confidence that not more than a j
| |
| i
| |
| 5% deficiency rate exists in the sampled population.) Of the six l
| |
| 1
| |
| populations, the sample selection for NCRs covering the years
| |
| 1975 to 1977 was reviewed by the NRC inspector. Twenty-one of )
| |
| 1
| |
| . the sixty-three selected samples were examined. No errors were '
| |
| noted in random number calculations or sample item identification
| |
| from the population item list. It was determined, based on the
| |
| NRC inspection, that the NCR sample selection conformed to l
| |
| Appendix D requirements.
| |
| !
| |
| . , ;
| |
| ISAP VII.b.2: Valve Disassembly (complete). !
| |
| (2) ,
| |
| i
| |
| During the NRC's inspection of VII.b.2, no errors in the 95/S
| |
| sampling plan were found. The NRC inspector reviewed 21 of the t
| |
| 111 sample selections and found them to conform to Appendix D;
| |
| ERC's implementing Procedure QAI-002, Revision 2, " Sample
| |
| Selection"; and CPP-006, " Sample Selection." Prior to completion
| |
| and issuance of the VII.b.2 Results Report (RR) on March 19,
| |
| 1986, ERC's QA/QC surveillance group and the Results Report
| |
| ,
| |
| Review Conmittee's (RRRC) review of sample selection identified
| |
| j
| |
| | |
| _ _ _ _ - _ - _ - _ _ ._ _ _ _
| |
| 1
| |
| 1
| |
| .
| |
| 0063.0.0
| |
| i
| |
| errors in the selection process. Corrective action by the ISAP j
| |
| 1
| |
| issue coordinator included revising the Random Sample
| |
| Identification List and performing additional hardware
| |
| reinspection. j
| |
| i
| |
| l
| |
| b. Electrical ISAPs
| |
| (1) ISAP 1.a.1: Heat Shrinkable Insulation Sleeves (Revision 1 of
| |
| the RR issued December 30,1986).
| |
| ,
| |
| The NRC inspected 13 of the 111 samples selected for this ISAP.- ,
| |
| 1
| |
| From the CPRT reinspection of the initial 60 items randomly i
| |
| selected, provid'ng a 95/5 sampling plan, one was considered to
| |
| )
| |
| be a defect requiring sample expansion. As required by !
| |
| Appendix D of the CPRT Program Plan, the sample was expanded by
| |
| an additional 35 randomly selected items. Four of the additional ,
| |
| !
| |
| thirty-five samples were found to be invalid and were deleted
| |
| because they represented locations that did not use heat
| |
| shrinkable insulation sleeves. To reach the required expanded 1
| |
| I
| |
| sample size, seven addit 1onal items were selected. Thus, the )
| |
| i
| |
| total valid samples selected by CPRT for reinspection was 98; )
| |
| i
| |
| however, during implementation ofcISAP I.a.2, " Inspection Reports l
| |
| on Butt Splices," 146 items were discovered th6t had been
| |
| inadvertently excluded from the original heat-shrinkable
| |
| insulation sleeve population. Proportional sampling was used on
| |
| this additional population by selecting 12 of the 146. The CPRT
| |
| I
| |
| ____-_-_a
| |
| | |
| .
| |
| .
| |
| i
| |
| 0064.0.0
| |
| advisor on engineering statistics approved the use of this
| |
| proportional sampling which was not addressed in Appendix D of
| |
| the CPRT Program Plan.
| |
| Due to errors in the calculation of the random numbers, one item
| |
| that should have been inspected in the additional 35 items
| |
| selected had been omitted. This item was, however, inspected and
| |
| is referenced in the working files as the " missed sample." With
| |
| the inspection of the " missed sample," the total number of valid
| |
| randomly selected items inspected was brought to 111 (the initial
| |
| i 98,12fromproportionalsampling,andtheone"missedsample").
| |
| Based on the review of sample selection documentation, detailed
| |
| inspection of 13 sample selections, and a review of other
| |
| sampling activities associated with this ISAP, the NRC inspector
| |
| determined that the 1.a.1 sample selection process confomed to .
| |
| Appendix D.
| |
| l
| |
| (2) ISAP I.a.4: Agreement Between Drawings and Field Terminations l
| |
| (Revision 2 of the RR, issued July 23,1986).
| |
| Of all the ISAPs and VII.c populations using random sampling,
| |
| this ISAP used a 95/1 screen instead of 95/5. Both screening
| |
| techniques are addressed in Appendix 0, Table 1. As with
| |
| ISAP I.a.1, additional population items were discovered during
| |
| ISAP implementation. Proportional sampling was again used and
| |
| | |
| 1
| |
| $ j
| |
| '
| |
| !
| |
| 0065.0.0
| |
| <
| |
| approved by the ERC engineering statistics advisor. Based on a
| |
| review of sample selection documentation and verifying in detail
| |
| the selection process (38 out of 383 selected items), the NRC
| |
| inspector determined that I.e.4 sampling conformed to Appendix D.
| |
| j
| |
| c. Mechanical ISAPs:
| |
| l
| |
| (1) ISAP V.a: Inspection for Certain Types of Skewed Welds in NF
| |
| ._ l
| |
| Supports (iiiiissuedOctober..22, 1986) C
| |
| I
| |
| , The NRC inspector examined in detail 16 of the 60 samples ~
| |
| se'lected and found sample selection conformed to Appendix D;
| |
| however, three documentation inconsistencies were.noted between
| |
| the Random Sample Identification List (RSIL) and ERC Procedure
| |
| QI-006, Attachment 6.5, Revision 2. Listed on Attachment 6.5
| |
| 4
| |
| were the 60 hangers inspected by ERC as taken from the RSIL. The ,
| |
| inconsistency was not with the actual unique hanger number, but l
| |
| with the alphanumeric suffix character which indicates the type
| |
| i
| |
| of hanger; i.e., A-anchor, S-spring, R-rigid, or K-snubber.
| |
| ,
| |
| Three hanger types were incorrectly coded as "K" instead of "R".
| |
| l
| |
| 4
| |
| The suffix characters also identify building, elevation, and code I
| |
| class. From reviewing the actual packages inspected, the NRC i
| |
| irspector verified that the correct hangers were selected and j
| |
| i
| |
| inspected. The ISAP V.a issue coordinator is in the prccess of ;
| |
| i
| |
| correcting the documentation inconsistencies identified by the i
| |
| NRC.
| |
| t
| |
| i
| |
| I
| |
| )
| |
| | |
| - _ _ _ _ _ _ _ _ _ ____
| |
| $
| |
| .
| |
| 0066.0.0
| |
| -
| |
| -.
| |
| J
| |
| (2) ISAP V.d: Plug Welds (Revision 1 of the RR, issued December 18,
| |
| h)'.
| |
| This ISAP contained four populations. Sample selection for each
| |
| population was based on the 95/5 screen. The NRC inspector
| |
| examined 67 of the 750 sample selections from the 4 populations.
| |
| Eleven errors were found by the NRC inspector involving random
| |
| number calculations and item selections. It should be noted that
| |
| prior to the issuance of the RR (Revision 1), the statistical
| |
| advisor reviewed 100% of this ISAP's sample selection. Based on
| |
| ,
| |
| this review,14 of the 250 samples had been identified with the-
| |
| same type errors that the NRC inspector had identified. These
| |
| 14 errors included the 11 errors found by this NRC. inspection.
| |
| The scope of the statistical advisor's review of sample selection
| |
| is further discussed in paragraph e. below. Based on results ,
| |
| I
| |
| obtained from ERC inspections, plug weld testing, and bounding ,
| |
| I
| |
| analysis performed by Ebasco, the statistical advisor determined
| |
| the errors found in the sample selection did not impact
| |
| inspection results nor was there a need to reopen the inspection
| |
| program. Since the errors resulted in a different item being
| |
| inspected and the statistical advisor's determination that the
| |
| sampling process was not compromised, it was not necessary for
| |
| these errors to be corrected.- This conclusion was supported by
| |
| referenced documentation which was found in the RR working file.
| |
| .
| |
| | |
| - _ _ _ _- _.
| |
| i
| |
| '
| |
| .
| |
| .
| |
| 0067.0.0
| |
| l
| |
| d. ISAP VII.c: Construction Reinspection / Documentation Review Plan !
| |
| 1
| |
| '
| |
| (inprocess).
| |
| I
| |
| This ISAP is unique because the VII.c work activities are divided into
| |
| 32 homogenous populations. On completion of all work activities, a
| |
| summary RR will be issued. Details of reinspection and document j
| |
| reviews performed will be addressed as appendices to the summary RR.
| |
| At the time of this NRC inspection., the RR and associated appendices
| |
| were in their draft form and subject to various CPRT inprocess I
| |
| reviews; e.g., RP,RC, ERC engineering assurance and QA.
| |
| .
| |
| Thirty-one of the thirty-two populations used statistical random
| |
| sample selection with the 95/5 screen. The NRC inspector examined
| |
| sample selections fer 5 of the 31 populations that used statistical
| |
| sampling. From these 5 populations, 154 of the 502 sample items
| |
| selected were inspected for compliance to Appendix D of the CPRT q
| |
| ,
| |
| Program Plan and ERC Procedure CPP-006, Revision 3, " Sample
| |
| Selection." Procedure CPP-006 was more prescriptive than Appendix D i
| |
| i
| |
| in that it provided ERC personnel with details for implementing the j
| |
| i
| |
| requirements for sample selection. The five populations inspected by !
| |
| I the NRC were: Cable Tray, Nuclear Instrument System Cable Termination, !
| |
| '
| |
| !
| |
| Electrical Equipment Installation, Instrumentation Equipment
| |
| Installation, and Large Bore Piping Configuration. l
| |
| !
| |
| Typical errors encountered were calculation of random sample number, I
| |
| i
| |
| use of duplicate random numbers; incorrect population item used; l
| |
| ;
| |
| _ _ _ _ _ _ _ _ _ _ _ _ .
| |
| | |
| --- _
| |
| '
| |
| i s
| |
| '
| |
| >
| |
| '
| |
| 0068.0.0
| |
| '
| |
| 3
| |
| 1
| |
| '
| |
| deviations from Appendix D not adequately documented; selection of >
| |
| items related to safe shutdown; and numbering of inspection work x
| |
| 7,
| |
| packages. The potenc.ial impact of these errors was that not all items
| |
| in a given homogenous population had an equal chance of being selected
| |
| fer reinspection review. Problems encountered that were not '
| |
| s
| |
| (
| |
| deviations from Appendix D or CPP-006 but made vtH fication of sample
| |
| selection difficult were; inadequate guidance for proportional ,t
| |
| l
| |
| sampling which was necessary when increases in population sizes were j.
| |
| j
| |
| required methcdofnumberingPopulationItemLists;andinadequate
| |
| guidance for the resolution of problems encounter d during sample
| |
| ,
| |
| selection. These errors and problems are rther iscussed below. -
| |
| l
| |
| l
| |
| l
| |
| x 1
| |
| '
| |
| 1
| |
| e. Sample Selection Review by the SRT j
| |
| The statistical advisor to the CPRT has conducted and is continuing to ;
| |
| I
| |
| conduct reviews of ISAP sample selection. By direction of the SRT,
| |
| the statistical advisor was required to conduct reviews of those ISAPs
| |
| and VII.c. populations using sample selection to assure conformance tc
| |
| Appendix D. This requirement was delineated in CPRT' memorandum
| |
| CPRT-138 dated December 3, 1985, which the statistical advisor stated
| |
| is being implemented by a 100% review of the semple selection process
| |
| forallISAPsandVII.cpopulationsutilizingstatistjcalsampling.
| |
| To date, the statistical advisor has reviewed 100% of the samph
| |
| selection process for 9 cf 22 ISAPs and 19 of the 31 VII.c.
| |
| populations using statistical san:pling.
| |
| | |
| ,.
| |
| 1
| |
| 3 !
| |
| '
| |
| o
| |
| 4
| |
| -s f
| |
| q 0069.0.0
| |
| \
| |
| !
| |
| A checklist was developed and used by the statistical advisor to
| |
| \
| |
| 'l perform the reviews and to document the findings and actions required.
| |
| ,
| |
| s On complet%n of the' review, the issue coordinator or population
| |
| [ engineer was given a copy of the checklist. Each finding and the
| |
| i
| |
| actions required were discussed with the audited group. A formal
| |
| tracking mechanism to verify comhletion of actions required had not, '
| |
| as yet, beer. ceveloped or implemented. From interviews with the
| |
| statistical advisor, a formal procedure and tracking system will be I
| |
| J
| |
| devekped and implemented to assure actions required are completed in
| |
| 3 a timely manner. This activity will be followed by the NRC as an open
| |
| '
| |
| s
| |
| item (445/67C2-0-04; 446/8702+-0-04). -
| |
| \
| |
| ,
| |
| ,
| |
| Each of the errors and problems fcund by the NRC inspector had been
| |
| identified ar.o occumented by the statistical advisor.
| |
| i t t
| |
| ToassurethatnoRRispublishedwyth'cpensampleselectionerrors, , ,
| |
| the RRRC revised its working file check ' list on February 17, 1987, to
| |
| require all open sampling errors identified against a RR be resolved ,
| |
| prior to RRRC approval of the working file and submittal of the RR to
| |
| I
| |
| the SRT.
| |
| ) ,
| |
| ,
| |
| f
| |
| f. ERC's Review of ISAP brd VII.c Sample Selection
| |
| \
| |
| (1) Engineering Assurance:
| |
| , 1
| |
| - _ _ - - _ _ _ _ _ - _ -
| |
| | |
| ,
| |
| i
| |
| ;
| |
| .
| |
| 0070.0.0
| |
| I
| |
| l
| |
| ,
| |
| ERC has established an engineering assurance (EA) group to
| |
| i
| |
| perform final review and assembly of records and supporting
| |
| documentation (working file) required for ISAP VII.c prior to
| |
| turnover to the CPRT central file. This effort h overred by
| |
| ,
| |
| Procedure CPP-026, Revision 0, " Final Review of ISAP VII.c
| |
| l
| |
| l Working Files." EA had perfonned an initial review of VII.c
| |
| sample selection during July and August 1986. A written
| |
| checklist was used to direct the review and document findings for
| |
| follow-up. Several items remain open. It should be noted that
| |
| l during the EA initial review of sample selection not all sample
| |
| , selections were finalized. Work was still inprocess to develop-
| |
| and complete some populations and perform sample selections. The
| |
| final review by EA for sample selection was scheduled to start in
| |
| February 1987, but was contingent on Population Rancom Selection
| |
| Identification Lists being completed and approved.
| |
| (2) Quality Assurance:
| |
| The QA surveillance group had perfortned indepth reviews of sample
| |
| selection during surveillance of inprocess activities on ISAPs.
| |
| For example, in ISAP VII.b.2, a number of errors were detected by
| |
| QA prior to completion ano publication of the RR. The noted
| |
| errors were corrected and reviewed by QA for adequacy.
| |
| Surveillance report II CS06 documented QA's review of
| |
| VII.b.2 sample selection. Rather than perform a 100% review of
| |
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| EA work, QA will review the EA ISAP V!I.c work on a sampling ,
| |
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| basis to assure the proc #s t conformed to procedural requirements.
| |
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| |
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| |
| In addition to surveillance of ISAP sample selection, the ERC QA
| |
| audit group had perfo*wed two programmatic audits of the sampling
| |
| process as documer[fid in ERC audit reports ERC-P6-05 and #
| |
| ERC-86-06. No findings were noted in those audit reports. .
| |
| , ,
| |
| ' l
| |
| g. Overview Qualfty Tecm (00T)
| |
| s1 .
| |
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| |
| '
| |
| ' Baseheninteviewswith0QT,thesampleselectionprocessforseveral
| |
| 3
| |
| .
| |
| ISAPshavebeenoverviewedenacase-by-casebasis;howeser,nc
| |
| indepth prograrratic review of ISAP sample selection was scheduled.
| |
| t$e responsibility for ISAP sample selection verification had been
| |
| placed with the CPRT statistical aavisor and the RRRC.
| |
| !
| |
| In sumrtary, of the 50 action plans using sample selection (19 external s - '
| |
| l issue ISAPs and 31 VII.c populations), the NRC inspected 11 for conformance
| |
| to Appendix D. From khe 11 action plans, 330 of the 1480 sample .selectione
| |
| were examined for erhors by the NRC inspector. Foi those action plans l
| |
| s inspected, the sample selection efforts were found to conform to
| |
| ' ppendix D.f Those errors in the sampling process that were identified by
| |
| A
| |
| -
| |
| .
| |
| the NRC inspector had also been identified by the CPRT statistical advisor
| |
| _
| |
| ar.d action to correct or (Ts(osition the errors had either been taken or
| |
| '
| |
| was being taken. ;i
| |
| s -, g .s i
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| .__ _ _ - - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - - - _ - _
| |
| .,
| |
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| |
| 0072.0.0
| |
| At present, the statistical advisor does not have a system to verify the
| |
| completion of action required to correct or disposition idertified errors. I
| |
| A comitment has been made to develop and implement such a system. This
| |
| comitment will be followed as a NRC open item.
| |
| >
| |
| No violations or deviations were identified.
| |
| l
| |
| 6. Exit Interview
| |
| Exit interviews were conducted February 10, 1987, ard March 3, 1987, with
| |
| the applicant's representatives identified in paragraph 1 of Appendix C of. l
| |
| .
| |
| this report. During these interviews, the NRC inspectors sumarized the
| |
| scope and findings of the inspection. The applicant acknowl. edged the
| |
| findings.
| |
| ..
| |
| .
| |
| k.
| |
| }}
| |