ML20237L272
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{{Adams | number = ML20237L272 | issue date = 01/16/1987 | title = Forwards Partially Withheld Insp Repts 50-445/85-07 & 50-446/85-05 & Exhibits Commenting on Attachment Mm of Ofc of Inspector & Auditor Rept.Writing Style Abreviated & Comments Unedited Due to Imposition of 870116 Deadline | author name = Phillips H | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | addressee name = | addressee affiliation = NRC | docket = 05000445, 05000446 | license number = | contact person = | document report number = NUDOCS 8708200155 | package number = ML20237K807 | document type = INTERNAL OR EXTERNAL MEMORANDUM, MEMORANDUMS-CORRESPONDENCE | page count = 776 }} See also: IR 05000445/1985007
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/ % UNITED STATES
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NUCLEAR REGULATORY COMMISSION' j
'rn p,. /5j REGION IV
, g,p [ 611 RY AN PLAZA DRIVE. SUITE 1000
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ARLINGTON TEXAS 78011
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January 16, 1987 ]
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MEMORANDUM FOR: NRC Headquarters
FROM: H. S. Phillips, Senior Resident Inspector
Comanche Peak Construction ,
SUBJECT: COMMENTS.ON ATTACHMENT MM 0F OIA REPORT l
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As requested by the Region IV. Administrator, I have provided
information about the specific Concerns addressed in the Attach-
ment MM; however, this of course, does not include comments on all !
items listed at the back of Attachment MM.
Ray Hall directed that comments be furnished by 2:00 pm on
January ' 16,1987. Because of time constraints, the writing
style changes after commenting on 85-07/05 and became more abbre-
viated and the reader is directed to Exhibits in order to meet'
the imposed deadline of January 16, 1987. In addition, there
was no time to go back and edit comments on 85-14/11 and 85-16/13.
This document is furnished in an incomplete state. ,
This information is provided in a sealed package that is to be opened
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by the Committee.
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H. S. Ph 111ps
Senior Resident Inspector ,
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.G7082OO155 870312
PDR ADOCK 05000445
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Insrection Report 50-445/85-07: 50-446/85-05 (85-07/05) l
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gpncern No. 1
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and PHILLIPS were concerned that Region IV (RIV)
manageme,]t downgraded the violation, concerning failure to translate 1
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des 2gn criteria into specifications and drawings, to an unresolved !
item in the. inspection report issued without giving sound NRC
regulatory and technical baris and unresolved items require no action. .
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In the inspection report (signed on October 2, 1986, by the onsite NRO
supervisor and inspectors) the violation reads as f ollows:
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"6. Failure to Translate Desi an Criteria Into Installation l
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Speci f i cati ons. Procedures, and Drawinos: and Failure to Control
Deviations from These Standards
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"10 CFR 50, Appendix B, Criterion III, as implemented.by TUGCO
DAP, Section 3, Revision 3, dated July 31, 1984 3 requires that
measures shall be established to assure that applicable I
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regulatory requirements and the design basis, are correctly l
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translated into specifications, drawings, procedures, and
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instructions. These measures shall include provisions to assure
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design documents and that deviations f rom such standards are
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controlled.
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l 1 l " Contrary to the above, Unit 2 reactor pressure vessel
installation criteria such as centering tolerances, levelness
tolerances Esic3, and shoe to bracket clearances were:
(a) specified on Construction Operation Traveler ME-79-240-5500
based on NSSS vendor recommended criteria which had not been
translated into CPSES specifications, drawings, procedures, or
instructions; and (b) changed on traveler without appropriately {
documenting such engineering changes.
"This is a Severity Level IV Violations (Supplement II.E) i
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(446/8505-05)." ,
The downg-aded item in the final inspection report reads as follows:
"12. Reactor Pressure Vessel and Internals Installation - Unit 2
"Thi s inspecti on was perf ormed by an NRC inspector to verif y
final placement of the reactor pressure vessel (RPV) and
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internals by examining the completed installation and inspection l
records. i
"a. Requirements f or Placement of RPV
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" Requirements for placement of the RPV to ensure proper
fit-up of all other major NSSS equipment are in Westinghouse
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Nuclear Services Divi sion (WNSD) ' Procedure for Setting of !
Major NSSS Components,' Revision 2, dated February 13, 1979, )
and ' General Reactor Vessel Setting Procedure,' Revi si on 2,
dated August 30, 1974. The NRC inspector reviewed the
following drawings, which were referenced in the RPV
operation traveler, to verify implementation of WNSD
recommendations:
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. "NSD drawing 1210E59 ' Standard - Loop Plant RV Support
Hardware Details and Assembly'
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. "NSD drawing 1457F27 ' Comanche Peak SES RCS Equipment
Supports - Reactor Vessel Supports'
. "E drawing 10773-171-004 ' General Arrangement
Elevation'
. "E drawing 10773-171-005 ' General Arrangement Plan'
"Neither site prepared installation drawings nor
specifications (which implemented the WNSD recommended
procedures) were available and the drawings examined did not
show certain specific installation criterion such as
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centering tolerances,, levelness tolerances and clearance
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between support brackets and' support shoes.
"The inspector considers this matter unresolved.
(446/8505-05)"-
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PdILLIPS' Understanding of Concern No. 1
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Reouiremerts: The requirements (Exhibits 1, 2 and 3).incluue the
appropriate'10 CFR 50,: Appendix B criteria; Final Safety Analysis-
Report (FSAR); and Texas Utilities Generating Company ( T UGCO)
requirements.
.Theseirequirements require: (1). design control interfaces between' ,
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design organization, (2) the translation of design criteria into
' specifications and drawings, and (3) the organizational
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- responsibilities must be described in the organization and program !
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sections of'the FSAR and Quality Assurance Plan (OAP).
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Noncompliance With Reautrements: The NRC inspection of the reactor
vessel' inst'allation activities identified a violation that appeared to
be more closely related to 10 CFR 50, Appendix B,. Criterion III
'(Exhibit 1); however, the NRC inspectors reali:ed that violations of
'other criteria probably caused this violation. Instead of writing
violations' of several criteria, the NRC inspector selected what he
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considered the most significant violation and documented.it.
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approach would allow TUGCO to address this specific violation and
perhaps what appeared to be violations of other criteria when
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addressing the corrective action necessary, cause of the violation,
and steps necessary to prevent repetition. As TUGCO was not required
to take such acti on because the violation was downgraded as an
unresolved item, NRC inspectors have identi-fied additional aspects of
the violations which have been subsequently identified and are also
discussed below,
a. Introduction
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The NRC inspector found that Westinghouse Nuclec.' Service
Division (WNSD), " Procedure For Setting of Major NSSS
Components," (a Pittsburgh, Pennsylvania procedure and not
site specific) had no signatures which would. Indicate that
the document had been reviewed and/or authorized. There was
no evidence that this procedure was reviewed and approved by
Gibbs & Hill (G&H) and integrated into a specification,
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procedure, or drawing. This also applies to TUGCO !
engineering. It was not included in the site document 1
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control system as it is probably not appropriate to do so as
it is a proprietary procedure with general application.
Westinghouse JW1 recommended that the customer generate a
detailed site specific procedure for WNSD site personnel to
revi ew; however, the next sentence disclaimed responsibility ,
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for this activity with respect to W if the procedure,
specialist, or consultants were used.
As no .G&H specification, procedure, or drawing was developed
and placed in the document control system, it was impossible
to meet Criterion.III which requires the same organization
that specified the design criteria to review changes. This
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happened because the installation criteria were simply taken
from an uncontrolled procedure and placed in an instruction
(the traveler); therefore, subsequent changes were not
approved by the original design organization. This is
contrary to Criterion III which states, in part,
" Design. Changes, including field changes, shall be subject
to design control measures commensurate with thosa applied
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to the original design and be approved by the organizations
that performac. this origina.1 design unless the applicant
designates another responsible organization." l
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. Failure of GLH to Perform Desion Interface / Coordination
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The TUGCO FSAR, Section 17.1.3 (Exhibit 2), and TUGCO DAP, l
Section 3.0, state that G&H is the architect engineer (AE)
and that GLH is required to control design interfaces and !
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coordinate responsibilities and activities of participating
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design organt:ations. The reactor vessel installation is
dependent on the configuration of ,the reactor containment
building for which W has no responsibility. The W procedure
describes prerequisites which must be met prior to reactor
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vessel installation and it appears that G&H was responsible i
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for controlling such interfaces and coordinating such ,
interface activities. l
The NRC inspector found no such involvement by G&H, as
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evidenced by a lack of guidance in any specification,
drawing or procedure reviewed and approved by the AE.
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This violates Criterion III and FSAR 17.1.3 concerning '
design interface responsibility.
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. Failure to Describe Westinghouse Site Organization
Responsibilities
The NRC inspectors found that W site organization
participated in revising design criteria; however, the FSAR,
QAP, and implementing procedures do not describe any such
design responsibilities. In a January 15, 1987,
conversation, the W site manager said they have no site
design responsibility or engineering responsibility.
WESTERMAN states in his testimony (page 73., July 10, 1986)
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that W is a super Quality Assurance (DA) organization that
is there to make sure the utility is not invalidating the
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warranty. '
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Note: Also, WESTERMAN had doubt if TUGCO was capable of
auditing them. This supports PHILL'lPS' concerns in I
Concern 3 below. WESTERMAN contradicted this statement
later by stating that W approved changes to design criteria
on construction operation traveler (traveler) ME79-248-5SOO.
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llllll(didnot identify the above failure to describe W
responsibility on-site; however, this f ailure to describe
the W site organization also violates Criterion I and II.
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Failure to Include Westinghouse Recommended Desion Criteria
Into Specifications. Proceditres, and Drawi nc s
The NRC inspector found no evidence that W design criteria
had been formally translated into the specifications,
drawings and procedures; i.e., were not reviewed and
approved by G&H, W, or by TUGCO engineering. Instead, the
NRC inspectors found traveler ME79-2489-5500, which had heen
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initiated in accordance with Brown & Root (B&R) construction
- Procedure CP-CPM-6.3 (Exhibit 4) which makes no provisions
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Appendix B to 10 CFR 50 or the TUGCO FSAR and DAP. This
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construction document provides great latitude f or expediting ;
construction. It can be initiated and prepared by the i
construction superintendent'or discipline engineers. It
allows approval by the appropriate OA personnel who have no
design responsibility. Procedure CP-CPM-6.3 requires W to
review the construction traveler but-there is no 04 program
description or procedure that describes the W organization
or responsibilities; therefore, neither W or B&R is
. authorized to make design changes. The B&R Quality Control
(OC) inspectors are authorized to make minor changes; l
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however, other changes must be authori:ed by B&R DA.
The W procedure (E:thibit 5) said it had no responsibility
for interfacing the Nuclear Steam System Supplies (NSSS)
with the plant structures. The procedure.does recommend
' tolerances but takes no other responsibility. Critorion III
requires field changes to be reviewed and approved by the
original organization. The NRC inspector found that the
design tolerr.nces on the traveler were not treated as
engineering design criteria. No engineering design change
authorization (DCA) was processed and the traveler tolerance
was changed by B&R construction, DA, and W representatives
who had no such design responsibilities specifically !
delegated to them in writing.
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This. failure to translate design re'quirements into
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specifications and. drawings is a violation of Criterion III
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and'FSAR, Section 17 '.' 1. 3. i
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.. Failure to Follow Traveler Procedure j
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Norman reviewed traveler ME79-248-5500 (Exhibit 6) for'
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compliance to tolerances and was either unaware of t ravel er
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Procedure CP-CPM-6.3 or apparently did not choose to review '
the traveler against.CP-CPM-6.3.
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PHILLIPS, during the OIA investigation reviewed TUGCO's and
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RIV management's' claim that this traveler is equal to !
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detailed procedures which are signed and authorized by
persons having the 'procer authority. PHILLIPS' detailed l
review-revealed the following deficiencies or noncompliance
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with the procedure, which means it cannot.be considered-a i
complete procedure'and they initiated the work with a faulty
procedure.
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(1) Procedure CP-CPM-6.3 is geared to construction and does. J
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not descr.ibe design responsibilities. As indicated in i
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paragraph 3.6.2 of the procedure, it assumes that j
specifications, procedures, and drawings had been
reviewed and. approved by design organizations and such
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documents have.been collected or referenced in a ]
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traveler package which shows how each construction step
is to'be accomplished to achieve the design shown in
drawings, specifications, etc.. No where in this
procedure did it delegate the authority to change-
design documents cricriteria. W responsibility was not
described other'than to acknowledge'their review for
commercial considerations.
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<(2) Traveler Procedure CP-CPM-6.3, Revision 5 required the l
traveler package either contain or reference
appropriate drawings, pr ocedttr es , instructions,
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manufacturer'r, manuals /guiuelines, or other.information
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necessary to accomplish the the activity.
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Traveler i
ME-79-248-5500 did not. reference the W procedure for
setting major'NSSS components and did not incorporate
all of this procedure into the traveler; i.e., the
traveler did not show that all prerequi si tes' or
conditions were met prior to installing the vessel
which would be Step 1 on the traveler. ]
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(3) CP-CPM-6.3 required that drawings and procedures be
ref erenced and the revision level be provided. No
revision level was provided for drawings W12iOE59,
W1457F27, C-E 10773-171-004, C-E 10773-171-005 and
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mechanical installation Procedure MCP-1. I
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(4) Step 6 of the traveler did not spectiscally state "not
less than 1 inch," as stated in Step J of the W vessel
setting procedure.
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(5) Revision 4 (Step 11 of the traveler) changed the 757,
contact required by the W procedure to contact area
acceptable to W. In this case, the uncontrolled tl i
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procedure was ignored without an engineering change l
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being processed. W responsibilities onsite were not !
described in the TUGCO FSAR, Section 17.1.3, or DAP;
however, these documents did assign this responsibility ,
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to G&H and TUGCO. Because W had no design
responsibility onsite. Without a description of.W in
these documents, the W representative may be anyone;
i.e., requires no technical e:: p er t i se.
(6) Revision 3 documented the violation of Step i for
minimum engagement for guide pins. The same comments
apply as for Revision 4.
(7) Revision 2 deleted the machining requirements without
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engineering review and justification. The same
comments apply for Revision 4.
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(8) Revision 5 changed the t equirement to 0.020" for each i
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side of the vessel supporting to a range of 0.015 to
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0.025" for each side. The same comments as for
Revision 4.
(9) The W representative accepting revisions / deviations of
the construction trave;er does,not appear to be the
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same as the person who approved the original traveler.
CP-CPN-6.3 required thos e who reviewed and approved the
traveler during preparation must review and approve
major changes to the proce(/ e. Since W
responsibilities were not described, there is no way to
identify who in the W'on-site organization or other W
organi:ations was authori:ed to change the uncontrolled
procedure to the construction traveler.
(10) Considering that the construc'. o traveler wat ured
instead of a procedure (reviewu. and approved by the
appropriate design engineering and QA/DC or gani:ations)
nonconformance reports (NCRs) should have been written
when the required tolerances were violated. As a
mi ni mum, appropriate site engineering and Q4/DC
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organi:ations should have dispositioned such
deficiencies.
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In September 1985 and presently, Phillip's understands the initial violation and reali=ed then and now that there are several other potential violations in addition to proposed violation which
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was dropped; i.e., additional violations-of Criterion 1 and
Criterion II as TUGC0 f ailed to describe OA W in program; violation of
Criterion V-- failure to follow procedures; Criterion VI--failure to !
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control documents; and Criterion XV--failure to write NCRs. Neither
B&R construction, QA or i even justified chanQes to informal W j
documents and in some cases gave arbitrary tolerances. There was more
than enough information to cite the originally proposed a violation.
Phillio's Understanding of Handlino/ Mishandling Concern 1
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Backorcunds' directed PHILLIPS to : syiew the NRC MC 2512
inspection program in October 1984 and du.-ing this review of the NRC ,
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Form 766 program covering 10 years, it was f ound that the storage and
-handling was observed by the senior resident inspector but the
installation of the vessel was not inspected in accordance with
inspection Procedure (IP) 50053. Frocedure 500538 showed completion
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by a RIV inspector in the Inspection Report 80-26; however, vessel -j
i nst al l at i on was really not observed as reported in tt NRC Form 766.
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PHILLIPS subsequently learned that CASE, the intervenor, had submitted
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Contention 5 (Exhibit 7) to the Atomic Safety and Licensing Board
(ASLB) which stated that TUGCO f ailed to adhere to " tality
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assurance / control provisions, Appendix B of 10 CFR 50, and the
construction practices f or various wort: and specifically the placement
of the reactor vessel for Unit 2.
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In late 1984 and early 1985, and PHILLIPS decided
that the installation of Unit 2 should be inspected to the degree i
possible (since installation was completed July 26, 1979) because NRC
inspection of the actual installation was not apparent and this issue
would likely be covered during the hearings. When WESTERM4N replaced
and assumed responsibility for the RIV ' Comanche Peak Task
Group, PHILLIPS discussed these issues with him and the importance of
the inspection.
En addition to this inf ormation, PHILLIPS and WESTERMAN were aware of
findings in " Miscellaneous Item 2, Reactor F'ressure Vessel," of
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NUREG-0797, Supplement 8 (Exhibit 8), which describes problems found
with regard to installing the Unit i vessel. In this case, a design
change was not properly coordinated between W, GLH, and TUGCG to
assure that design requirements were incorporated into project
specifications, drawings, procedures, and instructions / travelers.
This f ailure to interf ace resulted in deficiencies; i.e., reactor
vessel and insulation to the reactor vessel cavity fit, caused
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unacceptable conditions which were identified during hot functional !
testing.
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PHILLIPS was also aware of another deficiency (Exhibit 9) which should l
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have been reported as a 10 CFR 50.55(e) deficiency. On February 20.
1979, TUGCO reported that a major error had been detected in the
design of Unit 2 reactor vessel support structure; i.e., the reactor
vessel support shoes, their ventilation duct work, and surrounding
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reinforcing steel had been rotated 45 degrees from the correct
positions. Apparently, just prior to installing the vessel, TUGCO
learned that the reactor vessel would neither match the vessel support
feet nor would the piping system fit the other reactor loop
components. This appears to have been caused,by enother design
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interface problem; i.e., not assuring that prerequisite for vessel !
setting were acceptable as construction proceeded.
Properly Handlino: PHILLIPS provided this background information to ,
NORMAN prior to helping him prepare for his inspection and explained
vessel insta11at$on Procedures IP 50051, 50053, and 50055
(Exhibits 10.a, 10.b, and 10.c) which require review of procedures,
observation of work in progress or completed work, and review of
records. HUNNICUTT, RIV supervisor on-site, directed'IEEEEkta
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inspect the area and report his inspection findings. These findings
were submitted to HUNNICUTT, the reviewing supervisor, who was
stationed on-site from early 1984 through July or August 1985. On
June 10, 1986, thisviolationwasreviewedbylllllllkRIVBranch
Chief, and HUNNICUTT, prior to the management exit interview. It was
reviewed during the exit interview with MERRITT, TUGCO Construction
Manager; HALSTEAD, TUGCO Site QA Manager; and WELCH, Site QC
Supervisor; and they all acknowledged the violation. TUGCO
representatives were also well aware of this violation in advance of
the exit meeting.
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-CUMMINGS, a second Senior Resident Inspector, took the lead with
respect to writing the report. The draft report (Exhibit 11) was
completed. HUNNICUTT asked PHILLIPS to review only the paragraphs of
the report which he had written because PHILLIPS had several special
projects assigned, including involvement with South Texas hearings and
the Houston Lighting & Power vs. Brown & Root ' lawsuit. PHILLIPS had
almost no involvement with @ inspection and findings at this
point other than routinely discussing inspection results with him.
PHILLIPS tssumed responsibility for reviewing the final draft report
for accuracy when CUMMINGS left the site in August 1985.
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September 1985, WESTERMAN asked PHILLIPS to become technically
involved and to review findings because HUNNICUTT and
CUMMINGS were no longer on-site. Also, in late August 1985, TUGCO had
complained that they did not agree with all of findings. In
late August or early September 1985, PHILLIPS and met with
TUGCO representatives who presented information concerning
findings. The information presented at this time should have been
readily available to TUGCO during the inspection and well before the
exit. In any event, TUGCO should have responded within at least a day
or two after the exit meeting to show compliance. Refardless,llllllk
agreed to limited changes based on information presented in these'
meetings. PHILLIPS also arranged for discussions between BOSNICK, NRC
headquarters, and PHILLIPS. The final report was revised to
reflect these changes and on this basis PHILLIPS signed and concurred
HUNNICUTT also signed on Octobe; 1985 (Exhibit 12). I
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Mishandling: WESTERMAN replaced HUNTER in August-September 1985;
JOHNSON replaced DENISE; and HUNNICUTT was removed from site. The
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mishandling occurred shortly after WESTERMAN and BARNES were assigned
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to the RIV Comanche Peak Task Group and came on-site. According to
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WESTERMAN's July 20, 1986, statement, it appears that WESTERMAN sought I
out TUGCO personnel who were following up on the report because in his
mind, he questioned the violation concerning Item 10 in Exhibit 11;
i.e., where the NRC inspector was unable to retrieve records.
WESTERMAN further stated that he knew TUGCO's system was not fast but
they have always been able to come up with documentation. As a result
of TUGCO's abilsty to retrieve one single piece of paper two months
after the exit, WESTERMAN launched into a reinspection of virtually
all findings. WESTERMAN directed PHILLIPS to review
findings and meet with TUGCO to listen to their disagreement with
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findings. PHILLIPS does not recall TUGCO's ever disagreeing
with this Concern No. 1 in those meetings but they did disagree with
some findings on the ASME Section III Code.
The final inspection report (Exhibit 17.a) was forwarded for NOONAN's l
review and apparently HAUGHNEY's comments were taken as an opportunity
to make additional changes. In this case, a consultant, who had
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reviewed and inspected nothing, was used to counter the inspector's
detailed review and inspection. WESTERMAN subsequently met with
and/or had long and loud conversations with PHILLIPS and
several times between September 1985, and January 1986. as
badgered and harassed, for no good reason, to change his findings.
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disagreed with WESTERMAN each time he tried to persuade him
that Concern No. I was not a violation. WESTERMAN attempted to
solicit PHILLIPS support to convince this was neither a
violation or an unresolved item. PHILLIPS did not support WESTERMAN .
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but agreed with and r.tated that this was clearly a violation. -
WESTERMAN's attitude toward PHILLIP's changed at this point and
pressure and harassment to weat PHILLIPS down continued until the
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present.
It Was WESTERMAN's responsibility to escalate the differences but
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instead WESTERMAN ignored the differing prof,essional opinions of both
and PHILLIPS and directed that the violation be downgraded to
an unresolved item without basis (Exhibit 13). This also appears to
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be inappropriate as it appears that and CUMMINGS were not
contacted to get their understanding, advice, or concurrence on such
changes to the report. It is not clear as to whether HUNNICUTT was
informed of the difference and changes.
PHILLIPS signed the report in October and thought that WESTERMAN had
in some way resolved the issue with Jefore JOHNSON signed the
report on February 3, 1986. PHILLIPS later became aware that
had refused to sign the report and never had agreed with downgrading
the violation.
stated their difference of technical opinion
concerning changes in the final inspection report. JOHNSON, HALL,
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WESTERMAN, and BARNES had a meeting with on
February 25, 1986, but PHILLIPS was not invited to this meeting. RIV l
management simply ignored PHILLIPS, CUMMINGS, and perhaps HUNNICUT1 as
they were not allowed to attend. If RIV management had required all
to attend, differing professional opinions would have resulted. _.
*
<
PHILLIPS Understanding of Safety Significance
This concern is significant from several standpoints such ass
(1) Contention 5 licensing issue, (2) failure to NRC management to
regulate instead of promote the licensing of Comanche Peak Steam
,
Electric Station (CPSES), (3) TUGCO's QA program I and plan
deficiencies, (4) technical deficiencies, and (5) differing
i
professional opinions.
1. The significance of Contention 5 is that it claims that quality
assurance / control provisions required by the construction permits
and Appendi>: B of 10 CFR 50 were not adhered to concerning the
placement cf the reactor vessel for Unit 2. It appears that the
1UGCO quality program was not properly controlling all aspects of
this activity; however, NRC management refused to issue a
violation which would have assured TUGCO would take appropriate
corrective steps.
l l
2. WESTERMAN, supported by BARNES and JOHNSON, made it clear to
and PHILLIPS that they were e>:pected to promote the
..
a
a
^21
i
licensing process and to do the work for TUGCO by going to j
extremes to help them show compliance. The two'NRC inspectors
L were held to unrealistic performance standards concerning.how far
i
one must inspect after a violation is: identified, in this j
)
instance,.while expecting little or no performance.from TUGCO to
show compliance in a-reasonable period'of time. '
i
!
3. The TUGCO FSAR and QAP describe the design responsibilities;
'however,-it appears that G8<H did not discharge their-
responsibilities regarding.the coordination of design
responsibilities pertaining to civil structural, and NSSS
c
component interf aces as evidenced by their f ailure to develop i
'!
o
specifications,or. drawings which would incorporate W installation-
criteria. . Similar problems were experienced. concerning the
vessel supports for Unit 2, which should have reported as a
construction deficiency, and if identified may have identified
this problem as part of the corrective action. The onsite W
group responsibilities were not described -in the FSAR, QA Plan, ,
i
or other-procedures; therefore, W activities are not under the
control of the TUGCO program and this is significant as,
according to WESTERMAN, they were apparently performing
engineering design functions. Travel er Procedure CP-CPM-6.3 was l
supposed to be equivalent to a detailed procedure; however, the I
1
1
' failure to follow this procedure defeated this premise. It is
i
unrealistic to expect the traveler system to include all design
criteria and be a. design control document.
.
(
*
_ _ _ _ _ . . . _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _
!
22 5
f
4. and PHILLIPS do not agree with the statement that
'
'OIA concludes no hardware problem exists. Only the AE NSSS and
TUGCO can jointly determine this. NRC inspectors perform general i
inspections of design, procurement, and construction on-site, but ;
usually have little or no design engineering experience. l
Therefore, few NRC inspectors are qualified to evaluate the
complex design of the plant. Instead, NRC inspectors assume that l
design criteria is specified by the AE or other design
organizations and inspect for compliance to such criteria. When
noncompliance are identified, a violation is issued concerning
failure to meet this criteria and then;,TUGCO and the design
engineering organization are required to evaluate this deficiency
and take appropriate action. Since no violation was issued
relative to this concern, the overall technical significance is
unknown until either TUGCO or NRC engineers, with design
expertise, fully evalu' ate all aspects of these deficiencies. It
is also unclear as to whether the prerequisites for vessel
setting (Steps 1-19 of W procedure) were met as they were neither
referenced nor checked off on the traveler. Failure to meet the
prerequisites could cause design interface problems with other
components because all they depend on acceptable installation of
the reactor vessel.
5. and PHILLIPS have all been ostracized,
I
downgraded, defamed, disfranchised, and penalized for having
differing professional opinions with JOHNSON. WESTERMAN, and
4 a
_ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _
_-
,
i
23
l
BARNES. They have been ridiculed to their peers, who have
carried away these attitudes and in some cases, false rumors.
WESTERMAN, acting as an agent of JOHNSON, harassed and pressured
ktochangehisfindingstothepointthatheprobablywould
~
have given up if PHILLIPS had joined forces with WESTERMAN and
JOHNSON. Despite and PHILLIPS' differing opinions, this
violation was downgraded without sound regulatory or technical
support. Subsequent meetings on these differences have shown
inspectors the futility and dangers of expressing differing
opinions. This message has a chilling effect on inspectors and
leads inspectors to take the easy way and that way is to simply
avoid differences by never. documenting violations. The cafety
significance of this ef f ect is unmeasureable because nf the great
influence that the NRC has on licensees and applicants.
i
The changing of reports after the inspectors have signed and
concurred is unprof essionsl . Again, the message is so strong
concerning differing opinion, that the health and safety of the l
public is not well served.
This appears to be a persuasive RIV mamagement attitude. It is
so strongly promulgated that RIV inspectors soon learn to conform
to the " party line" and sit back, relax, and draw their pay. I
says it quite well in quotes shown in Exhibit 12.b.
l
l
_ _ _ _ _ _ _ _ _ _
_ _ _ . ______
24
Concern No. 2 q PHILLIPS was concerned that RIV management downgraded violation (described below) to an unresolved item and because sound regulatory and technical basis were not provided to support their action. Also unresolved items are a concern because they do not require TUGCO to respond to the NRC to explain the corrective action, cause'and future prevention of the violation.
In the signed inspection report the violation reads as f ollows: l
.
"7. Failure to Maintain Tolerances Recuired and Failure to Reoort
Tolerance Deviations on a Nonconformance Report
i
"10 CFR 50, Appendix B, Criterion IV as implemented by the TUGCO QAP, 1
i
Section 15.0, Revision 2, dated May 21, 1981, requires that measures
shall be established to control materials, parts or components which
do not conform to requirements; and nonconforming items shall be
reviewed and accepted, rejected, repaired; or reworked in accordance
with documented procedures.
" Brown and Root Quality Assurance Manual, Section 16, dated
March 27, 1985, requires that unsatisfactory conditions
identified on process control documents shall be identified on a l
nonconforming report.
.
i
- - . _____.__.._____________a
_ _ _ - -
)' 1.
!
,
l 25
" Contrary to the above, clearances between the reactor vessel
support bracket and support shoes were not within the original or
I
reviseJ. permissible tolerance stated in Construction Operation )
i
Traveler ME79-248-55 and the deviation was not reported on a {
l
^
l
nonconformance report.
I
"This is a Severity Level IV Viol ation. (Supplement II.E)
(446-8505-06)
,
Violations which were dropped or downgraded to unresolved do not
receive the following treatment: ,
l i
" Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric
I
Company is hereby required to submit to thic office, within 30 days of
the date of this Notice, a written statement or explanation in reply,
including: (1) the corrective steps which have been taken and the
results achieved; (2) corrective steps which will be taken to avoid
f urther violations; and (3) the date when full compliance will be
i
achieved. Consideration may be given to extending your response time ]
I
4
'
for good cause shown."
The final inspection report issued February 3, 1986, dropped these j
l
l
findings. The items just disappeared.
l
I
,
e' _mi
_ _ _ _ _ _ -
3
'
b
1
2o
$
I
4
,_ ?ILLIPS' -' Underst andi nc of Concern No. 2 '
I
Fecuirementsi. Tne requirements are described in the appropriate !
i
1
Criterion XV of Appendix B to 10 CFR 50, TUGCO FSAR and QAP, and B&R j
i
QA Manual (OAM) (Exhib'ts 1, 15, and 26). These documents require the
identification and correction of devi ations, d'ef i ci enc i e s , defective
material and equipment, and nonconformances. l
I
l
l
Noncompliance witb requirements: PHILLIPS reviewed finding
and violation which had been approved by previous supervision l
and 'HUNNICUTT) . In September discussions with related to I
Concern No. 1, it was apparent to PHILLIPS that understood the
\
issues-and had identified a second -violation; i.e., failure to
document out-of-tolerance conditions and have appropriate engineering
organizations evaluate the nonconforming condition.
PHILLIPS subsequently inspected the vessel installation and identified
other instances where a NCR and/or DCA would have been appropriate.
See di scussion in Concern No. 1. (PHILLIPS' Understanding Of The
Concern) which discusses revi sions to the traveler to disposition l
neveral failures to meet W tolerances.
I
i
1
l
_____________-_______
_
27
PHILLIPS' Understanding of How Concern No. 2 was Minhandled
Same as Concern No. 1.
PHILLIPS' Understands r.o of Safety Significance
l
l
This concern is an extension of Concern No. 1 and the safety
significance is virtually the same.
Concern No. 3
.
, and PHILLIPS were concerned that RIV management
downgraded vi ol ati on (described below) to an unresolved item
> 1
i
and because sound regulatory and technical basis were not proviced to
support their action. Also, unresolved items do not require TUGCO to ,
l
respond to the NRC to enplain the correction, c&use, and future
prevention of this violation.
l
l
1
l
The f ollowing viol ation was originally proposed on October 2, 1986,
(Enhibit 11). l
l
9
- _ _. - .-
.
l
28
l
'\
"8. Fail ure to Audi t' RPV Speci f i cat i ons/ Procedures 1__ Installation _ar ld
As--bu i I t Records
1
i
"10 CFR 50, Appendix D, Criterion XVIII as implemented by thn
i
TUGCO Quality Assurance (QA) Plan, Section 18.0, hevision 2,
dated July 31, 1984, requires that a comprehensive system of
planned and periodic audits be carried out to verify compliance
with all aspects of the quality assurance program.
" Contrary to the above, there was no evi dence that TUGCO had
audited either Unit 2 reactor vescel installation specifications,
placement procedures, actual hardware placement, or as-built y
l
records..
"This is a Severity Level IV Violation. (Supplement II.E)
(446/8505-08)."
The downgraded item in the final report ( E:< h i b i t 13) reads as follows:
"d. Recorde of DA Audits or Surveillance
The NRC inspector requested TUGCO QA audits or surveillance
per f ormed by TUGCO of the Unit 2 RPV installation. TUGCO
did not make available any documentation of an audit or
I
surveillance which evaluated specified placement criteria,
placement procedures, hardware placement, or as-built
1
1
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- - - - - _ _ _ -
l
29
records. This item is unresolved pending a more
comprehensive review of these activities (446/8505-07)."
NOTE: See Exhibit 11 and 12 for report details that explain the basi s
for these violations which were described in.the Notice of Violation.
PHILLIPS' Understanding of Concern No. 3
Requirements: The requirements for auditing (Exhibit 1, 17, 18
and 19) include Criterion XVIII of Appendix B to 10 CFR 50 and TUGCO
FSAR, Section 17.1.18; and QAP, Section 18. llllllldidnot include a
reference to BLR QAM Section 19.0 and implementing procedure OAP-19.1;
however, BLR also had responsibility to audit the installation of
mejor NSSS components but no evidence of such audits have been found.
Also, both TUGCO and BLR were required to implement ANSI N45.2.12,
" Quality Assurance Program Auditing Requirements for Nuclear Power
Plants." Criterion XVIII requires a comprehensive system of planned
and periodic audits bs implemented to verify compliance with all
asnects of the quality assurance program and to determine the
effectiveness of the program. ANSI N45.2.12 (Exhibit 10) describes,
in detail, the minimum requirements to meet Criterion XVI11 of
Appendin B and specifically addresses the need to plan the audit
program which includes auditing complex activities. The W
installation procedure (a complex activity) states that the reactor
vessel must be set correctly as it is key to installing all other
major components. In this case, there was not only a requirement to
.
_ _ _ _ _ _
- _ _ _ _ _ 1
i
30
audit complex vessel installation activities, but also a requirement
(Enhibit 18, paragraph 3.4.3) to perform supplemental audits because
of previous quality and design problems; i.e., the reactor vessel
cupports were installed some 44 out-of-tolerence and relates to
f ailed design interfaces between G&H, W, and.TUGCO.
Noncompliance with Requirements: requested audits of the
reactor vessel installation because of Concern No. 1 and 2, and
previous installation problems. inspected to determine why
TUGCO had not identified failure to control design in Concern No. 1
and to issue a nonconformance on out-of-tolerence conditions as
der.cribed in Concern No. 2. He contacted C. WELCH, TUGCO Site DC
Supervisor, to determine if audits had been performed concerning the
installation of the Unit 2 vessel. TUGCO found no audits of these
ottivities and the NRC inspector was also inf ormed that no
surveillance were performed.
This failure to audit this complex and critical NSSS activity is a
violation of Criterion XVIII of Appendix B to 10 CFR 50.
PHILLIPS' Understanding of How Concern No. 3 Was Handled / Mishandled
The basis of the mishandling starts with the philosophy described in
Exhibit 126. In order to understand the handling and mishandling o1
this specific concern, it is important to understand the background
concerning TUGCO's audit program. Also, this f ailure to audit cannot
_ _ _ - _ _ _ _ _ _ _ _ _ _
-
. ,
I
I
31
l
be considered an isolated case where the audit program did not work 4
!
which is supported by comments in d t ? nent paragraph.
Backcround: TUGCO obtained their construction permit December 19,
1974. The CA program delegated certain audit responsibility to the
,
)
AE, NSSS, and the constructor. Because of their dissatisfaction with
GLH, AE, and the contractor, B&R, TUGCO took away certai n
responsibilities from these organizations and one specific function
was portions of the audst function. TUGCO Unwisely assumed audit
responsibilities that a highly experienced licensee usually does not
assume and as a result, the TUGCD audit program has been continuously
i !
deficient. A 1984 NRC inspection of TUGCO's audits of W site and TUGCO si te activi ties revealed violations which were documented in the Inspection Report G4-32/11 (Enhibit 20). It also appeared that BLR site work activities had not been properly audited. As the BLR audit program was also suspect, this inspection was to be continued by C.
l l HALE's group on-site. Specifically, as the second part of the
84-32/11 inspection was to similarly review the BLR audit program, PHILLIPS was unable to complete the inspection due to limited
,
resources and other assignments.
l l
In addition, one must also consider that three consultant's reports,
i
by LOBBIN and Management Analysis Corporation (MAC) indicated that in
1976, 1977, 1978, and 1982, serious problems entsted in the TUGCO and
f B&R OA program; however, it appears that TUGCO took little or no
corrective action to correct these deficiencies. One of the
l - --- ---- - - - - - - _
- _ - _ _ _ - _ . __ - _ _. . _ _ _ .
1
32
significant findings that was common to TUGCO and B&R in these
consultant's reports was ineffective audit programs. Since the eudit
programs validate the other 17 criteria of Appendi:: D to 10 CFR 50,
this is significant because of the impact on many other areas which
may be deficient and go undetccted.
' PHILLIPS also found that the NRC had not performed an in-depth review
of the TUGCO corporate office from 1974-1984. Because of this,
previous violations and f ailure to perf orm required IE inspecticn,
PHILLIPS has emphastred the inspection of onsita Audits by TUGCO and
~
B&R to determine what activities have or have not been audited by
TUGCO and D&R. In cases where audits have not been performed,
RIV management takes the position that there is nothing that can ba
done as the opporutnity to audit has been lot. This is not entirely
accurate as those activities can still be audited through the review
oT completed work recorts and accessible attributes for equipment or
components may still be observed as a part of the audit.
In 1978, MAC (Enhibit 21) conducted an audit of TUGCO which was highly
critical of many TUGCO DA program areas such as organization, design,
,
procurement, complicated procedures, inadequate inspection criteria,
in-service inspection markings, e::clusion of proper engineering of
nonconformances, records storage facility, and an inadequate audit
program. These areas impacted technical work. Although Concern No. 3
relates to audits, the audit program is responsible for assuring these
other deficiencies do not exist. Subsequent NRC inspections have
i
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30
shown that correc ti ve action was not taken on these ceficienc)es until I
l
1984 and 16 some cases certain of these corrective actions were not
effective. In May 1985, PHILLIPS received the ASLB Notification from I
TUGCO attorneys, WORSHAM, FORGYTHEe SAMPLES & WOOLIDGE memorandum
(Exhibit 22), dated May 29, 1995. According.to this memorandum, it
appeared that TUGCO made a material false statement to PHILLIPS during
the NRC 84-32/11 inspection of corporate oanagement as they said they
had no other consultant report but they had this report thi was
critical of the areas that PHILLIPS was inspectino. The NRC
investigat. ion and resulting of NRC Board Notificat,an 85-067 and
85-076 (Exhibit 23) 9confxrmed this material f alse stJtement; h7 wever,
,
01 failed to confirm an additional mat eri al false statement ab ot,t
TUGCO's knowledge of the MAC audit of B&R.
In January 1956, PHILLIPS followed up on these MAC audits and found
that in 1986, TUGCO and B&R had still not taken complete and effective
corrective action concerning their audit programs. iN m4Y 1986, j
i
PHILLIPS wrote violations for failure to take corrective action but in
!
September 1986, was directed by IE headquarters and RIV management to j
l
drop these violations out of NRC Inspection Report 86-08/06 f
l
(Exhibit 30) as they claimed C. HALE, NRC inspector, would take care
of the vi ol ati ons. To date, these violations have not been issued and
in a recent conversation with HALE on January 6, 1986, he said he had
I
no intention of fc11owing up on the MAL reports. If violations are l
1
l
not written, PHILLIPS has informed RIV management that a difiering j
pro +essional opinion will be written,
1
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- - _ _ _ _ _
34
In February 1982, pages 1, 2, 3, and 14 of the P. S. LOBB1N
(Exhibit 24) aurat again advised TUGCO management of serious
deficiencies in the QA program which included inadequate experience,
deficient audit program, and an ineffective surveillance program. On
June 1, 1982, a TUGCO le,t,ter (Exhibit 25) sent a copy of this to R1V.
Contrary to what WESTERMAN says in his statements, this sh9uld have
caused an in depth audit in accordance with IE Procedure 35060, " Audit
of Licensee Management of QA." This alone made Procedure 35060
priority anti it should have been performed in 1980 under MC 2512
priority 2, and special audits in 198t, 1982, 1983, and 1984 until
th'ese problems were resolved.
.
RIV took na such action and in fact TUGCO management of the QA
function was not audited in depth from 1974 until PHILLIPS audited
TUGCO in' August 1984. WESTERNAN became very defensive about this;
1.e., RIV failed to perform OA inspections and this was in
Novembcr-December 1, 1964, before he was reassigned to Comanche Peak.
He later made veiled threats to PHILLIl<S about this matter it in
December 1985 while assigned to Comanche Peak.
NRC Construction Assessment Team (CAT) Report (Exhibit 26), dated
April 1983 -(conducted January 24 through March 3, 1983) i denti f i ed ,
serious OA and hardware violations. The audit program (Exhibit 26,
l l
pages 1, B-1 through B-3, and VIII-1 through VII-5) was again singled
;
out and this time it was tied to causing HVAC and electrical s
separat)on deficiencies. RIV vigorously opposed the CAT team while
l
<
. . _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ __ l
-- _ _ _ - _ _ _
3S
_
onsite and later their inspection report findings. The qualifications
:
of the team were questioned. Again RIV ignorea the 04 program
deficiencies at TUGCO corporate office and failed to perform required
QA inspec62cn per Procedure 35060. Even today, it is clear that RIV
management and inspectors still believe Comanche Peak is the best
plant in the country and the fault was with CAT members and Technical
Review leam, at al.
NRC Inspection Report 84-32/11 (Exhibit 20) was the result of
NRC Division Director, directing PHILLIPS and two NRC consultants to
audit TUGCO management of this OA program. ,1n preparing for thiu
.
inspection per Procedure 35060, PHILLIPS reviewed old inspecticn
reports and interviewed inspectors. PHILLIPS contacted CAT inspectors
to avoid duplication of effort. HANSEN, NRC CAT inspector, told
PHILLIPS he inspected the program at the TUGCO Dalles office but
really had not had enough time to completely analy:e their programt
l
however, he considered their audit program to be scmewhat deficient
from 1974 through 1982. HANSEN sent his field notes to PHILLIPS prior
to the inspection. As a' result, this inspection was also a follow-up
r.n his findings.
PHILLIPS el ected to audit TUGCO's program f or 1983 to avoid
duplication. PHILLIPS f ound serious violations that indicated they
had not corrected the deficiencies (Exhibit 24 and 26); however, in
August 1984, PHILLIPS was unaware of the MAC audit of TUGCO
l (Exhibit 21) as TUGCO purposely denied NRC this information. l l
-- _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
-._ - _ . _ _ - _ _ -_
e
1
36-
' Pages P-31 through P-33 (Exhibit 27) of NRC SSER No. 11 of-NUREG 0797
- referenced PHILLIPS' B4-32/11 inspection report. (electedto
'havo T'UGCOLrespond in the Action Plan and fir'a1 TUGCO Results Report;. ,
!
- however, this was done with the thought that TUGCO would take prompt
corrective steps and advise NRC of the results in a matter of 3-4
months. This did not happen because the TUGCd Results Report.on
.
audits was not issued until April 1986. F HILLIPS became uncomf ortable
with TUGCO's delay.in September through October 1985, and wrote memos
to both' WESTERMAN and HALE (RIV CPTG) to f ollow-up on 84-32/11. This
did not happen until about March 1986. However, PHILLIPS disagreed i
I
with HALE and the Results Report because it, appeared'that TUGCO has i
still not corrected-the problem, determined the cause, and took steps
to preclude repetition. This was based cn PHILLIPS findings in
February 1986, which showed that B&R had not audited 12 sections of
their ASME OA manual ar.d 11 sections of Appendix B to 10 CFR 50. This
was identi'fied in February 1986, but WESTERMAN downgraded this
violation to an unresolved item This was subsequently documented in !
PHILLIPS" Inspection Report 86-08/06 with two other violations
(concerning TUGCD and BbR f ailure to take corrective action) whi ch
were dropped. PHILLIPS was told he could not follow up on his own
findings in 84-32/11 as this responsibility had been given to H4LE.
This is most unusual . Littl e or no coordination with PHILLIPS has
;
occurred on the closure of his findings.
Inspection Specific Action Plan VII.a.4 (Exhibit 28, pages 5, 6, 7, 8,
and 9) and Results Report VII.a.4 (Exhibit 29) are TUGCO's answers to
E
_________m_ _ _ _ _ _ _ _ _ _ _
. _ _ _ _ _ _ _ _ _ _ .
37
audit program deficiencies; however, they do not specifically address
'
the MAC audit deficiencies and B&il audit program deficiencies. That
is the reason that TUGCO should be cited f or f ailure to take
corrective action.
TUGCO has never specifically responded to these violations and
PHILLIPS 1s concerned that Unit 2 will be almost complete before they
respond and by that time there will be nothing to correct.
,
PHILLIPS l
contends that corrective action has not been taken by TUGCO and BLR
concerns ng deficiencies in the site and its programs. The management l
l
of the RIV GPTG has not required prompt corrective steps of TUGCO, !
. !
especially with respect to the finding.in 64-32/11 and previous NRC
inspection / consul tant findings. Although the above events happened
5
outside the specific inspection per2od of Concern No. 3, such '
inf ormation shows the cantinued pattern of dropping violations and
disregard +or QA.
Pcgpfc Handlino: The inspection and documentation was properly '
handled while directed by HUNNICUTT, and CUMMINGS. PHILLIPS'
involvement was secondary as he only provided with background
information relative to Inspection Report 85-07/05 and guidance on the
requirements of IE IP 50051, 50053, 50055, (Exhibit 10) which cover l
I '
inspection of reactor vessel procedures, work installation, and
records od all acti vi ti es. Exhibit 10 (50055 page II-1) shows the IE
requirement to inspect audits (quality control inspections) performed
during various reactor vessel activities. f
1
1
:
-
)
)
i
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38 t
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under HUlJNICUTT's supervi sion, proceeded to inspect in
accordance with Exhibit 10 and documented hi s findings. found that reactor vessel installation (and no other audit of any activity
I
was offered) had not been audited by TUGCO and no surveillance were offered to show that something was done. At the exit interview, the ! NRC inspector, with and HUNNICUTT's concurrence, identified this f ailure to audit as .a violation. Three senior TUGCO managers 1
1
(MERRITT, HALSTEAD, and WELCH) were at the exit and acknowledged this i
I
finding. They offered no disgussicn or disagreement. As previously discussed in Concern No. 1, the report (Exhibit 11) was processed for
a
inspectors final signature. The handling was proper to this p'oint.
.
Mishandling: As discussed in Concern No. 1. The mishandling, again,
l
occurred because of attitudes described in Exhibit 12.b. The handling
.
was proper until WESTERMAN became involved and stated that this was no violation because Criterion XVIII of Appendix B of 10 CFR 50, FSAR
t
Section 17.1, and ANSI N45.2.12 requirements do not Fpecif2cally require that the audit activities concerning the reactor vessel acti vi ti es.
l
l
PHILLIPS disagreed with this narrow interpretation of the regulations because NRC regulations require the audit of many things that are not specifically called by name in (E: hibi t 1, 17, 18, and 19) regulations and requirements. This type of 111ogical reasoning cannot be applied - to auditing as it would allow TUGCO the option of choosing to audit
I
the residual heat removal system but not the safety injection system,
)
l
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4
_A
, _ .__ ___ -
79
- .
or worse,. if carried to further extreme:s as the audit requirements do
not specifically name the NSSS systems.
_
-PHILLIPS further contended, with no success, that the narrow logic
that TUGCO does not have to audit the reactor vessel activities 2s
unsaund because it ignores: (1) previous NRC findings and problems
experienced with Unit i and Unit 2 reactor vessel, (2) Contention 5,
and ( 3:) NRC and ANSI standard requirements. The login was also
uncound because it also reasons that a component does not have to be
audited because NRC regulations and ANSI standards do not specifically y
(
name components to be audited. ,
l
Appendix B, Critorion XVII (Enhibit 1) states that all aggects of the j
OA program shall be audited to determine compliance and effectiveness.
PHILLIPS concluded that all aspects also includes important components
such as the reactor vessel.
The FSAR list of qua12ty items (Exhibit 31) lists four major NSSS
component
a.e., without at least discussing in the NRC t'ransmittal letter that
this f ollow-up inspection was done in the August through September
1985 inspection period.
!
In WESTERMAN's statement, he stated that he consulted BARNES on
l
ASME III, Division 1, who is a Code expert (Exhibit 40.a). l
1
-
!
l
BARNES stated on pages 10-13 of OIA, Attachment "J", that was
-
in error (Exhibit 40.b, page 11). WESTERMAN advised PHILLIPS of
BARNES ccnclusion. It is not clear but based on WESTERMAN's )
I
stetements, it appears that NRC management challenged the finding and
]
discussed it with TUGCO prior to discussing it with NORMAN or
PHILLIPS. Accordingly, PHILLIPS, who does not consider himself a Code
expert, reli ed on BARNES experti se.
PHILLIPS did not perf orm a more detailed review of this matter because )
1
.ldlllll(underpressure, agreed that the material could probably be
a
i
traced and dropped the violation. He did not agree with BARNES' l
l
interpretation because BARNES was consi dering the issue from the I
!
standpoint of a spool piece manufat ured at a vendor when in fact, it l
was f abricated f rom bulk material on-site. )
i
l
l
l
1
- _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __ _ _ _
{
*
49
In preparing Comments on Attachment MM and Concern No. 4, PHILLIPS
perf ormed a more detailed review and it appears that B&R failed to
follow their marking and identification instructions on pages 6-8 of
D&R Procedure OI-DAF-11.1-26, Revi si on 18, and earlier revisions
(Exhibit 37). The subject spool piece was cut from bulk and this
requires the application of the heat number, ASTM /ASME type and grade,
schedule / wall thickness, spool number, drawing number, and piece
number. This ASME procedural requirement is identical to ,
original finding, however, it appears that because' was
pressured, he erroneously agreed to downgrade the violation as the
final report states that only the spool piece number and drawing
i
number were applied. i
l
l
'
PHILLIPS, although not a " Code Expert," pursued this matter further
when theprocedureagreedwithl technical opinion. A B&R
staff engineer was contacted and was presented withl
interpretation that NA3766.6 of ASME, Section III, 1974 Edition,
Summer Addenda versus BARNES' interpretation. The B&R construction
engineer independently researched the Code and stated that NA3766.6
applied. It appears that BARNLS' interpretation is not onl y dif f erent
f rort but also different from PHILLIPS and a D&R staff engineer
with Code responsibility.
BARNES' statements on pages 2 and 3, DIA Attachment J (Exhibit 40.b),
indicates that his enperience has been almost solely manufacturing
prior to coming to the NRC and his enperience as a vendor inspector
-
.. _ _
. _
50
This mav
did not include nuclear power plant construction e:;perience.
be the reason ne interpreted the Code from that perspective.
Exhibit 40.a, page 112 and 113 gives the impression that WESTERMAN may
have lost his objectivity because of hearsay.and. in turn, doubted
PHILLIPS objectivity concerning this report which he was not
originally responsible f or. It appears that the follow-up on
Code items and this specific issue may have become suspect for the
"Mr.
came reason, discussed on pages 148-158. He also states, that
has an enormous hard head." Next, 1UGCO accepts findings (on
pages 154 and 155) but on pages 155 and 156 WESTERMAN states he felt
*
.
it necessary to defend TUGCO, speak for them, and reinspect to show
compliance.
Saf ety_Si oni fi cance: The safety significance appears to be that TUSCO
does not have the abilitytoshowgdl kthat a single spool piece is
marked for about three months. It also appears that they think they
are in compliance; however, the marking on the spool piece does not
l
l
conform with the procedural requirements.
It is also very significant that an inspector was pressured into l
dropping what appears to be a valid violation. The OIA report
documents that t'nere is a persuasive of philosophy of handling I
vi ol at i ons inf ormally or as unresp1ved items (pages 29, 30, 32, 35,
36 and 37 of the OIA report). When inspectors feel pressured and
i
the safety
herassed and stop reporting conditions adverse to quality, l
)
!
- _
- _ _ _ - - _ _ _ . _ __ _ . _ _ _ _ - _ _ _ - _ _ - _ _ _ _ _ . _ _ . - -_ - _ _ _ _
51
< significance is great but cannot be measured because it is an unknown.
" organi:ational
That is the reason NRC must have the same . . .
freedom to identify quality problems; to initiate, recommend or
provide solutions; and to verify implementation of solutions . . . ."
as described for Utility personnel in Criterion 1 of "Organi:ation" of
Appendix B to 10 CFR 50. A regulator should understand this concept
better than anyone.
[pncern No. 5
PHILLIPS was concerned that RIV management did not require TUGCO to
respond in writing the violation concerning concrete mixer blades.
The following is Item 2.c. of the Notice of Vi ol ati on in the final
report:
"c. Brown & Root Procedure 35-1195-CCP-lo, Revi si on 5, dated
December 4, 1978, requires that central and truck mixer blades be
l
c hec leed quarterly to assure that mixer blade wear does not exceed
a loss of 107. of original blade height.
" Contrary to the above, on May 31, 1985, the NRC inspector
determined that there was no ob.1ective evidence (records) that
the mixing bl ades had been inspected quarterly since the trucks
were placed in service in 1977. (445/8507-04; 446/85-02)"
_ __ - -__ - --_
- _ - _ _ - _ - - -
52
The following is the required response in the original draft report:
'"During this inspection, at was found that certain of your acti vi t t e's
were in violation of NRC requirements. Consequently, you are required
to respond to this violation, in writing, in accordance with the
provision of Section 2.201 of the NRC's " Rules of Practice," Part 2,
Ti tle 10, Code of Federal Regulations. Your response should be based
on the specifics contained in the Notice of Violation enclosed with.
L '
thi s l etter. " *
l
The following (paragraphs 3 and 4 from NRC 1etter of transmittal,
,
dated February 3, 1985) show that the requirement to respond to the
viol ation was dropped.
"During this inspection, it was found that certain of your acti vi ti es
were in violation of NRC requiromants. Consequently, you are required
to respond to this violation, in writing, in accordance with the
provision of Section 2.201 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regul ati ons. Your response should be based
on the specifics contained in the Notice of Violation enclosed with
this letter. Since B&R Procedure 35-1295-CCP-10 has been revised to
provide documented inspection of truck mixer blades, there was no !
abnormal blade wear identified as a result of blade inspection, and
there have been consistent concrete strength and uniformity tests, no
reply to vi ol ation 2.c i s required.
- - - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
,
-- -
j
53
" Pursuant to the provisiens of 10 CFF( 2.201, 1exas Utalities Electr1c
Company is hereby required to submit to this of fice within 30 days of
the date of the letter transmitting this Notice, a written statement
or explanation in reply, including for each violations (2) the reason
f or the violations if admitted, (2) the corrective steps which have .;
been taken and the results achieved, (3) the corrective steps which
will be taken to avoid further violations, and (4) the date when full
complianco will be achieved. Where good cause is shown, consideration
will be given to extending the response time."
The details of this inspection are describecj in Exhibit 11-13.
.
\
PHILLIPS' Understanding of Coneer %t fo d
.
Reovi rement s: Ths requirements are described in the Notice of
Violation quoted above and in Exhibits 11-13.
Noncomnl i anc e: The noncompliance is also edequately described in
Exhibits 11-13.
PHILLIPS' Understanding _qf Handl i no /Mi shend) i no of Concern No. 5
Proner handlino Similar to Concern No. 1 and iour other concerns,
the findings were being properly handled by and HUNNICUTT.
'
vietation reqmi,ed a response to this
g 1 tter aee Not1ce o4
i
L --- - - - - - - _ - - - -
.
---_ _ __- - - _ _ __ _ _ _ _ _ _ ___ __ _
_ _ _ _ _ . - . _ - - - _ - - _ -- -_ -__
54
violation. PHILLIPS probably should have made this violation a Level
IV vi ol ation; however, TUGCO was given the benefit of this doubt.
Mishandlinqi The' mishandling occurred when BARNES and WESTERMAN came
to site and .got involved. WESTERMAN informed PHILLIPS that TUCC0
would not be required to respond. PHILLIPS disagreed and never )
I
subsequently agreed with this position because of the iall owing : J
l
t
i
. PHILLIPS only inspected the blades of one o' three trucks f or j
l
wear. Since no response was required, TUGCO does not have to j
look at the other twc trucks and inform the NRC of their
condition.
. .PHILLIPS ste.ted that an inspection requirement existed for
quarterly inspection of the blades for 10 years but there was no
l
evidence the inspections had been conducteo. This alone merits a
response, as no evident technical problem does not justify j
dropping OA corrective action.
I
1
j
l
.
PHILLIPS also stated that a required response often causes the l
)
utility to find the cause and sometimes it applies to other
inspection areas or procedures. Therefore, a response may have
caused the quality assurance organs ation to review other
inspection procedures to determine if inspection were being
accomplished as required and documented.
4
- - - - - - - . - - - - _ _ . - . . . . - . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _
_. - - _ _ _ - _ _ _ - _ _
-
)
-1
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- 55
% . WESTERMAN again gave the impression that he was protecting TUGCO )
f rom . unreasonable demands by i nspectors. 1
l
I
.pafety significance
i1
The technical significance of this violation as it specificell'<
relates to concrete mixer bladen at one trucx and admquate concrete is
qui te low technically; however, PHILLIPS ntates that the safet'/
significance may be low with respect to imomsCected trucks used and
concrete m2 xed during concr ete placement activi ties. To say it has
none would require the NRC inspector to inspect all trucks.
Obvi ousl y, a single NRC inspector cannot, and should not, be ex'pected
to inspect three trucks under the circumstances; i.e., once the
vi ol ati on is established, it is TUGCo's responsibility.
InnSection Renort 50-445/85-14: 50-446/85-11 (G5-14/11)
Contrarn No. 1. 2. and 3
PHILLIPS and YOUNG were concerned that RIV management not only
downgraded violations concerning the shipment of sole copies of design 1
records to Stone and Webster Engineering Corporation (SWEC) in New
York and several other branch offices in different states but also
dropped these findings from the report.
!
, - - -._ - ____ _ - - _ _ - - - . - - - - _ - - _ - - - - _ - _ - _ _-_ . _ - - - - - _ - . - - - - - . --. --_ -__ - _ -_ _
'
; s
,
-
,
,. .
.
f :'.
,
,
56
!
,
01AfRepert, Attachment MM, (Exhibit 41.a, page.9) adequately describes
_
. the. issues.
,;
.
The violations in Exhibit - 42.a were to be written as one violation of
" Criterion . XVII 1 violation wi th multiple examplus. The one onception
Lwas Criterion V violations; i. e., TUGCO's f ailure to have procedures
,
in plac? to control the shipment of design records. Pages 1-4 of
' '
.
Exhibit 42.a-(original draft report, paragraphs 5.a-b. in~the Details
n
Section) ' cover these ; issues; - however, one concern-was.not addressed i,n
' Attachment MM; i,e., the. failure to incorporate 10 CFR 50, Appendix B,
: requirements and commitments into-the highest GA manuals-by reference
or by describing such requirements in the contents. Exhibit 42.b,
-pages 67 and.68 of'the second draft, dated December 3, 1986, shows
that violations were downgraded and much of the text was also' dropped
from the final report.
PHil. LIPS Under st andi no of Concern Nos. 1. 2. and 3
Requirements; The requirements are described in Exhibit 1, 43, 44,
and.45, and include appropriate portions of 10 CFR 50, Appendix B;
FSAR Section 17.1; ANSI N45.2.9; and TUGCO OAP.
)
1
____ a
--- _
57
Noncompliance with Regpirements/ Commitments: The following discusses
the original noncompliance which are described in Exhibit 41.a.
"o TUGCO' failed to have/use procedures to control shipment of
original records to SWEC." .
This finding was dropped from the report. This' finding is so
important that it may be the cause of all of the noncompliance
concerning records described in the inspection report 85-14/11.
Accordingly, the most important aspect of the proposed violation was
lost and, of course, TUGCO does not have to, address the cc,rrection or
cause if it is not in too final Notice of Violation.
Criterion XVII, Exhibit 4, states that the Applicant shall establish
requirements for record retention.
FSAR 17.1.17, Exhibit 43, requires procedures which will establish a
1
04 records system to include all of the elements to control, account
for, and protect against deterioration and damage.
FSAR.1A(b)-36 (Exhibit 44.b) commits to implement the requirements in
accordance with ANSI N452.9. Paragraphs 5, 5.3, and 7 (Enhibit 44.a;
require that procedures to include a description of the storage area
(or areas). This would include permanent and nonpermanent storagc
areas. Specia) processed records; such as, radiographs, photographs,
negatives, and microfilm are required to be stored in an area to
* _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
- _ - _ _ _ _ - . _ _ _ _ . _ _ _ _ ._ _ _. _ _ _ __ -. ..
58
preserve them. Section 6. Retrieval, states that the system shall
provade for the accurate retrieval of i nf ormati on wi thout undue del ay.
Section'7 der,cribes the requirement to assure the accumulation and
transfer of records.
" Comanche Peak Steam Electric Station QA Pl an. " (Enhibit 45) does not
fully comply with Enhibit 1, 43, and 44. as it does not specifically
include and address all the requirements of the higher tier document
as they apply to the site as follows:
. The detini tion of a DA record (Enhibit 44.a, page 11).
,
. Location of all permanent and temporary storage areas
(Exhibits 43 and 44.a).
. . Specific on-site organizations responsible f or permanent and ,
temporary records storage; e.g., TUGCO vs Chicago Bridge & leon,
Bahnson, Westinghouse Service Division (W). etc. and interfaces
requirements and agreements when records are to be transferred
between-c ganizations (Enhibit 43 and 44.a). j
. The defini tt on of Lifetime / Nonpermanent DA records to cl assif y 1
records, as required (Enhibit 43 and 44.c).
)
. Requirement to inden (Enhibit 43 and 44.a). )
!
.
__-- - - _ _ _ ____--__-__-_-_U
______ _ ___
59
. Retention requirements (Enhibit 43 and 44.a). . Receip.t of records (Enhibit 43 and 44.a). . Retrieval (Exhibit 43 and 44.a). . Accumulation and transfer of records (Exhibit 43 and 44.a). . Instead of the CPSES DA Plan, Section 17.2, in establishing the
requirements, it states, "Quali ty Control documents are
initialed, collected, and maintained in accordance with approved
procedures," and infers that the lower tier documents set the
requirements. This procedure is also improper because it only
addresses DC procedures and should be addressing DA procedures.
It defers responsibility for defining records to the organization
implementing procedures. The responsibill* tar record systems
is also described in the lower tier procedures. This
organizational approach to control of records has caused estreme
problems.
"o Original design records shipped in cardboard boxes without making
backup copy."
This finding was dropped from the report; however, it is an importent part of the originally proposed violation. Criterion XVII of
_ _ _ _ _ _ _ _ _ _ _ _ -
____
l
bO
l-
Appendix B requires a description of record retention and that
includes assigned responsibility, location, and duration (Exhibit 1).
Exhibit 43 gets more specific and states: (1) procedures shall 1
describe responsibility, (2) that records will be protected against
damege and deterioration, and (3) the method of transfer between
organizations.
Enhibit 44.a describas in even greater detail how to meet the
10 CFR 50, Appendix B, Criterion XVII requirement. Although no
document is ever totally prescriptive enough to cover absolutely
everything, this ANSI document is sufficiently prescriptive
descriptive to tell a new applicant (TUGCO) how records should be
controlled. When construction first begins, each app'icant'is
required to protect and preserve the first piece of paper down to the
last piece of paper that is defined as a OA record of saf ety-rel ated
ac t i vi t i es. ANSI defines what a OA record is. Paragraph 5.4(1)
requires that records be kept in a permanent facility in standard
steel cabinets or, if this is not practical, keep them in fire
resistant cabinets (1-hour rating) or an alternative i s to kor.p
duplicate records stored in a separate, remote location.
This logic does not change when all design activities are completed.
The requirement to afford permanent or temporary protection f or design
i'
of ploing records became more important at this point. The precedent
f
for an NRC inspector has been to write violations on a f ew important
.
ba__
.. . - _ _ _ _ _ _ _ - _ - - _ _ _ _ _ _ - - _ _ - _ _ _ _
61
records not given this minimum protection during construction and this
is a well established fact. Regardless, paragraph D.3(6) states that
a method of control and accountability must be established by
procedure. Control includes preserving bul k design records during
movement from point A to point B. This can be done two ways:
(1) transfer the records in fire rated cabinets, boxes, or wrap with
fire resistant material; or'(2) retain a dup 1'icate copy.
TUGCO neither accounted for the records (i nventory) nor assured that
the method of transfer was appropriate. Instead, TUGCO informed the ]
NRC that: (1) it was too expensive and time consuming to duplicate the
records or send them in fire resistant cabinet or otherwise, and
(2) they had the right to proceed at their own risk. The last
statement appears to disregard the regulatory requirements in favor of
cost and schedule.
"o Failure to control and account for QA/ design records transferred
from site to SWEC."
This was a concern but not because the propoced violation was dropped.
The concern here was that the details were severely edited and this
left out the magnitude of the problem and the stated reason for the
violation; i.e., TUGCO's policy was to proceed at risk because of I
schedule and did not duplicate or ship the records in fire resistant
cabinets because of cost. This policy was also stated to NRC oy
various cornorate QA and site managers when the CB&I issue arose.
1
l
.
, --_-___-___ - -
.
62
l PHILLIPS' Understanding of Ni sh an d i '. no :
YOUNG identified the violations described in Exhibit 42.a. While the
inspection was still in progress, WESTERMAN became aware of these
violations and the inspector was unable to complete the inspection
before pressure was being applied to not consider these as violations.
WESTERMAN stated that TUGCO could proceed at risk and do what they
wanted to do with these old records because the records became
in-process documents when removed from the QA records vault and no
.
'
-
longer have to be protected in accordance with Criterion XV11 Records
of Appendix B to 10 CFR 50 and ANSI N45.2.9., An additional reason was
*
i
otated to be the f act that once the engineering reanalysis is
completed they will bc no longer' be needed and the new analysis is all
that is importent.
PHILLIPS and YOUNG, hhving many years of construction experience
on-site, did not agree these illogical arguments. Toward the end of
the month, WESTERMAN stated he would agree that TUGCO's failure to l
have and implement accountability and inventory controls was a
violation but, after much pressure and badgering, directed that all
the other items be dropped.
WESTERMAN mishandled these issues because he dropped valid violations !
i
and important datails from the body of the repert. Also, his I
techni que described in tatement was to harass, pressure, and
,
badger tne NRC consultant and Senior Resident into submission. He
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ _ .
._ _ -__. - - _ - _ - __--
63 '
spent so much time doing this he actually disrupted several
inspections. So much of PHILLIPS' time was used that he experienced
'
difficulty in getting his other work done and in providing guidance to
three other personnel who worked for him at that time.
Safety Significance:
l
The safety significance is that TUGCO has completed Unit i but has not
fully described DA record requirements in TUGCO OAP, Section 17.0,
The significance of shipping all of the piprng design records to SWEC,
New York, and various offices is that TUGCO risked the loss of all
these design records because of cost and schedule.
The significance of shipping all records without a specific inventory
and a method of accountability ( i . e. , how many records were sent from
site and how many records did SWEC receive and the reverse process to
return to site) results in not knowing if all records were reces ved by
SWEC and all were returned to site.
i
The significance of dropping the issues f rom the report is that TUGCO
was not f ormall y required to address these issues that appear to be
generic. l
l l 1 i
The significance of WESTERMAN's application of pressure and badgering inspectors caused insi.ectors to drop important findings. Perhaps the
l '
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l ,
_- _ _
64
NRC will never know how many issues were never brought up by
inspectors on this and other projects. Differing professional
opini ons do not come abcut in this type environment.
Concern No. 4 ard Np O .
PHILLIPS was concerned that RIV management downgraded two of
\
violations concerning TUCCO's failure to assure that CBLI records
were not afforded temporary storage protection in
(genprated on-site)
transit to Houston, Texas, and these records were not inventoried and
accounted for prior to leaving site and after their return to the
site.
Exhibit 46, pages 11 and 12 of Attachment MM to OIA Report, describes
this cent n in more detail.
Enhibit 42.a, pages 2, 3, and 4, of the original draft report
describes violations as originally written in the body of the
i
report. One was downgraded in the body of the next draft report I
(Enhibit 42.b, pages 68-70) and the other was subsequently downgraded
before the final report was issued.
The final inspection report (Enhibit 42.c) was issued March 6, 1986,
and was watered down to the point that it has little resemblance to
the original findings.
l WL_________
_
4
.
65
PHILLIPS' Understanding of Concerns No. 4 and No. 5
Requirements: Exhibits 1, 43, 44, and 45 which applied to Concern
No. 1, 2, and 3, also apply to Concern No. 4 and 5.
Noncompliance with Raouirements/ Commitments: identified one
violation with examples; i.e., failure to assure pro'per control,
inventory, and transfer of records between organi:ations as required
by the above exhibits. These examples were simply to be added
examples under one Criterion XVII vi ol ati on (i . e. , in addition to the
SWEC examples, et al). Specifically, the requirements of
Criterion XVII of Appendix B to 10 CFR 50 as described in
Subsection 17.1.17 were violated as follows:
i
"o This f ailure to transmit records in accordance with a procedure
and afford protection in transit equal to temporary storage
requirements are additional examples of violation identified in
paragraph above."
(
!
I
i
Exhibit i requires that the applicant establish requirements l
I
concern _ng record retention. The other words (assigned responsibility j
I
and location) mean a description from top to bottom of the handling of j
records. Location, not only means static, but also means dynamic or
movement. kfound no such control in place and TUGCO did not
- state that they had implemented such control. Since CB&.I had left
site,ll h(wasforced to accept TUGCO's statement regarding what
I
*
t - . _ _
i
.
66
happened.
Analternativewouldhavebeenforl to travel to
CB&I, Houston, or their coming to the site but it is doubtful that all
personnel involved were at CB&I, Houston, Texas.
It should be noted
thatlll (waswell aware,that a CBLI procedure
existed; however, his review of their procedur's showed that CB&I had
the option to send records in cardboard boxes or by the mail. None of
these measures assured protection in route commensurate with
FSAR 17.1.17 requirements (i . e. , protect from damage or
deterioration). The final report erroneously shifts the emphasis from
TUGCO to a CB&I procedure; however, TUGCO at no time showed that they
or CBLI used prudence in shipping these irreplaceable records.
"o The failure to maintain control and provide accountability of
records removed from storage is another example of the deviation
identified in paragraph above."
'
l
This should have been a violation as it also violates the
Critorion XVII concerning responsibility and location.
CPSES QAP 17.0 (Exhibit 45), is a shallow procedure and requirements
such as method of transfer between remote locations and inventory are
not specifically addressed. This allows lower tier organizations
on-site to establish requirements and this is not proper.
\
.
4 s
_ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _
l
I
67 !
l
.
PHILLIPS' Understanding of the Mishandling of Concern No. 4 and No. 5
PHILLIPS incorporated findings in the report. In this case,
WESTERMAN concentrated the pressure on PHILLIPS to remove the-
i
violation from.the report and finally directed that it be removed when
'
PHILLIPS would not agree with WESTERMAN's logic that site generated
containment liner and other records belonged to CD&I instead of TUGCO. j
i
TUGCO, in WESTERMAN's presence, else maintained that important and
irreplaceable site records; such as, containment liner, structural
steel restraints, tanks, etc., belonged to CB&I and they were free to
control them as they pleased. In reply to F,'HILLIPS' question of such
'
records being destroyed in transit, senior TUGCO management stated
that it was.3 TUGCO policy and they could proceed at their own risk.
If no requirements existed, it would not be prudent'for WESTERMAN to
endorse such a policy.
When WESTERMAN found that PHILLIPS would not agree, he' directed that
the violation be dropped from the report and write a letter to
Headquart ers to resolve the dif f erence in technical op2nion. PHILLIPS
wrote this letter which discussed the differences and forwarded it to
WESTERMAN. According to the OIA report, this letter "l angui shed" in
ERIC JOHNSON's office. This type treatment of inspector's safety
issues is devastating and has profound safety significance from a
regulatory standpoint.
I
_ _ - - _ _ _ _ _ _ _ _
- _ _ _ _ - _ _ _ _ _ - _ _ _
1
68
WESTERMAN made no further effort to follow Concerns No. 4 and S until j
l
after tne OIA investigation started. In desperation, WESTERMAN I
J
apparently had a number of people working on the concerns and other j
85-07-05 matters in this report and other reports to aid him during
]
the interview process. PHILLIPS was never advised of this additional
work; however, in the various OIA statements it is apparent that such
work was done. It was probably done between WESTERMAN's first
interviews on July 11 and July 20, 1986, the day before the last
interview. For example, WESTERMAN states that CB&I transferred the
records to Houston, Texas, in fire resistant cabinets and this
;
information is not even in TUGCOs file. PHILLIPS has followed up on
this information with TUGCO but they have never stated this to be the
case even as l ate as December 1986.
Sefetv Significance: It is safety significance that TUGCO has not
shown to date (and will probably be un3ble to) that every record that
lef t site was returned. This is significant from a quality assurance
and a hardware standpoint because records prove the quality of the
reactor liner and other hardware. This does not even consider the
l
Unit 1 records transfer. NRC follow-up inspection is incomplete and
the full significance is unknown.
TUGCO has stated that the records have been returned; however, it is
safety significant that such irreplaceable records were transferred in
!
accordance with a CBLI procedure that does not require that a
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- duplicate copies be retained at site or shipped in fire resistant
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containers. Their stated policy allows them to continue the practice as TUGCO says it is at their own risk.
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The f act that'NRC managers downgrade or drop safety concerns and do not forward letters containing differing technical opinions is very significant when it is the NRC regulations that help protect the health and safety of the public. Pressure and harassment of inspectors also add a dark cicud instead of professionally resolving the issues. This is highly significant because of the need for
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freedom to identify problems and see that solutions solve conditions adverse to quality ir.cluding the control of, records of hardware
- acceptability.
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Concern No. 6
PHILLIPS was concerned that management dropped YOUNG's violation
concerning failure to afford protection of records removed from the QA
vault and placed in nonfire-rated cabinets located in trailers at
multiple field locations.
Exhibit 47, pages 13 and 14 of Attachment MM to the OIA Report,
describes Concern No. 6.
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Exhibit 42.a, pages 4-5 of the original draft i nspecti on repor't ,
describes the violation which was originally written. In acccrdance
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with IE guidance-(MC 0610), this was to be an enample of the one
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Critorion XVII vi ol ati on proposed.
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Enhibit 42.b,.pages 76-77 of thu second draft inspection report, dated December 12, 1985, was rewritten to address more information to l convince RIV management that this was a violation. Exhibit 42.c, page 13 of the final Inspection Report 85-14/11. PHILLIPS' Understanding of Concern No. 6
.
Requirements (Exhibit 1, Criterion XVII; Exhibit 43, 44, and 45) which applied to Concerns No. 1, 2, and 3, also apply to this concern. Noncompliance: The failure to protect GA records removal from the QA vault to facilitate work in process is a violation of Criterion XVII regulatory requirements; however, it may altei natively be considered a deviation from Exhibit 44.a. All of the references require the protection of DA records f rom damage and deteriorate on.
.
PHILLIPS' Understendinc of the Handlina/ Mishandling of Concern No. 6 Prcuer Handlinq: YOUNG f ound that TUGCO had removed large quantities of QA records from the QA vault in order for construction personnel to be able to review previ ous work and facilitate new work. The records
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were moved to several different locations on-site that would be j
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convenient for construction. Both PHILLIPS and YOUNG considered this
move to expedite work a good work practices however, both became
concerned when it was learned that the completed original-QA records
removed from the QA vault were stored, in some cases, in regular file
cabinets in trailers without maintaining a backup copy.
YOUNG and PHILLIPS challenged this practice and asked why this was
done. The first answer was that it was too expensive to purchase
fire-rated cabinets. Further, review of this mat ter revealed that the y
definition of a record in their commitment (Exhibit 44.a, page 11) had
been ignored by TUGCO and they replaced this definition with their own
definition (Exhibit 48). TUGCO created a definition to fit the
l practice instead of fitting the practice to the ANSI N45.2-9
definition which states, in part, " Quality Assurance Records. Those
records which furrish documentary evidence of the quality of items and
of activities affecting quality, For the (,urposes of this standard a
document is considered a quali ty assurance record when the document
has been completed."
The practice was to take a multitude of c trmp l e t ed documents, that had
already been classified as 04 records and were in the vault, mix them
with incompl ete documents where work was still in progress, place a ,
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work traveler on top of the package, and ca?.1 this mixture
"in-process" dccuments. j
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LYOUNG's finding was presented at the exit as a violation by PHILLIPS.
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MERRITT,. Senior TUGCO-Manager, asked for clarification and discussion. q
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PHILLIPS' explained again and a BLR manager at the meeting statea that
1
it wouldLbe too costly to= store these QA records in' fire resistant ]
. cabinets. J
l Mi stiandl i na : At the exit, WESTERMAN apparently agreed with the cost
1
statement. He later told PHILLIPS there was no requirement to protect
QA records (completed documents) removal from the vault because they
became in process documents. PHILLIPS and YOUNG agreed that DA
records could be removed f rom the file to f acilitate work but that
TUGCD-is required to.give the OA records mixed'with the in-process
document temporary protection at the end of the work day c3 required
by ANSI.N45.2.9.
WESTERMAN' applied pressure to drop this finding altogether because he
said'the NRC ischnical Review Team (TRT) had found the practice
acceptable and so documented it in SSER lit however, the OIA report
also pointed cut that SSER 11 also indicated they were in fire
resi stent ebbinets.
' HALE concurred with WESTERMAN's definition of in process documents,
however, HALE only gave his opinion and no supporting documentation.
HALE gave no precedent because he has little construction experience
as he worked in NRC Vendor Branch until 1954. PHILLIPS and YOUNG have
construction experience and have observed many licensee's and
.
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73
applicant's practice;, sa ross the United States. This is the first
ti me t hey encountered a utility that does not undtrstand this
requirement to protect records. It is also the first time to
encounter NRC inspectors who do not understand this requirement.
PHILLIPS was directed to drop this violation.
WESTERMAN met with TUGCO management without PHILLIPS being present and
later informed PHILLIPS they did not consider it a requirement to
protect these records but would buy the fire-rated cabinets to protect
these records. Subsequent to this, other TlJGCO managers (OA) stated,
at different times during the last year, that they would nut be placr
into the appropriate cabinets.
PHILLIPS lact conversation with the TUGCO QA Director on December 15,
1986, revealed that they would not revise their procedure to require
any such practice but they will do it only because it is prudent.
PHILLIPS replied that this is not acceptable because they will not
admit it is a requirement and/or a comnitment and if they store for
prudency only the NRC has no reason to inspect the OA records so l
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stored. j
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Safety Si oni fi cance: The significance of this concern has diminished ]
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somewhat because TUGCO says the QA records are now stored in
fire-rated cabinets; however, the NRC cannot be assured that the l
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records will continue to be stored in this enanner because TUGCO
refuses to consider this a requirement.
Insoection Roonrt 50-445/85-16: 50-446/85-13 (85-16/13)
Concerns No. 1. 2. and 3
PHILLIPS was concerned that RIV downgraded a series of potential
violations to unresolved items involving TUGCO's system for
controlling 50.55(e) documentation. According to the draft inspection
repc-t, these potential violations included the following: ,
"o TUGCO failed to develop / implement a procedure to show or
reference objective evidence that deficiencies were corrected.
"o TUGCO f ailed to revise implementing procedures before corporate
NEO Procedure CS-1 was implemented, resulting in conflict with
five other procedures.
"o TUGCO failed to maintain 50.5D(e) files (OA records) that were
retrievalbe, i.e., could not produce record in almost a month."
)
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Exhibit 9, page 14-16 of OIA Report, Attachment MM, adequately J
describes these specific issucs. 1
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Exhibit 50, original rough draft report completed December 20, 1985,
pages 3-1 through 3-6, shows these vi ol at i ons as originally written.
This rough draft was handed to WESTERMAN before typing 'and editing to
allow JOHNSON and WESTERMAN to prepare tor a meeting on the subject
PHILLIPS had told WESTERMAN about difficulties experienced since
October 1985. The proposed violations would have resulted in the
fol?owing: (1) a violation of Criterion V, " Procedures," with two
examples; (2) a violation of Criterion XVII, "QA Records"; and (3) a
10 CFR 50.55(e) violation, " Failure to Report Corrective Action."
The final report issued August 16, 1986 (Exhibit 5), dropped all the
proposed violations and inserted an unresolved item based on
discussions between WESTERMAN and TUGCO in which PHILLIPS Was not
involved. WESTERMAN later informed PHILLIPS of commitments made by
TUGCO to form a Task Force.
PMJLLIPS' Understanding of Concern No. 1. 2. and 3
Requirements: The requirements are described in Exhibits 1, 14, 15,
16, 44.a, and 52 which include 10 CFR 50.55(e); 10 CFR 50, Appendix B,
Criteria V and XVII; and the TUGCO FSAR, TUGCO DA Plan.
Gu i d an c_e : The NRC had provided TUGCO with 10 CFR 50. 55 (e) guidance
which is in the back of the IE Manual Chapters (Exhibit 1.2.2). This
is guidance to the NRC inspectors concerning the applicability of
Appendin B Criteria. Contrary to statements made by WESTERMAN, this
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IE interpretation is that construction deficiency reporting comes
under applicaole Criteria of Appendix B to 10 CFR 50; i.e., as a
minimum Criterion V and XVII.
Noncomofiance.with Raouirements: The following discusses the logic
f or each violation originally proposed.
"TUGCO f ailed to develop / implement a procedure to show or
reference objective evidence that deficiencies were corrected."
This proposed violation is the most important aspect of this concern
*
as it has caused TUGCO's Construction Defici'ency Reporting (CDR)
system to be deficienct. MCCLESKEY, NRC consultant, started
~
inspecting the TUGCO CDR system in October 1985 and had made little
progress by February 1986. A large number of man hours were expended
before giving up the effort as useless at the time.
PHILLIPS and MCCLESKY (experienced in 50.55Ce] reportino)' == bed for
information to close out the 10 CFR 50.55(e) deficiencies and TUGCO
was unable to provide it. MCCLESKY was to review the individual
50.55(e) fi!es and then field verify the correction of these
deficiencies. TUGCO could not readily identify the nonconformance
report (NCR), design change authorization (DCA), or test deficiency
report (TDR) which described the deficiency. The reason they could
not readily identify these reports was that their CDR reports were so ,
bad that they did not reference the documents wnich identified the
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77
deficiency in the field or identify the corrective action document.
'Either document, if referenced in the report to the NRC, would have
allowed the inspector to pull the report from the file and identify
the proper document. This would allow the inspector to go to the 04
records vault and obtain the document from a file clerk and, after
reviewing this document, he could go directly to the field and observe
the deficient systems component or part. The document would also
prov2de identification numbers whereby the inspector could obtain
specifications and drawings from the document control office.
TUGCO could only respond to such a request by directing the inspector
to a manager, an engineer, BLR inspector, or some other person who'may
have been involved at one time. In many cases, this method led to
going from person to person to learn what they knew. The information
they provided was sometimes from memory or notes in their desk
drawers. After'a knowledgeable person was found, the search started
l for the appropriate documents. It took varying amounts of time to
identify one appropriate document out of thousands in the QA records
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vault. The person's ability to retrieve documents is also impacted by j
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other priorities and memory. f
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Once faced with this serious retrievability problem, TUGCO finally
admitted they had a problem and asked the NRC inspectors to terminate
their inspection until they could get a handle on things.
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TUGCO stated that they were writing a new Procedure (MEO CS-1) which
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'would help correct these problems. They asked DHILLIPS and MCCLESKEY l
to review the final draft and make comments. Comments were made to
.TUGCO and specifically concerned the f act that the procedure did not
adequately describe what identification and corrective action
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documents should be either ref erenced in the 50.55 (e) repc.-t to the i
NRC, or referenced in a letter to file, or otherwise cross indexed to ;
)
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or from the nonconformance or design change log. Despite these
comments, TUCCO issued the procedure without addressing how the j
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50.55(e) report referenced the NCR, DCA, or TDR, or cross indexed logs f
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to the 50.55(e) deficiency report. ,
NOTE: One muet not lose sight of the fact that this Applicant is not
just starting to construct a nuclear plant but has completed Unit 1
'
and is close to completing Unit 2. PHILLIPS and MCCLESKY had never
encountered such ineptness and they have inspected ,a l arge number
plants.
f
This failure to have adequate procedures as required by Exhibits 1, is
a violatinn of Criterien V of Appendix B to 10 CFR 50.
"TUGCO failed to revise implementing procedures before corporate
NED Procedure CS-1 was implemented, resulting in conflict with
five other procedures."
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MCCLESKY directed the above violation to PHILLTPS attention.
PHILLIPS, while writing the vi ol at 2 on, checked to verify that IUGCO
had revised the subordinate implementi ng proceduro=; bef ore issuing the
corporate procedure. Such revi ng on was important because the
corporate procedure affacted responsibilities, deportability criteria,
notification policy, and reporting instructions. This failure to
revise procedures as required by
Exhibit 54___________.___._..__._____
"llJGCO failmd to maintain % ,T5ies file- (94 records) u that were
r e t r i evrib l e , i.e., could not produce record in al most a month."
t
TUGCOs inability to retriove r u ned; t, + violation or at least a '
devietion, depending on ono' caniorcement out1000.
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Exhibit 43, page 17.1-41, st at e , that the method of identificat3cn and (
inde> 1ng of records for ease ai etr a s-vet;i l i t y wi ! ! be r u nt.tr ed by 1
proceduren t h a t. Implement thic l 3 4R r e q:.' t r emoi F . 'l li t .L I PS i nter pret s
i
t h i r- n a requirement which wa .iofated; howe,rrr, at a minamum a
commi t. ment was violated in f- hiti 5 44.a. caragraph 6..' unich states,
in part, ". . . r e t r i m. u .1 < : r. l . a rnet t on wi then ti undue dalay."
PHTl.l.1P9' understandtnq y;[ l' ,
.i . I : pd gh thpng1)n-J
P a r P.QCRthel : Prior to in1+1 o, i.vq ction ot ihe filn N
r,ch s P r 8 4c t t ui t Oc f t e t rani p P ap . , i i . *-
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80
10 CFR 50.(55e), PHILLIPS had performed a trend analysis of T UGCO' s
deficiency reporting as directed by Hunter. An adverse trend was
identified based on reviewing RIV inspection reports (over
200 violations and unresolved items). Six violations had been issued
and three unresolved items appeared to be violations instead of
.
unresolved items. Including PHILLIPS' experience et plants in
Region III and the South Tex-as Project, PHILLIPS concluded this was
the worst enforcement history he had witnessed (E::ha bi t __ , Trend
Analystr).
.
This analysis was furnished tn who planned to factor this into
the RIV Comenche Poal- Task Group (CPTG) follow-up inspection of ,
TlfGCO'r3 third party i n =pec t i ori . the Comer.che Peak Response Team
(CPRT). This was never done because WESTERMAN veplaced and he I
rejected the trend analysin and the idea of 1actoring this into the
follow-up inspection. WESTERMatt also rejected adverse trends in the i
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RIV inspection program for Unit 1 wher e it appeared thet RIV
inspectors had performed inadequate inspection: end rejected
r ei nsper-t i ons of the various MU ' " t <?-
Inspection p,ocedurus wh2ch would ;
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havo looked at 50.55(e) def2c1=nitn=, i n conj unt-ti on wi th reinspecting
the inspection procedures of N * *; 1 ? . .
WES TERMnN 2140 directed the
subject of trending be droppa1 at m inspection teper - C6 4.P/OS which
is discussed in a d i f f er er. * rec, .i ,.
In 1980 PHil.LI PS all er t ed 1 .' i.-=iir . h . 's e r 19? ' a r 's >n.1 prat)lomi
When he was at Gr su t h let as i a :v.,rrn F h:b)t 1.'.1.b, 4
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81
two memoranda; 8 pages). If these trends had been identified in 1980
or earlier, special NRC inspections could have averted what has
happened at Comanche Peak.
Proper Handlino: PHILLIPS pr'avtded MCCLEEhY w2th background materia)
and IE Procedure 92700 whicP require the inspection of TUGCO's CDR
system. As indicated in *.t s f i el d notes (Exhibit 57.a and b),
MCCLESKY experienced immediate problems while inspecting the CDR
proceduras and files. The cor rect 2 ve act3on portion of the procedure
was inadequate. Insuf I- t ci ent in+crmattan was on file to determine if
nonenportable items were proper 1y evaluated or li reportable items had ,
been corrected. In October, u of 13 files reviewed were deficient
regarding sufficient i nf orma t.1 on to verify corrective action. Twelve
additional files contained nonraportabl e def iciencies; however, of l
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three o+ these files were deficient to the point that the inspector
could not dJtermine whether or not the deftctency was reportable.
Thiis dat a was prevented t o WESTERMAN by F' tit LIff and MCCLEEKY .
Mi s h o n cilj,n g: PHILLIPS told WESTEPMnlJ thst he ha1 n o +; 1wn such a .nc 2 :5
in all his time with the NRC. PHIlLIPS had decided to thield
MCCLESkEY and keep him out af the line ai fire r9qdrding violattene,
becaure WESTERMAN had alreadv let YCUtlG' m contract e s: p i r e +cc the name
;
tea +on; t.e., writing <t71etinna. -
In this cace, LES T E PMAN cone nnt s atr1 slj the msth nn cou!d to
p r, n t . u ire , haram , and i n'. t .n t d a r - l 1111.1 li', to dtvp Fh we < t a l a t i c n .; .
.
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62
His statements suggested that PHILLIPS would be removed from the Job
because he was not a team player; i.e., would not agree to drop the
i violations. Veiled threats about- did not PHILLIPS make good money
and suggesting he would make less when removed t' rom site- started to
become serious from PHILLIPS standpoint. Such unprofessional behavtor
had never been encountered by PHILLIPS in nearly 29 years of working.
PHILL.IPS returned from three weeks leave on January 13. 1986.
PHILLIPS was conf ronted with t he drM t inspection report on which
JOHNSON had modo unprof essional c o<mrent s and rediculed PHILLIPS' draft
i r.sp ec t i on report C6-16/17., ( E .< h i b i t 58). Those comments ar e not only
,
uncalled for but al <so erroneous, i10l lNSON ' ~. statemnnt, Attachment P to
the OTA Report =: hows that he dnes not underetend quality assurance and
construction. His personal a t t.3 c L a and comments on this memo are
improper conditct for a sentor manager. In reading h2s CIA statement,
i t was evi dent he could not answer simple questions on IE MC 2512 and
DA procedures.
WES1EFMAN nid he had talked to JOHNEON about the pronIcms PH1LtIPS
was cresting for him. WESTEPMAN tal d PHILI. lFs t-h e t somethsng was
going to have to be done.
JUHNSON tems to the site and h r c :.'tm a t PH I LL I PS n .. r-r r. i i n F:ISCC
.nemnrandum PHILLIPS had writtsn. Dor 1og ihi7 ,t7i P, J OI 4H5GlJ and
T 'T ERMAN cie t 6H t h TUCCO to d19eiire thsir r. DP Watrm end Fl: It I. j Il ues
told he w,.cs niit nandad. .:re . ? , 41 7! 'lill L ll + .": mnen, l l GM + ,.M o
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commitments and went overboard. They formed a task force to develop
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huge folders on each item when a simple r ef erence in the 50.55(e) i
report list contained in the file or an indexing t'o the entsting NCR,
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DCA, etc. logs would have been sufficient. This task f orce has wori:ed
for a year and has had 5-10 people working on, it. If PHILLIPS had
been at this meeting to enpla3n, TUGCO may have elected to go the
simple and more inexpensive route.
In5;tead of being at this meeting. F HTLLIPS (with a broken rib) was
asked to give GAGLIARDO an onsite tour. Initially the purpose was
unclear as GAGLI ARDO heici barn on-site +or mpnths in 1984 ???As a
resul t , PHILLIPS'gave GAGLIAPDO a casual tour. WESTERMAN later told
PH.ILL IPS that the purpose of the tour was to test hi m f or site
knowledge and that he did not do well, JOHN 911N telephoned PHILL?PS a
couple of days later to repeet this and selv that he intentioned
PHILLIPS' construction exper3ence after reviewing his resume. All
this was to make a potnt.
At this point, PHILLIPS told LEG TFRMaN that he rernvared theFe t h i ng r4
t
as a " set up" and told WESTERMAN to tell "then' t o b ,M- L off; 1.o., he
would write this inspection report a s, RIV mancgement desired, and b r-
would ask whst they wanted t.r i t~ t o n tn the i n=Fpac t i on reporta in the
.
tuturc. PHILLIPS folJowed t h1 m ri o l s , '- ont1i Mc. , 1286 when inepect Ion
report th-OU/06 was wri iter.
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The mishandling of these items is abunduntly clear from reading
WESTERMAN's statement (Attachment D, Volume II, dated July 'a l , 1906).
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His twisted logic and lack of understanding the requirements of f
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10 CFR 50.55(e) are evidenced by the following references; however, l
Pages 348-412 must be read for a full understanding.
Eage 350: "Now it was my possation and still : s my pnsiti on that
there's no requirement in SO.55(es, or e procedure,.that having a
procedure to cover 50.55(e) is not an Appendix B requirement.
50.5S(e) is a reporting rnqui r mntn F which is placert on the untility
via the code ci requattions." ,
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Comment: This conflicts w3th ' .F. Guidance in Echihit S4. l
E4.ge_A51:
"O Ole a y . Are there prnrecturet, 1 or 1 dent t 4 ) at i nn , l
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documentation and nottt1 cotton of a f t 'c t a-1 are. A n t r at i on s --
"A Yes, sir.
!
"O .-- for nonf ont I rm i i ., i' ems
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"A YGS, ?> 1 r .
"U Lil: Av. iTI r: we T. ; i t*i..r i.,
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"A Nct -- well, wh at we"re talking sbout that fir. Phillips
wanted, was for the utility to have a status in a f i l e f or esch
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50.55(e) which he could go over to and look in that file and
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clos 2 out a 50.55(e). And I'm saying I don't know of any
requirement that would say the utility uould have to have those
in a file +or the convenience at the f.omm15,si on . Ihose recerda
are there; they are maint.alned; they are part of the permanent.
Now, 1f I"m a prudent i i c e rioec . I wi11 have t h -a t iind of a
sys t ein .
"O Did they have a m:. ton. o c.t i nr 5* . % ( e s , it's --
"A Yes, sir."
.
Comment: This is a false st at emr'nt au Pilil l. J r's nwmr asked for such a
system as he only asked that the 1,0 f- report it, IIPC : rafmtence the
nonconformance report, ref er enc + it in t hr 11]n, c.r r (a t er ence the CDR
on the NCR leg F H I LL I F 5 .,n.1 a un h i o :w. cm. pre .e on .. e this s t a t eini,n t
is t -n 1 s e .
l ) ['a o n 360: "If you went t ,, , -t n c,r it rsn t c .c be,r.e e r wir.r t s. y oi t would
' "
clearly be able to i desit ! . ..' t'sn a , . -> i : ic m . ' )
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Comment: McCLF CK t' c1atie ,a 1 i: . i i L. t i . ,
.
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Pace 362: In, response to how many 50.55(e) reports had been received:
"Oh we haven't'gotten very many here of late."
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Comment: PHILLIPS tracks 50.55(e) reports and this is a false ;
ctatement. Exhibit 59 shows thwt CP-86-50, for example, had been
received by July 17, 1986,.and this means that a total of fifty
50.55(e) reports had been issued thus far in 1986. WESTERMAN
testified on July 11, 1986, and knew this to be a f alse answer as
PHILLIPS furnished these reports and status reports to make him aware
of gechnical reports by number. In fect, the last report
(November 26, 1986) shows that 76 reports had been received in 1986.
PHILLIPS' experience has been that some projects have not received
this many 50.55(e) reports during all of their 6-8 years of
construction.
Pace 362: "I'm telling you 50.55(e) does not fall under
Criterion 15."
Comment: TUGCO FSAR, Exhibit 14, page 17.1-38, and Exhibit 15, CAP,
Section 15.0, consider 50.55(e) to fall under Criterion 15.0. This is
an example of WESTERMAN's defending something that TUGCO could not
even defend. It is impossible to deal with his logic as it skips from 1
point to point without rationale. His only logic is that is the way
it in because he says it is that way. PHILLIPS, YOUNG and
MCCLESkY were bombarded with this l acl- of logic 'and urjiess they were
- __- _ - _ - _ _ . - . _- - - . _ _ . _
1
87
1
<7willing.'to agree that' dark _is daylight, he started harassing,
,
pressuring ..and threatening.
'
,
Pace 362: "There's no' time limit onretrievability'."
\
Comment: TUGCO FSAR and ANSI N45.2.9 state there is (Exhibit 44.a,
page 17.1-41 and Exhibit 43). These words do place a time limit;
.'i.e., a: reasonable. amount of time or the norm. PHILLIPS and MCCLESKY-
considered a month excessive time to retrieve records.
Similar comments could be made on many of WESTERMAN's statements. As
: WESTERMAN was being advised by DARNES, HALE,.and ELLERSHAW (who have
i almost nothing but NRC Vendor Program experience), WESTERMAN and
JOHNSON proceeded to downgrade all.of PHILLIPS' and MCCLESky's
~
,
-findings because of a lack of management and construction exportence.
In reading. statements by JOHNSON and WESTERMAN related to these
concerns, PHILLIPS detected unprofessional conduct in the manner that
PHILLIP5 was attacked.
Safety Significance
l
The safety significance of these vi ol ations ic berause IUGCO's Eytem
for reporting to CFR 50.55'.o) de t t el enc t o:s ha.s been datic. tent during
the entire construct 2on ci Unit J and 80% oi' Unil J construction.
This statement is supported t, PH tL! IPS' trend malruts and by
+indings of the NRC TRT t ( m ni 1 r. nc t clicr .l 98 i *E:htb1t and SSER
'
!
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!
L__ - _ - - - - _ - - - - - - - - _ - _ - _ - _ - _ _ _ _ _
- _ - _ - _ _ _
,
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69
The significance of RIV management's lack of experience ano knowledge
with respect to 10 CFR 50.55(e) reporting, has been more safety
i
significant that TUGCO's de f icient management d r.d knowledge of the
system because RIV management'.c influence affects many utilities.
.
i Another strange practice in RIV is the fact they do not acknowt< . .s
receipt of the Applicant's 50.55ce) reports, as do other reolonn. this
may contribute to the inadequate reports inado ray TUGCO. It may also
follow that if RIV management doc. not under stsnd 10 rFR 50.55(e)
repor ting and +c1icw-up tn ap rcti.;n , tann RTV tnopecttans of those
areas hewe not been as good ar tho, t. h oi t i d tj a ve o r ten . 1 TUGC0 had i
i
*
bocn strictly required to implemsnt an adaq tato 10 E!R So.55(e)
repor ti ng syest em, RIV or NRC hear! quar t er s no r. t J a l cl- wnujd have
recogni: ed trends that are new snowing up in tha areas of design and
c on st r uc;ti on engineering. What can tJ e mor e Li gni fic ant than t hi s
i
I
considering the poor position TUGCO tinds itself in today. ]
,
Con r: rr n.- No. . ---
-
- - -
4
l
l
PHTLLJPS was concerned that RTV menagement down , aded the 1ollowing
document c on trol --r el a t ed s t a l 9 i 3. , r. o an unricel' m i t ro,:
1
l
;
l
" I UGCO nait rep. laced de u .t t > : t c t . c r- p tc r I C !' - . 3, b .t t wi o; 4 l
tiist ware F icla i nup _i ,
-
- . .ct pr mm ; , ! ..t 1: lad m ,
j
f
e n 7 t a l ! a t i p r. 1 avc l ci ,
I i f i
l
. __ ______-_ _ -__ ___ _ _
90
E>:hibit 62, pages 16 and 17 of 014 report, Attachment MM, adequately
explains the concern.
Exhibit 50. pages 4 of the ortain.41 dratt inspection report. desci 1bes
the violation which was dropped.
Exhibit 51. pages 6 and /, tinal incpection report issued, recorded
the itein as unresolved.
PHILt.1PS',_Undprstandinq_ol..Latit.g n la d
.
ljggui rement;_s : The requi r eme.it... are dee.cribed in b.nhibita 33 and 34 l
ctra.1 i ric l ude appropr 2 ate por t i os o, cd 10 LFR 50. Cr i i eri on VIII.
Appendin B; FSAR, Section 17.1 c.n d 1U0C0 UAP.
[[or.)c_omp l_i a n c o . n_ t_h Ge qu ) : qq.g u t. :. :
. it 2 u r.on c omp 1 1 co u.e . a. i a identliied a r>
c v i o l e t.t an of t.h e t d e n t i i- te o l. s a t r ".' qu i i u u. . L c :. n l1. i i b t t i 1. S ': ,
and 'A an descrabed
o in the c i . i i r.; 1 or a; t r c por t t .3 tit 50).
.
PHILLIPS' understanding al ' vi.s a ; t i .+ Nt ag gn q1.: n A .?t. Loncorn Na. 4
[2!),;1.qr oun d :
l I l .
3 o , b # $ .Em
l l
Recorts datin.) eack to l ' / .- 4 'e i: : . i- . b p l i . ;!.1 c n at
.
.
l
.
_ - _ _ _ _ _ _ . --__
. - - _ _ _ _ _ - _ _ -
,
l- !
91
{
l '
effort. The six RIV inspections reviewed did a fair . job with respect
to inspecting line IE IP92700 items: such as, TUGCO actions or
applicability distri but t on, assignment of responsibility, and
corrective action documented. Thece reports did not generally
emphasize field verification of hardware replaced, repaired, or
modified. Therofore, MCCLESF:Y's tasi: was to field veri f y selecteci IE
Bullatins.
Proner HandJin2g: MCCLESKY 4 'e n cued IE Nanual l'hapter requirements and
the backgtaun:] material p r a ,1 10 : ebu,e.
l
.
,
The r esul t r, oi this a rispot i a a: a tf:.h1 b2 t 50 and C. ) show that before
1 l IJosember 15, 1935, a potentia! . i .: l . P. t a n had haen identifled to high l l
l
l Icvel TUGCC engineert who su r e l ii. e.l . e d t ri this rev&ow. These exhibits '
alsso document TUGCO"s inac.11ty t. snow the carrect at41 t ch on residual
w
heat removal valves thet ar e 1,mta12en in a reaborisble tame.
.
,
PllILLIPS ttanslated thena f ; od; % s t n l.a a distt 1. n at: sm e t an r ap ort. a =,
1 l MCCL.EGM bed c ontacted TUCCD - ,f ictof po:nta a. s. o n t a c t ( c i rc l e.ed on
fi:; h t ta l L 64i. B&R 1ssued a no< a ar + at .nanca repart.
1 }h D n d l I fig : PHI L L1 PF h .r e:i- ' . nr < t ne iho e t -, i J - toctten or
the Inspect 1an nrp or t to WF I; id a d. rmp :t a u i t :5 ps i.1 :u l .;r j
j
t
item i ?Mr1CD uwi t chrete i . nW G ."' ,%r c h i . i
cr tnr trct( l r. .- ~
by gding tc Df44HDT, T Ur;r.1 ..4 .4 s a r. c I ar .- ..nitct-
p r a v i t' e d . M t c-r 3 J on.3 pto '
. r.?'.- :. d ) r ' . .n .r '
j
<
l
!
I I
l .
L 1 t . _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ - - .. I
_ . _ _ - - - - _ _ _ _ _ _ .,
. __ .-___ .-_ . _ - _ _ _____ _ _ _ _ . - _
.
l
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92
]
travelers were pr oduced. No explanation was provided as to why these
work records were not in the OA records vault; however, the specific
NAl1CD swi tch d'. ravel er s should has e been ava t I ab i e as Uru t 1 was
completed.
MCCLESK'/ had a number of que-tions ; that DR/',tJDT never rin swer ed .
MCCLESKY left the site in Fobruary 198o. Shortig before ha left,
there was disagreement at a meeting attendeo by Pil!lLIPS, MCCLECKY,
13RANDT, WESTERMAN and BARNEG regarding the fact that BRANQ1 naver
prov3ced the inf ormat i on requerted, the dotation was dr opped. TUG 3CO
l . c.;hou l d have been ci ted as originally writtwn in Exhibit 50 3 page 4-4:
however~ , after it drug out so long they finall y f ound the records. At
thin potnt, they should have baan cited for t allure to retrievo
l
r e c o r d r,, , a ditterent violest1on. but ac c.c r Lli n g t o WESTERMAtJ,. there as
no time limit. j
)
Ihe protracted t i .ne f or getting draft reportc nas emutwc many preol e.Tm
as in this ca20., The inspection ended Namnbar 40, l9G3. WESlGRM6.N
wn on-o te much c1 the ti me usitil the drait m: i aisi.ntted to Gl a r.
Fuoruary 1986. He was i n c t n '.i nij an not a l l ow i e.i_., .intattana based dn J
iniertDation PGCe1Ved ils letd Dr C C.W Er l ' ff . and s_ i r l . d u n LF V 10 9.:) .
I
I h l ". was not properly docuir.entsd in the flRC t.~3nemitt 1 1.> t t mr : 1.C..
I
additianal 1 isS'p O C l. l u n Out5ide l i '. t./ 1 *iEpEC i 10' pr . a. s 'i . IlC hcl ! ., N R t.'
t
e n h C I C oiD e n t okk1CeI y C Cii 31 d C.r 3 tl11 O i mfI .[2I 1ei b l . '- n TIlo d n t k Ih C
#
t!IO
l
U1 r.i Report tCuh1 bit 6S, I r i E p.: c i 1 L.i i !ec p r L 3 1o 1.,4 :r .eic ). Ih1% )
1
lQ rJ () O s ) e f ' 1 E.' pl' QD k Pill o
I
(
_ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _
_ _ - _ _ _ _
93
PH1LLIPS has performed follow-up inspection in subsequent inspection
perindc but has not closed thr item because of the mul ti pl e pe -otal ems
found. Be+cre this inspection (discussed balow) one switch was found
tc be a Train "C" (noncaf et y-re'l at ed ) switch; therefore, only one
switch is discussed. MCCLESkis field notes dateo in November 1985
conflict with the Master Data Beso, checked on July 25, 1986. This
information Master Data Base was not produced for MCCLESKY in 19G5,
but was, there in 1986. PHILLIPS found new finoings; 1.e., multiple
violations of the work traveler F'rocedura CP-CPM-6.3: therefore, the
item remains open.
Tr avol t r__EE D2-1415-5001 dated J u l;L ]_,1_l9BJ : ,
l Comments:
1. I h r> anita aJ tirst t r a vel er- wcs not reviewed, signed, or dated as
l l
required bv procedura. 2. Oper& tion fJuinber 1 does not reference and requis e di sasserabl y per
l instruction EEI-21, " In st al l a t i on Ra quir o.r.nn t .a tcr NnW.:C La ma t
Switches," Revision 0, dated August 20 190 '.
'
3. Operatioc. N c, . . P< . 2, t a '. a to t t ghtet. ":inuq t i c.h t . " Since t"ese
.M.Ve3 af' O equapment Qt o l. 1. C. A t i Un toEtPd *selIM1C), Wh 61. WGdid
h.AppOn 1f there ar..: Jr . , t i . 1.tfcecr.cca ,
'2 ' .: is iq F 2 oi;t ap >> t 7acl,e i
l '
1DQ1E! C,in d l'1C n t !i" C ' v l i .. i ) L z (di i.Iti" .41.*'t- i i hl c.a l O Citti i n i. J J:)
l i f L
_ . _ _ _ _ _
94
earthquake. This might cause failure if the switches on the
valves in the field are not tested to the same tightness as those
tested. j
4. Operation No. 5 does not. require determination per
Procedure EEI-8, " Class 1E and Non-Class 1E Cable Tcrminst2cns,"
Revision 3, dated May 18, 1982.
1
5. Operatico No. 6 does not require stops to be in accordance with
EEI 21.
.
6. Crewing Revision was not rccarced; and Procedur e I?evi si on Wer e
l
not recorded.
l l l
F l en 1 ar c menn t Trave)er EE 8".-0459-5801 datcct May_ Jk_L2fG.:
l
1. I h t ", second traveler does n o t. reference the (3rst traveler and
1
was not in the QA recorda 4'i l e at t h e t $ rt:e the incpection wts
erfarmad. One could ea:u 1 y con * usa uhlch h /ml or 1s l' h e l il'Et
1
i
C) f ' I hist one.
1
j
2- the +irGt statement on thiv h . .m l e r ,e . l * i c i. tht on _ c h in.t t t L> c
rQplaCGd bOC3ul0 It O h'O _1 % r. i,a,0! the tc .: . 11 r ec t r osi . 16 1 .
(M?Gith O f 1 '"? nf tWo t h i n gi r_ : '1) ti.e d c. J t g n de 'i~ 1 .g t t cn v o l c r u.,E
LdriOct e3 n (J '* jag not 14i3" 31 1 " ' r, J "~ '. n c
.
F 3 0 s.'ii .O n ' 3 Ci tJ) ha
! t
,
d H!S t .j n dr 21Hi ng / t r 46v.2.l tt sJ,4 r .,..u A n1 1. : i . ,,.t- F' w rist al j e;l t'
.
_ _ - - _ _ _ . - - _ _ _ . - _ - - - . _ _ _ - - _ - _ _ _ _ _ _ . _ _ _ . - - . - - .
(15
s&; itch per these documents. (No NCR was written if the first is
the case; and no DCA was written li the second was the case.)
The discrepancies above show a wealness (if not a violation) of OA
program requirements.; that i s, generic with respect to not requiring
installation per procedures. Even if procedures were referenced, no
revision was on the traveler and no revision: for the drawing were
recorded. What effect this has hsd on several hundred installations
is unknown at thi s point.
E::hi bi t 66, " Conversation f?ci cr o . usteo a u l ,- 8, 1986. documents the
.
TUGCO repre'ientat we's statm an' that T. n c y nad St.nt.lpr problems as did
MCCI.ECKY.
Satety_Stantitcance:
i
e
IIh inh a C b rien a huncreds o .- 2 . s i ' . .' , e.. ; - t :;l J r. ' a r ' 1 :s'.s c siutem is
3 7.1 l l unfn0Wn Js the tr wc!c:i - n ; "ii. pr'oc ed ur..? .. .T a t t c l .l owed .
e41thouah the original p r c t) J r.u .. th : enti t i c at: an w.a r m ,'ct er i cu z i ,'
sQl/Cd. dQCumGnted Swl tCilO e :. (1/ '": ~i.- *C1On
. <0 SW1 t' nd G 1 n Es t dt1 1 a d wag d
v101ution and the fai1utm t a< .a the douimant. was ei n ej 1s a
'
.1ofdt1on.
'
1M iaCt 3 1 'I 1 U! A s 'M- r O lU ; r ~ d 50 o ur :!ue this 1ssue,
t h e 'y . hay have IounO and pt i'lt;pI 8. ' i] . l - a '. 3 D n E On C. f . c 3 r
t r W G I Gi* 3 'y' G t OiG ( [ n I p O C~ i~ i G , i .' ' ( ; 1. ' ini ECG l l Jneou?
.
( J C r ic trevelers POvicWed.
.
_ _ _ . _ _ . _
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1
96
-
,
]
This item has wasted a great deal of the NRC inspectors time and i s
still not solved. This in itself is safety significant in that the i
l
inspector ends up inspecting less. This wou.ld not have happened i f
1
WESTERMAN and JIGHNSON had not intervened. l
l
.
Concern No. S )
PHILLIPS was concerned about the technical adequacy oi DISCO fire
seals installed at Comanche Pa:ak bocause certatn configurations had
!
recently failed in t e s t i n g). n cot a21cd r evi ew of the certifications
showed them to be at least irdotarminato and,, at worst, false.
.
Records of testing were destroyed in two successi , e t ir es according to
BIGCO management; however, t e :- t d a t e o, and dates of the fire conflicted
in one case. RIV management apposred to be mor e concer ned about
i
protocal of who to address the momcrandi..tm to than these problems.
Ex tu bi t 49, psges 17 and le of nttacnment nn to tne rinc 01a neport,
generally describes the concern; however, greater d a t ,.ti l about these
concerne i s. .ic ccr i bed in a e u tv v a.w o t p e r z wir c.p h (Mi nt,ana12 ng) .
,
Exhibit 5U, pages 6-1 thro Nh - ; .t- the or t cin al incprction drait
Rocnrt GS- 1 M 13, denrr i te o. . - i. , .:;; , ed i t em er i
'
we .~ 1 o l e t a cr i 3.
-
R 4l11 b 't t 51., paqr% 7 thrOUgr 5 '
t I n c.1 1 t r J[:C.',F.t ci. l 'ep ci- h O'i 1of 1'.
Showc two unr c r.o! '< ed i t ethw .
____ _______-_____-__- __ _ __-_ - Q
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97
CHILLIPS' Under t. t andi na of Concern No. 5:
Requirements: The requirements are describ'ed in Exhibits 1 and 52 and
i
include appropriate portions of 10 CFR 50 to Appendix B, Criterion XV; l
-10 CFR 50.55(e); and FSAR, Sectien 9.5, pages 9.5-29, 58, 67, 68, 69
and 223 as described in Exhibit 67. The testing requirements are
ASTME 119 and IEEE 634.
Noncomp i i ante with these Recuiremente.: Exhibit 50 adequately describes
the noncomniiances.
'
.
Epckoround: - i
1 1 PHILL.IPS i denti fi ed an unrosol ved item'and a vi o l at i on concerning; !
fortifications and damaged Gealc in 1984. YOllNG was ansigned to
'
+ollow-up and close these items, it p o n tu b l e , during inspection
8 5 - 1 6 / 1."..
Prgper H a n d l i n,g :
YOUNG brought the additional findings as descr2 bed in Exhibit o7 to .
1
l
PHILLIPS's attention about m i d e.i a y throuqh I:he inspnction period.
l
Because these technical problems .n i g h t a t i ect other plante, PHIL L I PS
;
wrote a memorandum to esped)ta to9 1 s t u s' . 1 h ia mem<]r andum recoinm?>nded l
an DIA i nv et. t i git t i on pr3nr to e t r chm c-1 e v e.1 i i e t i nn h e c =tu ne 1t UI4
:
I
l
l' fcund t 3 I. Ta e GF m1s1 Odd 100 coi-tit 1r***tt'.?M 1, t h .' 'I - Altr> (;a n a ch h r a-3 d i !r l l l
l
,
I
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98
l
than the specific Comanche Peak technical pecblem as these seals are
1
used in many plants. Thi s recommendation also considered the long
l
standing understanding that if potential wrong doing may bo involved,
i
l the investigators should review it first. l l l' l Mishandlinci - l
The mishandling started when WESTERMAN received Information regarding
potentially deficient fire stops. Instead at assisting the
inspectoru, WESIERMAN and JOHNSON actively blocked the memorandum from
going forward to Headquarters. JOHNSON came on-site in January 1986, ;
, I
'
not to discuss the technical issues, but to criticize PHILLIPS for
,
{
addressing the issue to a branch chief in headquarters instead of his l
i
signature. Thi s issue was raised in mid November 1985 and was still
in the r eview cycle in mid March 1986. An e::perienced manager would
have f orwarded this issue immediately, as he could have rewritten it
to suit his-style in Icss than an hour. It took about 5 months for
the memorandum to leave RIV. In statement, he defines it ac
worr yi ng thu inspector's work to death and this they have done to all
et PHILLIPS" work since he supported violattons in
Report 86-07/05.
The violations on BISCO seals were mi shandled because M WEETERMAN's
and JOhNGOW s lack of construction knowledge and e:: port ence as
evidenced abnvc and in WES1ERMnil's statement uittachment O, 014 )
Report).
l l
!
;
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-________-__--_---_-__A
- _ _ _ _
99
"A. Now, first off, the violation that I read you in here said
that there was no non-conformances required by UI-QP-16.0-4,
Revision 1. That's talking about Class 1-E equipment with
deficient-IEEE-323-344 test reports.
"We are talking in this particular documentation with
Appendi:: R requirements f or which there was not documentation of
test requireinents in accordance with ASTME 119 and IEEE 634.
ThatP s why I'm telling you the violation is not proper even
if there had been a violation. I cannot go f rom -- you want to
make this an exhibit to take a look at -~ from the procedure
which he says they violated .ihtch deals with I EEE --323 / 34 4, which
.
I s environmental and seismic queli fication of electrical
equipment, to say that en an Appendi: R type item, which is
ASTME 119 and IEEE 134, that that prccedur o would have required
them to write a non -con t ormanco report. " j
4
Comment: 11. is my opinion that that statement is technical]y incorrect
because this is not solely an Appendin N r ': qu .t r eme n t ., the fire steps
umed throughout the plant are required by I EEE~ L . 'I and ar e an intraraj
part of a bundle of Class IE cables which pcnetrate walls, floors.
etc.
l l 1 )
Exhibit 66,, pe,ges 9 and 10 o1 IFIE s34, cuppert thir
,
n par aqraph 5 2. .
and 3 It also . appears thal. Ma de:u gn Criterta 1 . And 11 of
l
Appendix A and Cri ter i a 111 sod ;I ai 10 G R 9 r aju s r e the cable +,u n l
l l ,
_
_ _ . _ _ _ _
,
s
100
fire stops to provide protection of cable from a redundancy standpoint
alone.
Page 635: "O. There are several par-ts of the TDR. There's the issue l
of deficiency and al so a b ot: cal 1ed potentially. reportable under
Part 21. -
A. I will you that I told Mr. Phillips if he wanted to
make a violation out of that, he should mal:e a violation out of
that.
I do not remember hit line ci logic, but he gave me
some line of logic abot? n o t. Wanting to ctto on deportability.
Now, if you go b ac k to the finei report. he added in an
item in here on pag'c 9 ,%. How that was his choico."
l l
Comaant: FHILLIPS does not recall thin statement which tefers to the
!
proposed violation concerning falturia to adequately svaluate a
construction det'2ciency (E: hitit t 50, p in g o 6-47 The basis of the
propcsed violation was that rho TUGCQ enginear c1141 not know if the
firo stops involved s y r.t e m : ior , si e chut d owi . . rhi n belng the case.
!
an improper evaluation alua.s L e a d t, to a no reporting situation.
WESIERMAN would not allow tvu ; . i c,J ati on to be written.
l
l
1 he ;;e discumstonn with IUD :r .o . t ,.ce untcaol .;c ttem in inopect3on
Report 85-16/1'. f i n c,l l y f:n > -n 4cequate c.,1ue r i nn and a
!
potentiall3 reportabla t r o.c. . , 3 ~.1danc 1 i. ri a h i b i t c /. the
d&Gign defIClenCy repOPt J'
'
, t ..Cd. il! 'l . : u} [ GW' 8 ap
l
l . I 1
_ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _
__
101
inepection has not been accomplished to date to determine the full
acceptability of the way these technical issues have been handled;
however, a quick review indicates the 50.55(e) was considered
nonreportable but not all t er.hni c a l concerns were addressed.
! @fjety Sieniftcance
This significance of this 2nsue is similar to Concern 1, 2, and 3 and
should be considered a part at that greater concern.
.
- - - - - _ _ _ _ _ - - _ _ _ _
y
.Exha
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s .
U CE'Co Q ' Y O'* E W &,rh'
k' i
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1
i
> - LIST OF EXHIBITS
1
Part 50, Appendix B, Criteria
18............................pp 413-433
2
F S AR S e c t i on 17. 2. 3, De s i g n Con t r o! . . . . . . . . . . . . . . . . . . . . u. .1B. . . p p 17 1-14
.
3
TUGCo DA, Section 3.0, Design
Control.......................p 1
1
4
B&R Traveler Procedure 1
CP-CPM-6.3...........................pp 1-11
5 westinghouse
Frocedure.............................,.........pp 1-8
6 1raveler NC
o 79-248-5500..................... ...............p 1-8
7 Contention
5................................................pp 3-4
8 NUREG-0797,
Mi s c ell a n eous I t em 2. . . . . . . . . . . . . . . . . . . . . . . . . . . .p p t-9 9 t h ru 102
9 RIV Report 79-03/03 and Letter and page .
3...................
10a IE Frocedure for Vessel Installation: 50051.................
10b IEP for Vessel Installation: 50053..........................
10c IEF for Vessel Installatten: Sv055..........................
11
Original Final Draft lnspection Report S5-07/05
Submitted to M 'Hunntcutt.....................
12a
Second Final Draft Inspection Report 85-07/05, Revision 1
Signed October 2, 1985, Submitted to RIV and HQ.............
12b Denise'r Comments
DIA Report.......................... .........
DIA
Attachment...................... .............pp 30, 42, 43
.......................pp
13
Report 85-07/05 Issued February 3, 1986.....................
14 FSAR Section
17.1.16....................................... pp 17.1-32 thru 39
15 TUBCD QAF Section 15.....................
Section 16..................................................pp
...................P 1
1-2
16 B&R DAM, Section
16.........................................P 1
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17. . FSAR Sectron 17.1.18,fAudits................................p 17.1-36 j
18 ANSI N45.2.12,' Draft 3, Revision 0,.1973, Requirements for
Auditing QA Programs for Nuclear Plants.....................pp 1,5,6
i
19 TUGCo DAP Section 18,. Audits................................p 1
20 NRC Inspection Report 84-32/11, Notice of Violatson and ]
Letter....................................................9p 1-3
21 MAC Audit of TUGCo and Response.............................pp 1-6,15,16 #
22 Worsham.Forsythe, Samples & Wooldrige Memo, May 29,.1985....pp 1-2
23 NRC' Boar'd Notification Nos. 85-067 and 85-076 Memo..........pp 1-2
-24- PSLLobbin Report, F e b r u a r y 19 8 2. . . . . . .' . . . . . . . . . . . . . . . . . . . . . . p p 2, 3, 4 4 -
25 TUGCo Transmittal Letter to NRC, (enc!csure Lebbin Reporti.. l
l
26 N R C C A T R e p o r t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . s . . . . . . . . . p p B- 1 t h r u 3 *
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L, VIII-1 thru 5
27 NUREG-0797, SSERLNo. 11.....................................pp 31-33
]
28' Commanche Peak Response Action Plan--! SAP VII.a.4.',...,......pp 5-9
29 Resul t s Rep or t--! S AP V! ! . a. 4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . p p 1-53
30 Letter and Draft of the Notice of Violation 86-08/06........pp 4-9 i
31 List of Quality Assured Structures, Systems, and
Cbsponents..................................................pp1-2
32 Original.and Fir 41 Inspection Report Detal15.................pp 16-17 i
.
l t
'33 Identification and Control of Materials Parts
a n d C oo p o n e n t s , F S A P 17.1. 8. . . . . . . . 2 . . . . . . . . . . . . . . . . . . . . . . . p p 17.1-25 thru 15
I
3g TUGC0 QAP, Section 8.0, Identification and
Controlofitems............................................p1
_ _ _ _ _ _ _ _ _ _ _ _ _ -
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LIST OF EIHIBITS <
35 Code Requirements NCA 3886.6 and NCA 4134.B.................pp 36, 46
36 B&R QAM, Section 9.0.........................................pP 1-4
7 B&R Procedure CP-CPM-6.9E, Revisions 2 and 4................pp 18-!9
DI-0AP-11.1-26, Re.1stons 4 and 18..........................pp 6, 7, 8
30 BLR !sometric PPP-CS-2-RB-076 and Bill of Materials.........
!
39 IE Inspection Procedures 49051,-53,-54,-55, and -56.......,.
40a Portions of OIA Attachment 0 Statement......................pp 112,113
and 148-158
40b ttachment,J................................................pp 1-3 and 9-13
41a Attachment MM of 01A Report.................................p 9
42a Ortgtnal Draft Inspection Report 85-14/11...................pp 1-4
42b Second Draft Report 85-14/11 (with directed changes)........pp 67-78
42c Final Inspection Report 65-14/11, March 6, 1786.............pp 10 and 13
43 FSAR Section 17.1.17, CA Records............................pp 17.1-40 thru 41
1
44a ANSI N45.2.9, Requiremer.ts for Collection, Storage, and Maintenance of 04 '
Records...................................pp 11-12, 14, 16-21
44b FSAR Commitmer.t ANSI N45.2.9...............................
45 TUGC0 QAP, Section 17.0, Site Construction Quality Records and Record Retention j
and Storage............p 1
46 Attachment MM to DIA Report.............................. ..pp 11-12
l 47 Attachment FM of DIA Report..........................- .....pp 13-14
48 TUGCo QA Rwcord Receipt Controll/ Storage
Procedure CP-QP-18.4, Revision 7............................pp 1-2
CP-CPM-7.1, Revision 3, pnd.................................pp 2-4
S 1 A ,0 2, R e v i s i o n 1 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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LIST OF EXHIBITS l
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49 31A Report, Attachment MM...................................pp 14-18
50 Original Hough Draft Report 85-16/13........................pp 3-1 thru 3-6 ,
4-1 thru 4-4 l
6-1 thru 6-4
51 Final NRC Inspection Report 85-16/13........................pp 5-9
52 R e g u l a t i o n 10 CF R P a r t 5 0. 5 5 ( e l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . p 3 8 8
53 TUGC0 QAP, Section 6.0, Document Control....................p 1
54 IE Guidance on 10 Code of Federal Regulation................p 8-9
55 T r e n d A n a l y s t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . p p 1 - 10
56 South Texas Memorandum (LessonsLearned.....................pp 1-5
BLR Engineering Memorandum..................................pp 1-2
57 McCleskey's Field Notes
$7a Review of Procedure NED CS-1................................p 1
57b Review of Construction Deficiency File......................pp 1-10
t
58 Johnson's Comments on Draft Report 86-16/13.................pp 1-5
59 Comanche Peal 50.55(e) Tracking.............................p 1
60 NUREG 0797, SSER 11, Cossents on 50.55(e) Reporting.........pp 0-279-280
61 TUGC0 Letter (TXX-4508) Unit Number Correction..............p 1
62 DIA Report, Attachsent MM...................................pp 16-18
63 McClesky Field Notes on IE Bulletin Review
N o t e s d a t e d h o v e m b e r 1, 19 8 5. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . p 2
Notes dated November 26, 1985....... ...........i...........pp 1-10
Notes dated November 26, 1 9 8 5 . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . p p 1 a n d 3
64 TUGC0 Of f i ci al Con t a c t Li s t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . p p 2
65 RIV Traveler for Report 65-16/13............................p 1
1
66 Conversation Record, P h i l l i p s -- B a k e r . . . . . . . . . . . . . . . . . . . . . . . . p p 1 and 3
9
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LIST OF EXHIBITS !
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, 67 B!SCO Fire Penetration Seat Memorandus November 25, 1985,
-
Draft....................................pp'1-3
March 6, 1986, Final........................................pp 1-3
8 Attachments (14 pages)
68 IEEE Standard 634...........................................pp 9-10
. 69 TUGCO/ BISCO Seal Documents
LDesign Deficiercy Report....................................p 1
TXX-4836....................................................p i
TXX-4966....................................................p 1-
TXX-4996............................................~.......p 1
50.55(e) Evaluation No. 0177................................p 1 ,
TSG-18695..................................................rpp 1-2. 1
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' art 50, App. B Title IO-Energy l
'ided with containment isolation valves as with a capability to permit appropriate peri-
ollows. unless it can be demonstrated that odic inspection and testing of components
he containment Isolation provis!ons for a important to safety. (2) with suitable shield.
Decific class of lines, such a.s instrument ing for radlation protection. (3) with appro-
ines, are acceptable on some other defined priate containment, confinement, and filter.
. asis:
* -ing systems. (4) with a residual heat remov.
.,
' (1) One locked closed isolation valve inside al capability having reliability and testabi.
nd one locked closed isolation valve outside lity that reflects the importance to safety of j
ontainment; or
decay heat and other residual heat removal. ,
(2) One automatic isolation valve inside and (5) to prevent significant reduction in
nd one locked closed isolation valve outside fuel storage coolant . inventory under acci-
ontainment; or >
dent conditions.
(3) One locked closed isolation valve inside
nd one automatic isolation valve outside Criterion 62-Prevention of criticality in
onts.inment. A simple check valve may not fuel storage and handling. Criticality in the
e u:md as the automatic isolation valve out- fuel storage and handling system shall be
prevented by physical systems or processes.
T~ 01 aNo at c isolation valve inside " "
nd one autcmatic isolation valve outside $#'fai gu ' -
4- mtsinment. A simple check valve may not Criterion 6J-Monitoring fuel and toeste
e used as the automatic isolation valve out. storope. Appropriate systems shall be pro-
..
de containment. vided in fuel storage and radioactive waste
systems and associated handling areas (1) to
solation valves outside containment shall
} e located as close to the containment as detect conditions that may result in loss of
residual heat removal capability and exces- j
'.
ractica1 and upon loss of actuating power. sive radiation levels and (2) to initiate ap-
', Jtomatic isolation valves shall be designed propriate safety actions.
s take the position that provides greater
: tiety. Criterion 6d-Monitoring radioactivity re.
i
Criterion 57-Closed system isolation leases. Means shall be provided for monitor.
P tives. Each line that penetrates primary ing the reactor containment atmosphere.
4
' actor containment and is neither part of spaces containing components for recircula- I
te reactor coolant pressure boundary nor - tion of loss.of coolant accident fluids, efflu.
innected directly to the containment at. cnt discharge paths, and the plant environs
.g osphere shall have at least one contain, for radioactivity that may be released from
J ent isolation valve which shall be either normal operations. including anticipated
ttomatic, or locked closed, or capable of operational occurrences, and from postulat.
mote manual operation. This valve shall ed accidents,
1 outside containment and located as close (Sec,161, as amended. Pub. L. 83-703. 68
the containment as practical. A simple Stat, 948 (42 U.S.C. 2201); sec. 201. as
teck valve may not be used as the auto. amended. Pub. L. 93-438,88 Stat.1242. Pub.
'
.
stic isolation valve. I. 94-79. 89 Stat. 413 (4't U.S.C. 5841))
Vf. Tuct and Radioactivity Control [36 FR 3256.Feb. 20,1971, as amended at 36
FR 12733. July 7.1971141 FR 6258. Feb.12.
Criterion 60-Control of releases of radfo- 1976: 43 FR 50163. Oct. 27,19781
live materitsls to the environment The
telcar power unit design shall include
tans to control suita,bly the release of ra. APPENDIX B-QUAI.ITY ASSURANCE CRI.
3 active materials in ga.seous and liquid ef. TERIA FOR NUCLEAR PowrR PLANTS AND
tents and to handle radioactive solid FUEL REPROCESSING PLANTS
* tstes produced during normal reactor op. 3
stlon. Including anticipated operatfor;al l
.
Introducsfon. Every applicant for a con.
:urrences. Sufficient holdup capacity struction permit is required by the provi-
all be provided for retention of gaseous alons of I 50.34 to include in its preliminary
d liquid effluents containing radioactive safety analysis report a description of the
Lterials. Mrticularly where unfavorable quality a.ssurance program to be applied to
e environmental conditions can be expect- the design, fabrication, construction, and
to impose unusual operational limita- testing of the structures, systems, and com-
ns upon the release of such effluents to ponents of the facility. Every applicant for ;
! environment. i
riternon 61-Fuel storage and handling aninoperating license
its final safety is required
analysis to informa-
report, include. !
d radioactivity control. The fuel storage )
$ hand!!ng, radioactive waste, and other tion pertaining to the managerial and ad- l
ministrative controls to be used to assure
items which may contain radioactivity safe operation. Nuclear power plants and
til be designed to assure adequate safety fuel reprocessing plants include structures. ,
der normal and postulated accident con. systems, and components that prevent or ,
lons. These systems shall be designed (1: mitigate the consequences of postulated ac.
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Chopier I-Nuclear Regulatory Commission Part 50, App. B
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cidents that could cause undue risk to the lems; .to initiate, recommend, or provide so-
health and safety of the public. This appen- lutions; and to verify implementation of so-
dix establishes clality assurance require. lutions. Such persons and organizations per-
ments for the design, construction, and op- forming quality assurance functions shall ,
eration of those structures, systems. and report to a management level such that this 1
.
components. The pertinent requirements of required authority and organizational free. i
"
. this appendix apply to all activities affect- dom, including sufficient independence i
ing the safety related functions of those from cost and schedule when opposed to I
'
structures, systems, and components; these safety considerations, are provided. Because
activities include designing, purchasing, fa- of the many variables involved, such as the
bricating. handling, shipping, storing, clean- number of personnel, the type of activity ,
ing, erecting, installing, inspecting, testing, being performed, and the location or loca- i
operating. maintaining, repairing, refueling. tions where activities are performed, the or- i
l, and modifying. ganizational structure for executing the I
y As used in this appendix. " quality assur- quality assurance program may take various
e ance" comprises all those planned and sys- forms provided that the persons and organi.
T' tematic actions necessary to provide ade- zations assigned the quality assurance func.
V quate confidence that a structure, system. tions have this required authority and orga. j
\ or coroponent will perform satisfactorily in nizational freedom. Irrespective of the orga- l'
service. Quality assurance includer quality nizational structure, the individual (s) as-
control, which comprises those quality as- signed the responsibility for assuring effec. l
P surance actiot.s related to the physical char- tive execution of any portion of the quality
acteristics of a material, structure, compo- assurance program.at any location where I
nent, or system which provide a means to activities subject to this appendix are being !
control the quality of the material, struc- performed shall have direct access to such I
ture, component, or system to pfedeter- levels of management as may be necessary j
mineo requirements. to perform this function. I
1. ORcANIZA'rloN 11. QUALITY ASSURANCE FRocRAM i
.
The applicant' shall be responsible for The applicant shall establish at the earll-
D the establishment and execution of the est practicable time, consistent with the l
quality assurance program. The applicant schedule for accomplishing the activities, a
%g', may delegate to others, such as contractors, quality assurance program which complies
4 agents, or consultants: the work of estab- with the requirements of this appendix.
lishing and executing the quality assurance This program shall be documented by writ-
,*y program, or any part thereof, but shall ten policles, procedures, or instructions and
-
retain responsibility therefor. The authori- shall t e carried out throughout plant life in
Y ty and duties of persons and organizations accordance with those policies, procedures. 3
k performing activities affecting the safety re- or instructions. The applicant shall identify
l
lated functions of structures, systems, and I
the structures, systems, and components to j
components shtll ce clearly established and
be covered by the quality assurance pro- '
delineated in writing. These activities in- gram and the major organizations particl- 1
clude both the performing functions of at- pating in the program, together with the
taining quality objectives and the quality as- i
surance functions. The quality assurance
designated functions of these organizations. I
The quality assurance program shall pro-
functions are those of (a) assuring that an
-
vide control over activities affecting the
appropriate quality assurance program it es- quality of the identified structures, systems,
,
i
tablished and effectively executed and (b) and components, to an extent consistent
verifying, such as by checking, auditing, and with their importance to safety. Activities
inspection, that activities affecting the
affecting quality shall be accomplished j
safety related functions have been correctly under suitably controlled conditions. Con-
performed. The persons and organizations trolled conditions include the Hse of appro-
1
performing quality assurance functions priate equipment: suitable environmental
l
shall have sufficient authority and organi- conditions for accomp!!shing the activity.
zational freedom to identify quality prob- such as adequate cleanness; and assurance
that all prerequisites for the given activity
--
'While the term " applicant" .is used in have been satisfied. The program shall take
these criteria, the requirements are, of into account the need for special controls,
course, applicable after such a person has processes, test equipment, tools, and skills
received a license to construct and operate a to sttain the required quality, snd the need
l nuclear powerplant or a fuel reprocessing for verification of quality by inspection and
plant. These criteria will also be used for ,
-
test. The program shall provide for indoctri- j
guidance in evaluating the adequacy of nation and training of personnel performing
quality assurance programs in use by hold- activities affecting quality as necessary to {
j
crs of construction permits and operating 11- assure that suitable proficiency is achieved ;
Ce m es. and maintained. The applicant shall regu- {
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Titla 10-En ;rgy
larly review the status and kdcquacy of the
.
I, tv. PROCUREMENT DOCUMENT CONTROL
quality assurar.: e program. Management of
!. other organizations participating in the Measures shall be established to assure !
quality assurancc program shall regularly that applicable regulatory requirements,
review the status and adequacy of that part design bases, and other requirements which
of the quality assurance program which are necessary to assure adequate quality are
they are executing. suitably included or referenced in the docu-
ments for procurement of material, equip.
str. cEsrcN CoNTRo!, ment, and services, whether purchased by
Measures sht te be estab!!shed to assure
the applicant or by its contractors or sub-
Inat applicable ristatory requirements and contractors. To the extent necessary, pro- l
the design basis, as defined in i 50.2 and as curement documents sha'.1 require contrac.
specified in the license application, for tors or subcontractors to provide a quality
those structures, systems. and components assurance program consistent with the per-
i
to which this appendix applies are correctly tinent provisions of this appendix,
translated into specifications, drawings, pro- v. trestRuctions, rRoCEDUREs. AND DRAWINes
; cedures, and instructions. These measures <
, shall include provisions to assure that ap- Activities affecting quality shall be pre. I
propriate quality standards are specified scribed by documented instructions, proce- I
, and included in design documents and that dures, or drawings, of a type appropriate to I
deviatier,s from such standards are con' the circumstances and shall be accom.
trolled. Measures shall also be established plished in accordance with these instruc- i
for the selection and review for suitability tions, procedures, or drawings. Instructions.
of application of materials parts equip- procedures, or drawings shall include appro-
ment, and processes that are essential to the priate quantitative or qualitative acceptance
safety related functions of the structures' criteria for determining that important ac-
systems and components. tivities have been satisfactorily accom-
Measures shall be establi::hed for the plished*
identification and controi of design inter-
Iaees and for coordination among pa rtici- y ,poeggggycogygot
patmg design organizations. These measures Measures shall be estab!!shed to control
shall include the estabhshment of proce. the issuance of documents, such as instruc-
dures among participating design organiza. Lions, procedures, and drawings, including
tions for the review. accroval release. dis. changes thereto, which prescribe all activi-
tribution. and revision of occuments involv. ties affecting quality. These measures shall
inc design mterfaces
assure that document & including changes.
The design control measures shall provide are reviewed for adequacy and approved for
for verifying or checking the adequacy of release by authorized personnel and are dis-
design, such as by the performance of tributed to and used at the location where
design reviews. by the use of alternate or the prescribed activity is performed.
simplified calculational methods, or by the Changes to documents shall be reviewed
performance of a suitable testing program. and approved hy the same organir.ations
The verifying or checking process shall be that performed the original review and ap-
performed by individuals or groups other preval unless the applicant designates an-
than those who performed the original other responsible organization.
design. but who may be from the same orga-
nization. Where a test program is used to VII. CONTROL or s URCHAsED MATERI AL, *
verify the adequacy of a specific design fea- EQmtNT. AND SERVICES
ture in lieu of other verifymg or checking
Measures shall be established to assure
processes. It shall include suitable qualifica- that purchased material, equipment, and
tions testing of a prototype unit under the services, whether purchased directly or '
most adverse design conditions. Design con- through contractors and subcontractors,
trol measures shall he applied to items such conform to the procurement documents. i
as the following: reactor physics, stress, These meastires shall include provisions, as
thermal, hydraulle and accident analyses; appropriate. for source evaluation and selec- ! {
compatibility of materials; accessibility for tion, objective evidence of quality furntshed it ;
inservice inspection, maintenance, and i j
repatr; and delineation of acceptance crite- by the contractor or subcontractor. Inspec.
~
)
ria for inspections and tests. tion at the contractor or subcontractor
Design changes, including field changes, source, and examination of products upon -
shall be subject to design control measures delivery. Documentary evidence that mate-
rial and equipment conform to the procure- s'
commensurate with those applied to the ment requirements shall be available at the 7
original design and be approved by the orga- nuclear powerplant or fuel reprocessing 't (
nization that performed the original design plant s1Le prior to installation or use of such
unless the applicant designates another re- material and equipment. This documentary l
sponsible organization.
evidence shall be retained at the nuclear
414
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Chapter I-Nuclear Regulatory Commission Port 50, App, B
D powerplant or fuel reprocessing plant site xt. TrsT CONTROL
,
4 and shall be sufficient to identify the specif-
I 9
'
le requirements. such as codes. standards or A test program shall be established to
specifications, met by the purchased materi assure thet all testing required to demon-
3 al and equipment. The effectiveness of the strate that structures, systems, and compo-
control of quality by contractors and sub. nents will perforrn satisfactorily in service is
,
contractors shall be assessed by the app 31" Identitled and performed in accordance with
cant or designee at intervals consistent wit"n written test procedures which incorporate
the importance, complexity, and quantity of the requirements and acceptance limits con.
the product or services. gg g,g g
test program shall include. as appropriate,
l
vr!!. IDENT2r! CAT!oN ANo coNTftok or proof tests prior to installation, preopera- 2
MATElt!ALs, PARTS. AND COMPONENTS tior.a) tests, and operational tests during nu-
f
clear power plant or fuel reprocessing plant
_
l
Measures shall be established for the operation, of structures, systems, and com-
.-
) '
identification and control of materials. ponents. Test procedures shall include pro-
parts and components, including partially
fabricated assemblier. These measures shall
visions for assuring that all prerequisites for
assure that identification of the item is the given test have been mct. that adequate
maintained by heat number, part number, test instrumentation is available and used.
serial number, or other appropriate means. and that the test is performed under suit.
either on the item or on records traceable to able environmental conditions. Test results
the item, as required throughout fabrica- shall be documented and evaluated to
tion, erection, installation. and use of the assure that test requirements have been sat-
isfieC.
'
Item. These identification and control meas-
ures shall be designed to prevent the use of
incorrect or defective material. parts, and xtt. CONTROL Cr MEAsVRINc AND TEST
goggygggy
"* E *
Measures shall be established to assure
Ix. CONTROL or sPECIAL PROCESSES that tools, gages. instruments. and other
Measures sha!! be established to assure measuring and testing devices used in activi-
that special processes. Including welding ties affecting quality are properly con-
heat treating, and nondestructive testing.' trolled, calibrated, and adjusted at specified
are controlled and accomplished by quall- periods to maintain accuracy within neces-
flec personnel using qualified procedures in sary limits,
accordance with applicable codes, standards
specifications, criteria, and other special re.- x!!!. HANDLINo. SToRAct AND sH!rFINo
quirements.
Measures shall be established to control
the handling, storage, shipping, cleaning
x. INsrtcTtoN and preservation of material and equipment
A program for inspection of activities af- in accordance with work and inspection
fecting quality shall be established and ex- Instructions to prevent damage or deteriora-
ecuted by or for the organization perform- tion. Men massary for partkular pd
ing the activity to verify conformance with ucts, special protective environments, such
the documented instructions, procedures, as inert gas atmosphere, specific moisture
and drawings for accomplishing the activity, content levels, and temperature levels, shall
Such inspection shall be performed by indi- be specified r.nd provided.
viduals other than those who performed the
activity being inspected. Examinations, x!v. INsrtcTroN, TEST. AND oPERATINo STATUS
measurements. or tests of material or prod- Measures shall be established to indicate,
ucts processed shall be performed for each by the use of markings such as stamps. tags,
work operation where necessary to assure labels, routing cards. or other suitable
quality. If inspection of processed material means, the status of inspections and tests
or products is impossible or disadvanta- performed upon individual items of the nu-
geous, indirect control by monitoring proc- clear power plant or fuel reprocessing plant.
essing methods, equipment, and personnel These measures shall provide for the identi-
shall be provided. Both inspection and proc- fication of items which have satisfactorily
ess monitoring shall be provided when con- passed required inspections and tests, where
trol is inadequate without both. If manda- necessary to preclude inadvertent bypassing
tory inspectica hold points which require of such inspections and tests. Measures
"It" easing or inspecting by the applicant's shall also be established for indicating the
designated representative and beyond which
work shall not proceed without the consent Operating status of structures, systems, and
of its designated representative are re- components of the nuclear power plant or
quired the specific hold points shall be indl- fuel reprocessing plant, such as by tagging
cated in appropriate documents, valves and switches, to prevent inadvertent
operation.
415
n - .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -- - - - - - -- - - - - - - ~ - - - ' - -~ ' ~~ ' ~ ~ ~
_ _ . _ _ _ _____ -
, _ . . . . . . .
,
* *
Prrt 50, App. C Tilb 10-En:rgy f
,
i I
Xv. NoncoNroRw No MATERIALS, PARTS, OR ty in the area audited. Followup action. in-
j couroNtNTs cluding reaudit of deficient areas, shall be }
1
Measures shall be established to control taken where indicated. i
;
~
materials, parts, or components which do (35 FR 10499, June 27,1970. as amended at
not conform to requirements in order to 36 FR 18301. Sept.17,1971; 40 FR 3210D,
p
'
a
prevent their inadvertent use or installa. Jan.20,1975) ;
.: tion. These measures shall include, as ap-
J propriate, procedures for identification, doc. APPENDIX C-A GUIDE FOR THE FINAN-
g umentation, segregation, disposition, and CIAL DATA AND RELATED INFORMATION
I
notification to affected organizations. Non- REQU: RED To ~ EsTAI.LIsH FINANCIAL
i conforming items shall be reviewed and ac-
cepted relected repaired or reworked in ac* QUALIFICATIONS roR FACILITY CON-
cordance w!th documented procedures. STRUCTION FERMITS AND OPERATINC
Lgegggg3
XVI. CORRECTIVE ACT!oN
cENERAL INroRMAT!oN t
Measures shall be ertab!!shed to s.ssure This appendix is intended to apprise ap-
that conditions adverse to quality, such as
-
failures. malfunctions, deficiencies, devi* plicants for licenses to construct. and oper-
ations, defective material and equipment, ate production or ut!!1zation fac!1%ies of the
'
and nonconformances are promptly identi- types described in 150.21(b) or 150.22, or a
fled and corrected. In the case of significant testing facility, of the general kinds of fi-
conditions adverse to quality, the measu m 3 nancial data and other related information
shall assure that the cause of the condition that will demonstrate the fina,ncial qualifi.
is determined and corrective action taken to cations of the applicant to carry out the ac-
preclude repetition. The identification of tivities for which the permit or !! cense is
the signi!! cant condition adverse to quality, sought. The kind and depth of information
the cause of the condition, and the correc- dtscribed in this guide is not intended to be
Live action taken shall be documented and a rigid and absolute requirement. In some.
reported to appropriate levels of manage * instances, additional pertinent materia: may
ment. be needed. In any case, the applicant should
include information other than that spect-
XV!L QUALITY A$sURANCC RECORDS led if such information is pertinent to es.
tablishing the applicant s fir:ancial ability to ,
Sufficient records shall be maintained to construct and operate the proposed facility,
furnish evidence of activities affecting qual- Since separate findings of financial quali-
ity. The records shall include at lea.st the fica.tlons will be made by the Commission at
following: Operating logs and the results of the const'ruction permit stage of the !!cens- j
reviews. Inspections tests, audits. monitor- ing process and at the operating licerne
ing of work performance, and materials stage, the nature of the information to be
analyscs. The records shall also include included in the applicat.lon at each'of these
closely related data such as qualifications of stages is discussed separately.
personnel procedures, and equipment. In* It is important to observe also that bcth
spection and test records shall, as a mini- 150.33(f) and this appendix distinguished
4 mum, identify the inspector or data record- between applicants which are established
I,h,y
f er, the type of observation, the results, the organizations and those which are newly
q . acceptability, and the action taken in con- j
nection with any deficiencies noted. Records formed entitles organized primarily for the 'i
purpose of engaging in the activity for
@(d
H
.Tg
g
,; shall be identifiable and retrievable. Con-
sistent with applicable regulatory require- which the permit or license is sought. Those
;g M In the former category will normally have a
ments, the applicant shall establish require- history of operating experience and be able
< 2. ments concerning record retention, such as
(4"%C duration, location, and assigned responsibill-the to financial
submit financial
4 ty. results statements reflecting
of past operations.
With respect, however, to the applicant
which is a newly formed company estab-
b)j *'33' ' * T8
lished primarily for the purpose of carrying g
A comprehensive system of planned and out the licensed activity, with little or no i
g
periodic audits shall be carried out to verify prior operating history, somewhst more de-
compliance with all aspects of the quality tailed data and supporting docurtentation J
f s
,
assurance program and to determine the ef-
festiveness of the program. The audits shall
will generally be necessary, For this reason,
the appendix describes separately the scope
j
'
be performed in accordance with the writ- of information to be included in applica- .
ten procedures o'r check !!sts by appropri- tions by each of these two classes of appil- !
ately trained personnel not having direct re. cants.
sponsibilities in the areas being audited. In determining an app!! cant's financial i
Audit results shall be documented and re- Qualifications, the Commission will require
viewed by management having responsibill. the minimum amount of information neces. !
416
i
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1
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- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
_
. . ... ' '
CPSES/FSAR
25l functional Quality Assurance program. Additionally, auditing has been
'501
51-
conducted within TUGC0 to verify the implementation of this Quality
Assurance program. This auditing program evaluates the effectiveness -
of the Quality Assurarce progam for conformance with design -
j
requirements; determines whether the Quality Assurance program is ic
compliance with established requirements, methods, and procedures; and
l
verifies implementation of recommended corrective action, d
TheCPSESQA)rogramiseffectivelyadministeredandcontrolledby
TUGC0 through close association with, supervision and audit of the I
contractors who perform the requirements outlined herein. The QA
programs of the contractors are reviewed by TUGC0 QA and/r' its agents
to assure that they contained adequate requirements and procedures to
control the quality level.
1
Responsibilities for implementation., of certain of the nuclear QA b
O activities included in the TUGC0 QA program during design, procurement 3
,
'
and construction have been delegated to Gibbs & Hill and Westinghouse.
These responsibilities are described in the current revisions of the ,
41l Gibbs & Hill Project Procedures Manual and the Westinghouse WCA; 8370.
BLR is responsible for QA functions relating to ASME Code work only.
P h nsibility for the construction site QA and QC pro pimt }
lies with TUGC0 Site QA. ~This QA program is organized to provide an
intergrated plan under the direct control of the TUGC0 Manager, QA.
.
17.1.3 DESIGN CONTROL
50l T.he TUGC0 Quality Assurance Plan provides for several levels of design
control. These levels include the design control measures of Gibbs &
i
. Hill as the Architect-Engineer, Westinghouse as the supplier of the i
nuclear steam supply system, and TUGC0 as the designated engineering
!
50 organization is responsible for plant design. TUGC0 has delegated to
Westinghouse responsibility for the Nuclear Steam Supply System )
design. The remaining designs are the responsibility of TUGC0 or have i
EXHIBIT 2
AMr.NDMENT 50
JULY 13, 1984 17 1-14
.
_
.
CPSES/FSAR
been assigned to Gibbs & Hill. Gibbs & Hill, as Architect-Engineer,
, is responsible for overall system design including the interfaces of
Westinghouse and TUGC0 designs. The design coatrol measures including
, review, approval, verification and checking are contained in the
50
'
.
current revisions of the Gibbs & Hill Project Procedures Manual,
,
Westinghouse WCAP-8370, and TUGC0 CPSES Project . Procedures Manual.
The verification of engineering design control measures is performed
.
by TUGC0 through review or audit.
The TUGC0 QA program requires that the prime contractors meet
l 50
applicable NRC Regulatory Guidc requirements for all safety-related
activities. For a discussion of Regulatory Guide commitments, see
sections IA(N) and 1A(8).
,' The CPSES QA Plan requires verification that applicable NRC Regulatory l 50
Guide requirements have been incorporated in activities affecting
quality by design review, audit, and surveillance of prime
y contractors.
This verification assures that applicable regulatory requirements and
l
the design bases as specified in the license application for safety-
related structures, systems, and components for CPSES are correctly I
translated into specifications, drawings, procedures, and
instructions. Audit by TUGC0 assures that the prime cont. actor
4
organizations' design control measures include a, clear dsfinition of
design interfaces, review and approval of initial design, including
changes or revisions, and that personnel performing design reviews are
thoroughly familiar with the regulatory requirements and design bases
described in the PSAR/FSAR and are independent of those originating
the design.
17.1.3.1 _Desion Control for Preparation of Drawinos
Design drawings are prepared, reviewed, and controlled per applicable
s project procedures.
These procedures ensure that design drawings are 5
17.1-15 AMENDMENT 50
JULY 13, 1984
_ _ _ _ _ _ - - - - - - - - - - - - - - - - -- ~--
. . *
A
CPSES/FSAR
reviewed independently for completeness, accuracy, agreement with
k design concepts, and possible interferences. Further review is ~ {
provided by engineers of related disciplines who review for
6
consistency and compatibility with related systems and design ~
requirements. Procedures also call for supervisory review for content
and compliance. Changes to drawings or drawing input are subject to
the same controls as were applicable to the original.
1'7.1.3.2 Engineering Specifications
50 l The TUGC0 Quality Assurance program requirt.s that measures be -
25 l
documented for the translation of applicable regulatory requirements
and design bases into specifications. Written proce'dures require that
6
the specification be independently reviewed for technical' accuracy,
completeness, conformance with applicable regulatory requirements, and
overall acceptability. Additional review is provided by related
disciplines to ensure coordination and by project canagement for
overall project requirements. Written procedures also document
'
9
-
, resolution of changes to engineering specifications. Written
procedures further require documentation of the reviews.
17.1.3.3 Review of Vendor Eouipment Drawinos. Specifications, and
Procedurg
6
Upon receipt from a' manufacturer, these documents are routed through --
the applicable engineering disciplines to check compliance with
engineering, drawings, and specifications. A contfolled interface is
maintained with the manufacturer to assure resolution of
9 discrepancies. Interdiscipline and supervisory reviews of this l
process are performed and documented cs well.
17.1.3.4 Engineering Calculations
6
Measures have been established that control the preparation of "~
calculations. Written procedures outline the method of preparation to
.
AMENDMENT 50
JULY 13, 1984 17.1-16
l
.
_ _ - _ - _ _ - - - _ - - - - - _ - - - - - - - - - - - - - - - - - - - - - -
. - - - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _
-
~
. .,
.
-.
CDSES/FSAR
( ensure uniformity, validity of assumptions and input, as well as
~
accuracy of results. Procedures also require review of calculations
'
9
by an independent checker. Each review is documented.
.
*
~
h,i 17.1.3.5 Design Review and Verification
u
Safety related design activity is reviewed in accordance with a
i
formalized and documented system. The types of review used are:
,
1. Checks to compare information presented on a drawing or other
document with a definite figure, criterion, or design base.
,
'2. Superviscr'y reviews of design work, conducted by a superior in a
given discipline, of work by a project team member in that !
discipline.
3. Interface reviews, by personnel of one discipline, of work
( performed by another discipline to determine that the reviewer's 6
discipline requirements and commitments are satisfied.
4. Review by QA to determine that QA requirements are included as
appropriate for the item being reviewed.
j
Design verification to review, confirm or substantiate the design is
perforined to provide assurance that the design meets the specified
;
inputs. Methods of verification include but are not limited to,
Design Review, Alternate Calculations 3 ard Qualification Testing.
Procedures will define the actions necessary to report and resolve
deficiencies identified during design verification,
l
Written procedures define the actions necessary to report and resolve
deficiencies identified curing design verification. 50 l
!
17.1.3.6 Desian and Engineering Surveillance
(
17.1 17 AMENDMENT 50
Jul.Y 13,1984
.
__
,
.
, ..,. 7
.
i
.I CPSES/FSAR
In order to verify that engineering and design of nuclear safety
b 6 related structures, systems, and components are performed in {
,
accordance~ with applicable procedures these efforts are reviewed by
Quality Assurance through surveillance or audit. The scope and -
frequency of these reviews is commensurate with the complexity of the j
desigt: and past performance.
The surveillance and audit functions are documented in written
procedures.
17.1.3.7 Record Accumulation & Control
Records associated with the design activity are main'tained and copies
6 f these records stored as required. These records are audited by
, TUGC0 QA and/or its agents.
17.1.4 PROCUREMENT DOCUMENT CONTROL
l L \'- 50 l Appropriate requirements have been established by the TUGC0 QL.ality (
Assurance program to assure that procurement documentation is
]
controlled and accurately reflects applicable regulatory requirements, '
,
25 design bases, and other appropriate requirements, such as industry
codes and standards. Safety-related procurement documents and 1
! .
specifications require that vendors submit written quality assurance
programs consistent with the importance and complexity of the
material, equipment, or service procured. Such quality assurance '
programs are consistent with pertinent provisions of Appendix B to 10
CFR Part 50.
50 l
I
TUGC0 has satisfied these requirements as follows:
,
Selected review of procurement documentation for Q-listed materials. -
25
equipment, and services is performed. This review is described in )
17.1.1.1.1.
i
AMENDMENT 50
JULY 13, 1984 17.1-18 ,
4
.
i ('
- _ _ .
COMANCHE PEAK STEAM EL.ECTRIC STATION
QUALITY ASSURANCE PLAN
.
+#. g SECTION s 3.0
. .
_
DATE: 11/20/85
V '
- %g\( DESIGN CONTROL REVISION: 4 i
PAGE 1 OF 1
3.0 Desion Control
The design control process for CPSES begins with Gibbs & Hill, as ,
Architect - Engineer, Westinghouse, as NSSS supplier and TUGC0 as the
engineering organization. Selected scopes of design responsibility
have been assigned to EBASCO and SWEC. Overall responsibility for
construction however, remains with TUGCO. The design control process
is an ongoing function which includes design criteria, design review,
and design change. This process is carried out in accordance with
established procedures.
3.0.1 Desion Criteria
t
The preparation, review, approval, and certification of design speci-
fications are normally contracted to Gibbs & Hill and Westinghouse.
TUGC0 performs desiga and design verificatier. activities on selected
contracts. To the extent applicable, the hsign criteria will be
consistent with that specified in the license application and will
utilize the requirements of recognized codes, standards, and practices,
y, The responsible design organization translates these design specifications
into appropriate instructions, procedures, drawings, or specifications. 8
This function includes design interface control as well as the generation,
review, checking, approval and revision of design and construction speci-
fications, and design drawings.
3.0.2 Desion Review l
The responsible design organization reviews respective designs for
confonnance to design concepts, licensing design criteria, and regulatory
criteria. The design reviews are performed by individuals or groups
other than those who performed the original design. Changes to design
specifications or documents are reviewed and approved by the same
individual or group responsible for original review and approval unless
designated otherwise.
3.0.3 Design Chance -
Changes to the design are documented. reviewed, and approved by the
original designers or other authorized individuals commensurate _e wit.h
the,gntrols . applied to the original, design. These controls extend to
,
the disposition of field changes and nonconfonnances. Approved changes ;
are incorporated into or identified on the original design document.
The TUGC0 QA Division audits TUGC0 and contract engineering organizations
% to verify that the design process including design change is perfonned
in accordance with the approved program and procedures. In addition,
Quality Assurance organizations of other engineering organizations audit
their respective
procedures and design organizations to ensure compliance to approved
instructions.
rvuvn Tra 3
_ _ -
~
' - ' '
- _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
1
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PROCEDURE ISSUE
. BROWN & ROOT, INC. NUMBER REVISION DATE PAGE I
~
*
J06 35-1195
1
TITLE: ORIGINATOR: 1 hw N.- '- M7 #f2,/j,e/g-
" PREPARATION, APPROVAL
REVIEWED ,. dp /I /
~ ~
'M"/ F
AND CONTROL OF
QA/ h 4
'
OPERATION TRAVELERS" APPROVED BY [ - / /-(/IMDATE
MiMTRUCTION PR)XIECT MANAGER -
.
nRMS '
INDEXED
,
-.
- - . _ _ _ -
'
.
n .
CPSES
'
CONTENTS
1.0 REFERENCES
2.0 GENERAL l
2.1 PURPOSE AND SCOPE
2.2 QUALITY ASSURANCE REQUIREMENTS 4'/CONTR0k
2.3 AUTHORITY AND RESPONSIBILITY.Y
2.4
2.5
DESCRIPTION OF AN OPERATION TRAVELER
TITLES '
/ C/V#- /
gpQ
3.0 PROCEDURE
.g
; 3.1 BASIC PREPARATION SEQUENCE
3.2
-
; ENGINEERING REVIEW
.f' 3.3 QA/QC REVIEW
3.4 RECORD COLLECTION
l
3.5 LOT RELEASE AND CONTROL
~
! 3.6 TRAVELER CHANGE CONTROL
3.7 TRAVELER "IN-PROCESS" AND " COMPLETED" CONTROL
NOTE
.
Tiils document has been completely retyped for convenience
in issuing Revision 5. Vertical lines (change bars) appear-
.
ing in the margins indicate what information was actually
changed, added.or deleted by Revision 5.
.
.
'
EXHIBIT 4
l MN
,
-
...
O
- --
- - -
--
- . . .
,
4
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-
JOB 35-1195 ARMS
COMANCHE PEAK STEAM ELECTRIC. STATION INDEXED
'
, ,
INTERIM CHANGE NOTICE NUMBER __2_,,,,,,, ,
. This ' notice applies to: Construction Procedure -CP-CPM-6.3 , Revision 5.
The intent of this change will .(X) / will not ( ) be incorporated in the next
revision to the procedure or instruction.
This Change applies:
Untill Further Notice ( ) Until the next Revision is issued (X)
Only as follows:
CHANGE THE PROCEDURE / INSTRUCTION AS FOLLOWS: ,
(1) Delete Reference 1.5.
(2) Change Paragraph 3.1.3 to read as follows:
3.1.3 : After the Traveler is prepared it shall be submitted to QC for .
review. QA/QC will not be required to review each cable tray
hanger traveler as each operational document' will be identical ex-
cept for the Traveler number. Review requirements for ASME related
travelers are delinetted in Reference 1.4.
(3) Change' Paragraph 3.1.4 to read as follows:
3.1. 4 QC shall return the Traveler to the originator for distribution.
All signoffs will be on the " original" making it the valid working
document. . Component support traveler packages shall be controlled 3
in accordance with Reference 1.4. 1
i
(4) Change Paragraph 3.6.2 to read as follows: l
3.6.2 When design changes are received that affect issued and approved
travelers, construction engineering shall notify the superinten- !
dent 'immediately. The applicable changes will be made to the trav- J
eier and it will then be reviewed in the same manner as the original
issue. At the superintendent's discretion, work m?.y continue on the
traveler operations not affected by the design change. Changes to
component support traveler packages will be routed in accordance with
Reference 1.4.
Reason for change: Additional requirements.
1
This change approved by: , 1
0 m $ .--- --
Dep~artMent fleao
7/3//77
' Date
YRty Assurance 5A -2~7
Date
ra4JN]
Reviewed By:
A4& T-3l- 7$
pate ,
eroeece,es.ae,msy
.
. . . . .
O
l
p .
, . . _ . . . . ~ . . - , ; .: _
!
--
JOB 35-1195 $EN
COMANCHE PEAX STEAM' ELECTRIC STATION gg
INTERIM CHANGE NOTICE NUMBER 1.
oAM
',
This notice applies to: Construction Procedure CP-CPM-6.3 , Revision 5 .
The intent of this change will (X) / will not ( ) be incorporated in the next
revision to the procedure or instruction.
This Change acolies:
i
.
.
Until Fu'rther Notice ( ) Until the next Revision is issued (X)
-Only as follows:
.
CHANGE THE PROCEDURE / INSTRUCTION AS FOLLOWS: ,
1. Add tha following sentence to Paragraph 3.6.2:
-
" Changes to component support traveler packages will be routed in
accordance with Reference 1.5" .
2. Add reference 1.5 as follows:
*
1.5 CP-CPM-6.9
j
,
.
Reason for change: Clarification
This change approved by: .
& kn
Depattarent H6ac
-Sve e7p;s G/6/7f
'Da't e
A. _
vality AssQfance
le= L= *19
Date
3 9 CAerte
Reviewed By:
$h
Proceaures & Reports
b ~b" W
Date
.
.
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. . . .
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-6
, ,
BROWN & ROOT, INC. PROCEDURE ISSUE
.- '
CPSES NUMBER REVISION DATE PAGE
l
1
JOB 35-l'95 t
CP-CPM-6.3 5 12/13/78 2 of 11 j
1.0 REFERENCES
I 1.1' B&R, CPSES Construction Procedure, CP-CPM-6.1, '
" Preparation and Approval of Construction Procedures
And Engineering Instructions".
4
1.2 B&R, CPSES Quality Procedure, CP-QAP-5.1,
"Preparatiori and Approvel of Quality Procedures '.
And Instructions". -
-
1.3 B&R, CPSES Construction Procedure, 35-1195-SFP-2,
"B0P Records Filing".
!
1.4 B&R, CPSES Construction Procedure, CP-CPM <0.9,
" General Piping and Inspection Procedure"
l 2.0 GENERAL
., 2.1 PURPOSE AND SCOPE
. 2.1.1 This procedure describes the preparation, approval and con-
trol of operation travelers which may be used at CPSES to
control activities affecting quality. The requirements of
this procedure are to be implemented by affected B&R Construc-
tion and QA/QC personnel when the operation traveler system
is implemented for a given safety-related ("Q") activity. This
procedure may aho be used for Balance of Plant (Non "Q") con-
struction operations. If used for Balance of Plant work, state-
ments in this procedure relating to-QA/QC do not necessarily ap-
ply and the functions relating to QA/QC may be accomplished by
other B&R departments.
2.2 QUALITY ASSURANCE REQUIREMENTS
2.2.1 .The operation traveler system has been designed to fulfill
Duality Assurance criteria set forth in Regulatory documents
and codes and standards applicable during the construction
phase of CPSES.
.
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W @- seogs
u.
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BROWN & ROOT, INC. PROCEDURE ISSUE
CPSES NUMBER REVISION DATE
r) JOB 35-1195 .
PAGE I
CP-CPM-6.3 5 12/13/78 3 of 11
.
'
.
2.2.2 When implemented as outlined in this procedure, the operation
traveler system fully complies with the QA criteria and no
.
.
{
q .. esditional enntrols are required. If only partially imple-
mented, then additional controls in the form of supplementary
-
~ instructions may be required to meet the applicable require- 1
ments. The provisions of References 1.1 and/or 1.2 may be I
utilized to supplement a partially implemented system. .'
~
-
2.3 AUTHORITY AND RESPONSIBILITY .
2.3.1 . Signature authority on a Construction Operation Traveler rests
with either the Construction-Superintendent (s) responsible for j
-
the work or with the Construction Engineer (s) responsible for l
technical cuidance. . The site QC Manager is responsible througn
the discipline Quality representatives to assure that the system
,is 9[fectively implemented for the selected activities.
2.4 DESCRIPTION OF AN OPERATION TRAVELER
. ') 2.4.1 The operation Traveler (Figures 2 and 3) serves as a fabri-
"
, cation / installation / inspection checklist describing operations
necessary to achieve a quality end product in an efficient
manner. Accordingly, the details required and included on the
face of the traveler will vary depending on the complexity of
the operation.
2.4.2 General information included on the operation traveler
is as follows:
a. Part; serial or tag number and material description (s),
where applicable.
b. The department asrigned the task to perform the
operation (s). This.is normally'ihown in the space
, provided on the traveler but may be documented in an alter- 4
; nate manner for simple operations,
i c. Operation description, methc<ds, procedures (instructions) !
by number and revision and other information as required ;
to successfully complete the operation per applicable '
requirements.
rm 1
.
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BROWN & ROOT, INC. PROCEDURE ISSUE
CPSES NUMBER -REVISION DATE PAGE
l
e-)
( JOB 35-1195
'
CP-CPM-6.3 5 12/13/78 4 of 11
1
i
d. All dimensions and tolerances necessary to assure com-
pliance to design drawings and specifications. This in- ,
,
formation may be given by Reference, provided persons per-
forming the work have access to the Reference.
'
))
e. Any needed offsite operations or processing cited in the
appropriate sequence with all other operations.
f. Necessary instructions for handling, c~1eaning, storage and
preservation of items. ,
-
g. Required QC inspection, hold, or witness points. i
h. A bill of material for piping component supports.
2.5 TITLES
2.5.1 Titles, when used in this procedure apply to the specific
person or his designee.
^
. 3.0 PROCEDURE
3.1 BASIC PREPARATION SEQUENCE
3.1.1 Samples of the Traveler forms are shown in Figures 1,. and 2.
These forms may be obtained from the Construction Engineer. !
The operation sequence and necessary detailed information
to' be written on the traveler will be developed as a joint
effort between the B&R construction craft personnel responsible
for doing the workuconstruction engineering personnel re-
_sponsible for technical requirements, and 0A/QC personnel
responsible for Quality Assurance requirements. It is
desirable to i'nclude all required information (such as dimen-
sions, specification data, and required supplementary instruc-
tions) with the Traveler to make a complete " Traveler Package".
However, the inclusion of information routinely available to the
persons performing the work is not a requirement. The sequ E
tial numbers assigned to each operation on the traveler are
for identification purposes and are not necessarily a sequential
order of work progression.
(
*c
;
- j
-
.
s- .
1
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. . . .
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_ - _ _ _ _ _ _ - _ . __ _ _ _ _ _
.
. . . . . -
- -
.
,
l
BROWN & ROOT, INC.
'
PROCEDURE ISSUE
CPSES NUMBER REVISION DATE PAGE
JOB 35-1195
CP-CPM-6.3 5 12/13/78 5 of 11
3.1.2 The discipline construction engineer is responsible to assign
numbers to Operation Travelers, and to keep a logbook record
, of the numbers. The traveler numbering system is as follows:
'
Exampie, "MR79-001-5000"
-
l
M = discipline (Mechanical, electrical, l
, etc.) l
.
R = department (rigging, rebar, pipe,
concrete,etc.)
.
79 = The calendar year in which the Traveler
was written.
001 = The individtial sequence number identifying '
a particular Traveler.
!
5000 = The turnover (start-up) system number for
.the activity described on the Traveler.
*
NOTE
For mechanical component supports the traveler '
number will be the component support identification -
number (if more than one traveler is required for j
a specific support, the mark number shal1~ be suf-
fixed by a-1 for the first additional traveler, etc.).
For electrical cable tray supports the traveler num-
ber will be the support mark number prefixed by " Ele-
79-CTH" (79 represents the year in which the s
traveler wa: prepared). These are the only exceptions {
to the above numbering system.
3.1.3 When a Traveler is prepared and ready for signature, it shall
be submitted _t_o 0A/0C for rev3w, the addition of inspection
hold or witnes's points, ANI revies, and signature. QA/QC will
-
not be required to review each cable tray hanger Traveler as
each operational document will be identical except for the Tri.v-
eier number.
3.1.4 Af ter reviewing and signing, QA/QC shall return the Traveler
to the originator for distribution to the field; except
component support travelers shall be sent directly to weld-
ing engineering to be distributed in the same manner as WDCs
per Reference 1.4. 311 QA/QC/ANI/ Engr. signoffs will be on
,
I
the " original" making it the valid working document. At the
discretion of the QA Manager, a copy of the traveler may be
filed in the QA vault for record retention purposes. l
_ M% '
. . . . . - - . . . - . . . .. . . . . . . . . - _ . . . . . . . .. . . . . . . . .
. . _ .
-
_
__ _ -_--_--- - " - - - - --~ ~ ' ' ~ ~ ^
-- -
E. i
. ..
. -
.
_ ._ _
BROWN & ROOT, INC. PROCEDURE ISSUE
. CPSES l NUMBER REYISION DATE PAGE j
JOB 35-1195 1
. CP-CPM-6.3 5 12/13/78 6 of 11
l
3.2 ENGINEERING REVIEW '
'
3.2.1 ' At the request of the responsible General Superintendent, the i
Chief Project Engineer through the responsible Discipline Engi-
neer shall complete reviews of applicable drawings, specifica- ,
tions, procedures, and weldino requirements to assute,_under- d
. : standing of and compliance with applicable design and construc- '
tion requirements.
'
3.3 QA/QC REVIEW . l
,
3.3.1 The Quality representative will perform a spot check of the com- i '
pleted forms for accuracy of information and will verify that.
required inspection, hold and witness points have been included.
He will assure that quality documents have been prepared per the
provisions of Reference 1.2 and are referenced in the Operation
Travelers as required to fully implement the QC functions.
3.4 RECORD COLLECTION
-
3.4.1 Traveler packages shall remain in the work area until the l
work described by the package has been completed and accept-
ed by the responsible QC Inspectors. Component support
travelers may be returned to the FWTC (ite the same manner
as WDC as stated in Reference 1.4) at the end of each work
shift or when the fini.1 sign-off is completed.
3.5 LOT RELEASE AND CONTROL
3.5.1 Let Release
3.5.1.1 Quantities of identical detail parts or items may be authorized
by the Quality representative on one Traveler package release
provided the parts or items are dimensionally identical and that
material control and/or traceability requirements can be accomo-
dated without creating an extensive ard/or confusing record keep-
ing or material marking system. The quantity of parts or items
to be included in one lot may be determined by the quantity of
parts required to fabricate one assembly or sub-assembly, or a
quantity of parts that could remain as one lot until all parts
or items are completed without jeopardizing the production
schedule.
.
[ W_ '
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.
.
_
&
_m._ _
. _ _ - _ _ _ _ _
.. . . .. . . .. .
. -
.
BROWN & ROOT, INC. FROCEDURE ISSUE
CPSES NUMBER REVISION DATE PAGE i
JOB 35-1195 I
CP-CPM-6.3 5 12/13/78 7 of 11 l
<
3.5.2 Lot Control
3.5.2.1 A quantity of identical parts released as a lot on a single
Traveler package release shall remain together until all oper-
ations have been completed and accepted by inspection, and the t
parts / items have been delivered to storage or to another Trav-
.
~
eier release for subsequent assembly / installation. If a non-
conformance is detected on one or more parts / items of a lot dur- 1
ing the operations, the confoming material and Traveler shall i
* remain in a. designated hold area until the nonconformance has
been adequately dispositioned. The site QC Manager may author'
-
ize certain exceptions to this rule. Such matters will be ,
h'andled on a case basis.
.
3.5.2.2- If certain parts / items are dispositioned 'iScrap" the quantity
of the lot on the Traveler shall be reduced to the quantity
found to be acceptable by inspection. Replacement items,
when required, shall be issued on another Traveler, reflecting l
a new release number. If an item or items in a lot requires 1
repair, such as welding, the entire lot shall be serialized ;
and appropriate records prepared to establish traceability for !
repairable items as required by applicable co(es and specifica-
tions.
3.6 TRAVELER CHANGE CONTROL
3.6.1 _All changes, regardless of their significance, must be doc-
umented on the Traveler, denoting the operations affected,
description and authorfty for the required change, and the
Quality representative's approval. The revision number and
a description of the change will be noted on the traveler
.below'the last traveler operation of the oriainal issue. If
necessary the revision description may be continued on a
continuation sheet. The back side of the traveler for piping
component supports will also depict the revision in the re-
vision block.
3.6.2 When design changes are received that affect issued and aoorov-
ed travelers, construction engineering shall notify the superin-
_tendent immediately. The applicable chances will be made to
the traveler and it will then be reviewed in the same manner
as the oricinal issue. At the superintendent's discretion,
work may continue on the traveler operations not affected by
the design change.
3
, - ~ ~ = ,
w
..._........._.......__. . . . . _ . .. . . . _ _ . . _ . . . _ . .
'
__ 9
, _ - - - _ _ _
-
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. ,
.
.-
p
BROWN'& ROOT, INC. PROCEDURE ISSUE
' -
CpSES NUMBER REVISION DATE PAGE i
, JOB 35-1195 -
'
CNCpM-6.3 5 12/13/78 8 of 11 ,
~
1
3.7 TRAVELER "IN-PROCESS" AND " COMPLETED" CONTROL
3.7.1 Travelers shal.1 be maintained complete throughout the construc-
'
tion process. Each QC Operation requires tho : initials and date*
l ' by QC denoting the inspection status. This shall be accomplished
at the completion of each operation and prior to moving parts
l or assemblies to the next operation, unless otherwise . I noted on the Traveler.
.
l 3.7.2 It is expressly prohibited to proceed beyond any hold point
requested by the Quality representative without his. approval,
' reflected by his initials and date at the applicable operation
on the Traveler.
3.7.3 The Ouality Control Manacer is charoed 'with the responsibility
.for assuring that all operaticn Traveler instructions have been
complied with and all previous operations have been oerformed
and accepted. The Discipline Inspection Supervisor is responsi-
ble to the Quality Control Manager for the asscratice that all
completed items, assemblies or sub-assemblies meet the require-
ments of the applicable drawings and specifications - by
inspection and acceptance of all items denoted on the Traveler
end associated check lists or instructions. After all operations
listed on the traveler have been completed and appropriately
.
sigred, the department supervisor implementing the work will
L
submit the traveler to construction engineering..or to the
FWTC for component support travelers. The discipline con-
struction engineer will log such receipt of the traveler
and in turn if "Q" related, submit it to the QC Department ,
for incorporation into the CPSES documentation system, l
Travelers for Non "Q" items will be processed in accordance
with Reference 1.3. ,
-l
1
I
l
_
..
, - _ _ _ _ _ _ _ _ _
.
*
. . . . - '
t ,,
[ .
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*
BROWN & ROOT,.INC: PROCEDURE ISSUE
... CPSES ' NUMBER REVISION DATE PAGE
!
JOB 35-1195
CP-CPM-6.3 5 12/13/78- 9 of 11
,
.
FIGURE 1A
SAMPLE TRAVELER FIRST SfiEET - Front Side
.
C.3.'T2; C. 3 CF12A7"C's UA'.T *.2 23-6193 .
. Ga'issi% P Md5Iat . 0: P"i "#S--- fv"1"a
'
e m... law.a .
_%rsstatta ca.stine of bette utd ?sess pnmmena:c
etat 1117 *ve . I t- d ' s.
-
j
;. y u1:.,m.m
u-c.n ro : : ara F,m: em samh .,*.e_m i.u f.Lsss.:n
: . - i i v.t s en t r- i
gg g _ W. h eam =
.i. V 9 tt g gg * "
ggy gg g "gy c . f. b. , ei 4 '. . u . 44/0C tra M'I l
gT 12TM3r '_ v /s '
.g ,,
,
... 6m. k,m== -
l'%"i .:
1 Kpe L.sk.all tanssetary 3* 13etive en m: sala 43 ei Lak 01 estag
amt:aa ei home 4ad beauLLtg t.sel. I'
1 CCTF) thapact all srsalas to mha Jere sasy ar9 sealed em Oe eng. .
, Cf. sida. bet.h *mak.a.
'
,, J Pipe .
Ps.1.1 Tank c1 etth dansamas11. sed'meaa estas 4tocru as m.
*
6 QCf7) ssteet &L1 emida so *.anh 01 for lashs.
C: .
.
3 Pies aeta11 home menneettaa Tank 01 and 02. taka ese estism as
meesJa d3 et tana 02 sa - ansmer sa sa samp 1.
4' Pipe % ralvec 'te alisw tanta to ete&L.sa.
7 QC:7) utar antar ta bee tasha ta as same leesi. Lassall 13 pump
Pipa ta Isak 01 and diarmaast heee at Taak 02 laavtag valve ta'
place.
4 Fipe Pume ?=='t ad-- of estar free tant C1 to tant 02. Cae watar
tres 33 samsar to assolatal? #11.1 taan C2.
9 CC"4 l aspers all unida so *.aak C2 for lenha. .
Cr.
la Pape
:Taaster votar nach ee SumLear:11and vacar steente tank.
.
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.
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BROWN'& ROOT,_INC. PROCEDURE ISSUE.
.~s. CPSES ' NUMBER REVISION CATE PAGE l
g 0 JOB 35-1195 I
CP-CPM-6.3 5 12/13/78 11 of 11 j
1
l
l
.1
FIGURE 2 i
!
I
SAMPLE TRAVELER CONTINUATION SHEET
- -
cas:re::cx orti.s :. s ix.r.:.2 c::.=2:::3
.
NN M* C l*T P13 d ".;;3
+ * '
PACT _ 0F__ ,
* *
FIDAAD ST -
gA;g ,
t?tTTED ST - 34 g ,
A" N SA*T
44 G0
er. No. !'. ". I"7 11 :n DG A.E
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-
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ARMS ,-
INDEXED i
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.
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'
CONSTRUCTION OPERATION TRAVELER 35 1195 q ,
TRAVELER NO.
@ME-79-248-5500 @ EQUIPMENT NO.
TCX-RCPCRV-01 @ NIT 2
NO. QUANTITY
1
PAGElOg h ,'
,,e m""%s
ACTIVITY DESCRIPTION REFE.RENCE DRAWINGS
eactor Vessel Innta11arion App nal m
EPEC./ PROC./EN'G. INSTR. LOCATION SYSTEM
MCP-1 NM Containment 42 n.c.
PREPARED BY Y O' DATEM*2.o M A DEPT MO - M-
's REVIEWED BY O DATE Y~# 'O QA/QC-E10G ANI
'.N w.trevss.um1& LeMD
*A
4 -io - H
'
l ANI REVIEW 8 DATE -
*
' EN.C $
O P. N O. DEPT. OPERATION , , . *
ENG ANI
%
d
General Notes:
'
f (1) All support nuts and bolts shall be -
tightened to " snug tight" condition. Snue
tight shall be defined as the condition
which insure that parts of'the joint are
brought into good contact with each other.
This can be attained by a few impacts of
an impact wrench or the full effort of a
man using an ordinary spud wrench.
Reference the appropriate.
' Traveler for rigging and lifting require-
q " ,
g. '
,
ments of the reactor vessel.
,,d g 1
Clean Ii$ R.V.
'
'
(2) Support Shim with acetone 8~
,
prior to installation.
.M{
(3) Reference Drawings:
B :g
W 1210E59--- R.V. Support Hardware
QA
OCT 02 1979
g 14 m 27--- Reactor vessel Supports e,o RECORD ,,3
.
L
.
,,j
.,_ , , .
.. C-E 10773-171-004----R.P.V. General y,y [go
-1)LES *NOTED Arrangement
R-
g. gg
*
80H AShURA NC C-E 10773-171-005----R.P.V. General 'N'
Arrangement O
-
wi. y s, (
l M/W Install the R.P.V. Supports and Shoes per N
* -
,
Drawings 1210E59 and.1457F27. The min.
~
7-'
,
, engagement for the guide pins is 2 ". Therefore ,
-- ,j *
, "the following gaps between the Support Shoe and ,
l
pin top ~ surfaces are as follows: ., j
.
w, . 1
'
@ -I
*
, EXHIBIT 6 l
.
*
' "
,.*
*
!
l
- _
l
. _ _ _ _ _ - - - _.
.
,. . . . _ . .
.,
a
a e 'e
.
*
.
A
-
- l'" '
CONSTRUCTION OPERATION VAVdLER CONTINUATION
TRAVELER NO. ACT!VITY DESCRIPTION
ME-79-248-5500 , Reactor Vesse.1 Installation PAGL,OF[f
2
PREPARED BY k DATE NOM -
REVIEWED BY & ~
DATE
ANI REVIEW Mb
_
_ DATE -
<
QA/QC
OP.NO. DEPT. OPERATION _
ENG ANI
g Hot Leg--Shoe to pin = -2 3/8" to -7/8"
( Cold Leg--Shoe to pin = v3/8" to 81 1/8" W
m
f GhuttM Y?
"::hi .
. thc eiC. chi.s a 1 .;/4 -
-
wr. . Pull M 71
The side imbed restraints to the side shim and i
support colums prior to concrete' pour. O *' '
clearance must be met after the pour. 0"
clearance shall be less than .001"? The' side
shims are to also be modified per CMC-4260'.Euf
Weld the side shims to the R.P.V. Gupport per I"4 * i
EPM-1457F27. QC to inspect Welds and attach applfca-'
ble NDE Reports.
The optimum elevation to set the R.P.V.
Support shoes is as follows (based on R.P.V.
A
-
As-Builts):
676 -----824'-5.754"
1580 ----624'-7.784"
2470 ----824'-5.755"
338 ----824'-7.777"
'
The shoe bearing surface should be as level as
possible, not be exceed + 1/8". The supports
- must be within 1/8" vertically, k" radially,
" tangentially. Record final readings on
Attachment # 1 . Obtain appropriate signatures,
y The Leveling screwcshall be set as close as -
17 feasibly possible to the following elevations:
ft"
'
6 70 ------ 82 4 ' - 7. 0 0 4 "
1580-----824'-9.034"
247 -----824'-7.005" ,0g %-} ,
y.3380-----824'-9.027"
FOR NORMM i
'
I
'
$he leveling screws must project 1" min.--lh"
. max. above the shoe bearing surface. ~
t. . ' 'V'
;
!
%p& Nm
* uM Aio. d a g tu. e/w
e,1+ 4 W. SW Ic ,.
H w WMYU 4% A *Y WPN
w cw A isd m+
M pim m A$ regN %% Nosf V CAm.a.f4 %b-
A M v h .W &
,
,,,,,,,. . 3...... . .. + . ..
..
,- . .:. f*.
.
'
.
[ ~ ,' CONSTRUCTION OPERATION TRAVELER CONTINUATION
TRAVELER NO. ACTIVITY DESCRIPTION
ME-79-248-55001s Reactor Vessel Installation PAGL30
PREPARED BY AA DATE EO M
REVIEWED BY
DATE ~#*
ANI REVIEW ** OATE
t
QA/QC
oP. NO. DE PT. OPE R ATION
ENG ANI
#
2 M/W Lower the R.P.V. The vessel should be level
to + ' " while suspended from the crane. The
'
QCW
vessel.must be orientated such that the inner
and out monitor tubes straddle the 2700 azimuth.
Lower the vessel to the point of contact with
the leveling screws, taking care that the
vessel weight is fully imposed on all screws.
Raise any screws not in contact with the under -
side of the vessel support pads.
3 M/W Level the vessel to within .0005" per foot
(.007" overall) on the internals seating
flange thru.the access covers in the shipping
*
fixture. Raise the vessel and adjust the
1eveling screws as necessary. Top of the
seating flange should be set at elevation
832'-10.058".
Maintain vessel orientation using W dupplied
instruments in the four keyways. Align the
vessel to + 1/64" of containment axis. A
worksheet Tor leveling readings is attached
for field use.
4 F.E. After obtaining proper elevation, level and
sj a{
orientation, recheck the calibration of all
instruments to be sure no errors have be h @u
introduced. off pwsc/%s/.s
5 M/W
%} 1-5- 79
Take height measurements between the under-
h "
,
*
QCW side of the vessel support pads and the
support shoe bearing surface at four points 7p
and record on Attachment # 2 . These results
must be no less than 1.00". Also record the
. ' reactor cavity temperature.- QC to initial and
date Attachment 2. Q4pyy,g- 900 g,
6 M/W Machine the permanent bottom shims to
QCW dimensions of Operation No.J. Tolerance to be
]
iME
..
. _ _ _ _ _ _ _ _ _ _ _ - _ _ . _ _ _ . - - - - _ - - - - _ - -
_ _ _ _ _ _ _ _ _ _
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;
I '.~ '. CONSTRUCTION OPERATION TRAVELER CONTINUATION
TRAVELER NO. ACTIVITY DESCRIPTION 4
E-79-248-5500 s Reactor Vessel Installation PAG {J g
PREPARED BY L DATE _D ED } %
# b {
REVIEWED BY - CL DATE
~
ANI REVIEW 'O DATE
i
CA/QC I
,
OP. NO. OEPT. OPERATION ENG ANI
i .001" - 0", temp. + 5 0 F.
l
l
7 INSVI, While bottom shims are being machined, apply g6
ggg R.P.V. insulation per manufacturers supplied ,g
drawings and instructions. QC to write inspection
report as required.
8 M/W Raise the R.P.V. and lower the leveling screWE
QCV until they are .375" i .010" above the bearing
surface of the support shoes. Install the hold 7-fyf
down nuts.
9 M/W Insert the bottom shim plates. Do not allow
QCV the bottom shim plates to be held off the <
bearing surface of the support shoe by the
leveling screws.
10 M/W Coat the top surface of the vessel pads with
prussian blue. Lower the vessel monitoring
.the vessel axis to the containment axis.
11 M/W Lift the vessel and check for surface centact h' ,g
between the top of the shim plates and bottom
QCW 4,-gu t'
of the support pads. 75% surface contact is
7 O required. lisnd:d Msc sh tm @l sw a nd. rapt @ 9fo de s
T4Ge#8A -
Ma to tttt1WetSheed 6tmt3C5WMM A8cittspfpary. g ,
l ' 034FFff
CC2 o9-
av 12 M/W After required contact area has been met,
Jp4 QCV remove prussian blue from the contact surfaces y.
7
g)
gg *
and coat the top surface of the shim plates
with "molykote type Z" dry film lubricant.
yg"dp3 Buff to improve finish. l
l
!
'- # 13 M/W Lower the vessel onto the shim plates.
the leveliness and axis orientation.
Check h.1
1
%h5
, l \
- _- 1
_ ._ _ _ _ _ _ _ _ _ _ _ - _
. . . . .
1
,- '
-
%.. l
.- -
['., CONSTRUCTION OPERATION TRAVELER CONTINUATION
'
TRAVELER NO. ACTIVITY DESCRIPTION
9
ME-79-248-5500 , Reactor Vessel Installation PAGE), g
DATE NO)%
'
PREPARED BY - -
REVIEWED BY - 1 ~
DATE _
ANI REVIEW $ DATE
cA/od
OP. NO. D E PT. OPERATION ENG ANI
14 M/W Take gauge readings of the spaces on either [
QCW side of the vessel support pads and record on J
Attachment # 3 . Also recorded cavity ~3 0~M '
temperature, gof
15 M/W Machine the side shims to the thickness
recorded in Operation # 14 minus .020" for
D.
QCW .
7,g
cold clearance. Tolerance i,s + 0, .001" 9
temperature + 5 F. gg og
_
16 M/W
Coat the surfaces
be in contact of the
with the sidesupport
vessel shims pads
which wilfR)
QCV
with "molykote type Z" dry film lubricant. g,g
Buff to improve) finish.
17 M/W Install the side shim in the support shoes.
Raise the vessel tc, a height necessary for toI:
installation of the shims. Bolt the shim
keepers onto the support shoes.
18 M/W Lower the vessel and check levelness and
vessel axis for orientation with containment
axis. Record and obtain approvals on
Attachment # 4 .
k 19 M/W
QCV
Verify cold clearance of .320" to 0"
for each side shim. sec PNnch w s' ~
.005"
3d Mro
.
7.gq? ,
20 (B QA review of operation traveler.y 7 Mrv N f
7
FOR INFORMATIONUNL f
1 1 WLO A S5emble RPV Su ppod Colu mn/%e c. 9r l
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.
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. CONSTRUCTION OPERATION TRAVELER CONTINUATION
! TRAV5ER NO. ACTIVITY DESCRIPTION )
!
A4E *79 . 2 4 8 . $ $D 0 @eg e4gy Veml 3 uk llM
4 PAG L __ ,jg
7
i PREPARED BY- @# .
DATE M'3 ' M j
HHVIEWED BY
* C -
DATE
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-
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DATE
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OP. NO. DEPT. OPER ATIO N ENG ANI
: ,
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p . V ..t.., . .
*
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_ CONSTRUCTION OP5 RATION TRAVELER CONTINUATION i
TRAVELER NO, ACTIVITY DESCRIPTION
ME ')9 t f 4 9 55bo Os4 W64,f fWfcJQ PAGdOF1 ,
'
PREPARED BY M .DATE h !O 't
l' REVIEWED BY DATE 7"' M **
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( Cent
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) .,*, CONSTRUCTION OPERATION TRAVELER CONTINUATION
TRAVELER NO. TiVITY DESCRIPTION
44C 7 9- 2.VG , 55N ^<lrv Vebsej .7 dldq PAGdOF[
PREPARED BY- b- DATE 73
REVIEWED BY
V
DATE 7 N- 2 f
ANI REVIEW DATE-
CA/OC
,
OP.NO. DEPT. OPEF ATION ENG ANI
Cleewovoca for k &% WcAe
w;ki n M. -hter m a -
a U'Iths
LU \$ %* S %'m . .. . .'A W . )
. . . . .
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{ pnoctrninas I
o , l
-
MR. JOROAN: The purpose of this meeting is to obtain i
3' ,' -information from the citizens Association for Sound Energy
4 . .
4
related to Contention 5 by the Bearing Board. A similar i
5l meeting will be held with Texas Utilities Generating
1,
6 s-
Company this afternoon. This information will be combined
7
l with' other information collected by the panel to form the I
.
f
6l basis for the NRC staff determination'regarding Contention '
i
9
5. The text of Contention'5 from the Board Order is as l
10
follows, and'I will read into the records -
t
, - 11 "centention 5: '
The Applicants' failure to adhere to !
12 t
quality.assuance/ quality control provisions. required I
13 i by the construction permits for Comanche Peak, Units
I4
l
l 1and2,andtherequ'irementsofAppendixBof.10CFRl
15
Part 50, and the construction practices employed, f
16 I
specifically in regard to concrete work, mortar
.
4
. i
1- 17
blocks, steel, fracture toughness testing, expansion '
'
16
,
joints, placement of the reactor vessel for Unit 2, j
'
I 19
,
welding, inspection and testing, materials used,
20
t
craft labor qualifications and working conditions (as !
7,1
[ .they may aff ect QA/0C) , and training and organization
r i ,
'
22
of QA/0C personnel, have raised substantial questions
23 .
l
as-to the adequacy of the construction of the
' - g
'
24 facility. i
.
.
As a result, the commission cannot make
25
the findings required by 10 CFR 50.57(a) necessary !
EXHIBIT 7
'
. , . , , ,
,
1
_ - - _ _ _ - _ _ _ _ _ - _ _ _ _ - _ - - i
_. ___
_ _ _ _ _ _ _ _ - - _ _ - _ _ - - - _ - -
.
,.., .
Y =; ? <-
4
I
for issuance of an operating license for Comanche '
,, , --
'
-
Peak.' And then there is a reference to the
!
3
, material. +
4
A panel of senior NRC managers was established by the
. ..
.
0 '
HRC Executive Director's Office on December 24, 1984,*to '
s >.
6
, evaluate Contention 5. The membership of the panel was f
I
-
' (
revised' January 16, 1995. The membership is comprised of
'
I*
the following persons drawn from various NRC Offices:
(
9
d
t
to Myself, Edward L. Jordan; I'm the Chairperson;
11
I'm the Director of the Division of Emergency
12
Preparedness and Engineering Response
,f
-
13 , -- . :
14 -
Dick Vollmer, Deputy Director, IE
15
16 j l
,
8
And if you will nod or something when you're '
I 17 introduced so everybody will recognize you. l
18 I
{' .
i
l
3
, 19 ! Alan Herdt, Chief of the Engineering Branch,
t
! 20 Division of Reactor Safety, Region II
:
2 21
:
h' 22 Robert Warnick, Chief, Projects Branch No. 1,
l 23 Division of Reactor Projects, Region III
24 l
*
:
I
25 Jim Sniezek, Director of the Regional Operations i
'
i l l l
. I
, .... . . ,.
*
1 t 1
-_____-_________________-_____.------.--Q
_ _ _ _ _ _ _ _ _ - _ _ __ _ _ _ _ _ . _
B u
'
.
o
-
(. h c.d Ovla<N
_ . . ~ - . __
/
/ 1. A11enetion Category: Miscellaneous 2, Reactor Pressure Vessel
~~
alin;acion ixumoers: AM-3 and 4A'-I3b.
3. Characterization: Two allegations concerning the reactor pressure vessel ,
(RPV) are characterized as follows: G% c.
t~- &
a. It is alleged that during hot functional testing (HFT) expansion {
caused the reacto pressure vessel reflective insulation (RPVRI) to
come in contact with the concrete biological shield wall (AM-3).
b. It is also alleged that the Unit 1 RPV is located 3/16 inch to the
west of the north-south centerline through the containment building
[
~~~
(AM-23b).
4. Assessment of Safety Significance: The NRC Technical Review Team (TRT)
reviewed the Final Safety Analysis Report (FSAR) for verification of RPV
reflective insulation quality class; background material in the NRC
Inspection Report 50-445/83-34; 50-446/83-18 and the affidavit of Doyle
Hunnicutt clarifying this report; Brown & Root (B&R) construction opera-
tion traveler 35-1195; and Westinghouse (W) Field Change Notices (FCNs)
TBXM-10609, 10611, and 10612. The TRT also reviewed photographs of con-
struction debris obstructions between the RPVRI and the biological shield
and discussed all of these documents with the Texas Utilities Electric
l Company (TUEC) Mechanical Engineering Supervisor, the W project manager. I and the TUEC heating, ventilation, and' air conditioning system (HVAC)
startup group leader. The TRT also reviewed documentation for het func-
tional test (HFT) No. ICP-PT-5502 for any information concerning the
allegations, but found no specific notations about them.
The Comanche Peak Steam Electric Station (CPSES) FSAR, Volume XIV,
Appendix 17-A, classifies the RPVRI as nonsafety-relatad. The support
ring (a support channel) for the RPVRI is part of the RPVRI; therefore, it
too is considered to be nonsafety related. The only function of this sup-
port channel is to support the refective insulation. It is not needed for
the safe shutdown of the plant but simply insulates the vessel. In this
case it assumed importance only because of its effect on adjacent safety-
- related structures or components. A Westinghouse FCN (TBXM-10609) dated
' h Sectember 27. 1983, documented an unacceptable condition which was identi-
fied during hot functional testing. Actual air temperatures during HFT
were 288*F near the reactor vessel flange versus 150'F maximum in the cool-
ing annulus between the RPVRI and the shield wall. Similarly unacceptable
temperatures were noted (150*F actual vs 135*F allowable) in the ex-core
detector wells. TUEC letter TX5054 reported extreme temperatures up to
314*F. Further examination by W personnel revealed that cooling air flow
was restricted by the RPVRI support channel because of construction debris
between the RPVRI support channel and the steel-lined concrete biological
shield wall and because of restriction by the support channel. The debris
was removed by a remote technique and the gap was fiberoptically inspected.
Instead of the nominal design gap (cold) distance of 7/8 inch between the
support channel and the shield wall, this inspection identified cold air
gaps as follows: a 7/8-inch air gap extending one quarter around (90*)
EXHIBIT 8
K-99
_ - _ __
.. l
z. .
l *
f
i !'
,
L
j i
i
l ,
'
the annulus circumference, a 1/2 inch air gap extending one half (180') j
i
>
around the circumference, and a 1/4-inch air gap extending around the '
-
l remaining quarter (90') of the circumference.
N ,
} The TRT discussed the field change notice with the TUEC Project Mechanical
. Engineer and the Westinghouse Site Manager. Specifically, the staff asked
the reason for there being too little space between the reactor vessel
insulation support chanr.cl (which supports the reflective insulation) and
the biological shield wall. The TRT learned that the original Westinghouse
a specification required the support channel to be inteide the insulation, j
t but TRANSCO Inc., the vendor, requested a design change to permit the sup- !
f4 port channel to be placed outside of the insulation. Gibbs & Hill Inc,,
the Archii.ect Engineer, did not incorporate this change into the design nor
'f did they consider the impact on the cooling of the reactor cavity; thus, i
there was too little clearance between the outer circumference of the sup- I
L port channel and the shield wall, which resulted in restricted air flow !
and overheating. j
.
Y T
,
During the HFT,60n_dply,JJk_U83, they reported the HFT deficiencytestde ,
I
L 0- I
[ N.Inr(11y)
10JJijLitem to theonJugntJ5.,1983,
_NRC and formally reported the
completing deficiacy
their as a in
reporting 10 CFR
TUEC Part {
tii ) letter TXX-4054, dated leptember 26. 1983. Tn correct this deficiency
.
,j TUEC modified the insulation support channel by cutting holes in the top
i and bottom flanges of the channel to allow sufficient air flow and heat
i
'
removal and to ensure proper operation of the ex-core detectors and pro-
tection of the biological shield wall. TUEC made this modification in
i
t accordance with W procedure MP 2.7.1/TBX-3, dated ,0,gdo,ber e 1,1983. In
F
addition, the ex1 sting insulation seals and heat removal capacity were
,
improved. Further discussions with the TUEC engineer revealed th't a air i
i flow tests had been performed since the Unit 1 support channel was
t modified; however, final results of these tests will not be known until ,
the HFT is redone. The retest was scheduled, completed, and is being j
evaluated. l
,
1 : The TRT found that the 50.55(e) report of the corrective action taken
d regarding this deficiency did not include determination of the underlying
a cause of the deficiency. In addition, the report included no d!.scussion
y of the effect on Unit 2 or how such a deficiency could be prevented in
O Unit 2. However, TUEC did fiberoptically inspect Unit 2 for debris or a
[ similar gap, and found no problems. The TRT determined that the areas
! : where debris entered the gap have been sealed in both Units 1 and 2, and
TUEC anticipates no further problems with debris,
,
l
1
p '
The TRT also evaluated the allegation concerning improper placement of the
j % Unit 1 RPV by reviewing RPV construction operation traveler (C0T) No.
:! np#
Q
35-1195 and the field survey note, " Final Setting Alignment," dated ,1une
29, 1978. In addition, the TRT reviewed the W " Mechanical Service Manual "
;
l which includes procedures for setting the RPV7 with the W project reanager
"
-
to determine the importance of the location of the RPV relative to the
centerline of the Containment Building. The W manual states that align-
, ment with other nuclear steam supply system (RSSS) components is tfie most
K-100
t
, . .
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ . _ . - - -
_ -_ _ _ _ _ - _ _ _ _
. -
I ,
l
critical location factor, and alignment with the center of the Containment
Building is of secondary importance.
The Unit 1 RPV is alleged to be misaligned by 3/16-inch; however, opera-
tion No. 7 of COT No. 35-1195 shows a setting tolerance of i 1/4 inch. ]i
The alleged 3/16-inch misalignment is within this tolerance. Attachment
35-1195-MCP-1 of COT No. 35-1195, " Alignment Location Record - Alignment )
Final Set," shows the maximum RPV deviation from the north-south and east- l
west centerlines of the Unit 1 Containment Building to be 0.003 inches i
which is within the specified tolerance. The TRT reviewed installation
records and determined that the critical relationship of the NSSS compo-
nents to each other, as well as to the Containment Building centerlines
(N-S, E-W), was accurately maintained during installation of the reactor
pressure vessel. l
5. Conclusion and Staff Positions: Based on review of documentation and Tabu
discussions, the TRT concludes that the RPVRI did make contact with con- R m re, !
i
struction debris, but did not contact the , teel-lined concrete biological y,,5,,
shield wall as specifically alleged. During fiberoptic inspection, TUEC
personnel observed no visible damage to the reflective insulation, and all
corrective modifications were accomplished and accepted in accordance with
procedure MP 2.7.3-TBX-3 and FCNs TBXM-10609, 10611 and 10612.
The allegation, as specifically stated, cannot be substantiated, although
it does have some merit because an unsatisf actory condition did exist in .
that the reflective insulation made contact with debris. However, this W
_allecation has both safety significance and gereric implications beciause of 6P
peripheral issues; 1.e., failure to assure that proper design changes were
communicated between organizations, failure to determine and report the un-
derlying cause of a significant deficiency, and failure to ensure a proper
gap between the support channel and shield wa'll when the vessel was set.
The TRT also concludes that the RPV is set within the design location M
tolerance. Therefore, this allegation is not substantiated arid has neither fru wt
safety significance nor generic implications. .'o.
T* h* *d
The TRT is unable to interview the alleger to provide its findings and
conclusions because the ioentity of the alleger is unknown. The TRT
could not identify the alleger responsible for allegation AM-3 because an
anonymous alleger called the Dallas Times-Herald. The identity of the
alleger of AM-23 is unknown because the person who received the allegation
did not record the alleger's name and no longer remembers it.
I
6. Actions Recuired: TUEC shall:
1. Review their procedures for approval of design changes to nonnuclear
safety-related equipment, such as the RPVRI, und make revisions as
necessary to ensure that such design changes do not adversely affect
safety-related systems.
I K-101
_ _ _
- _ _ _
,
,.
. .
1
2. Review pro'cedu'res for reporting significant design / construction
deficiencies, pursuant to 10 CFR Part 50.55(e), and make changes as
,
necessary to ensure that complete evaluations are specified. j
3. Provide analysis which verifies that the cooling flow in the annulus
l
between the RPVRI and the shield wall of Unit 2 is adequate for the
'
as-built condition. -
4. Verify during Unit I hot functional testing that completed modifica-
tions to the RPVRI support ring now allow adequate cooling air flow.*
The TRT notes that control of debris in critical spacings between compo-
nents and/or structures was identified as an issue both in the investiga-
tion of this allegation and in the civil and structural area (Item II.c, .
'
,
" Maintenance of Air Gap Between Concrete Structure"), contained in Darrell
G. Eisenhut's September 18, 1984, letter to TUEC (Attachment 3). Accord- l
-
ingly, TUEC shall also:
1. Identify areas in the plant with spacing between components and/or
structures that are necessary for proper functioning of
safety-related components, systems, or structures in which unwanted
debris may collect and be undetected t be difficult to remove.
2. Inspect the areat and spaces identified and remove debris.
3. Institute a program to minimize the collection of debris in critical
spaces and periodically reinspect these spaces and remove any debris
,
which may'be present,
i
I
1
I
t
.
<
*The test has been completed. However, TUEC's analysis of test results is
still undprway.
; I
; K-102
i I
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
- _ _ _ _ - _ , _
. .
, _
y
NUCLEAR RE U AT RY COMM.SSION
!. ..
-
g' 611 MYAN PL A DRIVE. SUITE 1000
AR LiuOTou. TE xAs 76011
-
k ..... March 14, 1979
.
In ' Reply Refer To:
-RIV
Docket No. 50-445/Rpt. 79-03
50-446/Rpt. 79-03
.
Texas Utilities Generating Company
,
~ ATTN: Mr. R. J. Gary, Executive Vice
President and General Manager
2001 Bryan Tower
Dallas, Texas- 75201
Gentlemen:
This refers to the. inspection activities performed by our Resident
- Inspector, Mr. R. G. Taylor, during the period February 2-28,1979, of
activities authorized by NRC Construction-Permit Nos. CPPR-126 and 127
for the Comanche Peak facility, Units No.1 and 2, and to the discussion
i of our findings with Mr. R. G. Tolson and other members of.your staff
during the course of the inspection.
Y
Areas examined during the inspection and our findings are discussed'in
,
the enclosed inspection report. Within these areas, the inspection con-
, sisted of selective examination of procedures and representative records,
i
interviews with personnel, and observations by the inspector.
j
Ou-ing the inspection, it was found that certain activities under your .
license appear to be in noncompliance with Appendix B to 10 CFR 50 of the i
NRC Regulations, " Quality Assurance Criteria for Nuclear Power Plants."
1
The Notice of Violation for the item of noncompliance reported in paragraph
9 of the enclosed inspection report was forwarded to you by our letter,
dated February 20, 1979; therefore, this letter does not require further
> response regarding this matter. L '
In accordance
2. Title 10 with Section 2.790 of the NRC's " Rules of Practice," Part
enclosed ins Code of Federal Regulations, a copy of this letter and the
Room. pection report will be placed in the NRC's Public Document
If the report contains any information that you believe to be
proprietary, it is necessary that you submit a written application to
. <
*
i
EXHIBIT 9
I
'0
!
.
- _ _ _ _ _ .
. _ _ . . . . . . - - -
. c
[' -
-
.
;
1
g b. The licenstre notified RIV by letter, dated February PO,1979,
that the matter of the reversed reactor coolant loop elbows
was not reportable. The RRI reviewed the referenced documen-
tation which concludes that the reversal is readily corrected
by addition of weld metal at the connecting joints and that
the initial report was premature since appropriate subsequent
QA and construction actions had not yet taken pla:e._ The
evaluation by the licensee concluded that the item was not
... . reportable within the context of 50.55(e). The RRI had no
further questions and the item is considered closed.
3. Mislocated Reactor ~ Vessel Support Structure
1
The licensee reported to the RRI on February 20,1979, that a major
error had been detected in the design of the Unit 2 reactor vessel
support structure. It had been determined that the reactor vessel
*
support shoes, their ventilation duct work, and the surrounding
reinforcing steel had been rotated forty-five degrees from the
correct positions through a design error. As a result of the rota-
tion, the. reactor vessel would not match the vessel support feet i
nor would the piping system to the other reactor loop components J
fit. The licensee concluded that sinc 2 the vessel could not be
'
inst.J1ed' and connected this precluded the deficiency from being
, '
. reported as a 50.55(e) item, but was necessaries of concern because
.
.... significant design and construction changes would be required to
,P accommodate the vessel and its connecting piping. As of the date
of this report, it has been detemined that the existing structure
can be modified to reorient the vessel correctly to the balance of i
the system. The exact details of the modification, however', are '
not known at this time. . The RRI will follow the modification
effort in detail until it has been concluded. ~
4. Plant Tours
The RRI toured one or nere plant areas several times weekly during l
the reporting period to observe the progress of construction of
safety related structures and the installation of equipment. Two
of the tours were conducted during second shift hours of work. The
RRI observed that housekeeping practices have improved during the
period, apparently through the combined efforts of the construction
and quality control forces. The RRI has been infomally advised that
a general housekeeping program is now operative, although undocum99ted.
The work force and work effort continues as previously indicated..'.I
No items of noncompliance or deviations were identified.
3
-),flE Inspection Report No. 50-445/79-01; 50-446/79-01
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L Reac2or Vessel Installation - l'
Review of Quality Assurance !
,' s Implementing Procedures
,
Procedure No.: 50051B
L Issue Date: 03-31-75
.
.
Y: I: )
SECTION II *
"
INSPECTION REQUIREMENTS
,
'
.
1
,, 1. For each onsite organization with QA'(including kC)
responstbtlities relative to reactor vessel installation,
ascertain whether quality assurance plans, instructions
and procedures, have been estabitshed, and whether they
,.
'
conform to the QA program as described in Chapter 17 of
'
the facility SAR. This shall be accomplished by completing
,
the inspection requirements of Procedure No. 351008 ;
relative to reactor vessel installation. 2"
.s
'
2. Determine whether appropriate and adequate pfoi[dures are
L included or referenced in the QA manual to. assure that L activities associated with reactor vessel installation are 4
controlled and performed according to NRC requirements and !
SAR ccmitments. In particular, ascertain whether
provisions have been established to assure conformance
with applicable requirements for the following a'ctivities:
'
a. Receipt Inspection and Handline
(1) Receipt inspections verify that the. reactor - i
j vessel and associated components are undamaged a'nd { I '
are in conformance with specifications,. including
any special protection requirements....
;
(2) Handling and storage a tivities are in 'accordance ,
with established procer.ures
(3) Record keeping requirements are adhered to
b. _ Crane and Ricaine Testino and Vessel Liftino
(1) Crane and rigging testing and vessel liftin'g
procedures are established prior to lifting the
RPV
(2) Braking and holding test procedures are
j
established prior to RPY lifting )
l
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EXHIBIT loa, b, e )
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$4,
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ReactorVesselInsta11atiin-
.
Review of Quality Assurance
,
% *
Implementing Procedures
a "
Procedure No.: 500518
Issue Date: 03-31-75
,
c. RPV Installation
(1) Work procedures are established for' RPV installation
!
activities, which cover handling, ple:ement,, level-
ing, final adjustment and data recording
(2) Use of special, technical personnel whenever complex
,
or unusual installation activities are involved )
,
'
(3) Record keeping requirements are met j
i
,(4) Installation records reflect the actual as-
,
.
installed conditions "'P '
-
d. RPV Installation Inspection -
'
., ' (1) Inspection activities cover pertinent installation !
;.
activities, such as vessel placementFleveling and ';
final adjustment, to ' assure that app 11 cable d-
specifications and work procedures are accom;ilished
as specified '- <
,
..'3., ;
(2) Inspection activities * meet established procedures,
including record keeping requirements and '
qualifications of inspection personnel responsible
'
for RPV installation inspection
-
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e. Post-Installation Activities '
(1) Vessel protection procedures and internal
cleanliness preservation procedures'are
established prior to need ,
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(2) Procedures
to. established in (1) above are adhered
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Reactor Vessal Insta11atien -
Observation of Work & Work Activities
~ (
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Procedure No.: 60053B
Issue Date: 03-31-75
-
.
SECTION II
~
INSPECTION REQUIREMENTS
Observe reactor' vessel storage, preservation, protection.
-
N
handling and installation activities and/or conditions and -
determine whether requirements of a
ii., -
work procedures and inspection (QC)pplicable specifications,
procedures are being met
;: (;- in the fo11cring areas: *
,
8 '
1. Stored Vessel Protection
'
a.
.
- .
Ascertain whether the reactor vessel is, being stored
in accordance with approved procedures
b. Observe seals and devices to identify vessel I
..
internal atmospheric conditions and verify maintenance
of requirements .
'
c. Observe condition of protective coating and/or
protective covering and verify conformance with
, '
,
requirements
d. Observe dunnage or support structures and detemine
whether protection from entry of dirt, water, flooding
(height of structure) and strength of support (shifting
,
or collapse of structure) is adequate and consistent with
storage specifications
t
2. Installation Technioues
a. Ascertain whether lifting and handling activities are (
consistent with established specifications and procedures, i
including special requirements and precautions '
b. Ascertain whether lifting equipment is as specified,
and the required lift tests and/or NDE of equipment i
have been satisfactorily accomplished 1
t
c. Observe whether placement is being, or has been,
~~. accomplished as specified in the creas of -(1) lifting
and accessory equipment. (2) route used and (3) rate
, of vessel travel during placemerit
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Reactor Vessel Installation -
Observation of Work 4 Work Activities
.-
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Procedure No.: '60053B 1
,
Issue Date: 03-31-75 *
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d. Observe the installed reactor vessel and, based on.a
-
review of the insta11atior, specifications. drawings.
' and work procedures, identify a number of requirements
(at least five, but not more than ten) such as
vessel support structures, vessel-to-support structures
fittings, number and le:ation of support structures
4
-
! i
an6 mounting pads, hold-down devices, shimming devices,
* and alignment requirement, and determine whether:
. r .
. (1) Work procedures have been or are being'fo116wed'
u-
(2) Installation is in accordance wf th specifications
y, and procedures ,
. .
,,,,y.,
. (3) Inspection (QC) procedures are being followed
3. Installed Vessel Protection i
a. Ascertain whether procedures for protection'of'the
e-
installed reactor vessel are being (or were)'followed
7
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b. . Ascertain whether protective devices are installed
'
. around top of open vessel to prevent entry of fcreign
objects and debris
.
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c. Observe whether vessel side openings are blanked off
i
to prevent entry of f9 reign objects and nozzle ends
.
q
are protected from construction damage
, i -
d. Observe whether work platfoms and scaffolding inside
vessel are nonflammable or treated to prevent spread
of accidental fires
,
i
e.
Determine whether ace'ess control activities meet
requirements, i.e., entry of authorized todis,
equipment and personnel only.
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Rehetor Vissel. Insta11ction -
_ Review of Ouality Records
Procedure No.: 500558
,
Issue Date: 03-31-75
.
SECTION II
INSPECTION REQUIREMENTS
'
Review the pertinent quality records relative to reactor
!* .
d vessel storage, protection, handling, installation and
' ' post-installation cleanline:s presentation. Ascertain
whether these records are in conformance with established
procedures and whether these records reflect work
accomplishment consistent with applicable requirements
.
in
i
the following areas: ' ' (
j
'
1. Storace Inspections
f
Review 50% of the (QC) inspection records covering reactor
,.
vessel storage. Ascertain whether: i
a. The stored vessel inspections were made at the
required frequency
,
'
'
b. Protection requirements were maintained
{
2. Handline and, Installation i
-
!
Review the pertinent' quality records (QA and OC)
associated with vessel handling and installation.
Ascertain whether: "
1
a. The established scope of quality assurance activities
relative to handling, installation and inspection
of the reactor vessel was accornplished
b, The work and inspection records confirm that the i
installation of the reactor vessel was in accordance
with specifications and work procedures.
3. Install _ed Vessel Protection l
Review 50% of the inspection rec rds relative to post-
installation vessel protection. Ascertain whether the
records confirm that: 1
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Reactor Yessel Installation -
Review of Quality Records
Procedure No.: 50055B
Issue Date: 03-31-75
..-
a. Adequate access control was provided
'
b. Required cleanliness of the vessel was maintained
4. Compare the records reviewed under 1., 2. and 3. above
with the detailed records retained from Procedure No.
500538. Ascertain whether the site records reviewed
under this procedure reflect the observations
.
made under Procedure No. S00538
-
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!. 5 - (1A Audits and QC Inspections N
r.
,
Determinewhethertherequirednumber.(or,'freqency)<.
of audits and inspections have been made relative'-
to reactor vessel storage, handling, installation
.
s and post-installation protection. -
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Reactor Vessel Installation -
Review of Ouality Records
Procedure No.: 500558
.,
Issue Date: 03-31-75
U
SECTION III
INSPECTION GUIDANCE
_ General Guidance
;
Applicable portions of the SAR should be reviewed to
determine license commitments relative to documentation
requirements for reactor vessel storage, handling,
' installation and post-installation cleanliness preservation
prior to reviewing records in this area. The inspector
,
should make this determination during inspection preparation.
Usually, several organizations at the co'nstruction site
are involved with safety related activities associated
4 - with the reactor vessel. Som2 organizations may perfom
only one activity, vessel placement, for example. The
pertinent records of all organizations involved should be
reviewed.
Specific Guidance-
~2.b. .> A review of more than 50% of tne inspection records
may be required to ascertain whether the vessel
was installed in accordance with specifications and {
work procedures.
,
3.a. - The records should confirm that only authorized 1
personnel, tools and e j
vessel or " clean area"quipment were allowed in the j
procedures. as specified in established
i
References
'
SAR, Chapters 1, 3, 4, 5 and 17, including pertinent codes
and standards referenced in these chapters
I
Regulatory Guide 1.38, Quality Assurance Requirements for
!
Packaging, Shipping, P.eceiving, Storage and Handling of
Items for Water-Cooled Nuclear Power Plants
Regulatory Guide 1.39, Housekeeping Requirements for Water-
Cooled Nuclear Power Plants
l- , ' l III-1
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_ . - l
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Reactor Vessel Installation - i
Review of Ouality Records !
Procedurt No.: 50055B ;
Issue Date:- 03-31-75
l
Regulatory Guide 1.65, Materials and Inspections for
Reactor Vessel Closure Studs .
Regulatory Guide 1.88, Collection, Storage and Maintenance
of Nuclear Power Plant Quality Assurance Records
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In Reply Refer To: !
Dockets: 50-445/85-07 I
50-446/85-05 i
)
'l
Texas Utilities E'ectric Company
ATTN: M. D. Spence, President, TUGC0
'
Skyway Tower.
400 North Olive Street
Lock Box 81
Dallas, Texas 75201
.
Gentlemen:
This refers to the inspection conducted under the Resident Inspection Program
by Mr. H. S. Phillips and others during the period April 1,1985, through
~ June 21, 1985, of activities authorized by HRC Construction Permits CPPR-125 and
CPPR-126 of the Comanche Peak facility, Units 1 and 2, and to the discussion
of our findings with Mr. J. T. Merritt, and other members of your staff at the
conclusion of the inspection.
Areas examined during the inspection included plant status, action on previous
NRC inspection findings, action on applicant identified design construction
deficiencies (10 CFR Part 50.55(e) reports) and plant tours. Within these
areas, the inspection consisted of selective examination of procedures and
representative. records, interviews with personnel, and observations by the
inspectors. These findings are documented in the enclosed inspection report.
During this inspection, it was found that certain of your activities were in
violation of NRC requirements. Consequently, you are required to respond to-
this violation, in writing, in accoroance with the provision of Section 2.201
of the NRC's " Rules of Practice,".Part 2, Title 10, Code of Federal
Regulations. Your response should be based on the specifics contained in the ,
Notice of Violation enclosed with this letter. l
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EXHIBIT 11
RPB2/B C/RPB2B C/RPB2 WRR
HSPhillips/dc DHunnicutt DHunter Vhoonan j
, / /85 / /85 / /85 / /85
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Texas Utilities' Electric Company 2
1
Should you have any questions concerning this inspection, we vill be pleased j
to discuss'them with you. j
Sincerely,
,
Dorvin R. Hunter, Chief
Reactor Project Branch 2
l Enclosures:
1. Appendix A - Notice of Violation
2. Appendix B - NRC Inspection Report
50-445/85-07
50-446/85-05
cc w/ enclosure:
Texas Utilities Electric Company
Skyway Tower
400 North Olive Stfeet
Lock Box 81
Dallas, Texas 75201
Texas Utilities Electric Company
i ATTN: J. W. Becx, Vice President l Skyway Tower
400 North Olive street
'
Loch Box 81 l
Dallas, Texas
'
75201
bec distrib. by RIV:
TEXAS STATE DEPARTMENT OF HEALTH
bec: to DMB(IE01)
bec distrib by RIV:
*RPB1 * Resident Inspector OPS
*RPB2 * Resident Inspector CONS
R. Martin, RA * D. Hunnicutt, Chief, RPB2/B ]
R. Donise, D/DRSS V. Hoonan, NRR
C. Wisner, PA0 S. Treby, ELD
MIS SYSTEM RIV File
Juanita Ellis Renta Hicks
*D Weiss, LFMB (AR2.015)
*w/766
I
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_ - - - _ - _ _ -
, . - . .. . . . .. .
*
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Texas Utilities Electric Company 2
Should you have any questions concerning this inspection, we will be pleased
-to discuss them with you,'
Sincerely,
l' l l- Dorwin R. Hunter, Chief
Reactor Project Branch 2
Enclosures:
1. Appendix A - Notice of Violation
2. Appendix 8 - NRC Inspection Report
l 50-445/85-07
50-446/85-05
'
cc w/ enclosure:
Texas Utilities Electric Company I
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas 75201
Texas Utilities Electric Company
ATTN: J. W. Beck, Vice President
Skyway Tower
400 North Olive street
Lock Box 81
Dallas, Texas 75201
< .
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_ _ _ - _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ . -
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)
.
Contrary to the above, commercial non-shrink grout was used to grout the i
Unit I reactor coolant pump and steam generator supports in lieu of Class !
"E" concrete as specified in Section 6-6 of drawing 2323-51-0550,
Revision 4. The NRC initially reported this item as unresolved in NRC
IR 445/84-16.
This is a Severity Level IV Violation. (Supplement II.E) (445/8507-02). !
3. Hydrogen Recombiners - Out of Specification Voltage Recorded on
Westinghouse Quality Release Document
10 CFR Part 50, Appendix B, criterion V, as implemented by the TUGC0 QA
Plan, Section 5.0., Revision 2, requires that activities affecting quality
shall be prescribed by documented instructions, procedures or drawings, of
a type appropriate to the circumstances and shall be accomplished in
accordance with these instructions, procedures, or drawings.
Brown and Root Procedure QI-QAP-7.2-8, " Receiving of Westinghouse Safety
Related Equipment", Section 3.1.d.1, required a QC inspector to verify
that the Westinghouse Quality Release (QR) document checklist items be
filled out completely and accurately. l
Contrary to the above, the voltage recorded on Westinghouse QR 41424
checklist, attachment 1, step 4.1, was outside the specified tolerance,
but the QR was accepted as satisfactory by quality control receipt
'
inspection. The NRC initially reperted this item as unresolved in NRC
IR No. 50-445/84-16.
This is a Severity Level V Violation Supplement II.E (445/8505-03).
4. Failure to Provide Objective Evidence (Records) to Show that Concrete
Central and Truck Mixer Blaees were Inspected
10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0
QA Plan, Section 5.0, Revision 2, dated May 21, 1981, requires that
activities affecting quality shall be prescribed by documented instruc- -
'
tions, procedures, or drawings, of a type appropriate to the circumstances
and shall be accomplished in accorc'ance with these instructions, proce-
dures, or drawings."
Brown & Root Procedure 35-1195-CCP-10, Revision 5, dated December 4,
1978, requires that central and truck mixer blades be ch6cked quarterly
to assure that mixer blade wear does not excmd a loss of 10% of original
blade height.
Contrary to the above, on May 31, 1985, the NRC inspector determined that
there was no otjective evidence (records) that the sixing blades had been
inspected quarterly since the trucks were placed in service in 1977. i
:
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This is a Severity Level V Violation. (Supplement II.E) (445/8507 04; l
L 446/8505-02). {
5. Failure to Issue a Deficiency Report on Cement S ales That Were Out of
Calib-ation
J 10 CFR Part 50, Appendix 8, Criterion V, as implemented by the TUGC0 QA '
Plan, Section 5.0, Revision 2, dated May 21, 1981, and Section 15.0,
f Revision 4, datea July 31, 1984, requires that activities affecting quality
shall be prescribed by documented instructions, procedures, or drawings, ,
of a type appropriate to the circumstances and shall be accomplished in j
accordance with these instructions, procedures, or drawiagr,. '
Brown & Root Procedure CP-QAP-15.1, "Fielti Control of Nonconforming I
i' Item, " states that nonconforming conditions shall be documented in a '
Deficiency and Disposition Report (DDR). Procedure CP-QCP-1.3, "Tnol
Equipmen'. Calibration and Control," dated July 14, 1975, stater that r
out-of-calibration equipment shall be identified on a DDR. '
Contrary to the above, on May 31, 1985, the NRC inspector reviewed the
calibration file for scale (MTE 779) used for weighing cement and found
that difficulty was encountered with the water and cement scales during a
1975 calibration of the backup plant scales; however, no DDR was issued
to identify this condition and require disposition of the scale and
concrete (if any) produced.
This is a Severity Level IV Violation. (Supplement II.E) (445/8507-06;
446/8505-04).
6. Failure to Translate Design Criteria Into Installation Specifications,
Procedures, and Drawings; and Failure to Control Deviations from These
Standaras
10 CFR 50, Appendix 8, Criterion III, as implemented by TUGC0 QA Plan,
Section 3, Revision 3, dated July 31, 1984, require that measures shall be
established to assure that applicable regulatory requirements and the
design basis, are correctly translated into specifications, drawings,
procedures, and instructions. These measures shall include provisions to
assure that appropriate quality standards are specified and included in
design documents and that deviations from such standards are controlled.
Contrary to the above, (a) Unit 2 reactor pressure vessel installation
design criteria recommended by the NSSS vendor, such as centering
tolerances, levelness tolerances, and shoe to t; racket clearances, were
not included in installation specification, procedures, and drawings; and
(b) the criteria were specified in Construction Operation Traveler
ME-79-248-5500, but were not treated as design engineering criteria as
evidenced by an undocumented changt of shoe to bracket clearances.
This is a Severity Level IV Violation (Supplement II.E) (446/8505-06). l
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_ _ _ _ _ _ _ _ _ _ _ . _
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'7. Failure to M.tintain Tolerances Stated and' Failure tn Report These Results ;
on a Nonconformance Report J
10 CFR 50, Appendix B, Criterion XV as implemented by the TUGC0 QA Plan,
Section V, Revision 2 dated May 21, 1981, requires that measures shall be
established to control materials, parts or components which do not conform
to requirements; and nonconforming items shall be reviewed and accepted.
l rejected, repaired; or reworked in accordance with documented procedures.
'
l Brown and Root Quality Assurance Manual, Section 16, dated March 27, '
1985, requirer, that unsatisfactory conditions identified on process
control documents shall be identified on an Nonconforming Report.
Contrary to the above, clearances between the reactor vessel support ~
brackets and support shoes were not within the tolerance stated in
Construction Operation Traveler HE-79-248-55 a..J the condition was not
reported on a Nonconformance Report.
This is a Severity Level IV Violation. (Supplement II.E) (446-8505-07)
8. Failure to Audit RPV Specifications / Procedures, Installation and As-built
Records >
10 CFR 50, Appendix B, Criterion XVIII as ' implemented by the TUGC0
l
QA Plan, Section 18.0, Revision 2, dated July 31, 1984, requires that a
i
comprehensive system off
C planned and periodic audits be carried out to verify compliance with all
,
aspects of the. quality assurance program.
'! g\ Contrary to the above, there was no evidence that TUGC0 had audited
3 either Unit 2 reactor vessel installation specifications, placement
9 '. f f
.
'
procedures, actual hardware placement, or as-built records.
y/ h.,s
This is a Severity Level IV Violation.
~
b (Supplement II.E) (446/8505'08). !
l 9. Failure to Properly Identify a Spool Piece
l
10 CFR 50, Appendix B, Criterion VIII, as implemented by the TUGC0
QA Plan, Section 8.0, Revision 0, dated July 1,.1978, requires that
measures be established for the identification and control of materials,
parts, and components, including partially fabricated assemblies. These
measures shall assure that identification of the item is maintained by
heat number, part number or other appropriate means.
Article NA3766.6 of ASME, Section III, 1974 Edition, requires that the
identification of material consist of marking the material with the
applicable material specification and grade of material, heat number or
heat code of the material, and any additional marking required by this
section to facilitate traceability of the reports of the results of all
tests and examinations performed on the material.
.
9
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' Contrary to the above, spool piece 3Q1 -(DWG No. BRP-CS-2-RB-76) had
neitner been marked with the material specification and grade, heat j
number or heat code of the saterial. !
This is a Severity Level IV Violation (Supplement II.E) (446/8505-09) )
l
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10. Failure to Furnish or Maintain Records for Material l
I
10 CFR 50, Appendix B, Criterion XVII, as implemented by the TIGC0
QA Plan, Section Revision , requires that sufficient records
be maintained to Turn,ish evidence of activities affecting quality. The
records shall include at least the following: cperating logs, and the
results'of reviews, inspections, tests, aud5ts, monitoring of work
performance, and materials analyses.
Articles NB-2130 and NA3767.4 of ASME Section III, 1974 Edit. ion requires
a certified Material Test Report for all pressure retaining material over
3/4 inch nominal size.
Contrary to the above, certified Material Test Reports were not available
for the 22 degree elbow, 10 inch 45 degree nozzle, and three thermowell
bosses, which were a part of the loop 3 cold leg piping subassembly.
This is a Severity Level IV Violation (Supplement II.E) (446/8505-10)
Pursuant to the provisions of 10 CFR 2.201, Tsxas Utilities Electric Company
is hereby required to submit to this of fice, within 30 days of the date of
this Notice; a written statement or explanation in reply, including: (1) the
corrective steps which have'been taken and the results achieved;
(2) corrective steps which will be taken to avoid further violations; anc
(3) the date when full compliance will be achieved. Consideration may be
given to extending your response time for good cause shown.
Dated:
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APPENDIX B
U. S. NUCLEAR REGULATORY ComISSION J
REGION IV 1
NRC Inspection Report: 50-445/85-07 Permit: CPPR-126 i
50-446/85-05 CPPR-127
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Docket: 50-445; 50-446
Applicant: Texas Utilities Electric Company (TUEC) i
Skyway Tower
400 North Olive Street
Lock Box 81-
Dallas, Texas 75201
Facility Name: Comanche Peak Steam Electric Station (CPSES)
Units 1 and 2
Inspection At: Glen Rose, Texas I
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Inspection Conducted: April 1,1985, through June 21, 1985
Inspectors: ~ ~
H. S. Phillips, Senior Resident Oate
Reactor Inspector Construction
(pars. 1, 2, 3, 8, 9, 10, 11, 15, 16,
17, 18, and 19)-
J. E. Cummins, Senior Resident Reactor 'Date
Inspector Construction (April 1 - May 10,1985)
(pars 1, 3, and 19)
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D. E. Norman, Reactor Inspecto'r Date
(pars. 1, 12, 13, 14, and 19)
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D. M. Hunnicutt, Section Chief Date
Reactor Projects Branch 2
(pars. 1, 4, 5, 6, 7, and 19)
0. M. Hunnicutt, Section Chief, Date
/j Reactor Project Section B
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InspectfonSummary
Inspection Conducted April 1,1985, throuch June 21, 1985(Report 50-445/85-07)
Areas Inspected: Routine, announced and unannounced inspections of Unit I
which included plant tours and review of plant status, action on previoJs NRC
inspection findings (violations / unresolved items), review of documentation for
site dams, and review of 10 CFR Part 21 and 10 CFR Part 50.55(e) construction
deficiency status, The inspection involved 77 inspector-hours onsite by
four NRC inspectors.
Results: Within the areas inspected, three violations were identified
(failure to promptly correct an identified problem with RTE - Delta Potential
Transformer Tiltout Subassemblies, paragraph 3.a.; and commercial non-shrink
grout was used to grout the Unit I reactor coolant pump and steam generator
supports in lieu of Class "E" concrete, paragraph 3.b.; hydrogen recombiners
out-of-specification voltage recorded on quality release docuraent, paragraph
3.c).
Inspection Summary
Inspection Conducted April 1, 1985, through June 21, 1985 (Report 44G/85-05)
Areas Inspectrid: Routine, announced and unannounced inspections of Unit 2
which included plant tours and review of plant status, acticn on previous NRC
inspection findings (violations / unresolved items), review of documentation for
site dams, review of documentation for voids behind the stainless steel cavity
liner of reactor building, observation of NDE on liner plates, fr.spection of
concrete batch plant, review of calibration laboratory records for batch
plant, review of concrete laboratory testing, inspection of level C and D
storage, review of reactor pressure vessel (RPV) and piping records / completed
work, and review of 10 CFR Part 21 and 10 CFR Part 50.55(e) construction
deficiency status, and review of violation and unresolved items status. The
inspection involved 355 inspector-hours onsite by four NRC insperters.
Results: Within the sixteen areas inspected seven violations were idehtified
(failure to provide objective evidence to show that concrete central and truck i
aixer blades were inspected, paragraph 8; failure to issue a deficiency report
on cement scales that were out-of-calibration, paragraph 9c; failure to j
translate design criteria into specifications, procedures, and drawings, )
paragraph 12a.; failure to maintain RPV installation tolerances / document j
nonconformance, paragraph 12b.; failure to audit RPV specifications, '
procedures, installation, and as-built records, paragraph 12d.; failure to
identify a spool piece, paragraph 14b.; and failure to maintain material ;
records, paragraph 14c.
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DETAILS
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1. Persons Contacted
Applicant _ Personnel
M. McBay, Unit 2 Reactor Building Manager
B. Ward, Gen. Supt., Civil
D. Chandler, QA/QC Civil Inspector
W. Cromeans, QA/QC, TUGC0 Laboratory / Civil Supervisor
F#J. Merritt, Assistant Projec't General Manager
*#P. Halstead, Construction Site QA Manager
#C. Welch, QA Supervisor TUGC0 (Construction)
J. Walters, TUGC0 Mechanical Engineer
.K. Norman, TUGC0 Mechanical Engineer
J. Hite, B&R Materials' Engineer
G. Purdy, B&R CPfES QA Manager
* Denotes those present at May 10, 1985 exit interview.
> # Denotes those present at June 10, 1985 exit interview.
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The NRC inspectors also interviewed other applicant employees during this
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inspection period.
2. Plant Status
Unit 1 ;
At the time of this inspection, construction of Unit I was 99 percent
complete. The fuel loading date for Unit 1 is pending the results of
ongoing NRC reviews.
Unit 2
At the time of this inspection, construction of Unit 2 was approximately
74 percent complete. Fuel loading is scheduled for approximately 18
months after Unit 1 fuel loading.
3. Applicant Action on Previous WRC Inspection Findinos
a. (Closed) Unresolved Item 445/8440-02: Potential Problem with
Dotential Transfomer Tiltout Subassemblies.
By letter dated June 15, 1983, Transamerica Delaval notified tha
applicant of an RTE - Delta 10 CFR Part 21 report to the NRC
reporting a potential problem with the primary disconnect clips of
the potential transformer tiltout assembly used in the emergency
diesel generator control panels at CPSES. The Transamerica Delaval
letter also provided instructions for correcting the problem.
However, the NRC inspector could not detemine if the prob 1cm had
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been corrected at CPSES and made this an unresolved item. The
i applicant determined that the problem had not been corrected and
subsequently performed the recommended corrective action. The
Unit I corrective action work activities were documented on startup
work permits Z-2912 (train'A) and Z-2914 (train B). The Unit 2 work
activities are being tracked as master data base (MDB) item 3003-31.
The failure to promptly correct this identified problem is an apparent
violation (445/8507-01; 446/8505-01).
b. (Closed) Unresolved Item 445/8416-03: Commercial Grout Used in Lieu
of Class "E" Concrete
The applicant determined that the use of non-shrink commercial grouc
in lieu of the Class "E" concrete specified on drawing 2323-51-0550
was acceptable. Design Change Authorization 21179 was issued to
drawing 2323-51-0550 accepting the use of the commercial non-shrink
grcut. However, the failure to grout with Class "E" concrete as
specified on the drawing at the time the work was accomplished is an
apparent violation (445/8507-02).
c. (Clo:ed) Unresolved Item A45/8416-04: Hydrogen Recombiners -
Out-of-Specification Voltaae Recorded on Westinghouse Quality l
Release Document
Quality Release N-41424 was revised changing the specified voltage
from 10+-2V to 12+-2V which put the questionable voltage within
specification limits. However, the failure of receipt inspection to
verify that the QRN-41424 was filled out accurately as required by
Procedure QI-QAP7.2-8 is an apparent violation (445/8505-03).
d. (0 pen) Unresolved Item 445/8432-06: 446/8411-06: Lobbin Report
Described Site Surveillance Program Weaknesses
During this reporting period the NRC inspector reviewed the status
of this open item several times and interviewed TUEC management and
site surveillance personnel. The Lobbin report stated that the
scope and objectives of the site surveillance program were unclear,
lacking both purpose and direction.
There is no specific regulatory requirement to have a surveillance
program; however, TUEC committed to have a surveillance program and
has established procedures to implement such a program as a part of
the 10 CFR Part 50, Appendix 8, QA program. This extra effort is a 4
strength; however, the NRC inspector also observed, as did the Lobbin
Report, that the surveillance program lacks both purpose and direction
to be effective and complimentary to the audit and inspection programs.
Since the TUEC audit group is not located on site, the TUEC surveil- !
lance program on site takes on added significance. l
This item was discussed with the TUEC site QC manager who described
a reorganized site surveillance function and changes that have
occurred. New procedures which describe this organization's duties
and responsibilities are forthcoming.
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TUEC has elected to defer responding to the violations pertaining to i
the audit function in NRC Inspection Report 445/84-32; 446/84-11, but i
rather to have the Comanche Peak Response Team (CPRT) respond to 1
this report and other QA matters. The surveillance issue is closely )
tied to the audit deficiencies in NRC Inspection Report No. 445/84-32; W
50-446 84-11. This item will remain open pending the review and
implementation of the CPRT action plan. A special point of interest
will be how audits and surveillance work together to evaluate the
control of all safety-related activities on site to essure quality
especially the overview of quality control effectiveness.
4. Document Inspection of Site Dams
The NRC inspector reviewed documents describing the inspection activities l
performed on the Squaw Creek Dam (SCD) and the safe shutdown impoundment 3
(SSI) for impounding cooling water fer the two units at CPSES. The <
purpose of the SCD is to impound a cooling lake for CPSES. A secondary
reservoir (SSI) is formed by a channel connecting the SCD impoundment to !
the SSI.
Three documented inspections have been performed since 1980. The
inspections were:
a. Relevant data for SCD is contained in Phase I Inspection, National
Dam Saf ety Program, Squaw Creek Dam, Somervell County, Texas, Brazos
River Basin, inspection by Texas Department of Water Resources.
Date of Inspection: June 10, 1980.
b. Inspection on August 25, 1982, by registered professional engineers
from Mason-Johnston & Associates, Inc., and Freese & Nichols, Inc.
c. Inspection on September 19, 1984, by a registered professional !
engineer from Mason-Johnston & Associates, Inc.
The inspection activities consisted of visual inspections by inspection j
teams that included accompanying Texas Utilities Service, Inc. (TUSI), j
and Texas Utilities Generating Company (TUGCD) representatives. i
Photographs were taken as a part of the documentation. The data for the l
piezcmeter observations and the data for the surface reference monuments !
were reviewed by applicant personnel and Mason-Johnston engineers.
No items of significance were observed or reported by these inspection
teams. Slight erosion areas were observed and reported. A Cracked area
on the service spillway upstream right bridge seat was observed by the 4
inspection teams and continued monitoring of this area was recommended by
Mason-Johnston and Associates. No signs of cracks, settlements, or
horizontal movement at any location within the SCD or the SSI were i
reported.
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The NRC inspector reviewed the applicant's records and the Mason-Johnston
inspection reports. These documents indicated that the SCD and SSI were 3
structurally stable and that the applicant was performing inspection
activities to maintain the struct: M integrity of these dams.
The state of Texas requires periodic inspections of these dams
(principally the 500) due to inhabited dwellings downstream. The
applicant has met these inspection requirements.
No violations or deviations were identified.
5. Voids Behind the Stainless Steel Cavity Liner in Unit ? Reactor Buildina
The NRC inspector reviewed applicant records, including NCR C-82-01202;
NCR C-1784, Rev. 1; NCR C-1784, Rev. 2; NCR C-1766, Rev. 1; NCR C 1791, {
Rev. 1; NCR.C-1824, Rev. 1; NCR C-1824, Rev. 2; Significant Dcficiency
Analysis Report (SDAR) - 26, dated December 12, 1979; DCA-20856; and
Gibbs and Hill Specification 2323-55-18. The review of these records and
documentation and discussions with various applicant personnel indicated
the following:
Structural concrete was placed in Unit 2 reactor building at
elevation 819 feet 6-3/4 inches to 846 feet 6 inches on June 21,
1979. This concrete was placed adjacent to the stainless steel
liner walls. The concrete forms for this poe= were not removed
until October 1979 due to subsequent concrete placements for the
walls to elevation 860 feet 0 inches. When the forms were removed,
honeycombs and voids were observed by applicant personnel. The
applicant's review of the extent of unconsolidated concrete resulted
in the issuance of SDAR-26 on December 12, 1979. Investigations
were begun and Meunow and Associates (M&A) of Charlotte, North
Carolina, were contracted to perform nondestructive testing on
in place concrete. M&A performed these tests on a two foot grid
pattern on the compartment ~and liner sides of all four steam
generator (SG) compartment walls. The selected test locations did
not include the locations where the voids were later found to be
located; therefore, the voids were not detected during the M&A
testing.
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In August 1982, preparations were made to pour the concrete annulus
around the reactor vessel. When the expanded metal forework was
removed from the reactor side of the compartment walls, voids were
observed and NCR C-82-01202 was prepared. DCA 20856 was prepared as
a precedure to repair the void arsa. DCA 20856 indicated that the
voids were not extensive (a surface area of about 28 square feet by
8 inches maximum depth) and that the repair procedure assured that
the total extent of voids had been idencified. One half (0.5) of a
cubic yard of concrete was used to complete the repairs as indicated
on grout pour card 261.
The applicant's review and evaluation of the gird pattern and a
comparison of SG compartments 2 and 3 to 1 and 4 indicated that
voids did not exist in SG compartments 2 and 3. The review of test
girds extended down to elevation 834 feet, which is the floor
elevation of th> liner. The liner walls of SG compartments 1 and 4
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were not tested at elevation 834 feet, but at elevation 836 feet
which is above the area of the identified voids. No testing was
.done on the liner side of the area of the voids below elevation 836
f e e t.- The program also included removal of 2 inch x 2 inch plugs
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raised questions concerning the concrete. The inspections of the
concrete by applicant personnel after the plugs were removed
confirmed that there were no additional unconsolidated concrete
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areas (voids).
. The applicant removed stainless steel ifner plates from three areas
l (one area about 1 foot by 1 1/2 feet and two areas about 3 feet by 1
foot, excavated or chipped to sound concrete, and cleaned the
concrete surface area. One and one-quarter inch (1 1/4) diameter
l probe holes and grout access holes were drilled in the liner plates
to determine the extent of and to assure full definition of the void
area. Air access holes were drilled in the stainless steel liner
plates to assure that grouting would be accomplished in accordance
with the procedure.
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The procedure (DCA-208561 specifed that the grout was to be cured
for 28 days or until the grout reached a compressive strength of 4000
psi. Repairs to the liner plates were specified in DCA-20856 and G&H
Procedure 2323-55-18.
DCA-20856 required that under no circumstances was cutting of the
liner across weld seams, across embedded weld plates, or into leak
chase seal welds or drilling through the liner at leak chase channels,
embeds, or weld seams permitted. Documentation review indicated that
DCA-20856 was adhered to and that no cutting or drilling oc. curred in
prohibited locations.
No violations or deviations were identified.
6. Nondestructive Testing Observations of Liner Plates in Fuel Transfer
Canal
The NRC inspector cbserved portions of non-Q liquid penetrant examinations ;
(PT) being performed on liner plate welds following re-installation of the l
liner plates in the areas of the fuel transfer canal removed for inspection l
and repair of the concrete. The inspector performed the PT on the welds j
as required by the repai. package and the procedure (Q1-QP-11.18-1,
" Liquid Penetrant Examination"). Scattered weld porosity was identified
by the inspection. The porosity was ground out and a repeat PT was
performed. The final inspection is scheduled to be perfomed by QC
inspection personnel. The liner plate areas to be inspected by PT were
identified in DCA 20856.
No violations or deviations were identified.
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,, 7. Rebar' Placement'and Cadweld Splice Observations and Records < 'The WRC~inpector reviewed the rebar placement'and Cadwell Splice j
activities associated with the Unit 2 containment (reactor building). 1
closure. '
a. Calibration of Tensile Tester
The NRC inspector observed the calibration of the Tinus-01 son
Universal Testing Machine (Model Number 600-12 Identification Number !
M&TE-784) on April 2 and May 7, 1985. The machine was calibrated
just prior to performing tensile testing of cadweld splices and
subsequent to completion of tensile testing each day that tensile
testing was performed. The machine calibration date for April 2,
1985, prior to start of tensile testing was observed by the NRC ,
inspector and recorded as follows:
Nominal load Calibration Readino ' Error Error Remarks
(lbs) (lbs) 'lbs) % _
0 0 0 0 0 machine on
4/2/85
100,000 99,750 +250 . +0 25
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200,000 199,600 +400 +0.2
300,00 299,450 +550 +0.18
-350,000 350,300 -300 -0.08
400,000 401,200 -1200 -0.03
500,000 501,350 -1350 -0.27^
600,000 602,450 -2450 -0.40
-The NRC inspector reviewed calibration data for March 4. March 8,
April 2 April 3, April 30, and May 7, 1985. All calibration data
met within the +/- 1% accuracy requirement specified by Calibration
Procedure 35-1195-IEI-37, Revision 3, dated March 11, 1982. The
reference standards were identified as follows:
10 No. Manufacturer Calibration Due Date
RS-75 BLH Electronics Jan~ary
u 27, 1987
RS-75.3 BLH Electronics January 27, 1987
b. Observation of Cadweld Splice Tensile Testina
(1) Qualification Tensile _Testina
on April 2, 1985, the NRC inspector observed the following
tensile testing of cadweld splices for cadwelder qualification:
E80 Q8, GBH Q1, GBH Q2, G8V Q1, 8F0 Q4, 8F0 Q3, 8FH Q4, GAH Q1,
GAV Q1, and G8V Q2.
Each of the above qualification cadweld splices was tensile '
tested to 400,000 pounds (100,000 psi) and met the requirements
stated in the procedure.
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(2) Production Tensile Testina
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The NRC inspector observed the tensile tester calibrations and
the following production cadweld splices tensile testing on 4
May 7, 1985: FXO 3P, FYD 4P, FYD 8P, FRD 87P, and FUD 6P.
Each of the above production cadweld splices was tested to
400,000 pounds (100,000 psi)and met the requirements stated in
the procedure.
(3) Installation of Production Cadweld Splices
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The NRC inspector observed installation of rebar and cadweld j
splices at frequent intervals (five or more observations per {
week during the weeks of April 8 and 15; May 6, 13, 20, and 27;
and June 3, 1985). The rebar installation for the Unit 2
closure was performed in the area identified as elevation 805
feet to elevation 875 feet and azimuth 300 degrees to 335
degrees. The installation activities observed included rebar
spacing, location of cadwelds, observation of selection and
removal for testing of cadweld splices for testing, and'
determination of location of rebars and cadwelds for the
as-built drawings.
(4) Occumentation Reviewed
l The NRC inspector reviewed the following documentation for the ! rebar placement and cadwelding for the Unit 2 containment
(reactor building) closure area:
Drawings DCAs NCRS
2323-5-0785, Rev.7 22616, Rev. 1 C85-200294
2323-5-0786, Rev.9 22728 C85-200339, Rev.1
2323-51-500, Rev.5 22737 C85-200355, Rev.1
2323-51-506, Rev.5 22836
2323-52-505, Rev.5 22878 (Sheets 1-7)
2323-52-508, Rev.2 22772
2323-52-506, Rev.3
No violations or deviations were identified.
8. Concrete Batch Plant Inspection
The NRC inspector used a nationally recognized checklist to inspect the
concrete production facilities. This list included the specific
characteristics for the following areas: '(1) material storage and
handling of cement, aggregate, water and admixture, (2) batching
equipment scales, weighing systems, adnitxture dispenser, and recorders.
(3) central mixer (not applicable because it had been dismanteled), (4)
ticketing system, and (5) delivery system.
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The current batching is a manual. operation since almost all concrete has
been placed. The. central mixer was dismanteled and removed from site two
or three years ago when concrete placement was virtually completed.
Presently, the backup batch plant (wnich was a backup system for the
central mixer) is in operation to complete the remaining concrete
placements. This batch plant is in good condition and complied with the
subject checklist except for one area
The NRC inspector inspected the'inside of one of three trucks used for
mixing concrete.(that is, the batch plant dispenses the correct we ut of
materials as required by the specific design mix numbers and the truck
then mixes the batch to be placed.) The blades inside the truck are
subject to wear and should be checked at a reasonable frequency. The
Brown & Rost (B&R) representative responsible for checking the blades in
accordance with B&R Procedure 35-1195-CCP-10, Revision 5, dated '
December 4, 1978, was asked for evidence that the blades had been checked
for wear on a quarterly basis and it was found that there was no record of
such checks dating back to 1977 when they were initially checked.
Procedure CCP-10, paragraph 3.10 " Truck Mixing", is silent on blade wear
but Section 3.11 infers that the blades should be checked for both
central and truck mixing. The inspection of both central and truck
mixing blades was not documented, although the B&R representative stated
that the mixing blades were periodically inspected and laboratory testing-
would have probably indicated if there was a problem with the mixing blades.
Strength and uniformity tests have consistently been within the acceptable
range indicating that concrete production was acceptable even though
mixing blade inspection was not documented.
Otherwise, the condition of the inside of the truck was satisfactory as
the drum and charging / discharging were clean. The water gage and drum
counter were in good condition.
This failure to follow procedures is a violation of 10 CFR 50 Appendix
B, Criterion V. Subsequent to the identification of this violation, the
blades were checked for wear and blade wear was presently within allowable
limits (445/8507-04; 446/8505-02).
No other violations or deviations were identified.
9. Calibration Laboratory for Batch Plant
The NRC inspector obtained batch plant scale numbers from tags which
indicated that the scales had been calibrated and were within the
calibration frequency. Cement (MTE 779), Water (NTE 766), admixture
scale (MTE 764), and aggregate (MTE 780) were reviewed. The scales had
been periodically calibrated since the batch plant was activated. The
records were adequate except as follows:
a. Scales MTE 766 records do not clearly differentiate between the
required accuracy of the scale and the digital readout.
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b. Scales MTE 779 and 780 records show various accuracy ranges for the ,
same scale; i.e., MTE 779 (SN749687) records the following: report
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dated January 1976 gives 1%; . report dated July 1976 gives 1% whils
report October 1976 gives +/- 0.2%.
The above iters are unresolved pending furthdr review of the licensee ]
actions regarding these records during a subsequent inspection (445/8507-05; I
446/8505-03). The calibration appeared to be proper.
c. Records for scales MTE 779 records contr.ined B&R memo'IM-1108 dated
July 16, 1975, which described a nonconforming condition. This J
condition affected the water and cement scales causing a 24-48 pound 1
deviation during the calibration test. The seeo stated that the '
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condition was corrected and the scales were then calibrated;
however, no deficiency report was written as required by B&R
Procedure CP-QCP-1.3, " Tool and Equipment Calibration and Tool
Control" dated July 14, 1975, and CP-QAP-15.1, " Field Control of
Nonconforming Items," dated July 14, 1975. As r. result there is no I
evidence that corrective action included an evaluation to determine j
if concrete production was adversely.affected. !
This failure to assure that a nonconforming condition was evaluated
is a violation of Criterion XV of 10 CFR Part 50, Appendix 8.
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(445/8507-06; 446/8505-04).
10. Concrete Laboratory Testina
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TUGC0 procedure QI-QP-11.1-1, Revision 6, was compared with ASME i'
Section III, Division 2, Subsections 5222, 5223 and 5224 to assure that
each ASTM testing requirement was incorporated into the procedure. l
The NRC inspector inspected the testing laboratory equipment and found
the test area was in good condition and each piece of equipment was j
tagged with a calibration sticker which showed it to be witnin the )
required calibration frequency. Test personnel were knowledgeable of )
test requirements and equipment.
The NRC inspector witnessed field tests performed by laboratory personnel
as follows:
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Date Truck No. Mix No. Ticket Wo; Air Content (%) Slump Teperature
(in.) _F
6/3/85 RT-41 925 64013 Req 8.2-10.3 NA 70 max
Mea 8.7-9.1 NA 57
6/3/85 RT-35 128 64014 Req 5.0-7.0 5 max 70 max
Mea 6.6 6.25* 57
" Truck was rejected by quality centrol but was later accepted when second l'
slump reading came into required range.
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The following laboratory equipment was checked and found to be within I
calibration: Forney Compression Tester, MTE 3031; Temperature Recorder
MTE 3013 and 3014; Unit volume Scale, MTE 1053; Pressure Meters MTE
30008, 3002 and 3004; Sieves MTE 1286, 1239, 1272, 1274, 1136A, 1156,
1094, 1093, 1095, 1178, 1179, 1300 and 1180; Aggregate scales, MET 1058
and 1067; and 2" grout mold HTE 1111.
The following test records for placement number 201-5805-034 were
reviewed: (1) concrete placement inspection, (2) concrete placement j
summary ant, (3) unit weight of fresh concrete. ) l
No violations or deviations were identified. ]
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11. Inspection of Q vel C and D Storace l
The NRC inspector inspected all laydown areas where piping, electrical '
conduit, cable, and structural reinforcing steel were stored. These
materials were neatly stored outside on cribbing in well drained areas
which allowed air circulation and avoided trapping water. This met the {
Level "0" storage requirements of ANSI N45.2.2.
The electrical warehouse contained miscellaneous electrical hardware.
This building was required to be fire and tear resistant, weathertight, and 1
well ventilated in order to meet Level "C" storage requirements. This warehouse
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was well kept and met all requirements except for a lock storage area
l located upstairs at the rear of this building (electrical termination ! tool room). Two minor problems were identified and the warehouse i
personnel initiated action to correct them.
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The first problem noted was that a box of nuclear grade cemert was marked
" shelf life out of date" but it had no hold tag. The box was
subsequently tagged with Nonconformance Report (NCR) E85-200453 after
being identified by the NRC. During discussions with the warehouseman, {
the NRC determined that engineering told the waret.ouseman to mark the
material and lock it up, but did not tell him to apply an NCR or hold 1
tag. TUEC should determine if engineering is aware of nonconforming
7aterial controls and provide training if this is other than an isolated
instance. Also, the NRC inspector noted a very small leak in the roof
above the electrical termination tool room. This leak was in an area that
did not expose hardware to moisture. The roof is currently being repaired.
The millwright warehouse storage area was inspected; however, only a i
small number of items or materials were stored in this area. The overall '
storage conditions in this area met or exceeded Level "C" storage l
requirements. i
No violations or deviations were identified.
12. Reactog Pressure Vessel and Internals Installation - Unit 2
This inspection was performed by an NRC inspector to verify final
placement of the reactor pressure vessel (RPV) and internals by examining
the completed installation and inspectior, records.
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a. Requirements for Placement of RPV
Requirements for placement of the RPV to ensure proper fit-up of all )
- other major NSSS equipment are in Westinghouse Nuclear Services
Division (WNSD) " Procedure for Setting of Major NSSS Components",
Revision 2, dated February 13, 1979, and " General Reactor Vessel
Setting Procedure" Revision 2, dated August 30, 1974. The NRC
inspector reviewed the following drawings, which were referenced in )
the RPV operation traveler, to verify implementation of WNSD j
recommendations:
o WNSD drawing 1210E59 " Standard - Loop Plant RV Support Hardware l
Details and Assembly"
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o WNSD drawing 1457F27 " Comanche Peak SES RCS Equipment Supports
- Reactor Vessel Supports"
o CE drawing 10773-171-004 " General Arrangement Elevation"
o CE drawing 10773-171-005 "Gencral Arrangement Plan"
Neither site prepared installation drawings nor specifications
(which implemented the WNSD recommended procedures) were available
and the drawings. examined did not show certain specific installation
criterion such as centering tolerances, levelness tolerances and
clearance between support brackets and support shoes. The lack of
engineering documentation did not provide full control of the
action and would allow changes to installation criteria important to
safety to be made without complying with established change procedures.
This is considered a violation of 10 CFR 50, Appendix B,
Criterion III (446/8505-06).
b. Document Review
- The NRC inspector reviewed B&R Construction and Operation Traveler
No. ME79-248-5500 which described the field instructions for
installation of the Unit 2 RPV. Requirements recommended by WNSD
procedures were implemented in the traveler. Worksheets attached to
the traveler showed the RPV to be centered and leveled within the
established tolerances. Traveler operation 19 required verification
of a 0.020 to 0.005 inch. clearance between the support bracket and
support shoe, after applying the shis plates. Change $ subsequently
changed the clearance to a 0.015 to .025 inch clearance. The
installation data reflected in attachment 3B of the traveler
indicated an as-built clearance of 0.012 to 0.026 inch which exceeds .
both the original anu revised tolerances. This condition was accepted I
on the traveler based on Westinghouse concurrence, and there were
neither nonconformance reports nor documented engineering cFsluations
to determine if the condition was acceptable. This failure to
document nonconforming conditions and engineering deviations is a
violation of 10 CFR 50, Appendix B, Criterien XV (446/C505-07) .
The NRC inspector reviewed the following receiving records for RPV
hardware and found them to be in order:
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, l, 0 Report No. 14322 for 54 each closure studs, closure nuts, and l closure washers l '
o Report No. 09507 for vessel S/N 11713, Closure Head 11713 and
26 0-Rings
o Deviation notices and corrective action statements
The NRC inspector reviewed the following completed travelers for !
internals installation and found them to be satisfactory:
i
l o ME-84-4641-5500, " Assemble Upper Internals" 1 ? l l o ME-84-4503-4000, " Install and Adjust Roto Locks i 1
o ME-81-2145-5500, "Retorque UI Column Extension"
l o RI-80-385-5500, " Transport and Install Lower Internals" !
o ME-84-4617-5500, " Repair Lower Internals" i
o ME-84-4640-5500 " Assemble Lower Internals"
c. Visual Inspection
At this time, visual inspection of the internals by the NRC inspector was
not possible, and inspection was limited on the vessel. placement to a
walk-around beneath the vessel to inspect the azimuth markings and for
construction debris between the vessel and cavity. No problems were
identified in this area.
d. Records of QA Audits or Surveillance
The NRC inspector requested TUGC0 QA audits or surveillance
performed by TUGC0 of the Unit 2 RPV installation. TUGC0 did not
make available any audit or surveillance reports of specifications
for placement criteria, placement procedures, hardware placement, or
as-built records. Failure to perform audits or surveillance of RPV
specifications, procedures and installation is a violation of
10 CFR 50, Appendix B, Criterion XVIII (446/8505-08).
'
No deviations were identified; however, three violations were
identified and are described in the above paragraphs.
13. Reactor Vessel Disorientation
On February 20, 1979, the applicant reported to the NRC Resident
Inspector that a design error had resulted in the reactor support
structures being placed in the wrong position on the reactor support
pedestal such that the reactor would be out of position by 45 degrees.
Initially, Unit 2 was to be a mirror image of Unit 1, however, a design
change was initiated to permit identical components for both units. The
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design change was implemented for the reactor vessel, but not for the I
pedestal support locations. The problem was not considered by the
applicant to be reportable under provisions of 10 CFR Part 50.55(e) since
the error could not have gone undetected.
The problem was reported to the NRC Offica of Inspection and Enforcement I
on February 22, 1979, and during a March 27, 1979, meeting in Bethesda, 1
Maryland, the applicant presented the proposed redesign and rework l
procedures for relocating the pedestal supports. No unresolved safety '
concerns with the repair were identified at the meeting.
During this inspection the NRC inspector reviewed various documentation i
relative to the disorientation problem, including design changes and the l
construction traveler which implemented the repair.
The following documents were reviewed:
o NRC Inspection Report 50-446/79-03 l
o NRC Inspection Report 50-446/79-07 )
o NRC Inspection Report $0-446/79-13 .
o TUSI Conference Memo, dated March 1, 1979, H. C. Schmidt to
S. Burwell (NRC Licensing PM)
o TUGC0 letter TXX-2980, dated April 30, 1979, to W. C. Seidle
o NRC letter to TUGCO dated May 29, 1979
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o DCA 3872, Revision 1, dated February 28, 1979, Subject: Rework of j
Structure for Placement of the RPV Support Shoes l
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o DCA 4122, dated March 22, 1979, Subject: Replacement of Rebar for J
RPV Supports '
o Construction Traveler CE79-018-5505,' dated March 14, 1979, Subject:
Rework of Reactor No. 2. Cavity - New RPV Support Locations
o Grout Replacement Cards No. 007,008, 009, 010, 014 and 015, various !
dates, Subject: Replacement of Grout around Rebar for Repair of RPV
Support Shoes
o Various Inspection Reports for Grout Properties and Application for i
RPV Support Shoes ,
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No violations or deviations were identified. l
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14. Reactor Coolant Pressure Boundary (RCPB) Systems
]
The inspection was performed to verify: the applicants system for
preparing, reviewing, and maintaining records for the RCPB piping and
components; that selected records reflected compliance with NRC
requirements and SAR commitments for manufacture, test and installation
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of items; and that as-built hardware was adequately marked and traceable
to records. The following items were randomly selected and inspected:
a. Pressurizer Safety Valve - This item was inspected to the commitment i
stated in FSAR, Table 5.2-1 which includes ASME Section III, 1971
edition through winter 1972 addenda. Valve S/N N56964-00-007, which
is installed in the B position was inspected. The following records
were .eviewed:
o QA Receiving Inspection Report No. 21211
o Code Data Report Form NV-1
o Valve Body CMTR {
The valve was in place, however, installation had not been
completed; therefore, the hardware installation inspection consisted
of verifying that the item was ttaceable to the records,
b. CVCS Spool Piece 301 - Requirements for this item are stated ~in
ASME, Section III, 1974 edition through summer 1974 addenda, which
is the commitment from the FSAR, Table 5.2-1. The item was field
fabricated from bulk material and installed in the CVCS with field
welds number 1 and 3 (ref. BRP-CS-2-RB-076). The following records
were reviewed:
o B&R Code Data Report
]
o Field Weld Data Card
o NDE Reports
o QA Receiving Reports (for bulk order)
o Certified Material Test Report (CMTR)
The installed spool piece was inspected for weld quality and to
verify that marking and traceability requirements had been met. The
item had been marked with the spool piece number (3Q1) and the B&R
drawing number, however, marking of the material specification
number and type, heat code, er other means of traceability could
not be found. In respect to material requiring a CMTR, (nominal
pipe size greater than 3/4 inch) NA-3766 requires marking with the
applicable specification and grade of material and heat number or
heat code. When material is divided, the identification marking is
required to be transferred to all pieces. This failure to identify
material merking is a violation 10 CFR 50, Appendix B,
Criterion VIII (446/8505-09),
c. Loop 3 RC Cold Leg - Requiremer.ts for this item are stated in ASME,
Section III,1974 edition through summer 1974 adder,da, which is the
commitment from the FSAR, Table 5.2-1. This piping subassembly
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consists of a 27.5 inch cast pipe with a 22 degree elbow on the
reactor end, a 10 inch 45 degree nozzle, a 3 inch nozzle, and three
2 1/2 inch thermowell installation bosses. The following records ;
were reviewed for the subassembly: ;
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o .QA Receiving Inspection Report No. 12389
o Westinghouse Quality Release (QRN 47523)
dW Code Data Report Form NPP-1
o 27 1/2 inch line CMTR
o 3 inch nozzle CHfR
o Field Weld Cata Cards
o NDE Reports
(1) The NRC inspector determined that CMTR's were required by the
,
code but were not available for the following items
. 22 degree elbow !
. 10 inch 45 degree nozzle
. 2 1/2 inch thermowell bosses
This failure to maintain retrievable records is a violation of
10 CFR 50, Appendix B, Criterion XVII (446/8505-10).
1
(2) Sandusky Foundary and Machine Company test report for the cold )
leg pipe certifies that material meets requirements of ASME l
Section II, 1974 editfors through winter 1975. Southwest l
Fabrication and Welding Company code data report NPP-1 Form l
certified that the cold leg subassembly met requirements of )
ASME Section III, 1974 edition through winter 1975. The FSAR
commitment is ASME Section III,1974 edition through summer
1974. This discrepancy is unresolved pending the applihant's
evaluation to determine if atterial nonconformances exist
(446/8505-11).
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(3) The cold leg NPP-1 Form stated that no hydrostatic (Hydro) test
had been performed. In discussions with Westinghouse and B&R
personnel, the statement was made that it is normal practice to ,
defer the p.srtial hydro test until tha whole system is hydro !
tested. B&R Procedures CP-QAP-12.1 and CP-QAP-12.2 describe !
requirements for the test.
ASME, Section III, (NB-06114(a)) states in respect to the time
of testing piping subassemblies, that the component test, when
conducted in accordance with the requirements of NB-6221(a)
shall be acceptable as a test for piping subassemblies.
NB-6221(a) states that completed components shall be subjected
to a hydrostatic test prior to installation in the system.
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Para' graph (b) of NB-6221 requires pressure testing of all
pressure retaining components that are within the boundary .
protected by overpressure protection. devices and paragraph (c)
permits substitution of the system test for component test. It
is not evident that the system test substitution was pemitted
for pipe subassembly since NA-1200 makes a distinction in the
definition between components and piping subassemblies. NB-6115
states that pressure testing of components shall be performed
, prior to initial operation of a system and that the Data Report
Form shall not be completed nor signed by the code inspector and
the component shall not be stamped until the component manufac-
turer has conducted the hydrostatic pressure test. Additionally,
NA-8231 prohibits the application of a Ccde stamp prior to i
hydmstatic test regardless of whether the test was perforined
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prior to or after installation of the itism. The NPP-1 Form for
the cold leg had been completed and signed by the manufacturer
and Authorized Nuclear Inspector (ANI). An ASME Code Stamp had .
also been applied to the ites. The NRC inspector observed that a
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. hydrostatic test had not.been performed and was noted on the
NPP-1 forri.
The above items are unresolved pending clarification of code
requirements by NRC headquarters (446/8ED5)-12).
(4) Since the cold leg pipe subassembly had not been pressure
testeo prior to installation, the NRC inspector revieweG the-
procedures and hydro test data applicable to Unit 1, since
Unit 2 hydro had not been completed. Requirements for the-tests
were presented in Procedures CP-QAP-12.2, " Inspection Procedure
) '
and Acceptance Criteria for ASME Pressure Testing" and CP;QAP-12.1,
ASME Section III Installation, Verification, and N-5 Certifi'
c6 tion." Procedure CP-QAP-12.1 requires that a data package to
be used in the test, be prepared with the test boundary and the
additional following data shown:
e Base metal defects in which filler material has been
added, and the depth of the base setal defect exceeds 3/8
inch or 10% of the actual thickness, whichever is less.
o 'Jntested vendor performed piping ciri:umferential welds.
o Approximate location and saterial identification and
description for permanent pressure boundary attachment
with applicable support number referenced.
o Weld history, which shall reflect weld removal End/or weld q
repair. ;
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The completed hydro data package (PT-5501) for Unit 1, loop 3
cold leg vas reviewed for compliance with the above
requirements. Drawing No. BRP-RC-1-520-001 had been used to
annotate the test boundary. A handwritten statement on the
drawing indicated: "No major base metal repairs could be
located" and "No hangers with weld attachments could be
lecated." Welds performed by the pipe subassembly vendor,
including the 22 degree circGeferential weld and the
penetration. fittings had not been identified. The'following
items were unresolved regarding the adequacy of the hydro test:
o Was the tieterwination of no major base metal repairs based
on a visual. inspection or on a review of vendor and site
inspection and. repair records?
o Was the shop circumferential weld attaching the 22 degree
elbow to the pipe assembly inspected during the test? If
so, where is,the inspection identified?
o Procedure CP-QAP-12.1 does not require identification of
welds for penetrations into the pipe assembly and they
were not identified on the drawing. Were those welds
inspected? If so, where is the inspection documented?
'
The ebove issues will remain unresolved pending further
evaluation by the applicant (445/8507-07; 446/8505-13).
d. Personnel Qualifications - Personnel who had performed selected tasks
were identified during inspection of installation records. Training
and experience records for the personnel were reviewed to verify
that employee qualifications and mintenance of records were current
and-met requirements. Names or codes for five welders and two NDE
examiners, who had performed tasks during installation of the items
being inspected, were identified and their qualification records
revicwed. There were no questions in this area of the inspection.
15. Special Plant Tours (Unit I and Unit 2)
'On May 23, 1985, the NRC inspector conducted a tour of selected areas of
Unit I and Unit 2. The group consisted of one NRC inspector, two NRC
Technical Review Team (TRT) representatives, two allegers, and several
TUEC representatives. The TUEC representatives tagged each area where a
deficiency was alleged. With the alleger's consent, a tape recorder was
also used to note locations and describe any alleged deficiencies. The
allegers indicated that they had identified all deficiencies during the
tour and all other deficiencies that they had knowledge The NRC TAT is
analyzing this information and will decide what action, if any, should be
taken.
I
During this tour the NRC inspector independently identified a f
questionable' practice in that the top of the the pipe chase at the north end of j
room 88 in Unit 1, safeguards building had two large stickers which j
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stated that areas on the wall were reserved for pipe hangers
GHH-51-1-5B-038-006 and R1(?)1-087-X11. These stickers were dated 1980.
It was ??? evident whether hangers missing or none were needed in these
locations and the reserve tags were not removed. TUEC representative:,
were unable to answer the question immediately. This item is unresolved
pending further review during a subsequent inspection. (445/8507-07;
446/8505-05).
No violations or deviations were identified.
16. Routine Plant Tours (Units I and 2)
At various times during the inspection period NRC inspectors conducted
general tours of the reactor building, fuel building, safeguards
building, electrical and control building, and the turbine building.
During the tours, the NRC inspector observed housekeeping practices,
preventive maintenance on installed equipment, ongoing construction work,
and discussed various subjects with personnel engaged in werk activities.
No violations or deviations were identified.
17. Review of Part 21 and 10 CFR 50.55(e) Construction Reports Status
The NRC inspector reviewed all reports issued to date to assure that NRC
and TUEC status logs were complete and up to date. A total of 183
reports have been submitted to date. This inspection period one Part 21
report on Diesel Generator Oil Plugs and two 10 CFR 50.55(e) reports on
the Equipment Hatch Cover and SA106 Piping (light wall) were submitted.
No violations or deviations were identified.
18. Review of Violation and Unresolved Item Status
The NRC inspector reviewed all violations and unresolved items reported
to date to assure that NRC and TUEC status logs were complete and up to
date. Two hundred nineteen items were reviewed. In addition, a trend i
analysis of NRC findings was performed to generally determine how many )
findings could be broadly classified under each criterion of 10 CFR, J
Part 50, Appendix B. The frequency of findings showed broad and general
trends under the following criteria: II. QA Program; III. Design Control;
V. Instructions, Procedures and Drawings; VII. Control of Purchased
Material Equipment and Services; IX. Control of Special Processes; X. l
Inspection; XI. Test control; XIII. Handling Storage and Shipping; XVII. l
QA Records; and XVIII Audits. The most significant trends were '
Criterion III, V, VII, IX, X, and XVIII. Also, a number of violations
occurred with respect to 10 CFR 50.55(e) items.
These findings mainly pertained to Unit I and related closely to trends
identified by the NRC Technical Review Team TRT. These trends will be
considered during followup on TRT findings. Also, Unit 2 inspection ,
emphasis will consider these trends during future inspections. j
No violations or deviations were identified.
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K 19. Exit Interviews
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The NRC inspectors met with members of the TUEC staff (denoted in
paragraph 1) on May 10 and June 10, 1985. The scope and findings of the j
inspection were discussed. The applicant acknowledged the findings.
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UNrTED STAT 2s j i
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,, NUCLEAR REGULATORY COMMi&SION -
! $ REoloN IV
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In Reply Refer To:
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Dockets: 50-445/85-07 , 1
50-446/85-05 ;
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Texas Utilities Electric Company
ATTH: M. D. Spence, President, TUGC0
Skyway Tower
400 North Olive Street ,
Lock Box 81 l
Dallas, Texas 75201 )
Gentlemen >
Titis refers to the inspection conducted under the Resident Inspection Program
by Mr. H. S. Phillips and others during the period April 1, 1985, through
June 21, 1985, of activities authorized by NRC Construction Pamits CPPR-125 and
CDPR-126 of.the Comanche Peak facility, Units 1 and 2, and to the discuslion
U our findings with Hr. J. T. Merritt, and other members of your staff at the
conclusion of the inspection.
Areas examined during the inspection included plant status, action on previous
NRC inspection findings, action on applicant identified design construction
deficiencies (10 CF; Pert 50.55(e) reports) and plant tours. Within these
areas, the inspection consisted of selective examination of procedures and
representative recceds, interviews with personnel, and observations by the
inspectors. These findings are documented in the enclosed inspection report.
During this inspection, it was found that certain of your activities were in
violation of NRC requirements. Consequently, ycu are required to respond to
this violation, in writing, in accordance with the provision of Section 2,201
of the MRc's " Rules of Practice," Part 2, Title 10, Code of Federal
Regulations. Your response should be based on the specifics contained in the
Notice of Violation enclosed with this letter.
T rele /ed' l4 k'N
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by A4e NE ae&J &new T' !;e d . 7 /* N '
is::rrer ore cow & H dub, y6.v mw
Yt$f4n/ e / /enry -lllfcp e/ pp gf for/ p / <
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EXHIBIT 12 3
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APPENDIX A
NOTICE OF VIOLATION
Texcs Utilities Electric Compan,y Docket: 50-445/85-07
Comancho Peak Steam Electric Station 50-446/85-05
- Units 1 and 2 Permit: CPPR-126
CPPR-127
l
During an .NRC inspeccion conducted on April 1 through June 21, 1985,
' violations of NRC requirements were identified. The violttions involved a
- failure to correct RTE Delta hardware problems; failure.to use class "E" ;
concrete (grout) as specified; failure to document unsatisfactory conditicas
during receipt. inspection of the Hydrogen recombiners; failure to inspect
concrete mixer blades quarterly; failure to document cement scales which were
out of calibration; failure to translate design criteria for reactor vessel
installation into specifications, procedures, and drawings; failure to maintain
stated tolerances and to report the failure on a nonconformance report; failure
to audit RPV specifications / procedures, installation, and as-built records;
failure to properly identify a charging system spool piece; and failure to
furnish or maintain records for reactor coolant systems materials. In accor-
dance with the " General Statement of Policy and Frocedures for NRC Enforcement
. Actions "10 CFR Part 2, Appendix C (1985), the violations are listed below:
1. Failure to Promptly Correct an Identified Problem with RTE - Delta
Potential Transformer Tiltout Subassembliess f
10 CFR 50, Appendix B, Criterion XVI as implemented by the Texas
Utilities Generating Cc ,, y (TUGCO)' Quality Assurance Plan, Section_
Revision requires that measures shall be established to assure that
onditioWa,dverse to quality, such as failures, malfunctions, deficien- !
cies deviations, defective material and equipment, and nonconformances are
promptly identified and corrected. i
Contrary to the above, a potential problem with RTE - Delta potential
transformer t11 tout subassemblies, which are used in the emergency diesel
generator control panels, was identified to the applicant via a letter,
dated June 15, 1933, from Transamerica Delaval Inc. This letter also j
provided instructions for correcting the potential problem. However, the
applicant did not perform the corrective action. The NRC initially
reported this item as unresolved in NRC Inspection Report 445/84-40.
l
l- This is a Severity Level V Violation, (supplement II.E) (445/8507-01 l
446/8505-01).
2. Commercial Grout Used in Lieu of Class "E" Concrete
10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 QA -
Plan, Section 5.0, Revision _ _, requires that activities affecting quality /
shall be prescribed by documented instructions, pro:edures, or drawings,
of a type appropriate to the circumstances and shall be accomplished in
accordance with these instructions, procedures, or drawings.
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. !n Reply Refer To: l
Dockets: 50-445/85-07 . t
50-446/85-05 1
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l Texas Utilities Electric Company
ATTH: M. D. Spence Fresident, TUGC0 f
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Skyway Tower
400 North Olive Street
( W _g{" L J
j
l Lock Box 81
Dallas, Texas 75201 J
G(ntlemen: j
This refers to the inspection conducted under the Resident inspection Program
by Mr. H. 3. Phillips and others during the period April 1,1985, through
June 21, 1965, of activities authorized by MRC Construction Permits CPPR-125 and
CPPR-126 of the Con.anche Peak facility, Units 1 and 2, and to the discussion
of our findings with Mr. J. T. Merritt, and other members of your staff at the
conclusion of the inspection. 3
,
Areas examined during the inspection included plant status, action on previous
l NRC inspection findings, action on applicant identified design construction
deficiencies (10 CFR Part 50.55(e) reports) and plant tours. Within these
areas, the inspection consisted of selective examination of procedures and
representative records, interviews with personnel, and observations by the
inspectors. These findings are documented in the enclosed inspection report.
During this inspection, it was found that certain of your activities were in
violation of NRC requirements. Consequently, you are required to respond to
this violation, in writing, in accordance with the provision of Section 2.201
-
of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal
Regulations. Your response should be based on the specifics contained in the
Notice of Vialation enclosed with this letter.
.
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RPB2/8 C/RPB2 NRR
l C/RPB21@tDHunter
HSPhillips/dc DHunnicut VNoonan
l P/I /B5 10/L/S5 / /85 / /85 t
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Texas Utilities Electric Company 2
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Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Sincerely.
R. P. Denise Director
Division of Reactor Safety
and Projects
Enclosures:
1. Appendix A - Notice of Violation 1
2. Appendix B - NRC Inspection Report
50-445/85-07
50-446/85-05
cc w/ enclosure:
Texas Utilities Electric Company
. Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas 75201
Texas Utilities Electric Ccmpany
ATTN: . J. W. Beck, Vice President
Skyway Tower
400 North Olive street
-
Lock Box 81
Dallas, Texas _75201
bec distrib. by RIV:
TEXAS STATE DEPARTHENT OF HEALTH
bec: to DHB(IE01)
bec distrib by RIt:
~*RPB1 * Resident Inspector OPS
*RPB2 * Resident Inspector CONS
R. Martin, RA * D. Hunnicutt Chief, RPB2/B i
R. Denise, D/DRSS V. Noonan, WRR
C. Wisner PA0 S. Treby, ELD
.
4
MIS SYSTEM RIV File
Juanita Ellis Renea Nicks -
*D Weiss, LFMB (AR2015) )
*w/766
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APPENDIX A
NOTICE OF VIOLATION
i
Texas Utilities Electric Company Docket: 50-445/85-07
Comanche Peak Steam Electric Station 50-446/85-05
Units 1 and 2 Peruft: CPPR-126
,
I
CPPR-127 l
During an kRC inspection conducted on April 1 through June 21, 1985,
violations of NRC requirements were identified. The violations involved a
failure to correct RTE Delta herdware problems; failure to use class *E' )
i
concrete (grout) as specified; failure to document unsatisfactory conditions .j
during receipt inspection of the Hydrogen recombiners; failure to inspect i
concrete mixer blades quarterly; failure to document ennent scales which were
out of calibration; failure to translate design criteria for reactor vessel j
installation into specifications, procedures, and drawings; and failure to 1
j
maintain stated tolerances and to report the failure on a nonconfomence report.
In accordance with the " General Statement of Policy and Procedures for PRC Enforcemen
Actions "10 CFR Part 2. Appendix C (1985), the violations are listed below:
1. Failure to Promptly Correct an Identified Problem with RTE - Delta
Potential Transformer Tiltout subassemblies
10 CFR 50, Appendix B, Criterion XVI as implemented by Texas Utilities
Generating Company (TUGCO) Quality Assurance Plta (QAP), Section 16.0,
Revision 0, requires that measures shall be established to assure that
-
.
conditions adverse to quality, such as failures, malfunctions, deficien-
k promptly identified and corrected.cies deviations, defective material and equip
Contrary to the above, a potential problem with RTE - Delta potential
4 transformer tiltout subassemblies, which are used in the emergency diesel
I
generator control panels, was identified to the applicant via e letter,
* dated June 15, 1983, from Transamerica Delaval Inc. This letter also
provided instructions for correcting the posential probles. However, the
applicant did not take the corrective action. The NRC initially
reported this ites as unresolved in WRC Inspection Report 445/84-40.
I
This is a Severity Level V Violation. (Supplement II.E) (445/8507-01
446/8505-01).
2. Commercial Grout Used in Lieu of Class *E' Concrete
10 CFR Part 50 Appendix B, Criterion Y, as implemented by the TUGC0 QAP,
Section 5.0, Revision 2 requires that activities affecting quality shall
be prescribed by documented instructions, procedures, or drawings, of a
type appropriate to the circumstances and shall be accom
dance with these instructions, procedures, or drawings. plished in accor-
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Contrary to the above, comercial non-shrink grout was used to grout the k
Unit i reactor coolant pump and steam generator supports in lieu of Class
"E" concrete as specified in Section 6-6 of drawing 2323-51-0550,
Revision 4. .
,
gW
This is a Severity Level IV Violation.- (Supplement !!.E) (445/8507-02).
3. Hydrogen Recombiners - Out of Specification Voltage Recorded on
Westinghouse Quality Rilease Document {
'
10 CFR Part 50 '. Appendix B, Criterion V, as implemented by the TUGC0 QAP,
Section 5.0., Revision 2 requires that activities affecting quality
shall be prescribed by documented instructions, procedures or drawings, of
a type appropriate to the circumstances and shall be accomplished in
!
,
accordance with these instructions, procedures, or drawings. )
Brown and Root Procedure QI-QAP-7.2-8 " Receiving of Westinghouse $afety .
Related Equipment" Section 3.1.d.1, required a QC inspector to verify
that the Westinghouse Quality Release (QR) document checklist items be
filled out completely and accurately.
Contrary to the above, the voltage recorded on Westinghouse QR 41424
checklist, attachment 1, step 4.1, was outside the specified tolerance,
but the QC receipt inspector accepted QR as satisfactory.
This is a Severity Level V Violation (Supplement II.E) (445/8507-03). !
4.
Failure to Provide Ob.iective Evidence (Records) to Show that Concrete
central and Truck Mixer Blades were Inspected I
- )
10 CFR Part 50, A
QAP, Section 5.0,ppendix
Revision8.2,Criterion
dated MayV, as
21,implemented by that
1981, requires the TUGC0
activities
affecting quality shall be prescribed by documented instructions,
'g 7 procedures, or drawings, of a type appropriate to the circumstances and
dy shall be accomplished in accordance with these instructions, procedures,
or drawings.
\[j Brown & Root Procedure 35-1195-CCP-10 Revision 5 dated December 4,
* 1e 1978, requires that central and truck, mixer bladas be checked quarterly
to assure
blade that mixer blade wear does not exceed a loss of 105 of original
height.
Contrary to the above, on May 31, 1985, the NRC inspector determined that
there was no objective evidence (reenrds) that the mixing blades had been
inspected quarterly since the trucks were placed in service in 1977.
This is a Severity Level V Violation. (Supplement II.E) (445/8507-04;
446/8505-02). i
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5. Fail e to issue a Ceficiency Report on Cement Scales That Were Out of
'10 CFR Part 50, Appendix 8 Criterion V, as implemented by the TUGC0 QAP,
Section 5.0, Revision 2, dated May 21, 1981, and Section 15.0, Revision 4,
* dated July 31, 1984, requires that activities affecting quality shall be
prescribed by documented instructions, procedures, or drawings, of a type
" ( appropriate to the circur.tstances and shall be accomplished in accordance
with these instructions, procedures, or drawings.
/
Brown & Root Procedure CP-QAP-15,1 "F,teld Control of Nonconforming
: ' Item. * states that nonconforming co,nditions shall be documented in a ,
j
Deficiency and Disposition keport (DDR). Procedure CP-QCP-1.3. * Tool
Equipment Calibration and Control,' ' dated July 14,1975, states that
out-of-calibration equipment shall be identified on a DDR.
l
Contrary to the above, on May 31 1985 the NRC ins ter reviewed the W41" l
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calibration file for scale (MTE i79) us,ed for weigh ng cement and found 7
s
'that a 24-48 pound deviation from the required accuracy was encountered
with the water and cement scales during a 1975 calibration of the backup
Q plant scales, however, no DDR was issued to identify this condition and
C, require dispositten of the scale and concrete Qf any) produced.
This is a Severity Level !Y Ytolation. (Supplement II.E) (445/8507-06;
446/8505-04).
6. Failure to Translate Deston Criteria Into Installation Specifications.
Procedures, and Drawings; and Failure to Control Deviations from These
, Standards
-
10 CFR 50, Appendix B, Criterion III, as im
Section 3 Revision 3, dated July 31,1984,plemented bymeasures
requires that TUGC0 QAP,
shall
be established to assure that applicable regulatory requirements and the
design basis, are correctly translated into specifications, drawings,
procedures, and instructions. These measures shall include provisions to
assure that appropriate qvality standards are specified and included in
design documents _ and that deviations from such staredards are controlled.
Contrary to the above, Unit 2 reactt,r pressure vessel installation criteria
such as centerin
,
clearances were:g(toleranccs,
a) specified levelness tolernaces, sad shoe to bracket
on Construction ration Traveler
' E 79-248-5500 based on NS$$ vendor recommended riteria which had not
been translated into CPSES specifications, drawings, procedures, or
instructions; and (b) changed on the traveler without appropriately
,
documenting such engineering changes. '
/ This is a Severity Level IV Yiolation (Supplomaat II.E). (446/8505-05).
I s A f "
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7. Feilure to Maintain Tolerances Reouired and Failure to Report Tolerance
Deviations on a Nonconformance Report ~
10 CFR 50, Appendix B, Criterion XY as implemented by the TUGC0 QAP,
Section 15.0, Revision 2 dated May 21, 1991, requires that measures shall be
established to control materials, parts or components which do not conform
to requirements; and nonconforming items shall be reviewed and accepted.
.
rejected, repaired; or reworked in accordance with documented procedures.
1
Brown and Root Quality Assurance Manual, Section 16 dated March 27
1985, requires that unsatisfactory conditions identified on process,
control documents shall be identified on a nonconforming report.
Contrary to the shove, clearances between the reactor vessel support
brackets and support shoes were not within the original or revised E
permissible tolerance stated in Construction Operation Traveler
ME-79-248-55 and the deviation was not reported on a nonconformance
report. .
This is a Severity Level !Y Yiolation. (Supplement II.E) (446-8505-06)
Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company
is hereby required to submit to this office, within 30 days of the date of
this Notice, a written statement or explanation in reply, including: (1) the
corrective steps which have been taken and the results achieved; (2) corrective
steps which will be taken to avoid further violationst and (3) the date when
full compliance will be achieved. Consideration may be given to extending your
response time for good cause shown.
.
Dated:
1
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APPENDIX B
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U. S. NUCLEAR REGULATORY COMISSIO;4
REGION IV
NRC Inspection Report: 50-445/85-07 Permit: CPPR-126
50-446/85-05 CPPR-127
Docket: 50-445; 50-446
)
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Applicant: Texas Utilities Electric Company (TUEC) ]
Skyway Tower
400 North Olive Street
Lock Box 81 ;
j
Dallas, Texas 75201
Facility Name: Comanche Peak Steam Electric Station (CPSES)
.
Units 1 and 2
Inspection At: Glen Rose, Texas
Inspection Conducted: April 1,1985, through June 21, 1985
Inspectors: '
_42 ad/ /0 [ff
H. 5. Phillips, Senior Resident Date
Reactor Inspector Construction
(pars. 1, 2, 3, B, 9, 10, 11, 15, 16,
17, 18, and 19)
~
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& bh Ms W1/ts
J. E. Cursr. ins, senior Resident Reactor Date
J Inspector Construction (April 1 - May 10,1985)
(pars. 1, 3, and 19)
*
f
D. E. Norman, Reactor Inspector
/Af//W
Date
(pars. 1, 12, 13, 14, and 19)
dk A., a w- Adskr !
D. M. Hunnicutt. Section Ghtef pate
Reactor Projects Branch 2
(pars. 1, 4, 5, 6, 7, and 19)
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Approved: dbf# //.2/F5
D. M. F.unnicutt, section chief, pate
Reactor Project Section B
Inspection Sunnary
Inspection Conducted April'1.1985, through June 21.1985(Report 60-445/85-07)
Areas Inspected: Routine, announced and unannounced inspections of Unit I
which included plant tours and review of plant status, action on previous WRC
inspection findings (viciations/ unresolved items), review of documentation for
'
site dams, and review of 10 CFR Part 21 and 10 CFR part 50.55(e) construction
deficiency status. The inspection involved '7 inspectorehours pnsite by,
four NRC inspectors. , .
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Results: Within'the areas inspected, fiME. violations were identified: fail-
ure to promptly correct an identified problem with RTE Delta Potential
N
Transformer Tiltout Subasseabites, paragraph 3.a.; commercial non-shrink grout
was used to grout the Unit I reactor coolutt pump and steam generator supports
in lieu of Class *E" concrete, paragraph 3.b.; hydrogen recombiners out-of-
specification voltage recorded on quality releasa document but QC receipt
inspector accepted, paragraph 3.c; failure to provide objective evidence to
show that central and truck mixer blades were inspected, paragraph 8; and
ftilure to issue a deficiency report on cement scales that were out-of-calibra-
tion, paragraph 9.c.
Inspection Susmary
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Inspection Conducted April 1.1985, through June 21.1985(Reportd6/85-05)
Areas Inspected: Routine, announced and unannounced inspections of Unit 2
which included plant tours and review of plant status, action on previous NRC
inspection findings (violations / unresolved items), review of documentation for
site dams, review of documentation for voids behind the stainless steel cavity I
itner of reactor building, observation of NDE on liner plates, inspection of
concrete bate plant, review of calibration laboratory records for batch
plant, revies af concrete laboratory testing, inspection of level C and D 1
storage, review of reactor pressure vessel (RPV) and piping reconis/coepleted
work, and review of 10 CFR Part 21 and 10 CrA Pa:4 50.55(e) construction
deficiency status, and review of violation and unresolved items status. The
inspection involved 335 inspector-hours onsite by four NRC inspectors.
Results:~ Within the sixteen areas inspected five violations were identified:
failure to correct RTE-Delta transformer problem, paragraph 3.a; failure to
provide objective evidence to show that concrete central and truck sixer blades
were inspected, paragraph 8; failure to issue a deficiency report on cement
scales that were out-of-calibration, paragraph Sc; failure to translate design
criteria into specifications, procedures, and drawings, paragraph 12a.; and
failure to maintain RPV installation tolerances /doclament deviations in a
nonconformance report, paragraph 12b.
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DETAILS
1.- Persons Contacted
Applicant Personnel
M. McBay, Unit'2 Reactor Buf1 ding Manager
B. Ward, General Superintendent, Civil
D. Chandler, QA/QC Civil Inspector
W. Cromeans, QA/QC, TUGC0 Laboratory / Civil Supervisor
*fJ. Merritt, Assistant Project General Manager
*fP. Halstead, Construction Site QA Manager
#C. Welch, QA Supervisor TUGC0 (Construction)
J. Walters, TUGC0 Mechanical Engineer
.
K. Norman, TUGC0 Mechanical Engineer
J. Hite, B&R Materials Engineer
G. Purdy, B8R CPSES QA Manager
* Denotes those present at May 10, 1985 exit interview.
# Denotes those present at June 10, 1985 exit interview.
The NRC inspectors also interviewed other applicant employees during this
inspection period.
2. Plant Status
'
Unit _1
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At the time of this inspection, construction of Unit I was 99 percent
complete. The fuel loading date for Unit 1 is pending the results of
ongoing NRC reviews.
Unit 2
At the time of this inspection, construction of Unit 2 was approximately
i 74 percent complete. Fuel loadin ,
months after Unit 1 fuel loading.g is scheduled for approximately 18
3. Applicant Action on Previous WRC Insoection Findines
a.
(Closed) Unresolved Ites 445/8440-02: Potential Problem with
Potential Transfomer T11 tout subasseelies.
By letter dated June 15, 1983, Transamerica Delaval notified the
applicant of an RTE - Delta 10 CFR Part 21 report to the NRC
reporting a potential problem with the primary disconnect clips of
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the potential transformer tiltout assembly used in the emergency
diesel generator control panels at CPSES. The Transamerica Delaval
letter also provided instructions for correctin the problem.
However, the NRC inspector could not determine f the problee~had l
been corrected at CPSES and made this an unresolved ites. The
applicant detemined that the probles had not been corrected and
subsequently performed the recommended corrective action. The j
Unit 1 corrective action work activities were documented on startup 1
work permits 2-2912 (train A)~ and 2-2914 (train 8). The Unit 2 work I
activities are being tracked as master data base (MDB) ites 3003-31. I
The failure to promptly correct this identified problem is sin apparent
violation (445/8507-01; 446/8505-01).
-4
b.
(Closed) Unresolved item 445/8416-03: Commercial Grout Used in Lieu ]
of class "E' concrete
The applicant determined that the use of non-shrink commercial grout j
in lieu of the Class *E" concrete specified on drawing 2323-51-0550
was acceptable. Design Change Authorization 21179 was issued to
drawing 2323-51-0550 accepting the use of the commercial non-shrink
grout. However, the failure to grout with Class *E" concrete as
specified on the drawing at the time the work was accomplished is an
apparent violation (445/8507-02).
c. (Closed) Unresolved Item 445/8416-04: Hydrocen Recce6tners - I
Dut-of-5 specification Voltage Recorded on Westinghouse Quality i
Release Document i
Quality pelease N-41424 was' revised changing th? specified voltage
- from 10+-2Y to 12+-2V which put the questionable voltage within
specification limits. However, the failure of receipt inspection to
verify that the QRN-41424 was filled out accurately as required by
Procedure QI-QAP7.2-8 is an apparent violation (445/8507-03),
d. (0 pen) Unresolved Item 445/8432-06: 446/8411-06: Lobbin R(port
Described site surveillance Program Weaknesses
During this reporting period the NRC inspector reviewed the status
of this open item several times and interviewed TUEC management and
site surveillance personnel. The Lobbin report stated that the
scope and objectives of the site surveillance program were unclear,
lacking both purpose and direction.
There is no specific regulatory requirement to have a surveillance
program; however TUEC connitted to have a surveillance progras and
has established procedures to implement such a program as a part of
the 10 CTR part 50, Appendix B, QA program. This extra effort is a
strength; however, the NRC inspector also observed, as did the Lobbin
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Repori., that the surveillance program lacks both purpose and direction
to be effective and complimentary to the audit and inspection programs.
Since the TUEC audi? group is not located on site, the TUEC surveil- '
lance program on site takes on added significance.
This item was discussed with the TUEC site QC manager who described
a reorganized site surveillance function and changes that have
occurred. New procedures which describe this organization's duties
and responsibilities are forthcomfag.
TUEC has elected to defer responding to the violations pertaining to
the audit function in NRC Inspection Report 445/84-32 446/84-11,but
rathe to have the Comanche Peak Response Team (CPRT); respond to I
this / aport and other QA matters. The surveillance issue is closely l
tied to the audit deficiencies in NRC Inspection Report No. 445/84-32; j
446/84-11. This item will remain open pending the review and imple- j
eentation of the CPRT action plan. A special point of interest i
will be how audits and surveillance wors together to evaluate the !
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control of all safety-related activities on site to assure quality, j
especially the overview of quality control effectiveness.
4. Document Inspection of Site Dams
1
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The WRC inspector reviewed documents describing the inspection activities
performed on the Squaw Creek Dcm (SCD) and the safe shutdown impoundment
;SSI) for impounding cooling water for the two units at CPSES. The -
purpose of the SCD is to impound a cooling lake for CPSES. A secordary
reservoir (SSI) is formed by a channel connecting the SCD impoundment to I
the SSI.
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Three documented inspections have been performed since 1980. The
inspections were: q
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a. Relevant data for SCD is contained in Phase ! Inspection, National I
Dam Safety Program, Squaw Creek Dam, Somervell County, Texas Brazos
. l '
River Basin, inspection by Texas Department of Water Resources.
Date of Inspection: June 10,1980. 1
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b. Inspection on August 25, 1982, by registered professional engineers
from Mason-Johnston & Associates, Inc., and Freese & Nichols, Inc.
c. Inspection on September 19, 1984, by a registered professional
engineer from Mason-Johnston & Associates. Inc.
The inspection activities consisted of visual inspections by inspection
teams that included accompanying Texas Utilities Service. Inc. (TUSI).
and Texas Utilities Generating Cempany (TUGCO) representatius.
Photographs were taken as a pcrt of the documentation. The data for the
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piezometer observations and the data for the surface reference monuments
were reviewed by applicant personnel and Mason-Johnston engineers.
No items of significance were observed or reported by these inspection
teams. Slight erosion areas were observed and reported. A cracked area
on the service spillway upstream right bridge seat was observed by the
inspection teams and continued monitoring nf this area was reconnended by
Mason-Johnston and Associates. No signs of cracks, settlements, or
horizontal movement at any location within the SCD or the SSI were
reported.
The NRC inspector reviewed the applicant's records and the Mason-Johnston
inspection reports. These documents indicated that the SCD and SSI were
structurally stable and that the applicant was performing inspection
activities to maintain the structurel integrity of these dams.
The state of Texas requires periodic inspections of these dams
(principally the SCD) due to inhabited dwellings downstream. The
applicant has met these inspection requirements.
No violations or deviations were identified.
5. Voids Behind the Stainless Steel Cavity Liner in Unit 2 Reactor Building
The NRC inspector reviewed applicant records, including NCR G-52-0120Z;
. I
NCR C-1784, Rev.1; NCR C-1784, Rev. 2; NCR C-1766, Rev.1; NCR C 1791,
Rev.1; WCR C-1824. Rev.1; NCR C-1824. Rev. 2; Significant Deficiency
Analysis Report (SDAR) - 26, dated December 12, 1979; DCA-20856; and
Gibbs and Hill Specifict. tion 2323-S5-18. The review of records and
documentation and discussions with various applicant personnel indicated
the following:
*
Structural concrete was placed in Unit 2 reactor building at
elevation 819 feet 6-3/4 inches to 846 feet 6 inches on June 21,
1979. This concrete was placed adjacent to the stainless steel
liner walls. The concrete forms for this pour were not removed
until October 1979 due to subsequent concrete placements for the
walls to elevation 860 feet 0 inches. When the forms were removed,
honeycombs and voids were observed by applicant personnel. The
.< applicant's review of the extent of unconsolidated concrete resulted
in the issuance of SDAR-26 on December 12, 1979. Investigations
were begun and Heunow and Associates (ME) of Charlotte, North {!
Carolina, were contracted to perform nondestructive testing on !
in-place concrete. MM performed thase tests on a two foot grid l
pattern on the compartment and liner sides of all four steam '
generator (SG) compartment walls. The selected test locations did
not include the locations where the voids wre later found to be
located; therefore, the voids were not detected during the MM
testing.
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In August 1982, preparations were made to pour the concrete annulus
around the reactor vessel. When the expanded metal fonswork was
removed from the reactor side of the compartment walls, voids were.
observed and.NCR C-82-01202 was prepared. DCA 20856 was prepared as
a procedure to repair the void area. DCA 20856 indicated that the
voids were not extensive (a surface area of about 28 square feet by
'8. inches maximum depth) and that the repair procedure assured that
the total extent of voids had been identified. One half (0,5) of a
cubic yard of concrete was used to complete the repairs as indicated
on grout pour card 261.
The applicant's review and evaluation of the gird pattern and a
comparison of SG compartments 2 and 3 to 1 and 4 indicated that
voids did not exist in SG compartments 2 and 3. The review of test
girds extended down to elevation 834 feet, which is the floor
elevation of the liner. The liner walls of SG compartments 1 and 4
'
were not tested at elevation 834 feet, but at elevation 836 feet
which is above the area of the identified voids. No testing was
done on the Ifner side of the area of the voids below elevation 836
feet. The program also included removal of 2 inch x 2 inch plugs
from the stainless steel liner at locations where test indications
raised questions concerning the concrete. The inspections of the
concrete by appitcant personnel after the plugs were removed
confirmed that there were no additional unconsolidated concrete
areas (voids).
.
The applicant removed stainless steel liner plates from three areas
(one area about 1 foot by 1 1/2 feet and two areas about 3 feet by 1
foot, excavated or chi
concrete surface area.pped Onetoand
sound concrete,inch
one-quarter and (11/4)
cleaned the
diameter
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probe holes and grovt access holes were drilled in the liner plates
to determine the extent of and to assure full definition of the void '
area. Air access holes were drilled in the stainless steel liner ,
plates to assure that grouting would be accomplished in accordance '
with the procedure.
The procedure (DCA-20856) specifed that the grout was to be cured
for 28 days or until the grout reached a compressive strength of 4000
psi. Repairs to the liner plates were specified in DCA-20856 and G&H
Procedure 2323-55-18.
DCA-20856 required that under no circumstances was cutting of the
liner across weld seams, across embedded weld plates, or ' nto leak
chase seal welds or drilling through the liner at leak chase channels,
embeds, or weld seams permitted. Documentation review indicated that
DCA-20856 was adhered to and that no cutting or drilling occurred in
prohibited locations.
No violations or deviations were identified.
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l 6. . Nondestructive Testing Observations of Liner Plates in Fuel Transfer
canal
The NRC inspector observed portions of non-Q liquid penetrant examinations <
(PT) being performed on liner plate welds following re-installation of the ;
liner plates in the areas of the fuel transfer canal removed for inspection a
and repair cf the concrete. The inspector performed the pT on the welds '
as required by the repair package and the procedure (Q14-11.18-1, !
,
' Liquid Penetrant Examination"). Scattered weld porosity has identified
by the inspection. The porosity was ground out and a repeat PT was 3
performed. The final inspection is scheduled to be performed by QC
inspection personnel. The liner plate areas to be inspected by PT were
identified in DCA 20856.
I
No violations or deviations were identified.
7. Cadwell Splice Observations and Records
a. Calibration of Tensile Tester
The NRC inspector observed the calibration of the Tinus-Olson
Universal Testing Machine (Model Number 600-12 Identification Number
M&TE-784) on April 2 and May 7, 1985. The machine was calibrated
just prior to performing tensile testing of cadweld splices ano
subsequent to completion of tensile testing each day that tensile
testing was performed. The machine calibration date for April 2,
1985, prior to start of tensile testing was observed by the NRC
inspector and recorded as follows:
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Nominal load Calibration Reading Error Error Remarks
(1bs) (Ibs) (1Ds) 5
! 0 0 0 0 0 machine on
4/2/85
100,000 99,750 +250 +0.25
200,000 199,600 +400 +0.2
300,00 299,450 +550 +0.18
350,000 350,300 -300 -0.08
400,000 401,200 -1200 -0.03
500,000 501,3E0 -1350 -0.27
600,000 602,450 -2450 -0.40
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The NRC inspector reviewed calibration data for March 4. March 8,
April 2. April 3 April 30, and May 7,1985. All calibration data l
met within the +/- 15 accuracy requirement specified by Calibration
Procedure 35-1195-IE!-37 Revision 3, dated March 11, 1982. The
reference standards were identified as follows:
ID Wo. ._ Manufacturer Calibration Due Date l
RS-75 BLH Ele tronics January 27,1987
RS-75.3 BLH Electronics January 27, 1987 j
b. Observation of Cadweld Solice Tensile Testing l
(1) Qualification Tensile Testinc
On April 2,1985, the NRC inspector observed the following j
tensile testing of cadweld splices for cadwelder qualification: '
E80 08, G8H Q1, GBH Q2, G8V Q1, BFD Q4, SFD Q3 SFH Q4, GAH Q1,
,
GAV Q1, and G8V Q2.
Each of the above qualification cadweld splices was tensile l
ter4ed to 400,000 pounds (100,000 psi) and met the req'utrements i
stated in the procedure.
]
(2) Production Tensile Testino l
The NRC inspector observed the tensile tester calibrations and
the following production cadweld splices tensile testing on
May 7, 1985: FXD 3P, FYD 4P, FYO 8P, FRD 87P, and FUD 6P.
b Each of the above production cadweld splices was tested to
400,000 pounds (100,000 psiland met the requirements stated in
. the procedure. ,
(3) Imsta11ation of Production Cadweld Solices
_
The NRC inspector observed installation of rebar and cadweld
splices at frequent intervals (five or more observations per
week during the weeks of April 8.and 15; May 6,13, 20, and 27;
and June 3, 1985). The relar installation for the Unit 2
closure was perfomed in the area identified as elevation 805
feet to elevation 875 feet and azimuth 300 degrees to 335
degrees. The installation activities observed included rebar
spacing,1ontion of cadwelds, observation of selection and
removal for testing of cadweld splices for testin9, and
determination of location of rebars and cadwelds for the
as-butit drawings.
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(4) Documentation Reviewe.d
The NRC inspector reviewed t% following documentation for the ,)
rebar placement and cadwelding for the Unit 2 containment
(reactor building) closure area: !
Drawings DCAs NCR$
j
2323-$-0785, Rev.7 22616, Rev. 1 C85-200294
2323-5-0786, Rev.9 22728
2323-51-500, Rev.5 C85-200339. Rev.1 i
22737 C85-200355 Rev.1 i
2323-51-506, Rev.5 22836
2323-52-505, Rev.5 22878 (Sheets 1-7)
2323-52-508, Rev.2 22772
2323-S2-506, Rev.3
!
No violations or deviations were identified.
8. Concrete Batch Plant Inspection. Unit 1 and 2
}
The NRC inspector used a nationally recognized checklist to inspect the i
concrete production facilities. This list included the specific
characteristics for the following areas: (1) material storage and
handling of cement, a gregate, water and admixture, (2) batching
equipment scales, wei hing systems, admixture dispenser, and recorders,
(3) central mixer (not ap
[ ticketing system, and (5)plicable
deliverybe::ause
system. it had been dismanteled), (4) i
The current batching is a manual operation since almost all concrete has
- been placad. The central mixer was disuanteled and removed from site two '
or t..ree years ago when concrete placement was virtually completed.
Presently, the backup batch plant (which was a backup system for the
central mixer) is in operation to complate the remaining concrete
placements. This batch plant is in good condition and complied with the
subject checklist except for one aria.
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The NRC inspector inspected the inside of one of three trucks used for
mixing concrete (that is, the batch plant dispenses the correct weight of
materials as required by the specific design six numbers and the truck
then mixes the batch to be placed.) The blades inside the truck are
subject to wear and should a checked at a reasonable frequency. The
Brown & Root (B&R) representative responsible for checking the blades in
accordance with BAR Procedure 35-1195-CCP-10. Revision 5. dated
December 4,1978, was asked for evidence that the blades had been checked
for wear on a quarterly basis and it was found that there was no record of
such checks dating back to 1977 when they were initially checked.
,
Procedure CCP-10, paragraph 3.10 * Truck Mixing'. is silent on blade wear
but Section 3.11 infers that the blades should be ch6cked for both
central and tru-k uixing. The inspection of both central and truck
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mixing bladet was not documented, although the B&R representative stated
that the mixing blades were periodically inspected and laboratory testing
would have probably indicated if there was a problem with the mixing blades.
Strength and uniformity tests have consistently been within the acceptable
range indicating that concrete production was acceptable even though
mixing blade inspection was not documented.
Otherwise, the condition of the inside of the truck was satisfactory as
the drum and chtrging/ discharging were clean. The water gage and drum
counter were in good condition.
This failure to follow procedures is a violation of 10 CFR 50, Appendix
B, Criterion V. Subsequent to the idantificetica of this violation, the
blades were checked fcr wear and blade wear was presently within allowable
limits (445/8507-04; 446/8505-02).
No other violations or deviations were identified.
9. Calibration Laboratory for Batch Plant Unit 1 and [
The WRC inspector obtained batch plant scale numbers from tags which
indicated that the scales had been calibrated and were w' thin the
calibration frequency. Cement (MIE 779) Water (KTE 766), admixture
scale (MTE 764), and aggregate (MTE 780),were reviewed. The scales had
been periodica)1y calibrated since the batch plant was activated. The
records were adequate except as follows:
e. Scales MTE 766 records do not clearly differentiate between the
required accuracy of the scale and the digital rendout.
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b. Scales NTE 779 and 780 records show various accuracy ranges for the
same scale; i.e., KTE 779 (SN749687) records the following: report
dated Jan'uary 1976 gives 1%; report dated July 1976 gives 1% while
the report dated October 1976 gives +/- D.25.
the above items are unre-
The
solvedcalibration appeared
pending further reviewtoofbe
theproper, however,s actions regarding the
applicant
correction of these records (445/8507-05; 446/8505-03).
c. Recotds for scales MTE 779 records contained BAR memo IM-1108 dated
July 16,1975, which described a nonconforming condition. This
condition affected the water and cement scales causing a 24-48 pound
deviation during the calibration test. The meno stated that the
condition was corrected and the scales were then calibrated;
however, no deficiency report was written as required by B&R
Procedure Ce-QCP-1.3, * Tool and Equipment Calibration and Tool
Control * dated July 14,1975, and CP-QAP-15,1, ' Field Control of
Nonconforming Items," dated July 14, 1975. As a result there is no
evidence that corrective action included an evaluttien to determine
if concrete production was adversely affected.
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This failure to assure that a nonconforming condition was evaluated I
is a violation of Criterion XV of 10 CFR Part 50, Appendix 8,
(445/8507-06; 446/8505-04). 1
.
10. Concrete Laboratory Testina Units 1. and 2
.
TUGC0 procedure QI-QP-11.1-1, Revision 5, was compared with ASME i
Section 111, Division 2, subsections 5222, 5227 and 5224 to assure that -'
each ASTM testing requirement was incorporated into the procedure.
The NRC inspector inspected the testing laboratory equipment and found
the test area and equipment were in good condition and each piece of l '
equipment was tagged with a calibration sticker which showed it to be
within the required calibration frequency. Test personnel were knowledge- '
able of test requirements and equipment.
The NRC inspector witnessed field tests performed by laboratory personnel j
as follows:
Date Truck No. Mix Wo. Ticket No. Air Content (S) Slump (in.) Temp (*F)
6/3/85 RT-41 925 64013 Req 8.2-10.3 MA 70 max !
Men 8.7-9.1 NA 57
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6/3/85 RT-35 123 64014 Req 5.0-7.0 5 max 70 max l
Maa 6.6 6.25* 57
* Truck was rejected by quality control but was later accepted when second 3
slump reading came into reqrired range. J
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The following laboratory equipment was checked and found to be within
calibration: Forney Compression Tester, MTE 3031; Temperature Recorder
MTE 3013 and 3014; Unit Volume Scale, NTE 1053; Pressure Meters NTE
3000B, 3002 and 3004; Steves MTE 1286, 1239, 1272, 1274, 1136A, 1156
1094, 1093, 1095 1178,1179,1300 and 1180; Aggregate scales, MET 1058
and 1067; and 2", grout mold MTE 1111.
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The following test records for placement number 201-58C5-034 were '
reviewed: (1) concrete placement inwtion, (2) concrete placement
summary and, (3) unit weight of fres1 concrete.
No violations or deviations were identified.
11. Inspection of Level C and D Storace Unit I and 2
The NRC inspector inspected all laydown areas where piping, electrical l
conduit, cable, and structural reinforcing steel were stored. These
materials were neatly stored outside on cribbing in well drained areas
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which allowed air circulation and avoided trapping water. This met the
Level "D" storage requirements of ANSI N45.2.2. i
The electrical warehouse contained miscellaneous electrical hardware.
This building was required to be fire and tear resistant, weathertight, and
well ventilated in order to meet Level "C" storage requirements. This warehouse
was well kept and met all requirements except for a lock ticrage area
located upstairs at the rear of this building (electricai termination
tool room). Two minor problems were identified and the warehoue
personnel initiated action to correct them.
The first problem noted was that a box of nuclear grade cement was urked
' shelf life out of date" but it had no hold tag. The box was
subsequently tagged with Nonconformance Report (NCR) E85-200453 after
being identified by the NRC. During discussions with the warehouseman,
the NRC determined that engineering told the warehouseman to mark the
material and lock it up, but did not tell him to apply an NCR or hold
tag. TUEC should determine if engineering is aware of nonconforming
material controls and provide training if this is other than an isolated
instance. 1.1s0, the NRC inspector noted a very small leak in the roof
above the electrical termination tool room. This leak was in an area that
did not expose hardware to moisture. The roof is currently being repaired.
The millwright warehouse storage area was inspected; however, only e
small number of items or materials were stored in this area. The overall
,
1
storage conditions in this area met or exceeded Level 'C' storage
requirements.
No violations or deviations were identified.
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12. Reactor Pressure Yessel and Internals Installation - Unit 2
This inspection was performed by an NRC inspector to verify final
placement of the reactor pressure vessel (RPV) and internals by examining
the completed installation and inspection records.
a. Requirements for Placement of RPY
Requirements for placement of the RPV to ensure proper fit-up of all
other major NSSS equipment are in Westinghouse Nuclear Services
Division (WSD) ' Procedure for Setting of Majer MSSS Components",
Revision 2, dated February 13, 1979, and * General Reactor Vessel
Setting Procedure' Revision 2, dated August 30. 1974. The NRC
inspector reviewed the following drawings, which were referenced in
the RPY cperation traveler, to verify implementation of WESD
recommendations:
o
WSD drawing 121DE59 " Standard - Loop Plant RY Support Hardware
Details and Assembly"
o
WSD drawing 1457F27 " Comanche Peak SES RCS Equipment Supports
- Reactor Yessel Supports" 1
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o CE drawing 10773-171-004 ' General Arrangement Elevation *
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o CE' drawing 10773-171-005 " General Arrangement Plan"
Neither site prepared installation drawings nor specifications
(which implemented the WSD recommended procedures) were available !
and the drawings examined did not show certain specific installation i
criterion such as centering tolerances levelness tolerances and ;
. clearance between support brackets and support shoes. The lack of
engineering documentation did not provide full control of the
"
action and would allow changes to installation criteria taportant to
safety to be made without complying with established change procedures.
4 f This is a violation of 10 CFR 50. Appendix B. Criterion Ill
,
(446/8505-05). .
b. Document Review
Qu&Awi-
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The NRC inspector reviewed B&R Construction and Operation Traveler
No. ME79-248-5500 which described the field instructions for
installation of the Unit 2 RPV. Requirements recommended by WSD
procedures were implemented in the traveler. Worksheets attached to "/"
the traveler showed the RPV to be centered and leveled within the 5 ;
established tolerances. Traveler operation 19 required verification )
of a 0.020 to 0.005 inch clearance between the support bracket and l
support shoe, after applying the shim plates. Change 5 subsequently
changed the clearance to a 0.015.to .025 inch clearance. The
installation data reflected in attachment 38 of the traveler
indicated an as-built clearance of 0.012 to 0.026 inch which exceeds
both the original and revised tolerances. This conditipn was acceeted g
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on the traveler based on Westinghouse concurrence, and*uere were
neither nonconfomance reports nor documented engineering evaluations
to detemine if the condition was acceptable. This failure to
document
violation of nonconforming conditions
10 CFR 50 Appendix and engineering
B, Criterion (deviations is a
XV 446/8505-00) '
The NRC inspector reviewed the following receiving re:ords for RPV
hardware ar.d found them to be in order: j
o Report No.14322 for 54 each closure studs, closure nuts, and I
closure washers
o Report No. 09507 for vessel !/N 11713. Closure Head 11713 and !
26 0-Rings
o Deviation notices and corrective action statements
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The NRC inspector reviewed the following completed travelers for
internals installation and found them to be satisfactory:
o ME-84-4641-5500, ' Assemble Upper Internals *
o ME-84-4503 4000, " Install and Adjust Roto Locks"
o ME-81-2145-5500, "Retorque UI Column Extension"
o RI-80-385-5500. " Transport and Install Lower Internals *
c ME-84-4617-5500. " Repair Lower Internals *
o ME-84-4640-5500, ' Assemble Lower Internals' I
c. _ Visual Inspection ,
~ At this time, visual inspection of the internals by the NRC inspector was
not possible, and inspection was limited on the vessel placement to a
walk-around beneath the vessel to inspect the azimuth markings and for
construction debris between the vessel and cavity. No problems were
identified in this area.
d. Records of QA Audits or Surveillance
The NRC inspector requested TUGC0 QA audits or surveillance perfomed j
by TUGC0 of the Unit 2 RPV installation. TUGC0 did not make available
any documentation of an audit or surveillance which evaluated speci-
fled placement criteria, placement procedures, hardware placement, or l
- as-built records. This ites is unresolved pending a more comprehen-
sive review of these activities (446/8505-07).
No deviations were identified; however, two violations were identified
and are described in the above paragraphs.
13. Reactor Yessel Miserientation ,
On February 20, 1979, the applicant reported to the NRC Resident !
Inspector that a design errer had resulted in the reactor support
structures betrg placed in the wrong position on the reactor support
pedestal such that the reactor would be out of position by 45 degrees.
Initially. Unit 2 was to be a mirror image of Unit 1 however, a design
change was initiated to pemit identical cosponents for both units. The
design change was implemented for the reactor vessel, but not for the
pedestal support locations. The probles was not considered by the
applicant to be reportable under provisions of 10 CFR part 60.55(e) sir,ce
the error could not have gone undetected.
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The deficiency was reported to the NRC Office of Inspection and Enforce-
ment on February 22, 1979 and during a March 27, 1979 meeting in 50thesda,
Maryland, the applicant presented the proposed redesign and reuotk proce-
dures for relocatirg the pedestal susports. No unresolved safety concerns
with the repair were identified at the meeting.
During this inspection the NRC inspector reviewed various documentation
relative to tne disorientation problem, including design changes and the
construction traveler which implemented the repair.
The following documents were reviewed:
o NRC Insp;ction Reports 50-446/79-03; 50-446/79 07; 50-446/70-13
o TUSI Conference Memo, dated March 1, 1979 H. C. Schmidt to
S. Burwell (NRC Licensing PM) I
i
o TUGC0 letter TXX-2980, dated April 30, 1979, to W. C. Seidle
o NRC letter to TUGC0 dated May 29, 1979
o DCA 3872 Revision 1, dated February 28, 1979, Subject: Rework of
Structure for Placement of the RPY Support Shoes
o DCA 4122, dated March 22, 1979, Subject: Replacement of Rebar for
RPV Supports
{
o Construction Traveler CE79-018-5505, dated March 14, 1979 Subject:
Rework of Reactor No. 2 Cavity - New RPV Support Locations
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o Grout Replacement Cards No. 007, 008, 009, 010, 014, and 015, various
dates, Subject: Replacement of Grout around Rebar for Repair of RPV
Support Shoes
)
o Various Inspection Reports for Grout Properties and Application for
RPV Support Shoes -
No violations or deviations were identified.
)
14. Reactor Coolant Pressure Boundary (RCPB') Systems C'
The inspection was performed to verify: the applicants system for
preparing, reviewing, and maintaining records for tha RCPB piping and
co'uponents; that selected recceds reflected compliance with NRC
requirements and SAR commitments for manufacture, test and installation
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of items; and as-built hardware was adequately marked and traceable to
records. . The following items were randomly selected and inspected:
a. pressurizer Safety Valve - This item was inspected to the coenitment
stated in F5AR, Table 5.2-1 which includes ASKL Section III,1971 4
Edition througn Winter 1972 Addenda. Valve S/N N56964 00-007, which )
;
is installed in the B position was inspected. The following records 1
were reviewed:
f
o CA Receiving Inspection Report No. 21211
o Code Data Report Form NY-1
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c Valve Body CHIR 1
The valve was in place, however, installation had not been
/ e.eJ w -
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completed; therefore, the hardware installation inspection consisted !
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of verifying that the item was traceable to the records.
b. CYCS Spool Piece 301 - Requirements for this item are stated in
A5ME, section III,1974 Edition through Summer 1974 Addenda, which . I
is the comitment from the FSAR, Table 5.2-1. The item was field l
fabricated from bulk piping and purchased elb9ws and installed in the !
CVCS with field welds number 1 and 6 (ref. BRP-CS-2-RB-076). The i
following records were reviewed:
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o B&R Code Data Report
o Field Weld Data Card
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o NDE Reports
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o QA Receiving Reports for piping and elbows
o certified Material Test Reports (CMTR)
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The installed spool piece was inspected for weld quality and to
verify that marking and traceability requirements had been set. The
itee had been marked with the spool piece number (3Q1) and the BAR 3
1
drawing number which provided traceability to thc material
certifications. !
{
c. Loop 3 RC Cold Lee - Requirements for this item are stated in ASME,
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sec; ton Ill, m4 Edition through Summer 1974 Addenda, which is the
commitment from the FSAR, Table 5.2-1. This piping subassembly
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consists of a 27.5 inch cast pipe with a 22 degree elbow on the 1
reactor end, a 10 inch 45 degree nozzle, a 3 inch nozzle, and three 1
21/2 inch thernowell installation bosses. The following records
were reviewed for the subassembly:
o QA Receiving Inspection Report No. 12389
o Westinghouse Quality Release (QRN 47523)
o Code Data Repert Form NPP-1
o 271/2 inch line CMTR I
o 3 inch nozzle LNTR
c Field Weld Data Cards
o NDE Reports
(1) Sandusky Foundary and Mat. hine Corpany test report for the cold
leg p pe certifies that material meets requirements of ASME
Secti n II, 1974 editions throJgh winter 1975. Southwest
Fabrication and Weiding Company code data report WPP-1 Form
certified that the cold leg subassembly set requirements of
{ ' ASME Section 111, 1974 edition through winter 1975. The FSAR
comitment is ASME Section !!!,1974 edition through sumer
1974. This discrepan:y is unresolved pending the applicant's
evaluation to determine if material nonconformances exist
(446/8505-08).
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(2) The NRC inspector reviewed the procedures and hydro test data
applicable to Unit 1, since Unit 2 hydro had not been completed.
Requirements for the tests were presented in Procedures i
CP&QAP:12.2, ' Inspection Procedure and Acceptance Criteria for
ASME Pressure Testing * and CP-QAP-12.1, *ASME Section !!!
Installation, Verification, and N-5 Certification." Procedure
CP-QAP-12.1 requires that a data package to be used in the test,
be prepared with the test boundary and the additional following
data shown:
o
Base metal defects in which filler material has been
added, and tha depth of the base metal defect exceeds 3/8
inch or 105 of the actual thickness, whichever is'less.
u Untested vendor performed piping circumferential velds.
o Approximate location and material identification and
)
description for permanent pressure boundary attachment !
with applicable support number referenced.
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o Weld history, which shall reflect weld removal and/or weld '
,
repair.
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The completed hydro data package (PT-5501) for Unit 1, loop 3
cold leg was reviewed for compliance with the above
requirements. Drawing No. BRP-RC-1-520-001 had been used to
' annotate the test boundary. A handwritten statement on the
j
drawing" indicated: "No major base metal repairs could be ,
located and "No hangers with weld attachments could be
l oc ated." Welds perfonned by the pipe subassesSly vendor,
including the 22 degree circumferential weld and the
penetration fittings had not been identified. The following
items are unresolved pending further review to determine:
o If "no major base metal repairs' was based on a visus 1
inspection or on a review of vendor and site inspection
and repair records.
e If the shop circu.nferential weld attaching the 22 degree i
elbow to the pipe assembly was inspected during the test.
o If welds for penetrations into pipe assembly were inspected
as procedure CP-QAP-11.1 d0es not require identification of
such welds and they were not identified on the drawing.
The above issues will remain unresnived pending further
evaluation by the appiteant (445/8507-07; 446/8505-09).
d. Personnel Qualifications - Perser.nel who had performed selected tasks
were identif f ed during inspection of installation records. Training
and experience records for the personnel were reviewed to verify
that employee qualifications and maintenance of records were current
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and met requirements. Names or codes for five welders and two NDE
examiners, who had performed tasks during installation of the items
being inspected, were identified and their qualification records
reviewod. There were no questions in this area of the inspection.
No violations or deviations were identified.
15. Special Plant Tours (Unit 1 and Unit 2)
On May 23, 1985, the NRC inspector conducted a tour of selected areas of
Unit 1 and Unit 2. The group consisted of one NRC inspector, twc WRC
Technical Review Team (TRI) representatives, two allegers, and several
TUEC representatives. The TUEC representatives tagged cach area where a
deficiency was allaged. With the alleger's consent, a tape recorder was
also used to note locations and 6escribe any alleged deficiencies. The
allegers irdicated that they had identified all deficiencies during the
tour and all other deficiencies that they had knowledge. The NRC TRT is
analyzing this information and will decide what actio6, if any, should be
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During this tour the NRC inspector independently identified a questionatie
practice in that the top of the the. pipe ch.ase at the north end of room 88
in Unit 1, safeguards building had two large stickers which stated that
areas on the wall were reserved (or pipe hangers GHH-51-1-SB-038-006 and
R1(?)1-087-X11. These stickers were dated 1980. It was not evident
whether hangers were missing or none were needed in these locations and
the reserve tags were not removed. TUEC representatives were unable to
answer the question tenediately. This item is unresolved pending further
review during a subsequent inspection. (445/8507-08).
No violations or deviations were identified.
16. Reutine Plant Tours (Units I and 2)
At yarious times during the inspection period WRC inspectais conducted
general tours of the reactor buildlag, fuel building, safeguards
building, electrical and control building, and the turbine building.
During the tours, the NRC inspector observed housekeeping practices, .
preventive maintenance on installed equipment, ongoing construction work, '
and discussed various subjects with personnel engaged in werk activities.
No violations or deviations were idef tified.
17. Review of Part 21 and 10 CFR 50.EM e) Construction Reports Status
The NRC inspector reviewed all reports issued to date to assure that NRC
and TUEC status logs were complete and up to date. A total of IS3 !
reports have been submitted to date. This inspection period one Part 21 . '
report on Die:e1 Generator Oil Plugs and two 10 CFR 50.55(e) reports on
the Equipment Hatch Cover and SAIO6 Piping (light wall) were submitted.
1
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No violations or deviations were identified. {
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18. Review of Violation and Unresolved Item Itatus ;
The NRC inspector reviewed all violations and unresolved items reported
to date to ascure that NRC and TUEC status logs were complete and up to i
date. Two hundred nineteen items were reviewed. In addition, a trend !
analysis of WRC findings was performed to generally determine how many
findings could be broadly class (fied under each criterion of 10 CFR,
Part 50, Appendix 8. The frequency of findings showed broad and general
trends under the following criteria: II. QA Program; III. Design Control;
V. Instructions, Procedures and Drawings; VII. Control of Purchased
Material, Equi twnent and Services; IX. Control of Special Processes; X. j
Inspection; XI. Test control; YIII. Handling Storage and Shipping; XVII. i
QA Records; and XVI!! Audits. The most significant trends uere
Criterion III, V, VII, IX, X, and XVIII. Also, a number of violations ,
occurred with respect to 10 CFR 50.55(e) itws.
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,
-21- .
f .
.
These findings mainly pertained to Unit 1 and related closely to trends
identified by the NRC Technical Review Team TRT. These trends will be 'i
co.1sidered during followup on TRT findings'. Also, Unit 2 inspection
emphrsis will consider these trends during future inspections.
No violations or deviations were identified.
19. Exit Interviews
The NRC inspectors set with members of the TUEC staff (denoted in
paragraph 1) on May 1C and June 10, 1935. The scope and findings of the
inspection were discussed. The applicant acknowledged the findings.
1
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Pages ,30, 42, and 43 of OIA REPORT
l
~- .. ..
M siated he observed on the part of WESTERMAN, JOHNSON and a few others. ~
a continual stre m of comments about watchi PHILLIPS, not trusting PHILLIPS,
'
and watching your back with PHILLIPS, which concluded was based upon
PflILLIPS' perfomance at the South Texas Pla ere he identified a number of
deficiencies in the utility's operation. .
opined thcre was some
distrust and some dislike and apprehension about having a strong-wil. led,
meticulous and capable person on the staff who was not easily swayed to a
different goint of view. further opinti that WESTERMAN Snd JOHNSON
were of 11 ce mind so an appea o ~an inspector would r,st Itkely be heard
strictly on its merits. They would back each other up (Attachment R, pages <.
3-15, 18-19 and 55-56).
iormerlytheDirector,DivisionofReactorSafetyand
Projects, Region IV, from January 1084 to January 1985, was interviewed
concerning the adequacy of the Region IV QA inspection program at CPSES.
Mstated his belief that the attitude of Region IV management was that it
,
did not want to create too mat.y preblems for the utility. He added that this
was difficult to determine conclusively; however, when he looked at the facts,
he found that the amount of inspnction activities compared to the need at the
pitht was very small, and that for a considerable pdriod of time, almost all
the_inspectionLat CPSES were done b.y the Resident _Inspntor with_yery little .
regional support. W stated that it was a fact that the inspections were not ,
being done. '
_Nfurther elabcrated on the Region IV inspection program b opining that
the Region did not have a strong orientation to QA progruns. believed
ithat had Region IV had such a strong orientation over the years, the problems
seen at CPSES, South Texas and Waterford would never have arisen. When asked
if greater emphasts by Region IV on the QA aspects of the NRC insrection !
program at CPSES could have resulted in TUGC0 implementing a better QA program
at an earlier stage, DENISE stated that he believed this to be true. He added
that if the program for QA is not strong, then any deficiencies which occur in
,
'
the construction organization will simply be magnified.
.
He stated that TUGC0 did not have e strong QA pro rem and the Region did not
remedy that situation over a period of years. _ further considered it a '
very severe deficiency" on the part of Region IV to have not: conducted an i
inspet: tion of TUGCO's corporate QA program and.taken corrective action _.
However.Mdid not believe the NRC should do the utility's job. E..
connented that.even though Region IV may not have fulfilled its
~
responsibilities, the utility cannot blame the NRC for its mistakes. However,
the NRC would have better represented the public, boi;h in tenfis of health and ,
safety and in terms of. expense, had Region IV demanded and obtained better -
1
q
,uality assurance from TUGCO. (Attschment R, page.s 6-9 and 23-25).
. . . . .
' i
EXHIBIT 12b
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correct because of already completed construction. This
2
,
,
is different than operating plants where deficiencies
3
in operating people and operating procedures could be
4
,
remedied without significant rework in a constructed plant.
c !
8
,
Nevertheless, Comanche Peak did not appear
'
6
,,
1
to me.at the time that I arrived in Region ~Four to have had 1
7
<,
an aggressive inspection program for a period of years.
8
I had conversations with the former senior resident
9
inspector, Mr. Robert Taylor, who told me that he had .
!
10
repeatedly appealed for assistance from the Region in l
11 l
conducting construction inspections, and that these appeals '
12
had not been responded to. The upshot of all this was ;
13
that the regional administrator had already given up
.
14
regaining control of inspection activities at Comanche
.
5. 15
Peak and at Waterford, and this was. simply implemented
~
!
! 16
soon after I arrived.
*
8 17 i
0 How would, I guess when we're talking
i !
i 18 a
about regional management we're talking about Westerman !
.I
up
g
andCheckandEricCohf* son. How would they pass on their f
i, 20
attitudes concerning specifically TUGCO to tha inspgetion, J
.
i
P
21
the resident inspector to l'e( thru know, you know, this
22
l is, we think TUGC0 does a pretty good job. They're being ,
25
unfairly criticized by intervening groups, therefore,
1
24
let us help them along. How would that attitude get passed j
.
25
along to the inspectors?
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Well, first of all, the attitude was passed
2 1
.,
on by lack of assistants to provide help to inspect the
3
plants. If you don't inspect, you will not find any
.
4
vAolations.
6
Secondly, one of the very favorite
6
.
approaches to discourage inspectors in writing violations
7
,and writing reports on those violations is to worry their
8
work product to death and question it to a great extreme.
3 ~
In dealing with the inspectors who worked
0
for me while I was in Region Four, I always conveyed to
11
them the attitude that if it looked like a violation and
12
smelled like a violation, then write it up as a violation
13
and let the utility defend itself against that violation.
14
If the utility was able to show that it was not actually
15'
in violation of the regulations, then I was perfectly
16
,
willing to retract the violation.
17 '
The attitude that led to worrying the
18
inspectors' report and the inspectors' notice of violation
18
to death simply me'ar.t' ,that the irispe' ctor would be
#
discouraged from writing notices of v.iolation because ,
21
he had to jump through so many hoops to get it out.
22
Whether or not that attitude and those actions of worrying
28 l
the violations to death sprang from the attitude of wanting l
24 I
to go easy on the utility or simply wanting to have an !
25
airtight court case before any notice of vio1' ation was
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1 issued would be difficult to tell.
.
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2 In my own view, the attitude of not
". ,
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3 regulating violations was the strongest force. I had
4 a sufficient number of discussions with Westerman to '
;
6 conclude that Mr. Westerman rea11y didn't believe in
, 6 enforcement. He didn't believe in enforcement as a means
A
i
7 of achieving compliance with the regulations, and so he 1
L e participated in worrying the paperwork to the point that
g
less than the number of violations that could have been j
.
10 written-were actually written.
11 ,
I veiwed the attitude of Mr. Check'as .
{
12 quite strongly anti-enforcement. Mr. Check on more than
,
13 one occasion told me that utilities had been licensed ,
i
14 by the NRC, had been found competent by the NRC, 'and that
j 15 } we should be extremely cautious in saying otherwise,
2
l 16 particularly in violations. So I considered Mr. Check
8
17 a very weak enforcement. advocate.
I
; la In addition to that, I believe that
I
y
e
gg
Mr. Check was greatly influenced by the political aspects
I
'
r
go ofanyoftheoperationsweMonductedwiththeutilities
'
i 21 or against them in terms of enforcement. In fact, I believe
i *
22 that Mr. Collins, who was a radional administrator, was
'
23 also very much swayed by the political environment within
24 the NRC and in conjunction with the licensee.
25 Q
How did, how would Westerman go about '
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I worrying inspection findings? Would he confront the
, )
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2
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inspectors head-on? Just drop violations frpm the report? !
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How would he go about that?
l
4
A While I was there I had no knowledge that
5
Mr. Westerman ever dropped a v'i'olation frem a report from
6
'
one of my inspectors. He would have direct contact with
,
7
the inspectors for the intended and correct purpose of
8
being sure that the notice of violation was written clearly
_ _
8
and well written with proper citations against 'the
1G ' regulations. That was his primary job.
11
In addition to that, of course, he had
12
the job of keeping track of the violations so that we I
'
13
could see that violations were answered and otherwise
14
responded to. I'm sure that he had many conversations l
15
with inspectors, and some of them got back to me, and
16
I can't remember the specifics, where he would argue that
11
something really wasn't a violation, and as I say, that
18
wasn't my attitude._ If it looks sufficiently like a
18
violation I would let the utility defend itself, rather
80 i
than have Mr. Westerman B,efe'nd th'd utility on violation.,
, ;
21
I don't say that Mr. Westerman's
22 J
contributions were all negative. He did call our attent, ion
l
25 i
to the need for greater precision in our language a number
l
24
of times, and this was beneficial. But overall,
1
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23
Mr. Westerman's attitude was anti-enforcement,
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13
,
! ,In addition to direct contact with
.,
,
2
inspectors, he interacted with section c,hiefs and branch I
j
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chiefs on the production of inspection reports and e.ny
i
4 accompanying notices of violation. In this interaction
6
I was told a number of times tNat Westerman didn't think
6 that a violation was an appropriate vehicle to achieve '
7 the corrected action. I can't recall any instance where
~
8
I agreed with that decision on his part.
9 -Q How would he prefer to handle it?
i
10 A He would have preferred to handle it by
11
discussing the matter with the licensee and by heving
12
any documented record be observations in the inspection
13 reports, rather than clear violations.
%
14 Q How would Mr. Westerman handle a disagreement
-
.
i 15
between himself and an inspector? For example, if he f
! !
[ 16
l didn't think something should be a violation, if he wanted ,
{ 17
to downgrade it to an unresolved item or something like
i
!. 18
that? Do you have any knowledge of inspectors just /
'I
} 19 agreeing with his call or how he handled 6that?
1
3D A I can't recall any,at the moment, and
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;
21
by and large I relied upo'n'the people that worked for
i .
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21 me to work througn that process. But Mr. Westerman normally
23
would have interacted with the section chief or more likely
24
the branch chief, Mr. Johnson, to gain his acceptance
25
of Westerman's conclusions,'and to you see, we have people
_ _ _ _ _ _ _ _ _
- _ - _ _ _ - _ _ _ _ _ _ _ _ _
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I lined up in a row and..an ins.pe.ctor who wants to write
_ _ . . , -
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2 a violation, a section chief who may have no strong feelings I
e
3 one way or the other, and a branch chief attempting to
_ )
4 make a call based on his attitudes, as well as the facts
5 available to him a d being in'fluenced by Mr. Westerman l
- . - - . . - . . - . . .
6 who basically had an anti-enforcement attitude, and in
!
7 someway that I couldn't testify to influenced by the
a regional administrator and deputy regional administrator.
g
I'd say at that time that, and I'm speaking
l
10 new of the time frame when I first arrived, the relationships
l
between regional administrator and the deputy regional'
-
11
12 administrator were poor. They simply.didn't like each
13 other, and they didn't share office responsibilities.
14 In fact, you might say there were at least two camps in
15 Region Four. That camp who, that didn't like Mr. Collins,
16 and that camp that was more dedicated to doing their job
17
I
than deciding whether they liked him or not. That didn't
18 have anything to do with whether they did their job or
tg not.
'
s . . .
so I forget the. exact data, but Mr. Martin
21 replaced Mr. Collins as regional administrator. From
22 the enforcement viewpoint I e nsidered this an improvement,
23 but my view on that was more influenc'ed by what Mr. Martin
24 said than by what I observed. Mr. Martin repeatedly said
25 in staff meetings and in briefings with the staff and
.
_ . _ _ . _ _ _ _ _ _ _ _ - _ _ _ - _ - - - - - - - - - - - - - - - - - - - ~ - - - - - - - - - - - - ' - - - - ~ - ' - - - - - - ' ' - - - ^ ' - - - - ' - ^ - - - ' - ~ ~ ~ ' -'
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, t ..
i in Reply Refer.To:
-Dockets: -50-445/85-07 M5 0 31986
50-446/85-05
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Texas Utilities Electric Company
ATTN: W. G' Counsil
.
Skyway Tower
400 North Olive Street
Lock Box 81
, Dallas, Texas 75201
Gentlemen:
;
' This refers to the inspection conducted under the Resident Inspection Program
by. Messrs. J. E. Cummins and H. S. Phillips and others during the period 1
April 1, 1985, through June 21, 1985, of activities authorized by NRC Construc-
tion Permits CPPR-125 and CPPR-126 of the Comanche Peak facility, Units-1 and 2
.and to the discussion of our findings with Mr. J. T. Merritt, and other members of
-
your staff at the conclusion of the inspection. .
"
-
Areas examined during the inspection included plant status, action on previous
NRC inspection findings, action on applicant identified design construction
deficiencies (10 CFR Part 50.55(e) reports) and plant tours. Within th6se
areas, the inspection consisted of selective examination of procedures and '
representative records, interviews with personnel, and observations by the ;
inspectors. .These findings are documented in the enclosed inspection report.
During this inspection, it was found that certain of your activities were in
violation of NRC requirements. ~ Consequently, you are required to respond to
. this violation, in writing, in accordance with the provision of.Section 2.201
of the NRC's " Rules of Practice," Part 2. Title 10, Code of Federal u
'
Regulations. Your response should be based on th6 specifics contained in the
Notice of Violation' enclosed with this letter. Since B&R Procedure 35-1195-CCP-10
_-
has been revised to provide documented inspection of truck mixer blades, there
-
was no abnormal blade wear identified as a result of blade inspection, and there-
-
have been consistent concrete strength and uniformity tests, no reply to
violation 2.c is required. !
V
i
EXHIBIT 13
RSE b R!B h CPT G DRSP NRR '
HSPhillips/h DMHunnicutt TFWesterman EHJohnson VNoonan #
I ln /8G
,
i /%/86-
. l /f86 I /f/G
+
j/4/6 l
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/g;TO/
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_ _ _ _ _ .. - _ - _ _ - - - _ _ .
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L Texas Utilitiies Electric Company' 2 1. L . Should you' have'any questions concerning this. inspection, we will he pleased
to discuss them with you. -
Sincerely,
066*gg eped M
t. 3 y ::: '
E. H. Johnson, Acting Director
Division of Reactor Safety and
Projects
l; Enclosures:
1.- Appendix A'- Notice of Violation
2. . Appendix B - NRC Inspection Report
'50-445/85-07
. , 50-446/85-05
'
, cc w/ enclosure: ,
;
,_. Texas Utilities Electric Company *
'
ATTN: J. W. Beck, Manager,
Licensing
.. Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas 75201 .
Juanita Ellis
President ' CASE
1426 South Polk Street
Dallas, Texas 75224
--
Renea Hicks
.-
Assistant Attorney General
Environmental Protection Division
P. O. Box 12548
Austin ' Texas 76711
Texas Radiation Control Program Director
bectoDMB(IE01)
bec distrib. by RIV:
*RPB , * MIS System j
*RRI-OPS *RSTS Operator '
*RRI-CONST *R&SPB
*T. F. Westerman, CPTG DRSP
g V. Noonan, NRR R. Martin, RA 1
S. Treby, ELD l
l *RSB 1 *RIV File J. Taylor, IE
*D. Weiss, LFMB (AR-2015) R. Heishman, IE
i *w/766
,
- -. - - _ _ _ _ _ _ _ _ _ . -
_ _ _ _ _ _ _ _ - _ - - _ . - _ _ _ _ _ . _ - _ _ _ _ _ . - _ - _ - _ . _ - _ _ _ . _ __ . _ _ _- __
.
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APPENDIX A ?
, .-
NOTICE OF VIOLATION .
Texas Utilities Electric Company Docket: 50-445/85-07
Comanche Peak Steam Electric Station 50-446/85-05
Units 1 and 2 Permit: CPPR-120
CPPR-127.
1985, violations
During
of an NRC inspection
NRC requirements conducted
were identified. on April with
In accordance 1 through
the June 21, General Statem
of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C (1985), the violations are listed below:
~ '
1. Failure to Promptly Correct an Identified Problem with RTE - Delta
Potential Transformer Tiltout Subassemblies -
.
' ~
~ 10 CFR 50, Appendix B, Criterion XVI, as implemented by Texas Utilities
Generating Company (TUGCO) Quality Assurance Plan (QAP), Section 16.0,
Revision 0, requires that measures shall be established to assure that
conditions adverse to quality, such as failures, malfunctions, deficien-
cies deviations, defective material and equipment, and nonconformances are
promptly identified and corrected.
Contrary to the above, a potential problem with RTE - Delta potential
transformer tiltout subassemblies, which are used in the emergency diesel
generator control panels, was identified to the applicant via a letter,
dated June 15, 1933, from Transamerica Delaval Inc. This letter also
provided instructions for correcting the potential problem. However, the
-
applicant did not take the corrective action. The NRC initially reported
this item as unresolved in NRC Inspection Report 50-445/84-40.
'
This is a Severity Level IV violation. (Supplement II.E) (445/8507-01
446/8505-01).
2. Failure To Follow Procedures
10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 QAP,
Section 5.0, Revision 2 requires that activities affecting quality shall
be prescribed by documented instructions, procedures, or drawings, of a
type appropriate to the circumstances and shall be accomplished in accor-
dance with these instructions, procedures, or drawings,
a. Drawing 2323-51-0550, Revision 4. Section 6-6 specified the use of
Class E" concrete for the Unit I reactor coolant pump and steam
generator supports.
I
- _ _ _ _ - _ _ i
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Contrary to the above, commercial nonshrink grout was used to grout
<
the Unit I reactor coolant pump and steam generator supports in lieu
of Class "E" concrete. (445/8507-02)
This'is a Severity Level V violation (Supplement II.E).
b. Brown and Root Procedure QI-QAP-7.2-8, " Receiving of Westinghouse
Safety Related Equipment," Section 3.1.d.1, requires a QC inspector
to verify that the Westinghouse Quality Release (QR) document
checklist items be filled out completely and accurately.
Contrary to the above, the voltage recorded on Westinghouse QR 41424
checklist, attachment 1 step 4.1, was outside the specifieo
tolerance, but the QC receipt inspector accepted QR as satisfactory.
(445/8507-03)
,
This is a Severity Level IV violation. ,
i c. Brown & Root Procedure 35-1195-CCP-10, Revision 5, dated December 4,
___ 1978, requires that central and truck mixer blades be checked
quarterly to assure that mixer blade wear does not exceed a 1 css of
10% of original blade height. <
Contrary to the above, on May 31, 1985, the NRC inspector determined j
that there was no objective evidence (records) that the mixing blades
had been inspected quarterly since the trucks were placed in service
in 1977. (445/8507-04;446/8505-02)
This is a Severity Level V violation (Supplement II.E)
d. Brown & Root Procedure CP-QAP-15.1, " Field Control of Nonconforming
- "- * Item " states that nonconforming conditions shall be documented in a
Deficiency and Disposition Report (DDR). Procedure CP-QCP-1,3, " Tool
.
- Equipment Calibration and Control," dated July 14, 1975, states that
out-of-calibration equipment shall be identified on a DDR_.
Contrary to the above, on May 31, 1985, the NRC inspector reviewed
the calibration file for scale (MTE 779) used for weighing cement and
found that a 24-48 pound deviation from the required accuracy was
encountered with the water and cement scales during a 1975 calibration
of the backup plant scales, however, no DDR was issued to identify
this condition and require disposition of the scale and concrete (if
any) produced. (445/8507-06;446/8505-04).
This is a Severity Level IV violation (Supplement II.E).
.
__
,
i
-3-
Pursuant'totheprovisionsof10CFR2.201,TexasUtilitiesElectrfcCompanyis-
hereby required to submit to this office within 30 days of the date of the '
>
,
letter trar,smitting this Notice, a written statement or explanation .in reply,
including.for each violation: (1) the reason for the violations if admitted. -
the corrective steps which have been'taken and the results achieved. .
-
the' corrective steps which will be taken to avoid further violations, and 4
the date when full compliance will be achieved. Where good cause is shown, '
consideration will be given to extending the response time. , i'
*
,
,
Dated at Arlington, Texas,
this 3rd day of February,1986
- .
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h,p[G'. I '
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1
APPENDIX B
+
U..S.HUCLEARREGULATORYCOMMISSION' .
;, >
REGION IV .I
*
n.
NRC Inspection, Report: 50-445/85-07 Permit: CPPR-126
, -
, -50-446/85-05 CPPR-127
Docket: 50-4;s; 50-446
. I
'
-/
Applicant: Texas Utilities Electric Company (TUEC) l
Skyway Toweri
, '
'
400 North Olive Street
t.ock Box 81 1
, Dallas, Texas 75201
'
l
Facility Name: Comanche Peak Steam Electric Station (CPSES)
- -
Units 1 and 2 .
.' . .. .
"
Inspection At: Glen Rose, Texas !
-
l .Ir.spection Conducted: April 1, 1985, through June 21, 1985
' Inspectors: C d /U f
! '
H. 5. Fhillips, Senior Resident ' Tate
Reactor Inspector Construction
(pars. 1, 2, 3, 8, 9, 10, 11, 15, 16,
17, 18, and 19)
--
l5 9/? YW W1/25
d. E. Cumins, Senior Resident Reactor Date
j
: Inspector Construction (April 1 - May 10,1985)
(pars. 1, 3, and 19)
' -
Y/ /8l// W .
D. E. Norman, Reactor Inspector Date
(pars. 1, 12, 13, 14, and 19)
AkG
D. M. Hunnicutt, Section Chief
< W2/gr
Uate
Reactor Projects Branch 2
(pars. 1, 4, 5, 6, 7, and 19)
.
_ _ _ _ _ _ _ _ . _ _ _ _
...
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-2- l
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. Approved: bff) de.u 1Y~ //,1Sf8d
D. M. Hunnicutt, Section Chief, ' Date-
L Reactor Project Section D i
i
Inspection Summary
Inspection Conducted April l',1985, through June 21,1985(Report 50-445/85-07)
Areas Inspected: Routine, announced and unannounced inspections of Unit I
which:1ccluded plant' tours and review of plant status, action on previous NRC
inspection findings (*'iolations/ unresolved items), review of documentation for
site dams, and. review of 10 CFR Part 21 and 10 CFR Part 50.55ft i OcMtruction
7 deficiency status, The inspection involved 77 inspector-hours onsite by four
. , NRC . inspectors .
.
'
Results: Within the areas insnected, five violations .were identified: fail-
ure to promptly correct an identified' problem with RTE'- Delta Potential
' Transformer Tiltout Subassemblies, paragraph 3.a.; commercial non-shrink grout
was used to grout the Unit I reactor coolant pump and steam generator supports
in lieu of Class "E" concrete, paragraph 3.b.; hydrogen recombiners out-of-
specification voltage recorded on quality release document but QC receipt
. inspector accepted, paragraph 3.c; failure to provide objective evidence to
show.that central and. truck mixer blades were inspected, paragraph 8; and
failure to issue a deficiency report on cement scales that were out-of-calibra-
tion, paragraph 9.c.
Inspection Summary
,
Inspection Conducted April 1, 1985, through June 21, 1985 (Report 446/85-05)
Areas Inspected: Routine, announced and unannounced inspections of Urit 2
which included plant tours and review of plant status, actinn nn nrevious NRC
inspectiun findings (violations / unresolved items), review of documentation for
site dams, review of documentation for voids behind the stainless steel cavity
-liner of reactor building, observation of NDE on liner plates, inspection of !
concrete batch plant, review of calibration laboratory records for batch plant,
review of concrete laboratory testing, inspection of level C and D storage,
review of reactor pressure vessel (RPV) and pipin
review nf 10 CFR Part 21 and 10 CFR Part 50.55(e)g records / completed
construction deficiency work, and
status, and review of violation and unresnived items status., The inspection
involved 335 Inspector-hours onsite by four NRL Inspectors.
... ..-
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I -Resti ts: Withili~Yfie _ sixteen areas inspected three violations were identified:
1 ,
failure to correct RTE-Delta transformer problem, paragrapbtg; failure to
provide objective evidence to show that concrete central and truck mixer blades ,i
,
were inspected, paragrapj;L,gi and failure to issue a deficiency report on cement
scales that were out-of-calibration, paragraph 9c.
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DETAILS .1
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1. Persons Contacted
Applicant Personnel
M. McBay, Unit 2 Reactor Building Manager
B. Ward, General Superintendent, Civil
D. Chandler, QA/QC Civil Inspector
W. Cromeans QA/QC, TUGC0 Laboratory / Civil Supervisor .l
*#J. Merritt, Assistant Project General Manager j
*#P. Halstead, Construction Site QA Manager
#C. Welch QA Supervisor TUGC0 (Construction)
J. Walters TUGC0 Mechanical Engineer
K. Noman, TUGC0 Mechanical Engineer ~
i
-'. - J. h.te, B&R Materials Engineer
G. Purdy, 3&R CPSES QA Manager
i .
* Denotes those present at May 10, 1985 exit interview.
# Denotes those present at June 10, 1985 exit interview.
t The NRC inspectors also interviewed other applicant employees during this
inspection period.
2. Plant Status
UnitJ, )
At the time of this inspection, construction of Unit 1 was 99 percent
-
complete. The fuel loading date for Unit 1 is pending the results of
ongoing NRC reviews. ,
~~
I
Unit 2 ;
At the time of this inspection, construction of Unit 2 was approximately
74 percent complete. Fuel loading is scheduled for approximately 18
e months af ter Unit 1 fuel loading.
Applicant Action on Previous NRC Inspection Findings
/ 3.
a. .IClosed) Unresolved Item 445/8440-02: Potential Problem with
Potential Transformer Tiltout Subassemblies.
By letter dated June 15, 1983 Transamerica Delaval notified the
applicant of an RTE - Delta 10 CFR Part 21 report to the NRC
reporting a potential problem with the primary disconnect clips of
the potential transformer tiltout assem)1y used in the emergency
diesel generator control panels at CPSES. The Transamerica Delaval
L:_ _ _ - _ _ _--
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letter also provided instructions for correcting.the. pro $lem.
However, the NRC inspector could not determine if the problem had i
been corrected at CPSES and made. this an unresolved item; 'The
applicant determined that the problem had not been corrected and'
T subsequently. performed the recommended corrective action. The Unit 1
;
corrective action work. activities were documented on'startup work
permits 2-2912 (train A) and I-2914 (train B). The Unit 2 work. I
activities are being tracked as master data base (MDB). item 3003-31. I
,
- apparent
The f ailure to promp(445/8507-01; e46/8505-011.tly correct this identified fp
violation ~
J
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, b. ,1 Closed) Unresolved Item 445/AA.1M11: Commercial Grout Used in Lieu
of Class "E" Concrete j
*
, h The applicant determined that the use of.nonshrink' comercial greut 'l . !
in lieu of the Class "E" concrete specified on drawing 2323-51-0550 >
.
. was acceptable. Design Change Authorization 21179 was issued to 4
! drawing 2323-S1-0550 accepting the use of the comercial- non-shrink- i H
'
's . grout. However, the failure to. grout with Clas:, "E" concrete as
-. specified on the drawing at the time the wor,k was accomplished is an
apparent violation-(445/8507-92). .
c. dClosed) Unresolved Item _445/8416-04;. Hydrogen Recombiners -
Out-of-Specification Voltage Recorded on Westinghouse Quality l
Release Document
Quality Release N-41424 was revised by Westinghouse changing the-
specified voltage from 10+-2V to 12+-2V which put the questionable
voltage within specification limits. However, the failure of receipt
inspection.to verify that the QRN-41424 was filled out accurately as
required by Procedure QI-QAP7.2-8 is an apparent violation
,_ .._ (445/8507-03). -
.,, d. .{Dpen) Unresolved Item _445/8432-06; .446/841106; Lobbin Report'
Described Site Surveillance Program Weaknesses
During this reporting period the NRC inspector reviewed the status of
this open item several times and interviewed TUEC management and site
surveillance personnel. The Lobbin report stated that the scope and-
. objectives of the site surveillance program were unclear, lacking
both purpose and direction.
'
i
There is no specific regulatory requirement to have a surveillance l
program;.however, TUEC committed to have a surveillance program and j
has established procedures to implement such a program as a part of i
the 10 CFR Part 50, Appendix B, QA program. This extra effort is a :
strength; however, the NRC inspector also observed, as did the Lobbin
Report, that the surveillance program lacks both purpose and
direction to be effective and complimentary to the audit and ;
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inspection programs. Since. the TUEC audit group is not-1kcated on
site, the TUEC surveillance program on site takes on added
significance.
This ited was discussed with the TUEC site QC manager who described a
reorganized site surveillance function and changes that have
occurred. New procedures which describe this organization's duties
and responsibilities are forthcoming.
TUEC has elected to defer responding to the violations pertaining to
the audit function in NRC Inspection Report 445/84-32; 446/84-11, but
rather to have the Comanche Peak Response Team (I,PRT) respond tc this
report and other QA matters. The surveillance issue is closely tied
to.the audit deficiencies in NRC Inspection Report Nom 445/84-32:
446/84-11. _This item will remain open oendino the review and imple-
. -mentation of the CPRT action plan. A special point of interest will
.. be how audits and surveillance work together to evaluate the control _
V of all safety-related activities on site to assure quality,
-
especially the overview of quality control effectiveness.
/ 4. Document Inspection of Site Dams
& The NRC inspector reviewed documents describing the inspection activities
perfonned on the Squaw Creek Dam (SCD) and the safe shutdown impoundment
(SSI) for impounding cooling water for the two units at CPSES. The
purpose of the SCD is to impound a cooling lake for CPSES. A secondary
reservoir (SSI) is formed by a channel connecting the 500 impoundment to
the SSI.
Three documented inspections have been perfonned since 1980. The {
_ , , .
inspections were:
.
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a. Relevant data for SCD is contained in Phase I Inspection National s
Dam Safety Program, Squaw Creek Dam, Somervell County, Texas, Brazos l
River Basin, inspection by Texas Department of Water Resources. Date !
of Inspection: June 10, 1980. I
b. Inspection on August 25, 1982, by registered professional engineers
from Hason-Johnston & Associates, Inc., and Freese & Nichols, Inc.
c. Inspection on September 19, 1984, by a registered professional
engineer from Mason-Johnston & Associates, Inc.
The inspection activities consisted of visual inspections by inspection
teams that included accompanying Texas Utilities Service Inc. (TUSI),
and Texas Utilities Generating Company (TUGCO) representatives.
Photographs were taken as a part of the documentation. The data for the
.
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piezometer observations and the data for the surface reference monuments
were reviewed by applicant personnel and Mason-Johnston engin8ers.
No items of significance were observed or reported by these inspection
teams. . Slight erosion areas were observed and reported. A cracked area
on the service spillway upstream right bridge seat was observed by the
inspection teams and continued monitoring of this area was recommended by
Mason-Johnston and Associates. No signs of cracks, settlements, or
horizontal movement at any location within the SCD or the SSI were
reported.
The WRC inspector reviewed the applicant's records and the Mason-,1ohnston
inspection reports. These documents indicated that the SCD and SSI were
structurally stable and that the applicant was performing inspection
activities to maintain the structural integrity of these dams.
The state of Texas requires periodic inspections of these dams
, , (principally the SCD) due to inhabited dwellings downstream. The
,
applicant has met these inspection requirements. -
>
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v No violations or deviations were identified.
p p AttM
p #,1, 5. Voids Behind the Stainless Steel Cavity Liner in Unit 2 Reactor Buildig
9 9.7 /,:'.
ce 1 In review of previous related TRT concerns, the NRC inspector reviewed
/2 #c[M ' applicant records, including NCR C-82-01202; NCR C-1784, Rev.1; NCR
,n. , ,, .s F ' C-1784, Rev. 2; NCR C-1766, Rev. 1; NCR C 1791, Rev. 1; NCR C-1824,
eg/ a de'J Rev.1; NCR C-1824 Rev. 2; Significant Deficiency Analysis Report (SDAR)
- 26, dated December 12,1979; DCA-20856; and Gibbs and Hill Specification
2323-55-18. The review of records and documentation and discussions with
'
various applicant personnel indicated the following:
-' ~
Structural concrete was placed in Unit 2 reactor building at
elevation 819 feet 6-3/4 inches to 84C feet 6 inches on June 21,
_- 1979. This concrete was placed adjacent to the stainless steel liner 1
wall s. The concrete forms for this pour were not removed until
i
October 1979 due to subsequent concrete placements for the walls to j
elevation 860 feet 0 inches. When the forms were removed, honeycombs '
and voids were, observed by applicant personnel. The applicant's
review of the extent of unconsolidated concrete resulted in the
issuance of SDAR-26 on December 12, 1979. Investigations were begun 1
and Meunow and Associates (M&A) of Charlotte, North Carolina, were
contracted to perform nondestructive testing on in-place concrete.
M&A performed these tests on a two foot grid pattern on the
compartment and liner sides of all four steam generator (SG)
compartment walls. The selected test locations did not include the
locations where the voids were later found to be located.
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- In August 1982, preparations were made to pour the concrete annulus
around the reactor vessel. When the expanded metal fornkork was
removed from th.e reactor side of the compartment walls", voids were
, observed and NCR_C-82-01202 was prepared. DCA 20856 was prepared as L
a prxedure to repair the void area. DCA 20856 indicated-that the
'- voids were not extensive (a surface area of about 28 square feet by 8
inches maximum depth) and that the repair procedure assured that the
l total extent of voids ~had been identified. Onehalf-(0.5)ofacubic
yard of concrete was used to complete the . repairs as indicated on
i
grout pour card 261.
The applicant's review and evaluation of the gird pattern and a
comparison of SG compartments 2 and 3 to 1 and 4 indicated that voids
did not exist in SG compartments 2_and 3. The review of. test girds
extended down to elevation 834 feet, which is the floor elevation of
the liner.. The liner walls of SG compartments 1 and 4 were not
' tested at elevation 834 feet..but at elevation 836 feet which is
. above the area of theLidentified voids. No testing was done on the
~ liner side of the area of the voids below elevation 836 feet. The --
,
program also included removal of 2 inch x 2 inch plugs from the
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__
stainless steel liner at locations where test indications raised
questions concerning the concrete. The inspections of the concrete
by applicant personnel after the plugs were removed confirmed that
there were no additional unconsolidated concrete areas (voids). ,
In accordance with OCA 20856, the applicant removed stainless steel
liner plates from three areas (one area about I foot by 1 1/2 feet
and two areas about 3 feet by 1 foot, excavated or chipped to sound
concrete, and cleaned the concrete surface area. One and one-quarter :
inch (1 1/4) diameter probe holes and grout access holes were drilled
in the liner plates to determine the extent of and to assure full
definition of the void area. Air access holes were drilled in the
~~ '~ stainless steel liner plates to assure that grouting would be
accomplished in accordance with the procedure.
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The procedure (DCA-20856) specifed that the grout was to be cured for
28 days or until the grout reached a compressive strength of 4000
psi. Repairs to the liner plates were specified in DCA-20856 and G&H
Procedure 2323-55-18. '
DCA-20856 required that under no circumstances was cutting of the
liner across weld seams, across embedded weld plates, or into leak
chase seal welds or drilling through the liner at leak chase
channels, embeds, or weld seams permitted. Documentation review
indicated that DCA-20856 was adhered to,and that no cutting or
drilling occurred in prohibited locati.ons.
No violations or deviations were identified.
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6. Nondestructive Testing Observations of Liner Plates in Fuel Transfer Canal
I '
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The NRC inspector observed portions of non-Q liquid penetrant examinations
(PT) being performed on liner plate welds following re-installation of the
p liner plates in the areas of the fuel transfer canal remuved for
inspection and repair of the concrete. The inspector performed the PT on
l
the welds as required by the repair package and the procedure ;
,
(QI-QP-11.18-1,"LiquidPenetrantExamination"). Scattered weld porosity j
l was identified by the inspection. The porosity was ground out and a -
i
repeat PT was performed. The final inspection is scheduled to be i
perfonned by QC inspection personnel. The liner plate areas to be 4
inspected by PT were identified in DCA 20856. I
No violations or ' deviations were identified.
pv5 4- 7. Cadweld Splice Observations and Records
!
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60
1
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a. Calibration of Tensile Tester -
The NRC inspector observed the calibration of the Tinus-Olson
l Universal Testing Machine (Model Number 6,00-12 Identification Number
M&TE-784) on April 2 and May 7, 1985. The machine was calibrated
just prior to performing tensile testing of cadweld splices and
subsequent to completion of tensile testing each day that tensile
testing was performed. The machine calibration date for April 2,
1985, prior to start of tensile testing was observed by the NRC
inspector and recorded as follows:
!
Nominal load Calibration Reading Error Error Remarks
(1bs) (1bs) (1bs) %
0 0 0 ~
- ~ 0 0 machine on
4/2/85 !
_~
100,000 99,750 +250 +0.25
200,000 199,600' +400 +0.2
300,00 299,450 +550 +0.18
,
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350,000 350,300 -300 -0.08
400,000 401,200 -1200 -0.03 j
500,000 501,350 -1350 -0.27
600,000 602,450 )
-2450 -0.40 j
i
The NRC inspector reviewed calibration data for March 4, March 8 {
April 2. April 3, April 30, and May 7,1985. All calibration data
met within the +/- 1% accuracy requirement specified by Calibration
Procedure 35-1195-IEl-37 Revision 3, dated March 11, 1982. The
reference standards were identified as follows:
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ID No. Manufacturer , Calibration Due Date -
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RS-75 BLH Electronics January 27, 1987
RS-75.3 BLH Electronics January 27. 1987
b. Observation oi waaweld Splice Tensile Testing
(1) Qualification Tensile Testing
On April 2, 1985, the NRC inspector observed the following
tensile testing of cadweld splices for cadwelder qualification: l
EBD Q8, GBH Q1, GBH Q2, GBV Q1, BFD Q4, BFD Q3, BFH Q4, GAH Q1, !
l
GAV Q1, and GBV Q2.
l
Each of the above qualification cadweld splices was tensile
'
tested to 400,000 pounds (100,000 psi) and met the requirements
'
stated in the procedure. -
.
i (2) Production Tensile Testing ,
The NRC inspector observed the tensile tester calibrations and
the following production cadweld splices tensile testing on
May 7, 1985: FXD 3P, FYD 4P, FYD 8P, FRD 87P, and FUD 6P.
Each of the above production cadwe16 splices was tested to
400,000 pound!,(100,000 psi)and met the requirements stated in
the procedure.
(3) Installation of Production Cadweld Splices
The NRC inspector observed installation of rebar and cadweld
-
splices at frequent intervals (five or more observations per l
week during the weeks of April 8 and 15; May 6,13, 20, and 27; !
-- andJune3,1985). The rebar installation for the Unit 2
closure was perfonned in the area identified as elevation 805
feet to elevation 875 feet and azimuth 300 degrees to 335
degrees. The installation activities observed included rebar j
spacing, location of cadwelds, observation of selection and !
removal for testing of cadweld splices for testing, and 1
determination of location of rebars and cadwelds for the
'
as-built drawings.
(4) Documentation Reviewed
The NRC inspector reviewed the following documentation for the
rebar placement and cadwelding for the Unit 2 containment
(reactor building) closure area:
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Drawings DCAs
NCRs {
2323-5-0785, Rev.7 22616, Rev. 1 C85-200294 !
.2323-S-0786, Rev.9 22726 C85-200339, Rev.1 !
2323-51-500, Rev.5 22737' C85-200355, Rev.1 '
2323-S1-506, Rev.5 22836
2323-52-505, Rev.5 22878 (Sheets 1-7)
2323-52-508, Rev.2- 22772
2323-52-506, Rev.3
No violations or deviations were identified. !
A 7cg4 - 8. Concrete Batch Plan,t Inspection, Unit I and 2
The NRC inspector inspected the concrete production facilities for the
following. specific characteristics for the following breas: (1) material
,
storage and handling 'of cement, aggregate,' water and admixture. (2) batching-
~
;.
. equipment scales, weighing systems, admixture dispenser, and recorders, ~ -
(3) central mixer (not applicable because it had been dismantled),
.
1
.-- (4) ticketing system, and (5) delivery system. I
The current. batching is a manual operation since almost all concrete has
been placed. The central mixer was dismantled and removed from site two
or. three years ago when concrete placement was virtually completed.
Presently, the backup batch plant (which was a backup system for the
central ~ mixer) is in operation to complete.the remaining concrete
placements. This batch plant is in good condition and complied with the
subject checklist except for one area.
The NRC inspector inspected the inside of one of three trucks used for
mixing concrete'(that is, the batch plant dispenses the correct weight of
~~ ~ materials as required by the specific design mix numbers and the truck
then mixes the batch to be placed.) The blades inside the truck are
~
.
subject to wear and should be checked at a reasonable frequency. The i
Brown & Root (B&R) representative responsible for checking the blades in
.accordance with B&R Procedure 35-1195-CCP-10, Revision 5, dated
December 4,1978, was asked for evidence that the blades had been checked
- for wear on a quarterly basis as required by procedures and it was found
that there was no record of such checks dating back to 1977 when they were
initially checked.
In the FSAR Volume V, Section 3.8.1.2.3, the applicant commits to
ACI 304-73. In ACI 304, the maintenance of mixer blades is required.
'
Procedure CCP-10, paragraph 3.10 " Truck Mixing," is silent on blade wear
but Section 3.11 infers that the blades should be checked for both central
and truck mixing. The inspection of both central and truck mixing blades
,
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was not documented, although the B&R representative stated that the mixing
blades wcre periodic 611y inspected and laboratory testing would have
probably indicated if there was s problem with the mixing blades, j
Strength and uniformity tests have consistently been within the acceptable '
range indicating that concrete production was acceptable even though
mixing blade inspection was not documented.
I
Otherwise, the condition of the inside of the truck was satisfactory as !
the drum and charging /discht.rging were clean. The water gage and drum
j. . counter were in good condition. ,
This failure to follow procedures is a violation of 10 CFR 50, Appendix B,
Criterion V. Subsequent to the identification of this violation, the
blades were checked for wear and blade wear was presently within allowable
limits (445/85_07-04; 446/8505-02).
. No other~ violations or deviations we're identified.
'g%v. 9.
_
Calibration Laboratory for Batch Plant Unit 1 and 2
'
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The NRC inspector obtcined batch plant scale numbers from tags which
indicated that the scales had been calibrated and were within the
calibration frequency. Cement (MTE 779), Water (MTE 7661, admixture scale
(MTE 764), and aggregate (MTE 780) were reviewed. The scales had been
periodically calibrated since the batch plant was activated. The records
were adequate except as follows:
a. Scales MTE 766 records do not differentiate between the
required accuracy of the scale and the digital readout.
b. Scales MTZ 779 and 780 records show various accuracy ranges for the
-- same scale; 1.e., MTE 779 (SN749687) records the following: report
dated January 1976 gives 1%; report dated July 1976 gives 1% while
the report dated October 1976 gives +/- 0.25.
The calibration appeared to be proper, howeverg the above items are unre-
solved pending further review of the applicant s actions regarding the
correction of these records (445/8507-05; 446/8505-03).
I
c.
Records for scales MTE 779 records contained BAR memo IM-1108 dated
July 16,1975, which described a nonconforming condition. This condi-
tion affected the water and cement scales causi'q a 24-48 pound deviation
(7,000 pound scale) during the calibration test. The memo stated that
the condition was corrected and the scales wore then calibrated; however, I
no deficiency report was written as required by B&R Procedure '
CP-QCP-1.3, " Tool and Equipment Calibration and Tool Control" dated
July 14,1975, and CP-QAP-15.1, " Field Control of Nonconforming
items," dated July 14, 1975. As a result there is no evidence that
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corrective action included an evaluation to determine if? concrete -
production. was adversely affected. -*
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This failure to assure that a nonconforming condition was evaluated
-is a violation of Criterion XV of 10 CFR Part 50, Appendix B,
(445/8507-06; 446/8505-04).
4 706[ 10. Concrete Laboratory Testing Units 1, and 2
- 4
.
TUGC0 Procedure QI-QP-11.1-1, Revis'un 6, was compared with ASME -
Section III, Division 2, Subsections 5222, 5223 and 5224 to assure that
each ASTM testing requirement was incorporated into the procedure. <
The NRC inspector inspected the testing laboratory equipment and found the
' test area and equipment were in good condition and each piece of equipment
was tagged with a calibration sticker which showed it to be within the
,' required calibration frequency. Test personnel were knowledgeable of test
*
requirements and equipment. -
,-
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__ The NRC inspector witnessed field tests performed by laboratory personnel
as follows:
, ,
Date Truck No. Mix No. Ticket No. Air Content (%) Slump (in.)
Temp ('F)
6/3/85'RT-41 925 64013 Req 8.2-10.3 NA- 70 max
Mea 8.7-9.1 NA 57
6/3/85 RT-35 128 64014 Req 5.0-7.0 5 max */0 max
Mea 6.6 6.25* 57
-
* Initial slump was high; however, after additional truck rotations the
slump was found acceptable.
~-
The following laboratory equipment was checked and found to be within
calibration: Forney Compression Tester, MTE 3031; Temperature Recorder
MTE 3013 and 3014; Unit Volume Scale, MTE 1053; Pressuro Meters MTE 30008,
3002 and 3004; Steves MTE 1285, 1239, 1272, 1274, 1136A, 1156, 1094, 1093,
1095,1178,1179,1300 and 11B0; Aggregate scales, MET 1058 and 1067; and
2" grout mold MTE 1111.
The following test records for placement number 201-5805-034 were
reviewed: (1) concrete placement inspection, (2) concrete placement
sumary and, (3) unit weight of fresh concrete.
No violations or deviations were . identified.
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Q ill. Inspection of Level C and D Storage Unit 1 and 2 ,, [
4 ,,.( O etI
p o # {
F ffp35 #pl"// , 7 conduit,
The cable,
NRC and structural reinforcing
inspector. steel were stcred.
inspected These areas where
on. cribbing inall
welllaydowr
!
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* materials were neatly stored outside drained ereas.
. ._ 3which allowed air circulation and avoided trapping. water. This met the
"D" storage requirements of ANSI N45,2.2.
W100hy.m ,6M ; Level
jp o 'b 'q. -The electrical warehouse. contained miscellaneous electrical hardware.
.
This building was required to be fire resistant, weathertight, and well
-
. ventilated in order to meet Level "C"' storage requirements. This
warehouse was well kept and met all requirements except for a lock storage
area located upstairs at the rear of this building (electrical termination
tool' room). 'Two minor problems were identified and the warehouse
personnel initiated action.to correct them.
.. The first problem noted.was' that a box of nuclear grade cement was marked
" shelf life out of.date" but it had no hold tag. The box was subsequently
1 -
tagged inaccordance with TUGCo nonconformance Procedure.CP-QAP-16.1,
-
Revision 24 (Nonconfomance Report (NCR) E85-200453) after being identified
by the NRC. During discussions with the warehouseman, the NRC determined
that engineering told the warehouseman to mark the material and lock it up,
but did P.ot tell him to apply an NCR or hold tag. Also, the NRC inspector '
noted a'very small leak in the. roof above the electrical temination tool
room. - This leak was .in an area that did not expose. hardware .to moisture.
The roof is currently being repaired.
The mi11 wright warehouse storage area was inspected; however, only a small
number of items or materials were stored in this area. The overall
storage conditions in this area met or exceeded Level "C" storage
requirements,
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No violations or deviations were identified. ;
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.gve6 12. Reactor Pressure Vessel and Internals Installation - Unit 2
f<. * This inspection was performed by an NRC inspector to verify final
.
placement of the reactor pressure vessel (RPV) atd internals by examining q
p ect the completed installation and inspection records,
CM a.- Requirements for Placement of RPV
/
Requirements for placement of the RPV to ensure proper fit'-up of all
other major NSSS equipment are in Westinghouse Nuclear Services
i
Division (WNSD) " Procedure for Setting of Major NSSS Components",
Revision 2, dated February 13, 1979, and " General Reactor Vessel
Setting Procedure" Revision 2. dated August 30, 1974. The NRC
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inspector reviewed the following drawings, which were ref;erenced in
the RPV. operation traveler, to verify implementation of WNSD
recommendations:
o WNSD drawing 1210E59 " Standard - Loop Plant RV Support Hardware q
Details and Assembly" i
o WNSD drawing 1457F27 " Comanche Peak SES RCS Equipment Supports -
Reactor Vessel Supports"
1
o CE drawing 10773-171-004 " General Arrangement Elevation"
o CE drawing 10773-171-005 " General Arrangement Plan" -
1
Neither site prepared installation drawings nor specifications (which i
implemented the WNSD recommended procedures) were available and the
.,
drawings examined did not show certain specific Installation
-
criterion such as centering tolerances, levelness tolerances and - i
;. clearange between support brackets and : support shoes. j
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The inspector considers this matter unruolved. (446/8505-05)
b. Document Review
The NRC inspector reviewed B&R Construction and Operation Traveler
No. HE79-248-5500 which described the field instructions for
installation of the Unit 2 RPV. Requirements recommended by WNSD
procedures were implemented in the traveler. Worksheets attached to
the traveler showed the RPV to be centered and leveled within the
established tolerances. Traveler operation 19 required verification
of a 0.020 to 0.005 inch clearance between the support bracket and
-- ~ support shoe, after applying the shin plates. Change 5 subsequently i
changed the clearance to a 0.015 to .025 inch clearance. The
.
- installation data reflected in attachment 3B of the traveler
indicated an as-built clearance of 0.012 to 0.026 inch which exceeds
both the original and revised tolerances. This condition was
accepted on the traveler based on Westinghouse concurrence, and there
was no documented engineering evaluation ensite justifying the final
tolerances. This matter is considered unresolved pending documentation
validating the final installation 'olerances. (446/8505-06]
The NRC inspector reviewed the following receiving records for the
RPV hardware and found them to be in order: i
o Report No.14322 for 54 each riosure studs, closure nuts, and
closure washers
o Report No. 09507 for vessel S/N 11713, Closure Head 11713 and 26
0-Rings 1
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Deviationsticesand'correctiveactionstatementsj
'The DC in'spector reviewed thel following completed travelers for
internals installation and found them to be satisfactory:
o ME-84-4641-5500, " Assemble Upper Internals"
o' 'ME-84-4503-4000. " Install and Adjust Roto Locks"
o ME-81-2145-5500. "Retorque VI Column Extension"
o RI-80-385-5500, " Transport and Install Lower Internals"
o ME-84-4617-5500, " Repair Lower Internals"
o ME-84-4640-5500. " Assemble Lower Internals"
'[~ c. Visual Inspection- -
_ At this time, visual i_nspection of
was not possible, and inspection wa,the internals
s limited by' theplacement
on the vessel NRC inspector
to a walk-around beneath the vessel to inspect the azimuth markings
and for construction debris between the vessel and cavity. No
b- problems were identified in this' area..
d. Records of OA Audits or Surveillance
The NRC inspector requested TUGC0 QA audits or surveillance
performed by TUGC0 of the Unit 2 RPV installation. TUGC0 did not
make available any documentation of an audit or surveillance which
evaluated specified placement criteria, placement procedures,
--
hardware placement, or as-built records. This item is unresolved
,
'pending a more comprehensive review of these activities
- ._
.
(446/8505-07)..
No deviations were identified; however, two unresolved items were
identified and are described in the above paragraphs. (11.aandd) ..
13. Reactor Vessel Misorientatien,.
M On February 20, 1979, the applicant reported to the NRC Resident Inspector
- 42'101 that a design error had resulted in the reactor support structures being
placed in the wrong position on the reactor support pedestal such that the
reactor.would be out of position by 45 degrees. Initially. Unit 2 was to
be a mirror image of Unit 1, however, a design change was initiated to
permit identical components for both units. The design change was
implemented for'the reactor vessel, but not for the pedestal support
-locations. The problem was not considered by the applicant to be
,
w - - - . - . - - - . - . - . - - . ~ - . - - - . ~
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reportable under provisions of,10 CFR Part 50.55(e) since the irror could 1
not have gone undetected. ,,
! The deficiency was reported to the NRC Office of inspection and Enforce- ,
ment on February 22, 1979 and durin; a March 27, 1979 meeting in Betherda,
.
Maryland, the applicant presented the proposed redesign and. rework proce-
dures for relocating the pedestal supports. .No unresolved safety concerns
'
. with the repair were identified at the meeting. .
t During.this inspection the NRC inspector reviewed various documentation
relative to the disorientation problem, including design changes and the j
l; construction traveler which implemented the repair. 1
The'following documents were reviewed:
L o NRC Inspectio'n Reports ~ 50-446/79-03; 50-446/79-07; 50-446/79-13
-
.:.
c' TUSI Conference Memo, dated March 1, 1979, H. C. Schmidt to S.
~
..
{ Burwell (NRC Licensing PM)
o TUGC0 letter TXX-2980, dated April 30, 1979, to W. C. Seidle
o NRC letter to TUGC0 dated May 29, 1979
~
o DCA.3872. Revision 1, dated February 28, 1979, Subject: Rework of
Structure for Placement of the RPV Support Shoes
o DCA 4122, dated March 22, 1979, Subject: Replacement of Rebar for
RPV Supports
o Construction Traveler CE79-018-5505, dated March 14, 1979, Subject:
- -- Rework of Reactor No. 2 Cavity - New RPV Support 1.ocations
-
- o Grout Replacement Cards No. 007, 008, 009, 010, 014, and 015, various
'
dates Subject: Replacement of Grout around Rebar for Repa',r of RPV-
Support Shoes
o _ Various Inspection Reports for Grout Properties and Application for
RPV Support Shoes
No violations or deviations were identified.
j uf3 14. . Reactor Coolant Pressure Boundary (RCPB) Systems
' Tff' 1
- The inspection was performed to verify: the applicants system for
preparing, reviewin9, and maintaining records-for the RCPB piping and ,
components; that selected records reflected compliance with NRC '
requirements and SAR connitments for manufacture, test and installation of
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items; and as-built hardh re was adequately marked and tracea@ e te
'
records. The'following items were randomly selected and inspe.cted:
L a. Pressurizer Safety Valve - This item was inspected to the comitment
stated in F5AR, Table 5.2-1 which includes ASME Section III, 1971
Edition through. Winter 1972 Addenda. Valve S/N N56964-00-007, which
is installed.in the B position, was inspected. The following' records
were reviewed: ,
!
'
o_ QA Receiving Inspection ' Report No. 21211
{
.
o Code Data Report Form NV-1-
o Valve Body Certified Material Test Reports (CMTRs)
'
The valve was in place, however, installation had not been completed;
*
therefore, the hardware installation inspection consisted of _ ,
-
,,
verifying that the item was traceable to the records. j
~~
r b. CVCS Spool Piece 301 - Requirements for this item are stated in ASME,-
Section III,1974 Edition through Sumer 1974 Addenda, which is the
comitment from the FSAR, Table 5.2-1. The item was field fabricated
from bulk piping and purchased elbows.and installed in the CVCS with -
field welds number 1 and 6 (ref. BRP-CS-2-RB-076). -The following
. records were reviewed:
o B&R Code Data Report
o Field Weld Data Card
'
o NDE Reports
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,
'
o QA Receiving Reports for piping and elbows
__
o CMTRs
The installed spool piece was inspected for weld quality and to
verify that marking and traceability requirements had been met. The
item had been marked with the spool piece number (3Q1) and the B&R 1
drawing number which provided traceability to the material l
certifications. ]
;
c. L6cp 3 RC Cold leg - Requirements for this item are stated in ASME, q
Section III,1974 Edition through Sumer 1974 Addenda, which is the ;
comitment from the FSAR, Table 5.2-1. This piping subassembly '
consists of a 27.5 inch cast pipe with a 22 degree elbow on the
reactor end, a 10 inch 45 degree nozzle, a 3 inch nozzle, and three 2
1
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1/2 irch thermowell installation bosses. Thefollowingbecordswert l
reviewee fer the subassembly: j
o QA Receiving Inspection Report No. 12389
o Westinghouse Quality Releas,e (QRN 47523)
o Code Data Report Form NPP-!
o 27 1/2 inch line CMTR !
o
o 3 inch nozzle CMTR
o Field Weld Data Cards
o NDE Reports
- .
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'"
(1) Sandusky Foundry and Machine Company test report for the cold
leg pipe certifies thit material meets requirements of ASME
-
Section II, 1974 editions through winter 1975. Southwest
Fabrication and Welding Company code data report NPP-1 Form !
l certified that the cold leg subassembly met requirements of ASME ; j Section III '1974 edition through winter 1975. '
(2) The NRC inspector reviewed the procedures and hydro test data i
applicable to Unit 1, since Unit 2 hydro had not been completed. !
Requirements for the tests were presented in Procedures
CP-QAP-12.2, " Inspection Procedure and Acceptance Criteria for
ASME Pressure Testing" and CP-QAP-12.1, "ASME Section III
installation, Verification, and N-5 Certification." Procedure 4
CP-QAP-12.1 requires that a data package to be used in the test,
_ _ . _ be prepared with the test bounoary and the additional following
data shown: '
o Base metal defects in which filler material has been added, ,
and the depth of the base metal defect exceeds 3/8 inch or
10% of the actual thickness, whichever is less,
o Untested vendor performed piping circumferential welds. !
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o Approximate location and inaterial identification and <
description for permanent pressure boundary attachment with I
applicable support number referenced,
o Weld history, which shall reflect weld renoval and/or weld '
repair. j
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The completed hydro data package (PT-5501) for Uqit[1, loop 3
co.1d leg was reviewed for compliance with the above
requirements. Drawing No. BRP-RC-1-520-001 had beeh'used to
annotate the test boundary. A handwritten statement on the 1
drawing indicated: "No major base metal repairs could be !
located" and "No hangers with weld attachments could be .
located." Welds performed by the pipe subassembly vendor, '
including the 22 degree circumferential weld and the penetration
fittings had not been identified. The following items are !
unresolved pending further review to determine.
l
o If the statement "no majer base metal repairs" was based on
a visual inspection or on a review of vendor and site !
inspection and repaiir records,
o If the shop circumferential weld attaching the 22. degree !
.
elbow to the pipe assembly was inspected during the test. ,
o If welds for penetrations into pipe assembly were inspected
-
since Procedure CP-QAP-12.1 does not require identification of
,
l
such welds and they were not identified on the drawing. ;
The above issues will remain unresolved pending further
evaluation by the applicant (445/,8507-07; 446/8505-09),
d. personnel Qualifications - Personnel who had performed selected tasks
@g pc were identified during inspection of installation records. Training
<and experience records for the personnel were reviewed to verify that
fr/ 7p s employee qualifications and maintenance of records were current and
s#%pc met requirements. Names or codes for five welders and two NDE
a*'
s
examiners, who had performed tasks during installation of the items
_ . . _ being inspected, were identified and their qualification records .
reviewed. There were no questions in this area of the inspection.
:_
No violations or deviations were identified.
15. Special Plant Tours (Unit 1 and Unit 2) *
On May 23, 1985, the NRC inspector conducted a tour of selected areas of
M' . 74 g Unit I and Unit 2. The group consisted of one NRC inspector, two NRC
Np Technical Review Team (TRT) representatives, two allegers, and several
TUEC representatives. The TUEC representatives tagged each area where a
deficiency was alleged. With the alleger's consent, a tape recorder was
also used to note locations end describe any alleged deficiencies. The ;
'
allegers indicated that they had identified all deficiencies during the
l
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_____..____________.-____m___________a
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tour and all other deficiencies that they had know' ledge. Tl e
l if any$RC TRT is
analyzing this information and will decide what action, , should be 4
taken. ~~
i
During this tour the NRC inspector independently identified a questionable l
practice in that the top of the the pipe chase at the north end of room 88 '
in Unit 1, safeguards building had two large stickers which stated that
areas on the wall were reserved for pipe hangers GilH-51-1-SB-038-006 and ,
R1(?)1-087-X11. These stickers were dated 1980. It was not evident i
whether hangers were missing or none were needed in these locations and I
the reserve tag 3 were not removed. TUEC representatives were unable to
answer the question imediately. This item is unresolved pending further i
review during a subsequent inspection. (445/8507-08). a
-
.
No violations or deviations were identified. (
i
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16. Routine Plant Tours (Units 1 and 2) _ ,
,
-
At various times during the inspection.. period NRC inspectors conducted
-
general tours of the reactor building, fuel building, safeguards building,
g ar$OV electrical-and control building, and the turbine building. During the
tours, the NRC inspector observed housekeeping practices, preventive
maintenance on installed equipment, nngoing construction work, and
discussed various subjects with personnel engaged in work activities.
No violations or deviations were identified.
17. Review of Part 21 and 10 CFR 50.55(e) Construction Reports Status
The NRC inspector reviewed all reports issued to date to assure that NRC
L and TUEC status logs were complete and up to date. A total of 183 reports
have been submitted to date. This inspection period one Part 21 report on
. _ . _ Diesel Generator Oil Plugs and two 10 CFR 50.55(e) reports on the
Equipment Hatch Cover and SA106 Piping (light wall) were submitted.
--
No violations or deviations were identified.
i
18. Exit Interviews
9 1A TheNRCinspectorsmetwithmembersoftheTUECstaff(denotedin
paragraph 1) on May 10 and June 10, 1985. The scope and findings of the
inspection were discussed. The applicant acknowledged the findings.
l.
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j 13
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Contrary to ?" =""^ , (a) Unit 2 reactor pressure vessel installation
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design criteria recommended by the NSSS vendor, such as centering
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tolerances, levelness tolerances, and shoe to bracket clearances, were '
,
.,
not included in installation specification, procedures and drawings; and
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(b)the criteria were specified in Construction Operation Traveler
HE-79-248-5500 but were not treated as design engineering' criteria as
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, evidenced by an undocumented change of shoe to bracket clearances.
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Contrary to t - ^^"^ Certified material Test Reports were not available '
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bosses, which were a part of the loop 3 cold leg piping subassembly. 4
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10 CFR 50, Appendix B, Criterion VIII and TUGC0 QA Plan, Section 8.0,
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Revision 0, dated sluly 1, 1978, --."4-- + hat manenroc h. .e+=k14-' > e-
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rticle NA3766.6 of ASME, Section III,1974 edition. -eg?-x t"+
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10 CFR 50, Appendix B, Criterion XVIII and TUGC0 QA Plan Section 18.0,
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Revision 2, dated July 31, 1984,acqJ., L , . ;;;; :h;r...'. .7.,.m J-
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Contrar.y to th; dat, there was no evidence that TUGCC had audited _
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either Unit 2 reactor vessel installation specifications, placement .
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procedures, actual hardware placement, or as-built records. I
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10 CFR 50, Appendix 8, Criterion XV and TUGC0 QA 'lan * eti: '/ , L.i:f--
5
-3 dated May 21, 1981 caa/+e +"+ -a""ra e ehall ha a'+:ili;h;d t;
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] Brown and Root Quality Assurance Manual, Section 16. dated March 2Q
?> .',_ 1985yhn th:t ==ti;fecter., ;sdit'^ : 4dantified on procau - _
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Contrary to : it;x , clearances between the reactor vessel support
99
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brackets and support shoes were not within the tolerance stated in
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I' Construction Operation Traveler ME-79-248-55 and the condition was not I
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- reported on a Nonconformance Report,
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10 CFR Part 50, Appendix B, Criterion Vj] requires that activities
'
affecting quality shall be prescribed by documented instructions,
,
procedures, or drawings, of a type appropriate to the circumstances and-
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shall be accomplished in accordance with these instructions, procedures,
,
or drawings.
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Contrary to & d commercial non-shrink grout was used to grout the
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"E" concrete as specified in section 6-6 of drawing 2323-51-0550,
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Revision 4. The NRC initially reported this item as unresolved in IR
,, 445/8416-03.
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Th4e 4 ! 3 $gverity t_gygl V.-ViCTlation. _,.
(Suppiement. ii;Et-(445t3307:U2I'
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8dflC 80A88 N A DOCxt? NO 4.fl.'ts:OA UCthtt #8MA 440W NWtt A
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votaf CN Om og viat cw isneer we so s400 snareceers for esca nom. # ine soar esseeds sa.e aumeer. N wWs se necessary as permentmas. uma anos e 80 ansrurvoro esen.)
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(OCFRPart50,AppendixB,CriterionVre;'~: th:t .;;i.i;k, -
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si
checklist, attachment 1, step 4.1 was outside the specified tolerance,
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inspection. The NRC initially reported this item as unresolved in IR
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10 CFR Part 50, Appendix B, Criterion V and Texas Utilities Generating _
a
_ _ _ _
Company (TUGCO) Quality Assurance Plan, Section 5.0, Revision 2, dated ~~'
- - - -
May 21, 1981, require that activities affecting quality shall be
.
prescribed by documented instructions, procedures, or drawings, of a type -
Z~ ,
appropriate to the circumstances and shall be accomplished in accordance ~
- - -
'
__.-with these instructions, procedures, or drawings.
_
..
_
11
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F. Brown & Root Procedure ~
,, 35-1195-CCP-10, Revision 5, dated December 4,
.-~- ,
_
..,
1978, requires that central and truck mixer blades be checked quarterly -
-
fl_ . to assure that mixer blade wear does not exceed a loss of 10% of original -
blade height. -
l_' _
-,
Contrary to the above, on May 31, 1985, the NRC inspector determined that
"
-
si there was no objective evidence (records) that the blades had been
= inspected , quarterly since the trucks were placed in service in 1977.
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2, dated
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, ~ May 21,1981, and Section 15 0
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* 31, 1984 j n"4" that 0 ti s t.ca o ficu.ing poi a
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Contrary to thTweve.,, on May 31, 1985, the NRC ewed the
inspector revi ~~'
_n_~
calibration file for scale (MTE 779) used for weighing cement and l
'd~
- that difficulty was encountered with the water
and cement scales during a
3 1975 calibration of the backup plant scales, however
,,
, no DDR was issued
n
to identify this condition and require disposition a e and
of the sc l
concrete (if any) produced. !
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INSPECTOR'S REPORT CTooo44( F 5 017 a
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Contrary to .h: 9 0'
, a potential problem with RTE - Delta potential
..,,
*
,
transformer tiltout subassemblies, which are used in the emergency dies
a generator control panels, was identified to the appitcant via a letter,
i.
dated June 15, 1983, from Transamerica Delaval Inc. This letter also I
it
*
provided instructions for correcting the potential problem. However, the
i
'
w applicant did not perform the corrective action.
The NRC initially
m
reportedthisitemasunresolvedinInspectionReport(IR) 445/8440-02 .
ti. {
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" i$ u bi. ,~iy [C'JC} V ufat
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_
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'.%i35vo-01). i
. _
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3
3
3,
32
,
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U.S. NUCLEAR REQULATORY COMMIS81oN
- _ _ _ _.
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CPSES/FSAR
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'
implementation of the disposition. IR's, DR's, and NCR's remain open
until the deficiency is satisfactorily resolved and identified
.
(
j
corrective actien satisfactorily completed. Upon completion of the
action required for disposition, repaired or. reworked items are
reinspected to verify compliance with specified actions and
requirements. The status of these items is maintained in accordance
with Section'17.1.14, " Inspection and Test Status" and Section
_
17.1.13. " Handling, Storage and Shipping".
l
l
i
Procedures require trending of deficiencies reported on inspection
reports, deficiency reports, and nonconformance reports to identify
trends adverse to quality. Trend reports are reviewed quarterly by !
appropriate levels of management to address areas requiring corrective
action.
.
Nonconformance reports and trend reports are reviewed upon issuance by
TUGC0 QA for significant conditions adverse to quality or chronically
repetitive deficiencies. If such conditions exist, procedures require
' -
additional action, as appropriate. This may include issuance of
(
corrective action requests as discussed in Section 17.1.16,
" Corrective Action". or reports to the Nuclear Regulatory Commission. I
i
17.1.16 CORRECTIVE ACTION
50l
fra O *f ;
i
TUGC0 requires that measures be established to assure that conditions
j
adverse to quality are promptly identified, reported, and corrected,
Responsibility for performing corrective action is assigned to
f
j
contractors, applicable subcontractors, and vendors so that each is
alert to those conditions adverse to quality within his own area of
activity. In the case of significant conditions adverse to cualitv. I
which are reportable to NRC under the provisions of 10 CFR Part 50.55
(e), measures are taken to assure that the hause of the condition is
determined and corrective action is implemented to preclude s
_,rge_t i t i_o n . Corrective action procedures placed in effect require
_ ,
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C I
AMENDMENT 50 !
JULY 13, 1984 EXHIBIT 14
17,1 33
_ _ _ _ _ _ - _ - _ _
- _
. . . .
'
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CPSES/FSAR
, thorough investigation and documentation of significant conditions
.
adverse to quality. The cause and corrective action is reported in
writing to the appropr1 ate, levels of manag; ant and to the purchaser.
_ _ .
This corrective action applied is subject to review by TUGC0 and the
prime contractor responsible for the original purchase specification. g
0
For CPSES, the Quality Assurance Plan requires that procedures and
practices be established and documented which provide assurance that
conditions adverse to quality, such as failures, malfunctions,
deficiencies, deviation g , defective material and equipment, and
#y,
nonconformances, are promptly identified, documented, and corrected as
7 19
_
soon as practicable, and that appropriate action be taken to corr
the cause of the condition. Corrective action documentation. W
_ request forms or formal letters are,used to document the corrective
_
action-related requests, responses, and follow up. The plan requires
,
~
that measures be established by the prime contractors to assure that
the acceptability of rework or repairs is verified by reinspecting the
( item as' originally inspected and that the reinspection is documented.
These measures are verified by review and approval of the prime
contractors' QA Program and by the subsequent audit for conformance to
the approved program. Significant conditions adverse to quality are
identified (such as those which, if they had remained undetected, d'g
' would have adversely affected safety-related functions), the cause of
the condition is determined, and corrective action is taken to
preclude repetition. Such significant conditions, their causes, and d
p/
o d5
the corrective action taken are documented and reported to appropriate 9j0
levels of management through established communication systems.
p Vb l
Correctiveactionfollowupand(close-outprocedures)okovidethat Y
corrective action commitments are imp.lemented in a systematic and
timely manner and are effective. '
l
The occurrence and magnitude of deficiencies and nonconformances !
'
requiring corrective action are evaluated by the purchaser's
inspectors during surveillance and at hold point inspection and
k
_
17.1-39
JULY 13, 1984
.
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.
,
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COMANCHE PEAK STEAM ELECTRIC STATION i
QUALITY ASSURANCE PLAN
SECTION : 15.0
/psygg%
pg DATE : 10-18-85
%,e[l NONCONFORMING ITEMS REVISION : 5 i
PAGE 1 OF 2
l
s
15.0 Nonconforming items {
The identification, documentation, segregation, and disposition of
nonconforming materials, parts, or components is outlined in written
procedures. The measures utilized by contractors, subcontractors, and
vendors are subject to review by TUGCO. The procedures, as a minimum: I
o prevent inadvertent use or installation.
[
o require investigation of the nonconforming item, decisions on their '
disposition, and preparation of adequate reports.
o control further processing, fabrication, delivery, or installation I
of items for which disposition is pending.
l
o assure that departures from design specifications and drawing i
requirements that are dispositioned "use as is" and " repair" are j k
formally reported to affected organizations and TUGC0 management.
'
When required by specific procedures / instructions, items identified as
unsatisfactory or incomplete and which can be corrected within a
reasonable period of time may be identified on an inspection report
and/or deficiency report. A nonconformance report is used to document !
~ deficiencies unless another method is prescribed by a specific
. .p.r.oced ure/ i ns tr uct i on . '
Nonconformance reports, unsatisfactory inspection reports, and
deficiency reports are made available to TUGC0 for evaluation. In
addition, TUGC0 QA assures that periodic evaluations of these report
are forwarded to TUGC0 management identifying trends adverse to
quality.
TUGC0 audits prime contractors to assure compliance. ,
i
In addition to being documented on a nonconformance report, inspection]
Irport, or deficiency rep g items found during design anc
__
construction wnich are reportable under the orovisions of 10 CFR
i 50.55(e) are reported to the Executive Vice President, Nuclear
'
_
Diqineerina and Operations or his designee for reporting to the NRC.
1 A reportable significant deficiency is a deficiency which, were it !
to have remained uncorrected, could have affected adversely the safety j
of operation of CPSES and represents:
'
v * M M.-* / N 5c L Y O *+'
(1,4NGoC5-1Q tl < , e-fevt be/2 L , IGTA k % .s'0 m) %
or ev.u n .n > % To Ko, E x n a s e r r 2 . 1. c.
5 Deit nu-m W b & ( p Q
m tw rua., oco , or i p it. t- q w e s u W ,u . .
9
_ ___ ._ _.
~
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COMANCHE FEAK STEAM ELECTRIC STAT /CN
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UUALITY ASSURANCE PLAN SECTION: 15.0
p+ -
%
Nonconforming Items DATE: 10/30/78
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REVISION : 0
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FAGE 20F '
a. A significant breakdown in any portion of the quality assurance
program; or,
b. A significant deficiency in final design; or,
c. A significant deficiency in construction of or significant damage to a
structure, system or component; or,
d. A significant deviation from perfomance specifications.
.
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e owemo *
_. EXHIBIT 15
1
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COMANCIE PEAK STEAM ELECTRIC STATION
QUALITY ASSURANCE PLAN
.
&g ug, SECTION :
16.0
.g' Corrective Action DATE:
7/1/78
( REVISION :
0
-
PAGE 1 Or 1
16.0 Corrective Action !
<
Documented measures are used to assure that conditions adverse to quality
such as failures, malfunctions, deficiencies, and nonconformances, are
promptly identified and corrected as soon as practicable, and that
appropriate action be taken to correct the cause of the ccndition. The
identification of significant conditions adverse to quality, the cause of !
the condition, and the corrective action taken is documented and reported
as required by proudures. Responsibility for performing corrective
action is assigned tt contractors, applicable subcontractors, and vendors
so that each is alert to those conditions adverse to quality within his .
Own area of activity. } !n the case of significant conditions adverse to
quality, which are repfrtaole. to NRC, under the orovisions of 10 CFR Part
-
50.55 (e), measures are taken to assure that the cause of the condition is
determined and_correctiv0 action is implemented to preclude ~ repetition.)~
.
Corrective action procedures require thorough investigation and
documentation of significant conditions adverse to quality. The cause and
corrective action is reported in writing to the appropriate levels of ,
management and to the purchaser. The corrective action applied is subjec*.
-
to review specifica
purchase by TUGC0 and the prirne contractor responsible for the original
m n. The acceptability of rework or repairs is
verified by reinspecting the item as originally inspected and that the
reinspection is docuinented.
The occurrence and magnitude of deficiencies and nonconformances requiring
corrective action are evaluated during surveillance and at hold point
inspection and witnessing. Additionally, these areas are identified for
audit purposes.
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BROWN & ROOT, INC. B&R PROCEDURE
fee < W mm CP-QAP-16.1, Rev. 27
- CPSE S -
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y ) Page 1 of 24
5~""
AUG 131988
J
CONTROL OF NONCONFORMING ITEMS
ORIGINATOR: ( -
n M .
Y, /-
e,,oc W -
_8'-/ 3-/ SN
DATE
REVIEWED BY: f!/f!8/,,
APPROVED BY:
y DaE -
f3 [13f8(,,
l)' 1 SATE
1.0 REFERENCES
2.0 cENERit CONTROLLED COPY
y 2.1 PURPOSE AND SCOPE *-
-
The purpose of this procedure is to establish a method by which '
nonconforming conditions are identified, documented, resolved, !
and closed. The requirements contained herein are applicable to
ASME Class 1, 2, and 3 fluid piping systems, their supports, and
in-line equipment. When implemented for other than safety Class 3
* 1, 2& 3 component third party involvement, (i. e . ) ' ANI is not
required.
NOTE: It is the responsibility of site employees to identify
nonconforming conditions in accordance with this
procedure.
2.2 DEFINITIONS
2.2.1 Nonconformance
(
A deficiency in characteristic, documentation, or procedure which i
renders the quality of an item unacceptable or indeterminate. !
2.2.2 Nonconformance Report (NCR)
A Nonconformance Report is the documen.t,,that is used to identify,
disposition and verify arequacy of the" executed disposition of
_ properly identified and documented nonconformances.
EXHIBIT 16
.
1
_ _ _ _ _ - _ _ _ _ _ . - - _
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CPSES/FSAR
'
I
TUGC0 verifies conformance to the record requirements by reviewing
60 ' contractors'/ vendors' quality assurance methods for record keeping, by
4
, auditing contractors'/ vendors' systems when functional, and by
selective review of quality records for completeness and accuracy. ,
l
.The permanent on-site record storage facility is constructed of
reinforced concrete, concrete block, masonry, or equal construction. !
A concrete floor and roof with sufficient slope for drainage is l>
provided. A sealant is applied to walls, floor, and foundation. All
- 50 entrance and exit doors are fire retardant type. A closed loop forced j
air circulation system to control temperature and humidity is )
provided. Dry chemical or gas fire extinguishers are provided.
4
1
Standard steel cabinets and metal shelving are used inside the storage
facility to contain records and files. Access to the records facility
is kcyt controlled so that only authorized personnel have access to
the records area.
17.1.18 AUDITS
4
TUGC0 requires that planned and periodic _ audits be performed to verify
compliance with all aspects of the quality assurance program and to
determine the effectiveness of the program. TUGC0 QA performs such
60
audits on TUGC0 and its contractors / vendors to provide an objective
evaluation of the effectiveness of their programs; to determine that
their programs are in compliance with established requirement,
methods, and procedures; to determine quality progress; and to verify
implementation of recommended corrective action. The TUGC0 audits,
both internal and external, are conducted primarily by members of the
Quality Assurance staff. Consultants will be utilized by TUGC0 on
audits as required.
<
EXHIBIT 17
-
AMENDMENT 60
NOVEMBER 3, 1986 17,1 36
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NtS1 !*f.5.2.12 - 1973 .
.
Ceution Kotice - This standard is being
t.
prepared'or revie.:cd and has n'ot been
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approved by /O:5I. It is' subject to -
L L
~i revision or withdraus1 before issue. .- .
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5. . ME0lfj_nr:'n Ts rcR AUDITT :c Or -
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OU.*.1.1T*/ !&iC*!K'CE PT:OGT.'03 JdO ,, ,
.3- ,
KUCLEt.n PO W n PLM TS
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0 [). l'. INTRODUCTION:1
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3 1.1' Purr, st - The purpose of this stenderd is to provide uniforci requirements
L '- and guidance for er tuhlishing and implementing a sys. tem of internel and ~
'
.2. cxternal.cudits of quality. assurance programs for nuclesr power p1 ants.
- ' 'L.2 - [5 1 opf, MThis stunderd emplific's the requireme me: of R:SI N45.2, Secti r.
.% / :6ndch:11 te used in cenhnstien with that r.tsndardg This stand:r:1 providec
w/ requirements and guidance for the pr.cparation, performance, reporting, and .
5
followp,,of audits of qualicyysurnnec-.p.togra s for nuclear power plante.-
,
> ,
1
This standard is not applienbic to surveillance or inspectf ons for the' pur-
'$' pose of procc :: control or product acceptance. _This standard applies to-
*
T - both internal end exthrnal audits performed by 'or for tiie plant ovner,
-
..... .
- ;j
') ,,
contrnetors, and other organizations participating in, activities affecting
.L .the__qualiev of structures, systems, and components which are importent to
! the nuclear r.afety of nuclear pecer plants. The activities covered by .
l' thic stnndard include designin;:, purchasing, fabricating, handline, chippin;;,
'
\
i , s_t oring , cicaninr,, crecting, installing, inspecting, testing, usintaining,
'i (repairinP.",andnodifying. *
*
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.i NOTE: This standnrd does not cover requirements for auditing of plant
':
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operationn and refueling. These are intendad to le covered by
'8-
#1s1 1118.7 - 1972.
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EXHIBIT 18 I
s
Draf t 3, !*cy. 0
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3. AUDIT SYSTO! .
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2 ; 3.1 Cf ,ner.a.). - This scetion cetab31 shen requirements for a comprehensive
3 oudit syr. tem which shall be planned, documented, and implemented to verify
4
*
cceplisnec vith the clements of a qus11ty assurance program. The cudit 1
5 systei. shall be described in approved, written policies, piens. . procedures',
6 -
instructions, or such other docu acnts as appropriate.. The objectives of
i .
7 perfor=!r.g hudies of the quality assurance program are: ,
.
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8' 3 *.1.1 To determins that a qdslity assurance program has been developed
P t and documented in accordance with the applicable requirements
.? of MiSI :245.2;
-
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'{
. 1
,11 3'.1.2 To verify by cycluation uf objective evidence that the. documented
12 program has been i=plemented; *
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3.1.3 To assces the c.ffectivancsn of the quslity ass 0rsnec,progr:m; '
. '
14 3.1.4 To identify progrs= nonconfonsnecc; and
.
15 3.1.5 To verify correction of identified nonconformances.
.
1G 3.2 rssen: tel Elenente of the Audit Svs tem - An effective nuhit sy=te:: shc11
17 be estchlished cud maintaincd end shall include the follouing essential
*
13 cicments: ,
-
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19 3.2.1 A nanngement policy statement whfch cor.mits the orgard:ation to an
20 audit system meetinf, the reqEircecnts of* this standard. 1
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21 3.2.2 J!anpoder, funding, and facilitics to impicecnt 'the system of
22 audits.
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( s . . Draft 3, Rev. 0
. Hay 2, 1973
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.. T ht , s u. L J s % -o m - .- 6 , t h % < b .- .
'l v e s u.1 ; 2.<. , h s -b % m.~t DA 6 A p-6. ,_c. yp t,4, .
-
. - .
h 3.4.2 Audits shall be re;ularly scheduled on the basis of the status
cod safety 1 :portance of the activittee to assurc conformance ;
3; *
vith the developed cf.d it.:pleacnted pro;;ran.{Applica'. sic elements
4 of the. quality assur nce procr..n shall be audiced at Icast
~~
5 ,
annually or et 1cest .once within the life of the activity,- ,
6 whichever 1 shorter. .
-
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7 3.4.3 Sepplcr.cntal audits are conducted for one er e: ore 'of the .,
9 following, condi: fens: . .
. . . .
.
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9 3.4.3.1 Focn $t is necc :sary to determine the capability ,,
0 ,
of 'i contr:ctor 's ouality nye" - . _ _ . . _ pr! en
1 to swcrding of a contr:.cc or purchase order.
- .
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'2 L 3.4.3.2 Uhen, after cuard of a contract, sufficient time has
-
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( cinpned fcr inp]e:. tenting the quality assurance progren -
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4, , enc it is appropriate to cetermina that the organization
b is adequately performing the functicus as defined 13 the
6 quality assur:nce program description, codes, standards, ,
7 and other contreet documents. ,,
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B
'/ / 3.4.3.3 tracn ci;nificant chan3ec cre made.in functional arcac
9 of the quality assurance pro;;rco such 'as significant
0 reorganization or procedure revisions.
P au ~ a kMv 3uei. smk.(i tr. ~l2t hhprwc>oald Ht.uph w+h.1 vktaoa
e 4*I. M,
-
se% b%.s oc r. .ed
*
ld a.lso
1 r, 3.4.3.4 1; hen there Ic evidence that' the' performance of reliability
\[
2 of scfety-rcisted iteme ic in jeepsrdy 8due to deficiencies
3 . or nonconfernance in the quality scsurance pre;;rsm.-
. . . - _ . . . _ . - - -
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//
94%4 d L e MJ .
3. 4. 3. 5 tihen a systematic, independent assessment of progrso effec-
5 tiveness of iter.i quality, or both, in necessary. q
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May 2, 1573 l
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COMANCHE MAK STEAM ELECTR/C STAT /CW
' -
QUALITY ASSURANCE PLAN
SECTION 818.0
g # DATE: 7/31/84
rC
- \fc#' f
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AUDITS REVISION: 2 -
-
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1
PAGE OF 1
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18.0 Audits
TUGC0 and its prime contractors perform planned and periodic audits, to
verify compliance with all aspects of their quality assurance program and
to determine the effectiveness of the program. TUGC0 audits the prime
l contractors, TUGC0 internal activities, suppliers and vendors as necessary
to provide an objective evaluation of the effectiveness of their programs,
to determine that their programs are in compliance with established
requirements, methods and procedures, to determine quality progress, and to
verify implementation of corrective action commitments.
The auditing system used by TUGCO.
,
<
* Recuires au'dit planning documents be utilized to identify I
organizations to be audited. Frequency of audits will be determineo j
in accordance with provisions contained in TUGC0 Quality Procedures. <
b-
g * Requires auditors to be familiar with the type of activities to be
audited and have no direct responsibilities in the area being audited. !
I
* Provides auditing checklists or other objective guidelines to identify j
..
those activities which will be examined. I
* Requires examination of the essential characteristics of the quality
activity examined.
* Requires an auoit report be prepared that note; deficiencies found.
* Requires the audit report be sent to management responsible for the
area audited for review and corrective action for deficiencies.
* Recuires a response that documents corrective action taken as resul t
of the audit.
* Requires reauditing of deficient areas when it is considered necessary
to verify implementation of required corrective actions.
TUGC0 maintains audit documentation on file.
U
,
EXHIBIT 19
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In P.eply. Refer To:
Dockets: 50-445/84-32 FEB 15 25
50-446/64-11
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Texas Utilities Electric Company l
ATTN: M. D. Spence, President, TUGC0
Skyway Tower
400 North Olive Street ;
;
Lock Box 81
Dallas, Texas 75201 {
.
Gentlemen:
This refers to the inspection conducted under the Resident Inspection Program
by Mr. H. S. Phillips of this office and NRC contract personnel during the
period August 20, 1984, through September 20, 1984, of activities authorized by
NRC Construction Permits CPPR-126 and CPPR-127 for the Comanche Peak facility,
Units 3 and 2, and to the discussion of our findings with Mr. D. Chapman and
other members of your staff at the conclusion of the inspection.
Areas examined during the inspection ' included 'a review and evaluation of how
effectively Texas Utilities Electric Company management has implemented the
corocrate quality assurance (QA) program for design, procurement, and
construction activities. Special emphasis was placed on evaluating t.he
management of the audit program; management's action to regularly review the
status and a.dequacy of the QA program; and followup on findings pertinent to
. program management identified by previous NRC"and consultant inspection teams.
Within these areas, the inspection consisted of selective examination of j
procedures and representative records, interviews with personnel, and ~
observations by the inspectors. These findings are documented in the enclosed
inspection report.
During this inspection, it was found that certain of your activities were in
violation of NRC requirements. Consequently, yo'u are required to respond to
this violation, in writing, in accordance with the provisions of Section 2.201
of the NRC's " Rules of Practice," Part 2, Title 10, Code of. Federal
Regulations. Your response should be based on the specifics contained in the
Notice of Violation enclosed with this letter.
These violations may be related to findings identified by the NRC Technical
Review Team (TRT). If the issues are considered to be similar, you may respond
to the items separately or as part of the Comanche Peak Response Team Action
Plan.
;
RRIhfv1/ TL/TFh h S&S C D/D P NRR g28
SPhillips/1t DHunn1 cutt R UHunter RDenise Noonan
% /\%/8f } /p /86 '/'gart
./84 2 /g,/8g Nb'/84 it /LU/84
$
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APPENDIX A I
NOTICE OF VIOLATION
.
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Texas Utilities Electric Company Dockets: 50-445/84-32
Comanche Peak Steam Electric Staticn, Units 1 and 2 50-446/84-11
Construction Permits: CPPR-126
'
CPFR-127 ,
!
Based on the results of an NRC inspection conducted during the period of
August 20, 1984, through September 20, 1984, and in accordance with the NRC
'
Enforcement Policy (10 CFR Part 2, Appendix C), 49 FR 8583, dated March 8,
1984, the following violations were identified: -
1. Failure to Reaularly Review the Status and Adequacy of the QA Procram l
Criterion II of Appendix B to 10 CFR 50, as implemented by the Preliminary
Safety Analysis Report (PSAR) and the Final Safety Analysis Report (FSAR),
Section 17.1, " Quality Assurance Program," and ANSI N45.2-1971, requires
that the quality assurance program shall provide for the regular review by
the management participating in the program, of the status and adequacy of
the part of the quality assurance program for which they have designated
responsibility.
Contrary to the above, the applicant did not establish quality assurance
procedures to regularly review the status and adequacy of the construction
quality assurance program; nor did the applicant appear to have reviewed
the status and adequacy of the construction quality assurance program.
This is a Severity Level IV Violation. (Supplement II) (445/8432-02;
446/8411-02)
2. Failure to Establish and Implement a Comprehensive System of Planned and
_Poriodic Audits
Criterion XVIII of Appendix B to 10 CFR 50, states, in part "A
comprehensive system of planned and periodic audits shall be carried out .
I
to verify compliance with all aspects of the quality assurance program and
to determine the effectiveness of the program." The requirements are
addressed in the PSAR and FSAR, Section 17.1, " Quality Assurance Program,"
which references Regulatory Guide 1.28 (ANSI N45.2) and ANSI N45.2.12
(Draft 3, Revision 4). Those commitments require that a comprehensive
system of planned audits be performed on an ennual frequency.
Contrary to the above, the following examples,were identified which
demonstrate the failure to establish and implement a comprehensive system
of phnned and periodic audits of safety-rplated activities as required,
as noted below:
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Notice of Violation -2-
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a. Annual auditr were not adequately addressed by the audit I
implementation procedures. ;
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' TUGC0 Procedure DQP-CS-4, Revision 0, dated August 9, 1978, only
required two audits of vendors fabricating reactor coolant
pressure boundary components, parts, and equipment; one audit of ,
vendors fabricating engineered safeguards components, parts, and i
.
equipment; and audits of balance of plant (safety-related) as
required by the quality assurance manager.
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TUGC0 Procedure DQP-CS-4, Revision 2, dated April 16, 1981
required only that organizations will be audited on a regularly
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scheduled basis,
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TUGC0 Procedure DQP-CS-4, Revisions 2 and 10, did not specify. i
auditing frequencies for design, procurement, construction, and
operations activities.
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TUGC0 Procedure DQP-CS-4, Revision 10, based audit requirements
on Regulatory Guide 1.33, Revision 2, February 1978. This
commitment did not fully address the requirements of the
construction quality assurance program,
i
The above procedure and subsequent revisions failed to describe and
require annual audits in accordance with commitment 6 and
requirements. Earlier audit procedures were not available to
j
determine if they met requirements. - '
b. . Planning and staffing to perform 1983 audits was inadequate to assure
that a comprehensive system of audits was established and implemented
to verify compliance with ,a_1,1 aspects of the quality assurance
.
program, in that, of 656 safety-related procedures (which control
safety-related activities) the NRC review revealed that the applicant
sampled only 165, or 25 percent, during the 1983 audit program. }
Consequently, significant aspects of the safety-related activities '
were not adequately audited,
t
c. The Westinghouse site organization, established in 1977 to perform !
Nuclear Steam System Supply (NSSS) engineering services, was not i
audited by TUGC0 during the years of 1977, 1978, 1979, 1980, and
1981.
s
d. Audits of venders that manufacture or fabricate parts, components,
and equipment for reactor coolant pressure boundary and engineered
safeguards systems have not been conducted annually dating back to
.
August 9, 1978.
This is a Severity Level IV Violation. (Supplement II) (445/8432'03;
446/8411-03) <
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Notice o'f Violation -3- j
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.3. . Failiste to Properly Certify a Vendor Compliance Inspector .
Criterion V of 10 CFR 50, Appendix B, states,. in part, " Activities
' affecting quality shall be prescribed by documented instructions,
procedures, or drawings, of a type appropriate to the circumstances and
shall be accomplished in accordance with these instructions, procedures, l
or drawings." -
TUGCO.ProcedureDQP-VC-4, Revision 6,dateddanuary5,1984,requiresthat
Level II inspectors (Corporate QA) shall attend and satisfactorily j
complete nondestructive testing courses including eddy current testing.
Contrary to the above, one of six inspector's files had no documentation
to show that the inspector had attended and completed an eddy current i
testing course. Subsequent, discussions revealed that he had been '
certified without meeting this requirement. The vendor compliance
supervisor stated that this inspection skill is not needed since there is
no present vendor work activity which would require this skill; therefore,
.
this procedure was' revised and the requirement omitted during this
-inspection.
This is a Severity Level V Violation. (Supplement II) (445/8432-05;,
446/8411-05)
Pursuant to the provisions of 10.CFR 2.201, Texas Utilities Electric Company is
hereby required to submit to this office, within 30 days of the date of this
Notice, a written statement or explanation in reply, including: (1) 'the
corrective steps which have been taken and the results achieved; (Z) corrective
steps which will be taken to avoid further violations; and (3) the date when
full compliance will be achieved. Consideration may be given to extending your ;
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. response time for good cause shown.
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Dated:
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AUDET REPORT
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Subject:
Audit of Texas UtfTitfas Generating Company DaiTas Offices
...
r and Ccmanche Feak neare ETectric Sta.tierr Constru
,, . , .. Date of Audit:
,
May T-TZ,19fE
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Audit feope:
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A management audit was conducted. of the Quality Assurance
Progras of Texas. Utitities Generating Company during the
.
fTme/f weeks of May T and May E.,1978.
The purpose of the audit
i
was to detaraine the adequacy of the QuaTity Assurance
Prcyms as reTated tn NucTear RaguTatory Commission requi{
,
mants and the effectiveness of implementation talenet progran
, , requiremarrts and authorfty delegations. i
Actfvities were
audited at both: the TUGC3 officas in LaTTas and at t
Comanche Peak construetfort site.
Activities of the Architect /
Jgineer and Constructor were audited onTy at the construction
.gite. The scope of the audtt included conef tmants made in
the PSAR., the Corporate QuaTity Assurance Manuat, the Com
Peek quatity Assurance PTan, the Pro,fect Procedures Manual
and the Browrw & Rcot Quaffty Assurance Mr.nuaTs and Proced
reTated to the Comanche Peak sita.
Audit 2rn
Delias offfee, May T-2. T978
- Je P. Jackson, .MAC Audit Teant Leader
J. M. Norrfs. MAC Auditor
*
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Comanchsr Paak Cons.true fort Site, May & E 5', May 8-TZ,1
,
J. P. Jackson, MAC Audtt Tenne Leader -
J. M. Norrfs, MAC Audftor
, , .
J. A. Hendrorr, MAC Auditor (May E-I2. onTy) (
!
PersonneT g !
",M
g 7, V D. N. Chapmarr
_COMPANK
TUGC0
ETI
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5 '! -::p R. G. Tolsort Q4 Manager. *-i-E
TUGCQ
R. V. Pieck Mgr, Site Surveillance, *-i-2
TUGCD/GE
- J. V. Hawkfas Civ. Inspec. Supv., *-T
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TUGCO/GM
Prod. Assurance (QA), *-T
EXHIBIT 21
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TU8CE AUDIT' REPORT
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'Q Personnel MAME COMPANY TITLE }
**7, $* / J. B. George TUSI
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p V Prof. General Mgr., *-1-1
5
J. T. Marrte , Tust Resident Nanager, *-1
E. E. Eibson - TU1I
[ Project Engineer, *-1-?. E. J. Murray- TUSI
f. Engineering Supv., *-T
J. J. Moorhead G8H
Resident Engineer, *-t-Z
R. C. Scott 81R j
. Site QA Manager., *-T
J. P. CTarke E&R
(
Siter QC. Manager,, *-T
R. Mann B&R
QA Records coordinator, *
19 C'. KirkTand BAR {
:p ' Prof,. GenersI Mge,. *-1
1 D'. DougTas B&R !
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7 Project Manager, *-T
L C. Frankun B&R
h Asst. Prefect Mgr., *4
*
P. Foscato B&R
Prof. Chief Engineer *-T
L. Mancoch B&R
Mat'T Procurement, Con-
/ A. Borers structfan Branch *-T
TUGC3 Vender complianca *
V A. Vep
s TUGC3
,, c.' Beggs QA Central Staff Function *-T.
TUGC3
R. Gary
,
Systems Compffance,. *-t-Z
TUGCC
V'.P.. Operations, *-1
t.. Ffker TUSI
P. Brie::ain V.P., Desfgn & Procurement. *-i
TijGCU/TUSI
President, 1 ;
* Tnterview
I Pm-audit meeting
E Fast audit meeting:
Audit Method: )
{
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The audit was conducted through a series of interviews with
responsible management and supervisiert and examination of
quality Assurance manuais, procedures, records and work -{
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operations both at the OaTTas headquarters of Texass utilities
Generating Company and Texas Utilities. Services,. Incorpora
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and at the Casanche Peak construction site. -
j Sousary:
.
The audit disefosed that eteent changes in authority dels-
gations had been generalTy weTT accepted and that morale !
.
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( TUGC0 AUDIT REPORT
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]p sumary (Cont'd): and team spirit were good. However the changes had not "
yet beerr forJatized. in revisions ts the PSAR t.nd the
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Comanche Peak Quality Assurance Plarr.
T' e audit al'so M2
dtscTosed that present practices in tha control'of desfun '
changes and cf certairr nonconformancas der not provide the
'
requisite levei of review by the original designer. Tn ' ' '
7ther-instancas it was evident that design changes'wre"OM
being used irr Tieu, of nonconformance reports. Except for
the areas, notad herein and below,. there was genera 1Ty good
adherence to eststing procedums.
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Findings:
T. The current activities of TUGCO. Quality Assurance per-
. sonnet are not consistant with the authority dategations
to Brower & Root and te Gibbs & Hili as defined. in the
PSAR and Conanche Peak QuaTity Assurance Pian.
l SteilarTy,, the QuaTity Assurance Pfarr and Procedures are ~ ! not consistant with current and pTanned rivisions irt
authorfty: delegations' to the Architect / Engineer and the .
Constructor,, and fs not complete in address.ing all
eighteen erfterfa of 10CFR50_ Appendix 8.
Tha Ia'ck of a
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melt fdentified plan of reorganization and responsibility
* causes uneartatttty irr carrying out some activities.
.
4 "There needs to be a plan for revising the Quality Asstar
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,g ance Program; suctt a plan should include the establishment
'g af an archttacture of procedures to show how other TUSI/
TUGCO and contractor manuets intar-relate with the QuaTit
, Assurance Manuar. The T4JGC0 QA Manager should, establistr
a schedute and as. sign responsibtTities for compTetion of
the necessary procedures.
The scheduTe should be suppie-
mentad wittr a management effort td monitor, adherence to
the plart and achievement of the schedule.
( Z.
The current site DC DCA sys.tas of after the fact coordi-
natierr of desfgn changes with the original designer
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TUGC0 AUDIT REPORT
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Findings:. Y provides a significant Msk of design error and door
d) *
not meet the requirements. of TOCFR5G Appendfx 8, 'n$r
y
,
of ANSI M45.2.IT, " Quality Assurance Requirements for .
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the Desfgrr of Nuclear Power Piants".
A systeer for expediting and documenting Gibbs & Hill -
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home office approvais should be established using.
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teTephone,. telecopier or telex as. e means of speeding
consnunication.
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2. The Comanche Peak Qualfty Assurance Flan does. not provide
,
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for a quality Assurance review of procurement documents -
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and changes theretor prior to purchase order placemept.,
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Qb, except for site originated procurement. Such a review
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p/ ts identiffed irr 10CFRSC Appendix E., Crftsefon IV' and I
is a requirement of ANSI N45.2.13. It shouTd be required
on> aII safety related procurement.1.
1 4.
*
The current combinatfort of Chapter-17 of the, PSAR, the
g TUGC3 Corporate Quality Assurance Manual, the Comanche
Peak Quality Assurance Pfarr, Prefect Procedures. and
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Browt & Root Manuals and Procadurgs provides a complex
array of procedures which is diff'icuTt to maintain
current and consistant.
.
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S. The current systene of providing inspection instructions
7 or checkTfsts ter inspectors is toor generic, placing an
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undue burderr on the inspector in attempting ta determine
applicahTe drawings and. specifications and appifcable
'revisfons thereto. A myiew of records of concrete {
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~ pours incidates that configuration ruffecting the as-
J
poured conditforr fs not clearfy defined. Appifcable
!
DC DDAs are not'noted in inspection documentation.
] Configuration needs to be clearly identified to [
inspeccces on: e current basis, incTuding af f apptfeable
]
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TUGCC AUDIT REPORT'
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Findings: DC DCAs. and. completed. documentation rxJst refTect tne
IE*"*'dI
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status of the appTicabTe changes.
\
h 6. Speciai_ processing markings for Tstar in-service.
inspections are careTessiy appTied. The circTe anit .
f V d arrow, used for sucfr marking is sometimes incomp1Ete
[,A and not recogn, table-for its intended purpose. In one
, '
d instance only a, portion of the circle resembling the
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Tsetar "C" was. dfscarnibTe. FatTure tar property . *
,
a
a marit these Tocators nowr wtTT cause delay and, possitrie
a .
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error when in-service inspections are made in highTy
irradiated areas. '
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7. Gisposftform of nonconforming itams does not aTways '
f ,,
acirfeve the requisite review hy appropriately quatiffed
destgrv personnet. A procedure,. Timited to. defects in
[ @[ concate was recentTy fssued.which bypasses.the estab-
) Ifshed nonconfornance controT systas and., thus, vioTates
reguTatory. requirements tre this regard. Lt other
instancas., the DC DCA progreat has beerr used tar bypass
the nonconformance reporting, systar. The nonconformance
corttrat systen shouTd be the means9er maintaining in -
spector integrity, identifying probies areas and provide
e drivirts force for their correction.
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2.
,
The records storage faciTity does not curmntTy have any
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means 'of fnternet ffre protactiers during hours it is
.
unmannedw ai,though it is understood some method fs
.
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pTanned. Quaifty Assurance records,. such as personnei
quaitffcations,. arer not maintafned irt the Records Cantar,,
but are anfntefneld in ffreproof ftTe cabinet- in a trniTer
under the cognizance of Browr & Root training coordinator.
] 9.
Approx.imateTy twenty-four percent of Centrai Staff audits
have noc been conducted as scheduTed. Combining Central
Staff audits., site audits and site survefliance activities
saa
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. TIGC3 AUDIT REPORT
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! ' Findings:
by TUGC3 and by Brown & Root fnts a singie, cohesive
(Cont'd) -
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program wouTd provide improved visibility to the overa.11
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audit and surve1TTance e#cre and permit evaluation and
)
tiustment to the audit schedule to attainable and yet
,
enective esquencier
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Gl5ERVATIONS & REC 0f9tENDATIONE .. . . ~- 15-
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XVII. RECOR E
Except for lack of internal fire protection, the quality records area ,
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is considered to be satisfactory. Some QueTfty Assurance records, such , , , _ ,
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as personnet quaitffcations, are not stored in the records center but -
,p are maintained separately by the Browr & Root trafsing coordinator.,
..
There fs not currentTy a catalog or Tfsting of req...uired records althougtl,, .
g/ ,
it is being prepared. A review of e'selectierr of Quality. Assurance
records showed the documents irr thes to have beert properly. completed
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and fn the correct order.
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Recossendatfort - The instaT1atfort of an ineet gas fim extinguishing .k.
syster or the identtffcatfos of geographicaTTy separate duplicate records-
j
shouTd be expedfted. TUGC3 shouTd review the fire protection capabfifties /
l of storage facfTitfes frr the training superviscr's trailer and consider
e dupTfcate set of si!n records te be maintained frr the records'ceitter. '
*
XVIII. AUDITE
Therer are sever I audit and; survef1Tance programs frt effect. Adtts by-
the cuaTftv Assurance Department Centrat Staff are performed on site
l
f activities. maior contractors at:d suppTfers. Site surveillance actions
,
ar* =Qd under the direcsfort of the TUGC0 CA Site Supervisors Steilar &I
survef1Tance activtties are carried out under the direction of the Brown &
Root Site Quality Assurance Manager. Whfie catted surveitiance actions, j
the survetTiance programs are formetTy planned and scheduled, utilize -
!
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checkTfsts ts guide.the activity and mcord resuits, arid issue reports
[
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cf deficiencies and require correctiert. Except. for forumi and documented
pre-eudft and post-audit meetings, aTT the elements of an audit program
j
are frr piace. It was repertad that the reason for catting the activity !
"survetiTance* was to avefd outside auditors finding the. program deficient J
.because it did not incTude the de:umented pre- and post-audit meetings,
yet the audttors fount that suca meetings were conducted, but on an
informal basis.
b Recommendation. - The auditors consider the present progrant te be an
effective toot which couid be fitrther improved. TUGC0 should consider
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CD GISERVATIONS & RECOMMENDATIONS - -
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combining the audit and surveitience activities ints a s. ingle., cohesive
effort. Such art integrated effort could cover required areas. meri
efficiently, without duplicattorr and at e frequency that carr be main-
tained. Such art audit progrra should be described.'in writtatt procedures. . -
arxL fnclude e descrfptien of bette the formai audit and the continuous . ., '
audit pian (surveitTance) and the method of conducting pre- and post-audit- --
meetings should be described to preciude later criticisms by outside -
.
organizations. Tha resulting audit progrant should be a superior tool for -
unnagement assessment of prograr impTementatiert and effectiveness.
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,, , puc 4TEC , UTILITIES GENERATING CON,tNY 1
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Sub,w Anacement Ouaf f tv Assurance Audit
-
RR C RTVED-
jut,12197~
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P. G. BRITTAR4
1 i
Attached are our resolutions to the findings and recommendations. made
l by Management Analysis Company as a resuit of their audit irr May.
Our analysis of the audit results has been discussed in general terms.
with John Jackson, and we see no need to respond fonnally to this audit.
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R.3T. Gary /
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L. F.Hkar '
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and steps have been takert to. improve the visibilit;y for the record. - --
6. Finding Sumary: Markings for in-service NDE inspections were not
always cistinct.
Response: We agree that_such markings should be TegibTe. QC *ill
inspect special process ISI mark.ings prior to turnover.
T. .
Finding Summary: We are using the DC/DDA (design change) program. to
bypass tne nonconformance system.
4,
- Response: This is not true. If construction identifies and
4 corrects a defect or obtains an approved engineering change prior ta-
QC fnspectiort, no NCR f s. required.
y
8. Ff adine Summary: The records storage facitity does not have
internal fire protection durfng off-duty hours.
Response:
Art inert gas fire protection system is oft order by TUSI.-
Target cate for installatferr is. August I.,1978.
9.
Findino Sumary: ApproximataTy 245. of audits schedufed by Dallas
staff nave not beert conducted. Audits by TtjGCO. and.8&R should be
combined fm one overali effort.
_
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Response:
-
Our audit schedute fs constantly being revised to refTect
enanging
investi manufacturing status and ts allow us to use audits to
arise. _ gate probTem areas of' the roost immediate concerrt as they
it as it is. jWe believe we cart defend our audit program,. and are T4av
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WonsnAx. FonsT rnr, SA.MPEI.5 & WOCI.DnIDGE
.. .sv. w. esp... t..I..v..e ... I
as. .. se 6. DALI.Ls, TzzAs MSok >
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,6 . . . . ., May 29,1985
"'*
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Peter B. Bloch, Chairman
Administrative Judge
Atomic Safety and 41censirfg Board
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Dr. Walter H. Jordan
!
Administrative Judge
881 W. Outer Drive
Oak Ridge, Tennessee 37830
Dr. Kenneth A. McCollom
Administrative Judge
Dean, Division of Engineering, !
Architecture and Technology
Oklahoma State University j
Stillwater, Oklahoma 74078 1'
,
1
Re In the Matter of Texas Utilities Electric Company, et al I
(Comanche Peak Steam Electric Station, Units 1 and 2)
Docket Nos. 50-445-1 and 50-446-1 ,
'
Supplementation of Appilcants' Response to CASE's Request
for Production
Dear Administrative Judges: l
'
. This is to notify you and all parties to the above deckets that Applicants have
identified a document which we believe to be within the scope of item to of
CASE's
August 4,1980. Interrogatories and Requests to Produce dated July 7,1980, as clarified on
1980 and supplemented their response by letters 22,1980, dated DecemberAppilcants
March su ,
'
5,1982, and April 19, 1982. The document, a copy of which is enclosed with this
!. (MAC) following a management review and audit of the quality a
of the Comanche Peak Project,
i
EXHIEIT 22
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Administrative Judges
May 29,1985
Page Two
Recently, in gathering data for a prudence audit hing performed for T EC,
a search was made by TUGCO personnel of inactive and closed corporate f1!es
located in TUGCO's Dallas office. In the course of such search, the enclosed
report was found. A memorandum dated July 11, 1978, which detalls TUGCO
resolutions to the findings and recommendations made by MAC, is also enclosed.
TUGCO management is evaluating the failure to produce this document at an .
earlier time and will advise the Board and parties of the results of this evaluation
in the near future.
Respectfully submitted,
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Robert A. Wooldridge
Counsel for Applicants
RAW /k!w
Enclosures
cc: Service List
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pung#
. 0, UNITED STATES
j i NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
+# 2 2 SEp G85
.....
Docket Nos.: 50-445
and 50 446
MEMORANDUM FOR: Chairman Tech
Commissioner Roberts
Commissioner Asselstine
Commissioner Bernthal
Commissioner Carr
l FROM: Vincent S. Noonan, Director
PWR Project Directorate #5
,
Divison of PWR Licensing-A -
SUBJECT:
BOARD NOTIFICATION - F01.1.0WUP OF BOARD NOTIFICATION
,
NOS. 85-067 and 85-076 REGARDING OFFICE OF INVESTIGATIONS
l
REPORT h0. 4-85-008 REGARDING THE FACTS SURROUNDING
TEXAS UTit.ITIES UNTIMEl.Y RESPONSE TO THE INTERVENERS
DISCOVERY RE0 VEST (BOARD NOTIFICATION NO. 86-20 )
This Notification is being provided to the Commission in accordance with the
revised Comission's notification policy of July 6,1984, to inform the
Comission on all issues on the cases before the Commission.
Background
On May 29, 1985, AppTicants notified the Board and parties that they had
identified a document which they believed to be within the scope of a
1980 discovery request from the interveners. Applicants had submitted their
* initi31 response in 1980 and supplemented their response through 1982. The
document was a report prepared in May 1978 by Management Analysis Company
(MAC) following a management review and audit of the cuality assurance procram
of the Comanche Peak Project. On June 12, 1985 Applicents provided the Board
and parties with their evaluation of the failure to produce this document at
an earlier time. In sumary, the Applicants determined that an individual
responsible for licensing made an error in judgement not to produce the report
in 1980. By Board Notification No. 85-067, you were informed the Executive
Director for Operations recuested the Office of Investigations to investigate
the facts surrounding Applicants' withholding of the 1978 MAC report.
In addition, by Board Notification No. 85-076, you were informed that durino
the 01 investigation the staff became aware of some additional audits
performed by MAC of the Brown & Root GA Progran at Comanche Peak and that the
staff requested copies of these reports for review to determine whether these
audits should have been provided to the intervenor as part of intervenor's
1980 discovery request as well. On September 16, 1985,
the board and parties with these three reports prepared inApplicants provided
1976, 1977, and
1978 by MAC for Brown & Root concerning the Brown & Root GA program.
Applicants stated that the three documents appear to be within the scope of
EXHIBIT 23
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of intervenor's discovery reouests. As noted above (BN No. 85-0761, the !
staff first learned of these reports in an interview with MAC personnel by '
OI on the subject of additional work by MAC relating to Comanche Peak (other
than the 1978 report commissioned by Texas Utilities and produced in the May
29, 1985, submittal).
Result of 01 Investigation '
i
The Office of Investigations has completed its investigation which examined I
the circumstances surrounding the failure of TUGC0 to provide the MAC report
on a timely basis to a discovery request by the intervenor and issued its f
!
report no. 4-85-008 (copy enclosed). 01 concluded that the intervenor's ;
interrogatory was sufficiently well-defined to reach the report at issue; j
the utility made a material false statement by c:nission of the report in
response to the intervenor's reouest; however, the omission was not made with {
the intention of violating the ASt.B's order. ,
!
The parties to the proceeding are being notified.by copy of this memorandum, t
Vincent S. Noonan, Director
PWR Project Directorate No. 5
Division of PWR I.icensing-A
Enclosure: 01 Report t!o. 4-85-008
cc: P. Bloch, ASI.B
W. Jordan, ASI.B
X. McCollom, ASI.B
E. Johnson, ASI.B
SECf (2)
EDO
OGC
ACRS (101
Service I.ist
(See next page)
*See previous concurrence. I
PD#5* PD#5* OGC*
AVietti-Cook:js CTrammell I. Chandler BPayes
8/14 86 8/14/86 9/16/86 / /86
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DIR: PD#5 j/
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VSNocnan d
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; e NUCLEAR REGULATORY COMMISSION - O 'W # ' 'a.1
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APR 11 1963 ' ,' - (
3ccket her, 50-'.45 M
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. Texas Utilities Generating Company
,CH : Mr. R. J. Gary, Executive Vice ?*esicent
and General Manager
2001 Bryan Tower-
Callas, Texas. ~5201 3
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Gentlemen: k
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SUBJECT: Construction-Appraisal Inscection 50-445/83-18, 50 446/83-12
This refers to the construction appraisal inspection conducted by the Office of ..
Inspection and Enforcemer.t (IE) on January 24 -' February t. 1983 and February
14 - Marchoffice.
corporate 3,1983, at the Comanche Peak Steam Electric Station and-your Dallas
The Construction Appraisal Team (CAT) was composed of
members of'IE and a number of consultants. The inspection covered construction
activities autnorized by NRC Construction Permit CPPR-126/127.
This inspection is the second of a series of construction appraisal inspections
being planned by the Office of Inspection and Enforcement. The results of-
these inspections will be used to evaluate 1: olementation of management control
of construction activities and the quality of construction at nuclear plants.
The enclosed report identifies the areas examined during the inspection.
Witnin these areas, the effort consisteo of detailed inspection.of selected
hardware subsequent to Quality Control inspections, a comprehensive review of
your Quality Assurance Program, examination of proceduras and records, observa-
tion of work activities and interviews with management and other per,sonnel.
Appendix A to this letter is an Executive Summary of the results of the inspec-
tion and 'of conclusions reached by this Office. Except for the area of the
heating,ventilationandairconditioning(HVAC) system,deficienciesnotedin
~installed hardware
installation did not indicate pervasive failures to meet construction
requirements.
control was identified. NRC In the HVAC system, a breakdown in work and quality
Region IV has discussed this matter with you and
it is our understanding that this matter received imediate action by ycu and
your contractors to evaluate and correct these conditions. NRC Region IV will
- continue to pursue this issue with you. Prompt management attention to the
resolution
needed, of otner detailed deficiencies identified during the inspection is
i
In contrast to the HVAC system, the NRC CAT inspectors found few deficiencies l
in its' inspection of safety system piping. ASME Code radiographs for this
piping ,and samples inspected in this area showed evidence of good workmanship.
EXHIBIT 26
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.96
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APPENDIX 3
,
90TENTIAL ENFORCEMENT FINOINGS
February '4,1983 and February la - March 3,1983, the fol
referredtoNRCRegionIV.I.spotentialenforcementfindings(Section
'
references are to the detailed portion of the Inspection Report) .
lectrical ano Instrumentation ' Construction __
lfjMP
l '.
Contrary to 10 CFR 50, Appendix B, Criterion X and FSAR Section 17.1.10,
certain inspection activities were not executed to _ verify installation
. confomance with procedures including gble spacing in trays, cable bend _M
radii,cablefill,nh1.Sunnnr.tsandtrayinstallationnaHwar,e,(Sections
II.B.1.a . b ,c,d, and II.8.4.b(1)) . _
f
1 //
12.
.
. Contrary to 10 CFR 50, Appendix B, Criterion XVI and FSAR Section 17.1.16
the established inspection ptogram did not provide adequate controls to
assure that deviations from electrical and electrical / mechanical separa- 3
L tion criteria as ~ defined in the FSAR were cromotiv identified and cor
rected (Sections II.B.1.f. II.B.4.a. and 11.e.4.b(2)). .
3 '
.
Contrary to 10 CFR 50, Appendix B, Criterion V, FSAR S
h[* ' ' '
. to certain aspects
implemented
'
of battery
(Section maintenance have not been developed.or
II.B.3.0,).
/'
Mechanical Construction
-
f~ ;
'
1.
/,j
,
/' Contrary to 10 CFR 50, Appendix B, Criterion V. FSAR Section 17.1.5,
!
. supports / restraints were inspected (Section
'
.
2. j
M
g Sections 17.1.10 and 17.1.17, an inspection pregram has "
.
N established to verify and document installaJ.? confoman's to drawing l
requirements
ment installat, ions in regard
- - . - ~ (SectiontoIII.B.2
pipe and supports
3). / restraints and mehenical equip-
3.
Contrary to 10 CFR 50, Appendix B Criteria V and X, $ I
conditioning
requirements. (HVAC) duct, supports and equipment do not conform to des
In add' tion, inspection procedures have not been established
or
(Section III.B.4- ).verify conformance of HVAC supports to design drawings
executed to
.
B-1
.
.
;
1dinc and Nondestructive Examination
[f .
Contrary to 10 CFR 50, Appendix B, Criterien IX and FSAR Section 17.1.9
certain special
controlled A "processes relative to the HVAC system were not adequately
y=Emproperly-oualifree preeedttses; improperly qualified
inspectors; improper
- cc. w ...-certification of NDE personnel (Secticn IV.B.3).
Civil and Structural Construction
( Contrary to 10 CFR 50, Appendix B, Criterion V and FSAR Section 15.1.5, civil
y construction test procedures were inadequate to ensure that mixer uniformity
tests as required by the ASME-ACI-359 Code were performedy +% rer:Mhd
% c"0 (Section V.b.2)
/
* procurement. Storace and Material Traceability
d Contrary to 10 CFR 50, Appendix B, Criterion XIII, FSAR Section 17.1.13,
CP-QAP-8.1, Rev. 5, CP-cpm-B.1, Rev.1, and MCP-10, Rev. 7, storage of certain
safety-related equipment in outsice lay-down areas and insta14ed.4n-the-prlant
un noi yropeMy enn+tcBed (Section VI.S.2).
Quality Control Inseector Effectiveness
Q 1.
Contrary to 10 CFR 50, Appendix B, Criterion II and FSAR Section 3.8,
M f individuals were certified to levels of capability without the requisite
a
experience described in Regulatory Guide 1.58 (Section VII.B.2.a.(2)).
2.
g
Contrary to 10 CFR 50, Appendix B, Criterion X and FSAR Section 3.8,
inspection records were prepared and accepted by L-I inspectors as the
" inspector of record" rather than the required L-II " inspector of record"
required by ANSI N45.2.5 (Section VII.B.2.b(1)).
Quality Assurance
1.
Contrary to 10 CFR 50, Appendix B, Criterion XVIII and FSAR Section-
17.1.18, QA audits have not been conducted at a frequency or at sufficien
'
depth to identify and correct significant problems in various areas of
/ construction; i.e. , HVAC and electricalsRFaraty (Section
VIII.B.2.b.(5)(c)). "
f 2. Contrary to 10 CFR 50, Appendix B, Criterion XVI and FSAR Section 17.1.16,
(f..']pBP audit findings related to maintenance instructions identified in 1979,
Ap
,
1981 and 1982 were not resolved in a timely manner (Section VIII.B.2.b.(5)(c)).
Lc 3.
P Contrary to 10 CFR 50, Appendix B, Criterion VI and FSAR Section 17.1.6,
drawings with out-of-date revisiens and drawings with damaged or unread-
able title blocks were present in construction work areas (Section
VIII.B.2.e.).
M. #9
,
'B-2
. . . - . . . .
$ $4 e. e ee u
*
O
m
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..g .
,, ...
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-
:
Desien Chance Controls and Corrective Action Systems
1
Contrary to 10 CFR 50, Appendix B, Criterion V and FSAR Section 17.1.5,
procedures were not adecuate to assure design charges were properly. i
transmitted to the Quality Control organization such that an appropriate
inspection could be performed (Sections IX.8/,1. nd IX.8.1.c),
i2 Contrary to 10 CFR 50, Appendix B, Criteria II and XV, and FSAR Sections
17.1.2 and 17.1.15, nonconfonning conditions identified relative to some -
safety-related harcware installations are not being properly documented,
s -
evaluated, and dispositioned through the Corrective Action Program. ,
(Section III.S.S. IV.B.2 and IX.S.21).
i
l l l
l
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B-3 ]
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e
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l
. QUALITY ASSURANCE ;
~' A. Objective i
The objective of this review was to determine the adequacy of the
I licensee's Quality Assurance (QA) Program. The program was reviewed to j ) determine if it was appropriately established in instructions and
.
manuals; and if the construction and quality assurance effort was
,
monitored through audits and other management actions. In addition, a
sampling review of specific steps taken by the licensee regarding the
oversight of contractors (,ontrol. of measuring and test equipment,
document control, and control of QA records was made to determine if
specific parts of the program were implemented. ,
(<
B. Discussion
1. Procram Retirements
The QA program is defined by a management endorsed hierarchy of
general directives and implemented by procedures at the corporate
and site levels to control construction activities. These
procedures were implemented to satisfy the licensee's Final Safety
Analysis Report (FSAR) commitments.
2. Pecoram Implementation
'
Implementation of this portion of the program was determined based
on reviewing the organizational structure, input from other NRC CAT
inspectors, the construction audit program, sampling drawing revi-
sions in the construction work areas, and reviewing the control of
measuring and test equipment.
a. Organization
The QA organization includes the site construction quality
control organization which is independent from the site construc-
tion management. The quality assurance organization reports to
the Vice President for Nuclear Operations, whose responsibilities
include the construction and. operation of the Comanche peak Steam
Electric Station (CPSES). The authority and duties of the
positions involved were described in the FSAR and corporate
manuals. The audit organization was located at the Corporate
Headquarters in Dallas. The QA organization was found to be in -
accordance with NRC requirements and the description contained in
the FSAR. Organizational Charts indicated that a number of staff
positions were vacant and had been for an extended period.
*
1
,
VIII-1 l
l
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. . . . . . . . . .
.. .
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. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
L -
l
3
'
. V
,
-
. 'N
s 4
,
.
"
b. Audits
-The licensee's audit program was reviewed. At least-18 audits-
out of 60, performed between 1978 and 1983, were selected and
reviewed with emphasis on the following major areas: auditor i
. qualifications and certifications; audit planning and scheduling;- '
audit instructions and check sheets; audit reports; audit results
and followup; and the overall effectiveness of the audit program.
(1) Auditor Qualifications and Certifications
(a) The licensee qualification and certification program for
auditors and lead auditors was established in QA
,
Procedure DG1-QA-2.1 " Qualification of Audit Personnel".
(b) The certification records for ten lead auditors were
reviewed. The lead auditors met the TUGC0 and ANSI.
N45.2.23 requirements. The review revealed, however,
that auditors not meeting the experience requirements for
the , lead auditor position had been assigned as " Acting.
Lead Auditor", but_ the limits of an acting lead auditor's
authority and the guidance provided was not defined.
(2) Audit planni g and Scheduling
.
(a) Document reviews and interviews revealed that audit plans
were developed and a system of check sheets were used as i
guides to the auditors to ensure that specific points
were reviewed. Open. audit findings were also reviewed
during the audit.' It was revealed that the check sheets
were developed by the auditor a,ssigned the audit or try
the audit group supervisor but were not approved by the
QA Services Manager.
Interviews revealed that audit schedules were developed
using previous audit findings, schedules, experience and
discussions with construction site supervisors concer,ning
construction problems. There were no trend analyses or
construction schedules provided to the QA organization by
the site; therefore, these.important sources of in-
fonnation were not used in developing.the audit schedule.
Also, there was no QA pr*>cedure to describe the method to ,
be used to develop audit schedules or what management *
I
aporovals the schedule should receive.
(3) Audit Reports
,
Audit reports provided a description of the audit scope;
identification of auditors; persons contacted; a suntnary of
results and a description of,any deficiencies or findings.
.
VIII-2 I
i
- _ _ - - _ -
- - ____
, 4 .. ~ ' ~'
. ...
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f
c ,
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,; j:. 'O (4) Audit Deficiency Recorting and Follow-uo l
'T ,
tv
'.
,. Audit deficiencies were clearly written and required timely
response by the management of the audited organization. The *
I
completed deficiencies were reviewed by the audit team leader
for adequacy. Deficiencies were reviewed in subsequent
.
{
audits for completeness. Prompt corrective action was not
!
always taken on audit findings (See Paragraph B.2.b.(5) l
below).
!
1
(5) program Effectiveness I
b
Although the audit program was in place, there were several l'
weaknesses in the program that decreased its effectiveness.
(a). Audit Effort
The audit organization is located at the TUGC0 offices in
Dallas. All audits are performed from that location.
There are eight auditors in the audit section. Although
audit teams are sometimes supplemented by personnel from
other sections of the QA organization, the eight member
audit section is assigned to perfom audits of suppliers,
subcontractors at the construction site, construction
activities and startup. Of the eight auditors in the
audit organization, four had technician background and
four had a general nontechnical background. None of the
auditors assigned to the group had engineering background
or experience. Interviews revealed that approximately
1200 man days were spent preparing for, conducting and
reporting audits at the site in 1982. A review of the 32
audits perfomed in 1982 revealed that about 330 man days
were spent on site perfoming these audits. This appears
to be a small percentage of the total audit effort
considering the level of effort ongoing at the site.
Interviews revealed that five additional auditor
positions had been authorized for more than one year but
the positions were still vacant.
(b) Audit Frecuency
Interviews and document reviews revealed that:
.
Twelve audits of construction activities were performed l
in 1981. Of these, six were of engineering and adminis-
trative areas such an audits of IE Bulletins, and pro-
curement and six, were of construction field activities. l
.
Thirty-two audits were perfomed in 1982. Only nine of
the audits were of construction field activities, the ;
!
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VIII-3 l
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_ _ _ _ _ - . _
-
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I
etherother
and 23 audits.were performed of engineering activities
support areas.
!
field activities: Of the audits of construction
one audit was performed of mechanical
piping activities, one of restraint and snubber instal-
lations, two of electrical work, one of civil work, one
of instrument
coatings and controls, and three of protective
application.
L
The frequency of '.udits of construction activities has been
very low and may have contributed to the problems in the
of this report. technical cistir.ines identified in Sections II, III, and IVl
!
.
!
i
(c)AuditEffectiveness
!
Areas of the construction activity were audited; however,
the auditsfordid
problems, not icentify major construction program
example:
!
.
Bahnson Services was audited yearly since 1980. The
last audit was in April 1982.
installation activities and personnel qualificationsAlthough fabr
were in the scope of the 1982 'sedit, such NRC CAT
identified items as undersized welds, out of tolerance
dimensional characteristics, and an inadequate struc- '
turalresolved.
and welding inspection program were not identified
:
.
The
timeselectrical
since 1980.area cf construction was audited caly four j
separation issue as discussed in the ElectricalThe audit i
Construction'Section (Section II) of this report. i
Ineffective
audit. corrective
findings; for example: action has been taken as a resu l'
.
Equipment maintenance was audited in August 1979 (audit
number (TCP-5)).
instructions were not beinAn audit finding. identified that vendor
maintenance instructions. g incorporated into ongoing
startup activities The July, 1981 QA audit of
Surveillance Summary (TUG-5) and the June 1982 Quality
problems with ensuring that manufacturers requireme
and qualification report requirements ,
parated into the maintenance program. had been incor-
An October 1982
qualification reports were not reviewed during
.
!
process of establishing maintenance requirements. The
.
VIII-4
4
,____ - -
.. - .
"
. .
I
l
_
-
problem was identified in 1979, and it has not been
.
resolved as eviderced by the 1982 audit. Thus, the '
- effectiveness of the corrective action system for audits
is not effective.. !
'
)
The NRC CAT inspector's co'nclusion is that weaknesses
exist in the established audit program. These weaknesses
include the scheduling and frequency of audits, the lack of
effective construction program monitoring., and in lack of
effective resolution of some audit findings,
c. 0A Procram Interfaces
The NRC CAT inspector reviewed the QA organizations' overview of
documents that prescribe actions taken by engineering, construc-
tion, and quality assurance personnel. A planned and systematic
program is in place with cea aspect being procedure review.
i
Interviews and document reviews revealed that:
(1) The QA/QC manager or a senior representative reviews all
inspection procedures.
(2) The QA/QC manager er a senior representative reviews con-
struction control procedures to ensure the prope construc-
tion-inspection interface exists.
, ! (3) Engineering control procedures are not reviewed by the QA/QC
manager or a representative of the QA organization. .
'
.
The lack of proper interface with engineering may have contri-
buted
repo rt.
to the issues discussed in Sections II, III, and IX of this
These issues relate to the final engineering design and
the final inspection reports not being reflected in the hardware.
d. Construction Monitorina
A program of co'nstruction monitoring was established. The
program consisted of: monitoring the ASME construction and
installation activities performed by Brown and Root (B&R), and
surveillance of concrete anchor bolt installations.
The monitoring of ASME construction activities consisted of a
systematic eview by two individuals of B&Rs compliance to
approved instructions, procedures and/or drawings that implement
the requirements of the B&R ASME QA manual. The monitoring was
scheduled in advance and providad a review, although less formal
than audit, of onooing ASME work activities. The surveillance of
anchor bolt installation was performed in accordance with .TUGC0
procedure Cp-Qp-11.2 Rev. 4
which indicates that 10
VIII-5
. - . . - . . . - - . . . .
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. M, ar_
4
l'
NUREG-0797
Supplement No.11
l
l
1
i
Safety Evaluation Report '
'
related to the operation of
" Comanche Peak Steam Electric Station,
Units 1 and 2
Docket Nos. 50-445 and 50-446
Texas Utilities Generating Company, et al. !
,
P
,
-
U.S. Nuclear Regulatory __
Commission
-
4, ,
Office of Nuclear Reactor Regulation
1
May 1985
. ,
, j.. =%q
4, % e
a ;
i
!
l
!
a
_ _
i !
, EXRIBIT 27 i
;
I j
1
_ _ _ _ _ _ _ _ _ - - _ _ _ -
-_ -_ _ _-_-_
, .. .
> . .' !
-
p
.
(4)
The method of categorizing irs and NCRs by building did not assure
meaningful trend analysis.
(5)
A '.984 CAR report identified three items that appeared to require
action; however, none had been taken.
(G)
CAR 029 was used as a vehicle for a specific disposition rather than
for generic action, as intended by the CAR system. l
!
The TRT QA.'QC Group also noted that approximately 40 different forms and re-
ports (other than NCRs) were used for recording deficiencies. Many of these
forms and reports did not appear to provide information entry into the Correc-
tive Action System to prevent problem recurrence.
,
In conclusion, the QA/QC Group found deficiencies in NCR implementation; and in
some cases NCR corrective action was unsatisfactory. The QA/QC Group found B&R
and TUSCO's corrective action systems poorly structured, ineffective, and poorly
applied.
'4.6 QC Inspection
The tables in Attachment 1 indicate those items of QC inspection that were con-
sidered to be deficient. Of particular concern were those items fca which QC
inspection was indicated as being primarily responsible and having a generic
impact
are eight level
suchof items
4 (frequent
in theoccurrences
tables. that have plant-wide impact). There
Of lesser concern were the 27 additional
entries that indicated QC inspection as a contributing factor for level 4
items, or as either a primary or contributing fr.ctor for level 3 items (fre-
quent occurrences, but apparently confined to a particular area or item). The
above 35 items indicated to the TRT that QC inspection was particularly deft-
cient in the areas of coatings and mechanical hardware, and that QC inspectors
made significant errors in a number of additional specific items.
inspection problems are generally accompanied by and associated with construc-Further, Q
tion / testing problems (see Section 4.4).
As described in more detail in the individual assessments listed for entries on
the tables in Attachment 1, QC inspectors in many instances failed to follow
design documents and the quality procedures for inspection. Of concern is the
potential for critical installations.to be inadequately constructed and improp-
erly represented on documents in the plant permanent records vault as well as
inaccurate accounting of safety-related systems and structures for input used !
in the stress analyses by the engineering group. In conclusion, the QA/QC
Group considers the site QC inspection program to be less than fully effective ,
j
in monitoring, detecting, and reporting deficiencies that have or could have a
significant safety impact on the plant. i
'
4. 7 Audits and Reportina
i
In the TRT's overall assessment of TUEC's audit program, emphasis was placed on
evaluating the administration of the audit program, management's action to re- !
i
view the status and adequacy of the QA program, and followup on findings iden- I
tified by internal (TVEC) and external audit teams (NRC and consultants). i
l l l ,
Comanche Peak SSER 11 P-31
i
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*-
l
TUEC's audit program consisted of internal and external audits of design, con-
struction, engineering, and procurement activities. TUEC assumed the responsi- ,
'
bility for external audits of vendors.
g Region IV found that TUEC's audit procedures did not comply with NRC require-
ments, and that the program was not implemented in accordance with procedures, ,
i
The lack of an established audit program was also substantiated by Region IV. '
For example, Region IV Report No. 50-445/84-32 cited TUEC for failure to estab-
lish and implement a comprehensive system of planned and periodic audits. Non-
compliances identified were: annual audits were not adequately addressed by
audit implementation procedures; planning and staffing to perform 1983 audits 1
j
were inadequate; the Westinghouse site organization performing Nuclear Steam i
Supply System (NSSS) engineering services was not audited by TUEC from 1977
l
through 1981; and audits of vendors that manufacture or fabricate parts, compo-
nents, and equipment for safety-related systems were not conducted in compli-
ante with annual or other applicable requirements dating back to August 1978.
.
Assessments by the Miscellaneous and Mechanical and Piping Groups concurred
with the QA/QC Group that the audit frequency of vendors did not comply with
ANSI N45.2.12 requirements.
Review of the past administration of the audit program disclosed that during
1981 and 1982, the height of construction, the audit staff consisted of four
auditors. From 1982 to 1984, the audit staff has increased from 4 to 12.
Also, on occasions, individuals participating on the audit teams were not QA
auditors. As such, a potential existed to compromise their independence. The
TRT reviewed the technical background, experience, and training of auditors, as
well as the quality of audit reports. The TRT determined auditor staffing and
qualifications to be questionable, which rendered the audit results for 1981 }
-
through 1983 potentially ineffective.
The TRT and Region IV reviewed the scope of the QA program audited during 1983.
Of approximately 650 safety-related procedures, 165 (25% overall) were audited.
In looking at quality procedures, TUEC audited 24% of TUGCO's implementing pro-
cedures and 39% of B&R procedures for a composite 32% audit rate. Although
audits on a sampling basis are acceptable, there was no evidence that all
safety-related areas were audited. The audits did not encompass all aspects of
the QA program in order to determine effectiveness.
J
' With respect to audit corrective action followup, it was learned that TUEC QA
had not been verifying that corrective action on previous audit findings was
accomplished.
For example, audit TCP-111, initiated to verify corrective ac-
tions on previous audit findings, was started prior to the TRT's review. TUEC
emphasized that TCP-111 be considered a " Punch List of Completion Tasks" to ,
i
verify that corrective action had been implemented and.not an attempt to re-
write or change previous audit findings. Another specific example of ineffecs
tive followup action was found that pertained to a deficiency identified in
audit TCP-23, performed in September 1981. Audit TCP-68, conducted in March
1983, attempted to verify corrective action of TCP-23's audit finding, but logs
that would document the corrective action had been destroyed. A new deficiency
was written at that time and the response was accepted, but the corrective ac-
tion implementation is still unverified.
In correlating nonconformance reporting to the audit finding / corrective action
reporting tracking system, the TRT noted that during 1983, 18 NCRs identified ,
!
Comanche Peak SSER 11 P-32
1
!
.
_
r
a
_a______ _ _ _ _ _ _ _ - - - - - - '
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..
the procedures.
QA need to retrain construction personnel in the contant and requirements of
'The TRT found that TUEC corrective action request CAR-024,
which dealt with inadequate construction training and records, was open for
12 months.
training of construction personnel.After CAR-024 was closed, five other CARS ic'entifi
The TUEC construction, startup/ turnover
surveillance group identified the above conditions in CAR-009, dated April 9,
1984, which had not been closed at the time of the TRT inspection. This fur-
auditsupports
ther findings.the TRT finding of inadequate followup and corrective action of
P'TheTRTfoundthatTUECmanagementhadfailedtoperiodicallyreviewthe -
and adequacy of their QA program. This was confirm.ed by Region IV (IR 50-445/
84-32). TUEC representatives stated that there have been no regular assess-
j ments or reviews of the adequacy of the total QA l'rogram by upper management,
f FSAR.as required in Criterion II of 10 CFR 50, Appendix B, and as commitised in the J
[Withrespecttofo11cwupcorrectiveactionforpreviousfindingscitedagainst
the audit program by NRC and TUEC consultant audit / inspection teams, the TRT
found TUEC's corrective action followup to be not fully effective. The Fred !
g lobbin
findings:Report (a TUEC con:ultant), dated February 1982, identified four major
i.e., comme (1) level of experience within the TUGC0 QA organization is low;
N4 rcial melear plant design and construction QA experience; (2) staff-
i ing for the audit and surveillance functions is inadequate; (3) the number and
y scope of design and construction audits conducted by TUGC0 QA to date has been
g limited; and (4) QA management has not defined clearly the objectives for the
surveillance program resulting in a program which, in the cuthor's opinion "is
presently ineffective."
quately addressed by TUEC.To date, findings (2), (3) and (4) have not been ade-
(Region IV Report No. 50-445/84-32.) i
Fullowing the Lobbin Report, the NRC performed a CAT inspection (IR 445/83-18;
446/83-12, !
gram at thedated Apriloffices.
corporate 11, 1983) and included a review of the TOGC0 audit pro-
The inspection included a review of 18 audits (
(conducted between 1978 and early 1983), auditor qualifications, audit plannin l
and scheduling, audit reporting and followup, and audit program effectiveness.g j
l
The report concluded that weaknesses existed in the established QA audit j
program which included the scheduling and frequency of audits, the lack of
effective monitoring of the construction program, and the lack of effective
resolution of certain audit findings. ]
QA program should have been more effective.The inspection also indicated that the
]
During the TRT's evaluation of allegations and concerns, it was observed that
_the
e audit function did not always identify QA program breakdowns, or if reported, l
~ttective
examples were: corrective action was not instituted to prevent recurfence. Typical
(1) untimely reporting of significant construction deficiencies
for 10 FFR 50.55(e) items, (2) QA breakdown in document control for satellite
!
306 which was not reported to the NRC, and (3) record reviewers ware reviewing '
and accepting documentation for work they previously performed as inspectors. i
Based on its findings ud observations, the TRT concludes that the QA audit and
reporting program has had and continues to exhibit deficiencies.
l
ficant period of time, recurring deficiencies include: inadequateOver a signi-
staffing
during peak periods; failure by management to review the QA program for effec-
tiveness; procedural and implementation inadequacies; questionable qualifica-
Comanche Peak SSER 11 P-33
I u - __ _-
. .: . . .
p .
.
COMANCHE PEAK RESPONGE TEAM
ACTION PLAN
.ISAP Vll.a.4-
l
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l Title:
.
Audit Program and Auditor Qualification
l l
Revision No. 0 1
L,
Description Original Issue ents -
k la
Prepared and
Q
Recommended by:
.
,
-
Review Team Leader [/
O*'*
M 'W 2 If6
_-
APProvad by:
-Senior Review 7,,,
p --
Data
shiler Ag,c -
%:-
EXHIBIT 28 --
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Revision: 1
Page ,5 of 9
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ISAP VII.a.4
(Cont'd)
4.0 CPRTACTIONPihN-
4.1 Scope and Methodology l
.
4.1.1 !
The scope of this action plan is to evaluate the !
adequacy of the TUCCO QA Audit Program from its 1
inception to the present, determine the effect of any
identified inadequacies on the Quality Assurance
-f 1
Program and/or.the physical plant, and to recommend
appropriate correct. ions and/or improvements to the
current program.
This evaluation will be accomplished
th~ rough a review which will address audit planning arid
scheduling,
up and closecut,preparation, performance, reporting, follow
and audit personnel qualification.
4.1.2
The specific methodology is described below.
4.1.2.1
f;
All revisions of the, program and6rscadutaD
!' ge.daining to, the..QA. Audit Proa_ ram _ Jhat,,,have
been in effect at CPSES(will be evaluated. t *
identify commitmeni;g.abhe dearee to wnic,n
the written program conformed to these
>
commitments. Include,d in this evaluatien
will be the CPSES PSAR/PSAR (Appendices 1A(N)
~
and 1A(B), Chapter 17.1, and QA branch
questions and answers); TUCCO Qgrporate
Quality Assurance Program; CPSES Project
.
Quality Assurance Plan (Design and
Construction); Dallas Quality Procedures /
Instructions manual.
<
4.1.2.2 Eeports, documentation nand. data. generated $
I
during the implementation..oL_,the pregum,will
be reviewed on a selectivt basis ta,evaluatt
the effectiveness
selection of.1
of specific @ ementation
items to be The '
will be based on concernbifed@reviewedd'by the
NRC; significant revisions,_ t;o commitments,
program description, and/or organization; and
to pursue questionable areas identified
r during the review. Specific., topics to be
. addressed include,the following:
$ Audit Planning Criteria
l
Published and As-run Schedules
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Revision: 1
Page , 6 of 9 1
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ISAP VII.a.4
(Cont'd)
4.0
CPRT ACTION PLAN (Cont 'd) i
'
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Audit Plans and CheelAfata
,
t
*
.
' Audit Reports
'
Audit Deficiency Follow up
.
sy ')
Audit Team Hembers Including Qualifications
and Staffing Levels,
Organizations Performing Audit Activities
a
Application of Audit Activities to Hardware
vs Program / Procedures
The object of this
conclusion cor::erningaluation is to_ develop a
he adsLquacy of gre
assessmertlprovided by e e Audit Program.yram
This info ~rination.will be used as ang.fot.
recommendations, for revision of the current
program, as appropriate.
4.1.2.3 Should audit program deficiencies or
',. y
pg j -l weaknesses related to construction activities
p p '. , be identified, they will be_ evaluated,to
determine whether action beyond-that
s,,.
spe,cified in ISAP VII.c is. required to ,
;
identify potential areas of concern regarding
construction quality. Should such actiens be
-
l
required,adetailedplanvil'1,bedeveljpe'd'~
and this ISAP revised to describe the
methodology. In addition, (bou.14 any j
identified audit program (gfAgfengieA.jppJy
also to off-site TUGCO inppliers, aJrogram
will be developed to determine _ths !
acceptability of the supp11eral,gual.Aty
assurance programs for the applicable
equipment and services during the period in
question.
This program, if required, will
utilize external sources of information such
as other utility or architect-engineer '
audits, the Coordinated Agency for Supplier
Evaluation, and the NRC " White Book". If -
suppliers are identified for which the' ~~ i
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Revision: 1
Page 7 of 9
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ISAP VII.a.4
(Cont'd)
4.0 CPRT ACTION PLAN (Cont'd)
adequacy of the QA program _pspppt be
. determined, a deta12 3d plan vill be ' develop'ed
to yesolve the eonie M n3~i[[s n j.IS W j~ev3 sed
to describe the methodology.
4.1.2.4 The current audit program, including auditor I
r> qualif1 cation requirement.s,_ vill btte.yaluAte.d
against licensing commitments contained in
the FSAP.
.
L
/- A determination vill.be made concernit6 the i
adequacy of the TUGC0 vritten program and the
qualifications of the audit staff and I
staffing levels for the remaining . j
construction phase of Unit 2 And for the
operations phase.
. 1.2.5 The. Result.s_ Report vill provido
recommendations f or correrteTis action and/or l
:
program improvements as appropriate.
~
'
4.1.2.6 Copies of *.he Results Report for this ISAP '
v111 be provided to TUGC0 for their
consideration in responding to the NRC Notice
of Violation (445/8432-03; 446/8411-03).
4.2 Participant's Roles and Responsibilities
4.2.1 TUCCO
4.2.1.1 Scope
TUCCO vill assist in identifying and locating
applicable information and documentation to
support the Review Team activities.
4.2.1.2 Personnel
Mr. D. McAfee, Dallas QA Manager, vill ensure
effective coordination between the Review
Team and TUCCO.
l
,
___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - - - - - - - - - - - - ' - - - - - ~ ' ^ ^ ~ ~^
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Rwision: 1
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ISAP VII.a,4 '
',
(Cont'd)
I
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4.0
..
CPRT ACTION $'LAN . (Cont 'd) *
l > r i
4.2.2 ERC '
/
f
4.2.2.1' Scope ,
1
ERC vill be responsible for reviewing-
applicable TUGC0 documentation to determine
4
the adequacy of the program.
4.2.2.2 Personnel '
', / ,t
Mr. J. Hante3 Review Team I.eader /
Hr. J. Celter ' Issue Coordinator l R
,
4.3 _ Qualifications of Personnel '
l
4.3.1
Participants will be qualified to the requirements of
the CPSES Quality Assurance Program gr '
requirements of the CPRT Program Plau.,to the specific
4.4 Procedures '
Program Plan and Issue-Specific Action Plans.
-
4.5 Standards / Acceptance Criteria ,
4
j
Audit activities shall be in ceu:pliancla with 10CFR50, Appendix
B, Critarion XVIII and the applicable codes and standards
relating to CPSES FSAR paragraph 17.1.18.
activities are receptable if: f
Specifically such-
4.5.1
Audits to assure that procedures and activities comply
with the overall QA program are perforr.ed by:
4.5.1.1 The-QA organization to provide a
comprehensive independent verification and ,
evaluation of quality-related procedures and
activities. i
4.5.1.2
The applicant to verify and evaluate the QA
programs, proceduras, a,nd activit.tes of
suppliers. '
'
,
4.5.2 ,
A'n audit plan is prepared idt.ntiiying audits to lie
'
performed, their, frequencies, and schedules. Audits ;
'
e'.cald be regularly scheduled based upon the status and
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.n a
_ _ _ _ _ - . - _ - . _ _ - - - _ - - - - - - - - - - - - - - - -
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1 Revision: 1
3 Page 9 of 9
' .
ISAP VII.a.4
..,,
(Cont'd)
*
,
4. 0 I CPRT ACTION PLAN (Cont'd)'
d . safety importen e of the activities being performed and
are initiated early enough to assure effective QA
duriag design, procurement, manufacturing,
, a
construction installation, inspection, and testing. ~
/
4.5' 3 ' Audits include an objective evaluation of quality-
.
related practices procedures, instructions; activities
and items; and review of documents and records to
( ' ensure that the QA program is effective and properly
, implemented.
4.5.4' Provisions are established requiring that audits be
yerformed in all areas where the requirements of
Appendix B to 10CFR Part 50 are applicable. Areas
which are often neglected but should be included are
l Letivities associated with:
4.5.4.1 Indoctrination and training p.rograms.
4.5.4.2 Interface control ancng the applicant and the I
principal contractors.
1-
4.5.4.3 Corrective action, celebration, and non-
conf omance control systems. ,
I
4.5.4.4 SAR commitments.
4.5.5 i.
Audit data are analyzed and the resulting reports
indicating any quality problems and the effectiveness
of t,he QA program, including the need for reaudit of
deficient areas, are reported to management for review
and assessment.
4.5.6 l
, Audits are performed in accordance with pre-established
written procedures or checklists and conducted by
trained personnel having no direct responsibilities in
the areas being audited.
4.6 Decision Criteria
,. ,
Decisions concerning the number of individual reports.
records files, etc., to be reviewed, and the level of detail
to which they will be reviewed, will be detet1nined by the
quantity
ISAP proceeds. and quality of data obtained as implementation of the
l
This item will be
been evaluated considered
to support a firm closed when
conclusion as tosufficient the data has
l acceptability
contained of the program
in Paragraph 4.5. against the acceptance criteria
_- ._
_ _ - _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
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COMANCHE PEAK RESPONSE TEAM I
RESULTS REPORT
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ISAP: VII.a.4
Title: Audit Program and Auditor Qualification .
REVISION 1 #
)
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Yft1 fS - l
I Coordinator / Date
f ,
!
Revi
a.
Team Leader'
/7
Date/ /
oL
i
John . Beck, Chairman CPRT-SRT Date
+/n/rc.
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EXHIBIT 29
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Revision: 1
Pags 1 of 53
;
RESULTS REPORT
ISAP VII.a.4
Audit Program and Auditor Qualification
1
1.0 DESCRIPTION OF ISSUE
The Comanche Peak SSER 11 Appendix P, Section 4.7, pages P-31
through P-34, describes the NRC concerns in the areas of Quality l
Assurance auditing and audit reporting. The concerns pertaining to
the audit program and audit personnel qualification have been ]
1
extracted and are presented here
" Region IV found that TUEC's audit procedures did not comply
with NRC requirements, and that the program was not
implemented in accordance with procedures. The lack of an
established audit program was also substantiated by Region IV.
For example, Region IV Report No. 50-445/84-32 cited TUEC for
failure to establish and implement a comprehensive system of"
planned and periodic audits. Non-compliances identified were:
annual audits were not adequately addressed by audit.
implementation procedures; planning and staffing tc perform
1983 audits were inadequate; the Westinghouse site
organization performing Nuclear Steam Supply System (NSSS)
engineering services was not audited by TUEC from 1977 through
1981; and audits of vendors that manufacture or fabricate
parts, components, and equipment for safety-related systems
were not conducted in compliance with annual or other
applicable requirements dating back to August 1978.
Assessments by the Miscellaneous and Mechanical and Piping
c3 Groups concurred with the QA/QC Group that the audit frequency,
of vendors did not comply with ANSI N45.2.12 requirements.
~
Revi'ev of past administration of the audit program disclosed
that during 1981 and 1982, the height of construction, the
audit staff consisted of four auditors. From 1982 to 1984,
the audit staff has increased from 4 to 12. Also, on
occasions, individuals participating on the audit teams were
not QA auditors. As such, a potential existed to compromise
their independence. The TRT reviewed the technical
background, experience, and training of auditors, as well as
the quality of audit reports. The TRT determined auditor
g3 ataffing and qualificatiqps to be _cutstionable, which rendered
the audit results for 1981 through 1983 potentially
ineffective.
The TRT and Region IV reviewed the(scope of the QA Program
audited during 1983. Of approximately 650 safety-related
procedures, 165 (25% overall) were audited. In looking at 4
,
quality procedures, TUEC audited 24% of TUGCO's implementing {
procedures and 39% of Brown & Root procedures for a composite
32% audit rate. Although audits on a sampling basis are
)
_ _ _ _ _ _ .
_ _ _ - . _ _ _ . _ _ - - ----- _ _ . - _ .
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- Rsvision: 1
Pass 2 of 53
RESULTS REP 0hT
ISAP VII.a.4 I
(Cont'd) l
1.0 DESCRIPTION OF ISSUE (Cont'd)
acceptable, there was no evidence that all safety-related
e areas were audited. The, audits did not encompass _all aspect,s
of the QA Program in order to determine effectiv,sness.
, With respect to audit .gorrective
o action follow-up, it was
learned that TUEC QA had nbc been verifying that corrective
action on previous audit findings was accorplish44. For
example, audit TCP-111, initiated to verify corrective actions
on previous audit findings, was started prior to the TRT's
review. TUEC emphasized that TCP-111 be considered a " Punch
List of Completion Tasks" to verify that corrective action had
been implemented and not an attempt to rewrite or change
previous audit findings. Another specific axample of -
;
ineffective follow-up action was found that pertained to a j
deficiency identified in audit TCP-23, performed in September, t
1981. Audit TCP-68, conducted in March, 1983, attempted to I
verify corrective action of TCP-23's audit finding, but logs
that would document the corrective action had been destroyed.
A new deficiency was written at that time and the response was
accepted, but the corrective action implementation is still
unverified.
Following the Lobbin Report, the NRC performed a CAT
inspection (IR 445/83-18;446/83-12, dated April 11, 1983) and
included a review of the TUGCO audit program at the corporate
offices. The inspection included a review of 18 audits
(conducted between 1978 and early 1983), auditor
qualifications, audit planning and scheduling, audit reporting
and follow-up, and audit program effectiveness. The report
concluded that weaknesses existed in the established QA audit
program which included the scheduling and frequency of audits,
e the.larl of effectiv_e m itoring of the construction program,
and the lack of effective resolution of certain audit
findings. The inspection also indicated that the QA Program
should have been more effective.
During the TRT's evaluation of allegations and concerns, it
was observed that the audit function did not always identify
QA Program breakdowns, or if reported, effective corrective
action was not instituted to prevent recurrence . . .
Based on its findings and observations, the TRT concludes that
the QA audit . . . progran has had and continues to exhibit
deficiencies. Over a significant period of time, recurring i
deficiencies include: inadequate staffing during peak periods;
. .
. procedural and implementation inadequacies; questionable
J
,
_ _ - _ _ _ _ - _ _
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Revisien: 1 1
Page 3 of 53
l
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RESULTS REPORT
ISAP VII.a.4
(Cont'd)
,
1.0 DESCRIPTiONOFISSUE(Cont'd)
qualifications and capabilities; incomplete assessment of the
QA Program on an annual basis; . . . In summation, the QA/QC
Group finds the past audit . . . system less than adequate,
and the audit . . . program at the time of the TRT review was
questionable."
2.0 ACTION IDENTIFIED I
'
-
Evaluate the TRT findings and qqngider the implications & j
+ these
h findings _on_qonst_ruction quality. "... examination of the
potential ~ safety implications shou 1T include, but not be l
l
limited to the areas or activities selected by the TRT." *
;
l
;- _" Address the root cause of each finding and its generic
-
implications..."
>- " Address the coll _ective significance of these deficiencies..."
;-- "_ Propose __an_ action plan...
do not occur in the future.,that will ensure that such problems
3.0 BACKGROUND
In addition to the TRT issue and SSER 11, the NRC issued the
following notice of, violation (445/.8M 2-03; 446/8411-03) on
j February 15, 1985: '
" Contrary to requirements, the following examples were identified
which demonstrate the failure to establish and implement a
comprehensive system of planned and periodic audits of safety-
Yrelatedactivitiesasrequired,asnotedbelow:
-
Annual audits were not adequately addressed by the audit
implementation procedures.
-
TUCCO Procedure DQP-CS-4, Revision 0, dated August 9,
1978, only required two audits of vendors fabricating
reactor coolant pressure boundary components, parts,
and equipment; one audit of vendors fabricating
,
engineered safeguards components, parts, and equipment;
and audits of balance of plant (safety-related) as
required by the quality assurance manager.
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- _ _
Revision: 1
Pego 4 of 53
RESULTS REPORT l
ISAP VII.a.4
(Cont'd)
.
3.0 BACKGROUND (Cont'd)
--
TUGC0 Procedure DQP-CS-4, Revision 2, dated April 16,
1981, required only that organizations will be audited
on a regularly scheduled basis.
--
TUGC0 Procedure DQP'-CS-4, Revisions 2 and 10. did not
specify auditing fr'equencies for design, procurement,
construction, and operations activities.
--
TUGC0 Procedure DQP'-CS-4, Revision 10, based audit
requirements on Regulatory Guide 1.33. Revision 2,
February, 1978. This commitment did not fully address
the requirements of the Construction Quality Assurance
Program.
The above procedure and subsequent revisions failed to
describe and require annual audits in accordance with
commitments and requirements. Earlier audit procedures were
not available to determine if they met requirements.
-
Planning and staffing to perform 1983 audits was inadequate to
assure that a comprehensive system of audits was established
and implemented to verify compliance with all aspects of the
Quality Assurance Program, in that, of 656 safety-related
procedures (which control safety-related activities) the NRC
review revealed that the applicant sampled only 165, or 25
percent, during the 1983 audit program. Consequently,
significant aspects of the safety-re3ated activities were not
adequately audited.
-
The Westinghouse site organization, established in 1977 to
perform Nuclear Steam System Supply (NSSS) engineering
services, was not audited by TUGC0 during the years of 1977,
1978, 1979, 1980, and 1981.
-
Audits of vendors that manufacture or fabricate parts,
components, and equipment for reactor coolant presrure
boundary and engineered safeguards systems have not been
conducted annually dating back to August 9, 1978."
v ..u
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Rsvision: 1
Page 5 of 53
RESULTS REPORT
ISAP VII.a.4
(Cont'd)
4.0 CPRT ACTION PLAN
4.1 Scope and Methodology
4.1.1 The scope of this action plan was to evaluate the
adequacy of the TUGC0 QA Audit Program from its !
inception to the present, determine the effect of any
identified inadequacies on the Quality Assurance
Program and/or the physical plant and to recommend
appropriate corrections and/or improvements to the )
3
current program. This evaluation was accomplished
through a review which addressed audit planning and i
scheduling, preparation, performance, reporting, j
follow-up and closeout and audit personnel i
qualification. *
4.1.2 The specific methodology is described below.
i"
.
4.1.2.1 (Iira'ifabTp revisions of the,gregra;n and
y ,procedurg.eJertaining to the QA Audit Program
for CPSES were reviewed to identify licensing
commitments and the degree of conformance to
these commitments in the written program.
Included in this review were the CPSES
PSAR/FSAR (Appendixes 1A(N) and 1A(b),
Chapter 17.1, and QA Branch questions and
answers), TUGC0 Corporate Quality Assurance
Program, CPSES Project Quality Assurance Plan
, (Design and Construction) and Dallas Quality
Procedures / Instructions Manun1.
' N 4.1.2.2 Papnve=: Amen-e= Hen and data generated
during the implementation of the QA audit
program were selected for review on the basis
of concerns identified by the NRC;
significant revisions to commitments, program
description and/or organization; and to
pursue questionable areas identified during
the review. Specific topics addressed
include the following:
!
Audit Planning Criteria,
Published and As-run Schedules,
Audit Plans and Checklists.
'
([ -
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Rsvision: 1 !
Pego 6 of 53 l
1-
RESULTS REPORT
ISAP VII.a.4 l
(Cont'd) l
l
4.0 CPRT ACTION PLAN (Cont'd)
Audit Reports,
Audit Deficiency Follow-up,
Audit Team Members, Including
Qualifications and Staffing Levels,
Organizations Performing Audit Activities
and *
Application of Audit Activities to Hardware
vs. Program / Procedures, )i
From this evaluation, conclusions were drawn j
l
concerning the adequacy of program assessment
provided by the sudit program. This l
l
information was used as input for the !
recommendations for revisions to the current
program.
4.1.2.3 Should audit program deficiencies or
weaknesses related to construction activities
be identified, they will be evaluated to
determine whether action beyond_ that
ap_cgifi.
e d Tn ISAP VII.c is required to
~
%identifypotentialareasofconcernregarding
,/ construction quality. Should such actions be
'. required, a detailed plan will be developed
and this ISAP revised to describe the
-
methodology.f (This conditional step was 3
etermined~to be not required and therefore
was not performed. Se_eSection6.0forj
discussion.) In addition, shoule any ,
*
identifie~ audit program deficiencies apply
also to off-site TUGC0 suppliers, a_pysgram
will be developed to datarmfaa the l
[Eceptabil E f the anpplissal quality i
1
assurance programs for the applicable
equipment and services during the period in ;
question. This program, if required, will
utilize external sources of information such
as other utility or architect-engineer
audits, the Coordinated Agency for Supplier
Evaluation and the NRC " White Book." If
suppliers are identified for which the
. . .. . ..
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Esvision: 1
Page 7 of 53
RESULTS REPORT
ISAP VII.a.4
) (Cont'd) ,
4.0 CPRT ACTION PLAN (Cont'd)
adequacy of the QA program cannot be
determined, 4_ detailed plan vill be develote,d t
to resolve the concern and this ISAP revised !
I~4to describe the methodology. ,
[This conditional step was determined to be'"'
not required and therefore was not
erformed. See Section 6.0 for discussion.)
__
4.1.2.4 The .gterent audit erogram. including gudit.or
y quali,icat.fon requirements, was evaluated
against licensing commitments contained in l
the FSAR. *
{
The qualifications of the current audit staff
were evaluated. A determination was made
concerning the adequacy of the TUGC0 vritten
program and the qualifications of the audit
staff for the remaining construction phase of
Unit 2 and for the operations phase.
4.1.2.5 QA/QC Program deviations were identified for
NN
correction land suggested program improvement _p
~
are presented.
4.1.2.6 Copies of the results report for this ISAP
will be provided to TUCCO for thei_r
.c.pnsideration in responrHng_en the NWf' Notice
.of Violation. (445'/842L-034_446/S411=03) ,
.:
4.2 Participants Roles and Responsibilities
4.2.1 TUGC0
4.2.1.1 Scope
TUGC0 assisted in identifying and locating
applicable information and documentation to
support the Review Team activities.
4.2.1.2 ' Personnel '
Mr. D. McAfee, Dallas QA Manager, provided
coordination between the Review Team and
TUCCO QA staff personnel.
.,
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Revision: 1
Page 8 of 53
:
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RESULTS REPORT
] ISAP VII.a.4
(Cont'd)
4.0 CPRT ACTION PLAN (Cont'd)
4.2.2 ERC
4.2.2.1 Scope
ERC was responsible for reviewing applicable
TUGC0 documentation to determine the adequacy i
of the program.
4.2.2.2 Personnel
Mr. J. Hansel Review Team Leader
Mr. J. Gelzer Issue Coordinator *
4.3 Qualifications of Personnel
Participants were qualified to the specific requirements of
the CPRT Program Plan.
4.4 Standards / Acceptance Criteria
Audit activities shall be in compliance with 10CFR50,
Appendix B, Criterion XVIII and the applicable codes and
standards relating to the CPSES PSAR/FSAR sections pertaining
to the QA audit program as interpreted in Section 7.1 of the
NRC Standard Review Plan (NUREG 0800). Specifically such
, activities are in compliance if (quoting from NUREG 0800):
-
o" Audits to assure that procedures and activities comply
with the overall QA program g ee performed by:
y
--
The QA_ organization to provide a
L
'
*
comprehensive 4M enendent verification and
-
N M s.' 0 - 1 W. - evaluation of quality-related procedures and
activities.
--
The applicant to verify and evaluate the QA l
'
programs, procedures, and activities of
suppliers. i
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-
An audit plan is prepared identifying audits to be
gerformed, th'eir fraq Q s, and schedules. Audits
-
should be regularly scheduled based upon tihe status and ,
'
safety importance of the activities being performed and
are initiated early enough to assure effective QA
during design, procurement, manufacturing,
construction, installation, inspection, and testing.
_ _ _ . _ - - _ -- - - - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
F
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-#; Ravision: 1
Page 9 of 53
RESULTS REPORT
l
l
ISAP VII.a.4 '
(Cont'd)
4.0 CPRT ACTION PLAN (Cont'd)
e
-
Audits include an Q G h evalus h of quality-
related practices, procedures, instructions; activities
and items; and review of documents and records to
(
ensure that the QA program is effective end properly
implemented. )
.
-
Provisions are g established requiring that audits be
g performed in.g1})arbsg where the requirements of ' I
Appendix B to 10CTR Part 50 are applicable. Areas
which are often neglected but should be included are
activities associated with:
--
Indoctrination and training programs. '
--
Interface control among the applicant and the
principal contractors.
--
Corrective action, calibration, and non-
conformance control systems.
1
--
SAR commitments,
i
-
33 Audit data are_.analyted and the resulting repongs I
-
indicating any quality problems and the effectiveness
of the QA program, including the need for repudit of
deficient areas, are reported-ta --nagtEAn; ter reviev ;
,
and asseasment.
i
-
e Audits are performed in accordance with pre-established
written procedures or t hecklists,and conducted by
tIAined personnel having no direct responsibilities in
the areas being audited."
4.5 Decision Criteria
Decisions concerning the number of individual reports,
records and files to be reviewed, and the level of detail to ,
!
which they were reviewed, were based on,the quantity and
quality of data obtained as implementation of the ISAP
proceeded. Sufficient data were evaluated to suonore the ,
'
concl1.is_ione reached ~ac to the 4EAmptability i the Drear _am
agains,t, the acceptanc,e_ criteria contained _ inJragraph_4.4.,
,
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Revision: 1
Page 10 at $3
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RESULTS REPORT -
!
ISAP VII.a.4
(Cont'd)
5.0
IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESU
The TUGC0
inception QA Audit Program adequacy was evaluated from its
to the_presert.
and the February 15, 1983 The specific TRT findings in the SSER 11
this section. Notice of Violation are eddressed in
The implementation of this action plan was accomplished in two
phases:
Qualificat.1_on (Section 5.2).6.udit Program.(Section 5.1) and M t Personn
These sections are~sub-divided as
follows to address the various elements of the Audit Program and
the Audit Personnel Qualification Program: r
-
Section 5.1 Audit Program :
.
.
5.1.1 Organization ,
5.1.2 Staffing s
5.1.3 Audit Planning and Schedulin h,
5.1.4 ic d () Q t-o f2.2 r-
A6ditPreparation(
.
i
5.1.5 Audit Performance
5.1.6 Audit Reporting
C.A ( e
5.1.7 AFollow-up and Closecut M
,e
-
Section 5.2
Audit Personnel Qualification :
5.2.1 Qualification Requirements '
5.2.2 Training / Qualification Records ',
Implementation consisted of a review of program definition and
implementation documents, a review of records and other related ., i
documents and interviews with personnel involved in the program h .
g,
The historical PSAR/FSAR was reviewed to identify the standards and
audit program and qualification of nudit personnel. regulato
determined that This review
\
p- The basis for the audit program from December 1973 (Amendment t
.
#2 of3.._Revimien
(Draft the PSAR) G. through
May the present is ANSI N45.2.19-19]J !
on Quality Assurance Requirements During Design and2 1973) as i
1
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\qj ) **%
.. ,
_ _ - _ _ ----- L
W[
*
7 Rsvicion: 1
Pass 11 of 53
RESULTS REPORT
ISAP VII.a.4 l
(Cont'd) !
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Procurement Phase of Nuclear Power Plants" (Gray Book), dated
June 7, 1973, and as amplified by the " Regulatory Staff )
'
Comments and Supplementary Guidance on N45.2 Standards"
contained in Section D.2.b of the Gray Book.
.
The only exception to this commitment is that since August j
i 1984 (Amendment f52 of the FSAR) TUGCO elected to adopt, as an i
alternative for scheduling external audits, the guidance
provided by Regulatory Guide 1.144, Revision 1 September l
1980, Paragraph C.3(b). i
-lThebasisforauditpersonnelqualificationswasANSI
g -N45.2.12-1973 until June 1, 1983, which was the effective date
. .of TUGC0 commitment to Regulatory Guide 1.146, August 1980,
jvhich endorses ANSI N45.2.23-1978.
The documents and record files reviewed included the following:
- CPSES PSAR
#
- CPSES FSAR, p h
*
-
TUGC0 Corporate Quality essurance Program, -
P
- -
CPSES Project Quality Assurance f Plan for Design and
, Construction.
G y _
Dallas Quality Procedures / Instructions Manual,
~
-
Audit Rt. port Files,
- Audit Report Notes Files,
- Equipment Release Files (Vendor Compliance Release
Inspections),
- Vendor Correspondence Files,
-
Vendor Reevaluation Files.
-
Vendor Performance Evaluation Files and
- Audit Personnel Training / Qualification Files.
UcA .t Q k
%/cMl fl3 W y da
_.
____ . . .
__.
_ _ _ - - - - _ _ - - _ _ _ _ - _ - - - - - - - - - - - - - -
:\
Esvision: 1
Pasa 12 of 53
RESULTS REPORT
ISAP VII.a.4
(Cont'd)
1
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Findings pertinent to each topic w1il be discussed within the
appropriate sub-section. At the and of each sub-section a
% statement regarding possible adme effects of the findings on the
auditprogramwillbemade.j5hereisnodirectconnectionbetween
p fheauditprogramandthequalityofinstalledhardware;therefore,
no conclusions regarding the st'atus of the physical plant have been/
'*" "' A
,
L,? -)
f
N Recommended corrective action for QA/QC Program Deviations
identified in the body of this report are summarized in section j
f 5.3, " Evaluation of Findings". !
5.1 Audit Program *
Documents and files were reviewed to evaluate the adequacy and
effectiveness of the TUGC0 audit program including
organization, staffing, planning and scheduling, preparation,
performance, reporting and deficiency follow-up and closecut.
Initially. 69 audit files were reviewed to assist in reaching
( a conclusion pertaining to the performance of the TUGCO QA
3
audit personnel. Internal audits were selected to provide
N '
da fra= *ka 4ncepedan af the nroer== to the cresent, as well
i
I
as a sampling of the various disciplines and major topics of j
interest such as document control and l
nonconformance/ corrective action systems. Vendor audits were I
selected primarily to review TUGC0 activities pertaining to
prime contractors (B&R, ]{, G&ll) as well as on-site
contractors. This review was not intanded to be a
comprehensive evaluation of the scope, content, conclusions,
etc., of the audit; rather, it was intended ec, determine if
the required steps in the audit process had been properly
performed. The review addressed the following items:
-
Audit Preparation - To determine if the audit scope was
documented, if an audit team leader had been
designated, if checklists had been prepared and if they
appeared to contain an appropriate level of detail.
-
Audit Performance - To identify the audit team, to
determine if pre-audit and post-audit conferences were
conducted, if it appeared that objective evidence had
been examined and if audit personnel appeared to
evaluate program elements to some depth.
_ _ - _ - - -
- - - _ _ - - - _ - _ _ _ _ - _ _ _ _ _ _ _
, . .,... . - - . .. - . . . - . . - ~ . . .
Rsvision: 1 ;
Pegs 13 of 53
!
RESULTS REPORT
ISAP VII.a.4 '
.
(Cont'd) I
i
!
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l
-
Audit Reporting - To determine if audit reports had )
been prepared that veuld provide appropriate management 1
with sufficient information concerning the adequacy and I
effectiveness of the audited QA program elements. '
-
Audit Deficiency Follow-up and Closecut - To determine
if responses to audit deficiencies were evaluated, if
p ~__
an, acceptable course and schedule for corrective action
a had bien agreed on knd if implementation of corrective
-_sction was verified. # .
---------..-... .. ,
/ Y
. , - Later, as the result oF i
Team Issue Coordinators, u gn u ic edfromoth)erQA/QCReview
7 nin (9 audit files' vere reviewed in
depth in an attempt to reach
,
onely ton'as to why particular
'
,
programmatic problem areas (e.g., non-conformance control and
corrective action systems, inspector training, qualification,
and certification programs), which were identified by External l
Sources had not been identified and corrected through
implementation of the TUGCO QA audit program. The review of
these nine (9) files included a re-review of four (4) o f __t h,e
_
sixty-nine (69) previously revieiTed and were selected on the ;
basis of their titles ~Tn the audit intfex as being the total j
available that addressed these subjects. This review included
'
the following activities
.
-
A detailed review of the audit checklist for content
,
and to attempt to determine if the checklist was 3
l
developed from requirements documents or from the I
existing written program, '
-
A review of auditor field notes to attempt to determine
the depth of examination, sample size (when
applicable), type of objective evidence evaluated,
whether program documents were evaluated against
requirements, and if apparent deviations had been
flagged to be included in the audit report.
-
A review of the audit report to determine if the
findings documented in the auditor field notes were
accurately reflected in the report and
-
A review of documentation subsequent to the audit
report in an attempt to determine the adequacy of
auditor evaluation of responses to audit deficiencies, !
dialogue leading to sgreement on proposed corrective I
action and verification of completion of corrective l
action.
!
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Revision: 1
Page 14 of 53
i
RESULTS REPORT
ISAP VII.a.4
(Cont'd)
5.0 IMPLEMENTATION OF N, TION PLAN AND DISCUSSION OF RESULTS (Cont'd)
i
In response to the NRC Notice of Violation (445/8432; {
446/8411), the audit files representing the 29 internal audits
' of the design / construction phase performed during 1983 were L
reviewed to identify the major activities, organizations, and
y C{ Appendix B criteria which were addressed, to enable an
evaluation of the audit program coverage for the year. These
p 19 files included div;eJwhich had been previously reviewed. !
i
b The Design Adequacy Review Team provided a list of design-
g C-{~
Du
specifications which they plan to evaluate for design adequacy
and Architect-Engineer / Vendor interface. From the vendors
identified, twelve were selected for this review based on
considerations such as frequency of audits performed. *
awareness of problems with a particular vendor, apparent time
frame of vendor activity and type of product. Additional
rationale for selection is contained in the working files for
this ISAP.
A review was performed of TUGC0 QA Audit and Vendor Ccapliance
files (audit reports, audit notes, equipment releases, vendor
correspondence, vender performance evaluation and vendor !
reevaluation files) for chese twelve vendors to evaluate the
degree of awareness by TUGC0 QA of the adequacy,
effectiveness and status of the QA programs of their vendors ;
despite the fact that annual vendor audits were not scheduled.
_
The results of these reviews are summarized in the following
paragraphs.
5.1.1 Organization
ANSI N45.2.12-1973, Section 1.4, " Organization", J
states, "The organizational structure, functional i
responsibilities, levels of authority, and lines of
internal and external communication for management
direction of audits of the quality assurance program
shall be documented".
Although Section 17.1.18 (Audits) of the CPSES FSAR
states that TUGC0 will perform audits, nowhere in
Section 17.1.1 (Organization) is the responsibility for
the audit program delineated.
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}L. Ot.1...c.h GL.AQ_ Gv %g ,
'1El.h. (.{. k , , '
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - -
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Revision: 1 l
Page 15 of $3 l
RESULTS REPORT
ISAP VII.a.4 1
l
(Cont'd)
.
,
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)'
I
Within section 17.1.1.1, the list of principal duties
-
and responsibilities of the Director, Quality Assurance
includes " monitoring and surveillance of the quality
,
assurance activities conducted by TUGCO, prime
.
contractors, sub-contractors and vendors." However -
there is no specific mention (nor has there bet.n since
the original docketing of the PSAR) of responsibility
for the audit program. ;
During the review of the QA program and records, it was
determined that the QA organization was in fact
responsible for th6 audit program and that TUCCO
management recognized and supported this *
4
responsibility.
It was noted that on December 30, 1985 TUGC0 QA ]
initiated a reque,st for an FSAR revision to include the '
audit program among the principal duties and
responsibilities of the Director Quality Assurance.
The TUGC0 QA Audit Program is administered and 4
implemented by the Dallas-based Quality Assurance f
organization. The implementing procedures for the j
audit program are contained in the Dallas Quality i
Procedures / Instructions Manual. Since 1982, procedures
in this manual have assigned responsibilities for
execution of portions of the QA audit program to the l
position of Supervisor, QA Audits. This position was '
not officially recognized in published organizational
descriptions and organization charts until the issue of
procedure DQP-QA-16, " Dallas Quality Assurance
Organization" in September 1985. During the review of
the audit program procedures and records, it was
determined that the position was filled during this
period and was recognized and supported by QA
management. l
Although ANSI N45.2.12-1973 and the accompanying staff I
comments and guidance pertain primarily to the auditing
( organization, the requirements of the ANSI standard and
the associated supplementary guidance listed below
apply as well to the audited organization as an
1
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Page 16 of 53
RESULTS REPORT
ISAP VII.a.4
(Cont'd)
l
I
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
, integral part of the overall audit program. Therefore,
these requirements should be included in QA program 1
documents applicable to the audited organization as
.
well as the auditing organization (e.g., Corporate QA
Program, Project QA Plan) to ensure compliance by all
responsible organizations. !
--
An effective audit system shall include
provisions for reasonable and timely access
of audit personnel to facilities, documents,
and personnel necessary in the planning and
performance of the audits.
.
-
At the post audit conference an effort shall
be made to establish a tentative course and
schedule of corrective action for non-
conformances. Where it is not possible to
provide such information at the post audit
conference, the managsment of the audited
organization should commit to a specific date
for the determination of the course of
corrective action and the schedule for !
implementation. '
-
Management of the audited organization or
activity shall review and investigate the
audit ~ findings to determine and schedule
appropriate corrective action. They shall
respond to the report in writing, within 30
days after receipt.
The review of these files indicated that these *
requirements had been met in that:
-
There was no evidence to indicate that audit
personnel had been denied reasonable an!
timely access as required to perform their
duties.
-
There was no evidence to indicate that
problems had been encountered pertaining to {
the establishment of the tantative course and
schedule of corrective actions and schedule
for implementation.
)
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Paga 17 of 53
l
)
RESULTS REPORT
ISAP VII.a.4
(Cont'd)
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
I
-
There was evidence that management of the
audited organization reviewed and
investigated audit findings and determined
and scheduled corrective action. Written
responses were received by the auditing l
organization within a reasonable time of the !
requested date (on time, or v1 thin one week)
in approximately eighty (80) percent of the 1
files reviewed. This ratio is not unusual in
the experience of the RTL.
The first two of these requirements listed above er.e
nqt,ag ressed in.the._TU,_GC0 QA pronram documents. T_he *
third is addressed to_the_ audited organization only *
through,the transmittal-of-ther-au%
Conclusions
'
It is concluded that the failure to formally document
j
'
l
the responsibility for the audit program in the
PSAR/FSAR resulted in no adverse effect on the audit
( program because sub-tier program documents were written
', and management acted as if the responsibility had been
formally documented. s
l
l
V It is concluded that the failure to formally describe
'
the position and responsibilities of the Supervisor, QA
-
'
Audits, in organization descriptions resulted in no
adverse effect on the audit progrant because audit
~ j/ program documents were written and QA management acted
, ! as if the position had been formally documented.
' It is concluded that the failure to include the
responsibilities of the audited organization in )
,' appropriate program documents resulted in no adverse l
effect on the audit program because review of the audit
.( files revealed that the requirements had been met by
-
the audited organization.
5.1.2 Staffing
i
The adequacy of the TUGC0 audit staff (number and
qualifications) has been questioned by the NRC. When ;
considering the adequacy of an audit staff, one must
include not only personnel assigned full time to the
audit function, but also the qualified personnel
available on call to the audit organization.
.
F
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' Revision: 1
Page 18 of 53
~
RESULTS REPORT
i '
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ISAP VII.a.4
(Cont'd)
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5.0 . IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) I
The applicable etandards and regulations contain no
requirement for at audit staff, per se; only that
management shall establish an audit system that
includes maupower, furding and facilities to implement
the system. This allows management maximum flexibility
to allocate resources, even to the extreme of assigning
a fv11-time audit administrator responsible for
planning and scheduling of audits and tracking open
items, who has free access to qualified audit personnel
as required for individual audit preparation, conduct,
reporting and follow-up, but who has no permanently l
assigned audit staff. '
Therefore, judgement on the adequacy of the size of an
audit staff must be based on factors such as assigned
duties and responsibilities, outside resources
)
available on a timely basis and the ability to !
accomplish the scheduled audit activities (providing j
schedules are not dictated by manpower availability). l
The years 1981 - 1982 were cited by the TRT as a period
when the numbers and qualifications of the TUGC0 audit j
staff were questionable. In addition, Region IV
i
Inspection Report 445/84-32 cited 1983 as a period when i
the audit staff was inadequate. A review was performed I
of training and qualification files for TUCCO Quality '
Acsurance personnel (designated audit staff and others)
who participated in the audit program as Lead Auditors
or auditors during these periods. The following
tabulation summarizes the characteristics of these
personnel. i
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Revision: 1
Pags 19 of 53
RESULTS REPOR_T
ISAP VII.a.4
(Cont'd)
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i
/* ,
1981 1982 1983 !
Designated Audit Staff
(Including Supervisor)
5 11
N
14 (.
!
,
Total Participants 20
g' Qualified Lead Auditors 0 16 18
Education *
Masters Degree l
0 1 1 !
/ Bachelors (Engineering) 7 6 8
Bachelors (Other) 2 2 5 l
?
Associates (Technical) 0 1 2- !
l Associates (Other) 0 1 1
! Some College 1 2 3
NOTE: Four of the engineers rare registered
i Professional Engineers, and one was a :
certified Quality Engineer. One holder of an l
Industrial Management degree was also a
certified Quality Engineer.
Since the formation of a designated audit staff in
1979, through the present, it has been the practice to
supplement the staff as needed with other qualified
members of the QA organization to function as auditors
and lead auditors. It is therefore concluded that,
based on the evaluation of the years 1981 through 1983 i
.
and the other files reviewed, the formally designated
),auditstaffcouldbeconsidereddeficientinnumbers
and technical qualifications, but h the effective i
-
sj gudit staff of Qualit;r Assurance eersonne'l was, and
1
,
-
f 3 1nues to.be,.adequtta..ip both number an~'d ~
qualifications.
Iq !
,
. .
Conclusions
/
w -
Based on the reviews performed, it is concluded that
individuals did not audit activities which they were
-
responsible for performing.
'
t
It is concluded that audit staffing was adequate to
-
implement the audit program and schedules during the
periods of interest.
,
*
Personnel holding multiple degrees are listed only once, in the
highese applicable category.
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Page 20 of 53 '
RESULTS REPORT j
4
ISAP VII.a.4
(Cont'd)
4
'1
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5.0 IMPLDENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
5.1.3 Audit Planning and Scheduling
This section addresses the following topics:
-
Scheduling requirements,
-
Vendor audit scheduling and performance.
-
NRC Notice of Violation pertaining to Westinghouse-
site organization.
-
Planning and scheduling process for internal audits
and *
-
NRC Notice of Violation pertaining to 1983 audit
program coverage.
The requirements of ANSI N45.2.12-1973 pertaining to '
audit planning and scheduling can be paraphrased by
saying that audits are performed by or for an
organization participating in activities affecting
quality and that elements of the Quality Assurance
program affecting these activities shall be audited at
least annually or at least once within tha life of the
activity, whichever is shorter, Within this context,
the following terms are defined:
-
Organization - Plant owner, contractor, etc.,
-
Activities - As listed in the last sentence
of ANSI N45.2.12-1973, Paragraph 1.2. and
-
Elements - The 18 criteria of 10CFR50
Appendix B.
The TUGC0 written program (i.e., PSAR/FSAR, QA Program.
QA Plan and implementing procedures) reflected the
requirement for scheduling intarnal audits on an annual
basis only from August 1973 through April 1981. The
annual requirement was not reintroduced until November
1984. Additionally, the program eve has required
that vendors be audited on an annua asis.
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Pags 21 of 53
.
RESULTS REPORT
ISAP VII.s.4
(Cont'd)
I
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5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) !
l
Not until the issuance of DQP-CS-4, Revision.11, in ]
November 1984, was the TUG':0 written program in full
, compliance with spplicable planning and scheduling
commitments. This revision reflected the options
permitted by Regulatory Guide 1.144 to audit vendors on
a triennial basis, provided annual assessments are
performed. This revision also contained the
requirement to audit other applicable organizatfuns
(e.g., TUGCO, site contractors) at least annually.
* I
Titis lack of requirements in the written program for '
-scheduling annual internal audit and supplier audits ,
Constituted a noncompliance with licensing commitments y
l
Vendor Audit Program
In evaluating the effect of this noncompliance on the
*
vendor audit program, the following evolution of TUGC0
QA audit program responsibilities was identified:
-
From.1973 to 1977, 'TJGC0 was responsible for
auditing only the major contractors: Gibbs &
Hill (G&H), Brown & Root (B&R), and
Westinghouse (}{). During this same time
period G6H, B&R, and W had prime
responsibility for vender preaward surveys,
audits, and source inspections. However,
TUGC0 did participate in these activities.
- Early in 1978, although W retained its
original role concerning NSSS vendors and E&R
Y4 y retained full responsibility for its ASME
suppliers, TUGC0 assumed more direct control )
g'
gb /d . in_theothervendorcreswardsurvey, audit]
and source incpection activities previously
delegated to G&H and B&R. This included
balance of plant vendors (safety-related and
non-safety-related), on-site contractors and
non-ASME material suppliers. Additional
control was exercised through increased
involvement in the scheduling process and the
conduct of more joint audits.
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Page 22 of 53
,
RESULTS REPORT
ISAP VII.a.4 s
(Cont'd) '
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5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
1
, -
Early in 1981, TUCCO began performing ] F ,
vendor-related activities without G&H ( l
g,h ./ D o c a involvement. Also during 1981, TUGC0 assumed j
full responsibility for non-ASME material l
suppliers from B&R. This level of I
responsibility has continued to the present.
Based on the review'of the audit inder, it was
determined that TUGC0 QA performed audits of the major {
contractors during the period from 1973 to 1977 as !
follows:
j
, 1973 1974 1975 1976 1977
*
- G6H 1
N/A 4 1 1 2
'W 1 0 1 6 4
l
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B&R (Houston) N/A 1 0 2 1
B&R (Site) N/A N/A 2 {
1 1
j
!
The PSAR was docketed in 1973 and the Construction j
Permit was issued in December 1974.. The tabulation 1
indicates thte with two exceptions, required audits
were performed during this period in accordance with
the annual requirements of ANSI M45.2.12-1973.
From 1978 (when TUGC0 became more involved in the
administration of the audit program) through 1984, the ,
l
performance of contractor / vendor audits was not in '
accordance with _
of fre g y.~ ja plicable requirements
Foi example, for time
for 11ve of'the 1 E_jsp
twelve
vendors reviewed, the initial audit was performed after
the first release inspection (in three cases more than j
j
a year afterward) which was not in compliance with the i
ANSI requirement that auditing be initiated as early in I
the life of the activity as practicable to assure
, timely implementation of quality assurance
requirements.
(j fqur months. to six years. AlaRassLbetween audits ofI_t was
; these vendors. No s _
,
annual basis througliingle vendor
out this tia was audited
tperiod, on_a3
which
constituted a violation of the ANSI requirement for
[annualaudits.
The foregoing raises a concern that the TUCCO QA
organization was not cognizant of the effectiveness of
the vendor's QA programs. In assessing this concern,
the following was disclosed:
_
_ _ -_-__- ._
...
i
,
Revision: 1
'
Page 23 of 53
I
,
RESULTS REPORT
.
ISAP VII.a.4 ;
(Cont'd)
..
)
l
5.0 IMPLEMENTATION OF ACTION. PLAN AND DISCUSSION OF RESULTS (Cont'd) q
'
-
In October 1978, TUGC0 QA instituted a Vendor
Rating program whereby numerical ratings were
assigned to vendors based on type, severity,
and quantity of-defects identified during
source inspectior.s. These ratings were
utilized to adjust the scheduling of
. inspections and audits. In January 1981, &
Vendor Performance Evaluation system was
instituted which enhanced the Vendor Rating j
system by also considering the number of '
items submitted for inspection in calculating
the rating. It was noted during the review
' that various audit notifications and/or *
q
reports documented that some of these audits '
had been initiated as a result of
, unsatisfactory source inspection reports. ,
-
In May 1979, a Joint Inspection / Audit program 0
\
was instituted whereby auditors would p l
accompany inspectors on releas. inspection
trips to investigate specific program areas [
based on problems identified during previou
source inspections.
~
l
~
TUGC0 QA also utilized " Requests for
Corrective Action" which were correspondence
'
, i
with the vendors requesting corrective action
for specific, identified problems when it was {
concluded that the problems did not warrant '
an audit investigation or did not appear to
indicate an adverse trend.
'
-
Internal documents known as " Yellow Flag- ;
Sheets" were also utilized by the TUGC0 QA l
staff to ensure that applicable QA personnel !
were aware of status and/or problems with
particular vendors, e.g. a bold placed on
shipments from a vendor until after an audit
was performed.
While it is recognized thai: source inspections and
-
,
limited-scope audits performed in response to
' identified problems might not be considered adequate
substitutes for regularly scheduled program audits,
the did provide data which were utilized totTotre'
xten by TUGC0 to evaluate ths effectiveness 2 vendor
QA programs.
- - _ . _ _ .
. <
,
Revision: 1
'
Page 24 of 53
RESITLTS REPORT
ISAP VII.a.4 3
(Cont'd) l
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
It is concluded that during the period prior to 1978,
the frequency of performance of contractor / vendor
audits, with the exception of the two cases noted, was
satisfactory, but for the period from 1978 through
k November 1984 the frequency was net satisfactory.
~
Qtheit source
is further concluded that as a result of
inspection activities, the limited audit
activity, vendor ratings, corrective action requests
'
// A , d.ed<A *~ ^ ' and internal QA communications, that sufficient ,,.-
/gg information was available to, and__used to eene exten_t g(,
7
__
_1y., the QA organization to evaluate.the effectiveness
4 .g '
of vender QA programs sven though audits of the venders A'
were not performed en an annual basis. .
The NRC notice of violation (445/8432-0?; 446/8411-03) !
identified that the Westinghouse site organization had
not been audited from its inception in 1977 through
1981. To provide background, the description of the
Westinghouse site organization in the NSSS contract ,
between TUGCO and Westinghouse includes the following
in Section 5.0 (paragraphs A and B are not applicable
to this discussion):
"C. Construction Site Services - Beginning 21
meaths prior to the arrival of the first of
Vender's equipment at the job site (or such
later date as may be mutually agreed upon). '
Vendor shall establish an organization with
representation at the job site to the extent
necessary in the judgement of Purchaser to
l
coordinate construction site activities for '
Vendor's equipment. This organization will
be retained with representation at the job i
site until fuel' loading of the second NSSS is j
completed. =
!
D. Field Testing and Startup Services - Vendor i
shs11 establish an organization to provide
advice and consultation on testing and
startup. Special startup and testing
equipment (or its then current equivalent)
identified in Exhibit A shall be provided at
the job site by Vendor on a cost-free loan 1
basis. Testing and startup procedure !
preparation assistance shall also be
g provided."
j
*
% 4(
pNO~
4 4.Q )
ap :% -a. .. 4v.,, ._,]'w, p ggg-
.
;:
. i
i
;
- _ _ - _ - _ - - - -
w .
- Revision: 1
Page 25 of $3
, RESULTS REPORT
ISAP VII.a.4
(Cont'd)
5.0 IMPLDENTATION OF ACTION PLAN AND DISCUSSION OF PISULTS (Cont'd)
,
i Further, the safety-related activities relating to
erecting, installing, inspecting, testing, etc., of the
i
NSS3 were the responsibility of TUGC0 and were
m
performed by TUGC0 br Brown & Koot organizational
elements. The activities performed by the Westinghouse
site organization were primarily liaison and did not
include the categories of ssfety-related activities
requiring periodic audits as listed in Section 1.2 of
ANSI N45.2.12-1E73.
This understanding of the involvement of the
Westinghouse site organization in the site safety-
related activities was confirmed by TUGC0 QA during the {
performance of an audit of Westinghouse site activities
pertaining to work on the reactor internals (audit
TWH-23) in March 1982. This audit confirmed that the
development of work travelers was performed by Texas
Utilities Services, Inc. engineering and that
construction and inspection activities were performed
by Brown & Root. The audit also revealed that
Westinghouse-Pensacola supplied drawings and performed
overview surveillance of TUGC0 and Brown & Root
activities related to the reactor internals. After
concerns were expressed by the NRC, an audit of
Westinghouse site activities was scheduled and
performed in November 1984 (audit TWH-30). This audit
confirmed the TUGCO understanding of the Westinghouse
site organization scope of work.
It was determined that the W site organization scope of
work did not include the categories of safety-related
activities requiring periodic audits per ANSI
N45.2.12-1973. This position was confirmed by TUGC0
through the performance of the above-mentioned audits.
t is therefore concluded that there was no requirement
o audit the Westinghouse site organization.
Internal Audit Program
As previously discussed, ANSI N45.2.12-1973 requires
that applicable program elements affecting an activity
be audited annually. This means that the activities to <
be audited must be identified along with the program '
elements affecting these activities. Audits of these
.
_ _ _ _ _ _ . . _ , _ . . _ - _ _ _ - - - _ - - - - - - - - - - - - - -
- _ _ - _ - _ - _ . - - _ _
e .
Revision: 1
Page 26 of 53
;-
RES g SJ EPORT
ISAP VII.a.4
(Coc t.' d) , .
,1
*
,
)
5.0 IMPLEMENTATION.OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) ]
activities are to be schadolad on the basis of their
status and safety importsace and performed to evaluate
the adequscy and, effectiveness of the program as ,
developed and implemented by tha participating
organizations.
t
Evsluating the ahquacy of the TUCCO QA internal audit
program at the construction site is complex. Prior to
1978, site, audits were echeduled and conducted as
vendor audits. Since that time, except for contractors
operating under their own QA programs, site audits have
been scheduled and conducted er internak audits.
The following paragraphs describe the evolution of th I
audit planning process during the Design / Construction
phase of CPSES.
When the TUCCO internal audit program was first
implemented at the construction site in 1978,. audit
planning and scheduling appeared to be primarily
activity-oriented. However, by 1982 audit planning
appeared to have become primarily organization-
oriented. During the review of the audit files,
observations related to the structure of checklists,
tusk assignments of team members during the audit,
structure and content of audit reports, is well as ,
audit titles indicates that audit planning and
scheduling continued to be organization-orienced.
This approach to audit planning evolved to accommodate
the organizations 1 structure and procedure systeme that
developed as TUGC0 assumed additional responsibility
for site activities.
The written program has always required that audit
planning and scheduling activities be performed, and
the reviews of the files revealed that audit schedules
had been prepared. However, it was determined that ,
l
until the istuagge of procedure DQP-AG-4 "CPSES
Construction Phase Audit Program," Revision 0, on
September 4._ Q85M htre was no procedure that detailed
~the audit pl.anning,and scheduline'proceas, A review of
this procedure revealed that although r4dits were to be )
va n.. . . -
.
-
_ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ - _
_ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ -
d
Revisica: 1
Page 27 of 53
REStTLTS REPORT
ISAP VII.a.4
(Cont'd)
'
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
performed annually, activities to be audited would be
; determined from existing programs and procedures,
rather than from an analysis of site activities l
l
, affecting quality and their importance to safety. The i
procedure also implied that audit planning was '
organization-oriented.
,o ;
However, as a result of discussions with TUGC0 QA
management and a review of audit schedules, it is
concluded that the audit planning and scheduling i
' process has generally considered project activities as !
an input. Procedure DQP-AG-4 has since been revised
(Revision 1, dated Jaeuary 27, 1986), and now describes
an adequate audit planning and scheduling process.
-
)
Procedure DQP-AG-4 also provides for the development of
i
g ., an annual audit schedule which is subject to periodic
review and adjustment based on project status, program ,
.
changes, outside reviews, etc. As-run schedules for
past years have been prepared to document audits
scheduled but not performed (and the reasons
why they were not performed), and additional audits
which had been added to the schedule.
It was noted that the proposed 1986 audit schedule
j
includes a short scoping statement for each scheduled
audit. This enhancement to the schedule provides a
more complete description of the planned audit program
/ coverage.
?
(f ' Also related to audit planning, the NRC Notice of pa violation (445/8432-0?; 446/8411-03) stated that TUGC0
audit planning for 158 was inadequate because only 25
percent of the safety-related procedures were audited.
This use of procedures as an audit planning baseline is
appropriate only when the procedures are pre-defined as -
the program elements. Accountability for audit
coverage would then be simplified because a procedure
listing is very specific as opposed to developing a
list of octivities, applicable criteria, and
participating organizations. Attractive as it may
appear, this method of audit planning contains
weaknesses and is not recommended
because auditing strictly by the procedures could
result in overlooking an activity for which a procedure -
was required but had not been developed. I
l
did R O /r 4 f, A-G42Ai 32 ( ,t , , 5
4g (
t L___--___ . _ - _.
_ - - _ _ _ _
.a -
Revision: 1
Page 28 of 53
l
RESITLTS REPORT
ISAP VII.a.4
(Cont'd)
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
By calculating the percentage of procedures addressed
by the audit program, an inference could be drawn as to
P the adequacy of audit program coverage. However,
-
unless this information is correlated with actual
c project activity, previous audit and/or surveillance
, results, importance of the activities represented by
procedures not audited, etc., no judgement should be
made of the adequacy of audit program coverage based
solely on percentage of procedures audited.
A review of the 1983 Audit Program revealed that TUGC0
. performed twenty-nine (29) internal audits of
design / construction phase activities as well as eight - ,
onsite audits of construction contractors. l
I
From data gathered during the review of the twenty-nine l
O (29) internal audit files,_a matrix was developed E l
evaluate the activities audited, the program elements
(Appendix B criteria) addressed, and the organizations
through which they were addressed. In addition, the .
list of activities audited (contractor and internal)
was compared to the major site activities in process
during the year as identified by project control
personnel. These evaluations revealed that th Q 9,83, 3
audit program addressed the. major on-going site
activities, that all site organizations were audited, ,
and that all program elements (Appendix B criteria)
were addressed. Therefore, it is concluded that the
audit program coverage of the Design / Construction Phase
of_CPSES during 1983 was adequate. It was also noted
that the audit schedule was adjusted throughout the
year in response to organizational and program changes,
to address problems identified by outside organizations
and to reflect changes in the project schedules.
Conclusions q
It is concluded that the failure to perform vendor
audits on an annual frequency vanuited in no advnam
- effect_on the audit program because of the additional
(, _D activities implemented by the QA organization to
supplement the audit activity.
;
(, - ,
1
S
/ I
I
- _ - _ _ - - _ - - _ -_.
,
j
!
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Rsvision: 1
Page 29 of 53
RESULTS REPORT
ISAP VII.a.4
(Cont'd)
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
-
It is concluded that there was no requirement to audit ;
the Westinghouse site organization.
It is concluded that the lack of a formalized ))
-
methodology for internal audit planning and scheduling
resulted in no adverse effect on the audit program
because it was established that audit planning was
[C)7[ > accomplished and audit schedules were prepared to
'
.
g7M
'
im menttheaudityr am.
*
5.1.4 Audit Preparation
Nar W W ^ A V.
The audit preparation phase consists primarily of *
i
l
accumulating pertinent documents and data from internal
and external sources from which the Audit Team Leaders
would develop the final detailed audit scopes and audic
checklists.
The reviews of the audit files revealed that while
checklists had been prepared for the conduct of the
audits and that sources such as TUGC0 site
surveillance, INPO evaluations, CAT reports, etc., had
been utilized to address topics of special interest,
the majority of the checklists reviewed in detail
appeared to have been developed from existing
procedures rather than from governing requirements. As
discussed previously, utilizing procedures as the
baseline could preclude verification that the
procedures, individually or collectively, adequately
implement the requirements.
It can be an acceptable practice to perform only
compliance audits for those portions of a program which
remain basically unchanged. However, there was no
Tvidence in the TUCCO QA sudit files reviewed to
indicate that a comprehensive assessment of the written
program had previously been performed in the areas of
-l Non-conformance Control / Corrective Action or QC l i
Training / Qualification / Certification to ve'rify that
the program procedures were in compliance with
governing requirements.<
In addition, the checklists reviewed did not provide
for verification that procedures in different CPSES
procedure systems that address the same or similar
activities vnt_consisten_t in approach, level of detail
or control of the activity.
.
- _ _ _ _ _ _ - _ _ -
;
_, . . . . - . . . - l
Rcvicion: 1
Pegs 30 of 53
l
REStTLTS REPORT
ISAP VII.a.4 {
(Cont'd)
5.0 IMPL7JiENTATION OF ACTION PLAN AND DISCUSSION CF RE$ULTS (Cont'd)
During 1985, the QA Audit Group initiated the use of an
" Appendix B Checklist." Applicable portions of this -
standard checklist are now utilized by the audit team
to verify that the procedures within the scope of the ,
audit are in compliance with the applicable criteria of 44 i
10CFR50 Appendix B. ,f,g'
Conclusions Ytj.
V
It is concluded that the gydit preparation activities '.
were not_adeaunte. This resulted in an adverse efiact
~
?
on the audit program, in that most audits reviewed did
not evaluate the adequacy of the written program to * ,
'
/
implement the governing requirements.
5.1.5 Audit Performance g.
)
ANSI N45.2.12-1973, to which TUGC0 was committed g-
through May 1983, contains no specific criteria for an
Audit Team Loader. I
~
From February 1982 through February 1985, as a portion ->
of on-the-job training, the TUGC0 program contained s
\'
provisions for a lead auditor candidate to be
designated as the a,cting Audit Team _Leaier, to perform .*t
\
/
under the direct supervision of a cuallfind_ Lead y
Auditor. 4
This practice did not constitute a noncompliance prior f
to the June 1983 commitment to ANSI N45.2.23-1978.
However, from that time until the issue of procedure
DQP-CS-3, TUGC0 QA Audit Program," Revision 12, dated
February 15, 1985, the pn ectice did constitute a
technical noncompliance with the requirem D
' ANSI N45.2.27;197s.
It is not uncommon for an audit team leader to delegate
functions to team members during the course of an
audit, for training or other reasons, while retaining
G 1timate responsibility therefore. Bovever, in the
TUCCO program, full responsibility for an audit was
assigned to other than a qualified Lead Auditor, whir.h
vas
a contrary to the requirements of ANSI N45.2.23-1978.
.
_ _ _ _ _
- _ - _ _ _ - _ _ _ - _ --
..< . , . . ,
! ) ,
R visien: 1
Page 31 af 51
RESULTS REPORT
.
ISAP VII.a.4
(Cont'd)
5.0
IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RE
ANSI N45.2.12-1973 requires that auditors be
independent of any direct responsibility for the
activities they will audit. The reporting level for
the Director, Quality, Assurance provides adequate
independence of the QA staff from the design and
construction activities.
The NRC raised a question in SSER 11 concerning the
V .LM S.bjeScivity of surveillance _ personnel performing audits
' of activities over which they had surveillance
~ ~
resp'onsibilit[y. This practice is not uncommon'in the
industry and, in fact, can be beneficisi to the audit
program in that the knowledge and experience gained by
personnel from surveillance activities can be utilized
as input to the audit planning process and through j
participation on the audit team. The only time this
*
situation might constitute a conflict would be th? case
where the purpose of the audit was to evaluate tL4
adequacy and effectiveness of the surveillance program
itself.
during thisNoreview.
audits of this nature were identified
It waa dater-d e?
.
.
*.bn* pre-audit and post m dtt
conferences were conducted by the audit team and that
appropriate personnel were in attendance.
The review of the audit files revealed that objective
evidence had been examined when appropriate to support
the audit activity as defined by the audit' checklists.
It appears that the auditors evaluated program elements
to an appropriate depth to support the audit
checklists.
Conclusions
it is concluded that the practice of designating a lead
auditor candidate as an acting team leader resttited in
? no adverse effect on the audit program because the
(N -
" acting team leadeg.,perfopged .iht Activities under the
adirmet adervlaiort.oLa-quaH
asabe.r..of >he and.i.t .. gam. ff ad_ lead _,a,Luditor
'
'
who was s
(
r t
a concluded that the practic'e of utilizing site
surveillance personnel as audit team members had no !
adverse effect on the audit program because these
) personnel did not perfonn audits of activities which
they were responsible for performing.
.
_-_
.
-
Revision: 1
Page 3? of c3
RESULTS REPORT ._
\
ISAP VII.a.4 ,
(Cont'd)
I
5.0 i
IMPLEMENTATION OF ACTION PLAN AND DISCUSSIO
5.1.6 Audit Reporting
has not always complied with the requirements
N45.2.12-1973.
Early in the program, audit reports did
not consistently include itema such as a description of
o the audit scope, persons contacted, a summary of audit
results and an evaluation statement regarding the
effectiveness
a' adit ed . of the QA Program elements which were
However, the information not included in the {
reports, with the exception of the'surnary and the
evaluation statement,
j
can be found in the audit files.
The content
improved over and
time.quality of audit reports have gradually
Currently, the audit reports
provide the reader with an adequate understanding of
the scope and results of the audit. The current
~
N45.2.12-1973. procedures adequately reflect the requirements of ANSI
During the detailed review of the nine (9) audit files
. in the training and nonconformance control areas
(aec Page 12), seversi devictions were observe 4 that
irdicate weaknesses in the implementation of the audit
program related to audit reporting:
-
There were approximately twenty instances
where the published audit reports did not
appear to accurately reflect the auditors'
field notes and/or checklists.
items in'the notes that appeared to beFor example,
deficiencies were reported as concerns or
comments, and in one case, an item identified
as "unsat" on the audit checklist was not
reflected in the audit report at all. The
items
any itemsidentified did not pertain directly to
of hardware. .
the RTL that additional data could have been(It is rec 8
obtained which could have altered the
conclusions and was not reflected in the
notes / checklist).
l
l
.
I
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a \
Ravision: 1
Page 33 of 53
RESULTS REPORT
i
ISAP VII.a.4
(Cont'd)
i
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
In many of these cases, the accompanying i
notes seemed to indicate that the auditor i
either judged the "importance" of tha finding l
in the decision to document, or may have had l
sdditional information which was not included i
in the audit files. There was no discernible l
pattern for not documenting identified
unsatisfactory conditions.
l
It was noted that the category of " concern"
was deleted from audit reports in April 1984
with the issue of revision 7 of DQI-CS-4.6.
All discrepancies are now categorized as -
3
deficiencies in the TUGC0 audit program. '
It is the responsibility of the Audit Team
Leader to ensure that the audit report
accurately reflects the audit findings as
documented by the audit team, and that
pertinent backup data is included in the
audit files.
-
There were occasions when maior sections of
Detrvere not completed whiDF i
l
' Effec't, altered the scope of.the audit. This
was not documented in the audit report. This
could have provided an inaccurate view of
audit program coverage.
In some cases, the reason for the omission I
was noted on the checklist (e.g., " time '
constraints", " covered by another checklist",
"would have required verification of other
procedures", etc.), but in some cases was
not. There was no discernible pattern in the l
stated reasons for not completing checklists. '
In March 1985, the QA Audit Supervisor l
instituted a " Checklist Review Verification
Form" (act procedura11v define D which is l
used by the Audit Team Leader to document the j
extent of completion of the audit checklist.
This form is now utilized in the audit 3
planning process to ensure that incomplete ;
items are rescheduled as required. -
!
.
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Ravision: 1
Page 34 of 53
_RESULTS REPORT
ISAP VII.a.4
(Cont'd) I
' $
5.0
-
IMPLDIENTATION OF ACTION PLAN AND DISCU
-
It was noted that the TUGC0 audit reports do
i not include a formal Recommended Corrective
Action for identified deficiencies. The
language of ANSI N45.2.12-1973 can be
interpreted either way as to whether or not
this is a requirement. The RTL supports the
TUGC0 position, although it is contrary to
experience, because the responsible
organization is better able to determine the
proper course of corrective action and is ,
ultimately responsible for the final i
determination and implementation. !
organization remains responsible forThe QA ' {
evaluation and approval of the course of j
corrective
effective action as well as verification of
implementation.
-
Audit report distribution did not appear to
be consistent in that the reports in some
cases were addressed to the supervisor
responsible for the activity requiring
i
corrective action rather than to project
management,
receive copies. although project management did
Although this is technically
not a violation of requirements, it can cause
project management to be omitted from direct
participation in the reporting,
investigation, and corrective action
activities of the audit process. In
addition, original recipients did not always
receive subsequent correspondence related to ,
follow-up and closecut. i
, eenclusiens
!
audit reports (e.g., audit scope, susmary o
results, evaluation statement) 2ould h va resulted in
h a contributed lo a__ lack of full understandin _
the
r h of the adequacy and effectiveness of the QA _
program as evaluated by the QA organfration.
1
I
_ - _ - _ - - - - - - - -
- _ _ _ _ _ _ _ -
, , '
i-
I
1
Revision:
'
, ,
1
! Fage ti of 53
RESULTS REPORT
,
,
i
ISAP VII.a.4 !
(Cont'd)
f
5.0
IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
It is concluded that the failure to properly document
audit deficiencies could have result,ed in an adverse
gffect on the adequ' fey'bf the audit prBgram in that
,
-
appropriate management may not~be made aware of all
itema reguiring cor.rective~ ~action
Luportance. ~"-"-~
or -of- -their,
~
It is concluded that the failure to document deviations
from the audit check 11sts'could have resulted in an
^
adverseeffectontheauditprograminthata3pripriate
-
managemen't mIgEt'not be made aware of program
activities / elements which were not evaluated. !
.
It is concluded that the failure of the auditor to
recommend effective corrective action for audit
' deficiencies resulted in no adverse effect on the
audit program because the organization responsible for
the activity has the ultimate responsibility for
determination of corrective action.
It is concluded that the lack of consistent
distributi_on of_a.udit' reports and subsequent
correspondence igu,16..hsvs..rea d erLin.an. adverse effect
on the adequacy of the audit program in that project
management would not be involved in the activities
pertaining to investigation, corrective action and
closeout of audit deficiencies.
5.1.7 Follow-up and Closecut
The final major step in the audit process is timely
follow-up, by both the audited organization and the
auditing organization.
The review of the audit report files indicated that,
throughout the program, the early steps of the follow-
up process appeared to have been completed in a timely
manner by both the audited organization and the )
j
auditing organization. This included determination of. '
and schedule for completion of corrective action by the
audited organization, evalua. tion of the proposed
corrective action by the auditing organization and
additional correspondence between the two, as required,
until resolution was reached. q
;
!
.._ )
_ _ _ _
_ - _ - - _ -
,
.. . . . *
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Revision: 1
Page 36 of 53
RESULTS REPORT
,
ISAP VII.a.4
(Cont'd)
5.0
IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESU
The timeliness of. implementation of corrective action
by the audited organization cannot be ascertained from !
i
the audit files for reasons that are discussed below.
Interviews with the Assistant QA Hanager indicate that )
the general feeling within the auditing organization ]
was that implementation of corrective action was
timely. However, the timeliness of verification of ,
implementation of corrective action by the auditing l
organization, as well as closecut of the audit
deficiencies and audit reports was often
un sa tis f ac tory,.
l
Tnis situation was eventually recognized and addressed
by TUCCO QA through the performance of audit TCP-111 i
August 1984of Open Construction Audit Findings" in
"Closecut
This audit was performed to verify
implementation of corrective action for
and 22_c.cncerns._some of which had_been _83 def4rienrits.,
~
ooen f* mr
-
csif'ylarD During the audit, all but four (4) items (2
deficiencies and 2 concerne) were found to have been
completed.
These four items were reissued as three
deficiencies against audit TCP-111, which were then
closed in a follow-up two monehe later.
The NRC addressed the inability of TUGCO QA to close an
audit
TCP-68 finding from TCP-23 during the conduct of audit
The deficiency in question was subsequently
identified as audit TCP-40, Deficiency 2. It was
determined that this deficiency was closed during the
conduct of audit.TCP-99 in March 1984
}4}
~
i Contributitigicaus'eh to the lack of timely follow-up
were a combination'of (1) the practice of each lead
auditor being responsible for scheduling applicable
!
follow-ups during subsequent audits, (2) related audits I
being scheduled up to a year later, and (3) lack of a
formal tracking and status system for audit
deficiencies. The apparent lack of urgency for
follow-up may have been influenced in part by the
general feeling that implementation was indeed timely,
and therefore additional action was not required to
expedite implementation.
*
Procedure DQI-AG-1.8. " Internal Audit Deficiency
Follow-up/ Closeout" issued in June 1985, addressed
these problems by instituting a tracking system for
internal audit deficiencies.
described in the procedure is adequate.The tracking system
!
!
_ _ _ _ _ _ _ -
____ _ _ - _ _ _ - _ _ _ _ _ _ _ -
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Revision: 1
Pass 37 of 53
RESULTS REPORT
ISAP VII.a.4
(Cont'd)
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Conclusions
It is concluded that the failure to perform timely
l verification of implementation of corrective action for 5
audit deficiencies,Eould have resultad in an advers_e
effect_qn_the_ adequacy of the andfe eregtgm in that one
of the major gosis of an audit program is to identify
and ensure corrective action for program deficiencies.
5.2 Audit Personnel qualification
Program documents and audit personnel training / qualification
files were reviewed to evaluate the adequacy and effectiveness
of the TUGC0 program for qualification and certification of
audit personnel. The results of these reviews are summarized
in the succeeding paragraphs.
5.2.1 Qualification Requirements
1
6
Prior to June 1983, TUGC0 was committed to the
requirements of ANSI N45.2.12-1973 for audit personnel
training and qualification. The TUGC0 written program
for this period was in compliance with the ANSI
requirements.
It was noted from reviewing the training and
qualification files for this period that, beginning in
;
1977, a form similar to the form contained in ANSI
l
i
N45.2.23 was being used to document certifications for
lead auditor. The use of the modified form was
proceduralized in 1980. It was noted that in the use
of this form (for which there was yet no commitment)
TUGC0 was twsrding qualification credits for attributes
in addition to those specified in ANSI N45.2.23 and was
I
not requiring the same number of qualification credits
I
as was the ANSI.
Revision 5 of CQI-QS-2.1, " Qualification of Audit
Personnel," issued June 1, 1983, resulted in the
written program being in compliance with ANSI
N45.2.23-1978. At this time; audit personnel who had
been qualified and certified under the previous
procedure revision were reevaluated and new
certifications issued. This procedure has since been
cancelled and the appropriate material incorporated
into DQP-QA-2, Revision 11. The current procedures are
in compliance with governing requirements.
.
.
.
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I
#
,
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Revision: 1
Page 38 of 53
.
RESULTS REPORT
i
ISAP VII.a.4 '
(Cont'd)
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Conclusions
It is concluded that the audit personnel qualification
program adequately reflected the requirements of the
appropriate governing standards and regulatory guidance
and therefore resulted in no adverse effect on the i
audit program.
5.2.2 Training / Qualification Records
Of approximately fifty (50) personnel identified as ,
having performed as auditors or lead auditors since i
1978, the personnel qualification files of 41 of thead
individuals were reviewed for evidence of education,
training and experience used as a basis for
qualification and/or certification. The personnel
reviewed were all members of the TUGC0 QA organization,
though not necessarily assigned to the audit staff.
Included in this total are all who performed as
auditors or lead auditors since 1981, as well as some
who had participated earlier.
)
All files, except as discussed below, contained
adequate documentation (e.g., resume, training records,
i reading lists, certifications, etc.)
appropriate to the time of certification, including ;
evaluation and racertification of personnel on-board on '
June 1, 1983 (Date of Commitment to ANSI
N45.2.23-1978).
{
' Files for six personnel contained no resume or other
independent supporting documentation for lead auditor
I
' certifications issued in 1977, 1978, and 1981. None of
these personnel have participated in the program since
1982. Although no judgement of competency of these
personnel can be made from the records reviewed, others
certified during this period were determined to be
adequately qualified, based on their records.
Review of Lead Auditor qualification files indicates
that all personnel currently certified as Lead Auditor,
except as noted below, have satisfied the requirements
of ANSI N45.2.23-1978.
Although there is no regulatory requirement to verify
the education, experience, etc., for audit personnel, !
it was noted that TUGC0 QA is in the process of
performing these verifications for the current staff j
and has incorporated such a requirement in DQP-QA-2.
{
!
!
,
- _ _ - _ - - - - - - - - - - - - - - -
,
.
R* vision: 1
P8,ge 39 of 53
RESULTS REPORT
ISAP VII.a.4
(Cont'd)
5.0
IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
ANSI H45.2.23-1978, Section 4.2 states that the
development and administration of the examination for
i lead auditor is the responsibility of the suployar. It
also states that te?s activity may be delegated to an
independent certifying agency but that the employer
shall retain responsibility for conformance of the
examination and its administration to the standard.
The applicable TUGC0 procedura does not specifically
reflect this requirement, eithough it could be
interpreted to do so.
During the review of qualification files of current
staff members, it was observed that at locat three '
personnel had been granted certification am lead
auditor who had no record of being administered an
examination by or for TUCCO. They had been given
*
credit for examinations administered by previous
employers. It is believed that this action has not
resulted in the certification of unqualified personnel,
but it constitutes a violation of the requirements of
ANSI N45.2.23-1978.
Based on the review of audit personnel training and
qualification files, it was concluded that with the
exception pertaining to the examination of Lead
Auditors, the TUGC0 program for qualification and
certification
implemented. of audit personnel was satisfactorily
_ Conclusions
It is concluded that independent backup information not
being in the files for auditors in the past resulted in
no adverse effect on the audit program in that the
files did contain evidence that QA management had
performed an evaluation of the personnel and found them
to be qualified.
It is concluded that the failure of TUGC0 to administer
lead auditor examinations to particular individuals
resulted in no adverse effect on the audit program in
that the personnel are otherwise qualified and are
auditors. espable of satisfactorily performing as lead
believed
_ ___ , _ _ - - - - - - - - - - - - - - - - ' - - ' - - _ _ _ _ _ _
- _ - _ - _ _ _ _ _ _ _ _ - -
_ .
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Page 40 of 53
REStfLTS REPORT )
ISAP VII.a.4
(Cent'd) .
l
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
*
5.3 Evaluation of Findings
* '
This section summarizes the deviations and weaknesses
identified throughout this report. Each item includes the
17, '
8 determination of whether or not it was considered to be a
,[ QA/QC program deviation, states a recommended corrective
r
'~
action if appropriate, or describes corrective action which
has already been taken.
"
,
The corrective actions describe below are intended to preclude
,
recurrence of the identified deviaticha. It has been
determined that remedial corrective action would provide no
additional benefit to the QA Audit Program. *
Audit Program
)'- 10CFR50, Appendix B, Criterion I, states in part,
". . . the authority and duties of persons and
! organizations performing activities affecting the
safety-related functions of structures, systems, and
<
i components shall be clearly established and delineated
in writing . . ." Criterion IVIII states in part, "A
$ comprehensive system of planned and periodic audits
,
shall be carried out. . ."
Contrary to the above, the CPSES FSAR does not address
the organizational responsibility for the definition
and implementation of the audit program.
, This is a QA/QC Program Deviation.
I
t Therefore, it is recommended that the CPSES FSAR be
; revised to define the responsibilities for the audit
,
program. A proposed change to the PSAR has been
_l submitted to TUGC0 licensing, has been reviewed by the
RTL and found to be acceptable.
$
.
p~ -
10CFR50, Appendix B, Criterion I, states in part,
-
". . . the authority and duties of persons and
!
organizations performing activities affecting the
safety-related functions of structures, systems, and ;
components shall be clearly established and delineated
in writing . . ." Criterion IVIII states in part, "A
comprehensive ' system of planned and periodic audits
sha?.1 be carried out. . ."
Contrary to the above, the QA program documents did not
delineate responsibilities for the Supervisor, QA
Audits.
- _ - _ . . . _ _ - ----
- _ _ _ - _ _ _ _ _ _ _ _
-
. . .. .- .
-
Revision: 1
Pcg2 41 of 53 I
*
RESULTS REPORT
4
ISAP VII.a.4
(Cont'd)
^
o.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
This is a QA/QC Program Deviation.
Corrective action was taken in DQP-QA-16, Revision 0, I
issued in September 1985. This has been reviewed and l
found acceptable.
3- 10CFR50, Appendix B, Criterion V, states in part, !
-
" Activities affecting quality shall be prescribed by
documented instructions, procedures . . . of a type
appropriate to the circumstances. . ."
ANSI N45.2.12-1973, paragraph 3.2, states in part, "An
effective audit system . . .shall include . . . -
provisions for reasonable and timely access of audit
personnel to facilities, documents, and personnel
necessary in the planning and performance of the
audits. . . ."
.
' ANSI N45,2.12-1973, paragraph 4.5.1, states in part,
, l
". . management of the audited organization or
.
activity shall review and investigate the audit
findings to detemine and schedule appropriate ,
;
corrective action. They shall respond to the report in (
vriting, within 30 days after receipt." {
l
The " Gray Book", paragraph D.2.b, states in part, i
". . .during the (post-audit] conference an effort
shall be made to establish a tentative course and
schedule of corrective action for non-conformances.
Where it is not possible to provide such information at
the post-audit conference, the management of the
audited organization should commit to a specific date
for determination of the course of corrective action
and the schedule for implementation."
Contrary to the above, neither the TUCCO QA Program nor
the CPSES QA Plan, the documents in the written program
which would provide direction to the management of the
audited organizations, addresses the requirements.
* This is a QA/QC Program Deviation.
<
It is recommended that appropriate QA program documents
(e.g., Corporate QA Program, Site QA Plan) be revised
to include these requirements.
-
3e TRT concluded that the QA aud'it program had
~
!1nadequate staffing during peak periods.
l
.
_ _ _ _ _ _ _ _ , _ _ - . . _ _ _ . _ _ - - _
_ __ _ _.
_ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _-- - - -
h , ,
. .. .
Revision: 1
.w . '
[jf, RESULTS REPORT
. , .
1 J.
'
ISAP VII.a.4
< . kt jl (Cont'd)
'
*
.,,. .y '
-
W. ' :
*
;
'
5.0 IMPLDENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) I
)
!ThisNRCfindingwasevaluatedbyconsideringboththe
! t designated audit staff and other members of the QA
organization who performed as auditors. The total
number of participants in audits shows that the audit
staff was adequate in numbers and qualifications.
,Accordingly, this NRC Finding was not substantiated.
k- ANSI N45.2.12-1973, paragraph 3.4.2, states in part, l
" Applicable elements of the Quality Assurase Program i
shall be audited at least annually or at least once '
within the life of the activity, whichever is shorter."
Contrary to the above, iuternal annual audits were not
specified in procedure from 1981 to 1984.
h .
This is a QA/QC Program Deviation. The NRC finding in
this area was substantiated.
Corrective action was taken in DQP-CS-4, Revision 11
'
issued in November, 1984. This has been reviewed and
found acceptable.
$ ,- ANSI N45.2.12-1973, paragraph 3.4.2, states in part,
" Applicable elements of the Quality Assurance Program
shall be audited at least annually or at least once
within the life of the activity, whichever is shorter."
Contraty to the above, vendor annual audits were not
j specified in procedures.
This is a QA/QC Program Deviation. The NRC finding in
this area was substantiated.
i
Corrective action was taksh in FSAR Amendment #52
issued in August 1984 and DQP-CS-4, Revision 11 issued
in November, 1984. This has been reviewed and found
acceptable.
4 *- ANSI N45.2.12-1973, paragraph 3.4.2, states in part, i
" Applicable elements of'the Quality Assurance Program j
shall be audited at least annually or at least once j
within the life of the activity, whichever is shorter."
Contrary to the above, annual audits were not performed
for contractor organization in two (2) instances out of
sixteen (16) required audits from 1973 to 1977.
.
- - - _ _ _ . . _ _ _ _ _ _ _
- _ _ - - - _ - - - _
,
' k1.. . , sF' r Rsvision: 1
a ., -
; Page 43 of 53
1- ' % . , ~.
*
l.
.;;s RESULTS REPORT
' '
F ?> ,f,i: '
ISAP VII.a.4
,-
(Cont'd)
.
. ,, ,?
:
5.0
IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
This is a QA/QC program deviation. The NRC finding in
this area was substantiated.
Corrective action was taken by QA management in that
for the remainder of that phase of the TUGC0 audit
program, audits of major contractors were performed at
least annually.
-
7 ANSI N45.2.12-1973, paragraph 3.4.2, states in part,
" Applicable elements of the Quality Assurance Program
shall be audited at least annually or at least once
within the lifs of the activity, whichever is shorter."
Contrary to the above, annual vendor audits were not
performed in that initiation was not timely and/or
intervals were too large in all twelve (12)
. organizations examined between 1976 and 1984.
This is a QA/QC program deviation. The NRC finding in
this area was substantiated.
Corrective action was taken in DAP-CS-4, Revision 11,
issuedacceptable.
found in November 1984. This has been reviewed and
g - f NRC Notice of Violation (445/8432-03, 446/8411-03)
stated that the W site organization was not audited
between 1971 and 1981.
It was determined that the natu're of the work
activities for the W site organization did not involve
control of safety-related activities and therefore is
'
not required to be included in the audit schedule,
accordingly, this NRC Finding was not substantiated.
$' - ANSI N45.2.12-1973, paragraph 5.3, states in part,
" Planning of the audit system shall be conducted to
assure covers'ge of the applicable quality assurance
program . . . and in paragraph 3.4.2, " Audits shall
. . . assure conformance with the developed and
implemented program."
Contrary to the above, audit checklists were developed
from existing procedures rather than governing
requirements for the u.ajority of audits reviewed. For
example, no assessment of the written program adequacy
was performed in areas of non-confor'. nance or corrective
action or QC Training / Qualification / Certification.
_ _ _ , _ _ _ ,_ ___ __ _ _ _ - - - - - - - - - " - - - - - ' - - __-
:
-
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*
Page 44 of 53
;
;
'
S
f,
' RESULTS REPORT
Ih ISAP VII.a.4
{
,, J (Cont'd)
.
)
<..
J
l
@f LDfENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
This is a QA/QC Program Devfation.
Corrective action consists of use of an " Appendix B
checklist". This has been reviewed and found
acceptable. However, for program enhancement, DQP-AG-2
.hould be revised to reflect use of this checklist.
y' ' -
Checklists did not provide verification that procedures
:n different systems were consistent for the same
'
;.
.
N
activities performed by different organizations.
*
,
This is not a QA/QC Program Deviation.
,
Gf' - ANSI N45.2.12-1973, paragraph 1.5.1, states in part.
"[An] Audit [is) a formal documented activity performed
in accordance with written procedures or checklists to !
verify, by evaluation of objective avidence that a
quality assurance program has been . . . implemented in
accordance with applicable requirements of ANSI N45.2.
Contrary to the above,.the audit preparation phase was
less than adequate because audits did not provide
sufficient checking of program adequacy for the
activities being audited and resulted in incomplete
evaluation of the adequacy of the overall QA/QC
program.
ThisisaQA/QCProgramDeviation.
Corrective action consists of the use of an " Appendix B
Checklist." This has been reviewed and found
acceptable. However, for program enhancement, it is
recommended that procedure DQP-AG-2 be revised to
ref1act the use of this checklist.
/ Q- ANSI N45.2.12-1973, paragraph 4.2.2, states in part,
responsibilities (of the audit team leader) include
orientation of the team, . . . assuring communications
within the team and with the organization being audited,
participation in the audit performance, and coordinating the
preparation and issuance of reports."
l
i
t
l
_ - _ _ _
~ . .w. .. w;
' ~ -
Revision: 1
y Pass 45 of 53
D
)
.(51$h
-
' ivy *
RESULTS REPORT
'
Ye ISAP VII.a.4 ,
(Cont'd) )
-
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
'
ANSI N45.2.23-1978, paragraph 1.1, states in part
" requirements . . . for the qualification of audit team
leaders, henceforth identified as a " Lead Auditors", who
organizes and directs audits, report audit findings, and
evaluates corrective action."
Contrary to the above, Lead Auditor candidates were ,
designated as acting team leaders (with signature I'
authority).
i
This is a QA/QC Program Deviation.
.
Corrective action was taken in DQP-CS-3, Revision 12, *
issued in February 1985. This has been reviewed and i
found acceptable.
[[* - ANSI N45.2.12-1973, paragraph 4.4, states in part "An
audit report shall be written and signed by the audit
team leader which provides:
-- Description of the audit scope
- A summary of audit results including an
evaluation statement regarding the
effectiveness of the QA program elemects
which were audited."
Contrary to the above, audit reports did not include
scope description and evaluation statements.
This is a QA/QC Program Deviation.
Corrective action was taken in CQI-CS-4.6, Revision 0,
issued in July 1981. This has been reviewed and found
acceptable.
-
Audit files contain instances of:
~~
--
Field notes on identified conditions that are
not properly addressed in the final report.
t
--
Checklists that are not completed.
I
l
l
1
l
i
i
i
.
. . . . . ._
_ _ _ - - - . _ _ _ - _ _ _ _
u -
^*
Revision: 1
Page 46 of 53
RESULTS REPORT
ISAP VII.a.4 :
(Cont'd)
{
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Qg .
,U
This is not a QA/QC Program deviation, but indicates I
.
.m im
C I hplementationweaknessesinthatthedocumentedrecord
, as not reflect all actions of the audit team.
Q- ANSI N45.2.12-1973, paragraph 4.4, state.s in part,
" Distribution of the [ audit] report shall include I
responsible management."
Contrary to the above, original recipients did not
always receive subsequent ecrrespcudence related to
follow-up and closeout of audit reports.
This is a QA/QC Program Deviation. *
Corrective action was taken in DQP-AG-5, Revision 0,
dated September 9, 1985. This has been reviewed and
found acceptable. However, for program enhancement,
applicable procedures should be revised to define the
addressees and minimum distribution for audit reports.
/-@ -
'
ANSI N45.2.12-1973, paragraph 4.5, states in part,
" Follow-up action shall be performed by the audit team
leader or management of the auditing organiu tion to:
. . . confirm that corrective action is accomplished as
scheduled."
Contrary to the above, QA verification of timeliness of
closeout was unsatisfactory although audit personnel
believed that actual implementation of corrective
action was timely.
This is a QA/QC Program Deviation. The NRC finding in
this area was substantiated.
Corrective action was taken in DQI-AG-1.8, Revision 0,
issued in Juna 1985. This has been reviewed and found
acceptable.
Audit Personnel Qualifications
1 -
The procedure for qualification of audit personnel
contained weaknesses in that, for example, '
j --
g
OJT could be performed under qualified
auditors in addition to Lead Auditors.
!
;
!
___________-
_ _ - _ - - - _ -
, , . .. ... - . - . . -
-
! L '. . Rsvision: 1
.y. ;.s ~ .9 Paga 47 of 53
. .: ...
. I.7 ?~
RESULTS REPORT
u<
.'.
'
ISAP VII.a.4
% (Cont'd)
$U
'
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) j
'
--
The required reading list was incomplete.
'
! --
There was no stated requirement to retain
,
;
information pertaining to examinations.
-
!
This is not a QA/QC Program Deviation.
I
When procedure DQP-QA-2, Revision 11 was issued in
]ecember1985,theweaknesseswereeliminated.
-
[Six(6)auditpersonnelqualificationfilesinthe
,
i period prior to June 1983 are incomplete. .
!
This is not a QA/QC Program Deviation.
[ y' - ANSI N45.2.23-1978, Paragraph 4.2, states in part, "The
*
development and administration of the examination for
1ead auditor . . . is the responsibility of the
employer. . ."
,
Contrary to the above, at least three members of the
current audit staff have been certified as Lead
Auditors by TUGCO, but have not been administered an
examination by, or for, TUGCO.
This is a QA/QC Program Deviation.
It is recommended that these personnel, and any others
currently cerf.ified who did not meet the requirements,
be administered an examination in accordance with the
require'eents of the standard.
5.4 Trend Analysis
A total of fourteen (14) QA/QC Program Deviations were
identified. These findings are characterized as failures to
fully translate audit program requirements into the procedures
used to implement the program.- This can also be characterized
as a lack of specificity in the CPSES implementing
procedures.. This therefore resulted in a failure to properly
implement the audit program. <
Because each of the deviations can be traced to inadequacy of !
procedures, this has been determined to constitute a trend.
Therefore a trend analysis has been' performed in accordance
with Appendix E of the CFRT Program Plan.
1
I
..
.l
, ,, -._ . - -
4 +
Rsvision: I
f' Page 48 of 53
+ ,
RESULTS REPORT
ISAP VII.a.4
(Cont'd)
.,
'
5.0 IMPLEMENTAT::0N OF ACTION PLAN AND D,ISCUSSION .0F RESULTS (Cont'd)
None of the deviatione described in Section 5.3, taken
'
individually, is believed to represent a significant breakdown
in the audit program. However, taken collectively, there was
j
a potentiel for breakdown in the audit program. Therefore
this is considered to be a trend adverse to the audit program.
As noted previously, there is no direct connection between an
audit program and the quality of installed hardware. For this
reason, it cannot be concluded thtt this trend is an " adverse
trend" as defined by Section 3 of Appendix E of the CPRT
I
Program Plan. However, an. inadequate su M t program can fail
to identify weaknesses in the prescribed QA/QC programs that,
in turn could allow hardware problems to go undetected. For
this reason the RTL has determined that a root cause and
generic implications analysis shot.id be performed. -
5.5 .oot C D and Generic Implication Evaluation
The NRC findings led to two hypothesized root causes which
were: 1) TUEC's audit procedures did not comply with NRC
requirements and 2) the program was not implemented in
accordance with procedures. The CPRT evaluation 41so found
instances of failure to implement governing requirements
properly, but in each case this was traced to a lack of
specificity in the implementing procedures for the CPSES
Quality Assurance Audit Program. Therefore, all substantiated
findings can be traced to the h of NRC's hypothesized root
_causes. Asdiscussedbelow,[CPRTinvestigationhasshownthat]
,\ f
the lack of procedural compliance with NRC requirements was
% caused by lack of a management system which would provide for
{ l
overall coordination and control of project activities and
provide a consistent mechanism for translation of governing
.
i
j
requirements into implementing proceduros and by failure to l
j periodically check program procedures against program l
!
requirements and commitments. This lack of procedural i
j
compliance remained uncorrected because of the apparent lack
f of full appreciation by threvioD TUEC management of the role
I of an effective QA Audit Program in ensuring the overall
effectiveness of the CPSES QA Program and therefore is
considered,to.be the p t cause. f
-
The generic implications of this root cause will be eval _uated_
duri6g the condiTct of tither ASAFs and v11A De Considered
during the collective evaluation phase of the QA/QC Program.
!
. _ _ _ _ - _ _ _ _ _ - - _ - _ _ _ - _
_ _ _ _ _ _ - _ . _ _ -
. . . . -
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l
RESULTS REPORT
{
ISAP VII.a.4 I
(Cont'd) )
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
A (substantive c5'r.tribut o r cau,s3 for the lack of a full
assessment or cne completeness of QA Audit Program
implementing procedures is determined to be the lack of a
* procedural hierarchy for CPSES. A procedural hierarchy would
provide for at least one additional eier of erocedures which
would nrnvida a-bridge feos ths.reautr Qs doents to the
$glemanring nrecedures, and in additien would provide T "
vehicle for management to describe the overall coordination
; and control of project activities and organizations for topics
such as the following:
-
Interpretation and application of commitments to codes,
standards and regulations,
;
i
j -
Definition and application of self-imposed I
i' requirements.
.
-
Standardization of terminology and definitions,
-
Delineation of responsibilities.
-
Description and responsibility of organizational
interfaces and ,
!
-
Structure and content of sub-tier procedures. j
A (irotential neneric unIse= g is that the types of
procedural inadequacies identified in the audit program may 1
, exist in other procedure systems at CPSES. The lack of an !
!
upper tier of procedures covering the topics identified above !
leads tg prorsfure_ development by each organization without
_
,
formal corp _ orate guidance or for==1 coordination between
j' organizations. Further investigation is required to determine !
;
if this lack of standardization contributed to similar
procedure inadequacies in other areas or organizations.
Purther investigation is beyond the scope of this action plan
and will be addressed as part of Collective Evaluation of the
Constructi6n'QIl@~~ Program using information from this and
~
other ISAPs.
Corrective actions related to the adequacy of the current
CPSES QA Audit Program have been identified. Additional
actions to prevent future occurrence of similar deviations or
programmatic weaknesses are discussed in Section 8.0 below.
.
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Revision: 1 I
Page 50 of 53
l
)
1
RESULTS REPORT
ISAP VII.a.4
(Cont'd)
?r
6.0 . CONCLUSIONS
Section 4.1.2.3 of ISAP VII.a.4 describes conditional steps that
were to be performed depending on the results of revious and
evaluations. Although audit program deviations and weaknesses
related to construction activities were identified, it has been j
determined'that no action is required beyond that specified in l
ISAP VII.c, which addresses all areas of safety-related hardware
and is intended to provide confidence that any currently
unidentified concerns related to the quality of construction of the l
CPSES hardware vill have been identified, evaluated and resolved.
Therefore, no additional programs or plans were developed to
address this area. Audit program deviations applicable to off-site
TUGC0 suppliers were also idencified. During the investigation and
evaluation of the impact of these deviations, sufficient *
information was obtained to provide confidence that the i
acceptability of the suppliers' quality assurance' programs for the I
applicable equipment and services could be. and was. evaluated bV
TUGC0 during the periods in cuestion. Therafara. nn m uieinna_1
programs or plans yeta_da.y. eloped en daemmina the acceptability of'
the suppliers' qqality_ assurance nrogr=== h==ed on the afforts of ,
QI.heg,o
1
As a result of this review of the TUGC0 QA audit program, it has
8
-p been determined that at no time has the written program been in
, (yll compliance with moverning stancarna =nn regulatory guidatice,
-
and in addition has exhibited other weaknesses as described in this
report. This determination substantiated the TRT finding that
".. . . TUEC's audit procedures did not comply with NRC
requirements."
The ov,erall_ effectiveness of the_.audie evenram_h== han g
fully adequate. Specific examples ares it has failed to identify
I' and cause corrective action of inadequacies in such areas as QC
inspector training, qualification, and certification; and control
i
of non-conforming items and corrective action. It is concluded,
from the evidence observed, that the failure to identify and cause
corrective' action in these two areas was due primarily to the
practice of auditing to existing procedures while not performing
verification of the adequacy of existing procedures to implement
program requirements. It fS further concluded that the cause of
the deviations and weaknesses in the QA audit program which have
been identified in this report are the result of inadequate
procedures. This resulted from the lack of a procedure hierarchy
which would have provided for overall coordination and control of
project activities and organizations by set..or management for
topics such as the following:
.
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Revision: 1
Page 51 of 53
*
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RESULTS REPORT
ISAP VII.a.4 d
1
(Cont'd)
6.0 . CONCLUSIONS (Cont'd) 1
-
Interpretation and application of commitments to codes,
standards and regulations,
-
Definition and application of self-imposed requirements,
-
Standardization of terminology and definitions. I
-
Delineation of responsibilities.
-
Description and responsibility of organizational interfaces
and
- _ Structure and content of sub-tier procedures. -
,
Based on the written record the overall competency of the audit
!
personnel appears to be adequate to perform the required audits for
the design, construction, and operation phases of CPSES. Except as
previously noted, the program for qualification of audit personnel
is considered to have been adequate,.although TUGC0 was slow to
recognize and incorporate applicable standards and guidance
available to the nuclear industry. ;
The NRC TRT and Region IV findings concerning auditor staffing and
qualifications during 1981, 1982, and 1983 could be considered-
valid if the program had been totally dependent on the personnel
assigned to the permanent audit staff. However, in light of the
total number.gp b uslificatio.no of personnel available to._and
utilized _ inn the_apd1t. program. tha_a.udit se,aff is considered both
p . p%(- adequate and qualified,
~
Audit planning and scheduling,.though in the past not in compliance
regarding frequency and not formally systematized until recently,
did appear to be well thought out in the context of the TUGC0
concept of the audit program requirements at any particular time.
However, due to the-lack of a procedure hierarchy which would
provide a firm basis for the development of implementing
procedures. the effectiveness of the audit program to determine the
.
adequacy of the construction QA program was less than desirable.
There is evidence that appropriate consideration has been given to
input from sources such as NRC inspections, previous audits, and
surveillance.
Except as noted, the findinas pertaining to scheduling of audit
frequency are valid. Appropriate procedures have been revised,
which now properly address scheduling of audit frequency.
.
g.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - _ _ _ _ _ _ _ _ _ . _ - _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ . . _ _ _ _ _ _ _ _ _
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Revisica: 1
Page S2 of S3 i
RESULTS REPORT
ISAP VII.a.4
(Cont'd)
6.0 CONCLUSIONS (Cont'd)
!
The current written program for auditing and audit personnel J
qualification is in compliance with applicable requirements except
in the following areas
-
Definition of responsibility for the audit program in the FSAR ;
1
-
Definition of responsibilities of the audited organization 1
!
In addition, at least three currently certified lead auditors have $
not been administered an examination by or for TUGCO.
Appropriate corrective action should be taken in these areas.
.
".0 ONGOING ACTIVITIES
l
The Audit Program and procedures discussed in this report are i
applicable to the remaining construction phase on Unit 2 and for
the operating phase of the plant.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE
To prevent future occurrence of the same or similar deviations and
weaknesses in the QA audit program (or other portions of the CPSES
program) management, particularly senior management (Vice President
and above), must actively participate in the program and be kept ,
appraised of audit program results.
;
1
This may be accomplished through development of a hierarchy of
'
procedures as described in Section 6.0 of thns report. This would
provide the necessary standards and management controls under which
the overall program can be effectively defintd and Laplemented. In
addition, the procedures should provide for direct senior
management participation in the audit program in areas such as
audit planning and scheduling, and resolution of progrannatic
problems.
i
Management at all levels must utilize the output of the audit
program (audit reports, summaries, trend analyses, etc.) to
evaluate _the adequacy and effectiveness of their portion of the QA
program. This should be A:complished by developing requirements
for appropriate participation in the development of corrective
action for identified deficiencies, and follow-up to ensure that
the corrective action has been effectively implemented.
- - - _ _ _ _ _ _ _ - - _ _ _ _ _ - _ _ - - - _ - _ _
_ _ _ _ _ _ _ _ - - _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
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Revisien: 1
Page 53 of 53
RESITLTS REPORT
ISAP VII.a.4
(Cont'd)
6.0 CONCLUSIONS (Cont'd)
i In addition, an independent, periodic assessment of the audit i
program is essential to provide Senior managemest with timely
!
identification and corrective action of deficiencies or weaknesses
in the audit program. Such a program will be definei in ISAP
-
VII.a.5.
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f
In Reply Refer 'I o g
DR/4FT 1 ;
Docket: 50-445/G6-ue 6/30/86 '
50-446/86-06
l
Texas Utilitius Generatriu4 Looy mi y
ATTN Mr. W. G. Counr,11
Executi ve Vice Presi dent .
400 North Olive, L.D. 81
Dallas, TX 75201
!
)
Gentlemen ,
This' ref ers to the construction inspection conducted by Mr. H. S.
Phillips anci other members ai the Reqion IV Comancho Pool: Group during
the pet-fod April 1'through May 31. 1WE, rei activities authori::ed by NRL.
Construction
Electric Permito
Station. CPPR-126
Unsts 1 and and Cf'FR-127 for the Comanche Peak Steam
2. arid to the di scussi .. of ou t- findings
with yo and other members et your utalf at the conclusion of the
inspection. 1
Areas of constructi on euenia smd dur a ng the inspection included a revieu o;
activities, action on previous findings, plant status, Brown & Root
audits
and pipeof siteoractivitiec,
supp t s / r es t r el
a i ect i i cn1 cab l e /i n strument ati on i nst al l at i on ,
n t s., N i i hi r. these areas, the inspection
consi st cr2 of sel ecti ve enaminct i nn of procedures and representative
records, intervi ewn wi th persor.nal , and observations by the inspectors.
The inspection findings are docunser.t eri in the enclosed inspection repor-t
During this inspection, it was (cund that certain of your activities worn
in viol ati on o f NRC rerpi a ronie .11 r . I 1.nt.e quer tl y,
you are required to
respond to theno violationu, a is wit.ing, in accordance with the
provisions
Title 10. Code of Section
of Federal 2.201
Regul ofatthe NPL + " Rules of Practice," Part 2,
i ons.. l
the specifien contained Your response should be based on
. letter. in the 1.ot. ice of Violation enclosed with this
?
Also duri.ng this i nspec t i ori, it was found that certain of your activi tier
appeared
the NRC. to deviate from accepted industry standards / commitments made to
These items and rei erenCFs lo the standards / commitments are
i de~.t i f i ed in the enclosed Notice of Deviation. You are requested to
respond to these deviations in writino. Your response should be based of
the specifics contained thc the Ikitice of Deviation enclosed with this
letter.
We have also
identified enaminedfindings.
inspection eitt i orin you have takent with regard to previously
in paragraph 3 of the enc]oned rrport. the status,of these items is identified l
EXHIBIT 3')
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The response directed by thic l et ter and the accompanying Notice is not
subject to the clearance procedurea c, F the Office of Management and
Budget as required by the Paperuor L F. eduction Act of 1980, PL 96-511.
Should you have any qua k,t i en ts concerning this inspection, we will bo
pleased to discuss them with ycu.
Si nc er el y,
.
E. H. Johnson, Director
Division of Reactor Saf ety
and Projects
Enclosures:
1. Appendix A - Notico o; Violation
2. Appendi:. D - Natica of Di.'v2 a t 2 on
3. Appendix C - NRC Inspection Hrport j
'
50-445/86-08
50-446/86-06
cc w/ enclosure:
Texas Utili ti es Electric Con.p a n y
ATTN: J. W. Doc 6 , Monar a .,
'
Licensing
Skyway Tower
400 North Olive Street
Lock Box 81 ,
Dallas, Texas 75201 ]
j
Juanita Ellis }
i
President - CASE
1426 South Polk Street
Dal 1 as. Tenas 75224
Renea Hicks i
Assistant Attorney General
Environmental Protection !
Division
F O. Box 12548 -
Austin, Texas 78711-2548 f
'
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Texar, Radiation Control Program Director l
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, - .,
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4
ShtWM h A.
NOT1,CL OF VIOLATION
Texas-Utilitien Generating Company- Dockets: 50-445/86-08
50-446/86-06
Comancho Peak' Steam Elactric Permits: CPPR-126
Station, Units 1 and 2 CPPR-127
'
During an NRC inspection conducted on April 1-May 31, 1986
L violations of . NRC requi rements were identified. The violations: involved;
Texas Utilities Generating Company's (TUGCo) f ailure to take ef f ective
~
and comprehensive correcti vo action on- audit program deficiencies;
failuretof' Brown & Root Inc. to perform annual audits of the entire QA
program during 1980, 1902, and l'?N; 'i ailure of BLR to audit the OA
Manual and implementing-procedures to a sufficient depth to assure
control of field design changos, special processes, and inspecti on
'activitie from 1980 through 1985; failure of B&R to develop / usa
checklists which provide objective evidence of compliance;' failure to
: adequately audit.special prococcas inside the reactor,' auxillary,
>
safeguaros and diesel generator buiIdings from 1980-1985; failure of BLR
to correct" audit program defi ci enci es i dentified by consultant audi ts
which remained deficient from 19Bv- 1 ?B;5 ; failure of BLR-to correct
deficiencies idontiFied in audit Cf' in; failure of TUGCo to address
. instrument installation criteria in a procedure; and failure of TUGCo to
adequatel y t f ollowup' on the corecct i ve action commitmentsEfor an audit-
deficiency. . In accordance wit h iho " General Statement.of Policy and
Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985),
the1 violations are listed below
' A '.'
Criterion XVI of Append 1: D to 10 dFR Part 50, as implemented by
Final Safety Analysis Report (FSAR) Section 17.1.16 and Texas
y
Utilities Generating Company (TUGCO) Quality Assurance Plan (QAP)
Section 16.0, Revision 0, dated July 1, 1978, requires that
d\ conditions adverse to quality be promptly identified, reported, and
corrected.
FSAR Section 17.1.16,: " corrective Action", states that TUGCo
requires that measures be established to assure that condi% ions
adverse to quality are promptly identified, reported, and corrected. !
Responsibility f or perf orming corrective action is assigned to !
contractors, applicable subcontractors, and vendors so that each is
alert to those conditions advel se to quality within his own area of l
, activity.
4
1. TUGCo f ailed to take adequato and ef f ective corrective action
concerning audit def ic: encies identified in P.S. Lobbin (a
consul ting engineer for IUGCo) Report dated February 4, 1982
concerning the site audit programs which included contractor
audit programs.
.
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, - - - - _
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2.
TUGCo f ailed to tal.c coa.orehensive corrective action
concerni ng si te contractors' audit programs after the NRC
g
' Construction Appraisal Team (CAT) report dated April 11, 1983
" found that a site contractor *s audit program had been
inef f ecti ve 'in ' detecting and obtaining corrective action in 1
{
saf ety rel ated mechanical end electrical components f or -
heating, ventilation, and air conditioning (HVAC). That is, j
TUGCo did not adequatel y evaluate other site contractors' audit .j
programs (including' the Brown and Root Inc. site audit program) i
to asrure that similar deficiencies did not exist in other
areas cf the site audit program. f
~
As a result of TUGCo's failure to take adequate corrective
. action on audit deficier.cies identified but not limited'to the {
above examples, the EhF: raudi t program has been deficient f rom-
1980 through 1986 as evidenced by the ncncompliances described .j
in Violations ft anr1 L Mjow and Deviation No. 2 in Appendix D
Notice of Deviation. l
L
This i's a Severity Level IV v2 ol ation (Supplement'II)
(445/8608-V-01; 446/0606-V-01).
*
B.
Cri t eriQAP
TUGCo on XVIII of1Appendi:.
Section D in 10 CFR Part 50 as implemented by
U. u, Ravamlan *
Section 17.0, requi res that a
~,
dated July,31, 1984 and FSAR
ca.hprehensi ve system of planned and
periodic audits shall be em ried out to verif y compli&a ze wi th all
aspects of the qualit y encurance program to determine the
effectiveness of the program and be performed in accordance with
procedures or check 12stz, r ebu l t t., be documented, and followu~p-
action, including roaudit. o+ dolicient areas, shall be takon.
1.
FSAR Section 17.1.18, "nudits", requires that planned and
peri edi e audi ts bo per1 aru.cd to vertfy compliance with all
aspects of the quality
effectiveness. abcurance program and to determine the ,
.
Brown k Root. Inc. DA danual Section 19.0 issued September
17,1981 and impl ementi ng procedures DAP-18.1 dated July 14,
1975 and subcequent revits ans and CP-QAP-19.1 dated October
15,1984
(which superceded DAP-18.1) require the B&R DA manager
to assure that the untire UA program is audited annually.
Contrary to the above, Brown & Root Inc..faile'd to audit the
entire A9ME/DA program to determine program effectiveness for
calendar years 1980, 1982, and 1984. (445/8608-V-04;
441,8606-V-04)
2. FSAR Section 17.1.5, " Instructions, Procedures, and 1
Drawings", requires that safety related activities be
ac compl i shed in accordance with
these documents and through
auditing, as described in 17.1.18, TUGCo determines that i
.
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quality related acti vi t s en are accomplished in accordance with i
q
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those approved instruction, procedures, and drawings,
BLR CA Manual Section 19.0 issued September 17, 1981 requires
1'
that measures be established for an audit program that will
provide _ objective evidence of compliance with the QA manual;
compliance with pertinent specifications, codes, and
l procedures; and a method of keeping management informed of DA
program effectiveness.
Contrary to the abovo' BLR f ailed to adequately audit the sito
ASME DA manual, specifications, codes, and procedures to assun
OA program of f ectivcness as f ollows (445/8608-V-08;
446/8606-V-OS):
a. BLR f ailed to audit the QA Manual and procedures; i.e., I
Audi t CP--17 (1YSU) todicated that neither the QA Manual
nor implementing procedures for design control (f i el d
changes) and the Authori:*ed Inspector interface activitini
were audited. Al so, the B&R auditors informed management
in this report that the area of material traceability for
'
hanger and component support modification (related to
speci al procemr.oc and design control) were not
suf f i ci en t l y audsted to assure compliance with applicable
i codes and standards. There is no evidence that these
arean r ec ei vr>d emphasi s duri ng (subsequent) audits.
b. BLR failed to aucht- t r.a OA manual and procedures; i.e.,
BOR QA Manual Sectien 4.U; " Design Control" issued
September 17,1981 and implementing procedures for field
changes which were in effect from 1980 through 1985 were
not audited to softicient depth and were not audited at
all in 1980 and 1905. The audit reports f or this 6 year
period do not document the audit of any implementing
procedtres; 1.s., CP-CPM-4.1 (1981) " Construction Request
for Engineering Design Changes"; CP-CPM-9.13 (1984,
Revision 10) " Modification of Vendor Supplied Catolog
Item"; GCP (no date) " Control of Field Sketches"; WEI 4.6 ;
(1982) "Instructao: for Control of Welding Engineering
CMC's"; and CP-QAP-04.01 (1983) " Program for
Repair /Alterr.tlon ci hBMC-N Stamped Components".
.
l
c.
BLR failed to audit the DA manual and procedures; i.e.,
BLR DA Manual Section 10.0 " Control of Special Processes" j
issued September 17,1981 and implementing procedures which I
were in effect from 1980-1985 were not audited to
sufficient depth and were not audited at all in 1984. The
audit reports for this 6 year period reference !
approximately 12 (UA manual sections, procedures, and I
construction procedures) of 75 applicable project {
documents (less may have been audited) . This activity
1
represents a large part of the ASME work acti vi ty '
.
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perf ormed ior 1UGCo and a partial audit of less than 3% ot
the project documents pur year is too low f or this ,
important work act a vi ty. !
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d.
BLR f ailed to audit the QA manual and procedures; i.e.,
BLR.QA Manual Section 11.0, " Examination, Tests, and
Inspections", issued September 17, 1981 and implementing
. procedures which were in effect from 1980 through 1985
were not audited to suf ficient depth and were not audited
at all in 1980. ~f he audi t reports f or this 6 year peri od
references 8 of SS applicable project documents (less may
have been audited). Th2s ASME work activity represents c' I
large amount of work done for TUGCo and partial audit of
}}