IR 05000445/1987002
| ML20216C252 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/22/1987 |
| From: | Barnes I, Ellershaw L, Hale C, Spessard R, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20216C144 | List: |
| References | |
| 50-445-87-02, 50-445-87-2, 50-446-87-02, 50-446-87-2, NUDOCS 8706300248 | |
| Download: ML20216C252 (34) | |
Text
w . ,
2 ',
'. !
"" ',
'
b
. . .
l'
.( .
- y 'A
-
- 4
,;,
'
g
-
.a- 1 ,
7,.
4 ,- .#,
_
," ,- <-
( ,
q
.;
,
ff 1
..
. APPENDIX'B'
.m
'
'
, ,
'NRC COMANC 5 PEAK RESPONSE TEAM-ACTIVITIESLINSPECTION REPORT
~
"
', e .. S. NUCLEAR REGULATORY COMMISSION-4 REGION.1V,
- ,
r NRC Inspection Report: '
50.445/87-02 Permits: . CPPR-126
< J' '50-446/87-02~ CPPR-127'
ct ; Dockets: 50-4451 Category: $2E 50-446--
.
, Construction' Permit-Expiration Dates: ..
..' . Unit 1: August.1, 198 ' Unit 2: August'1, 1987-Applicant: TV Electri tSkyway Tower 400 North Olive Street
,
Lock. Box 81 <
Dallas,: Texas .
75201 e
'
Facility Name': Comanche Psak Steam Elect'ric Station-(CPSES),:
Units'l'& 2 Inspection At: . Glen Rose,-Texas
,
Inspection Conduct d:2 January 1 through. February 28, 1987-Inspectors:- n ~
/I k
- - L' E. Ellershaw, Reactor. Inspector, Region IV Dath /
CPSES Group _ . .
E (paragraphs 2.a-f, 2.h-1, 2;n, 2.s, 3.c, 4.a,'and 4.b)
l C. J. %Te, Reactor Inspector, Region IV Date / i CPSES Group (paragraphs 2.g, 2.m, 2.q-r, 3.b, 3.d, and 5) ;
i. t
-
'
.
" [U64 &
P..C. Wagner, React 6r Inspector, Region IV (o ft 5 / 8 7 Date l
!
CPSES Group i (paragraphs 2.0 p, 3.a, and 4.a)
<
"
8706300248 870622 o n_
"
, PDR ADOCK 05000445 .
~ G- PDR ,
j J
r,
. ,
l 2 l i
i i
Consultants: EG&G J. Dale (paragraphs 2.a-f, 2.h, 2.j-1, and 4.b) !
A. Maughan paragraphs 2.0-p and 4.a)
W. Richins paragraphs 2.n and 4.a)
V. Wenczel paragraph 5)
..
Parameter -K.J.Graham Birmingham (paragraphs (paragraphs 2.1, 2.s,2.g, and .c 2.q-)r, 3.b, and 3.d)
D. Jew (paragraph 4.a)
Reviewed By: G /15 /97 :
R. L. Spessard, Deputy Director, Divisi @ of Date l Inspection Programs, Office of Inspect 1on i and Enforcement Approved: " $ 7 I. Barnes, Chief, Region IV CPSES Group Date i
Inspection Summary i Inspection Conducted: January 1 through February 28, 1987 (Report 50-445/87-02; 50-446/87-02)
Areas Inspected: Nonroutine, unannounced inspection of applicant actions on previous inspection findings, Comanche Peak Response Team (CPRT) Issue-Specific Action Plans (ISAPs), assessment of VII.c populations, and the ISAP sample selection proces l
Results: Within the four areas inspected, two deviations (several concrete pours were not included on the Population Items List, paragraph 4.a.[3]; and documents missing from the ISAP VII.c project files, paragraph 4.a.[4]) were identifie .
l
,
1
!
l I
e_ e
3 !
l
DETAILS i l
!
' Persons Contacted
- J. M. Ayres, Quality Engineering (QE) Supervisor, TV Electric
- R. P. Baker, Regulatory Compliance Manager, .TV Electric
- J. L. Barker, Engineering Assurance Manager, TV Electric -
- J. W. Beck, Vice President, TU Electric j
- E. J. Brabazon, Deputy Program Manager, CPRT
T. Braudt, CPRT, TV Electric
'**
J. A. Buck, Senior Review Team (SRT), CPRT l
- W. G. Counsil,. Executive Vice President, TV Electric
- R. D. Delano, Nuclear Licensing Engineer, TU Electric D. Ferguson, Results Report Review Committee Chairman, CPRT t
- J. R. Gelzer, Issue Coordinator, ERC l
- M. R. Gross, Jr., Staff Member, CPRT !
- J. Guibert, SRT, CPRT !
- P. E.'Halstead, Site Quality Control-(QC) Manager, TV Electric j
- T. ' L. Heatherly, Regulatory Compliance Engineer, TU Electric j
- G. S. Keeley, Nuclear Licensing Manager, TU Electric ,
'
- J. E. Krechting, Director of Engineering, TV Electric ;
D. McAfee, Quality Assurance (QA) Manager, TV Electric l
J. McNally, Population Engineer, ERC
J. W. Muffett, Executive Assistant, Engineering & Construction, .j TU Electric i
- L. D. Nace, Vice President, TV Electric i
- D. M. Reynerson, Unit 2 Project Manager, TV Electric 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, TV' Electric
- M. R. Steelman, CPRT Support, TU Electric
T. G. Tyler, CPRT Program Director, TV Electric C. Vincent, Issue Coordinator, ERC F. Webster, Engineering Statistics Advisor, CPRT ]
D. R. Woodlan, Licensing Supervisor, TU Electric j l
i
!
i
- -
. !
- Denotes personnel present at the February 10, 1987, exit intervie l
- Denotes personnel present at the March 3, 1987, exit intervie !
- Denotes personnel present at both of the above exit interview . Applicant Actions on Previous Inspection Findings (0 pen) Open. Item (446/8513-0-09): Potential deviations were
~ l identified by ERC concerning:~ (1) weld location,.(2) undersize welds,. 'j (3) welding not per weld symbol, and (4) violation of minimum thread i engagemen These conditions were documented on Deviation Reports !
(DRs) I-S-HVDS-109-DR-1, DR-2, DR-3,'and DR-4 and incorporated into !
Nonconformance Report (NCR) M86-250134 This item will remain open pending disposition of the NC i i
Since these conditions were determined.to be not nonconforming, this !
item is close ! (0 pen) Open Item (445/8514-0-15): Potential deviations were j identified by the ERC inspector concerning a missing color code and 1
"
the allowable distance between color code marks was exceeded. These were identified on DRs I-E-ININ-066 DR 1 and DR 2 and subsequently on NCR I-85-102025SX. This population was reinspected at a later date for additional attributes and the package designation changed from I-E-ININ-066 to I-E-ININ-066R. The reinspection generated one additional DR, DR I-E-ININ-066R-DR-3, which resulted in the issuance of NCR I-86-101916X. This NCR also incorporated the previously identified NCR. This item will remain open pending disposition of ;
the NC I (0 pen) Open Item (445/8514-0-16): A potential deviation was I 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-85-101890S Because of added attributes, this population was reinspected and the NCR superseded by NCR I-86-101915X. This item will remain open pending disposition of
!
the NC (Closed) Open Item (445/8514-0-24): A potential deviation was identified by the ERC inspector concerning a missing nameplate and an actuator spring that could not be located on the damper associated with reinspection package I-M-HVIN-043. A subsequent inspection by another ERC inspector revealed the existence of the required nameplate and also identified from review of vendor I i
-
.-
. .
Drawing 5800-M-027, Revision CP-1, that the damper was a motor actuated fail-safe damper, Model No. SL-100-ML-N, which does not utilize a spring for activation._ The NRC inspector confirmed by examination of the damper and review of the vendor drawing that the results of'the subsequent ERC inspection were correct. This item is ,
I close ' (0 pen) Open Item (445/8514-0-28): A potential deviation was identified by ERC concerning an undersize horizontal brace. This-condition was identified in DR.I-S-HVDS-023-DR-4 and incorporated into NCR M-86-100321SXR1. This item will remain open pending disposition of the NC (0 pen) Open Item (445/8514-0-29): A potential deviation was identified by ERC concerning undersize fillet welds. This condition 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 NC (Closed) Open Item (445/8516-0-12; 446/8513-0-08): The ERC nonconformance evaluation checklists did not provide for the evaluation of the technical adequacy of NCR dis'osition p This ERC QA/QC RTL'and the VII.a.2 issue coordinator has stated that evaluation of the technical adequacy of NCR dispositions is outside l 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 !
dispositions for technical adequacy. The evaluations assessed the NCR dispositions to determine: (1) if the disposition fully addressed .
the nonconformance; (2) if an adequate technical justification was I provided; and (3) whether the disposition block was correctly identified. To provide further assurance, the applicant has decided i to expand its program to assess the technical adequacy of the remaining NCRs with these disposition categories. This activity will be overviewed by TERA as an independent third part NRC inspection of this' process will be reported in a subsequent inspection perio (0 pen) Open Item (445/8516-0-15): Potential deviations were identified by the ERC inspector concerning locknuts missing from clamp bolts and a bolt hole was incorrectly located. This condition was subsequently identified in DRs I-S-0S42-25-DR-1 and DR-2 and incorporated into NCRs M-23216NR1 and M-25338N, respectively. This item will remain open pending disposition of the NCR i. .(Closed) Deviation (445/8516-D-35): The ERC inspector failed to record the presence of existing 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 component ERC
r
- -
.. .
..
.-
Quality Instructions (QIs) QI'019, QI-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 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 recurrenc (0 pen) Open Item (445/8516-0-38): Potential deviations were identified by ERC concerning: (1) weld symbols and locations, (2) undersize welds, and (3) a Hilti Kwik Bolt embed violatio These conditio'sn were documented in DR I-S-HVDS-029-DR-1 and DR-2, and incorporated into NCR M-85-102014X. This item will remain open pending disposition of the NC !
, (0 pen) Open Item (445/8516-0-39): Potential deviations were identified by ERC concerning: (1) incorrect member dimensions, (2) incorrect weld configuration, (3) incorrect weld size, (4) incomplete fusion in welds, and (5) violation of weld undercut 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- This item will remain open pending disposition of the NCR ! (0 pen) Open Item (445/8516-0-40): Potential deviations were identified by ERC concerning: (1) dimension violations, (2) incorrect duct dimension, (3) incorrect orientation, (4) welds were undersize, )
and (5) incorrect weld profile. These conditions were documented in DRs I-S-HVDS-103-DR-1, DR-2, DR-3, DR-4 AND DR- These DRs were then incorporated.into NCR M85-101991 This item will remain open pending disposition of the NC (Closed) Violation (445/8518-V-03; 446/8515-V-02): Item A.1, failure to certify an inspector in accordance with procedural requirement As corrective action for this violation, the applicant committed to ;
revise Procedure CP-QP-2.1, " Training of Inspection Personnel," with !
date of full compliance by May 21, 1986. The procedural revision was to provide for identification of qualification responsibility and u authority of Level III personnel involved in training and s certification activities including those areas where a cross-over of !
. qualification authority existed. The violation was issued due to the l failure to identify this cross-over authority. The NRC inspector i verified that CP-QP-2.1, Revision 21, dated May 8, 1986, and associated memorandum TUQ 3748 dated May 12, 1986, provide for this identification of cross-over authorit This item is close Item A.2, failure to follow procedures when justifying waivers of on-job training (0JT) in the certification of four QC inspector The NRC inspector has reviewed the information provided in the
>
.
}
' l h _'_ V ';y J
- .S p
~
<
, supplementa1 re'sponse-to this violatio This review and ,
. . reinspection of the files for the four QC. inspectors: verified that-
. justification other.than ". .-2 hours OJT and previous related inspection activity.. . ." was. included.' The justification on the waivers included.".:. . demon'stration of practicalJfield ability to
, the satisfaction of a certified Level II." This. demonstration
. provided ". . ." assurance'that the individual does have ' comparable'
or ' equivalent'. competence to that which would have been
. gained . . ..." Therefore, specification.on the waiver of the previous related inspection activity was'not required in these case ,'
Since'the required information was included elsewhere in' the q certification files, a violation did not occur in this example'and q this item.is closed.' U n. ;(Closed) Open Item (445/8603-0-15): This open item: addresse d.
i : inspector certification documentation for fill and backfill placement ERC . issued DR R-S-FILL-GEN-DR-1 regarding inspector certification-for the safe' shutdown impoundment dam construction for the period April 24, 1976, through April'19, 1977. Inspector certification documentation for Freese & Nichols Consulting; j Engineers (F&N)'a'nd Mason & Johnson Associates, Inc. (M-JA) could not 1 be located during the initial ERC documentation review "
TU Electric subsequently requested copies of. certification records 'l from F&N and M-J These documents were obtained and are being transmitted to the Permanent Plant Records Vault (PPRV). The NRC j inspector reviewed these inspector certification documents and found' 1
.that the inspection personnel were qualified to perform the :
inspections and/or. laboratory tests. This item is close i (Closed) Unresolved Item (445/8607-U-17): Incomplete craft installation procedure instruction. NRC ins ector review of- ^
Revision 5 of Construction Procedure EEI-8, p' Class 1E-and non-Class Cable Terminations," had identified the omission of installation 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 commitments related to preinsulated environmental {
sealed (PIES) splices. During-this report period, the NRC" inspector reviewed Revision 6 of EEI-8 dated September 23, 1986, and determined
_
that adequate provisions for all types of splices had been incorporated therein. It should be noted that the adequacy of the ,
splices installed under the old procedure revisions is being addressed in ISAPs I.a.2, " Inspection Reports on Butt Splices;"
I.a.3, " Butt Splice Qualification," for PIES splices; and I.a.1, ,
" Heat Shrinkable Insulation," for uninsulated splice (Closed) Unresolved Item (445/8607-U-18): Incomplete inspection '
procedure instructions. In addition to revising EEI-8, the CPRT also committed to having certain inspection requirements for PIES splices installed in control boards incorporated in the QC inspection !
procedure, QI-QP-11.3-28, " Class 1E Cable Terminations." The NRC
'
L: l
r:
]
1
. .
8 j
l
)
inspector review of Revision 28 of this procedure had indicated that
>
other. types of splices and PIES splices installed in locations other I than control panels were not subjected to the same requirements as the PIES splices in control panels. Further NRC inspector review of j the applicable facility commitments and of Revision 31 to !
QI-QP-11.3-28 found that all of the applicable provisions not J previously included had been incorporated into the' procedure. It should be'noted that the adequacy of the splices instal. led under the { ;
old procedure revisions is being' addressed in ISAPs I.a.2, i
" Inspection Reports on Butt Splices;" I.a.3, " Butt Splice Qualification," for PIES splices; and I.a.1, " Heat Shrinkable l
.j Insulation," for uninsulated splice j
q. (Closed) Violation (445/8615-V-06): Failure of the Unit 1 PFG to f provide specific instructions for the control of design documents issued for extended time period .i The NRC inspector verified tha!. Procedures CP-CPM-7.4 and CP-CPM-7.4A i were revised July 25, 1986, to provide instructions for the control of design documents issued for extended time periods. As stated in the response, these two procedures were superseded by issuance'of Procedures CP-CPM-7.1 and CP-CPM-7.1A on December 15, 1986, when the Unit.1 and 2 PFGs were combined. 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 both Units 1 and 2. These procedural i revisions provide the required controls. This item is close r. (Closed) Violation (445/8615-V-07; 446/8612-V-07): Failure to I control the activity by which the onsite fabrication shop provides
.
inspection traceability of identical shop fabricated item j s
NRC review of Procedures CP-CPM-7.3A, " Material Storage / Identification for Structural Steel Fabrication,"' Revision 0, DCN #2, dated August 12, 1986, and QI-QP-11.14-1, Revision 24, dated July 28, 1986, 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 deviations were noted during the previous inspection, the above revisions to the )
applicable procedures close this ite '
s. (0 pen) Open Item (445/8615-0-11): During inspection of Verification Package I-M-MEIN-035, the NRC inspector identified that an equipment ,
'
foundation anchor bolt nut was not bearing load and that a 1/4" gap existed between the anchor nut and the load bearing mating surfac Subsequent NRC review of ERC overview inspection documentation revealed that an ERC overview inspector had already identified the deviating condition and that DR I-M-MEIN-035-DR2 had been issued and I validated, resulting in the issuance of NCR M-23094 NR-2. This item remains open pending disposition of the NC ___-
r ,
, _
- .
,
' ~
3.' :CPRT-ISAPs (excluding'ISAP VII.c)
.. Heat-Shrinkabl~e Cable Insulation Sleeves (ISAP I.a.1)
I* ,
During this: inspection _ period,.the activity. identified by NRC Reference.01.a.01.07 was. inspected as-follows:
.
.
!: Establish' Sampling Plan / Select Sample (NRC Reference'01.a.01.07)-
.The NRC inspector reviewed the CPRT: files and determined that a sample of 128. heat'shrinkab'le. insulation. sleeves was. selected by the CPRT for inspection from 'a total of 1359 locations listed in the action plan. A detailed dis'cussion;of the sample selection process for this ~ISAP .is contained in paragraph 5.b(1) belo ,
Since the:. sample selection process was determined to adequately fulfill the CPRT commitments, this activity and NRC inspection is complet '
No violations'or deviations were identifie QC Inspector Qualifications (ISAP I.d.1)
.During ~ this inspection period, the NRC inspector inspected the processing of DRs and the. verification of inspector qualifications performed during ISAP I.d.1 by ERC personnel for inspectors whose '
. certifications were not found acceptable during ISAP VII.c revie This inspection was accomplished by first reviewing.the controlling Procedures.CPP-025, '.'QC Inspector Qualification Evaluation," and CPP-010, " Preparation of Deviation Reports," and then performing a detailed review of DRs related to inspector certification that were generated during'the VII.c review process. The DR processing was reviewed.by.the NRC inspector for'the following attributes:
-(1) Inspector certification related DRs were forwarded to the ISAP I.d.1 issue coordinator in accordance with CPP-1 (2) The validity of DRs was properly evaluated by the ISAP I~. issue coordinato (3) The transmittal of DRs was in accordance with CPP-10.
<
(4) The determinations of inspector qualification for the uncertified QC inspectors was proper and the determinations were documented on the Inspector Certification Evaluation Summary (ICES) for (5) The determinations to reinspect any previous work of unqualified inspectors were proper and documented on a memorandum addressed to the ISAP VII.c file as required by procedur l
.. .
(6) Reinspections of any previous work performed by the unqualified !
QC inspectors were accomplished in accordance with QI-005,
" Evaluation of Inspector Performance."
(7) ~ Validated DRs were transmitted to TU Electric for documentation on an NCR/D ~
The above procedures were determined by the NRC' inspector to provide the necessary controls for evaluation and processing of the DRs. The procedures specified the personnel responsible for performing the DR evaluations and the actions required for documenting the evaluations. The procedures also provided guidance for the DR evaluations by reference.to ISAP I.d.1, "QC Inspector Qualifications," and QI-005, " Evaluation of Inspector Performance,"
which detail the methods to conduct evaluation of QC inspector certification and qualificatio The process by which ERC performs an analysis of file documentation ,
to evaluate the qualifications of QC inspectors is being inspected by !
the'NRC under its review of ISAP I.d.1. That process is identical to the process utilized for evaluation of inspectors identified by ISAP VII.c, with the exception that proper QC inspector certification i is determined by the ERC VII.c inspectors in accordance with VI !
inspection / documentation review required in 28 of the 75 QIs used for reinspection ,
During sample inspection of the document review packages, the NRC has l been verifying whether a certification exists for the inspector of i record, where require l To evaluate the system by which inspector certification / qualification l is evaluated, the NRC selected a sample of 32 DRs concerning-inspector certifications that were identified during the VI document review All 32 DRs were found to have been transmitted, processed for validation, and maintained as specified by CPP-10 and l CPP-025. The NRC inspector verified that the results of the I. !
issue coordinator's review of the certifications in question were J documented on inspector certification summary forms and that !
justification for the results was provide l
!
The NRC inspector found that of the 32 DRs selected, 28 were I determined by the issue coordinator to be valid and 4 were determined )
to be invalid. NRC review of the packages for the four invalid DRs j found that the certifications had existed for the certifications !
questioned by the VII.c DRs and that documentation existed to support the certification NRC review of the packages for the 28 valid DRs found that 2 inspectors were determined by the I.d.1 issue coordinator to be unqualified for the inspections performed. Therefore, a I. q Phase III reinspection was specified as corrective action. The !
26 remaining inspectors were determined by the I.d.1 1ssue
i
!
, ,
i' 1 11 I l
coordinator to have been qualified for the inspections performe ;
The basis for the disposition of the 28 valid DRs is shown in the i following' table: ;
q Inspector qualified under equivalent Brown & Root (B&R) 1
'
certificatio H Inspector qualified under Level II and all daughter certification Inspector qualified under contractor certification other {
than B&R (e.g., R. W. Hunt). 4 1 Inspector qualified as determined by Special Evaluation i Team /RTL revie Inspector qualified but administrative / clerical errors i require D Inspector qualified under previous similar certificatio Total determined qualifie .!
Total determined not qualified and sent to Phase III for Reinspectio The NRC inspector verified during review of the validated VII.c DRs that the I.d.1 determinations of qualifications were supported by documented 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 i be qualified, that previous training and inspection activity was sufficient and applicable for the certification in questio l The NRC inspector verified that the 28 valid DRs were transmitte'd to l TU Electric and NCRs were prepare 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 l 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 reinspections which were satisfactorily performed by ERC inspectors in accordance with these matrice No violations or deviations were identified. The evaluation of DRs pertaining to inspector qualifications generated by ISAP VII.c or other.ISAPs will continue to be inspected by the NR c. Inspection for Certain Types of Skewed Welds in NF Supports I (ISAP V.a)
Status of NRC Inspection Activity The NRC inspector verified compliance with the following ISAP activity commitments:
~ ,
u
'd e-
'I Chronology of Inspection Methods (NRC Reference 05.a.01.00) i The methods for QC inspection of type-2 skewed welds and the written procedures describing the methods and means of documenting the l inspections have changed during the construction of the CPSES project. The technical focus of ISAP V.a is the inspection of the geometric and dimensional characteristics of skewed welds at
' locations where simple fillet gauge measurement was not possibl In order to determine what inspection instructions were applicable for specific time frames, a chronology of inspection methods i documented in QC procedures was developed by the third party to .
correlate the period of time and specific procedure revisions for !
inspection of type-2 skewed weld 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 inspection of ASME pipe and attachments welded to the pip QI-QAP-11.1-28: which addressed the fabrication, installation and inspection of ASME pipe supports except for attachments welded to the pip '
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 type-2 skewed welds using the scribe line technique was incorporated into the procedure at that tim ,
QI-QAP-11.1-28: Revision 16 dated December 15, 1982 - The type-2 skewed weld inspection methodology was deleted from the pipe support procedure, CP-QAP-11.1-26: Revision 9 dated December 16, 1982 - The type-2 skewed weld inspection methodology was incorporated into the piping procedur 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 skewed welds on pipe support ;im <
\
4, A
- y
,,
V'( .
- (
6'., 4
,
g
-,
pm <
a
.q
'
m' h j
'
CP-QAP-12.li Revision' 4 dated February 2.c1983,- and Revision' 5 dated March 18,-1983.- These'. revisions'were issued to. initiate reinspection
-
'>
g ~o fLall' accessible structural' welds on ASME. pipe supports.
%e '
. QI-QAP-11.'l-26: Rev'idion13datedAugust4,1983-!Theprofile
. technique for measuring' size of type-2' skewed welds was added to the-. 1
'c'
piping. procedure.' ',
.
' QI-QAP-11.1-28:' Revision;29 dated January 25, 1985.- The scribe line" L technique for measurement of type-2 skewed fillet welds was reincorporated into the support procedur l
- QI-QAP-11.'l-28:JRevision 30 dated April 15, 1985 - The profile j technique for measurement of-type-2 skewed welds was incorporated- '
into the support procedur _
.,
'
-Six different methods'of documenting'the results-of' type-2~ skewed weld inspections were permitted by procedure' at various times. These'. '
methods were: i (1) HIR Hanger Inspection Report -
(2) CSC Component Support. Checklist
.
(3) MWDC- Multiple' Weld Data Card l
.(4) WICL Weld Inspection Checklist f (5)' CSF/SWIR ' Component Support Fillet and Skewed Weld-
Inspection Report
(6) COT Construction ~ Operation. Traveler The NRC inspector reviewed historical revisions of the ASME, Quality
' Assurance Procedures / Instructions Table'of Contents to verify the accuracy of the developed chronology and also checked the methods permitted by these procedures for documenting type-2 skewed weld 'l NRC inspection of this activity is complete. NRC inspection of activities listed above also provide a basis for completion of activities required by NRC Reference 05.a.01.01 and 05.a.01.0 No violations or deviations were identifie Document Control (ISAP VII.a.3)
,.
'
Du' ring t' his report period, the activities identified by NRC Reference 07.a.03.04 and the closeout of related external issues were inspected as follows:
.
, w dq
'
I
, .-
>
i ' ,
L '
.
, >
'
.'
ProcedureEvaluation-(NRCReference07.a'03.04) f This ISAP required an evaluation of'the current CPSES document ]
- control; procedures. The-issue coordinator' performed the evaluation,. j l conducted and documented the results'of the interviews, and completed !
a procedure checklist, which in total formed.the basis for the .
~
evaluatio ,
.The; NRC' reviewed the procedure checklist and compared it to th ..
requirements in Criterion VI of. Appendix B.to'10 CFR Part'50, and t 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 this
'
.
checklist, the NRC inspected the current controlling Procedure DCP-3, ^
Revision 19, "CPSES Document Control Program," to verify.that ERC had implemented the checklist properly and that the procedure met th 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 approve ~by. authorized personnel prior to distribution; and measures'to assure .
that all documents used for construction or. inspection, activities
~
H were maintained current and in a' controlled status; Additionally,. ,j the procedure provided for: retrieval'or identification of supersede documents and for'an ' ongoing monitoring of' document control-performance of all controlled doc'ument. files.by an independen monitoring team. 'No differences between'the.NRC and ERC~results were noted in the completed checklist 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 document .
. were fourid to beLat their current ' revision with all design changes - i entered when compared to the DCC master list of controlled document ^
Thelimplementation'of tho independent monitoring team was inspected- l by the NRC inspector by interviewing the head of the monitoring team,. ;
. reviewing' monitoring'reportsLand executive summary reports, and -i reviewing the report distribution which included the Vice-President,.
Engineering and Construction. Th'e monitoring team's reports !
'
indicated that-the' document control groups were achieving an error-rate of less than 0.1%.
The NRC interviewed the ERC engineers responsible for 11-of the- :I
'
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 rat Based on"the' foregoing NRC inspections and the favorable comparison ,
with the results of the ERC inspections, this item has been properly l t , i
<l
_
,
i
, , ,
i
'
implemented. No violations or deviations were noted during the inspection of this area of the document control progra j l
Closeout of Related External Issues Two external issues related to document control were identified in l ISAP VII.a.3. The issue of unauthorized procedures used for i 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 addresse !
'
The NRC interviewed the current B&R document review supervisor who stated that the document review group does not cuerontly use a
" Controlled Copy" 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 use This individual indicated.that the stamp was used on copies of small bore typicals before presentation to the ANI for review. .1he practice was stopped and the stamp defaced after issuance of $pecial Inspection Services (SIS) Report 355, which documented the ANI's concern about the use of the stamp. Evidence of the stamp dafacing was p'rcvided 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 improper use of the " Controlled Copy" stamp had been previously determined by the NRC Technical Review Team (TRT) in c SSER 11 to have had no adverse safety implications. No further NRC inspection cf this item is planne . Construction / Reinspection (ISAP VII.c) i Establishing Populations Section 4.3.1 of ISAP VII.c, Revision 1, required safety-related hardware to be categorind into populations with homogenous work activities (HWAs)' and associated quality characteristics (attributes) i from which the required-random samples were selecte It also required that a description and justification for homogeneity be prepared for each population. Finally, each population was to have a
.
list of all final QC accepted safety-related itens. The CPRT 1 guidelines for establishing homogenous populations were contained in the project procedure for ISAP VII.c, Procedure CPP-005, Revision This procedure required the discipline engineers to review equipment lists from CPSES in order to subdivide the plant into homogeneous populations that have been constructed using reasonable bemogeneous work processes. The equipment reviewed, as specified in !
paragraph 3.0 of ISAP VII.c, was limited to that which was safety related, construction complete and final QC accepted. The equipment {
i
'f
w yg , x ,
k[p wQAK W-.
,I 4 l
l
,tc . g
$ i
'
16 i
!
!
1 '
i
.would be inspected for attributes selected after a complete ' review of l engineering documents pertaining to the individual population I W
The generation of a Population Description, Master Population list, 1 Population Items List, and a Work Process Memorandum are also
. procedurally required along with adequate control of subsequent j revisions to each of these document The NRC inspectors reviewed six ISAP VII.c populations '(i.e. , Large Bore Supports. Rigid, Large Bore Supports Nonrigid, Small Bore Pipe !
Supports, Pipe Welds / Material, Concrete Placement, and Electrical !
Cable) to ensure that the homogenous populations were correct and i
'.
adequate and that ERC procedures, primarily CPP-005, were being l adhered t .
(1) Large Bore Supports Rigid (LBSR), Large Bore Supports Nonrigid -
(LBSN), and Small Bore Pipe Supports (SBPS)
The NRC inspector's review of these three populations was performed concurrently because the population descriptions are similar except for the population boundaries (large bore rigid, large bore nonrigid, or small bore) and the Population Items Lists were all derived from the same source document;.the Hanger Installation Tracking System (HITS) lis (a) Population Descriptions i
? !
'
/- NRC inspection verified that the systems listed by the CPRT
,U-for inclusion in these three populations were designated in Section 17A of the FSAR as safety related, either Safety
{, Class 1, 2, or 3, and Seismic Category I. Cross checking
,
from FSAR Table 17A to the three populations, however, by
~~
the NRC inspector identified that the Chilled Water System (CWS) was omitted from the CPRT population Subsequent review of the Population Items Lists did reveal that the C CWS was included in the population; it was only
,
inadvertently left off the Population Description lists of
'
systems. The NRC inspector agreed that the listed I population boundaries described all supports within the !
definition of each population and that the Population Descriptions adequately described those items which are not L
included within the scope of the populations. For example, ,
the Population Description for Small Bore Pipe Supports, l
,, Revision 1, dated July' 23, 1985, states that the population L
~
boundaries shall be small bore (2" NPS and smaller) pipe supports located in Units 1 and 2 and common areas which are seismic category I and of Safety Class 1, 2, or The scope of each population item shall include the support cc nponents shown on the individual drawing Exclusions frw this population will be building structural members, small bore piping, large bore pipe supports, and instrument ,
!
)
(- - =
'
Q , d
- , .
,
s t
( ,'-
' '
t, 17 N'
.,
'
8 .
) '
,
c >
!
$ ) , t
' i
'
piping and tubing supports. All CPRT sign-ohfs for revbiw' 3
.g cod approval as wall as' control and filing in CPRT records "
v} of the population' descriptions wersperformed per ,
' s p rocedur i h'
,
'
{
t t s 4 s t ,d ,
s(b) Master Population List ' ,L4 i '
.
I
.
'
,
^
NRC inspector r,etfew of the original Master Population List 1
%'
'
p and all. su'eseedint . revisions (one throtsh five) verified (L '
4' -that the ebovd thre4 populations were included on the list
' <
and that t'eview;Jarproval, and contpol of the documents are 4 e per procedurej i '
, -
! .
. t (c) Population Items Lirt
\- k Each of th'e three Population Items Lists were derived from the HITS list. Th6 CPRT initially established the validi,ty n and, accuracy of the HITS. list and then segregated out ths t ,
' 6, three homogenous' pipe support populations (LBSR, LBSN, and s j
SDPS). To establish validity anA accuracy of the HITS list, the CPRT randomly selected M B&R Hanger Location
,
(BRHL) drawings out of the listed total of 2013 and <
m
'
manually checked to see that all supports listed on the .
', 'N 4 .,
3 J60 BRHLs were also listed on the HITS list. To verify th9 j
/ -
. 'J" 7 accuracy of the support status listed on the' HITS list, '
? <
>
(. s . s60 supports were randomly selected from the 60 BRHLs and 3 t
,' their status individually verified by checking records in'
'
}
v the various vaults and processing areas. This was require 0 because only final QC accepted pipe supports were to be reinspected under the VII.c program. No discrepant s
,
,
conditions were detected by the CPR ,
, <$
To assess validity and accuracy of the CPRT. verification of
!, . the HITS list, the hRC . inspector selected 10 out of the
,
f. { l Ii
,
60 BRHLs that the CPRT had reviewed, and verified that all
,
,' '
supports shown on the BRHLs.were included on the HITS lis .;
To further assess the HITS list, ten additional BRHLs not !
'
selected by the CPRT wera seiected by the NRC inspector and ,
4 1 ,
'
checked against the liITS list.foi sepport inclusio These
'
' { \, 10 BRHLs were selected such that a cecss section of l 7 safety-related systems within the population were included in the review. Finally, the NRC inspector reviewed the
'
,
!
n ,
,
completion status'of 10 of the 60 supports that the CPRT s '
'
'
had verified by researching records in the various vault
[,{l 3 < Jocations. No discrepancies were identifie ,g r \ > ,
- (d) Work Process Memoranda
"
< Pevision 3 to Procedure CPP-005 dated May 28, 1986,
,
,
required all ISAP VII.c populations to have a Work Process
,
Memorandu This memorandum was to identify safety-related
.
,
..
.
]
. .
construction work processes and attributes that can be reinspected and/or verified by document revie l During this report period, the Work Process Memoranda covered under this inspection were in the final draft stages; therefore, they will be reviewed at a later dat This is an open item pending completion of NRC review of ,
these Work Process Memoranda (445/8702-0-01; l 446/8702-0-01). ,
I (e) Revisions l NRC review of all revisions to the Master Population List, Population Descriptions, and the P7."slation Items List for-the three populations revealed that the criteria of Section 5.5 of Procedure CPP-005 were being adhered to as far as sign-offs for review and approval, and control and
'
vaulting of the subsequent revision No violations or deviations were identifie (2) Pipe Welds / Material (PIWM)
This population was created by combining the two populations i which were previously titled Large Bore Pipe Welds / Material ;
(LBWM) and Small Bore Pipe Welds / Material (SBWM). In addition to this combination, mechanical equipment, site-made, pressure boundary welds were added to the PIWM population, and tubing welds were organized into a separate populaticn (TUWM). At the present time there is no documentation on file relative to the basis-for these actions. This is an open item pending development of such documentation and NRC review (445/8702-0-02; 446/8702-0-02).
(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, however, it was observed by the NRC inspector that the Boron Thermal Regeneration System, Combustible Gas Control System, Post Accident Sample System, and the Plant Gas System were not 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 Descriptio l l
,
o e i
The NRC~ inspector concurs with the population boundaries and items not included in the population, as listed in the Population Descriptio ,
(b) Master Population List NRC review of the original Master- Population List and all subsequent revisions (one through five) verified that the PIWM population was included on the list and that review, approval, and control of the documents were per procedur ;
(c) Population Items List l
The source document for the Population Items List was the B&R Comanche Peak Craig Computer Tracking System (CCTS)
Report WEC-C-WE-REPORT issued June 12, 1985. This report ,
was a computer sort of all safety-related and QC accepted i large and small bore pipe welds and instrument tubing welds contained in the B&R computerized data base Welding Engineering Component Master Report used for tracking construction progress of site-made weld Attachment 6.3 of ERC Procedure CPP-005, Revision 3, states, in part, "The Responsible QA/QC Discipline Engineer . . . [p]rovides the basis for accepting the list !
as valid." In addition, "The QA/QC Lead Discipline Engineer and the QA/QC Engineering Supervisor review Population Items List? to ensure that they are complete, accurate, and consistent with the requirements of this procedure." ERC stated on the Population Items List that the following four steps were taken to validate the list:
1) A verification was made that the 591 site-made welds listed on the ASME III N-5 Data Report Index for the Unit 1 Auxiliary Feed Water system were on the
! Population Items Lis L 2) A review was performed of field welds specified on all 26 Unit 1,BRP drawings for the Residual Heat Removal j system and 26 randomly selected Unit 2 BRP drawings l with respect to their inclusion in the l WEC-C-WE-REPOR All welds were found to be included.
I
!
3) A review of 675 WDCs from several Unit 2 systems for instrument piping welds was performed with respect to i their inclusion in the WEC-C-WE-REPORT. All welds were found to be include !
4) A review was performed of the construction completion (C/I) status of welds listed in the Welding Engineering Component Master Repor From this
a
.Y
, ,
I ef' ? 9-
.
t review, it was ascertained that most of the diesel
, ,
' generator (Unit 1 and Unit-2) piping site-made welds '
had not been assigned a complete / incomplete status runder the C/I column. . Accordingly, these welds.were not . identified in WEC-C-WE-REPORT computer sort of ~
. complete,-QC accepted piping welds. These' welds were
. added to the WEC-C-WE-REPORTLto complete the'
Population' Items List.- 1 a
The NRC inspector. initially. compared the systems listed in
.
'
FSAR Table.17-A to the source document to assure H . consistency. Next, the NRC inspector randomly selected-
,23 BRP drawings'for' Unit 1 and Unit 2'not previously:
selected by the CPRT and verified that the 416 site-mad welds were included on the Population Items List. No omissions'were note To further. verify accuracy of'the CPRT approach, 10 of the 52 BRP drawings reitiewed by the CPRT were compared to the source' document. .No discrepancies were foun (d) : Work-Process Memorandum See paragraph 4.a(1)(d) abov .
(e) ' Revisions NRC review of all revisions to the' Master Population List, Population Descriptions, and the Population Items List for the population revealed that the criteria of Section 5.5 of Procedure CPP-005 were being' adhered to as far as sign-offs for review and approval and. control'and filing in CPRT records.of the subsequent revision j No. violations or deviations were identifie s
'
(3) Concrete Placement (CONC)
The concrete placement. population contained 7617 concrete pours identified on a computer' printout generated by B&R from concrete pour card (a) -Population Descriptions The'NRC. inspector. reviewed ERC document QA/QC-RT-328, I Revision 0, " Population Description for Concrete Placement." The population boundary included. al Category'1 concrete construction that had been completed and approved as of August 1, 1985. The Category 1 l structures were listed in Attachment A of the Population d
-
Description. The NRC inspector verified that Attachment A i
'
o
..i .
J agrees with the FSAR, Section 3.2.1.1.1, which also lists )
Category 1 structures. A subsequent review of the j Population Items List (see below) verified that the list 1 contained concrete pours from each of 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 in CPRT records of the Population Description were performed per Procedure CPP-00 (b) Master Population List NRC review of the Master Population List, Revision 5, verified that the concrete placement population was included on the list. Review, approval, and control of the Master Population List was per Procedure CPP-00 (c) Population Items List i The NRC inspector reviewed ERC document QA/QC-RT-1628, Revision 1, " Population Items List Concrete Placement."
The population source was a 254 page computer printout generated from individual concrete pour cards by B&R. This list included the concrete pour number, date poured and a brief description of the area poured for each of the 7617 concrete pours in the populatio According to this document, the population list " . . . includes all safety-related concrete pours in Unit 1, 2 and areas common to both units."
Attachment 6.3 of ERC Proceduro CPP-005, Revision 3, states, in part, "The Responsible QA/QC Discipline Engineer . . . [p]rovides the basis for accepting the list as valid." In addition, "The QA/QC Lead Discipline Engineer and the QA/QC 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 Population Items List that the following three steps were taken to validate the list:
1) Twenty arbitrarily chosen pour numbers identified on B&R drawings were found to be on the population lis ) An arbitrary selection of concrete pours from Inspection Report Logs were reviewed against the
! population list and no discrepancies were identifie ) A review of the population list confirmed that no time gaps were apparent in the pour date ;e ,
>
'
"
.22
.The NRC' inspector reviewed the steps taken by ERC to-validate the population list fo'r ' concrete placement.' Only step.1 above was documented. A handwritten, unsign'ed 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. The 20 concrete pours selected by ERC for verification of the completeness of the population list represent only 0.26. percent of the total population of'7617. The extent of'the ERC review is. inadequate to ensure accuracy and'
.
' completeness of the Population Items' List. .The NRC inspector. verified that the 20 concrete pours' selected by-ERC were on the population' lis In' addition,.the NRC inspector prepared a randomly se.lected
, list of 134 concrete pours from 17 B&R drawings'and compared this list with the Population Items List t determine if the 134 concrete pours were included. The following discrepancies were discovered:
'1) Pour Nos. 205-9810-039 through 205-9810-056 are shown as block-out type pours in the east diesel generator
' foundation, Unit 2,.on Drawing SSB-20655, Sheet.1, 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 TV Electric records cente Pour Nos. 205-9810-039 and .205-9810-041 through-205-9810-047 were assigned on drawings at least twice and are shown, for example, on Drawings SSB-20605, Sheet 1, Revision 7, and'SSB-20618, Sheet 1, Revision 2, to be concrete curbs, removable slabs, etc. ; not block-out 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 installe ) Pour No. 205-4822-003 is shown as a shielding wall fo the Primary Sampling room on Drawings SSB-20605, Sheet 4A, Revision 0, and SSB-20605, Sheet 4, Revision 0. This pour number was not on the j Population Items List. A pour card for this pour was located in the TV Electric Records Center. The NRC inspector verified by_ field inspection that the shielding wall had been installe ,
q
- v+ ^
./' i
, ..]
23 U
, ,
u
'
The above discrepancies ' indicate that the Population It' mse List .is not entirely complete and accurate and does not- <
include ". . .~all safety-related concrete pours in LN t 1, 2.and areas common to both units," as stated. .The ;
ERC review of the- Population -Items List to ensure accuracy ' i This:is a deviation'
'
and completeness was inadequat ;
(445/8702-D-03;-446/8702-D-03). i (d) Work Process Memorandum'
i-See paragraph 4.a(1)(d)'abov l (e)' Revision's NRC review of all revisions to the Master Population' List, Population Descriptions, and-the. Population Items' List for i the population revealed that the criteria.of Section 5.5 of Procedure CPP-005 were being adhered to as'far as sign-offs for review and approval, and control and filing in CPRT q Records of the subsequent revision No violations or deviations other than as'discu sed in (c):
above were identifie (4) ' Electrical Populations
.The NRC inspector reviewed the Population Items List documentation for each of the electrical. populations to determine which sources were used to develop the population and the basis for the CPRT determination that the developed population.was accurat 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 TU 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 ,
cables and raceways. Cable and raceway' changes authorized by I design' change authorizations (DCAs) were entered into EMS on a daily basis. . The EMS then provided a printout of these daily changes on a Daily Activities Report. Since EMS was neither a required permanent plant
'
.the previous EMS revisio document s and nor controlled Daily Activity by procedures, Reports had not been retained as permanent plant records; however, the NRC inspector observed that' copies of the EMS printouts which had l been used by ERC for population list development, were retained l in the QA/QC Review Team files in the CPRT document control '
cente : I
,
_
,
h t
r :, Dc ,
p ,
,
+,
The electrical cable.(CABL) population was. selected for a more p' - detailed NRCfinspection to evaluate the implementation of the-appropriate procedures for establishing and accepting the
'
_ populatio (a)l Population Descriptio , The NRC inspector's review of the Population Description
.
for cables identified that the population was to includ '
-all Class 1E', safety-related power, control and instrument l 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 conductor seal assemblies, NIS cable connectors, and unscheduled lighting (except.for sep'aration barrier material inspections). These three groups were. excluded-from the cable population-because they were included in <
,
other populations. Based'on his understanding of the >
systems involved, the NRC inspector concurred that the population boundary and the items not included within.'the scope of the population represented a valid. population of involved electrical cable. The CPRT! review and approval as H" well as the filing of the Population Description was performed per Procedure CPP-00
(b) Master Population List
'
NRC' review of the Master Population' List, Revision 5, verified that the electrical cable population was included on'the list.. Review, approval, and control of the Master-Population List was per Procedure CPP-00 '
(c) Population: Items Lis Procedure CPP-005 required the responsible QA/QC Discipline'
Engineer to prepare a list of all applicable items ~within the population out1.ined in the Population Description along with the. method of development. This' list was then to be) ,
reviewed and approved by the QA/QC Engineering Supervisor- '
who would forward it to the QA/QC RecordsfAdministrato The NRC inspector verified that a comparison of the items l documented in the Cable Population Items List to the items required by CPP-005 was performed by the QA/QC Discipline r Enginee The list was divided into three parts:
. Population List Source; Basis for Accepting the List; and J Basis for Accepting any Additional Items. The NRC inspector determined that this met the requirements o CPP-00 I
..t v:W .
'25 -
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 !
E the EMS cable report (ELE SAFETY RPT) dated June 17, 1985,
'
and'the Gibbs & Hill (G&H). Lighting Panel. Schedule, ~ .
-
Drawings 2323-El-0942-01'through -05-and.E2-0942-01 through-03. NRC inspector review'of these documents disclosed'
~
that Drawing 2323-E2-0942-03 did not exis The NR inspector then reviewed the file applicable to the Basis for Accepting the List and questioned how the EMS was-validated by the CPRT as'a'completeLsource of applicable-electrical. cables. The NRC inspector'wasLinformed that.the
.QA/QC Discipline Engineer responsible for the cable '
population had selected 30~ cables each from the racewa schedules for Unit 1 and Unit 2 (2323-El-1700-
'o and 2323-E2-1700) and.then. compared these' cables to the EMS-listing he had used in order to verify the validity of the source documents.: The NRC inspector also' verified, by a 1 review of the CPRT files, that the'QA/QC Engineering. . .
Supervisor had approved and forwarded the list as required... '
-The NRC inspector determined, based on the above, that the requirements of CPP-005 had been fulfilled in establishing this populatio In an effort to separately evaluate the acceptability o the cable population (which contained over 14,000 cables)
the NRC inspector chose an arbitrary sample of affected:
cables. Between 1 and 6 cables from each safety-related plant system from the Unit 1 and the Unit 2 raceway schedules in the plant permanent records vault and 14 cables from the unscheduled lighting panel drawings were selected. This resulted in a sample which containe cables from 55 systems in Unit 1 and 122 cables from 51 systems in Unit 2. These cables were then" compared to the CPRT's cable population list to provide assurance that the population-list used by ERC'was complete. The comparison of these -lists produced the following findings:
1) The list of Essential and Emergency Lighting cables was not in the, file,
,
2)- Pages 813 and 814 of the EMS listing were missing'from the file, 3) Cable E0000425 was not' included in the file list, and p
4) Cable E0135036.was shown as EG135036 in the file lis 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 l
a + ,
h?
- T# ,
26 I
'
.
'I
~
'pages were available from working copies; DCAs 18,100 and 18,547 authorized a designation change for cable !
E0000425:to A0000425; 'and the improper separation train p
'
' designation _(G vs. 0) for cable E0135036 was a. data entry error.', Since;the NRC's inspection showed that the cable population.lis.t developed by the CPRT'from.the EMS. appeared to be more. complete than the Cable and Raceway Schedule J from the permanent plant record vault, the NRC inspector )
found that the population list was' acceptable. . However,- 1
"
the condition of the record files not being' complete as-evidenced by 1) and 2) above is a deviation from ERC ,
Procedure CPP-004, " Project Working Files," Revision 2,- !
dated D.ecember:17,1985 (445/8702-D-04; 446/8702-D-04). -
(d). Work Process Memorandum See paragraph 4.a(1)(d) abov (e) ' Revisions j
,
NRC review of all revisions to the Master Population List, .;
Population Descriptions,.and the Population Items List for-
-
-
H the population revealed that the' criteria of Section 5.5 of 1 Procedure.CPP-005 were being adhered to as far as sign-offs for review and approval, and control and filing in CPRT records of the subsequent revision No violations or deviations other than as discussed in (c),
above, were identified, Reinspection of HVAC Equipment Installation (HVIN)
Status of CPRT Activity A total of 181 HVAC equipment packages were randomly selected and inspected from a population of 604 packages representing Units 1, i 2 and commo A total of 331 DRs were written with 187 determined to 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 populatio The NRC 1 inspector identified that approximately 30 percent of the_ random and W engineered samples consisted of fire dampers that were statused as j
" Abandoned In Place"; i.e., nonsafety related. This raised a j question with respect to the inclusion of nonsafety-related equipment ]
in the HVIN population. This was discussed with the population engineer who provided the following information. Due to problems that were identified with fire dampers which limited their ability to
!
!
l . . . . .
. . - .. - . .. --- . --- - . i
I
, o ..
i
,
<
i l
function correctly, a study.was performed (GTN-60298 dated July,27, l 1984) that concluded certain fire dampers could be " Abandoned In l Place" and would not be required for a safe shutdown. These dampers j were included in the HVIN population as an accessory connection only 1 and were inspected for proper mounting and bolting, but not l operability, to assure that these dampers would not interfere with d operation of the HVAC system at some later date. ERC issued letter QA/QC-RT-5584 dated February 2, 1987, to the population file, j providing this'information. The NRC inspector verified the validity l of the information through review of the study and supporting
^
documentation and found this to be consistent with ISAP VI regarding Populations Items List developmen The NRC inspector has previously witnessed four inspections and performed five inspections with no further inspection activity planned for this populatio i No violations or deviations were identifie . ISAP Sample Selection Process The purpose of this NRC 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 Progra Plan, Appendix D, Revisions 0 and 1, "CPRT Sampling Policy Applications and Guidelines." Appendix 0 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 Action Plans (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 inocerational and testing ISAP sample selection was reviewed in a previor "^9pect!.m with results documented in NRC Region IV !
Inspection Report 50-445/85-18; 50-446/8S-15. Another activity previously inspected by the NRC for 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; 50-446/86-2 &
'
The NRC approach used to review ISAP documentation and the inspection of samples selected was: (1) to review the requirements identified in Appendix 0 and the applicable procedures, and (2) to verify implementation of the sample selection process by comparing the samples selected to the controlling commitments. Samples were then reviewed to assure that:
random number selection and item number calculations were correct; items identified for inspection had a valid sample number and a random number l assignment; errors in the selection of items for inspection had been ;
resolved; departures from the sampling process had been identified; '
populations were clearly defined and segregated; minimum sample size criteria were correct and documented and enlargement of sample size was made, as necessary, to assure that the minimum sample size would be achieved for all attributes; expansion of sample size, based on identified i J
..
,
hardware deficiencies,-conformed to requirements; and the sample selection process was suitably documented to provide an auditable trai I Of the 19 external source issue ISAPs considered for inspection, 5 completed and 1 in process ISAP were inspected. From ISAP VII.c, 5 of 31 in process populations were inspected. The following are the results of this NRC inspectio j
! QA/QC ISAPs (1) ISAP VII.a.2: Nonconformance and Corrective Action (inprocess).
This ISAP contained six populations, each requiring a separate sample selection that would provide a.95/5 screen. (The 95/5 screen or sampling plan provides a 95% confidence that not more than a 5% deficiency rate exists in the sampled population.) Of the six populations, the sample selection for NCRs covering the years 1975 to 1977 was reviewed by the NRC i inspector. Twenty-one of the sixty-three selected samples were i examined. No errors were noted in random number calculations or sample item identification from the. population item lis It was determined, based on the NRC inspection, that the NCR sample [
selection conforrned to Appendix D requirement (2) ISAP VII.b.2: Valve Disassembly (complete).
During the NRC's inspection of VII.b.2', no errors in the 95/5 sampling plan were found. The NRC inspector reviewed 21 of the 111 sample selections and found them to conform to Appendix D, 3 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 on March 19, 1986, ERC's QA/QC surveillance group and the Results Report Review Committee's (RRRC) review of sample selection identified errors in the selection process. Corrective action by the ISAP issue coordinator included revising the Random Sample Identification List and performing additional hardware !
reinspection Electrical ISAPs (1) ISAP I.a.1: Heat Shrinkable Insulation Sleeves (Revision 1 of ,
the Results Report issued December 30., 1986). )
i The NRC inspected 13 of the 111 samples selected for this ISA j From the CPRT reinspection of the initial 60 items randomly l selected, providing a 95/5 sampling plan, one was considered to I be a defect requiring sample expansion. As required by Appendix D of the CPRT Program Plan, the sample was expanded by J an additional 35 randomly selected item Four of the l
i
I c , sm
!
,
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 sample size, seven additional items were selected. Thus, the total valid samples selected by CPRT for reinspection was 98; however, during implementation of ISAP I.a.2, " Inspection
! 3 Reports on Butt Splices," 146 items were discovered that 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 advisor on engineering statistics approved the use of this
'
proportional sampling which was not addressed in Appendix D of the CPRT Program Pla 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." i With the' inspection of the " missed sample," the total number of valid randomly selected items inspected was brought to 111 (the-initial 98, 12 from proportional sampling, and the one " missed sample").
Based on the review of sample selection documentation,: detailed j inspection of 13 sample selections, and a review of other
'
sampling activities associated with this ISAP, the NRC inspector determined that the I.a.1 sample selection process conformed to !
Appendix (2) ISAP I.a.4: Agreement Between Drawings and Field Terminations (Revision 2 of the Results Report. 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 D,. Table 1. As with ISAP I.a.1, additional population items were discovered during ISAP implementation. Proportional sampling was again used and approved by the CPRT engineering statistics advisor. Based on a .
review of sample selection documentation and verifying in detail l the selection process (38 out of 383 selected items), the NRC ]
inspector determined that I.a.4 sampling conformed to i Appendix j
c. Mechanical ISAPs:
(1) ISAP V.a: Inspection for Certain Types of Skewed Welds in NF Supports (Results Report issued October 22,1986).
The NRC inspector examined in detail 16 of the 60 samples 1 selected and found sample selection conformed to Appendix D; however, three documentation inconsistencies were noted between .
l
_ .. . . . . .
-J
- ,
. ~ a i
the Random Sample Identification List (RSIL) and ERC Procedure QI-006, Attachment 6.5, Revision 2. Listed on Attachment were the 60 hangers inspected by ERC as taken from the RSI The inconsistency was not with the actual unique hanger number, but with the alphanumeric suffix character which~ indicates the type of hanger; i.e.,.A-anchor, S-spring, R-rigid, or K-snubber. !
Three hanger types were incorrectly coded as "K" instead'of "R".
The suffix characters also identify building, elevation, and code class. From reviewing the actual packages inspected, the NRC inspector verified that the~ correct hangers were selected and inspected. The ISAP V.a issue coordinator is in the process of correcting the documentation inconsistencies identified by the NR (2) ISAP'V.d: Plug Welds (Revision 1 of the Results Report issued December 18,1986). '
This ISAP contained four populations. Sample selection for each population was based on the 95/5 screen. The NRC inspector !
examined 67 of the 250 sample selections from the 4 population Eleven errors were found by the NRC inspector involving calculation of the random number which resulted in a different
/ random item being selected. It should be noted that prior to-the issuance of the Results Report (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 inspectio The scope of the statistical advisor's review of sample selection is further discussed in paragraph e. below. Based on results obtained from ERC inspections, plug weld testing, and bounding 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 only resulted in a different item being randomly selected and inspected and the statistical advisor determined that the sampling process itself 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 Results Report working
'
fil d. ISAP VII.c: Construction Reinspection / Documentation Review Plan (inprocess).
i This ISAP is unique because the VII.c work activities are divided j into 32 homogenous populations. On completion of all work 1 activities, a summary Results Report will be issued. Details of l reinspections and document reviews performed will be addressed as appendices to the summary Results Report. At the time of this NRC inspection, the Results Report and associated appendices were in i
I L j
_ -
.
<
r 4 * .-
31 their draft form and subject to various CPRT inprocess reviews; e.g., l RRRC, ERC engineering assurance and Q J Thirty-one of the thirty-two populations used statistical random g sample selection with the 95/5 screen (one population had less than 1 60 items, field fabricated tanks, thus all items were included in the '4 sample). The NRC inspector examined sample selections for'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 Program Plan and ERC Procedure CPP-006, Revision 3, " Sample Selection." Procedure CPP-006 was more prescriptive than Appendix D in-that.it provided ERC personnel with details for implementing the requirements-for. sample i selection. The five populations inspected by the NRC were: Cable Tray, Nuclear Instrument System Cable Termination, Electrical Equipment Installation, Instrumentation Equipment Installation, and Large Bore Piping Configuratio Typical errors encountered were calculation of random sample number; ;
use of duplicate random numbers; incorrect population item used; deviations from Appendix D not adequately documented; selection of items related to safe shutdown; and numbering of inspection work packages. Problems encountered that were not deviations from Appendix D or CPP-006 but made verification of sample selection difficult were: inadequate guidance for proportional sampling which was necessary when increases in population sizes were required; method of numbering Population Item Lists; and inadequate guidance for the resolution of problems encountered during sample selectio These errors and problems are discussed belo e. Sample Selection Review by the SRT The statistical advisor to the CPRT has conducted and is continuing to 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 to 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 sample selection process for all ISAPs and VII.c populations utilizing statistical sampling. To date, the statistical advisor has reviewed 100% of the sample selection process for 9 of 22 ISAPs and 19 of the 1 31 VII.c. populations using statistical samplin '
A checklist was developed and used by the statistical advisor to perform the reviews and to document the findings and actions required. On completion of the review, the issue coordinator or population engineer was given a copy of the checklist. Each finding and the actions required were discussed with the audited group. A formal tracking mechanism to verify completion of actions required had not, as yet, been developed or implemented. From interviews with
,
e s - * .o
the statistical advisor, a formal procedure and tracking system will be developed and implemented to assure actions required are completed in a timely manner. This activity will be.followed by the NRC as an 1 open item (445/8702-0-05; 446/8702-0-05).
Each of the errors and problems found by the NRC inspector had been l identified and documented by the statistical adviso To assure that no Results Report is published with open sample i selection errors, the'RRRC revised its working file check list on February 17, 1987, to require all open sampling errors identified against a Results Report be resolved prior to.RRRC approval of the working file and submittal of the Results Report to the SR f. ERC's Review of ISAP and VII.c Sample Selection (1) Engineering Assurance ERC has established an engineering assurance (EA) group to i perform final review and assembly of records and supporting l documentation (working file) required for ISAP VII.c prior to j turnover to the CPRT central file. This effort was governed by i Procedure CPP-026, Revision 0, " Final Review of ISAP VI Working Files." EA had performed an initial review of VI sample selection during July and August 1986. A written ,
checklist was used to direct the review and document findings i for follow-up. Several items remain open. It should be noted that during the EA initial review of sample selection not all sample selections were finalized. Work was still in process to ;
develop and complete.some populations and perform sample ;
selections. The final review by EA for sample selection was f scheduled to start in February 1987, but was contingent on Population Random Selection Identification Lists being completed j and approve j i
(2) ERC C a ity Assurance i l
The QA surveillance group has performed 19 surveillances of in l process ISAP activities. These surveillances, performed j immediately prior to Result Report submittal to the SRT, were to 1 determine that Results Reports appropriately addressed the i respective action plan. For those ISAPs using sample selection, 4 the surveillances included an in depth review of sample selection methodology and results. The purpose of thr sample selection review was to verify the sample selection process methodology and results were adequately documented and conformed to the requirements of Appendix D of the CPRT Program Pla With respect to ISAP VII.C, QA surveillance performed a review of sample selection which included population description and selection methodology for first and second samples taken, proportional sampling, and extended sampling. As described I
t
, 9
'
V 1 ;
,
. g y,
[, <
'
. .
t
p
, ,
Jabove,'EA'will perform a 100 percent review of VII.C sample selection' activitie .In addition tdLQA' surveillance off1 SAP sample selection, the ER QA audit group;has performed two programmatic audits :of the
'
sampling process as documented in ERC audit reports ERC-86-05.- i
-
and ERC-86-06. LNo findings were.noted in~those audit reports, a
< g. - Overview Quality Team (0QT)
. .
.
From interviews with the 0QT, the NRC determined that.the.0QT j has not planned any reviews of ISAP- sample selection., ' The review responsibility for ISAP sample' selection had been ]"
,
j assigned to the CPRT statistical advisor and the RRRC. The sample selection for several:ISAPs have been examined by the 0QT.' These were'notfin depth reviews such as those conducted by the.ERC_QA surveillance group or the CPRT statistical adviso Rather; the 0QT reviews were to determine' that statements.made in the.ISAP Results Reports with respectato sample" selection l methodology and results'were. traceable to supporting j documentation in the'ISAP working file. .The 0QT: compared j Results Report statements;to the working _ file'to verify that th'e H documentation existed with regard to population definition, 1 population size,. sample selection methodology, results of sample selection, and the justification for additional and/or expansion of sample selectio .
.
In summary, of the 50 action plans using sample selection (19 externa issue ISAPs and 31 VII.c populations),.the NRC inspected 11 for j conformance to Appendix D. From the 11 action plans, 330 of the 1480 sample selections.were examined for errors by the NRC < inspector. . Fo
- those action plans-inspected, the sample selection efforts were found to s conform to Appendix D. Those errors in the sampling process that were identified by the NRC inspector had also been identified by the CPRT- f statistical advisor and action to correct or disposition the errors had either been taken or was.being take At present, the statistical advisor does not have a system to verify the completion of action required to correct or disposition identified error j j
A commitment has been made to develop and implement such a system. .This _l
- commitment will be followed as a NRC open item, as discussed in I paragraph 5.e. abov No violations or deviations were identifie I
' Exit Interview Exit interviews were conducted February 10, 1987, and March 3, 1987, with
- !
the applicant's representatives identified in paragraph 1 of Appendix B of
!
j
-
,
o .,
this report. During these interviews, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the finding l I
i
?
I l
i l
,
.