ML20134G031
| ML20134G031 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/05/1985 |
| From: | Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| Shared Package | |
| ML20134E873 | List: |
| References | |
| NUDOCS 8508220293 | |
| Download: ML20134G031 (264) | |
Text
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=O O e g UNITED STATES y' - ', NUCLEAR REGULATORY COMMISSION REGION IV M 511 RYAN PLAZA DRIVE. SUITE 1000
- ARLINGTON TEXAS 70011 JUL 5 1985 _
/EMORANDUMFOR:V. S. Noonan, Comanche Peak Group FROM: R. P. Denise, Director, Division of Reactor Safety and Projects, Region IV
SUBJECT:
VISUAL INSPECTION OF PAINTED SUPPORT WELDS On July 2,1985, members of the RIV Conenche Peak Group met with representatives of TUGCo and its contractors to discuss the inspection of component support welds. The request to meet on this subject had been
. received during the previous June 26, 1985, site visit made by yourself, other TRT members, and members of the Region IV staff.
The applicant initially proposes not to remove paint from component support welds (ASME - NF and AWS) which are to be inspected as a part of their independent CPRT-QA/QC inspection effort.
The basis for not removing the paint from component support welds is that the CPRT third party visual weld reinspections are not inspections of record and that " safety 'significant deficiencies" can be adequately identified without ~
the removal of coatings as described in the attached position paper.
Region IV indicated during the meeting that a limited sample of welds with the paint removed may be necessary. We believe the applicant would be amenable to this position. The applicant is hesitant to remove paint since it is epoxy based. Removal and repairs are difficult with epoxy based paint.
The applicant requested an early decision from the NRC regarding the acceptability of not removing paint from structural component welds prior to performing visual inspection.
Region IV did indicate that we would try to respond by July 12, 1985. We plan to respond by letter and to document followup of this issue in our monthly inspection reports. Region IV will utilize IE resources, including the Region I t
NDE van as required, to ensure a complete program.
{
I am requesting that the TRT review the attached position paper and provide comments to Region IV regarding the acceptability of performing visual inspection of component structural painted welds. Region IV has
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V. S. Noonan 2 considerable past experience at Wolf Creek in this same issue; how6ver, I do not feel that Region IV should be setting agency standards in this matter. I would recommend that the TRT interface with I&E on this matter. -
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. N j R. P. Denise, Director Division of Reactor Safety and Projects I' Attachments:
- 1. Attendancy list July 2, 1985 meeting
- 2. Position Paper on Visual Inspection of Painted Structural Welds .
'c'c w/o enclosures:
R. Martin, RIV J. Taylor IE R. Heishman, IE H. Denton, NKK.
D. Eisenhutt, NRR m p 4
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ATTACHMENT 1 July 2,1985 Meeting to Discuss Visual Inspection of Painted Structural Welds Attendees .
j Name Company Tom Westerman NRC Region IV Clif Hale NRC Region IV Terry G. Tyler ENERGEX - CPRT Program Director Andrea Burke ERC - Welding Engineer Kim Keller PDS - Mechanical Engineer Claude Moehlman TUGCo H. F. Faery, Jr. Stone & Webster Douglas Snow B&R - QA/QC Lee Ellershaw NRC Region IV i Jon Christensen ERC - Deputy QA/QC Review Team Leader Don Ellis Stone & Webster - Chief, Materials Engineering A. A. Patters ERC - Reinspection Engineering Supervisor l
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FCSITION PAPER ON VISUAL INSPECTION OF SUPPCRT WELDS I
_ _ . _ . . 4 STONE & WEBSTER
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POSITION PAPER ON VISUAL INSPECTION OF SUPPORT WELDS i
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- Sopy to:
JChristenson(ERC) R8 Kelly APatterson(CPSES/ERC) DEEllis RBrown(CPSES/ERC) KReinschmidt ABurke(CPSES/ERC) VHoffman CPSES/ERC File Chrono File /JGalla HFFaery/CFReeves/mt l
J.L. Hansel June 17, 1985 l VP, Engineering Services j Evaluation Research Corporation J.O. 15297.00
! c/o Texas Utilities Generating Company Conanche Peak Steam Electric Station Farm Road 201 Glen Rose, TX 76043 POSITION PAPER ON VISUAL INSPECTION 0F PAINTED SUPPORT WELDS 4
The attached position paper is forwarded for your consideration. Our evaluation is based on the premise that a third party visual weld reinspection of :cmpleted and accepted component supports are not inspections of record.
These reinspecticns are a third party overview to provide reasonable assurance that no safety significant deficiencies exist with respect to component support welds (ASME-NF and AWS). We conclude, therefore, that such reinspections can adecuately be accomplished without removal of the coatings from the weld.
Should you need further assistance, please do not hesitate to contact us.
i C.F. Reeves H.F. Faery O'nsulting Engineer Assistant Chief Engineer NOT Division c a i c ; x n.
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o, - a Reevaluation of Component Support Welds Through Paint INTRODUCTION A decision has been made to evaluate previously-inspected and accepted safety-related construction work at the Comanche Peak Steam Electric Station '
(CPSES). Systems under reev.aluation will include component supports ( ASME and AWS), for piping, electrical raceways, HVAC. This paper is directed at the reevaluation of the welding associated with these component supports. The component supports being evaluated have been erected, subjected to in process and final acceptance inspection, may have received final protective coatings, and been released for testing along with the associated components. On the basis of this evaluation performed at CPSES it has been concluded that visual reevaluation of the aforementioned welds can be done without the removal of the coatings. This discussion centers on that matter and provides the rationale and justification for this conclusion. It should be noted that welds associated with pressure boundaries, such as piping welds and the containment liner welds, are not included. Included in this paper are treat-ments of: findings of the NRC Technical Review Team (TRT); analysis of paint thickness; findings of other independent reviews; weld attributes associated with visual reevaluation; and comments on welding history for the site.
Attributes for Evaluation of Weldino of Component Supports Ccmponent support welds are designed, installed, and inspected in accordance with the ASM2 Code (for pipe supports) or the AWS Code (for other component supports). Each code contains requirements for the performance of work. In the case of component supports, both codes stipulate acceptance by visual inspection. Volumetric examination or other nondestructive testing is not 1
applicable to the component supports.
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Component support welds are not, and are not classified as, pressure retaining welds. The critical attributes for such welds are those related to weld i
strength. The following attributes fall into this category:
o weld existence and location o undercut a length and size o lack of fusion (usually associated
- o cracking with overlap) .
All of these attributes, with the exception of cracking, are detectable and measurable through a paint coating. Fine cracking (which occurred prior to painting), if unrepaired, may not be detectible in a visual inspection of coated welds. However, cracking with displacement would likely not be hidden by a paint coating; and cracks occurring after paint application would likely be highlighted by the coating itself.
The remaining inspection attributes nonnally addressed in a visual weld !
inspection are directly visible, and in most cases, measureable under coatings of the type and thickness used at CPSES. Such attributes are:
! o craters a weld profile o are strikes o slag and spatter o porosity Effect cf Coatings The coating system used on component supports at CPSES consists of a primer and final coatings as shown in Appendix 1.
A recent investigation of paint thickness on raceway supports (Appendix 2) conclude.s that the average paint film thickness is approximately 10 mils.
- Further, there is a 99.9 percent degree of certainty that less than 1 percent of the welds could have a paint thickness in excess of 20 mils. A small sample of film thickness taken for this evaluation tends to support these findings (Appendix 3).
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s i For measurements which are related to weld strength, such as weld size and
,. s undercut, variations due to a 10 to 20 mil film thickness appear to be insignificant, falling in the range of 1/64 inch or less. In fact, coatings on the weld will normally introduce a measure of conservatism in inspection results. Measurement of a properly sized weld that has t'een coated may
) indicate that the weld is undersized, when in fact that i; not the case.
Significant undercut, porosity, and overlap conditions appear to be ,
detectable under a coating of the type found at CPSES.
The Technical Review Team Report and Other Independent Reviews In July 1984 the TRT conducted an investigation of allegations related to improper construction practices at Comanche Peak. Part of that investigation was concerned with welding in "as-built" piping and electrical raceway supports. NRC inspectors made visual inspections of these support welds in both the coated and the uncoated condition. Pipe support welds were evaluated on the basis of the ASME Code Section III, NF and Brown and Root Quality Instruction criteria. Electrical raceway support welds were inspected to AWS 01.1 acceptance criteria. The inspection results are summarized below: '
o Pipe supports (389 welds inspected including 89 painted) i a r Attribute Frequency of Unsatisfactory Occurrence !
l porosity 1 (size unspecified)
I incomplete weld 1 omitted weld 1
] undersize fillet weld 4 (1/32 - 1/16 undersize) !
I excessive grinding of 2 base metal undercut 1 4
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o o Electrical Raceway Supports (59 welds inspected) w Attribute Frequency of Unsatisfactory Occurrence i
undersized fillet welds 15 (1/32 - 3/32 undersize) l t
misplaced welds 2 The TRT report cited no evidence of significant generic weld deficiencies such as cracking or poor workmanship. Indeed, the most prevalent deficiency was fillet weld undersize, a readily detectable deficiency in either a painted or an unpainted condition. It should also be noted that the welds exhibiting porosity and undercut were detected by inspection through paint. Once detected, the TRT team requested that the paint be removed for confirmatory inspection (Appendix 4). Appendix 5 contains a copy of the TRT report.
t Several NRC reviews within the past two years have also addressed findings rele/ ant to the welding program at CPSES, and relevant to the conclusions outlined in this paper.
o A Construction Appraisal Team (CAT) inspection was conducted at C% in January-March 1983 (Appendix 6). It concluded that 1e program for welding, welder cualification, NDE and (twral training activities :
appeared to be effective and wall saninistered. This was supported by visual examinations. ..hrved NDE results and practices, witnessing ;
field weld- ',* process, and the general level of workmanship. The CAT f1 eegister concern with welding in the HVAC area by rejecting 45 percent of inspected welds. Once again it should be noted that these
- weld rejections were concerned primarily with undersized fillet welds.
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o Results of a Region I NDE inspection during April-May 1983 (Appendix 7)
- showed that material traceability and visual examination procedures were acceptable. The purpose of the inspection was to verify adequacy of welding quality control.
o A Special Review Team during April 1984 (Appendix 8) addressed the issue
, of welding materials control for safety-related piping system components 4
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in order to verify compliance with code requirements and good practice.
l* __ Specific attention was given to:
segregation, identification, and control of filler metals j -
oven storage of low hydrogen electrodes to limit moisture pick-up l l -
handling of returned filler metals !
documentation of current welder qualification limitations -
The review found no evidence of uncontrolled or improperly controlled welding f materials. The report stated that " licensee's welding material controls met l
l or exceeded cede requirements and good practice." i l
Within the past month another independent review has been conducted by i Evaluation Research Corporation (ERC) to ascertain the adequacy of the f welding procedures and controls employed at CPSES. Appendix 9 contains their l
i findings. In sumary the review found that '
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o Proper procedures were in place to protect the low hydrogen weld rod i
coatings through the use of heated ovens. Additionally, control ;
i measures were employed for both issuance and return of used rods to !
j nested storage. i 1
4 o Pre-heat procedures were established in accordance with the job j specifications.
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- o Records indicate that a well-established and controlled program existed '
for welder qualification, training, and certification.
i Another independent study has recently been completed by ERC in an attempt to
- develop a history of weld-related problems at CPSES. From a total population i of 21,067 nonconfonnance reports (NCR) (mechanical and electrical), a i statistically valid sample of 500 NCR's were evaluated for evidence of significant deficiencies relating to welding on supports. An analysis of this j sample indicates that cracks on support welds have not been a significant problem at Comanche Peak. This study further shows that porosity, undercut, i
and lack of fusion have also not been a significant noted deficiency, each one j
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0 o representing less than one percent of the total population of NCR's (Appendix s 10).
Metalluray The base materials used for supports at CPSES are ASTM A-36, A-500 Grade 8, A-588 Grade B, and A-240 Type 304 (Appendix 11). The first three are medium ,
carbon ferritic steels, and the latter an austenitic stainless steel. These materials are readily weldable, compatible with the electrodes used to make the welds, and normally produce welds which are not prone to cracking. Proper control of the low-hydrogen E 7018 electrodes will prevent moisture pick-up by the coatings of the electrodes, thus reducing any susceptibility to hydrogen-delayed cracking. Proper joint cleaning and preheat of thicker members are two other measures employed to promote diffusion of hydrogen from the weld metal. Type 304 stainless steel is not susceptible to hydrogen-delayed cracking. Additionally, the ferritic materials, including the E 7018 filler material, are manuf actured with the proper manganese-sulphur ratio to preclude hot (licuation) cracking. The most significant factor which could induce cracking with these materials is highly restrained joints. For the types of welds discussed herein, this condition is unlikely. In summary, from a metallurgical view there is no reason to suspect weld cracking problems given that proper procedures were followed.
Improper welding technique is instrumental in producing deficiencies such as fine porosity, overlap, and undercut. Fine porosity, a surface phenomenon, could be masked by coating but is of little significance if undetected.
Overlap, associated with lack of fusion, would normally be detectable under paint unless it is of short length. Short length could possibly indicate two conditions: limited or no lack of fusion; a mechanical notch, relevant only ,
for structures under fatigue type loads. As with oserlap, the presence of undercut is only significant where fatigue is a factor (or it violates minimum material thickness). Fatigue loading is normally not a f actor for the component supports under discussion, j
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Comanche Peak Reevaluation
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The ree<aluation effort relative to component support welds at Comanche Peak is not a product " final acceptance inspection." That has already been ;
accomplished. The purpcse of the reevaluation is to verify that original inspections and the product conform to design requirements. In light of this
, and the foregoing discussion, it is entirely appropriate that inspection of ,
i the accepted welds be accomplished through the applied coatings. Several [
facts support this decision -
I o With the exception of cracking, the attributes important to weld strength can be measured with adequate accuracy through paint. An independent analysis (Appendix 12) by an engineering laboratory addressed this same issue at two other nuclear plants, arriving at the same conclusion. -
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o Several independent and separate reviews of the welding procedures, welding materials control, and welding inspection documentation indicate no evidence of weld cracking nor any reason to suspect weld cracking as a generic issue.
o Given proper fit up and appropriate preheat, sound welding procedures, adequate welder qualification, and good workmanship, the materials used to produce component support welds at CPSES should provide sound, generically crack-free welds. Further, under these conditions, one i would expect to find minimal examples of porosity and undercut.
l o The welds at CPSES have already been inspected and accepted under bare metal conditions and under both the ASME and AWS codes. Deficiencies have been identified and appropriate corrective action taken. Although some deficiencies were found by the TRT, these were minor in nature and recognizable through paint.
o Removal of paint from welds can create problems detrimental to the personnel involved in the removal process and to other installed components in the plant. Chemical products are not recommended. They l
.. - . - - . - . . . . . ... _ . _ - . - - . - . - - . - . . - . - i
i are difficult to control and cleanup, and they are hazardous to
- personnel. Additionally, accidental exposure of austenitic stainless
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steel or nickel base alloy surfaces to these compounds can cause stress corrosion cracking if the compounds are not completely removed (Appendix 13). Mechanical cleaning can be used, but the removal process can mask certain defects, such as overlap, porosity, and possibly undercut.
j Removal of paint for a visual reevaluation imposes an inordinate 2 economic hardship on the Owner, and provides no significant improvement in the visual evaluation.
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o Recently, similar inspections were allowed by the NRC at Wolf Creek 1
1 Generating Station. Visual inspections of painted fillet welds were I
conducted on safety related structural steel through coatings of primer and topcoat. The subject welds had also been previously inspected and i accepted (Appendix 14).
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- Cenclusion i
i There does not appear to be evidence of a significant or generic problem associated either with the component support welds or the welding program at Comanche Peak. Significant strength-related weld attributes can be reliably evaluated through a paint coating. Accordingly, for previously inspected and accepted ASME-NF and AWS component support welds, visual reinspection through
- paint should provide adequate confidence that the weld will perform satisfactorily in service, i
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Appendices i i
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i 1. Paint Type and Application Technique
! 2. R.C. Iotti Memorandum on Paint Thickness Sampling 4 3. Singh Memorandum on Paint Thickness i
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- 4. Telecon inquiry to NRC l- 5. Technical Review Team Report ,
- 6. Construction Appraisal Inspection 50-445/83-18, 50-446/83-12 i 7. NRC Region I NDE Inpsection April 18-May 6,1983
- 8. Comanche Peak Special Review Team Report, April 3-13, 1984 i 9. ERC Evaluation t
- 10. NCR Review - Analysis of Sample Results '
- 11. Materials Employed for Supports and Welding at CPSES I l 12. Statement by Fritz Engineering Laboratory l 13. Removal of Paint Memorandum
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TEXAS UTILITIES GENERATING COMPANY OTT!CE MEMOR ANDUM 7, Pe;er 3r:wn/S.P. Singh - ERC May 28, 1935 cl.n Rose. Tens y a CW;CHE PEAX STEAM El.ECTRIC STATION Constructicn Adequacy i
The felicwing infor nation is being furnished as requested by B.P. Singh.
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! Pr: ducts.
l Usage Pr duct Thickness in Mils (DFT) ',
Primer Carbo Zinc #11 2-5 I i
Primer (re; airs only) Carboline 191 2-4 i To:c:at -
Phenotine 305 6-9 (total system)
J
- 2) Mafer =aterial types used for supports
l AST'f-A-36 l ASTM-A-500 Grade B ,
I ASTM-A-553 Grade A or B '
- 3) Maferity of welding uses E70 Electrodes. '
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]1 dm Randy Hooten Project Civil Engineer Unit 1 ,
j CRM/ct cc: R.B. '41111ans t
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INC MING _ CUTGOING _X TIME 10 10 _ A.M. P.M. DATE.05/31/85 File No.4.12 Ferson called: Raymond Hebert
Title:
Civil Suoerintendent, Reactor II Br:wn & Reot Tel. ( ) x-651
; Representing: _
arsen Calling:3. p. Sinch
Title:
)
l Representing- ERC iTel. ( _
) x-596 lOther Parties involved: NONE 5,3 4,,.t . PAINT CHARACTERISTICS FOR HANGERS ,
i
, gg y,. ;- TOPICS ITEM Mr. Hebert was called to obtain information on the paint typt and application , techniques used for painting hangers (for conduits, cable trays and pipe) at CPSES.
l Mr. Hebert provided the (cliewing information: 4 j 1 Faint type (both inside and outside Containment) Primer: Cartazine 11 I Primer: (recairs only) Carboline 191 i To:c:at: Phenoline 305 . 2 Paint app'lfcation-
- Shco fabricated hangers are spray painted. In the field, a suitable mathed of paint applicaticn was used which could be spray, roller or brusn.
] I 3 There is no difference (exceot for color) in the type of paint or in the mothed of paint acplicatien for different types of hangers. It snould te necec that the painting of hangers inside c:ntainment were ! ins:ected by Q.C. and the ins:ection documented on Q travellers. Painting cutside Containment received Engineers' inspection only. Painting work in pregress en Unit 2. is also under a non Q program. l bb ' 6.P.Skngh i c: Roger Br wn l R. Hebert ERC File , 5F5/sp fl l l i j $ ppa #2 I \ fY .
I Orr!CE MEMOR ANDUM To D. Callacher (IRC) Cisn Rose. Tsou Aeril 15. 1485 Subject COMANCHE PEAK STEAM ELECTRIC STATICN UNIT NO. 1 RISCL'JTION OF UNSATISTACTORY _ INS?EC ICN/ VELD THICKNESS Wo have ec=pleted evaluation of the paint thickness which exists in cable tray hangers fillet velds. During ERC's inspec:icn of the Unit 1 CTH's, it had been agreed that an allevance of 31 =ils (1/3;") was to be taken for the thickness of paint that exists.on
- he velds. A direc: consequence of such allowance was the identificatic:. as "undet-sized" of any fille: velds whose si:e didn't exceed the specified si:e by 1/32".
Mcasura=en:s of :he paint :hickness have been taken at three locations in or near :he fillet velds, a :he :hroa:, and very near the veld a: :he :vo base ne:bers. Measure-
- =cn
- s were taken en fille: velds of CTH's inside as well as outside contain=ent. No discernible dif ference exis:s between the thickness of the paint inside or outside cen:si=nen:. nor is :here any observable or statistically significan: difference between
- he pain: :nickness a: the veld throat or in the base members.
The =easure=en:s indicate : hat the average pain: fi1= thickness is about 10 mils. Thick' noss of 20 =11s or : ore =ay be present, but the probability of such occurrence is less han cen:hs of one percen:. Consequently, you are advised that a : ore appropriate allevance f pain: thickness on cable ::ay hangers fillet velds is 20 mils or less. Cn :he basis of our measure =ents, ve have 99.99 percent confidence that less chan one For:ent of :he velds veuld have pain: thicknesses in excess of 20 mils. l :his =e=c, I a= also informing you that the Visual Weld Acceptance Criteria (VWAC) l soo=1:ted by the Nuclear Construe:1on Issues Group (NCIC) states that fillet velds =ay bo inspec:ed vi:h :he paine present. Apparently, no allevance need be taken for the presence of ;ain: vnen deter =ining if the veld is undersized (i.e., the veld is con-sidered ;;operly si:ed if ic =ee:s the si:e requiremen: vi:h the paint on); as the VWAC < is silen: on pain: thickness . The VWAC prepared by the NCIC has been reviewed by :he NEC, and ; unders:and tha: it has been accepted or is very close to acceocance. On :he basis of :he foregoing, please revise the allevance for pain: to be :ere when resolving unsatisfac:ory condicions of fillet velds in your inspection reports. Con:2: ne a: ex:ension 354 if you have any ques: ions.
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A HEM 0LUDUM TO: File _ TROM: 3. P. Singh DATE: June 5. 1985 / K/ff ,- SU3 JECT: Paint Thickness en k'elded Supports This meno is written to document the results of paint thickness
- sessurements on velded supports. Supports were selected arbitrarily and thickness of the paint was measured on the base metal close to the toe of fillet velds. The table en attached page suc:marizes the results of the seasurements. -
k i 3.IF. St.ngn
!?S: pew Attachment
/)spruoir 2 f"fI --
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m _Supeert Type No. of Paint Thickness Paint Measurements Hin Max Av. Pipe Support Primer & Top 34 on 3 supports 2,5 12 7.3 Coat - Pipe Support Primer only 7 on i support 0.5 3.5 1.5 Cenduit Support Primer & Top 11 on 3 supports 1.5 9 5 Coat cable Tray Primer & Top 5 on 1 support 6 10 8.5 Coat ' Duct Support Base metal 6 on 1 support 3.5 5 5 galvanized, welds sprayed with primer J Instrument: DFT Gage MCI 3120 Date of Measurementst 5/ /85 hp 3 r~t t
. . - . . . . - . - .- . . - . . . . - . . .. - ~ - . .- ~ - - .. - --
F-1 e 6 4 l 1 . 1 e l 1 I n l
INCOMING OUTGOING X TIME 9:30 .A 2 P.M. CATE.05/31-85
, File No.A...12 IPerson called: Mark Eli
Title:
Not recuestes l
! Representing: Nuclear Regulatory Ccmmission Tel . (301)S97-4881 x866 Person Calling:8. P. Singh yttte: Issue Coordinator Representing: Evaluation Research Corocration M . ( 9171897 4881 x596
;0ther Parties Involved: None g eet. TRT INSPECTICN OF WLEDS ON SUPo0RTS AF-1-001-001-533R AF-1-001-702-533R REF. .
TCPICS i ITEM l Mr. Elf was called to find out if paint was removed prior to the TRT Iospection
; cf Subject Supports referenced in the January 8th letter cf NRC.
l Mr. Eli strongly felt that paint removal was essential for an ideal weld inscection, thougn certain attributes (e.g. leg size) can obviously be looked at without removing paint. Specifically, he provided the folicwing informatien: 1 58ccort No. AF-1-001-001-533R Leg undersize c:uld be seen on the painted weld. Porosity was suspected. Paint , was then removed and porosity was confirmed. 2 Su:: cort No. AF-1-001-702-533R Undercut was suscected in the painted weld and was confirmed after paint removal. l l cc: Reger Brcwn Mark Elf gh l ERC File 3. b. Singh I l SPS/sp c
; ALL FRED FA M y
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- - - .. . . ~ . _ . . . . . . . . . . . . . _ ,
O a CCF GCHE PEAK TECHNICAL REVIEW IIAM (TRT) RIPORT FROM g EPDoherty CC
'R3Ke117 RJRudis DTKing J0Webb ford nWAckley k8 7 FACanuso JCAldridge PRaySircar DATurnbull: dam 4
CC::appile Qf JAKirkebo - P.3 Site ~s\y - CCRichardson , l Attached is a copy of the Technical Review Team report for the Comanche Peak Plant which was issued by the NRC on January 8, 1985. This report is distributed for information due to the nature of its' contents, and the nature of the inspection itself, which is the first TRT Report we have seen. As stated in the cover letter, this inspection was conducted as an element of the NRC's review of the Comanche Peak License Application. _/ / - E.P. Doherty Supervisor - Design Control Procedures
- Engineering Assurance Attachment i ,'
J* 9 1 '
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) uucuan necuuTORY cOMSSION ms . co . o. c. mm RECEIVED
(,.ek/ ..* JAN 14 S'S
^
January 8, 1985 I SEMOR VICE PRES! CENT : mr Engmesme & Coerati:ns Docket Nos. 50-445/446 Mr. M. D. Spence, President Texas Utilities Generating Company 400 North Olive Street ,. Lock Box 81 1 Dallas, Texas 75201
Dear Mr. S;ence:
Subject:
Comanche Peak Review I i On July 9, 1984, the Comanche Peak Technical Review Team (TRT) began an NRC
- 1. staff to reach its decision regarding the licensing of Co The ensite effort covered a number of areas, including the review of allegatiens of improper construction practices at tXe facility.
On Septe.ber 18, 1984, the NRC met with you and other Texas Utilities Electric Company representatives to provide you with a request for additional infor-mation in the electrical and instrumentation, civil and structural, and test program areas having potential safety implications. On November 29, 1984, we reported coatings areato you and re on the status of our technical review in the protective miscellaneous areas. quested additional information in the mechanical, and TRT reviews of construction QA/QC allegations and technical issues have progressed to the point where we can now provide you with the status for a program of our efforts plan specifically addressing in the ourconstruction concerns. QA/QC area and a recue infomation regarding these allegations and technical issues will beFurther background which will document the TRT's detailed assessment of the s issues examined. The TRT effort constitutes one element in the process of the agency's review of the Comanche Peak license application. ) The OA review group on the TRT was I comprised of about 20 individuals having a total of over 300 years experience in nuclear engineering, QA., and related fields. This group spent several months at the Comanche Peak site examining the construction QA program in depth. l The TRT findings are provided in the enclosure to this letter. We have not proposed the TRT. specific TUIC corrective actions as we have in previous reports from We request that you evaluate the TRT findings and consider the implications of these findings on construction quality at Comanche Peak. We request that you submit to the NRC, in writing, a program and schedule for ompleting a detailed and thorough assessment of the QA issues presented in j the enclosure to this letter. , _ - - e e ;, * -* e w ** *
, ' " ^
.- ' . . - - _ . . _ . c .n _; _ J . _-
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~
Your progragmatic plan and the plans for its implementation will be reviewed
' and evaluated by the staff before NRC considers the issuance of an operating license for Comanche Peak Unit 1. i The TRT considers the construction QA/QC findings to be generic to both Units I and 2 and your program plan and schedule should address both units. This program plan shall: (1) address the root cause of each finding and its generic implications on safety-related systems, .
programs, or areas, (2) address the collective significance of these - i deficiencies, and (3) propose an action plan from TUEC that will ensure that such problems do not occur in the future. Your actiont thenld censider the use of_ management personnel with a fresh ee-toective to evaluate the TRT's findings and 1melement veur escrective actions Finally, you should consider we use of _ an independent consultant to provide oversight to your program. i The findings of TRT with respect to QA/QC allegations, along with the TRT's 4 assessments of ycur response to this letter, will be provided to the Senior Management Panel on Contention 5 established by the Executive Director on December 24, 1984 The Senior Management Panel will detemine an overall MRC staff position on Contention 5 based on an integrated review of a number of sources of infomation concerning QA/QC at Comanche Peak in addition to the TRT findings, including infomation from the CAT team, the SRT team, 01, Region IV and the Hearing Board. The TRT's overall evaluation of the technical issues and allegations is nearing completion. As we finalize infomation received in conversations with allegers, and further assess the implications of our findings we will infom t you of additional concerns, as they arise. In the mean time, your examination of the potential safety implications of the TRT findings should include, but not be limited to the areas or activities selected by the TRT. In order to fully discuss these concerns with you we are scheduling a meeting for January 17, 1985 which will be held in our office in Bethesda, Maryland. This meeting will provide an opportunity to ask questions regarding these concerns prior to femulating your program plan. Additional meetings will be held at NRC request as your program plan is fomulated. This request is submitted to you in keeping with the NRC practice of promptly notifying applicants of outstanding infomation needs that could potentially i affect the safe operation of their plant. Future requests for infomation of this nature will be made, if necessary, as TRT technical reviews continue. l Sincerely, l i . S . s. Tr or Division o Licensing Office of Nuclear Reactor Regulation l ~ Inclosure: As stated cc w/ enclosure:
- See next page
. - . :.2 .a ' - - -
un. m.2 2 - . .. . CCMANCHE PEAK - mr. N. D. SPince ~ president
' Texas Utilities Generating Company 400 N. Olive St., L.8. 81
} Callas, Texas 75201 I cc: Micholas 5. Reynolds Esq. lishop Liberman, Cook, Mr. James E. Cummins j Resident Inspector / Comanche Peak Purcell & Reynolds i 1200 Seventeenth Street, N. W. Nuclear Power Station Washington, D. C. 20036 c/o U. 5. Nuclear Regulatory Consission P. O. Box 38 Robert A. Wooldridge, Esq. Glen Rose, Texas 76043 l Wcesham, Fnrsythe, Sampels 8
; Wooldridge 2001 Bryan Tow,er, Suite 2500 Mr. Robert D. Martin ! Dallas, Texas 75201 U. 5. NRC, Region !Y i
611 Ryan Plaza Drive i Suite 1000 Mr. Homer C. Schmidt Arlington, Texas 76011 4
! Manager - Nuclear Services Texas utilities Generating Campany Mr. Lanny Alan Sinkin
! Skyway Tower 114 W. 7th, Suite 220 400 North Olive Street Austin, Texas' 78701 L. 8. 81
; Dallas, Texas 75201 ! 8. R. Clanents Mr. H. R. Rock Vice President Nuclear ! Gibbs and Hill, Inc. Texas Utilities Generating Company Skyway Tower 393 Seventh Avenue New York, New York 400 North Olive Street 10001 L. 8. 81 Nr. A. T. Parker Westinghouse Electric Corporation William A. Burchette, Esq.
P. O. Rex 355 1200 New Hampshire Avenue, N. W. Pittsburgh, Pennsylvania 15230 Suite 420 i Washington, D. C. 20036 Renea Hicks, Esq. i Assistant Attorney General Ms. Billie Pirner Garde Environmental Protection Division Citizens Clinic Director P. O. Box 12548, Capitol Station Austin, Texas 78711 Government Acenuntability Project 1901 Que Street, N. W. Mrs. Juanita Ellis, President ' ' Citizens Association for Sound David R. Pigott, Esq. Energy 1426 South Polk Orrick, Herrington & Sutcliffe ! 600 Montgomery Street Dallas, Texas 75224 San Francisco, California 94111
" Ms. Nancy H. Williams Anthony Z. Roisman, Esq.
CYGNA Trial Lawyers for Public Justice 101 California Street 2000 P. Street, N. W. San Francisco, California 94111 Suite 611 i
. Washington, D. C. 20026 ..__-,___-___~.
1
. . 1 CONANCHE FEAK -2*
cc: Mr. Deyis Kelley
- Resident Inspector - Comanche Peak c/o U. 5. NRC
- 9. Q. Sox 1029 Granbury Texas 76048 \
Nr. John W. Beck *
- Manager - Licensing . l Texas Utilities Electric Company Sk.way Tower 400 N. Olive Street L. 8. 81 '
Dallas, Texas, 75201 Mr. Jack Redding Licensing Texas Utilities Generating Company 4901 Fairanent Avenue Bethesda, Mary 1and 20014 i
)
l l
-- - , - - , - - . . - , . , - - - . . - .,,-.,.-.,,-..y. -., ,..,- ,.-
_ .- . .a - . a -- -- ---- ~~ ~ __ l I O e l t g Enclosure Technical Review Team Findings Resulting Fres ! Quality Assurance / Quality Control Allegations In evaluating the QA/ i pleted the following:QC progras at CP5ES, the Technical Review Team (TRT) cos ! and records, Brown selected &affidavits Root (B&R) personnel and allegers, (2) revie , Office of Investigations repo,rts, and (3) physically inspected ha I allegations at Comanche Peak Steam Electric station ( i 1 i QUALITY ASSURANCE PROGRAM l The TRT found that hithough the TUEC QA program documentation set N sents, the weaknesses of its imples.entation in several areas demonstrate that TUEC in several lacked areas:the cosaiteent to aggressively implement an effective QA/ i A. i TUEC failed to periodically assess the ever 11 effectiveness of the site QA program adequacy in that there have been by senior management. no regular reviews of prog i Further effectiveness of its QC inspection progr,am.TUEC did not assess the , 3. During the peak site construction period of 1981-2. TUEC employedl only four auditors, in technical all of whom had questionable qualifications disciplines. l' Although charged with overview of all site i construction and associated vendors, these Gallas based auditors provided only limitad QA surveillance of construction activities. s C. i Repetitive NCRs were issued that identified the need to retrain con- ' struction personnel in the requirements and contents of QA procedures. One corrective action request (CAR) dealing with inadequate construc- ! tion training and records remained open for one year. The identical
- problem was identified in a subsequent CAR, which still had not been closed at the time of the TRT's onsite review.
! D. 'i The TRT found many examples of incomplete and inadequate wo and ineffective QC inspection in TUEC's evaluation of the as-built program.
- (See Section 4 for a detailed discussion.)
i E. ! Some to inspect craft wrkers their newlyand own work assigned records.as QC inspectors were in a position Site management did not view this lack ofconflict-of-interest. potential separation between production and inspection roles as a 3 F. i There reporting were potential weaknesses in the TUEC 10 CFR 50.55(e) systoa. Applicable procedures did not identify what types l , _ _ _ _ , _ . _- -- -- - '~
~~ mew.-r-e,-- .-y-, - - - - -
- maz; x - - - ^
mm --- :: : ; ; -- 2 ;;; - m l nor how they should be evaluated for reporta Evalu- l ation guidelines for reporting hardware deficiencies lacked cla l g and definitive instructions and the thmshold for reporting deficien j cies was too hi p. s cies that were not reSpecific past and present construction deficien-11 of this enclosure. ported by TUEC are listed in Sections 4, 5 and 1 G. . The TUtc exit interview systas for departing employees appeared neither well structured nor effective, as evidenced by the lack of .- { esplayee confidence, limited fuplementation, failure to document i explanations and rationale, and failun to complete cornetive . actions and to detarsine root causes. H.
! The B&R corrective action system was generally ineffective and w bpassed instances: by the MR QA Manager, as exemplified in the followin 1
1. There wre no definitive instr'uctions to describe the types of problems that required corrective action. Minimal procedural being left to the judgement of the QA Manager. '
- 2. Since June 1983 ,
MR had issued no Corrective Action Requests (CARS), this function. and was substituting menos and letters of cencarn for j speration and appeared ta bypass the CAR systas.T \ I. ! The in tive TUEC that: corrective action system was poorly structured and ine ; 1. Controlling procedures wre brief and general. I 2 i There was no translation of FSAR requirements on trending an details on how trend analysos were to be accomplished. 3. Quarterly reports were not issued in a timely manner. 1 4 The method of categorizing meaningful trend analysis. problems by building did not assure 5. l A 1964 over, none CAR hadmport identified three items requiring action; how-been taken. 6. ! CAR 029 was used as a vehicle for a specific disposition rather i than for generic action, as intended by the CAA system, 2 QUALITY CONTROL INSPECTION l The TRT evaluated the CPSES QC progras to do ' quality of design, procedures, processes and product at the plant.
-ef this nyiew showed the following problans . .
- The nsults 1 .
t u_,_ -- -- ~ ~ ~ ~ ~ ~~ .___ . . ._. _.-. . -
A. Based on the TIT review of about 200 fuel pool travelers TUte mes ! unable ta maintain an effective and controlled QC pro s ' . cool liner fabrication, installation, and inspection. gram for fuel Typical fuel l
, pool traveler irregularities were: *
{ 1. There was apparently a routine practica during construction of i i the fuel pool that allowed craft personnel to complete a pertion of the inspection report forms prior to the actual inspe.: tion.
- l i Craft personnel entered the word '5AT." dated the entry, and '
left blank only the space for the QC inspector's signature. I t,
- I appeared that the craft personnel were judging the inspection results prior to inspections.
- 2. The date accompanying the signature for visual examination of a1 inside weld was changed to a date that appeared to precede the
, examination.
- 3. Entries by the same inspector for two different inspections did i
i not appear to match in that one entry appeared to be written by another person. , 1 i 4. The procedurv number for a dye penetrant inspection was changed t by an inspector different from the one who conducted the inspection.
- 5. The data for a dye penetrant inspection was changed by an !
inspector other than the one who performed the inspection. ' 'l'
- 6. Fuel pool travelers were found with missing QC signeffs for fitup and cleaniness. No proof could be found that some of the required weld fitup and cleanliness inspections were ever
] performed. > 7. The TRT review disclosed the following irregularities with j traveler entries in addition to those listed above: (a) Data changes after the fact I (b) Signoffs for functions out of sequence } (c) Corrections af ter the fact
- (d) Changes to first party inspector date signeffs (e) Missing signatures ,
i 4
- 5. There were examples of limited corrective action, including vendor-
) supplied pipe whip restraints that had received inadequate source inspections. Twelve NCRs were issued involving weld defects on these restraints. TUEC corrective action included paint removal from only a sample of the welds and 21 restraints were selected for reanalysis; I however, the TNT found no basis or criteria for paint removal er how } 4 the worst casa restraints were identified. i < l The reviews of allegations in the Civil and Structural, Coatings, Electrical, Test Programs, and Piping and Mechanical areas aise indicate QC inspection j , deficiencies, as provided in our letters of September la, and Novanber 29, 1944.
-t-+-:--- A '~ ^ ~ ' " ~ " '
._ .m, . _ - _ . _ _ . _ _ . - - - - - - - -
s 1 3 T-SMIAT INCIDENT The T-shirt incident has previously been explored in many forums, including i hearings before the Atasic Safety and Licensing neard. The TRT has examined . this matter, but will not now describe all of the associated issues. Impor-tantly, however, the TRT believes that TUEC management failed to adequately investigate the incident ta determine its root cause,' but reacted es though the - ' QC inspectors invcived were suf1ty of disruptive behavior. Of particular concern to the TXT is the strong perception that TUEC QA management any have .
- acquiesced to pressures and coglaints from construction personnel and any have
, failed to adequately seport their QC workforce.
- 4 INSPECTIONS OF AS-BUILT PIPE AND ELECTRICAL AACEWAY SUPPCATS j
The TRT conducted a series of inspections encompassing as-built safety-related pipe support and electrical raceway support installations. These inspections were of completed systems or components that had been previously inspected and accepted requirements. by TUEC QC.as meeting the respective construction and installation j ] A. Pipe Su; pert Inspections Tables inspection effort. 1 and 2 are indicative of the scope of the TAT pipe support as-built Of the 42 pipe supports inspected, 37 wre randomly ! selected, while 5 originated from an alleger's list. Forty-six deficien-j cies were identified in the a pports inspected. Followin the deficiencies identified and the applicable critaria. g are examples of ! inspections of this sample ranged from December 1982 to October TUEC's final QC 1944. : i 1. Comeonent Support Welds: (a) Applicable criteria
; ASME Section Ill, NF Subsection and subarticles NF-4424 and ! MF-5360 set forth rules for examining w1ds.
! R&R QI-QAP-11.1-28 Revision 25, Parac-aph 3.5. 5.1 delineates criteria for the exastnation of welds, including inspection ) 1 parameters for acceptable weld sizes. The TRT found supports exhibiting welds that did not appear to be in accordance with the above-referenced codes and procedures. l (b) Examples of deficient welds i (1) Support No. AF-1-001-001-533X. Discrepancies included porosity; insufficient veld leg; incomplete w lds and insufficient fill. This support was removed, scrapped, and l completely rebuilt subsequent to the TAT inspection. i I
- /
__._._ ___ ___- l _ _._ _ _ ._ _,. _ ___. _ . _ . _ i____ ~
T
-l1 Table 1 Pipe supports in unit 1
' Supports Inspected by TRT As-luilt group 842 Class I s19 ports inspected 4 Class 2 supports inspected 14 Class 3 supports inspected -
24 Mangers with problaes 26 Total probless identified 46 Procedure edequacy problems 5
- Haresare-related pmbleas 15
- As-built drawing related problems a Component identification probless 2 Weld-related problems 10 QC record problems i 1 Material identification problems 4 Welds inspected without paint by TRT 305 Welds inspteted with paint by TRT 89 -
Total welds inspected by TRT 394 Welds needing weld repair 10 I of welds inspected 2. 5% Supports needi.ig velding repair 6
% of supports iispected 143.
51dc No. of supports System Itspected Containment Safety Injection (SI) 1 Containment Reactor Coolant (RC) 4 Containment Residual Heat Removal (RHR) 2 Fuel Handling Component Cooling (CC) 11 Safeguares Safeguarcs Residual Heat Removal (RNR) 1 Containment Spray (CT) & Safeguards Domineralized Water (DO) 1 Safeguarcs Auxiliary Feedwater (AF) 4 Auxiliary Chemical Volume & Control (CS) 1 Safeguards Main Steam (MS) 2 Safeguards Chilled Water (CH) 1 "All 42 pipe supports inspected by the TRT had been previously accepted by sita QC. e e O O + ,e -~ *~ '" ~
! Tablo 2 Pip- tupports 1:3 unit 10 Probles resetery
,Henger No. Ble. of Problems
- 1. No locking device for threaded fasteners M -
RC- 1-901- 702-0025 2 10eresere probid i C5-1-oft 5-003-A42E j 2. Illn, edge distance (en base plate) violated CC-N-039-006-F430 1 Ilevesert prob.
- 3. Baseplete hele-location dimenstens out of tolerance l
CC-N-039-007-F4M 4 As-tuftt prob. CC 126-010-F 3M l CC 126-Oll-F3 M CC-1-126-012-F334 4
- 4. Spherical bearing /wesher gap excessive CC-1-126-015-F4M 4 Itereere prob.
! RC-1-052-016-C41E RC-1-852-020-C41E ets-1-416-001-53M i
i Sc Spherical bearing contaminatten 4 i $1-1-090-006-C41E 2 Meresere prob. l i MS-I-416-002-53M
! E. Snubber edapter piste-Insufficient thread engagement MS-1-416-002-53M 3 Proced. pret.
SI-1-090-006-C41E CT-1-013-012-532E 1
- 7. Insufficient throeded ene'at, threaded red (sight holes) SC-1-901-702-C025 1 kresore prob.
j
- 8. tanahar/ Strut lead pin locking device broken er missine M-1-001-014-53M 1 leeresere prob.
- 9. Lead side of pipe clamp halves not pere 11e1 M-1-001-001-53M 2 . Proced. pesh.
M-1-001-014-53M
- 19. Plpe clearances w/seppert out of tolerance CC-1-126-013-F3M 2 Iteresore prob.
i 11. Pipe clas ,1echnut leese M-1-001-702-53M } M-1-035-til-53M 1 18erire prob. t
*All 42 pipe s w ts laspected by TRT had been prevlessly accepted by site (C .
1
- t .
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, Yablo 2 (Centinued, Ope sepperts in eenit la '
prd lee Categey Henger tee. . .!
- 12. Snubber /5way strut alsalignment No. of Problems Type .
} CC-1-126-014-F434 2 Hard. sere problem i RC-I-052-020-C41R
- l 13. Snubber cold set dimenslen does not match drawing ,u i
C5-1-005-003-A42k 1 Ao-Bullt prob.
! 14. Snubber erlentatten does not match drawing CT-1-005-004-522R 2 As-tullt preb. '
C1-1-013-010-522M ' l 15. Campenent type /model no. Installed does not match
! drawing SI-1-090-806-C41K 2 Campen. 19 preb.-
RC-1-052-020-C41R I
- 14. Its identification for support materials, parts, and CT-1-013-Gl4-532R components 4 poot1.Identific.['
j CC-1-l?6-012-F33R prob. tt j CC-N-039-005-F4 M ! M-1-035-Oll-53M ) 17. ! Der column line dimensten does not match DOHl. Support not affected j Dimenelen 1 As-Bellt prob. l
- 18. Weld pereelty excessive / {
M-1-001-901-53M 1 Weld-related pret i 19.' Weld undercut excessive / M-1-001-702-53M 1
- 29. Wald length tenderstred Weld-relatedpret; AF-1-901-901-53M 1 Weid-related pesti L j - 21. Weld leg er effective threat isodersIred i M-1-901-001-5334 3 Weld-reisted pret HH-1-006-012-C42R i
CC-N-039-907-F434 -; 22. Wald called out on drawing does not eulst la fleid CC-1-126-813-F33R 1
- 23. Wolds added la fleid are not reflected on drawing w id-related prob, M-1-901-702-53M 1 Weid-related pech' numerews welds '
- 24. Escesolve grindine resulting In min. thicliness
- - cletettens (weld clean-up) M- t-037-002-53M 2 Weld-related prob CT-1-013-014-532R
! ! 25. Its QC Swy-off en weld data card ji CC-1-126-013-F3M 1 gt record problem - i 46 Total probleme I identirled by Tari t ) *All 42 pipe supports inspected by TRT had been previews 1y accepted by site QC.
~
l ia . .. t k
s . (2) S aport no. AF 1-001-702-533R. f.xhibited extraneous welding
' that was not escaented on tae as-built drawing. One of the required melds was undercut beyond the limits of acceptance
, (this weld was subsequently repaired). t (3) Support me. CC-1-126-013-F33R. Support drawing required a i
j 1/4" fillet wels to connect Ites. 5 to itas 5. This sold was amitted in the field. ' i i (4) S e port No. CC-I-039-007-F43R. A required 5/16" al. around* I fillet vele has an approximately 1/14" under:12e un Id leg for the length across the top flat of the tee steel. i f '
. (5) Support No. RN 1-Oc6-012-C42R. An all-around 1/4" tillet ,
wele connecting item.5 te itse 7 was undersized by 1/32" to l 1/16" across the top. '
)
(4) ,Suposet No. AF-1-037-002-533R. This support exhibited a ; i
'1/ W to 3/32" reduction in plate thickness and weld size j due to excessive grinding of the weld at the base plate. I Base material thickness of the support plate was reduced beyond the limits of acceptance in three locations.
l (7) Suecort No. CT-1-013-014-532R. Excessive overgrinding of ; welas resultes in notching of the sway strut rear brackets. This condition was repaired subsequent to the TRT inspection.
'{ 2. Lockina Device for Threaded Fasteners:
i (a) Applicable criteria ' j Subarticle NF-4725 states in part that all thresced fasteners, , j except nign-strength bolts, shall be provided with locking 4
; devices to prevent loosening during service.
{ ASWE 5+et. III, Div. 1. Interpretation No. I!!-1-83 49R provides ! inat the user should satisfy himself that any otner device than those described in NF-4725 is capable of acting as a locking ' device under all service conditions. i Brown & Root Procedure QI-QAP-11.1-28. Attachment 2. Operation 7. Jnspection AttriDute n., requires tnat all exposed threans De
! free of extraneous material.
~ l ! CPSE5/FSAR Perseraph 17.1.2 states that the design verification i l procecure assure that eravings, specifications, procedures, and Instructions meet stipulations of related codes and standards. i 10 CFR 50.55(eM1'l directs that the holder of the construction permit sna11 notify the NRC regarding each deficiency found in i design and construction which, if not corrected, could adversely affact the safety of operations at any. time throughout the , espected lifettae of the plant. j
._.,,_,,h..~. - - - - - - - - - - ,----
There appeared to be a difference in locking devices en threaded fasteners for siatlar pipe support har*are made by two separate vendors. Whereas in some cases Nuclear Power Service Incorporated-(NPSI) specified only put and appl,1 cations. ne locking device, ITT-Grinnell requimd two nuts in those same , If the design of NPSI models indeed should be found to need the "lockauts or their equivalent, there could be hundreds of pipe supports installed without adequata locking devices. . ! The TRT found examples in Unit I when deficiencies existed so that
- TbEC was in potential violation of the codes, procedures, guidelines.
- and commitments concerning locking devices for threaded fasteners.
In spite of the requirements pursuant to 1C CFR 50.55(e)(1) TUEC did not report to the NRC the emission of thread-locking devices in the Unit I nuclear safety systems and did not attempt corrective action i until May lock capability. 1984, when TUEC tested previously applied paint fer thread-That test was inconclusive, since it did not estab-lish that the paint, an epoxy process, would reliably perform as an
- effective locking device under all service conditions and throughout j
the expected lifetime of the plant. I to the TRT which paint was the subject of test.ing.Further, TUfC cou i TUEC had a potentially inadequate quality assurance specification No. teners. 2323 A5-31, which did not cover inspection of painted threaded fas-
! The paint was applied to ASME cide controlled NF hareware per l specification 2323-AS 30 (non-Q) which required no inspection. This issue appears te be generic for Unit 1.
i The TRT notes that TUCC did not initiate an NCR identifying the widesprea ' problee of missing locknuts; only a Request for Inforsation was generated, which TUEC could not locate for the TRT. An NCR, required by procedure, ! would have brought the probles and its ramifications to management atten-tion and would have provided a vehicle for controlled, organized, and approved eagineering disposition. (b) Examples of deficien; leeking devices. Pipe support AC 1-901-702-C325 had a load bolt at a beam attach-
- ment which did not exhibit an approved locking device. (The bolt material type was 5A-307 grade A.) Additionally, pipe support
; C5-1-085-003 A42K had no approved locking device on the "special clamp" bolts, even though the design drawing for this clamp showed each bolt with a nut and a lucknut.
3. Minieur Edce Distance for Bolts: (a) Applicable criteria 01-0 0 11.1-28 Revision 19, Parecceph 6.1 required that bolt holes in structural mencers shall not M closer than 1-1/2 tim 1,he bolt dieseter free the edge of the seaber to the center of the bolt hole. l
*3 ,.~.... ..
?
ASM! Sect. "1" Div. 1. Subsection NA. Appendia NY!!, Table XVI -Za62-Itt?-1, givss specifically aliewee einfaum edge dis-tances for to: t holes (reased, rolled edges of plates, shapes, punched or bars. er drilled) at shearwd er L
, (b) Example of sinism edge distance violation The baseplate for pipe siepert CC-I-039 006 F43R, located in the '
i component cooling systes, Room 249A, Fuel Nandling Building, violated etnism edge distance criteria for belt holes. - I
- 4. Base Plate Mole-Location Disensions:
2 (a) Applicable criterien
)
I1!-QaP-13.1-28. Revision 39. Attachment 4. Paranesch 2, under ! "aericatson tolerances, l' sits a " hole centerline location to . j 11/4" or as shown en the design drawing." (b) Examples of hole-location dimension problems The TRT found the horizontal seaber of Support CC 1-126 010 F33R l 1 ! was 3 inches lower at its centerline relative to the upper bolt- l
; hole center 1tne than shown en the vender-certified drawing. The '
as-built drawing had not been revised to reflect the actual installed condition in the plant. This support was located in the component cooling system, Rees 247A, in the Fuel Mandling ' ) Building. Other supports with stellar hele-location violations l found in the inspections were: CC-X 039-007-F43R, t CC-1-126-011-F33R, and CC-1-126-012-F33R. .\ ' ] 5. Spherical learine Gas: ! (a) Applicable criterien l 8eown & Roet Procedure. 0!-048 11.1 28. Revision 25 paracropn 3.7.3.1 states tnet "a suf f tcient nuncer of spacers shall De uses to prevent the spherical bearings from becoming dislodged," and "in no case shall the resulting gap be acre than i the thickness of one vender-seplied spacer." l ' l (b) Examples of spherical bearing. gap deficiencies An e"xcessive free gap existed between spherical bearing and' ! ^ washers on the sway strut assembly of support CC-1-126 015-F43R. ' Other supports with stellar bearing gap anoeilfes found in TRT's
, inspections eers: RC-1052 014 C41K, RC-1-052-020 C41K and j MS 1 415 001 533R. The fretwency of this type of procedure vie-1ation in the TRT's limited inspection suggests that this probles j
is generic for Unit 1. 1 i . . I
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- 6. Scherical learine Contamination:
i (a) Applicable criterien I t ! 1 01-0A7-11.529 tevision 22. Paracrash 6.3.1 #ete P states in part ! ! that "bearung interna' ene external surfaces shal: i rust and fo he free of i ! the housing. ' reign asterial, and bearing shall move freely within! 1 i l (b) faaaples of spherical bearing contamination
- 4 i
The TRT fevnd paint contamination in the bearings of both snubur ; assentlies on component support $11-090-006 C41K that severely i 4
- ebstructed the bearing cavities and lietted their movement. This Class I component support is located in the Cantaiteent 8vilding
] of the Unit I safety injection systas. A steiler condition esists on support MS 1-416-002-133R. ! 7. snuever Adaster piste se, tina - i.aen .< run nr.ad rneaee es: (a) Applicable criteria l Of-QAP 11.1-28. Revision 22. Paracconh 6.1, states that "all ' i bolts, stues, or threases rees shal' have full threas engagement i in the nut." i Asut Sect.111. that "the thresasDiv.1. of all$dnection W. Subarticle W 4711 states be' ts er stues full length of thread in the nut." shall te engages for sta { l QI-Qal 11.1-28. Revision 25. Attachment 29 permits less than full tareac engagement in snreacec plates. This allowance for less than full thread engagement is a potential violation of the A$#t Code Seet.111. NF 4711; no code case was invoked to set , astee sms procedure. The requirement af NF-4711 that "the i threses of all belts er studs shall be engaged for the full 1ength of thread in the nut" aise imp 1fes that there be a full !' 1ength of a threaded hele in plates, shapes, er bars where the required threaded hele length is the same as the helt diameter. l Further, there is no evidence that partial thread engagement at ! the snubber adapter plate connection has been given censideration in the design precedures for liMar-type supports, nor does it I appear that sufficient design margins nave been introdutbd to i allow for less than full threaded connection. The TRT did not check "as built" analyses te determine whether any such varia-1 tiens from the design nors had been considered in the "as built" l j stress calculatians. i What is in question is whether any calculations had been made to 1 { address this particular thread engagement conditten for each size 1 snubber being used in the plant. i l J ___ _ ._--_ ___ -~~.m"-_'_-
i (b) t.zamples of lack of full thread engageaient Snubber (shock arrester) adaptar plata belt threads were insuffi-t tiently engaged in all four threaded holes of component support Its-1-416 002 533A. The worst cohottien was 0.095" short, or more than 251 less than full thread engagement. Siellar lack of full ' thread engagement deficiencies was fesnd on NF supports
$1-1-090-006 C41K and CT-1-013-012-532K. '
- 8. Threaded Rod Thread Encacement:
(a) Applicable criterion Q1-QAP-11.1-28, Revision 21, Paraceaph 6. 3. 2. 4. directs that "QC sna)) verify threac engagement if site [signtFholes are present in the strut body.* (b) I.xample of rod thread engagement oeficiency
' Sight holes were present in the strut body to verify threaded rod engagement. The rod was not visiD1e through the sight hole for support AC 1-901-702-C825.
- 9. Snutter/ Sway Strut load Pin Lockinc Device:
(a) Applicable criterien Qt-QAP-11.128, sevision 22 Paracesch 6.3.1.1.b states that "the size of the cotter pins, when usec, shoula De the maximum size the hole will accoamodate and shall be fully opened." (b) Example of locking device deficiency i Sway strut No. AF-1001-014 533R had a broken cotter pin.
- 10. Load Side of Pipe Clan Ha1ves Not Paralle1:
(a) Applicable criterion 01-QaP-11.1-28. Rev. 25, Sec. 3.7.3.1 states that " pipe clamp halves, in relation to attacning eyerod end, shall be parallel."
, (b) E.namples of halves not parallel Clamp halves for pipe supports AF 1-001001-$33R and AF 1-001-014 533R were not parallel.
- 11. Pipe Clearances outside of Allowable Tolerance: ;
(a) Applicable crite.rien j Q1-QAP-t) the ses gn 1-28. Revision 19. AttacNeent 4. itee 3.b states "where l
- shows 0" en one side and 1/16" en the other. 0" aust i be maintained while 1/14" i 1/32" is required en the other side.'
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( (b) Examples of pipe clearance violations
, Pipe sw port CC u6 013-F33R exhibited no clearance on top er g bottaa, while the hanger drowing called out 0" en the bottaa a6d 1/14' en top. A similar probles existed for pipe support AF-1-001-700 5334. s
- 12. Pipe Clase Locknut Leese:
4 l (a) Applicable criterion .. j QI-0AP-11.1-?t Revision F1. Seet. 5.1 states that "unless other i wise snown en the erawing, f asteners will be tightened securely." l (b) Example of lesse locknut A pipe clamp locknut for pfpe support Ar-1035-011-533R was found loose (less it.an finger-tight)
- 13. Snubber /$wev Strut Nisalignment:
t (a) Applicable criterien 01 049-11.1-20. Revision 18. Sect. 5.3.1.4 states that "saxieum sway strut aisalignment shall not excesa 5" for ITT-Grine11 and NP51 from the centerline of the sway strut." (b) Examples of misalignment Pipe support CC 1-126 014-F43R exhibited angularity that exceeded this requirement. A similar probles existed with pipe support i R: 1 052 020-C41R. 14 Snubbee Cold Set (AC) Disension Did Not Match Drawing: (a) Applicable criterion I QI-QAP-11.1-28. tion of acre than Revision 24. Sec. 3. 8. 3. 5. b states that "devia-i 1/4" from the spectftec cold setting (AC dimension shown en the design drawing) is not permitted, unless authorized by a design change."
- 3
) , (b) Example of incorrect AC dimension i
Pipe support CS 1-045 003 A42K deviated by approximately la from the cold set dimension shown en the design drawing.
- 15. $vesert Confiouration Did not Match Orawine:
(a) Applicable criterien 1 01-04P 11.t-28. Revisten P4 Attsevent 2. Operation 3 lists the following <nspection attr<>ute: " support configuration complies with the design drawing
- i
(b) Examples of configuration problems Pipe support snubber CT-1-005-004122K was installed end-to end opposite from the orientation shown on the drawing. A simila { L probles existed with pipe support CT-1-013-010 5221, where dimren ' sienal discrepancies existed on the support drawing that detailed the erfentation of the snubber. . i i
- 16. ,
Component TweModel No. Installed Did Not Match Crewine: (a) Applicable critarion *
. i 01-0A7 12.1 20. Revision 24, Sect. 3.2.1.1 states that
- vendor-
. suppliec NPT stampee component supports snall bear marking (i.e. , '
name plate) traceable to the design drawing." (b) Examples of component identification problems. Model nebers of installed snubbers for pipe support 51-1-090 006 C41K did not match the model number en the design drawing. A similar problem existed with pipe support RC-1-052-020-C41R. ! 17. Weld Data Card Missine DC Initials For Welds: (a) Applicable criterien 01-0AP-31.128. Meteria' Rev. 25. Parecrash 3.5.3 W1 dor and Weld verification states that ""he QCI sna' 1 verify that the weiser is qual)f tes to make the weld utilizing the welder quali-fication actriz (attachment 16, typical), that the use of the ! WP5 (Attachment 17, typical), and the type of filler material listed en the WML (weld fi11str material log] are the same as those listed en the weld data card (WDC), and the welder's systo) has been recorded on the WML." (b) Example of deficient weld data card Support number CC 1126 013-F33R had some welds performed with no QC inspector initials er signatun en the corresponding blocks of the weld data card for that support inspection package.
- 14. Identification of Materials and Parts:
(a) Applicable criteria 10 CTR 50 Appendix 0. Criterien VI"! states that 'measuns shal) ! assure that faentification of the "tes is maintained by heat ' number, part number, serial number er other appropriate means either en ites er en mcords traceable to the itas, as mquimd throughout itse fabrication, erection, installation and use of the a
... , , _ __. . 14 - ~ . - -
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\ . . ! 07-0A7-11.1 23. installation inspection, Revision the19. QCSect. 3.1.f shall inspector states that 'at verif neber, the estarial type, grade and heat nuoer ... yusin the hanger i information provided on the Material Identification Leg.'g the * (b) Examples of asterial identification deficiencies i A replacement part (sway strut eyered) for pipe support 4 CT-1-013 014 532R had no apparent material identification eith i' t The Material Identification Leo (MIL) did no ficatten traceable to the orig < n of the replacement part. 4 A CC-X-039-005 F434, and AF-1-035-011-5334.sim 8. Deficiencies with High late of Occurrence i i The already following listed in the pipe support previous inspections by the TAT were in additio! examples.
, inspections are summarized in Table 3. Results of these ancillary i l
tion to assess their generic implications.The TRT identifie items may systems. have a high rate af occurrence throughout plant sa i tion critaria were as follows:The specific ' frequently occurring" iteml ' (1) j Strut and snubber load pin spherical bearing clearance with wash 1 was excessive (Ref. QI-QAP-11.1-28, Sec. 3.7.3.1 Rev. 25). i (2) i Strut and snutber lead pin locking devices ( not specifically address load pin locking devices). (3) s Sec. 3.7.3.1 Rev. 25), pipe clano halves en lead side were n 4 (4) i Bolts threaded into tapped holes of snubber adapter plates had less related discussions on pipe supportsthan full thread engag! tolting - Lack of Full Thread Engagem,ent" within Part A of thise section en as-built 1nspection). (5)
"Hilti Kwik" bolts (concrete expansion anchors) as installed did noti j seet sinimum effective emocament criteria (Ref QI-QP 11.21, sec. 3.5.1 Rev. 14). i
- (6) j Locking devices for threaded fast 4ners were alssing er of a non-j
; pipe inspection). support deficiencies within Part A of this sec i
e .
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_ . . _ l Table 3 Summary of additional TIT inspections
. w \
- t Area: Room 77N, El 810'-4" t '
I Unit 1. Safeguards Sleg No. of Supports No. af $wports Deficiency inspected Defitient 5 Deficient Ites 1. Excessive . 92 5 5.45 Spherical Searing C1earance Iter. 2. Load Pin Locking 92 14 15.2% Device Missing Ites 3. Pipe C1 amp Halves 40 9 22.55 Not Parallel Item 4. Snubber Adapter 19 *13 Plate Bolts With to be Less Than Full determiner Thread Engagement Area: Cable Spread Room 133, El 807'-0" Unit 1. Auxiliary 31de Deficionev lelts inspeeted Numter Deficient % Deficient Iter. 5. Hilti Kwik Solt 24 3 12.51 Does Not Meet MinipJr Estedment** 88cits had less than full thread engagement, neiaking into account the " allowed" slippage of the bolt for a distance of one nut thickness due to torquing (Ref. " Installation of 'Hilti' Orilled In Bolts" 35-1195 CE!-20, Rev. 3, Para. 3.1.4.1) and the sintes specified emtecaent, the above hilti bolts violated the " effective" cate m ent requirements.
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j The T1ti undertook additional hardware inspections to ascertain the regu-larity with which tMse specific itses may uist. All eccessible pipe s supports in Roos 77N, at the 810-foot, 6-inch elevation of the Unit 1 , Safeguards Building, were inspected for ' frequently occurring
- deft-ciencies 1, 2, 3 and 4 listed above.
*ftequently occurring" deficiency 5, electrical swport 'Milti' b located in tk Cable spread Room 133, at tM 30,7-foot elevatten of ttm Unit 1 Auxiliary Building, wre inspected. For details en " frequently ;
occurrin ; l teners,'g" deficiency 5, see itse A.2, ' Locking Device for Thesaded Fas- ' of the pipe support deficiencies, described above.
- C. Electrical Raceway Supoort inspections The TRT inspected electrical conduit supports and cable tray hangers to the requirements of Q!-QP-11.10-1 Inspection of Seissic Electrical Support and Restraint Systems; QI-QP-11.21-1, Requirements of Visual i Weld Inspection; and other applicable instructions for conduit support and cable tray hanger inspections. All electrical raceway supports l
included in TRT inspections had been previously QC accepted. Table 4 : suussarizes the results of the TRT inspections not previously provided as part of our letter of September 18, 1964. The TRT found the following discrepancies during its inspection of selected electrical conduit supports and t.Aele tray hangers in Unit 1:.
- 1. Undersite welds:
(a) Applicable criterion i OCA 3464, Rev. 23, pace 3 of 32, note 3 states in part that l "welcing requirements as snown en various details should be read as the sinteum requirseent.' . (b) Examples of undersize welds Three of four welds en conduis support C120-21194 3 (cable
~
spread room) were undersized. The requirec wld size was 1/4" at all wid joints, while the measured wld size was 7/32" to 5/32" for the full lengths of three out of the four wlds, i Stailarly, cable tray hanger CTH 5424 (Containment Building) '
' had 12 undersf2e welds. The all around w1ds on the six 1
?d horizontal beams should be 1/4" in size, according to !
detatis Li and La on Drawing F5E 00159, sheet 5424,1 of 2. i The sensured size of these w1ds was 3/16" to 5/32" at each connection. Also, swport IM SP 7b exhibited undersize mlds asasuring 7/32" to 5/32" instead of the required 1/4". T.;
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i i Table 4 Sumary of electrical raceway support inspection by the TAT - unit 1 i 'l 'N Support m 1ds inspected
> 59 swports' inspected la Supports with problems 3 (605) l Types of probless '
i
! " i
' Hardware related, other than welding 6 Unauthorized configuration change 1 .
Weld related types of problems (categories) 2 Welds requiring rework 41 Welds made in field but not recorded on drewing 40** le u. stiffeners added but not recorded on drawing 40 l i tendinc/ Area , Supports Cable Spread Room CTH 12646 C 130 21-250-3 C 120-21-194-3 Auxiliary luf1 ding CTH 6742 Containment CTH 5424
'All electrical supports inspected by the TRT had been previously inspected and accepted by QC, '
i
" Full visual inspection was not performed by the TRT en these extra welds, l
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- 2. Mise 14ced Welds:
i i
.s (a) Applicable criterien l, '> L
' HI-09-11.10-t, Revision 29. Parecroph 3.5.2. Assembly
- .nspection. ' ncluees the requirement to inspect a support
; i "er configuration. Paragraph 3.6.2 of the same procedure !i ,
requires that support welds receive visual inspection and ji that nonconfersing welds be reported. l (b) Examples of misplaced welds 'l l l Buring inspection of Hanger CTM-6742, the TRT found that two ' structural welds were nede in the wrong direction. The 1 3/14" shop welds which join MK 10 and MK-11 were made hori- ) zentally instead of vertically, as shown on drawing F5E-00159, sheet 6742. QC Inspection Report ME-I-0024909, i
. dated February 16, 1944, accepted all inspectable attributes as satisfactory prior to the TRT inspection.
l
! 3. 1)neuthorized Configuration Changes:
i (a) Applicable criterion E ! 1 QI-07-31.10 1. Inspection of leismic Electrical Seeeort and Restre'nt Systees, marserson 3.5.2 includes the requ< resent for inspection of a support for sanfiguratten compliance. (b) Examples of configuration change , The TRT found that cable tray hanger CTH 5424 (Containment l i Building)- had been fabricated to include 40 acre stif feners and 80 more welds than required er shewn en drawing F5I-00159, sheet 5424, 2 of 2. Detail L . Inspection Report M(-1-0004155 verified final QC inspection and acceptance on j January 3, 1984. Further, cable tray hanger CTH-6742 (Auxiliary Building) Clip, MK 12, should be 6" x 4" x 3/4" angle stock in acco,rd-3 ance with F5E-00159, sheet 6742. The actual flange thick-i 4 ness of MK 12 was 3/8".
- 4 j , 4, Milti Anchor Bolt installation Deficiencies:
j (a) Applicable criterion QI-QP 11.2-1 Concrete Anchor Solt Installation, provided
- requirements for proper installation anc inspection of l Nilti ancher bolts.
1 s l 1 I I
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=
_ .. .. - - . +--_ - 2 = : x -- - (b) Examples of Hilti belt deficiencies I( 6
) L CTM-6742 (Auxiliary Building) anchor belt torque was not verified (Darsaraoh 3.5 of the procedure). M11t1 bolts 4 sere ! not marked in accordance with attachment 1 of the procedure. ! ner was the length of these belta verifiable (seranceph 3.h 4,
i CTM-5424 (Containment Building) base plate belt holes had i violated einious edge distance- edge distance cannet be, loss than 17/8" (Attachment 2 of the procedure). Actual dis-tance was 1 5/8" to 1 3/4" from the nearest plate edge. This condition affected five of the eight Milti anchor bolt
. holes in the base plates for this hanger.
One Milti bolt was skewed to more than 15 degrees. Maximus allowable skew was 8 degrees without corrective bevel I i washers (naracesch 3.1.2). 1
. 'The Milti bolt tarque on this hanger CTH 4741 (Auxiliary Building) was not documented as being verified by QC (paragraph 3.5).
- 5. Undersize Nuts:
There was inconsistency in the application of nuts for SA-325 3 bolts in that both standard and heavy hex nuts were used. No stipulation was found which would permit the use of standard (non-heavy) hex nuts. This condition is a potential violation of the Material $cecification ASTM A325 (ASTM Part 4-1974) paracraon 1.5, which provices that "neavy nex structural tolts ane heavy hei nuts shall be furnished unless other dimensional requirements are stipulated...." S&A Drawing No. F5E-000159, sheet 5424, 2 of 2, required the use of ASTM A325 bolts for cable tray hanger number CTH-5424. D.
$way of Pipe support and Electrical Raceway Succort inspections 1
The as-built verification effort conducted by the TAT provides evi-i dence of faulty construction by craft personnel, installed hardware i that does not match as-built drawings, and ineffective QA and QC inspections. I to be a large Despite neer of the small size of the TRT's sample, there appears deficiencies. The potentia 1'also exists that these deficiencies analysis. are not represented correctly in the final stress l 0 0 I C e,c m, ome.eam ,a w w* Aq yW% *W*WM e_ *W* 4 "" T ** $
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The TRT evaluated the CpsE5 doceent contes 1 systes to determine if it was O
. effective and if it ensured consistent quality of documents and records.
. the resuiza .f t.hi, revie. .howed the roiiewing ,robi.s.
t
). . A. , The TRT found that there was a potential for deement control cantar (DCC) i field to crafdistribution t personnel. centers (satellites) to issue deficient deement packages Typical problems identified were: packages were net thoroughly examined; procedures and guidelines were not specific or were not followed; and documents controlling operation of the centers existed in the fore of guidelines and charts rather than as controlled procedures.
- 3. '
The TRT found that many problems indicativs of inadequate drawing control i i existed at CPSES free September 1981 to April 1944 These problems had been identified prior tg the TAT's evaluation by both TUEC and NRC l Region IV aud1ts and reviews. t
- l i
prior to placing the satellites in operation (a phased effort between t February and August 1983). OCC distributed drawings, component modifica-tion cards (CMCs), and design change authorizations (OCAs) to file custo-dians, task welding engineering, the pipe fabrication shop, QC, and the hanger force. Document control through this systes proved ta be ineffective. 1 In an attempt to correct identified problems, DCC satellites were created
') to distribute drawings to field personnel, rather than use the file custo-dians.
However, between August 1983 and April 1944, recurring problems
*- with doceent control were identified. Examples of the types of doceent
- follows: control problems that existed between August 1983 and April 1984 were as
- 1. Drawings released to the field were not current.
- 2. Drawing and specification changes wre not current.
- 3. Design docuentation packages wrs' incomplete.
4.
- DCC did not provide the sate 11'tes with up-to-date drawings, CMCs, t.
DCAs and doc uent revisions. ) 5.
- Drawings hanging from an open rack, which had no checkout control, i were available to craft and QC personnel,
- 6. Design change logs wre inaccurate.
- 7. Design deements wre not always properly accounted for in DCC.
- 4. Current and superseded copies of design documents wre filed together. -
9. Satellite distribution IIsts were inaccurate.
~
*
- 10. There were discrepancies between drawings contained it the sate 111tes and these in DCC. .* .
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- 11. Some drawings were missing from the satellite files.
! l 12.
I Telephone requests for design documents resulted in the issuance of : i Woc 1ments that bypassed the controlled distribution systas.
, In April 1SN, document topproblees.
control management took a direct interest in recurring Their efforts appear to have been successful. - For instance, in April ISH satellites 306 and 307 had error rates of 3C% . and 10%, respectively; but by July ISM, these error rates had fallen to
- 1ess than 1% for both satellites.
The TRT .has found that TUEC document control after July ISM was adequate; however, the effects of document control inadequacies prior to July ISM have yet to be fully analyzed by TUEC.
. C.
I Deficiency reporting procedure CP-EP-16.3 appeared to relate only to craft i
~
and engineering personnel and was not directed to noncraft and nonengineer-ing personnel who say have had knowledge of reportable items Procedure CP-EP-16.3 indicated that the applicable manager was respons.ible for docu-menting and reporting Deficiency and Disposition Reports (DDRs); but there were tute wouldno checks processorabalances DDR. to ensure that a sanager or a designated substi-D. TUEC did not consider the CYGNA audit findings regarding the DCC as appropriate for forsal repa 3 'as required by procedure CPttipg to the NRC pursuant to 10 CFR 50.55(e), 2 EF-16.3, " Control of Reportable Deficiencies." E. The TRT found that the DCC issued a controlled copy stamp to the QC depart-sent Inspector.to expedite the flow of hanger packages to the Authorized Nuclear were not describedMethods for this procedures. in TUEC's kind of issuance and control of such stamps 6 TRAINING / QUALIFICATION The TRT identified numerous weaknesses during its review of the ASME and non-ASME training, certification, and qualification of QC and DCC personnel. TUEC's training and certification prograr lacked the programe.atic controls to ensure that the requirements in 10 CFR 50, Appendix 8 were achieved and maintained. The items identified by the TRT include those listed below, items previously provided in our letter of September 18,19M.in addition to the A. Twenty percent of the training records reviewed contained no verifica-tion of ed. cation or work experience. 4 . 8. , The results of Level I certification tests were used for soee Level II certifications ratner than the results of a Level II test. C. After failing a certification test, a candidate could take the identical test again. l I
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i E. Wite-out was used on cartification tests.
.o l J F. L Seven inspectors had questionable qualifications.
G. There tion could was no limit er control on the number of times an exami be retaken. 4 H. No guidelines were provided for the use of waivers for on-the-job training. .'. I. j In some from cases recertification was accomplished by a simple "yes" a supervisor.
; J.
j There to Augustwas no formal orientation training for DCC personnel prior 1983.
\. '
j K. The responsibility for adr.inistration of the non-ASME t i i prag m was not clearly assigned to a single individual or g up. L' n- E rsonnel capabilities were loosely defined by levels M. j ! There testing,were suchneerous as: additional problems in non-ASME cartification j no requirement for additional training between 3 1' a failed test and the retest; no time limitation between a failed test and a ratest; two different scoring methods to grade a test and a retest; no guidelines on how a test question should be disqualified; no progras for periodically establishing new tests l except when procedures changed; and no details on how the acaninistration of tests should be monitored. i N. The exemption provision in ANSI M45.2.6, which allow d substitution of previous experience or demonstrated capability, was the ncesal method for qualifying inspection personnel rather than the exceptional method. 7 VALVE INSTALLATION The TRT found that installation of certain butt wided valves in three systees j The three systems involved wre the spent fuelrec;uired re temperature-sensitive parts. cooling vol and cleaning me control system. system, the baron recycle system, and the chemical and 1 This installation process was poorly controlled in that disassembled damaged, parts parts. or interchanged were piled in uncontrolled areas, resulting in lost, changing This practice created the potential for inter-ature ratings. valve bonnets and internal parts having different pressure and tamper-l Y~ ~' " ~ ' ~ r 7 [ ~ :T '. < ~
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; 8 ONSITE FA8RICATION i
na The TRT L findings ngarding onsite fabrication shop activities ind
' A.
The scrap and salvage pile in the fabrication (fab) sho was not identified and did not have restricted access. p laydown yard 5. Material the applicable requisitions procedure. prepared in the fab shop did not comp , D C. ." the work under their responsibility.The fab shop foren D. I ensure that MR-fabricated threads conform or to an applicable standard. o E. i j Indeterminate cleanup operations bulk were materials singled thatcontrolled with accumulated safety as an I material in the fab shop laydown yard. F. Site surveillance of material storage was not documented . G. Work in the fab shop was performed in response to c menos es w and T. 3 instead of hanger packages, travelers, and controlled drawin . s HOUSEKEEPING AND SYSTEM CLEANLINESS However, two issues were identified that cleanliness deficiencies. e. systa= indicate A. The purpose of this procedure was to verif - reactorvisual wiping, coolant loops,and inspection, including swipe testing. the reactor vessel, byn- means of h Tests to determine surfacetestchloride systems en and fluoride contamination were performed by T notes, however,gineers and Westinghouse representatives. The TRT reac*.or vessel- one on the side and one on the bottoa.tha vessel had been properly cleaned. number of swipe tests say no B. In rooes 67, 72, and 74 of the Unit 2 Safeguards Building, the TR observed when weldingthat not all was being done snubbers in close proximity were towrapped them. with protective was tion ofainstalled violation of MR during equipment procedure welding. CP-CPM-14.1, which required pro This condition was immediately corrected when the TRT reported it to TUEC QA m and an inspection in other areas as well. was performed by TUEC to correct similar cond l s' ww<m-m g* "r*W _ _ -- ~ __,p .e--
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j , j . 20 NONCONFORM NCE REPORTS (NCRs) I n 2 v There were systems. The TRT several found that: weaknesses in the NCR and deficiency id ~
. A.
i The TUEC procedure for preparation and processing of NCRs contain explicit instructions for handling voided NCRs. B. equipment on a permanent equipment tra . a nonconforming procedures. condition; such usage of the NCR was not defined in ,
- t C.
There was an inconsistency between paragraphs 2.1 and 3.2 cedure CP-QP-16.0. Paragraph 2.1 required all site employees to i
-1 visor, while paragraph 3.2.1 required persons I personnel to submit a draft NCR to the Paper Flow Group.
j D. The form was NCRbeing fers adequately hadcontrolled. no form number or revision dat f E. l There were two versions of the TUEC NCR form, one with and I- out a space for the Authorized Nuclear Inspection (ANI) review. F.
]
The NCR form had no space to identify the cause of the non and the stsps taken to prevent its recurrence. G. The NCR fors had no provision for quality assurance review. H. The TRTdeficiencies. recording found approximately 40 different forss (other than NC considered in trending nonconforming conditions.Many of these i 11 ! MATERIALS 33 of the same pipe supports that the TRT had field traceasility was adequate for those 33 pipe supports, with The material the exception four material inspections. identification discrepancies, as noted in section 4 on a related material and numerous hardware components.In a This QA breakdown was NRC in accordance with the requirements of 10 CFR I
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UNITED STATES NUCLEARB ULATORY COMMISSION m - N.o.c.:osss t
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* . ,U . **'l . i,1 1983 g ..4 iCccket Nos. 50-445 J and 50-446 I
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Text.s Utilities Generating Ccepany
- ATTN: Mr. R. J. Gary, Executive"Vice President and General Manager i 20013rjan Tcwer i
Dalla.s, Texas 75201 j Gentlemen: 1 SU3 JECT: Construction Appraisal Inspection 50-445/83-18, 50 446/83-12 This refers to the construction acpraisal inspection conducted by the Office of Ins:ection and Enforcement (IE) en January 24 - February 4,1983 and February 14 - March 3,1983, at the Ccmanche Peak Steam Electric Station and ycur Dallas c:r; crate office. The Concructicn Appraisal Team (CAT) was ccmcosed of mem:ers of IE and a nummer oY tcqs,ultants. The ins:ection covered construction activities authori:ed by NRC Construction Pennit CPFR-125/127. This instection is the second of a series of c nstruction appraisal inspecticns being planned by the Office of Inspection and Enforcement. The results of these instections will be used to evaluate imolementation of management control cf c:nstruction'activitjes and the quality of construction at nuciear plants.
- The enciesed report identifies the areas examined during the inspection.
i Witnin :nese areas, the effort consisted cf detailed inspection of selected l hareware sucsequent to Quality Centrol inspections, a comcrehensive review of ycur Cuality Assurance Program, examination of precedures and records, cbserva-d tien of work activities and interviews with management and other personnel. Accencix A to this letter is an Executive Summary of the results of the ins:ec-tien anc of conclusions reached by this Office. Except for the area of the heatine, ventilation and air ccnditioning (HVAC) system, deficiencies netar in. instailec hareware yns.aiia:Len recuiredid not i_Micate teriasive failures t6 eaa- ens t ru c ti e n_' ents. c:in-fai was icenttilea. NRC In the HVAC system, a creakcewn in work and cuality negion IV has discussed this matter with ycu and it is cur understanding that this ::atter receivec immediate action by ycu anc your c:ntracters to evaluate and c:rrect these ccnditions. NRC Region IV will c:ntinue :: pursue this issue with you. Prem:t management attention to the res:lutien of otner detailed deficiencies icentified curing the inspecticn is neecec. 3 4 /, b* In c:ntrast to the HV/f systam in its ins:ection the NRC CAT ins:ectors found few ceficiencies t pi:ingancsamples,cp:A}fesysys,tempiping. ASME Ccce radiogrsons fer nis 1
..(ms?ected
- in : Mis area shewed evicence of goed workmansnip.
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' i AP.911 1333 Texas Utilities Generating Ccepany .~
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1 Appendix 5 to this letter contains a list of potential enforcement actions - based en NRC CAT inspector observaticns.
' These have been referred to the Regien IV Office for review and necessary action.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures . wil' be placed in the NRC Public Occument Recm unless you notify this office.
- by teleshene, within 10 days of the date of this letter and submit written application to withhold infornation contained herein within 30 days of the date of this letter. Such applications must be consistent with the requirements of 10 CFR 2.790(b)(1).
' No reply to this letter is required at this time. NRC Region IV will address the pctential enforcement findings at a later date and any required response j will be addresst.d at that time. ! Should ycu have any questiens concerning this inspection, please contact us or tne NRC Region IV Office.
- Sincerely, cW_i ,
- g. '
's
/
,j Pchard C. DeYoung, Q1 epm (-
lC fice of Inspection and Enforcement
~
Enclosures:
- 1. A::encix A - Executive Su.r.arj -
- 2. A:pendix B - Fotential Enforcemen:
Fincings l
- 3. Ins:ection Re: ort 50 445/83-18, 50 446/83-12 e
8
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i N q , 1 l I f APPENDIX A EXECUTIVE
SUMMARY
' An anncunced Construction Appraisal Team (CAT) inspection was performed at the Cc=anche Peak Steam Electric Staticn during the period January 24 - February 4,
- - t 1983 and February 14 - March 3,1983. '
) OVERALL CONCLUSICNS
~
It is the position of the Centtruction Appraisal Team that the results of this 4 inspection indicate several constructicn program weaknesses. NRC Regien IV has been made aware of these werknesses and is pursuing them with licensee manage-i ment. The licensee is initiating corrective action and/or continuing his effort to resolve the identified c:ncerns. Prempt management attention to c:her deficiencies identified during the inspecticn is neeced. In acdition, the NRC CAT team found few deficiencies in its inspection of safety system ( piping and ASME C:de radiography for this piping. Inspecticn of samples in
; this area shewed evicence of gecd werkmanship.
The icentified c:nstruction program weaknesses are as follcws:
! 1. Results of the inspection indicated a breakdcwn in fabricatic'n, instal-3' latien, and inspection in the heating, ventilation, and air c:ndittening (iiVAC) systems.
2. A num:er of examcles were identified of failure t: meet criteria for se: ara:icn of safety-related cables frem mechanical structures anc piping, i anc se:aratien of redundant trains of safety systems. This was cue in part to :ne licensee decision to not inspect installa: fens for recuired I se:aratien until installaticn is essentially c:mplete. The NRC CAT ins:ect:rs are c:ncerned whether; (1) the inspections can be effectively c:ncuctec after installatien, and (2) whether adequate c:rrection actions can be ac::::lished after installation is c:=pleted. Correction of cable se:aration deficiencies at a later date could require repeating pertions of system testing. (Ncte: This matter is being pursued with the licensee by Regicn IV, IE and NRR through site review and evaluatien.)
- 3. The licensee's cuality assurance cr: gram did not en'sure that certain i
hancer, su:;crt, electrical and mechanical equipment was installec to the lates design dccuments, and c:mmensurately that an acprepriate inspection was c:nducted t: the latest design documents,
- t. .
Findings aisc incicate a number of instances where ncne:nferming c:n:itions were identified; hcwever, varicus metneds (e.g., punenlists, ins:ec fen repcrts, verbal, and other infor=al metheds) were usec :: address and resolve these ncnc:nformances. These methods do not ccm:iy with recuirements :: icentify ncnc:nforcing concitiens anc previce
, ccrrec-ive acticns : prevent recurrence.
- 5. The licensee's Quality Assurance audit pr: gram should have been more
- effec ive in cetecting and cetaining correction of deficiencies in 1
A-1
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's safety-related work; such as these in the HVAC system, mechanical
. equi; ent, and electrical cc penents. --
f In sun ary, the identified weaknesses require increased dedicatien by =anage-
=ent at all levels to assure cc=pleted installatiens =eet design requirements and that inspecticn dccumentatien reflects that the cc=pleted installations have been adequately inspected to the latest design document.
AREAS INSPECTED AND RESULTS '* Electrical and Instrumentation Construction: Multiple instances of deviations j fr:= requirements were ecservec relative to electrical and electrical / j mechanical separation criteria. The review of procedures and records asso-
! ciated with electrical inspection activities indicated inadecuate precedures to l assure reinspection of modified, previcusly accepted Class IE c =penents.
, Mechanical Censtruction: Deviations frem design recuirements were observed in QC ac e::ec p1;e supports / restraints, and HVAC installaticns. The existing i
' pr:gra= for pipe suppert/ restraints does not appear adequate to pre:erly verify that final as-built hareware meets the final design requirements. QC ins:ecticns of the HVAC system succert dimensional features were not performed and due:/accesscry inscection activity centrols were not defined in precedures.
4 4 These deficiencies were reflected in the as-built c:nditions which did not c:nferm to design require =ents, f 3
- Piping installation c:nditiens appeared adequate and extensive pr blems with mechanical equipment were net evident.
' eldine/Nendesthetive Examination: The welding and NDE a:cears to be in ac::r:ance ties r=. vealwita recu1re=ents except f:r the HVAC area. The HVAC welding activi- ' significant deficiencies. Preblems were identified with uncersi:ed weics in s: rue: ural su::cr.s, inacecuately trained ins:ection persennel, i=:r:;erly qualified welding precedures, and inadecuate welding dccumentaticn.
The review of radiegra; hic film cf ac;roxi=ately 50 field welds, the review of N E Or:cedures, anc :ne interview of NDE perscnnel, including ce cnstration of NOE tecnnicue, indicates an adecuate NDE program for safety system piping in ac::r:ance with recuirements. Civil and St-uctural C:nstructfen: Occumentatien reviewed in this area shewed na: in general, wort was perTormed in acecrdance with site procacural recuire-ments anc :ne licensee's c: mitments. 1 Precurement. St: race. and Material Traceability: Precurement, on-site storace in wareneuses, anc material traceactitty were found to be acceptable. Satoies of s:Orage in cutside lay-down areas and in-place s : rage of safety-related equi; tent reveaiec that sc e ecuipment was no prctected as required. CC Ins:ect:r Effectiveness: Sixty-three cuality centr:1 insbectors were in arviewec. instances of harrassment or intimidation were either pre:erly rescivec by TUGCC or were referrec to NRC Regien IV to be includeo in an ~ cngeing inves-igaticn. Interviews and certificatien reviews reveaiec :nat seme A-2
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s m .m. , inspecters have been certified without the required ccmbinatien of educatien! 4
.s and excerience specified by ANSI Na5.2.6,1978. Interviews and document _
reviews revealed that individuals not certified as Level II were evaluating the 1 [ validity and acceptability of final inspections centrary to the requirements of ANSI Nt5.2.5 as ccmmitted in the FSAR. Cualitv Assurance: The licensee's quality assurance program should have been more effec:1ve in monitoring and centrolling safety-related activities, as exemplified by NRC CAT identified deficiencies in the HVAC and electrical .* separation areas. Desien Chance Centrols and Corrective Acticn Svste.ns: In the area of certain
- l nangers, supports, elec;r1cai anc mecnanical equipment, the licensee's program j during construction has lacked adequate controls to ensure informaticn trans-l mitted from the design organization was provided to the quality centrol organi-l
- atien for use in performing timely QC inspections. This fact contributed to the licensee's inability to have an adequate program in-place at the time of a ! this inspection to ensure that field installatiens were censtructed to the latest design dccument and that an accropriate quality inscection was ccm-plated. In addition, the large nu=cer (approximately 70,000 CMCs and 15,000 l OCAs) cf design change dccuments centributed to the difficulty in determining wnetner the " final" installation was in accordance with the " final" design.
There were instances where nonconformances were identified, but varicus methcas (seme infer =al) were used to address and resolve these ncnconformances rather than the method specified by site precedures. Evidence of appropriate correc-
- tive acticn and technical justificatien could not be determined in scme cases.
I e s 2 A-3
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* . m ,S UNITED STATES NUCLEAR R'EGULATORY CCMMISSSION 6
0FFICE OF INSPECTION AND ENFORCEMENT . t l( ' DIVISION OF QUALITY ASSURANCE, SAFEGUARDS, AND INSPECTION FROGRAMS REACTOR CONSTRUCTION FROGRAMS BRANCH Report No.: 50-445/83-18, 50 446/83-12 "
, Oceket Nos.: 50-445, 50-446 2 Licensee: Texas Utilities Generating Ccmpany 2001 Br . Dallas,yan TexasTcwer 75201 Facility Name:
Ccmanche Peak Steam Electric Station Units 1 and 2
; Inspecticn At: ; Cemanche Peak Steam Electric Station, Glen Rose, Texas and Texas Utilities Generating Ccmpany, Dallas, Texas Inspection Cenducted: January 24 - February 4,1983 and February 14 - March 3,1983 4
Inspecters: ,8 dd pA. S. deacn, 5r. Reac;cr construc: 1cn Date 51gnec
'f Engineer Team Leader) .
mi f l ?.$ P. 1. Kesnisnian, 5r. Reac:cr construc: 1cn 74:e/51gnea Encin er
;m y-8-[S G. C. Gewer, Sr. Aeac:ce Ccnstrue: 1co.
Engin*** Date 51gnac
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- a. A. nansen, I spec:1cn 5peclastst 4/W73 Date 51cnec L. ,
N.5.'e Aeac:tr Cens rue:1cn ingineer A.-9-88 ca:e 51gnec ;
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, n. a. Enli: 1ps, Reac:cr Construe:1cn Engineer cate signec Censultants:
R. M. Cemeten, D.C. Ford, E. Y. Martindale, and F. A. Fimental A:pr:ved Sy: - '
-h b R. F. netsnman, Galef Ca:e signec
- Reac:cr Ccnstructicn Programs Branch
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TABLE OF CONTENTS k TCPIC t SECTION INSFECTION SCOPE AND
- OBJECTIVES..........................'........... I ELECTRICAL AND INSTRLHENTATION CONSTRUCTION. . . . . . . . . . . . . II ............
l MECMANICAL
< CONSTRUCTION.............................................
III
) i WELD ING AND NONDESTRUCTIVE EXAMINATION. . . . . . . . . . . . . . .IV. . . . . . . . . .,. . .
CIVIL AND STRUCTURAL CONSTRUCTION................................... V PRCCUREMENT, STORAGE AND MATERIAL TRACEABILITY........................ VI QC INSFECTOR EFFECTIVENESS.......................................... VII QUALITY ASSURANCE .................................................. VIII DESIGN CHANGE CONTRCLS AND CORRECTIVE ACTION SYSTEMS.. IX . . ... ...... ... AT.TACMME!iT A - PERSCNS CONTACTED AND 00CUMENTS REVIEWED O s a
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~ I. INSPECTION SC0pE AND OBJECTIVES I The cbjective of this inspectica w6s to evalu te the ade I tion at the Cemanche peak Steam Electric Station (CpSES)quacy . Thisofobjective construc-was accomplished through review of the construction program, the quality '
assurance program, and the design change program, with emphasis on the ' installed hardware in the field. ' a Within the areas exami'1ed, the inspection consisted of a detailed examina- " tien of selected hardware subsequent to licensee quality centrol inspec-tiens, a selectiveofexamination and cbservation of procedures and representative records, in-process work. Interviews were conducted with designated site managers, persennel on a reutine basis. quality control inspection personnel, and craft For ear.% of tire areas inspected, the following was determined:
~
Is the hardware installed in accordance with the approved design? De individuals with assigned responsibilities in a specific area understand their designated responsibilities? Are quality verifications performed during the construction process with applicable hold points and are quality verifications conducted to acequate inspection acceptance criteria? Do perscnnel involved with Quality Assurance / Quality Centrol have the organi:ational intimidation? freedem to perform their tasks without harassment or Are management centrols established and implemented to control activities in the subject area? The areas in which a selected sampling inspecticn was conducted include: Electrical and Instrumentation Ccnstruction Meenanical Construction Welcing and Ncndestructive Examination i Civil and Structural Constructicn precurement CC Inscec:cr, Storage and Material Traceability Effectiveness
. Cuality Assurance Design Change Centrols and Corrective Acticn Systems -
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i . 1( APPENDIX B p0TENTIAL ENFORCEMENT FINDINGS ! As a result of the Ccnstruction Appraisal Team (CAT) inspection of January 24 - February 4,1983 and February 14 - March 3,1983, the following items have been . referred to NRC Region IV as potential enforccment findings (Section 1 references are to the detailed pertion of the Inspection Report). 51ectrical and Instrumentation Construction , @{ .j v Centrary to 10 CFR 50, Appendix B, Criterien X and FSAR Section 17.1.10, certain inspecticn activities were not executed te verify installation '0 c:nformance with.precedures including cable spacing in trays, cable bend radii, cable fill, cable supports and tray installatien hardware (Sections II.3.1.a b, d, and II.S.4.b(1)). (2.) As Centrary the estaclisnedtoinspection 10 CFR 50, did pregram Appendix not provide B, Criterien adecuate centrolsXVI to and 11FS assure that deviations frem electrical and electrical / mechanical separa- J tien criteria as defined in the FSAR were prcmptly identified and cor-rected (Sectiens II.S.I.f. II.3.4.a. and II.S.4.b(2)). h Centrary to 10 CFR 50, Appendix 3, Criterien V . FSAR Section 17.1.5, and 15EE Standard 450, precedures to implement inspection activities relative to certain as:ects of battery maintenance have not been develcped or implecented (Section II.5.3.c.). Mechanical Construction , dh i s 1.) Centrary to 10 CFR 50, Ap;endix B, Criterien V, FSAR Sectien 17.1.5, y/ and GI-0Ap-11.1-28, certain OC ac:ectec ASME pipe su::cris/ restraints ar
', TW # ne installed in ac:ctdance with the design document to which the pipe a
su:per:s/ restraints were inspected (Section III.S.2). 2 Q Centrary :: 10 CFR 50, Appendix S, Criteria X and XVII, and FSAR g ,0 b (
) Sections 17.1.10 and 17.1.17, an ins:ection pr: gram has not been as j#- es:aclisnec :c verify and dccument instr.11atten c:nformance to crawing J recuirements in regard to pi:e su::cr:s/ restraints and mechanical equip-ment installatiens (Section III.3.2 and 3). !
@ Cen:rary to 10 CFR 50, Acpendix 2, Criteria V and X, and FSAR Secticns h
17.1.5 anc 17.1.10, installed and QC accepted heating ventilation and air
.( concittening d.0
/ re:uirements.(HVAC) cuct, sue:cr s and ecuipment do not c:nfer= to design In adcitten, ins:ecticn prececures have not been established J
u s .~f cr executed :c verify c:nformance of HVAC su:perts to design crawings
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1Weldinc and Nondestructive Examinatien f Centrary tc 10 CFR 50 Appendix B, Criterien IX and FSAR Section 17.1.9,
- p( ' certain special prcces,ses relative to the HVAC system were not adecuately
# centrolled, including improcerly qualified precedures; imprcperly cualified j,0p inspecters; imprcper certification of NDE personnel (Section IV.S.3). 1 I
Civil and Structural Ccnstruction 0 Centrary to 10 CFR 50, Appendix B, Criterion V and FSAR Section 15.1.5, civil cccstruction test precedures were inadequate to ensure that mixer uniformity j9 1 3 tests as required by the ASME-ACI-359 Code were performed at the prescribed 4
/\ frequency (Section V.S.2).
Precurement. Sterace and Material Traceability J V Centrary to 10 CFR 50, Accendix 3 Criterion XIII, FSAR Section 17.1.13, q9'O+ CF-CAF-8.1, Rev. 5, CP-CPM-8.1, Rev.1, and MCP-10 Rev. 7 storage of certain s
- safety-related equipment in outside lay-down areas and installed in the plant
'f was net properly centrolled (Section VI.S.2).
Cuality Centrcl Inscector Effectiveness c 1. Centrary to 10 CFR 50, Appendix B, Criterion II and FSAR Secticn 3.8, N t jfI individuals were certified to levels of cacability without the recuisite )
- y experience described in Regulatory Guide 1.58 (Section VII.B.2.a.(2)).
- w
.0 2. gb, Centrary to 10 CFR 50, Appendix B, Criterion X and FSAR Section 3.8, inspectierr records were prepared and accepted by L-I inspectors as the j'Q0 3
"inscacter of reccrd" rather than the recuired L-II "inspecter of recerc" required by ANSI.N'5.2.5 (Section VII.S.2.b(1)).
Cuality Assurance
/
- 1. Centrary te 10 CFR 50, Accendix 3, Criterien XVIII and FSAR Secticn 17.1.18, OA audits have not been conducted at a frequency or at sufficien dacth to identify and ccrrect significant problems in varicus areas of ccnstructien; i.e., HVAC and electrical separatien (Secticn VIII.B.2.b (5)(c)). ,.
- 2. G Centrary te 10 CFR 50, Accendix B Criterien XVI and FIAR Section 17.1.15, aucit fincines related to maintenance instructicns identifiec in 1979,
% ~- ~ 1951 anc 1952 were not resolvec in a timely manner (Section VIII.B.2.b.(5)(c)).
3. Centrary to 10 CFR 50, Appendix B, Criterion VI and FSAR Secticn 17.1.5, 40.0ft drawines with cut-of-date revisicns and drawines with damaced er unreac- #
.abletitleblockswerepresentincenstruction'workareas(Section VIII.3.2.e.).
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_~ - _ . . ~~ -- . _ . _ _ A q Desien Chance Centrols and Corrective Action Svstems g 1. Centrary to 10 CFR 50, Appendix B, Criterien V and FSAR Section 17.1.5, j }g transmitted to the Quality Centrol organization such that an apprcpriate Oh 0 procedures were not adequate to assure design changes were properly i inspecticn eculd be perfor=ed (Sections IX.S.4, 1.b and IX.S.I.c).
- 2. Centrary 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 seme OA [
safety-related hareware installations are not being properly docu evaluated, and dispositioned thrcugh the Corrective Action Program. (SectionIII.B.T.IV.S.2andIX.S.2)). . G l e 9 I i 0 d 33
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o . A 3 II. ELECTRICAL AND INSTRUMENTATION CONSTRUCTION
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A. OBJECTIVE I g 1 The cbjective of the assessment in this area was to determine whether safety-related electrical and instrumentatien c:mpenents were being installed and inspected in accordance with aperoved engineering designs, regulatory requirements, and the applicant's FSAR ccmmitments. Additional objectives were to determine whether procedures, . j instructions, and drawings used to accomplish construction activities
- were adequate and whether quality-related records accurately reflect j the c:mpleted work.and the inspected activities. .
- 3. DISCUSSION
- 1. Electrical Cable Installation The NRC Cc'structien n Appraisal Team (CAT) inspectors selected a samole of installed electrical cable runs that had been inspected by i
Quality Control (QC) inscectors. The sample include'd pcwer, control and instrument cables. For each of these cables, physical i inspection of cable was made to ascertain ecmoliance with applicable l design and installation criteria relative to size, type, lccatien/ routing, band radius, protecticn, separation, identificatien, physical leading and supports. The follcwing power cables, totaling accroximately 1,800 feet, were selected frem different systems, electrical trains, physica1 a lccations and sizes. , Cable No. Tvee Frem To E01001613 1/c 750 MCM W-108 EFSWE301-02 EFMCE307-06 EGIC0337A 1/c 750 MCM W-208 EFSWESC4-07 EFMCE304-01 E01C0410 3/c 6 AWG W-120 EFMCE301-09 TEXCSAPBA01 EG10C037 1/c 4/o AWG W-206 EFSWEA02-11 CFICTAFC504 AGIC0355 4/o TRIFLEX W-812 EFSWE504-09 Fenetratien E11 The following instrument cables totaling apprcximately 1,000 feet were selected and inspected to confirm the previously stated I 1 installatien attributas. t Cable No. Tyee Frem To E0125235 1 SiiD TW Fair Cent Spy Fmp C2 ' 50F Inst PNL 01 15 AWG W-165 EG 125262 W-270 Elec Fenetratien. Term Box i E-14 for ILT4781 A sampling of a:pr:ximately 1,200 feet of installed electrical
~ c:n:rol cable was selected fr:m varicus areas of the plant. The N inspection was per# rmed by examination of cable segments within s
4 selec:ed cable tray sec:fons installed in the Safeguares, Auxiliary, Cen:rol anc Cantainment builcings. It sneuld :e noted that nis methed of sampling did not c nfirm the specific reuting of cables. i 11-1 6 s e _ "m-*-'" ## E9 ) -# " * *
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A detailed explanation of this matter is covered in the following paragraphs under Cable Identification. The NRC CAT inspectors g cbserved acproximately 500 feet of in-process cable pull activities. 3 This figure represents three centrol cable pulls, reuted in various areas of the plant. These were cable nuccers ECO21928 N/M, E0117573 and E0221ESS.
; The cbserved in-precess cable pull activities were p[trformed in accordance with procedural requirements. **
[a. Cable Scacine in Trav
- The design basis specifies that amcacities for cable instal-
! led in trays require derating based on their installed configura-tion.
l Gibbs & Hill Specification 2323-ES-100, Rev. 2, Section i 4.2.1.4, states in part, " Power cables run in cable tray shall have maintained cable spacing where so indicated in the cable and ,
- 1 raceway schedule and cable pull cards. Maintained spacing '
between cabies- (edge to edge) shall be a minimum of one quarter of the diameter of the largest cable". 1 Texas Utilities Generating Company (TUGCO) procedure QI-CP-11.3-25.6, Section 3.1.4, states in part, " a minimum secaration of one quarter of the cable diameter shall be main-tained between siderail of cable tray and adjacent cable". The i ! NRC CAT inspectors noted the following cable trays contained
- I -
improperly spaced medium voltage power cables:
/ Trav No, i
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/ - T12GABF27 T120A!!20 T12GABP71 T11GEA323 i
T120AE!!0 D" ' 71205ECC6
. T12GABF14 T11GSA506
- b. Cable Send Radius Gibbs & Hill specifica:f en 2323-ES-100, Pev. 2', Secticn 4.2.2.3, states, " Cables shall be trained so that the minimum bencino radius for pertinent plant cable training is not exceeded". ~
TUGC0 Precedure OI-QP-11.3-26.5, Revisien 16, Section 3.1.1, states in part, "The QC inscector shall cetermine the minimum bend radius" for the cable being installed or removed, and snall incluce minimum bend radius ins:ec:f en during the surveillance. i
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1 The NRC CAT inspectors noted electrical cables that were installed with folicwing less than a11cwable minimum bend radius locations: ' in'the . I( Cable No. or Tyce Locatien 0120532 Battery Charger No. BCIEDI EG102592 Battery Charger No. BCIED2.2 iB) Train Type W-216 T12GCBF82 - 1/t0102534 T120C8031 T12030560 1/c Type W-206 T11GEA837, C11G05112 CableTravFIll The Comanche Peak Station (CPSES) FSAR, Section 8.3.3.1, states in part, " Cable tray fill criteria generally limit the. summation of the cr:ss-sectional areas of control.csbles and pcwer cables to a maximum of 40 and 30 percent, respectively, of the useable cross section of the tray. However, these percentages may be exceeded provided the folicwing conditiens ,are satisfied: 1 (1) Cables do not extend above the side rails of the cable tray. ( (2) For power cable the thermal rating of the cable is not exceeded. (3) Cable tray support design is adequate..."
' During the inspection of installed electrical cable, the NRC CAT inscectors identified cables that extended above the side rails of Cable Tray Nos. T12G53G22 and T13GACD14
- d. Cable Su : ort.s. - .
Gibbs & Hill Scecification 2323-ES-100, page 4-5, paragrach (b.) states in part, "Where succorts for cables in vertical cable tray and c:ncuit are not shewn on the drawings, tcp-of-riser sue orts... and additional sucports if required for long vertical risers shall be provided by the centracter to meet the folicwing
; recuirements:
* (1) Su::Or.s shall be Kellem's mesn grips or engineer a: proved equal...
(2) One cable support shall be provided at the top of vertical raceway or as close to the tcp as practical. A su:: ort shall be provided for each additional interval as specified in the 4 fellcwing table: ... " f The NRC CAT inspectcrs identified several runs of 750 mcm 6.9 kV SHLD cable installed in vertical riser Tray No. T11GSA501 and T11GSAS.15 of over 100 feet, withcut specifiec supcorts. ~ II-3
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i( The CPSES FSAR requi*es that all Class IE cables be' identified by I a nine alphanumeric character tag.
- Gibbs & Hill Specification 2323-ES-100 further requires that identification tags be placed at the termination point of the cable; for example, in an equipment housing or at a terminal box. .
During the inspection of the selected sample of Class IE control - cables, it became evident that without a more liberal use of
- identification tags, it would be extremely difficult to trace the i physical routing of the samples selected. This was due to the '
' quantity of cable installed in the tray, which in some cases completely buried the selected cables for extended distances.
It was dec'ided by the NRC CAT inspectors that the control cable sample wculd be made by an examination of cable installed in selected tray segments frem varicus areas of the plant. While this method cf sampling could not confirm the total reuting of c:ntrol ecles, it did provide adequate assurance that other quality attributes of cable installation had been met.
!Mscussions with the contractors electrical QC group revealed that further difficulties with cable identification are en-c:untered when installed class IE control cables sustain in-sulation damage. The repair procedura requires that the cable to be repaired or replaced must be identified. To accomplish this, ,'
the QC inspect:r may often attempt to trace the cable to its terminatien point by the " hand-over-hand" method. Where this is not possible, extensive evaluation of raceway schedules are made througn the process of elimination to determine which of the cables c:ntained in that tray are of the type, si:e anc reel f:etage as the one whien is damaged. This process has been fcund ; to be time-c:nsuming and not always accurate. An example was given of cne damaged cable which was identified and pulled cut, only to find that it was not the cable it was thcught to be, althcugn current cable identification methces are in c:nformance with a;mlicant cemitments, the practice of placing
/ identification tags only at cable ends has hindered the installatien and inspecticn effort.
. Electrical Se:aration i
5 The CPSES FSAR, Section 8.3.1.4, states in part, "The minimum separatien distance between recundant Class 1E ecufgeant and l circuits inches..." internal to the main centrol beards is maintained at six l' 1 During the ins:ection of cable terminations within c:ntrol beares, the NRC CAT ins;ect:rs icentified multiple instances where the six inch separation between recundant train wiring had not been =aintained. Scme of these ac eared to have been caused by impr:per training of cables within the panel, others were a II-4
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result of the location of the terminal point on a device and its j q proximity to a device of the redundant train, if The electrical QC organi:ation has documented many of these cenditions by use of the Nonconformance Report (NCR)or as a j punchlist item. Hewever, there appear to be instances which have not been addressed and/or corrected, ) l i Gibbs & Hill Specification 2323-ES-100, Secticn 4.2.2.3, states ..- in part, "In the event that the above separation distances are not maintained, barriers shall be installed between redundant
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Class 1E wiring. For main control boards, Service Air Ccmpany stainless steel flexible conduit type 5563 shall be used as a barri er." The NRC CAT inspectors observed two installed barriers whose c:nfiguration provided inadequate protection between redundant wiring as well as barriers installed in the main centrol boards of a type other than Service Air Company stainless steel flexible conduit type 5563 as required. '
- 2. Electrical Cable Temination An inspection of a selected sample of electrical cable end terminatiens was performed to detemine ccmpliance with the acolicable requirements. Inspection attributes included verification of proper lug material and size, proper mounting hardware, accurate location and identification of terminal blocks and points, proper r crimp and crimping teol, verification of the calibration status of teol and instruments used, and proper terminating of cable conductors. The NRC CAT inspectors inspected cable end teminations en the follcwing cables.
Cable No. Tyoe ' Location EG112182 7/c CP1-ECPRTC-05 EG016018 9/c CPI-ECPRTC-05 EG127547 8/c CPI-ECPRTC-05 E0109846 9/c CPI-ECPRCR-03 E0112867 12/c CPI-ECPRCR-03 E0109511 2/c CP1-ECPRCR-03 E0110070 12/c CPI-ECPRPR-03 E0139235 12/c CPI-ECPRTC-01 A0118460 2/c CP1-ECPRTC-01 .
' A0123795 9/c CPI-ECPRTC-01 EG113353 12/c CPX-ECPRC3-01 EG'.13355 12/c CPX-ECPRC3-01 .
EG1130904 2/c CPX-ECPRC3-01 E0113348 12/c CPX-ECPRC3-01 AC016325 2/c CPX-ECPRCS-01 E0113331 12/c CPX-ECPRCS-01 E013SSS2 3/c CPX-ECPRCS-01 EG113361 7/c CP1-EPMCE3-02 i II-5
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EG113367 7/c CPI-EPMCEB-02 EG113368 2/c CP1-EPMCE3-02 g EG1132SS 2/c- CP1-EPMCES-02 3 EG100474 3/c CP1-EPMCE3-02 E0113354 7/c CPI-EPMCES-01 E0113365 2/c CPI-EPMCES-01 E0113366 2/c CP1-EPMCES-01 E0113285 2/c CP1-EPMCES-01 E0100414 3/c CP1-EPMCE3-01 . E0115077 7/c CPI-EPMCES-09
- E0113274 2/c CPI-EPMCES-09 E0113542 2/c CP1-EPMCES-C9 E0113865 2/c CPI-EPMCES-09 E0100E90 3/c CP1-EPMCE3-09 E0125664 3/c CP1-EPMCES-09 EG100701 3/c CPI-EPMCES-08 EG109259 2/c CP1-EPMCE3-08 E0106198 '
2/c CP1-EPMCE3-07 E0109253A 7/c - CP1-EPMCEE-07 E0132388 2/c IPT-2327 The NRC CAT inspectors also observed the in-process termination of four Nuclear Instrument System (NIS) Triax connectors. These were completed in various channels of the Reactor Protection System (RPS) system as fellcws: Ca'ble No. Channel EY140790 IV E3140711 III ER14C509 I EY140794 IV Two instances of improperly ter ninated conductors were noted in the fellcwing lccations, and were subsequently documentec by OC personnel cn an NCR. Cable No. Location A0123795 CPI-ECPRTC-01 754-94, 96 (Terminal. lugs are not properly tightened) E013331 CPX-ECPRC3-01 (Insulatien damage to green conductor at terminal point SS)
- 3. Electrical Ecui: ment Installation A sa= le of thirty-five pieces of installed electrical etuictent were inspected. Sa:cles were selec ed from both Unit 1 and 2, based on system functien and safety classificaticn. Ceepenents selected included the follcwing:
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- a. Motors The installatten cf fcur motors. and as:cciated hard.eare its I( inspected for suen items as location, anchoring, grounding, identificatien and protection.
Motor Identificatien Component Cooling Water Pump Motor No. CP1-CCAPCC-01M RHR Pump Motor No. TBX-RHAPRH-01M ..? RHR Pump Motor No. TBX-RHAPRH-02M Safety Injection Pump Hotor No. TBX-SIAPSI-02M During the inspection of these items, it was noted by the NRC CAT inspectors that in several instances the motor or pump had not been grcunded. Discussions with the electrical QC gr:up revealed that grcunding was not regarded as a part of Class 1E equipment at CPSES and therefore dcas not receive QC inspection. The NRC CAT inspect:rs cencluded that the installhtien activities relative to the abcVe, electrical equipment were perforned in acc:rdance with procedural requirements. Grcunding fer motor or pumo casings, which is required for persennel safety and protec-tien, had not been performed in several instances. Reinspection of electrical equipment is discussed in paragraph 8 of this section. -
- b. Penetra:icns The follcwing installed centainment penetration assemalies were inspected:
Number Elevatien, Feet 1E49 810 1E14 870 1E46 843 2E23 856 The locatien, type, meunting and identification were c:m;ared with the installa:icn drawings. GC records asscciated with inspecticn of these items were also reviewed. Activities cbserved and d6cumentation reviewed incicated werk performed in this area was in ac: rcance with requirements.
- c. Met:r Centrel Centers .
The follcwing 450 V motor control centers (MCOs) in the Auxiliary and Safeguarcs buildings were ccmpared to installaticn drawings relative to location, counting and icentificaticn: II-7 _ ___ . . - . ._--_ .----,--,: , ~ - ~
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') No. I!33-2, CP1-EPMcE3-05 1
3( No. 1E34-2 CPI-EPMCE3-06 .- No. 2!31-1
, CP1-EPMCES-01 4
The insta11atiens reviewed indicated work was perfemed in accor-dance with requirements.
\
- d. Switcheear l
'
- l The following 6.9KV switchgear was inspected and compared to insta11atien drawings relative to locatien, mounting, and identification.
Switcheear Identification ' ! No. 1EA1, CPI-EPSWEA-0 i No. 1EA2, CP1-EPSWEA-02 j No. 2EA1, CP2-EPSWEA-01 i No. 2EA2, CP2-EPSWEA-02 Insta11atien activities relative to these switchgear were per-1 formed in accordance with requirements. l , ; e. Station Batteries
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i The ' Unit 1 125V vital battery rooms were inspected, including the ' iristalled batteries, battery racks and associated equipment. The locatien, mounting, anc environmental control for installatien
- No. B7-1EDI, CPI-cPSTED-01 and No. BT-1ED2, CPI-EPSETED-02 were c
- mparoc with applicable requirements and QC inspection rec:r s.
'J I i j During the inspection of these items, the NRC CAT inspec crs i < identifad that there was a considerable amcunt of activity in the battery recms. This was cue to preparation for relocaticn of the vital battery cells so that rework of the seismic battery racks c:uld be ace:molished. The inspectors observed that altncugn the batteries were charged and in a state of operation, there were no signs posted to prenibit smoking or open flaces. Additionally, c:ncrete chi:;ing activities in the wall accve the batte. ries had lef: :e:csits of c:ncrete en the cells themselves. Discussiens i with tne electrical GC gr:un revealed tnat the 125V batteries had i been under the c:ntrol of TUGC0 since 1979; and had been moved
- twice since initial installation. During these moves, j'
rescensibility for ins:ecticn of attributes asscciated with j handling, meunting, protection, and re-energi:ation was given to a c:ntract:rs CC group. l The NRC CAT inspec: Ors cbserved the activities asscciated with reicca icn of the vital battery cells. During this activity, two cell casings were damaged and removed frem service. 3 II-B !
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m . n .m x / i w;, , w L;;., _ a s. . m 3 A review of records asscciated with maintenance of the vital gj batteries was made to assure that all attributes of the main: i tenance program had been accomp.lished and documented.' Items such - i 3 as cleanliness, cell voltages, specific gravity and electrolyte ! level had been inspected and dccumented on a regular basis. l Hewever, the NRC CAT inspectors observed that the CPSES FSAR, in Section 8.3.2.1, under " Testing and Inspection," states in part, !
" Periodic inspection and testing of DC systems are perfemed to menitor the condition of the equipment to ensure reliable ..'
cperation... All maintenance and testing procedures and criteria for replacement are in accordance with IEEE 450-1975, and Reg. Guide 1.129.. IEEE Standard 450-1975, Section 3.3.3 requires a yearly check and record of: (1 Call Conditien (Detailed Visual Inspection) (2 Cell-to-Cell and Teminal Detail Connection Resistance (3 Integrity of the Battery Racks . The NRC CAT inspectors found that the procedure used to perfom surveillance of these station batteries (No. ELM-701, Rev. 0) did not implement the requirements for yearly inspection of call-to-cell detailed teminal resistance, nor was there docu-mented evidence that these attributes had been inspected or verified. Discussions with the TUGC0 Electrical Maintenan'ce Grcup revealed + that the Electrical Maintenance Procedure No. ELM-715 was in the process of being issued to control activities associated with in'spection of call-to-cell detail terminal resistance performed te date.
- f. 125 Volt DC Svstem Etui;eent asscciated with the operation of the 125V DC System was inspected to verify comoliance with applicable scecifications and drawings. The NRC CAT inspectors selected the follcwing sample of equipment.
Identificatien No. Ecaiement EC-1ED1-1, CP1-E?BCED-01 Eattery Charger EC-1ED3-1, CP1-E?BCED-C5' Batterj Charger EC-1ED2-1, CP1-EFECED-02 Battery Charger SC-1ED4-1, CPI-EPECED-06* Sattery Charger IVIEC-1, CPI-ECIVEC-01 Static Inverter IVIEC-2, C71-ECIVEC-02 Static Inverter 59/1ED1 Overvoltage Relay 59/IED2 Overvoltage Relay 270C/1ED1 Under/oltage Relay 27DC/1EC2 Uncervoltage Relay 54/IED1 Grcund Protecticn Relay 64/IED2 Grcuno Protecticn Relay II-9
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i I 'These items were originally Unit 2 equipment transferred i a by Pemanent Equipment Transfer (P.E.T.) to Unit 1 - i / % -
! Installation activities reviewed indicated work was performed in 1 I( accordance with requirements.
I
- g. Emereenev Diesel Generator 1
The electrical aspects of the Unit 1 emergency diesel generator ... : (A and 8), including control cabinet wiring, were inspected for i
, location, mounting, separation, protection and identification.
These reviewed aspects indicated work was performed in accordance with installation requirements.
- h. Motor Ocerated Valves A samole of four motor operated valves (MOVs) was selected and inspected for items such as location, mounting, grounding, protection, and proper wiring. The MOVs selected were:
POV Identification No. 1HV4776/28537 No. 10611/650 No.1HV558/SF270925 No. 1HV4709/16142 Inspection of work performed in this area indicated the work was perfor=ed in accordance with requirements.
- 4. Electrical Conduit and Cable Tray Insta11atien
- a. Electrical Conduit The NRC CAT inspectors cbserved 86 runs cf installed electrical c:nduit, asscciated pull boxes, fittings, and the asscciated c:nduit succorts. Total footage of these c:nduit runs was accreximately 1,800 feet. The inspection revealed several ciscre:ancies in .the area of electrical conduit installation, inclucing many instances where covers to junctien/ pull bcxes, and c:nculets were not installed as required.
Discrepancies in the identification numcers between installed - c:nduits and the QC inspection reports in the QA vault were discovered. Further discussion of this matter is fcund in paragra:n 7 of this section under Precedure. Additicnally, werk performed may not have been inspecteo to tne acercoriate design dccument; specifically, c:nduit succert installations. Further discussien of this matter is fcuno in paragraph 8 of this section uncer Inscecticn Precedures. Relative to NIS c:nduit installation, the recuired se:aratien fr:m flucrescent lignt fixtures was not maintained. The CPS 55 II-10
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l l j FSAR, Section 8.3.1.4, states in part, "all nuclear instrumentation system (NIS) cables are routed in conduit i
![ according to their channel assignment...' Also, a minimum clear -
air separation of two feet is maintained frem conduit to 1 electrical noise scurces such as pcwer and red control cables." I - j TUGC0 in part, Procedure
"...a minimum OI-QP-11.3-29.1, Rev. 8, Section 3.1.2, states,
. separation of 2'-0" must be maintained between NIS conduit systems and fluorescent lighting fixtures and .. .
lighting of more thansystem conduits except for conduits crossing at an angle 15 degrees. The NRC CAT inspectors identified the' folicwing installed Class IE NIS cenduits which do not maintain
- the required separatien from fluorescent light fixtures. These were as follcws:
Conduit No. citewo45 . C16Y10039 JBIA-9157 C16Y10041
- 4
- b. Electrical Cable Trav Eight runs of installed cable tray, ccmprising 134 tray segments with an aggregate length of about 1,500 feet, were inspected relative loadin . to suoport location, separation, protection and pnysical
) Centro Samples were selected from the Reactor, Auxiliary, and Safeguards buildings. A randem inspection of an accitienal 500 feet of cable tray was also ecmpleted. l l
- 1) Cable Trav Attachments The NRC CAT inspectors observed several instances where cable tray; segments were not boltee togetner or properly attached to associated seismic supports, >
These instances were identified during the inspection of the folicwing caole trays: 4 Cg rav No. s mr.auo i T13GRCLO9 4 i T13GC7019 1 i 713GCF020 T13GACE94 l
- 2) Cable Trav Se:aration
, The NRC CAT inscectors identified instances of cable tray i! secaratien that did not meet the CFSES F5AR ccemitments, j Theseofins areas theances plant. reflect a conciticns that exist in other Examcles of deviatiens frcm recuirements were identified in the areas of recuncant train sacaration, internal centrol panel wiring separation anc electrical meenanical separation.
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m~ t j The NRC CAT inspectors noted that actions taken to correct separatien deficiencies have yet to be implemented. It is l'Q underst cd that the use of cable tray covers and other acceptab'e
;I fire barriers will alleviate a number of tt;ese problems; however, 1
there appear to be instances, particularly In the catescry of electrical mechanical separation, which may not be correctable withcut a significant amount of rework to installed ccmponents. j 1 The CPSES FSAR, Section 8.3.1.4, states in part, "The cable and .-
! raceway separation criteria are based on preservation of *
- independence of redundant systems... Cables of redundant Class IE circuits are run in separate cable trays, conduits, ducts and enetrations."
t "The raceways of cne train are separated from those of the other train by locating them in separate structures or en opposite a sides of large roems or spaces. Where this is not possible, u i separaticn is maintained as described belew, or by providing barriers. The Class IE cables are rcuted such that any single i failure in ene train system does not cause a failure in another j train system." i The CPSES FEAR, Section 8.3.1.4, continues: "In plant areas which are free from potential ha:ards such as missiles, external , fires, and pipe whip, the minimum separaticn between redundant cable trays is three feet between trays separated hori:entally and five feet between tray separated vertically." The NRC CAT inspectors identified the following installed Class IE cable tray segments which did not maintain the required separatien between redundant trains: Train "A" Train "B" T130AC351 From T13GAC279 T130AC354 Frem T13GAC271 T130AC353 Frem T13GCF008 T120A3523 Frem T23GACD85 T120ABA42 Frem T23GACD55
- Gibbs & Hill Scecification 2323-ES-1CO, Rev. 2, Secticn 4.3.2 states, "... cable tray shall not be placed witnin 6 inches of Class I er II piping or c
- =ponent welds unless otherwise approved by the cwners field representative (additional allcwance shall be mace for pi:e insulation). The se aration for non-safety related i
and Class III piping and cable tray is to be a minimum of 1 inch fr:m the Outside of the pipe or insulation." T'JGC0 Pr::ecure 01-0P-11.3-29.1, Rev. 8, Section 3.1.7, states in part, " Raceway and sue: orts shall not be located witnin (6) inenes cf Class I or Class II pioing welds or ::m;cnent welds..." Also, " Cable tray shall be separated fr:m piping er piping insulati:n by a minimum of (1) inch." II-12 y yy ny , , 3- - ~ ~ ~ ~ ~~'
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2 . - o - f' __ l l j The NRC CAT inspectors identified the follcwing installed Class 1E cable tray segments which did not maintain required separation 1 7 frem piping or pipe insulaticn.. l t : I[ ' Cable Trav No. (l ' i T13GACE79 T13GACZ92 T130 SCC 77 T1305CC78
- T1305CC79 T1305CC74 .
T13GACE79
' The NRC CAT inspectors discussed the above findings with the applicant's lead electrical engineer, and learned that the a:plicant is aware of the prcblems. The applicant is anticipating to perfcrm rework where possible, if not, other ; measures will be evaluated.
t NOTE: NRC Region IV, IE and NRR persennel are mesting with the i 1 licensee at the site during the week of April 4,1983, to further evaluate these and other electrical / mechanical
! separation .cenditions, i
I
' (3) Cable Trav Identification l T
> The CPSES FSAR, Section 8.3.1.3, requires that electrical raceway systems be physically identified by a nine alpha-numeric cnaracter tag num:er and color code system, which is to identify whether or not the given raceway c:ntains safety related cables.
The NRC CAT inspeciar examined the selected sample of Class IE cable tray and c:nduit to verify that identi'icatien tags and color c:cing were present, .and prcperly applied, relative to location, materials, and c:nfor-.ance with design drawings. All hareware inspected to these attributes satisfied tne identification requirements.
- 5. Instn: mentation The NRC CAT inspect rs selected a samcle, of instrumentation j
- c:=;cnents which monitor process variables c:morising the Reacter pr:tection System (RpS), Cc=penent Cccling System (CCS), and the ! Engineered Safety Features Actuation System (ESFAS).
t Instrument c:mpenents were reviewed to detamine if installatiens were ac::mplished in ac:ordance with c'esign drawings, acclicaele ceces and s:ecificttiens. Items sucn as lccation, mounting, identi-ficatien and protecticn were c:=;ared with installaticn drawings f:r the folicwing c =ponents: I II-13 _ --_ , _ -- - - , . m ~, - - - - - - -
y.. j -
.4 'I ; Pressure Transmitter Flow Transmitters 3 'g9 iju 1 PT-544 1 FT-2464 A 1 PT-2138 1 FT-2466 B i
1 PT-535 1 FT-2463 A 1 PT-534 1 FT-424 1 PT-4252 1 FT-426 l 1 FT-2465B
, 1 FT-414 - ;. Pressure Switch Flow Indicatine Switch 1 PS-4519 1 FIS-4650
{ Level Indicatino Switch ft 1 LIS-4754 - !! The NRC CAT inspectors observed approximately 700 feet of installed i! instrument tubing, supcorts, and associated hardware. Tubing was examined to verify such items as, preper material, slope, mounting, separation, and color ceding. The inspectors also examined inspec-i tien records associated with the installation of tubing and tubing supports. Ouring the inspecticn of instrument tubing, the NRC CAT inspectors a noted that in several locations, tubing runs had sustained minor J damage; specifically, dents, flattening, and disfigured instal-
' latien. It was determined that this damaca was due to c:nstruction activities which had occurred after QC inspection of the tubing.
Ca= aged areas were recorded by the contrac crs QC and reported on an NCR. i Other cbserved activities and reviewed dccumentatien indicated work 1 perfer:ed in this area satisfied the apprcpriate requirements. l
- 6. Calibraticn The NRC CAT inscectors performed an examination of the en-site Brcwn
& Rcot (5&R) Calibratien Facility. Included in this examination was a review of precedures and documentatien associatec witn calibraticn activities, an inspecticn of the calibra:icn facility to insure c:=pliance with the environmental conditions specified, and the inspection of a selected sample of calibrated tools and c:=penents.
The NRC CAT inspec:cr selected the following sample of reference standards, measuring and tes ecuipment, ano certified :cols. These were ins:ected -to verify properly documented calibration status, pre;er st: rage canditions, current and approved calibraticn re;crts on file, and traceability of itets associated with the s:c:les history file. II-14
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g'- ' No. RS-216 Digital Multimeter i g No. RS-086 Photographic Step Tablet No. RS-020 Outside Micremeter No. RS-094 "Go-No-Go" Gauge No. RS-067 Decade Resister Measurine and Test Ecuicment
- No. M&TE 1432 Dynamometer
! No. M&TE 1132 Micremeter Deptn Gauge No M&TE 1553 Megger Test Set No. M&TE 0156 Vernier Calipers i No. M&TE 1270 Soil & Aggregate Steve ; No. M&TE 1961 0xygen Analy:er j No. MATE 2409 Ory Filit Thickness Gauge i No. M&TE 2388 Current Transformer ! No. M&TE 1829 Battery Megger Tester ; No. M&TE 1995 f Ultrasenic Thickness' Gauge Certified Tools I l
No. CT-1365 Crimping Tool No. CT-0608 Torque Wrench No. CT-1606 Crimping Tool
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Items reviewed satisfied applicable requirements. This subject is also discussed in Section VIII of this report. j -
- 7. Preceduras The NRC CAT inspectors examined approved TUGC0 dccuments to verify that instructicns, precedures, and drawings used := ace:: plish elec-trical activities affecting quality contain the acpr priate inspec-tien anc/cr acceptance criteria.
Electrical QC inspections are being perfor=ed in ac::rdance with the TUGC0 Electrical Inspecticn Manual. During the review of these dccuments precedural inacequacies were identified in the follcwing areas: The ins:ectors cbserved examples of electrical c:nduit installattens whcse identifica:icn inspection numbers re: orts in did not match those incicated en the QC the vault. Discussions with Electrical QC persennel revealed that sc=e conduits are installed with a unit identification num er. These conduits are inspected and dccumented in ac: r:ance with the a:clica:le QC procedure. Subsequent to the ins:ecticn, the identification num:er may be changed in ac::rcance wi n EI-EF-1 (E-1) and Item 13(c) of 2323-El-1700, which state that,
- "The third character ceneting plant num er 0,1, or 2 is generated by the c:=puter frcm the first cable r uted througn the c:nduit."
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- t These identification changes are incorporated on Field Structural m Engineering (FSE) drawings and sent to the field for construction g use. Howe'ver, the F5E drawings are not controlled by the Occument g
Centrol Center (CCC) nor are they used by QC for inspection. As a result of this, the CC inspection records may not indicate the true identification number of the installed conduit; further, there are no procedural requirements which address reinspection of these items.
] A list of over 100 conduits affected by simi.lar changes were l
- reviewed by the NRC CAT inspectors. These items were fcund during randem inspections performed by the QC grcup. In scme~ instances, j the list indicated changes not only in the unit designater, but in jj '
voltage level and recundant train designations as well. Inspection i' precedures which do not address reinspection of modified, previously accepted ccmpenents does not appear adequate.
- 8. Inscection'Reccrds The NRC CAT inspectors reviewed records generated for inspections j
1 - that were perfor=ed relative to cable tray, cencuit, electrical cable installation, cable termination, electrical equipment installaticn, seismic supports, instrument tubing, and instrument {, installation. 4 I l
; ) Assessment was perfor=ed in this area to determine whether inspecticn records have been properly prepared, maintained, and centained dccumented evidence of inspection completion and results.
l Elect ~rical anc instrumentation inspection records were secred in the i QA reccrds vault, and were identifiable and retrievable. Inscacticn recercs were ce=pleted in accordance with the applicable quality centrol procedures. The records identified the QC inscector, the type of cbservatien by precedural reference, accactability, and reference to documents pertaining to identified deficiencies. The NRC CAT inscectors questioned the adecuacy of dccu=entaticn asscciated with reinspection of previously accepted items. In the case of sc=e electrical ecuipment records, the reinspection signatures for ecui; rent that was relccaced per Design Change Autnerica:icn (CCA) were not found in the ecuipment receres package, but were en a traveler initiated by the civil / structural grcup. Acditionally, attributes verified by the original inspection rescr: were not scacifically addressed in this subsequent dccumentaticn. The NRC CAT inscec:crs were unable to determine, frem the reccrds available, the extent of the reinspection which was perfor:ec. Similar cenci:icns were cbserved in the review of recercs asscciated with inscecticn of electrical cencuit and cable tray supper:s, many of wnich have been =ccified by ccmcenent codificaticn changes (CP.Cs) ' with multicle revisiens,~ and whose inspecticn receres indicate inspecticn dates which do not reflect the dates of the latest revisien of ne CPC (this matter is discussed in detail in Section IX cf this recer ). II.16 n -. - .-
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T Additionally, there were examples of documentation of conditions s which deviate frem requirements by use of systems other than the NCR
; j system. Exa=cles include the use of Request For Informatien g
l Clarification (RFICs) to document deviations frem requirements rel4tive to electrical separation. The engineerin RFIC was, in effect, a disposition of the prcblem,g response and in scmeto the l instances was used to initiate field rework. The use of the RFIC in ,; this manner is censidered centrary to QA program requirements. Also, the NRC CAT inspectors found that punchlists were used to dccument deficiencies. Some of these deficiencies were censidered to be nonconforming ccnditions by the NRC CAT . inspectors. Folicwing the review of inspection records. the NRC CAT inspectors g related the following concerns to the B&R QC supervision:
. That some records do not show the extent nor do they adequately reflect the reinspection activities for previously accepted
{ items.
. That the mathed of documenting deviations frem requirements relative to electrical separation, and the method of identifying and dispositioning discrepancies thrcugh the exclusive use of punchlists were not in accordance with QA procedural requirements.
3J e I 1 l 1 l i II-17
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, j
e . III. MECHANICAL CONSTRUCTION
,( ]
A. Cbfectives l The cbjective of the assessment of mechanical construction was to determine if installed and QC accepted safety-related mechanical items conformed to engineering design, rsgulatory require. tents and licensee ce=itments. Additional cbjectives were to determine whether procedures, instructions, and drawings used to ac:cmplish . ccnstruction activities were adequate and whether quality-related
- records accurately reflected the completed work and the c:mpleted
; activities.
- 3. Discussien
} The specific areas of mechanical construction that were evaluated ..
were piping, pipe supports / restraints, mechanical equipment, and { heating, ventilating and air conditioning (HVAC) equipment. To j acccmplish the cbjectives stated above, the fellcwing activities were performed in each of these areas:
' A detailed field inspection of a sampling of QC accepted hardwa re.
A review of precedures and documentation. Discussion with responsible QC and Engineering persennel to determine overall kncwledge of site procedures, inspecticn and acceptance criteria, and to identify prcblems with procedures, design / field engineering /QC interfaces, inspector qualification, and QC indepencence.
- 1. Picina A sample of piping runs was selected to include different systems, building Iccations, configurations, and si:ss. The follcwing lines, totaling approximately 600 feet, were selected for inspection:
System Drawines Si:e Diameter Containment Scray BRP-CT-1-SB-027, Rev 3 2" Auxiliary Feedwater BRP-AF-1-SB-006, Rev 11 8" & 10" ' ERHL-AF-1-SE-006, Rev 2 Centainment Spray BRP-CT-1-53-023, Rev 3 2"
- Residual Heat Remcval SRP-RH-1-RS-003, Rev 5 3" BRHL-RH-1-RS-003, Rev 2 Residual Heat Removal ERP-RH-1-RS-C01, Rev 13 12" CRHL-RH-1-R5-001, Rev 2 Auxiliary Feecwater SRP-AF-1-SB-025, Rev 11 4" BRHL-AF-1-SB-025, Rev 2 1
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Centrol BRHL-CS-1-RS-023, Rev 0 2" Safety Injection BRP-SI-1-AB-002, Rev 5 4" BRHL-SI-1-AB-002, Rev 0 The above runs were inspected in the field for proper configura- .. l tien, identification of valves, surface condition, valve orientation, bolted flange connections, interferences and support / restraint location, and function. .The following dccuments provided the basic acceptance criteria for the i inspections:
. QI-QAP-11.1-25, Rev 9, "ASME Pipe Fabrication and Instal-lation Inspections" .
QI-QAP-11.1-31, Rev 5, " Installation Inspec, tion of Mechant-cal Joints" Applicabla piping isemetric drawings (BRPs) and hanger location isometric drawings (ERHLs) Pipe Supports / Restraints are installed and inspected te detail drawings. The NRC CAT inspectors utilized the BRHL isometric to verify support / restraint function and location as a check that the piping was installed and supported / restrained as analyzed by the designers. Not all supports / restraints had been installed at the time of inspection. The piping configuratien, valve , identification, support / restraint location and function, and flanged joint makeup appeared to ccnfon:t to precedural drawing requirements. , The Cemanche Peak Steam Electric Station (CFSES) pregram accressing IE Sulletin 79-14 (79-14), " Seismic Analysis for As-Built Safety-Related Piping Systems", was reviewed. l Precedures governing these activities are as folicws: i CP-EI-4.5-1, Rev 8, " General Program for As-Built Piping Verification"
. CP-QP-11.13, Rev 5, "As-Euilt Verification" OI-QP-11.13-1, Rev 8. "As-Euilt Piping verificatien Instructicns" The 79-14 program is basically part of a continuing l as-built / piping analysis iteraticn process. The as-built s
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survey package for stress prcblem 1-017 (a portion of the s Safety Injection System) was examined and the as-built survey deficiency punchlist ccmouter printcut for problems - l 1-003, 1-006, 1-007, 1-010A, 1-010C, 1-0198, 1-021 and
' il 1-028 were reviewed. Program details were discussed with )
the Texas Utilities Services. Inc. (TUSI) Technical Services Sucervisor (responsible for engineering aspects) . and the TUSI QA Specialist Supervisor and As-Built Coordinator (responsible for field inspections). .. i
- As a result of this "As-Built" review, the NRC CAT inspec-i tors identified concerns as to the ~ exclusive use of punch-
- lists to document discrepancies between detail drawings and i
as-built hardware (versus a documented / controlled method of identifying, correcting and preventing recurrence of deficiencies). The above procedures do not involve the
, nonconfor. nance procedure or otherwise involve the cuality assurance program in addressing discrepant conditions on QC accepted piping and supports / restraints. Specific examples of this concern are detailed in the support / restraint section of this report. The related program requirements are discussed in this report in Section IX.S.2 " Corrective Action Systems."
- 2. pice Succor s/ Restraints ASME pipe support / restraints are fabricated, installed, and QC inspected to detailed drawings prepared by ITT Grinnel, Nuclear Power Services Industries (NPSI), or TUSI Pipe Support Engineer-ing (PSE) and applicable Comconent Modification Cards (CMCs).
Small born (less than 2i" dia.) Class 2, 3 & 5 supports / restraints may be shewn on typical drawings or on " engineered" detailed drawings. Suppurts may be " final" inspected several i times based on subsequent changes to original design; because of I the issuance of revised design drawings, and primarily by the issuance of CMCs by PSE (field engineering). When engineering considers that the " final- as-built" stress analysis has been perfor:ed and there is a high probability that furtner changes to the sucport will not be recuired, a Vencer Certifiec Drawing (VCD) for large bore supperts and a Design Review Drawing (CRD) for small bore supports is issued. These drawings incorporate any "information only" type CMCs and any modifica:1cns necessitated by load changes. QC then inspects the supports for those features revised by the VCD/CRD and for obvicus missing parts. The follcwing samcle cf 24 installed and QC accepted pipe succor:s/ restraints were selected for inspection to previce a variety of types, si:es, systems ano locations: ,i III-3 "Q V}TF #' ) ) T ~ A l , ,7 ~ } ,y
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m 4 Succort/ Restraint No. Lccatien Size Class Tvce RC-1-015-708-C41R Cont. 2" Strut [ CC-2-AS-023-002-3 SI-1-SS-233-006-2 Aux. Safeguards 2" 3 1 Strut
' 11" 2 Box SI-1-068-706-C42R ~ Cont. 2" 2 Box RH-1-004-007-532R Safeguards 12" 2 Strut
- CS-1-357-001-522R Safeguards 6" 2 Strut SI-2-031-425-Y32R Yard 12" 2 Box .
CS-2-063-413-542R Safeguards 8" 2 Strut
- RC-2-121-401-SS2R Safeguards 3" 2 Strut CS-2-012-403-C42R Cont. 3" 2 Strut CC-1-136-706-E63R Electr. 3" 3 Strut SI-1-037-005-532A Safeguard 8" 2 Anchor FW-1-017-702-CS2K Cont. 18" 2 Snubber CC-1-116-037-F43A Fuel 12" 3 Anchor CT-1-002-008-532R Safeguards 16" . 2 Strut
' CC-1-116-006-F33R Fuel 12" 3 Strut
'RH-1-003-002-542R Safeguards 12" 2 Strut
-CS-1-063-008-522R Safeguards 8" 2 Box
,/) SI-1-031-046-Y325 Yard 12" 2 Spring y
RH-1-001-001-C41S Cont. 12" 1 Spring SI-1-092-008-C41K Cont. 6" 1 Snubber CS-1-001-016-C42K Cont. 3" 2 Snubber
-C5-1-055-010-5425 Safeguards 4" 2 Spring RC-1-075-026-C61R Cont. 4" 1 Strut Scme of these' suoports had VCDs issued, seme did not. The above sucperts were inspected against their detail drawings and CMCs for configuration, identification location, fastener / anchor
' bolt installation, clearances, mem,oer si:e, and damage /protec-tien. In addition, acproximately 200 additional supcorts were cbserved in the field for obvicus deficiencies such as loose or missing fasteners, improper clearances or angularity, damage and impreper expansion anchor spacing.
Accectance criteria for the field inspections are centained in the fellcwing documents: Catail support / restraint drawings and acplicable CMCs Tycical drawings inciucing small bcre General "etes drawing CP- AA-001 OI-0AP-11.1-23 Rev.16, " Fabrication, Instaliatien Inspec-tiens of ASME Component Supports, Class 1, 2, and 3" CI-QAP-11.1-28A, Rev. O, " Installation Inspectien of ASME Class 1, 2 and 3 Snubbers" GI-CP-11.2-3, Rev. 11. " Torquing and 5; acing of Concrete
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The follcwing discrepancies were identified on the supports / restraints inspected: , f . U-bolt c:nfiguration not per drawings: e- k D 3-028-532h AF-1-059-001-533R
, - '/-
H-RC-1-Ra-039-015-2 H-CS-1-RB-017-001-2 3 H-RC-1-RS-035-004-2
, . Lug to restraint clearance excessive:
- I 00-2-01g-007-F33R (11/32" vs 3/32")
i . Dimension not per drawing:
.N RC-1-075-026-C51R (2' 4 3/4" vs 2' 10 1/2")
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. Richmend insert anchor bolt threads not as required:
CS-1-001-016-C42K
. Snubber load pin missing:
FW-1-017-702-CS2K
. Void in c:ncrete near c:ncrete expansion anchor:
SW-1-102-716-Y33R
. L ese strut locknuts:
.~ SW-1-003-002-A33R SI-1-044-025-532R?
. Missing / broken cdtter pins:
14 supports
. Class 3 hanger mismarked as Class 2:
H-GH-X-AB-0042-003 Numer:us c:ner instances of loose locknuts, U-belts, anc missing or breken cetter pins were cbserved en Class 5 supports / restraints that were under the TUGC0 QA/0C pr gram. Contri-buting to the preolems identified with U-bolt installations are c:nfusing drawings which snow U-bolts with 1/15 inch clearance recuirec, but also with dcuble nuts en the cutside of the retaining plate. Clear acceptance criteria is needed prior to A inspectiens being performee. 1
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e . l The NRC CAT inspectors witnessed the QC inspection of fifteen small bore supports and six large bore supports to the VCD per procedure CP-QAP-12.1. Twelve of the small bore supports were [ satisfact ry. Three were unsatisfactory due to drafting / des.ign i
- errors, primarily due to incorrectly incorperated CMCs into the VCD. Three of the large bore supports were unsatisfactory with an improperly welded bracket, two undersized welds, a missing
, high strength pin and an improper clamp spacer.
Discussiens with the Supervisory Authorized Nuclear Inspector
* (ANI) indicated that there were deficiencies with the accepted I hangers and difficulties in detarmining the specific activities '
perfomed during the fabrication / installation phases. The ANI office has recently been receiving completed ASME support /
' restraint packages for review and acceptance for the A3ME Code )
4 Data Report. Of the initial packages of QC accepted VCD supports / restrajnts that were inspected in the field by the ANI, approxi-
) mately 10% (13 of approximately 130) have been returned to 21R QC due to undersized or otherwise unacceptable welds. The ANI 1
was inspecting these installations for basic configuratien and welding details only. Of approximately 665 vender certified, QC inspected supports forwarded to the ANI on or before February 23, 1983, approximately 100 had been returned for deficiency corrections. 1 The NRC CAT inspectors reviewed the deficiency punchlists
. generated by QC during the VCD inspection. Six punchlist items for hangers were selected (biased sample) to verify that noncon-forming conditions were being properly identified and action to taken. Two of these items, an 1
prevent recurrence impr:perly was being(CS-1-063-046-522K) and expansio installed U-bolt anchor spacing not per drawing (FW-1-098-008-C525), are con-sidered by the NRC CAT inspectors to be noncenforming condi-tions, but were not documented by QC on NCRs. Subsepuent to the NRC CAT inspector requesting an evaluation of these items by QC, NCRs were issued. Three more items concerning undersized, missing, or discrepant welds (CC-X-032-700-A43R, CC-1-151-004-553R, CC-1-131-013-543R) had been documented on NCRs. However, review of the dccumentation packages and applicable revisiens to the i support / restraint d" wings and CMCs indicated that none of these j welcs had bcEn changed by drawings or CMCs since the " final" QC inspectien acceptance of these supcorts. The fact that tne supports were accepted originally by QC with deficient welds or that unauthori:ed/ uncontrolled work had been performed on these supports was not indicated on the NCRs. ASME NCR forms do not provide for any evaluaticn or signoff for acticn necessary to prevent recurrence. Ncnconforming conditions noted during the VCD program are a:parently not being properly decueented or identified to effect action to prevent recurrence. 4 1 III-6 ___TE~5DENE~~NT ~
. ja ebe ~ cm .
m - c- - - - :- '~ ~~ i n L _ m. During the review of the 79-14 "as-built" program discussed in Section B.1 above, the NRC CAT inspectors selected eight items frem the walkdcwn survey to detemine if discrepancies on QC , i J{ accepted supports / restraints were being properly dispositioned. At least three items (MS-1-003-003-C725, SI-03g-019-522R and SW-1-025-CO3-403R) shewed apparent nonconforming conditions for which no changes had been specified (on drawings or CMCs) since
- QC acceptance of the support / restraint. In addition, the j
as-built survey team had identified at one point in time 33 QC .. i t accepted supports that had been disassembled or completely '
' removed without authorization. These conditions were not i
documented in any system that would provide long tem corrective action, but were referred to the construction organization via
. memo. It is recognized that the as-built survey team may not be using the latest CMC issued against the supports they,are inspecting, which may make the determination of a nonconfaming condition. difficult. However, it appears that nonconforming
) c:nditions noted during this program are not being properly j identified, documented or evaluated to effect action to prevent recurrence. ' The inspection of Class 5, seismic supports was a part of the TUGC0 QA/QC program as delineated in procedure QI-QP-11.16-1, Rev. 14. " Installation Inspections of NN5 Seismic Category II Supports for Class V Piping". Paragraoh 3.16.3 of this proca- , dure pemits documentation of discrecancies found during inspec-tiens either on Inspection Reports (irs) or Nonconformance Reports as directed by the QA/QC Civil Mechanical Supervisor. The QA/QC Civil Mechanical Sucervisor has issued a memorandum directing QC sucervisors that discrepancies are to be documented en irs only. This precedure and memorandum have thus overricden the ncnc:nforming conditions and corrective action recuirements cf prececure CP-QP-16.0, "Noncenfomances" and the TUGC0 QA' i canual. Althcugn irs "related to base metal defects are input to j the " trend analysis" and corrective action system, other types 4 of unsatisfact:ry irs (location, angularity, memoer si:e, crientation, etc.), which may represent none:nforming conditiens are not. Therefore, this action is another case where noncon-i forming c:nditions are not identified such that root causes and tttiens to prevent recurrence can be determined and appre-priately dispositioned. ' A review of procacures governing safety-related pipe supports / t restraints indicatec that there are procedures covering many ascects of the program (fabricatien, inspection, VCD walkdcwns, pre-hydro walkdcwns, pre-turnover walkdcwns) and that scme are quite c:morenensive and provide detailed information and acces-tance criteria. Mcwever, the procacures related to ins:ection ! of su:: orts are scmewhat c:nfusing and unclear as to the
- specific attributes recuiring inspection. For examcle, the written instructiens/enecklist fer VCD ins;:ections recuire a s
; verification of sucport "cenfiguration". The intent of this item was not clear. The interpretations by QA/QC manacement, QC suterv.isers, and QC inspectcrs offered during discussions with j -
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NRC CAT members varied frem a detailed inspecticn of many attributes to a verification that in fact a snubber is installed ! i when a snubber is indicated as required. Walkdewn procedures
)
j g also do not previde sufficient specific inspection attricutes ' and checklist / markup centrols fo~r identificatien and correction of the large num:er of loose and missing cotter pins and j fasteners. , 1 A review of the documentation packages for the 24 supperts/ , restraints listed previcusly was performed. The packages are -
- difficult to follow due to the large number of changes involved
- with an average of over five CMCs per support and as many as 16 on one support. Previous inspections are not voided.
i It was observed that from a total of 55 inspection reports, covering approximately 410 total attributes, there was only one indica-tion of an unsatisfactory IR and only one NCR was written. For non-ASME supoorts, QC rejects 20 percent of the supports sub-mitted for final inspection in addition to requiring immeciate correction of minor hardware items (loose bolts, etc.). The near perfect rec:rd in the ASME program indicates that prcblems are being turned back to construction for resolution (through imediate correction or issuance of CMCs). This practice when conducted for all types of deficiencies circumvents the Correc-tive Action Program to identify and prevent recurrence of 1 significant deficiencies. ! Review of 14 of these packages indicated the following discreo-ancies that reinforce this concern. Although the Multiple Weld Data Card (MWDC) has a CMC log block, in numerous instances the Tcg indicates CMC revisions and entry dates much later than the QC inspection signoff dates (some entries over one year after i inscection). As tne coversheet Inspection Report dcas not list CMC revisions, it is not possible in most cases to identify which CMC (design document) was used to perform the inspection. i Further, the "QC Checklist for Snubber Installation" does not specify the drawing or CMC revision. In 10 of the 14 packages, CMC revisions were issued after the date that construction
- signed off on the MWDC that the installatten was c0mplete, and
- en or shortly before the date of the OC inspection. Most of these CMC revisiens were not "information cnly" or clarifica-tien, but pertained to important design features such as dicen-siens, material changes, baseplate c
- nfiguratien, etc. In ene '
instance, three CMC revisiens were issued between c:nstructicn c:moletion and QC inspection. In one case, the IR was signed j- - i off indicating inspection ecmpleted the day before the MWDC with
' the detailed checklist items was signed. In one instance, the center-to-center cimension on a snucber was chanced on a CMC revisien to " meet as-built c nditions", but had 6een QC inspec-i tad satisfactorily twice before.
The follcwing statements summarize the assess: rent of pipe support / restraint activities: ,
? /
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= A~ AA-- ~
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- a. Numercus cases of QC accepted installed hardware not s conforming to drawings and CMCs were identified by the NRC CAT inspectors, ANI, and B&R QC during VCD inspections, and by TUSI "as-built" personnel.
! b.
- These conditiens indicate poor inspection work, unclear / '
erroneous drafting, and/or unauthorized, uncentrolled alteration f ccmpleted work.
- c. Numerous instances exist where nonconforming conditions -
1 have not been properly identified to provide the input to the QA Corrective Action Program for determining root causes and preventing recurrence.
~
- d. From discussions with site personnel and the obviously
. large number of CMCs, it appears original design drawings were used only as guides to construction, and the actual
; design / analysis was performed after c:nstruction and ' inspection. This may have resulted frem the man required due to relocated piping, interferehces,y changes and the CMC program itself.
4 e. The acceptability of the installed hardware to meet design
; requirements based on a series of partial inspections j (versus a final complete inspecticn after work is completed) is questionable based.on the following points:
I . Numbersof" design" changes (CMCs) Somewhat unspecific inspection procedures Amcunt of cngoing construction activities and the apparent lack of discipline regarding construction personnel ta'mpering with QC accepted hardware. Drafting and design discrepancies ccted in initial drawings, CMCs and VCDs. The number of discrepancies noted on suppcrts previ-cusly accepted by OC. 1 Ins:ection documentation not indicating.the " design" document (drawing and/or CMC) revisien tnat was used fer the inspection. In c:nclusion, although extensive major technical pr:blems were 1 not identified in the pipe sue: ort / restraint hareware pr action is required to addrass the above pr: gram c:ncer,ns. cept Scecifically, attentien must be focussed in the areas of the i ncnc:nformance/ccrrective acticn pregram, c:merehensive final
- s ins
- ections and inspection documentation in creer to provide c:nfidence in the ac:eptability of installed pipe satports/
i .) restraints, f 1 III-9 _ _ _ - _ - _ _ - - . - - - - - - --I______ --- - ^ ' ' ~ ~
e ,
- 3. Mechanical Ecutement
' The follcwino sample of installed and OC accepted mechanica' I(
' equipment was selected and inspectac.for proper location, identification, fcundation/ support configuration and condition, in-place storage conditions and damage.
TBX-GHATGD-01, Wasta Gas Decay Tank TBX-GHATGD-07, Wsste Gas Decay Tank - TBX-GHATGD-10. Wasta Gas Decay Tank .
- TPX-TRAHLC-01, Letdown Chiller Heat Exchanger CP1-00APRM-01, Reactor Makeup Water Pump CP2-CDAPRM-01, Reactor Makeup Water Pump
, CPX-DDAPRM-01, Reactor Makeup Water Pump CPX-CSATBA-01, Boric Acid Tank CPX-CSATBA-02, Boric Acid Tank CPX-BRATRH-01, Boric Acid Tank .
TCX-CSAHLD-01, Letdewn Heat Exchanger TBX-TRAMMH-01, Mcderating Heat Exchanger Acceptance criteria for the field inspections were taken from vender drawings and technical manuals, and site structural / foundation drawings. The Operations Travelers detailing the installation and accep-tance of Reactor Makeup Water Tank-01, Moderating Heat Exchanger-01, Boric Acid Tank-01, and Letdown Heat Exchanger-01 were examined. So problems were identified relative to the loca' tion, identifie cation, in-place storage, or damage to mechanical equipment. - All foundation nuts were installed and appeared tight. However, the makeup of the fcundation bolt / nut assemolies was inconsis-tent, and in seme cases, the confomance with vendor require- I ments was in question. For the tanks and heat exchangers ( inspected, scme bolts had single nuts, seme had double nuts, and \ some had a mixture of single and double configuraticns. Vencer , and site foundation drawings indicated single nuts. The Opera-tiens Travelers and site structural bolting precedures do not require or address double nutting. The Westinghcuse technical manual for the above heat exenangers specifies that the nuts on ; the slotted end of these units be backed off sligntly to allcw
- movement curing thermal expansion. Most of the bolts on the sliding ends of all of the heat exchangers ins;:ected were double nutted and appeared to be drawn dcwn tight. The sliding end of f the Letdcwn Chiller Heat Exchanger appeared to have had greut j
between the sucport bracket and the foundation pad. The Ocera-
; tiens Travelers did not address the technical manual recuire-i ment; they stated only that the units were to be installed in accordance with applicable drawings.
i
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4 4 Heatino Ventilation and Air Conditionino (HVAC)
- i i i HVAC systems on Unit 1 and Common are essentially 100% complete
, j and turned over to TUGCO. Many portions are operating. Unit 2 l .) installations are approximately 80% complete. J 4 - In general HVAC duct and equipment supports are fabricated and 1 installed by the Bahnson Service Co. (BSC) in accordance with I:; typical drawings and procedure DFP-TUSI-003. BSC QC inspects I expansion anchor installation and the fitup and welding of duct ' . supports. After installation. the support as-built configura-tion is sketched by draftsmen. This unsigned, unreviewed sketch is sent offsite to Corporate Consulting and Development Co. (CCL) for seismic analysis. If analysis indicates that modifi-cations are required, the supports are modified. OC inspected
, for new expansion anchors and welds, and the draftsmen prepare a 1 final and formal "as-built" drawing. This drawing is checked, and approved and then reviewed by BSC Site Quality Assurance.
This "as-built" is resubmitted to CCL for final review and 1 - analysis. Because the typical drawings provide ho axial
- bracing, most duct supports are modif<ed. Nowhere in this i process does BSC QC inspect the supports for proper location, 1 procer configuration or member size and length. No QA/QC 1
verification or audit of the drafting department's as-built efforts is performed. ] Eight duct supports and one fan support were inspected in the field for preper location, ccnfiguration and conferrance to drawing, design and procedural requirements. Five of these nine supports did not conform to the configuration and dimensiens ;
! . shewn on the as-built sketches or drawings. Following is a list
- of the supports inspected and the discrepancies noted
i Sucocrt Discrepancy
- *A-C3-854-IN-4X None
, i A-C3-854-2N-1AX None :
l A-C3-854-2N-C5 3 dimens. (discre;ancies of .
, 3t". 2 3/8", di" frem ! design) i i
j A-C5-854-4-2N-C12 None l A-SGI-852-1J-1C-01 1 dimen. (6i" variance) SG1-852-1J-2B- 1 member s'i:e smaller than 4 1 shewn (3x3x3/8 vs 4x4xi) l1 fi
- 1 % c
- su:por:s with " final" as-built drawings have the "A" prefix, the
, remaining three had enly the field sketen used for initial saismic analysis
!. at the time of this inspection. III-11 I, .
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.m Suocort Discrecancy CB-807-2N-A ,
1dimen.(1") CB-807-2N-B None SKRFC-791402(FanSupport) 2 dimens. (2 3/8", 2 3/8") and Hilti location spacing (2 missing, 2 in error) l Ducting is inspected for proper installation during the system turnover walkdown. No checklists are used and acceptance i documentation for as many as 38 segments were observed on one j . general Inspection Report. BSC personnel stated that deficien-i cies noted during the walkdown were noted on a punchlist, corrected and reinspected. However, these punchiists are not a controlled er a retained document, and QC reinspection and closecut are not addressed by site procedures. BSC personnel c:uld not provide an example of a completed / closed out punch-list. Turnover package 3601, in the final stages of completion, was
, e::amined in the BSC office. This package contained 35 Inspection' Reports, accepting 495 duct segments, which were all signed by one QC inspector on one day. The inspecticn activities to verify proper makeup of 495 joints and aporoximately 200 support locations would take several weeks and recuire controls over the process to assure that all recuired inspections are performed. BSC procecures do not provice instructions to QC personnel on hcw to docur.ent/ control the in-process walkdown activities and BSC personnel could provide no evidence that the indivicual inspections included in this package were recorded on log books, marked up drawings, or i similar centrol mechanisms.
The following duct segments arid in-line equipment were inspected in the field for conformance to drawing and procedural require-ments: ' CRKE-1, EMD-7 Seg ents 6 through 12 Fan CPX-VAFNID-01 Fan CP1-VAFNID-07
. Fan CP1-VAFNID-10 Cam:er CPX-VADFMV-05 l Isolatien Valve CP2-VAD-PSC-08 Approximately 25 duct segments adjacent to the suppcrts inspec-tec were also examined.
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I s Five of eight joints in the CRKE-1, EMD-7 line had one or more ! loose bolts. Numerous other joints observed during the support inspection also had loose or missing. fasteners and missing 1[ lockwashers (for example: four loose bolts on the joint adja. I cent to support A-SG1-852-1J-1C-01). The flange bolts for containment isolation damper CP2-VADPBC-08 and a similar damper on Unit I did not properly fit the holes and were not fully installed. On damper CPX-VADPHV-05, the gasket on one side was partially missing and the other side had no gasket at all, bolts were loose and lockwashers were missing. The bolting require-ment of BSC procedure DEP-TUSI-008 that requires additional corner bolting on duct accessories was not. met on the damper on the discharge side of Fan CPI-VAFNID-07.
, The BSC program to inspect and document the installation of l
HILTI concrete expansion anchors, however, appears to have been thorcugh and effective. . In summary, the number and variety of discrepancies noted by the NRC CAT inspectors between installed hardware conditions hnd drawing / procedure requirements indicates that the QC inspection requirements and controls have not been sufficiently detailed in procedures, nor has the OC inscector performance in the field been adequate to assure that HVAC systems are installed as required. There was an apparent failure of the BSC Corporate, Brown and Root and TUGC0 QA organiza-tiens to identify and correct the observed program deficiencies during their aucit/ surveillance activities. 9 O l
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a .s n IV. WELDING, NONDESTRUCTIVE EXAMINATION A. Objective Determine by direct observation and independent evaluation of work performance, work in progress, and completed work, whether field welding activities associated with piping, hangers / supports, steel structures, and heating, ventilation and air conditiening (HVAC) systems, are controlled and performed in accordance with NRC require-ments, SAR connitments, and applicable codes and specifications. In addition, determine by direct observation and review of records that welders and nondestructive examination (NDE) personnel are adequately trained and qualified in accordance with established performance standards and applicable code requirements. B. Discussion
- 1. Pice Succorts/ Hangers Twenty-seven pipe supports were selected for inspection of welding. All of the hanger welds had been previously cuality control (CC) inspected and accepted by Brown & Root (B&R). A listing of the hangers follows:
F1pe Unit ASME Tyce Si:e. in. No. System
- Class Hanger No.
Box 1.5 1 SI 2 51-1-53-23B-006-2 Strut 6.0 1 CVC 2** CS-1-357-001-522R Sox 12.0 2 SI 2 SI-2-031-425-Y32R Strut 8.0 2 CS 2 CS-2-063-413-542R Strut 3.0 2 RC 2 RC-2-121-401-552R Anchor 8.0 1 SI 2 SI-1-037-005-532A Strut 16.0 1 CS 2 CT-1-002-008-532R Strut 12.0 1 CC 2 CC-1-116-006-F32R Eox 8.0 1 CVC 1 CS-1-063-0CS-522R Spring 12.0 1 SI 2 S!-1-031-046-Y325 Strut 12.0 1 RH 2 RH-1-004-C07-532R Strut 12.0 1 51 2 SI-1-031-024-Y32R Strut 8.0 1 CVC 2 CS-1-063-037-A42R Box 3.0 1 CC 3 CC-1 136-706-E63R Strut 2.0 2 CC 2 CC-2-AS-023-002-3 Strut 3.0 2 RH 2 CS-2-012-403-C42R Strut 12.0 1 CC 3*** CC-1-116-037-F43A Snubber 18.0 1 FW 2 FW-1-017 702-CS2K Snubber 3.0 1 CV 2 CS-1-001-016-Ca2X Snubter 6.0 . SI 1 SI-1-092-005-C41K Spring 12.0 1 RH 1 RH-1-001-CC1-C415 IV-1 __ . . . . _ . . ,_ , _ _, .,- .-7.._.. _._.,_.m___. .- - . .
..,.. x : m e - ~ w.a.; : L - - .w ..
e e l i i Pipe Unit A5ME p Type Size.*in. No. System
- Class Hanger No. i Spring 4.0 1 RC 1 RC-1-075-026-C61R Spring 4.0 1 CV 2 CS-1-055-010-542S Strut 18.0 1 FW 1 FW-1-017-001-562K Strut 2.0 1 RC 1 RC-1-015-708-C41R Strut 12.0 1 RH 2 RH-1-003-002-542R Box 1.0 1 CVC 2 CS-1-58-059-003-2 l '5I= safety injection; CVG = channcal and volume control; CS = containment spray; RC = reactor coolant; RHR = residual heat removal; FW = feedwater j ** Undersize Weld
] ***0verlap, Improper Contour l l .
- The majority of hangers inspected utilized fillet welds for
! joining hanger components and details. , Two of 27 hangers exhibited unacceptable welds. Manger CS ; 357-001-522R exhibited one undersize fillet weld. The weld was l 1 1/16-in. to 1/8-in, under the specified recuirement. Hanger CC-1-116-037-F43A exhibited overlap and improper weld contour.
, Thirteen of 27 hangers had been inspected to vendor certified drawings (VCD).
[ The welds, for the most part, exhibited good workmanship. Some j of the hangers inspected were painted and NRC CAT inspection of these hangers was mainly for weld size.
- 2. Safety Related succorts/Hancers for Electrical Conduit 4 anc Instrumentation ,
1
- a. Electrical Conduit succorts/Hancers These conduit supports / hangers are fabricated on-site both ,
in the shop and in the field. The following cenduit supports / hangers were being fabric.sted in the en-site shop. 4 The NRC CAT inspection was performsd on the subject hangers ' i before the hangers were painted. i
)
4
- C03G09160-1 C12G06431-26 C04G21038-1 4
C03G09160-2 C12G10452-3 C12G21174-2 C03G09160-3 C12G10652-4 . C23 HIC 674-6 C12021194-4 C12G10455-23 i j .e s e i i
- IV-2 s
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N All welds on the above supports / hangers were visually i inspected by the NRC CAT inspectors for acceptance to QI-QP-11.10-4 which invoke AWS 01.1, " Structural Welding Code." The NRC CAT intpectors examined the on-site shop '
} facilities, and'reviewad fabrication procedures, inspection ,
records, and in-process activities relating to material
- identification, marking, cutting, cleaning..and welding. :
The NRC CAT inspectors observed the arc-stud welding l process being requalified. Requalification was performed for 1/4-in. , 3/8-in. , and 1/2-in. studs. Two studs for
- each of the indicated sizes were welded for requalifi-cation. Welding was performed in accordance with AWS D1.1.
- The welded studs passed the bend test in accordance with AWS DI.1, and therefore the welding process was judged i acceptable.
The NRC CAT inspectors examined field' installed and OC accepted supports / hangers. The inspected hangers were constructed for the most part of 6-in. x 6-in. square tubing. The supports / hangers were relatively complex as < evidenced by the numerous secondary supports attached to the primary structure. The subject supports / hangers : inspected (listed below) were partially fabricated in on-site shops and completed during field installation: r C03G18046-7 C22K06857-1 C12K15116-1 C03GISO46-8 C22K06902-1 CC2030179-1 C03G18046-9 C12012705-6 CO2030179-2 C03G18046-10 C12012705-7 SH-IN-CHM-!b C12K06108-2 C12Q12705-11 SH-IN-chm-Sc C13G13999-2 C12015077-7 SH-IN-CHM-Se C03G18046-11 C11Q04797 1 SH-!N-CHM-Sf SH-IN-CHM-5g The identified hanger / support welds that were inspected (both shop fabricated and field installed) were visually acceptable. Review of the shop activities revealed that the work was being conducted with preper centrols and the quality of the workmanship appeared censistent with good ' industry practice,
- b. Instrueentatien Hancers/Suecorts The majority of instrumentatien and centrol (!&C) non-ASME (safety-related) hangers are fabricated in she;s en-site.
E&R fielo construction installs them by bolting or welding the hanger assembly to building structures. Both field and shcp inspections were being performed by the licensee. , l IV-3 1 I m._..._ ._ .
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w o s The NRC CAT inspectors observed shop fabricaticn of six hangers at various stages of manufacturing. In-process
'tI activities reviewed were material traceability and identi-fication marking, application, cutting and cleaning of materials, welding, filler material control, and hanger identification markings.
Review of documentation for the shop fabricated hangers included review of material records, engineering drawings for configuration, inspection records for welding, material
- verification, visual inspection of welds, inspection report number, and verification of surface preparation for painting. Documentation indicated inspections were performed according to QC document QI-QP-11.8-2.
Ten field installed and QC accepted hangers were also reviewed by the NRC CAT inspectors. The inspected hangers are identified by the following numbers: 5-1467 S-2729 S-1806 5-2723 5-2244 S-2724 S-2250 S-2726 5-2292 S-2762
~
The identified field installed hangers were inspected for visual weld acceptance in accordance with AWS 01.1. ano no
- deficiencies were identified.
- 3. Heatine Ventilation, and Air Conditionine (HVACI The NRC CAT inspectors perforned field inspection of HVAC welds on hangers, ducting accessories such as flow control devices, air dam;ers, and containment isolstien valves. All of the items inspected by the NRC CAT inspectors had been previously accepted by Bahnsen QA/0C.
- a. HVAC Sur:crts/Har;ers Structural steel hangers succorting ducting runs were
> visually inspected to determine if welding met the retuire-ments of AWS 01.1. Typically hangers are field fabricated frem 4-in. x 4-in. x 1/2-in. structural steel argle tren. Hangers inspected and results are as follcws: I l l l l l I IV-4
- -~ -. ._.... , . _ _ _ , ._........,_,_..y..,,,_.,, _ , , . . . . _ . _ , . _ , _ , . _ , . , _ , _ _ ,
. - . _ . , _. - - - - , - ~ ^
No. or
;g 3 No of Welds Unacceptable No. Hancer No. Inscected Welds 6 )
1 C3-807-2N-A 21 11 i 2 C3-807-2N-B 21 . 10 i 3 SGI-852-1J-15 12 11 4 SGI-852-1J-1C-01 12
' 3 .-
5 SGI-852-1J-28 12 10 - 6 SGI-852-1J-16A 18 6 7 DG-844-2X-1AR 14 8 8 06-844-2K-1AT 14 5 9 DG-844-2K-1AQ 14 2 10 OG-844-2X-1AR 14 3 11 OG-844-2K-150 6 3 12 OG-844-2X-18C 6 . 3 13 RS-1A-C1 3 2 14 KB-1A-C2 3 1
, TOTA 1. 170 78 Thus, a rejection rate of accroximately 45% was exhibited for welds on structural steel hangers. The majority of those welds that were unacceptable were rejected because of undersi:e welds. The size of weld specified on most of the drawings was 1/2-in. These welds usually measured sporoxi-
. mately 3/8-in. The rest of the welds were unacceptable because of insufficient length, undercut, and improper weld c:nt:ur.
Bahnson QA/QC personnel observed and acknowledged most of the above weld deficiencies. It was reported after the NRC CAT ins:ection that on February 28, 1983 the licensee's audit of the installed HVAC system confirmed the ceficien-cies and a 10 CFR 50.55(e) report was filed by the licensee.
- b. Centtineent Isolatten Dameer The Unit i HVAC c:ntainment isolation cam:er c:nnection flange detailed en Bahnsen sket:n,150-C01, shcus a'48 in,
' cir:ular flange made frem 2-in. X 3-in. X i-in. angle iron. Inspection of this flange in the field revealed that it is * ' actually fabricated frem two pieces of flat stcck joined by fillet welding to form a right angle flange. This is c:ntrary to the sketch. The drawing is also in error in that it fails to specify a fillet weld joining the two pieces of material. Further:cre, the fillet wele ucen ins:::tien was fcund to be unacceptable in a num:er of areas. IV-5
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Secause of Ifmited access to the full circumference of the weld, only a 180-degree segment was inspected. Approxi-i o mately 40t of the 180-degree segment of the weld was J visually acceptable in accordance with AWS 01.1. The rest
,i(
of the weld exhibited areas of undersize welding, linear
} surface indications, are strikes, undercut, overlap, and in general, a poor level of workmanship.
l
- c. *.
HVAC Welder and Procedure Qualifications .
; Bahnson procedure QCI-CPSES-009, specifies that welders shall be qualified to ASME Section IX. Gibbs and Hill ;
' specification 2323-MS-85(Bahnsoncontractrequirements) !
specifies that welding procedures and welders may be ! qualified in accordance with AWS 01.1 or with ASME Section IX. Actual field fabrication is performed to the require- , ments of AWS 01.1, Structural Welding Code " and AWS 019.0, i
" Welding Zine-Coated Steel".
The NRC CAT inspectors reviewed welding procedure ; specifications and welder perfomance qualifications. This review revealed the following discrepancies. Wp! No, process Comments
/ 85C-12.1 GMAW AWS 01.1, 5.5.2.3 specifies that the
, cover gas flow rate be 225% of the rate qualified; however, WP5 85C-12.1 fails to specify the actual rate used during qualification.
AWS 01.1, 5.5.2.3 specifies :10% for , amperage, 7 for voltage, but !$C-12.1 l fails to specify a range; s:ecific l values are given for ames and volts, but no tolerance is permittad by WFS 85C-12.1. ESC-15 GMAW The weld procedure cualification sneat
!!C-14' for BSC-15 specifies unicue values for -
!!C-14.1' amps volts, travel scoed, and gas flew. !
The WP5 85C-15 specifies 30 40 ft2/hr gas flow, 90-170 amps, 12-2! volts, i 5-12 in./ min travel. The ranges are
' outside of the tolerances pemi ted by AWS 01.1.
!!C 13 GMAW WPS BSC-13 scocifies ranges for amperage, voltage and travel. No weld procedure cualificaticn raccrd was availacle for WP5 !!C 13 that states what values were usec curing the cuali-fication test.
IV-6
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j -- -. t ! BSC-20 SMAW 95 amps is indicated on Welding i j Procedure Qualification Record Sheet for this precedure. WPS BSC-20 speci-f ]- fies a range of 70-160 amp. This range
.. exceeds the :25: tolerance permitted by AWS 01.1. (71-119).
- Same coments apply to these procedures as for BSC-15
- Bahnson specification 2323-MS-85 paragraph 2.14b Welding.
* (modified by Design Change Authorization 9898) specifies that all weldin shall be in accordance with AWS D19.0-72.
Paragraph 2.14(g),a of speci'ication 2323-MS-85 scocifies that welding procedures and welders shall be qualified in accordance with AWS 01.1 Section 5 g ASME Section IX. All of Bahnson welding precedures have been qualified in accordance with ASME Section IX. Qualification in accor-dance with ASME Section IX is permitted providing the requirements of Section IX meet or exceed all of the recuirements of AWS D1.1. As noted above, weld procedures 85C-13, 85C-14., BSC-14.1, BSC-15, and BSC-20 fail to meet all the requirements of AWS 01.1, and are not qualified procedures. The balance of Bahnson's weiding procedures were not reviewed by the NRC CAT inspectors and their
' status of qualification, was not determined.
- d. HVAC Weldino Occumentation A review of Bahnson quality control records and precedures reveals a failure to identify what weld procedure was ecoloyed for a scocific hanger weld. The welding material issue slip, used to control the issue of welding reds, has a space to enter the HVAC system identification. Hcwever, as determined by review of welding material issue slips, the seace provided for system identification only incicates the plant elevation, building, and reactor unit num:er.
Also, traceability of the welding material utili:ec anc the welders employed on specific welds cannot be determined. Bahnsen field ins:ection reports, althcugh providing for ac:actance of welcing, fail to identify the welcar, tne I welding precedure, and the welding matari.als used.
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- e. HVAC OC Inseector's Oualification i
l
! j{ ') HVAC QC inspecter qualifications, both past and present, were revie~wed. Training records, experience, and educa-1 tional requirements were compared with the requirements of
?
ANSI 45.2.6 and Regulatory Guide 1.58. On the basis of this review, the supporting documentation appears to meet the minimum requirements of ANSI 45.2.6; however, QC training appears to have been based on review of QC proce- - dures. Little eviderce was available that reflected *
- j. technical training of substance.
The QC' inspectors informed the NRC CAT inspectors that up to 1 year ago SSC inspectors were not using fillet gauges, or other similar tocis for measuring weld sizes. Further-more, during the NRC review some inspectors exhibited limited knowledge of welding inspection. QC inspector qualification records appear to meet the letter of the ANSI requirement but it was apparent that the QC inspectors lacked proficiency in the inspection of weltis. 4 Visual Examination of Pioine Welds Seven piping isometrics were preselected for visual inspection of piping welds. Nine additional piping isometrics were selected at random for visual ins:ection of welds. All of the
-'; piping runs had been inspected and accepted by 8&R QC before NRC CAT inspection. The inspected piping runs and other system pa'rameters are as follows:
Fioinc 5a :ie Pian Pipe Ft. No. Unit Isemetric dia. of ASME of No. Svstem* No. (in.) Pice Class Valves Welds 1 CS CT-1-58-028 2.0 55 2 2 26
- 1 CS CT-1-58-027 2.0 50 2 2 29 1 51 SI-1-58-C04 6.0 85 1&2 2 12
!:' 1 SI SI-1-AB-002 4.0 120 2 2 12 2 SI SI-2-AB-C01 4.0 85 2 0 12 1 AFW AF-1-58-CC6 10.0 62 2 '2 11 j{ 1 AFW AF-1-58-025 4.0 105 3 2 11 . TOTAL WELOS "T!T i l <s . i l IV-8 3.,y.. 3 ppe, - - . - - . . . -- : - 7 7 -- -
m . . _ , _ _ - - _ - -. m.,r - 4 i Aancemlv 5eiec:ec Picino Runs fh Unit No. System' Isemetric No. No. of Welds 1 $I SI-1-RS-037 1 1 $1 S1-1-58-042 1 11 1 SI 5!-1-RB-053 1 i 1 SI SI-1-R8-052
-1 1 .
1 51 SI-1-R8-033 *
!, 1 SI $1 1-R8-043 6
7 1 CS CT-1-R8-017 3
, 1 CS CT-1-R8-019 8 l 1 RHR RH-1-58-003 i J
! TOTAL WELDS i 39
'C5
- containment spray; s1 = safe y injection; AF4 = auxiliary feedwater; RHR = residual heat removal i
i The welds inspected (identified by 16 piping isometrics) are l ASME III Class 1, 2, and 3 welds. The size of the piping ranged
' frem 2.0 to 24.0 in. in diameter; a piping was involved in the sample. pproximately A total of 1521400 ft ofwelds piping were visually inspected in accordance with ASME III-74 for undercut, overlap, lack of fusion, surface porosity, and other
- anomalies related to surface conditions. Both vendor and field
}) fabricated welds were part of the sample.
Three of the 152 welds exhibited undesirable surface conditions: Weld F-118 (reference SI-1-58 004, safety injection system) exhibited below insufficient the adjacent pipe weld in that the face of the weld was surface. This weld was also imoroperly located on the isemetric drawing (150) provided. The ISO for weld F-118 specified that the weld should have been located at a given position frem a wall. Actual field location was en the esposite side of the wall, apprcximately 8-ft frem the 1ccaticn shown on the ISO. A ncnconformance re ort (NCR) was preparec ty
; the licensee for both the surface condition of the weld and for misiccation.
4
+ ! One weld identified en ISO RH-1-58-003 Rev. 9. joins a secticn of 12.0 in, pipe to a section of 3.0-in. pipe. The transitien, reducin 8.0-in.g elbow was vendor fabricated. The weld joining the 1 pipe sections exhibits a taper or slope of apprcximately 4: 1. The slope permitted by ASME !!! is 3:1 maximum. ; This condition was discussed witn SSR QC persennel, and at tne end of
{ the NRC CAT inspectien, the matter was still uncer review, t I i i IV-9
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i Aweld-o-let(venderinstalled)identifiedenISOCT-1-RB-019, Rev.1 (adjacent to field weld FW-4) has insufficient weld l l p>
, w reinforcement on the weld joining the weld-o-let to the pipe.
The subject weld exhibits less than full weld reinforcement.
- This conditien is readily apparent by nocing that portions of the weld preparation en the weld-o-let side are observable.*
A review of quality control procedures 'and engineering and con- ,.
. struction specificaticns for vendor and field installed weld-o- -
lets or' sock-o-lets reveals a lack of criteria for specifying the required size of weld reinforcement for less than full re-i inforcement welds. Typically, weld-o-lets can be installed on several sizes or diameters of piping and wall thicknesses. On i the basis of the engineering requirements (temperature and pressure) for a given system, the size of the weld reinforcement needs to be specified for those cases where the weld is less than full reinforcement.
- 5. Review of Radiocra:hs '
i Radiographs for a total of 81 B&R welds, 88 ft of Chicago Bridge & Iron (CB&I) centainment liner plate welds, nine Southwest Welding Co. welds and ten ITT Grinnell welds, involv-ing 1254 film were reviewed for ccepliance to applicable s requirements. All weld radiographs had been previously reviewed
.) and accepted by the licensee or his authorized representative.
One hundred twenty-five additional film were also reviewed in the radiographic interpretation reem for the cur;ose of evalua-ting three interpreters' ability to follow S&R procedures and their ability to properly interpret radiographic film. Cenditiens were disclosed by the NRC CAT inspectors in six welds that recuirt attention and correction (See Table IV-1). These ccnditiens were discussed with the licensee representative. These cencitions are summari:ed belew:
- a. Brcwn and Root weld radicgracnic film d24555-CS-1-RE-30 sevealed an indication of insufficient fusien (IF) which
! was rejected on the original film by the E&R interpreter but was not identified en a subsquent recair shet. This deficiency was identified by the NRC CAT inscector. Brcwn j and Root prepared a ncnconformance re;crt (NCR) and the new radiograph that resulted frcm this NCR confirmed the IF.
The new radicgrach also revealed that the angle of the i repair shot had been taken 180* frem the, original shot,
*ancener uncersi:e weld was fcund (not par: cf pice shecle) en a 2-in.
cia.? ster seck-o-let en piping 1ccated in CC puma rocm 01. This sock-o-let
, is welced to a 8-in. line shewn en 150 CC-2-AB-015.
IV-10
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t j thus changing the appearance of the IF on the film and
) reducing the likehood of its being identified.
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- b. The NRC CAT inspector revtew of B&R radiographic film
!4152-MS-1-RS-081 revealed an area on the film, that coin-ciced with the pipe weld gone, which was more dense i (thinner material) than that part of the film showing the parent material. - B&R prepared an NCR and later confirmed a thin wall section by takir.g an ultrasenic thickness ' reading. The area was approximately 0.014-in, under -
mini =um wall thickness. This radiograph had been accepted
- by B&R QC. B&R stated that weld repairs to this area would be made.
c. 3&R film #29030-FW-RS-020 revealed an area of IF and I aligned enlongated porosity in excess of 1-in. that had been accepted by S&R. An NCR was prepared and new radiographs were taken. The new radiographs revealed the I same c ndition and the weld was rejected. The licensee representative stated this weld will be repaired. l d.
! B&R film #28669-CC-AB-018 revealed an indicatien of IF that l' was not marked by the interpreter (the same interpreter involved in film 29030). 'this indication was hewever, identified by another B&R interpreter when a subsequent
'i repair shot was evaluated. The NRC CAT inspector's review of the original film for the subject weld revealec incica-
) -
tiens of ine:=plete fusion similiar to the repair weld radiogra:h. period of time. Both film evaulations were made within a shcr This deficiency in film interpretation was referred to the licensee representative for folicwup and c:rrective action. e. Curing the NRC CAT inspectors review of radicgraphy film (20519-CS-1RS-028, 29012-CS-2-AS-091) two welcs were cbserved to have densities that are belcw minimum in the area of interest or are outside the +300 - 15% for penetra-meter requirements in the A5ME Code and B&R precedure. As a follewup to the above, it was learned that B&R had changed the three-view RT technicue to a fcur-view teen-nicue approximatel density problems. y two years ago to correct icw-film
, S&R is new in the process of reviewing f radicgrapns of welds shot before that time with three-view tecnnicue. The NRC CAT inscector was informec by the licenseee that any radicgrapns fcund that do not meet ceda recuirements will be re-radiograpned.
f. Initial review of accroximately 10-ft of radiogra: hic film taken of c:ntainment linear weld seams revealec linear incications. Subsecuent visual examinaticn of the liner plate, in the area of interest, revealed that the liner plate c:ntained grincing marks adjacent to the weld. Dr. the basis of a correlation of the grincing marks en tne IV-11 l w-
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I i a j liner with marks on the radicgraphic film, the NRC CAT inspector agrees that the welds are acceptable. l( iI . No deficiencies Welding were identified and ITT Grinnell in the review of Southwest sample of radiographs. I 3 6. ( Review of NDE Precedures, Practices, and Personnel Oualificatiens
- a. '
. Review of Brown and Rcet NDE Precedures -
i A total of 19 precedures were reviewed by the NRC CAT I inspector.. It was observed that most.of the procedures had been revised within the preceeding five months. With the
; exceptien of QI-QAP-2.1-1 and QI-QAP-10.2-3, the procedures appear procedures to befollew:
adequate and in good order. Cements on these (1' ) OI-0Ap-2.1-1. Nondestructive Examination Persennel Ce rti fication
, This procedure does not detail specific requirements 1 for work experience and hcw the NDE Level III makes
{ his determination for qualificatien before i certificaticn as required by SNT-TC-1A, 1975 edition. (2) OI-0Ap-10.2-3, Radicerachic Examination
- This paragraph allows the use of Ir 192 on steel as thin as 0.125 withcut explanation.
Review of records
- disclosed that this procedure requirement was based en a qualification film using two flat pieces of material in the center of the film. This set of conditiens is not representative of the gecmetric conditions that would be encountered en an actual radiograph of piping welds. !
The qualification film ravtaled a marginal ai sensitivity. i
- b. Ce r.ificatien Records
, Records of 63 separate certifications involving 22 ;ersons were reviewed.
1 fer a Level II that cenThere was one certified ultrasonic reco angle beam, snear, wave:afnec no evicence of experience in examination. A subsecuent inter-1 view with this persen and a signed document confirm that he
?
had no experience with shear wave techniques. The persen 4 stated III before thathe this wasinformation certified. was made kncwn to the Level The recuirements of ANST-TC-1A were not met in the case of this individual. TheliRC CAT ins;ector was infomed by the licensee that this ;ersen hac net performed any ultrasonic werk for B&R. IV-12
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. c. Interviews
' g ,y Twenty persons were interviewed for determining their ji understanding of procedures, and their ability to perform
; the operatiens for which they were certified. Each persen
! interviewed ment appeared to have a good attitude toward manage-and precedures.
They all had a current ccpy of procedures assignments. and were very open and willing to discuss their ( j , d. Work in Prcoress (Method Demenstration) 4 Observations of 21 separate nendestructive examination's were performed. Of the 21, nine were radiographic, one i ultrasonic, and eleven liquid penetrant. Of the nine -i demonstrations in radiography, two were field setups, three were for welders' qualification, one for darkreem prece-
, dures, and three for in-process film viewing.
I (1) Radiocrachy
} .
In all cases, the personnel demonstrated a seed understanding of how to use the equipment, and how to perform the nondestructive examinations. j (2) Ultrasonic
] One person certified at Level II was asked to cenduct a calibration procedure for 3/4-in, plate. The calibration was performed satisfactorily.
(3) Licuid Penetrant i i All personnel perfer=ed in a satisfactory manner except in their understanding for centaminatien of the penetrant application by brush. This is not censidered a major prcblem, e. NDE Eouiement Calibratien and Material Verifica:icn i Over 47 items of ecuipment anc materials were checked fer calibratien, requirements.certificatien and ccmoliance with estaclisnec
. They incluced:
8 ultrasonic instruments
. 4 densitereters 15 cassetts 3 survey instruments 4 density strips 3 Ir192 decay charts
; The items reviewed satisfied the specification anc precedural requirecents.
IV-13
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- 7. Review of Welder Qualificatien 1>
1(i
*I Frem the sample piping runs inspected, welder identification numcers noted en piping welds were selected and the welder performance qualifications records reviewed for ccepliance to l
WES-031, " Specification for the Qualification of Welders and Operators". l The welders whose qualifications were reviewed are identified -
.. belew by their assigned symbols:
i . I j h AW AIM i - AWD AUA BIG AHX APL AHK AHF AFO ARP AGM ' SCO BGU- . ABR A review of WES-016, " Schedule of Standard Test Welder t Qualification Matrix and Welder Perfor=ance Qualification Log" was contacted. WES-016 specifies the various weld tests for { 1 qualification and requalification of welders. A review of the i welder qualificatien matrix, listing the cross-matrix of the
~ welding procedures applicable to each welder, was also ccnducted i -s to ensure that the essential variables for welder qualification
> in accordance with ASME Section IX, were not violated.
No deficiencies were cbserved in the welder qualifications reviewed.
- 8. Review of B&R Welder Oualification Precram B&R has instituted a prcgram whereby the weld engineering unit utilizes welding technicians in the field to oversee and assist welders in the ccnduct of their work. Addi:fonally, tests for qualification, (both the types of tests administered to newly
- hired welders and to welders being upgraded) exceed the require-ments of ASME Secticn IX. Furthermore, S&R has implemented a pregram to qualify welders by radiographic testing rather than meenanical testing per ASME Section IX. Secticn IX of the
~ ASME Code permits either radiographic or meenanical testing. .
Radiograchic testing nor . ally is more cifficult to pass, thus requiring a higner skill level. No discrepancies were cbserved during the review of this program.
- 9. Su=marv - Weldine and NDE Activities Overall, the B&R prcgram for welc'ing, welders cualifica:icn, NCE and general training activities appears to be effective and well
' administered. This cbservation is sucperted by visual examinations, observed NDE results anc practices, wi:nessing field weics in peccess and the generai level of werkmansnip , demonstrated.
IV-14 4.. ~ **vwy9're,- '"P93 ON I
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.; Findings in the HVAC drea with respect to undersi:e welds, weld i inspection practices and lack of adequate documentation indicate
- g 'l~
sericus QA/QC deficiencies for that particu.lar work.
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.g q UROWN & R001 film RtVILW h pTABLE IV - 1 o zu Ewg p' > r' > r b a us a di bh * " as 3s es as = o. c o -a s n e oz u .c az =o Ma o N smec IIibl a.b za ae so b'!i . 24555 CS-1-HB-30 2 18-1 ok T 'Insuf fElent fusion reJRtcil on ori inal TIlm, leut 128"iSR CS-1-RD-30 2 18-1 0 ok --- --- 0 was missed on repair sliot. f2k ,sR CS-1-RB-30 2 18-1 --- ok flCR written, sulesevinent U' 2 Rf confirmed finding.
]4162 MS-1-RB-018 2 4R2 ---
ok --- --- Low density noted. IICH prepareil ley il<. Uf , j verified area to lie 0.014 in, under minimum wall. "
-j condition had licen accepted lay licensee. [
429030 IW-2-RU-020 V 1 1A --- ok --- --- 10 inification of incomplete fusion and aligneil linear IJ il porosity not marked. 4 Verified lay RI. NCR written liy UAR. .; j28699 CC-2-AB-018 2 4R1 --- ok 3 6 Indication of incomplete fusion not marked on 20069. Next repair shot of weld showed same in- ' 4 - complete fusion and was caught by different inter- p preter. This film (28669) and 29030 was misread d by same interpreter. [;
- 2( ) CS-1RB-028 2 5-1 2.72 ---
3.34 6 film density below minimine in area of interest:
'29018 CS-2-AB-091 2 1R 1.87 --- --- ---
2' Low density. .. f! { j; l ;- 3
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3 V. CIVIL AND STRUCTURAL CONSTRUCTION
! .-) A. OBJECTIVE Determine by review of documentation and by independent evaluation of c:mpleted work, whether work, inspection, and test activities relative to the civil engineering area were acccmplished in accordance with project specifications and procedures. .. ', The specific areas evaluated included concrete placement, c:ncrete 1
i
- testing, soil.. inspection, protective coating, containment liner, and structural steel installation activities.
B. DISCUSSION
- 1. Concrete Placement i .
l This area o' f inspection was initiated by a review of the procedures " li delineated in the project concrete specification and the " Civil Inspection Manual." As there was little or no work being performed in this area, the evaluation of the concrete placement program was i limited to a document review of completed work activities. Five c:ncrete placement record packages were reviewed. The place-ments reviewed were as follows: PLACEMENT DATE
- 201-8805-01 9/18/79 201 '885-018 7/18/80 002-EI78-052 5/06/80 :
201 4823-008 9/21/79 105-9555-002 9/15/80 The NRC CAT inscect:r attemeted to correlate all related cccurentatien reviewed to tne above concrete placement rec:rcs. i This rela:ed dccumentation includec tne following inspec-icn anc ! test rec:rds: Cadweld Inspecticn Reccrds Cacweld Sleeve Inspection Records Cacweld Splicer Qualifications 4 Cadweld Splice Testing Reports V-1
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.. e Reinforcing Steel Inspection Reports * ' ]; _
Miscellaneous Steel /E= bed ent In:pection Reports ' I( Concrete Inspection Records Curing Inspection Reports In-Process Test Records
- Additionally, records involving associated grout and pressure greut
; placement, were. reviewed. Five "Cempressive Strength of Ceres" and five " Defective Concrete Placement" records were reviewed and ccm-pared to the applicable Ncnconformance Report (NCR).
In general, the records reviewed reflected that cencrete placement activities,were performed in accordance with the site precedural
; requirements ard the licensee's FSAR commitments.
i i
- 2. Cencrete Testinc '
A review of the precedures included in the " Civil Testing Laboratory Manual" was performed. The evaluation of the concrete testing pregram ments. was limited to a review of completed testing activity decu-Samoles of various civil testing laboratory inspection records were selected. These samples included:
\
Mix Design Data (Two Mixes) Cc=cressive Strength Tests Selected Aggregate Tests Selected '*ater Tests Related Noncenfor=ance Reports Acditienally, certificatiens for cement, air entrain =ent, aggregate, anc eccxy greut were reviewed. Reinforcing steel anc miscellanecus steel certificaticns were similiarly reviewed. During the review of these various test reports, it was disecverec tnat ne mix unifomity tests had been per#ormed to the cc=mitments centained in Section 3.8.1.6 of the FSAR. Paragrapn 5 of this section, "Censtructicn of Concrete" requires that cencrete ccnstructicn, including mixing, be in accordance with CC 2200 of ASME-ACI-359. Section CC-4223.2 of this document, " Operation of Mixers" states, "The range of mixing capacities and correspending mixing times for all mixers shall be determined by the perfemance of mixer uniformity tests as specifiec in ASTM C94, " Specification of Ready-Mixed Cencrete". Table CC-5200-1 defines the testing y-2
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l! t frequency for these required tests. The licenses could provide no ) evidence that these tests had been performed. Thus, tests to verify ! proper cperaticn of the concrete mixers were not performed during
- ,T concrete construction.
~
. Soil Inscacticn
[' Ten soil inspection test records were reviewed and found to have
, been performed in accordance with site procedural requirements. It i was noted that a number of these tests required several ratests, but j
- acceptance criteria and test performance were noted to be in accer- '
; dance with program requirements. -
- 4. Protective Coatino I
Three protective coating application inspection records and the associated. adhesion tests were reviewed. One in-process protective coating application was observed. During this portion of the review, NCR C-650 was reviewed relevant to prctective coating applications. This NCR documented deficiencies relevant to a safety-related concrete placement. The latest revision of the NC:1 required the application of protective
. coatings over the concreta repairs, but deleted the requirements for the applicable adhesion test. Licensee representatives indicated this area would be reviewed under an inspection "back-fit" program for protective coating application. Mcwever, since this program had not been initiated at the time of this inspection, licensee representatives assured the NRC CAT inspector that this matter would receive appropriate review.
- 5. Cent'ainment Liner Installation Procedures for the installation of the centainment liner are defined by tne " Chicago Bridge and Ircn (C3&I) Handbook"; specifically, Scok 2, Secticn IIIa and Section IIIb (Centract 74-2427/25U). Three separate traveler packages were reviewed to these procedures.
Samples were also selected frem the following files: Vender Material Certifications Visual Inspection Reports LPT Examinaticn Reports l Mpi Examination Reports ; UT Examination Reports
' Radiographic Inspecticn Reports '
" Actual ractographs were reviewed and are dccumented in the Welding /MDE section, Section IV of this report.
V-3
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xx - :---------:----:---- The "CSI Nonconformance Control List", and the reference to the applicable repair checklists were ecmpared. "CBI Request for Acceptance of Nonconformity as a Deviation" was also reviewed. i The records reviewed reflected that the containment liner installa-1( ' tien activities were perfomed in accordance with the si*a procedural requirements. [ 6. Structural Steel Insta11atien , l - Procedures delineated in the "Non-ASME Mechanical Inspection Manual" - ! i related to structural steel installation activities were reviewed. - l 1 Four structural and miscellaneous steel installation inspection - records were reviewed. -
, One portion of an installation was observed in the field. Applica-
- tion of traceability, where applicable, was noted. Documentation
; reviewed included a selected sample of:
} Receiving Inspecticn Reports Material Requisition Requests Applicable Certified Mill Test Reports Applicable Certificates of Compliance Fabrication Traveler Sumaries Applicable Design Changes and Nonconfomances Documentatien reviewed and the activity observed reflected that structural related activities were performed to the site precedural requirements and the licensee's cccmitments.
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VI. PROCUREMENT, STORAGE AND MATERIAL TRACEABILITY A. Cbfective The cbjective of this portion of the inspecticn was to examine on-site 3( procurement, receipt, stcrage, maintenance anc traceability of safety-related equipment and material to determins the adequacy of the lican-see's program relative to these activities. , 4 f B. Discussien The approach used to perfonn this part of the inspection was to tour .~ i
!* the site and observe construction activities in progress. Various. site persennel were interviewed and samples from different disciplines at various stages of work were selected. Delivered equipment and material at locations in storage or installed in the plant were also inspected.
Applicable documentation relative to these activities was also
! reviewed. - .
0.w.'f:ational charts and procedures were reviewed and discussed with site personnel. Offices and other site facilities were toured and , examined, including temporary offices, warehouses, outside lay-dcwn - areas, and the plant areas of Units 1 and 2. A selection of 71 samples was made for procurement and storage consi-deration from mechanical; electrical; civil / structural; instrumentation and control; heating, ventilation and air conditioning (HVAC); welding and miscellanecus categories. In addition, 73 samples were selected specifically for material traceability, including 58 weld joints, each involving two materials to be welded with one or more sold filler materials. The fcilewing describe the results of inspection in the areas listed. i
- 1. Precurement and Receivina 1 A-total of 71 purchase order files for safety-related equipment and material were examined. A detailed inspection was =ade of 35 samoles. Referenced engineering specifications, quality requirements, submittals, approved-vender status, revisions, and other aspects were reviewed.
l ' Quality Control (QC) authori:atiens to ship frcm vendors' plants and on-site QC receiving inspection documentation were examined. The receipt of rsquired material certificaticns was examined. Records reviewed reflect that precurement and receiving activities were performed in accordance with procedural requirements. It was noted that the computeri:ed system implemented at the site provided adecuate centrol of vendor submittals and engineering approval cf test reports and data. VI-1 4 l _ h__
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- 2. Storage and Maintenance l a. Sterage Facilities - General l
Warehouses and lay-dewn areas for Class A, B, C, D and E stcrage I( levels were examined. The Class A storage space requiring temperature and humidity control was fcund to be within control limits. Discussions with warehouse personnel revealed back-up provisions to maintain control in event of a site power outage. i
. Wald red storage areas in Warehouse A and evens in Field Weld Rod -
Room #2 were examined and found to be maintained within required temperature limits. Storage facilities observed and records reviewed reflected that the identified storage facilities comply with site procedural i requirements. . However, a lack of control over two unmarked areas apparently used as scrap yards was discovered. These areas 'and centants therein were as follows-(1) Numerous piping, valves and other items were identified on the ground in a fenced area with the gate removed on the East I side of the Pipe Shop. No signs identifying this area were observed. (2) .umerous cables, motors and other items were found on the grcund in an area with no enclosure on the North side of the Electrical Lay-dcwn Area. No signs identifying this area
. were observed.
The observed lack of control of these two areas d:es not meet NRC or site procedural requirements for the c:ntrol of equipmen and material.
- b. St: race in Warehouse Buildings The st: rage of equipment and material in storage bins and
, lay-dewn areas within warehcuse buildings was examined.
Activities observed and records reviewed reflected that storage I activities in warehous~e buildings were performed in ac::rdance i with site procedural requirements. ,
- c. Storage in Outside Lav-Ocwn Areas -
The storage of equipment and material in outside lay-dewn artas was examined. C rreston, dust and dirt were noted on a number of safety-related items due to the lack of c: vers and/or protective coatings. For
', example,128 ITT-Grinnel hanger struts and approximately 400 s
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j i.. * . . NPSI hanger struts, with associated bolts and nuts, Nuts,were bolts noted and in outside lay-down areas north of Warehouse A. 3 - bearing pins were noted to be very rusty. Bearings were noted to be corroded and dirty. Specific samples inspected were: g [ (1) The nut and threaded portion of the strut was corroded i relative to ITT-Grinnel Hanger Strut, Serial No. E3473, ID No. E-TI-040, Class 2. Bearing pins and retainer rings were corroded. Bearings were dry and corroded. 1 (2) The bolts, the nuiis and the bearing pin for NPSI-Hanger 2045418542R,, Class 2 were Stnat, CF.- 0046A, ID No. SI corroded. The bearing was dry, corroded, and covered with i dust. (3) Corrosion was noted on outside of the Joseph Oat Corp. Automatic Nuclear Strainer, CP-0029A, Serial No. 23080, 1977, Zurn Tag No. CF2-SWSRAU-02, Zurn Serial No. 6250. Corrosion was also noted on similar equipment stored in .a nearby location. These examples indicate a failure of the licensee to satisfy a the FSAR comitments and to properly follow site procedural requirements for protection of material and equipment in storage. 1 d. In-Place Storace of Ecaiement 1 The storage of equipment in place in the CPSES plant was inspec-ted. Corrosion was noted, and some wood, metal and paper trash were noted adjacent to safety-related equipment. Specific examples noted were: (1) The Motor Operated Valve. Serial No. 43554. Tag No. GGC302SGMO, Safeguards Bldg.-2, Elevatien 790 ft. was
- observed to be without a protective cover. The drive mechanism was noted to 'be dry.
(2) The Auxiliary Feedwater Pump and Motor, Pume CF2-AFAPMD-02, and Motor CF2-AFAPMD-02, were not covered. Corresion was , noted on the base and wood, metal and paper trash were noted I on and arcund the base. (3) The intake filter of the Cemconent Cooling Water Pump Motors CPA-CCAPCC-01M, and CPI-CCAPCC-02M were clogged with foreign l materials and debris, thus restricting the air flow to the motor.
~
(4)ConstructionmaterialswerepresentontheResidualHeat Removal (RHR) Pump Motors, T5X-RHAPRH-01M and T3X-RHAPRH-02M. Oil was observed to be dripping frem the inside of one RHR motor casing. J The examples of improper storage of installed ecuipment centioned , above represent the licensee's failure to satisfy the site storage requirements.
- VI-3 ,
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- The activities to control and perform maintenance by the mill- F I
J( wrights for mechanical equipment, and by the electricians fora centr k i electrical equipment were reviewed. Generic maintenance schedules are system is used by each group. applied where applicable, and additional instructions ar[ For each piece of equipment requiring maintenance, a card listing .. B the maintenance work and schedule is used. A QC representative - verifies the work and signs after each maintenance activity has ,
- been completed on the equipment. A number of maintenance record 4
cards were reviewed, and no deviations were noted. The infomal manner (often by telephone) of identifying equipment requiring maintenance, particularly special maintenance to comply with vendors' instructions, was questioned by the NRC CAT inspector. The actual maintenance work and schedule are specified by discipline engineers for use by the craft items in storage at the plant without a more femal system of c:ntrol. Similar concerns identified by the licensee relative to maintenance requirements and scheduling of maintenance are discussed in the Quality Assurance section (Section VIII) of this report. All maintenance records reviewed indicated maintenance was perfor=ed to the requirements in accordance with the specified schedule. In additien, a lack of adequate maintenance procedures to protect safety-related equipme'nt from corrosion and/or other damage after installation and before turnover to TUGC0 for cperation was identified. During a tour of the plant, extensive corrosion was noted en_the tuce support / spacer plates of a Unit-1 Containment Spray Heat Exhanger that had the outer shell removed for an internal mocification. DiscussionsThere revealed had been thata the time licensee was aware of the corrosion condition. - delay between the installation of the heat exchanger and tne i i turncver to TUGCO. ciping installation hookup had been deleted at the time of piping hookup, and.no protection against internal corrosien had beej acalied after piping hockup. l of the two heat exchangers for Unit 2 by the NRC CAT inspector.
- The Unit 2 Containment Spray Heat Exchangers Purchase Order (P.O.) CP-0050, Joseph Oat & Sons, Inc.Itvender was noted storage thatand a
installatien instructions were reviewed. Nitregen blanket on the shell side (safety-related Class 3) was specified prevention. at 10 psig, to be checked monthly, for moistureN installatten hcokup to piping. Site maintenance car:s maintained by tne millwrights called for checking the Nitrogen blanket weekly, but no instructions were provided for protection after installation hookuo. Maintenance carcs for the two Unit 2 heat exchangers revealed the following: VI 4
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- (1) For heat exchanger CP2-CTAHCS-02, site maintenance of Nitrogen blanket was deleted 4/6/80 at installation when opened for piping installat. ion hockup. Thus, this heat
,3 -
exchanger has not been under a nitrogen purge or any other
)g '
protection for over 21 years. -
- (2) For heat exchanger CP2-CTAHCS-01, site maintenance of Nitrogen blanket was deleted 11/5/81 when opened for piping installation hcokup. Thus, this heat exchanger has not been ;
^
under Nitrogen blanket or any other protection for over 1
. year. ...
Licensee personnel are aware of this problein and are investi-gating corrective actions to remove any corrosion and prevent
- future' corrosion as the heat exchangers are tested and placed in operation by adding a rust preventive to the liquid involved, and possibly applying a chemical cleaning process. Consultations with chemical engineering personnel of Dow Chemical Company and Westinghouse (the NSSS vendor) are in progress to resolve this problem. The licensee stated that a solutien is inticpated after the forthcoming Hot-Functional Test on Unit I has been completed, and the internal corrosion condition of the Unit i heat exchangers is better defined.
- 3. Traceability Significant effort was devoted to discussions and examinations of sammles and records pertaining to traceability of in-place material i back to engineering drawings and specifications and to procurement a
sources and heat numbers. Generally, it was noted that the licensee
. has placed a high degree of emphasis on traceability. A total of 73 sa= pies were examined for traceability, including:
58 Safety-related piping w'eid joints, each involving two materials and one to three weld filler materials
- 1 Class 1, safety-related structural weld joint A Lots of materials for safety-related hangers 1 Lot of HVAC structural succort material 2 Lots of HVAC duct material ,
3 Multi-lot samples of weld filler material 1 Lot of safety-related fastening devices 3 Lots of miscellanecus snim steck, and hanger strut hardware Specific results of the inspecticn regarding the traceability area are as follows:
- a. Safetv4 elated Picine Weld Joints .
A total of 58 piping weld joints were selected for traceability, i Of these, 42 were selected by observation of ccmoleted work in i the plant, and the balance included welds identified by other CAT i team members in the applicable secticns of this report. i s VI-5 i . 1 m: m-r- ,,
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m c. . _ - - . _ __x - _. . =: - During early examination of 27 sample weld joints in the plant, 4 heat numbers could not be found on the pipe, but records were found to be complete. Further examination of the joints in the 7 plant resulted in locating the 4 heat numbers that were not I g readily located. Discussions with licansee personnel revealed g that QA reviewed spool pieces at the fit-up staca and checked all 1 materials for correctness and traceability to heat numbers prior ' to welding, and again after welding before QC signatures were
; applied to the records. ,
- Also, during the examination of records for sample weld joints.
- record discrepancies were noted for two weld joints. A review of the welds and records involved revealed that design changes had been made, and that, while the actual welds were correct, the
' documentation had not been accurately changed. The two record discrepancies were corrected by a Component Modification Card i
3 (CMC) change Serial No. 87228, initiated 2/1/83, and a Manufacturing -Record Sheet (MRS) change, Serial No. MI-612, dated 2/22/83. - Samole results of traceability examinations of weld joints are as follows: (1) Wald No.: W-21-1 (shop weld - pipe to valve) j Welder: 8YL , System: . Service Water 1 Drawing: SW1A814 Spool 7Q3 3 Class: 3
.' Pipe: Heat No. NS894 4
Valve: Heat No. AJ330 4 Weld Rods: Heat Nos. 746100 and 762550 i i (2) Weld No.: W-8-1 (shop weld - pipe to pipe)
- Welcer: AMA System: -Chemical Volume Control Drawing: CSIA3003, Spool 3Q2 Class: 2 Pipe: Heat No. 713876 4
Pipe: Heat No. 2S970 Weld Rods: Heat Nos. 4232R308L and 463628 (3) Wald No.: FW-1A (field weld - pipe to weld-o-let) Welder: AST System: Containment Spray i Drawin CTIS2023, Spool IQ2 j Class:g: 2
.i pipe: Heat No. 280385 l l Weld-o-let: Heat No. 320J Weld 1 !
Rods: 463638 and 545506 ' I. l b t ) l VI-6 i
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1 (4) Wald No.: W-1 (shop weld - pipe to flange) Walder: AGZ System: Safety Injection g Drawing: SIISBil, Spool IQ2 6 ' Class: 2 Pipe: Heat No. BWL16M Flange: Heat No 54J2L Wald Rod: Heat No. C3220E
, (5)WeldNo.: W4-1A (shop weld - pipe to pipe) -
. Welder: AXP, ATX
- i 4
System: .. Chemical Volume Control . Drawing: CSIAB005, Spool 12Q2 Class: 2 Pipe: Heat No. 51891 Pipe: Heat No. M-2253
. Weld Rods: Heat Nos. 4282R and 463638
! (6) Wald No.: FW-163 (pipe to 45' elbow) '
l Walder: BCJ, ATI System: Safety Injection Drawing: 5I153004, Spool 10Q2 Class: 2 Pipe: Heat No. 28970 45' Elbew: Heat No. U4LLH4 Weld Rods: Heat Nos. 463552, 463638, 546506 (7) Weld No.: FW-12A (pipe to pipe) Walder: AGR
. System: Safety Injection
. Drawing: SI155004, Spool 4Q2 Class: 2 Pipe: Heat No.. M0635 Pipe: Heat No. M0623 .
Wald Rods: Heat Nos. Consumable insert 42S2R30EL and rod 463628 (8) Wald No.: FW-18A (pipe to valve) Welder: BCJ, AGR
. System: Safety Injection Drawing: 5I15E004, Spool 6Q2 Class: 2 Pipe: Heat No. M0623
, Valve: Heat No. (S/N) 85740038 Weld Rods: Heat Nos. Consumable insert E3047T315 and red 746100 i
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! (9) Wald No.: FW-10 (field weld - pipe to 45' elbow)
{ Welder: AGN i System: Containment Spray i ! Drawing: CT155023, Spool 702 i ; Class: 2 Pipe: Heat No. M0624 45' i Elbow: Heat No. U4KCH Weld Red: Heat No. C3220E VI-7 l l w, g. .-,w -e- -r- < m = ++ me-*wprm , o +- w -w - w.p=- ~ + eer,9 y g - yey y -w-r + e- " h ~ ** N-*. *
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Walder: AFN, ABT System: Centainment Spray Drawing: CTISB023, Spool SQ2 l Class: 2 Pipe:. Heat No. M0624
! 45' Elbew: Heat No. U4LLH4 .
Weld Reds: Censumable insert 25257308 and red 463730 i
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NOTE: Certifications verifying heat numbers for these samples .- were in the central files.
- b. Class 1 Structural Wald Joint -
One weld on a large structural support furnished by Westinghouse and fabricated by Teledyne Brown Engineering was examined for traceability, with satisfactory results as folicws: Weld: Mcunting Plate to Shim Plate (no number assigned) Welders: BOA, BKX, CEA, BXU Item: Whip Restraint for Safety Injection System Drawing: EIV-0527-0508-2, Loop-3 Class: ASME III, Class 1 Plate: Heat No. E130514, Mtl. ASTM-A588 Plate (Shim): heat No. IG0200 Mtl. ASTM-SA-36 Weld Rods: Heat Nos. 431L245, 52592, L22580 and 421P5132 Certs: Chemical and physical certifications for plate materials and weld rods were in the records file.
- c. HVAC Structural Support Material One lot of angle iron purchased under Purchase Order No.
TUSI-1148 for Sahnsen Service Ccepany (HVAC centracter) was examined for traceability, with the following satisfact:ry ' results: Item: 140 pieces of galvanized angle iron 4"xx4"xt"x20' Spec.: Mtl. ASTM A-36; Galvanizing ASTM-A-123-78 Heat No.: 425340 Color Code applied by Sahnsen: Red-Orange i Certs: Physical,-chemical and galvanizing certificatiens were in records file. l d. HVAC Duct Material i Two lots of metal sheets purchased under Purchase Order No. I TUSI-0776 for Bahnson Service Company (HVAC centractor) were examined for traceability, with the fellowing satisfactcry results:
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, s (1) Item: 149 pieces of galvanized sheet metal 48"x120"x10 GA Spec: ASTM A-526. G-90 coating Heat No.: 500H3480 Color Code applied by Bahnson: Caution Yellcw
.) Certs: Physical, chemical and ceating certifications were in records file.
(2) Item: 28 pieces of galvani:ed sheet metal 48"x120"x10 GA Spec: ASTM A-526. G-90 coating Heat No.: 516N1509
. . Color Code applied by Bahnson: Flare Red . .
Certs: Physical, chemical and coating certifications were - in records file.
- a. Weld Filler Material Three purchase orders (PCs) for large quantities of weld filler materials were examined for traceability as follows:
(1) PO 20725 to Sandvik Inc. Examination of records showed traceability to specifications, QC Receiving Inspection Reports, and certifications for chemical analysis and physical tests for various lots. (2) P0 CPF-1049-5 to Murex Welding Products. Agent for Airco Welding Products.
~. Examination of record showed traceability to specifications, J QC Receiving Inspection Reports, and material certifications
~
for chemical analysis and physical tests for various lots. (3) P0 14920 to Arcos Corporation.
. Examination of records showed traceability to specifications, l QC Receiving Inspection Reports, and certifications fer i chemical analysis and physical tests. !
- f. Safety-Related Fastening Device (Stud)
A samole from the field was randemly selected. Infor.atien proviced was that the item was a stainless steel stud with notations DF60, 560T and VA.
- . The sa=ple satisfactory inspection results were as follcws:
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! * , ,, s. System: HeatingandVentilatingSystem(VA) Drawing: VA-X-AB-004C, Rev. 6 P. 0.: 30228, Item 20 ' Item: 7/8"x5" Stainless Steel Stud,
/ s Spec.: ASME SA453, Grade 660 -
Vender: Texas Bolt Co. (on appreved vender list) QC Receiving Inspection Report: RIR 13847 . Certifications: Chemical and physical tests in file Heat (Trace) No.: OF60 Code Class: 2
- Material Requisition: MR-154401 * '
Application: To attach flange of piping from Hydrogen Purge
- l l
Exhaust Filter Package to flange of Heating and Ventilating System. NOTE: T" after 660 designates the vender (Texas Bolt Co.)
- g. Miscell'aneous (1) Two purchase orders for safety-related shim stock were examined, with the following satisfactory results:
(a) P.O.: CPF-1648-5, Stainless Steel Shim Stcck Receiving Inspection Report: RIR-19319 i Certifications: Received with shipment. 2 (b) P.O.: CPF-1725-5 Stainless Steel Shim Steck Receiving Inspection Reports: RIR-18899, RIR-18900 and RIR-19633 Certifications: Received with shipment (2) Hardware and materials for a sample Hanger Strut were examined. Results are as follows: NPSI supplied hanger. DWG. No.: CT-2-001-406-532R, Rev. 1 Drawing Item No.: 4-Rigid Sway. Strut ' 3 Hardware and Material Identification Control Numcers t (traceable to heat numbers): Pipe - NP 288 Eye Red - NH 631 Nut - NR204 Eye Rod - NH 631 Nut - NR 236 Bracket - NF 1287 Hex Nut - NB 250 Pin - NH 846 Activities observed and records reviewed reflected that the traceability activities were perfor.:ed in accordance with site precedural requirements. Emphasis on the necessity for geed traceability was apparent throughcut the site organizations. I e VI-10 t
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VII. QUALITY CONTROL INSPECTOR EFFECTIVENESS A. Obfective . The cbjective of this portion of the inspection was to determine if quality centrol inspectors function freely in performing their tasks, ' withcut intimidation by craft personnel or supervision; and if inspection persennel are qualified, trained and have the organizational freedem to perform their tasks.
. B. Discussion ,-
- 1. Precram Recuireisents The Quality Control Pregram is defined and implemented by the Cor-parate Quality Assurance Manual, and by more detailed Quality Assurance procedures and instructions which are endorsed by management directive. Management and supervisor responsibilities have been described in these precedures. ,
The Final Safety Analysis Report (FSAR) contains implementing statements for 10 CFR 50 Appendix B and provide cemitment statements to regulatory guides including NRC Regulatory Guide 1.58 (ANSI N45.2.5), which define Quality Program requirements. Quality Assurance procedures were developed to implement these comitments. For example, QAP-2.1 defines the requirements for the training and certification of mechanical inspection personnel.
- 2. Precram Imolementation Imolementation of this portion of the pecgram was deter =ined frem discussions with Quality Control persennel and their supervisers, frem a review of inspector training, frem a review of certification precedures and the inspector verification files, and'frem a review
, of the sequence of recording and permanently filing the results of inspecticns. :
Interviews were held with 63 inspectors randemly selected frem Texas !
, Utilities Generating Company (TUGCO) and c:ntractor organi:atiens !
performin I Grinnell)g inspections en site-(Brown These discussion included&the Rect, Bahnson inspector's Services, area of and I assignment, backgrcund, training and education, perception of hcw thorcughly inspectors were trained and prepared to perform inspections, and involvement relative to construction craft interfaces, including the presence of any fem of intimidt. tion. Cements c:ncerning inspector qualifications in the area of nondestructive examinaticn (Secticn IV) and specific cements c:ncerning electrical (Section II) and mechanical (Secticn III) inspection procedures are presented in the applicable sections of this report. h VII-1
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- a. Inscector Qualification / Certification I (1) Inspectors were required to attend training sessions, perform a independent reading of standards relative to their inspection area, and were tested with regard to this training material.
In;pectors were required to participate in on-the-job ' training (0JT) which was verified by a senior. inspector designated in writing to verify this training. Appropriate forms and certificates were on file, in .
- accordance with ANSI N45.2.6 requirements, attesting to the .
inspector's background, experience, education and training and certifying aa inspection capability in particular ccnstruction activities. (2) During the review of the training records and from interviews with supervisors, it was found that some QC inspectors were certified with less experience than required. For example: 1
- a. Three individuals were certified Level II (L-II) as mechanical inspectors having authority to witness pump or c:mponent disassembly and reassembly with qualifying experience only in welding and nondestructive examination.
- b. One individual was certified L-II as mechanical inspector having authority to witness pump or component disassemoly and reassemoly using education as a factor in the qualification process when the education was from a non-technical, unrelated college degree.
- c. One individual was certified Level I (L-I) electrical inspector after only 3 weeks of electrical inspection experience.
i
- d. Two individuals were. certified L-I anchor bolt inspectors ;
j with less than 1 month inspection experience. ! j , ANSI N45.2.6 requires a minimum of 6 months experience for L-I when a candidate has a high school diplcma or equivalent education, and 3 years experience for L-II when a candicate has a high school diplcma or equivalent education.
- b. Rec:rdine Ins:ection Results (1) The Inspection Repcrt (IR) form was the document primarily !
1 used to record inspection results. A review was mace of the I recording, reviewing, and filing of inspection ~ reports with the follcwing results:
- a. The FSAR and the TUGC0 response to NRR Generic letter i
81-01 state that TUGC0 is in c:mpliance with Regulatory Guide 1.58, which endorsas ANSI N45.2.6, ." Qualifications l cf Inspection, Examination and Testing Personnel for Nuclear Power Plants." ANSI N45.2.6, Section 3 and Table 1 i e VII-2
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j . provides the levels of capability for project functions and defines them as: s' .-L-1 capable of recording ' inspection, examination, and testing data and implementing inspection, examination, - and testing procedure. l
. L-11 capable of performing as a L-1 plus; Planning inspections ....
Evaluating the validity and acceptability of
~
inspection .... results Reporting inspection, examination .... results. Supervising equivalent .... personnel Qualifying lower level personnel The requisite qualification for these capability levels is p'r ovided within Section 3 of the standard,
- b. The NRC CAT inspectors found during interview and document review that:
. With a few exceptions, as stated above, inspectors were experienced.
. In the areas reviewed, QC inspectors completed and signed irs. L-11 certified inspectors in the electrical and instrument areas of inspection reviewed the irs, but did not document their review. In some inspection discipli-nes, such as mechanical (non ASM-) and conduit supports experienced. lead ins;ecters (designated L-1) reviewed the IR before it was sent to file. -
In other inspection disciplines, such as Civil CC, there were no routine reviews performed by an experienced lead inspector. In each of these cases, the reports were not signed by the reviewer. Document reviews revealed that inspection instructions and inspection reports were detailed and inclusive. Licensee representatives indicated that the reason for these detailed instructions and reports was that they could be co=cleted by inspectors with no additional reviews by other inspectors or supervisors. The intent of ANSI N45.2.5 is that a L-11 be the inspector of record. The practices in place at the site did not ensure that this requirement was satisfied. i i f VIII-3
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- c. Ins:ector Intimidation During discussions with inspectors it was revealed that in one 3 section of the inspecticn organization threats and intimidations
./ had been made. This informaticn was transmitted to NRC Region IV
, since an investigation in ttis area was currently in progress. An inspector from a different inspection area reported previous threats, which resulted in the craft person making the threats being removed from the project. Aside frem the engeing investigation, it was revealed that . agressive action was taken by management to prevent inspector intimidation. Inspectors frem one section reported that they were informed not to prepare nonconformance reports. This instruction was issued by memorandum and is discussed in Section III and Section IX of this report. 9 e 4 VII-4
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t i f m VIII. QUA!.ITY ASSURANCE A. Cbfective - The objective of this review was to determine the adequacy of the licensee's Quality Assurance (QA) Program. The program was reviewed to determine if it was appropriately established in instructions and 4 2 manuals; and if the construction and quality assurance effort was In addition, a . menitored through audits and other management actions.
- sampling review of specific steps taken by the licensee regarding the oversight of contractors, control 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. Prceram Recuirements 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 imolemented to satisfy the licensee's Final Safety Analysis Report (FSAR) comitments.
- 2. Prceram Imolementation Implementation of this portion of the program was detennir.ec based on reviewing the organi:stional structure, input from other NRC CAT inspectors, the construction audit program, samoling drawing revi-siens in the ccnstruction work areas, and reviewing the control of measuring and test equipcent.
- a. Orcani:ation The QA organi:ation includes the site construction quality control organi:ation which is independent frem the site construc-tion management. The quality assurance organi:ation reports to the Vice President for Nuclear Operatiens, whose res;cnsibilities include the construction and operation of the Cemanche Peak Steam Electric Statien (CFSES). The authority and duties of the positions involved were described in the FSAR and corporate manuals. The audit organi:ation was located at the Corporate Headquarters in Dallas. The QA organi:atien was fcund to be in acecrdance with NRC requirements and the description contained in the FSAR. Organi:ational Charts indicated that a number of staff positiens were vacant and had been for an extended pericd.
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I i g b. Audits
.; J The licensee's audit program was reviewed. At least 18 audits l
j out of 60, performed between 1978 and 1983, were se'lected and j reviewed with emphasis on the following major areas: auditor
] qualifications and certifications; audit planning and scheduling; -I audit instructions and check sheets; audit reports; audit results and followup; and the overall effectiveness of the audit program. .
(1)AuditorQualifications2ndCertifications (a) The licensee qualification and certification program for i auditors and lead auditors was established in QA
, Procedure DGI-QA-2.1 " Qualification .of Audit Personnel". l
- (b) The certification records for ten lead auditors were
, reviewed. The lead auditors met the TUGC0 and ANSI l N45.2.23 requirements. The review revealed, however, l
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': authority and the guidance provided was not defined. (2) Audit Plannino and Schedulino j (a) Document reviews and interviews revealed that audit plans ' were developed and a system of. check sheets were used as guides to the auditors to ensure that specific peints were reviewed. Open audit findings were also reviewed during the audit. It was revealed that the check sheets were developed by the auditor assigned the audit or by the audit group supervisor but were not approved by the QA Services Manager. Interviews revealed that audit schedules were develcped using previous audit findings, schedules, experience, and discussions with construction site supervisors concerning constructicn problems. There were no trend analyses or construction schedules provided to the QA organi:ation by . l the site; therefore, these important scurces of in-
; formatien were not used in developing the audit schedule. (
Also, there was no QA procedure to describe the methcc to i be used to develop audit schedules or what management approvals the schedule should receive.
~
/
(3)AuditRecorts Audit reports provided a description of the audit secpe; identificatien of auditcrs; persens contacted; a sumary of results and a description of any deficiencies or findings.
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e , . ] (4) Audit Deficiency Recortino 'and Follew-uo Audit' deficiencies were clearly written and required tiasly response by the management of the audited organization. The ccmpleted deficiencies were reviewed by the audit team leader for adequacy. Deficiencies were reviewed in subsequent audits for ccmpleteness. Prempt corrective action was not always taken en audit findings (See Paragraph B.2.b.(5) 1 below). , . . (5) Procram Effectiveness Although the audit program was in place, there were several weaknesses in the program that decreased its effectiveness, i (a) Audit Effort j The audit organi:ation is located at the TUGC0 offices in Dallas. All audits are performed from that location. i
- There are eight auditors in the audit section. Although audit teams are sometimes supplemented by personnel from i
other sections of the QA organization, the eight member
' audit section is assigned to perform audits of suppliers, subcontractors at the construction site, construction activities and startup. Of the eight auditors in the audit organi:ation, four had technician background and i
-) . -
four had a general nontechnical background. None of the
- auditors assigned to the group had engineering background or experience. Interviews revealed that approximately 1 1200 man days were spent preparing for, conducting and reporting audits at the site in 1982. A review of the 32 audits perfor=ed in 1982 revealed that about 330 man days were spent on site performing these audits. This apcears to be a small percentage of the total audit effort considering the level of effort ongoing at the site.
- Interviews revealed that five additional auditer positicns had been authorized for more than ene year but the positions were still vacant.
(b) Audit Frecuency i Interviews and d:cument reviews revealed that: i j Twelve audits of construction activities were performac
- - in 1981. Of these, six were of engineering and adminis-trative areas such an audits of IE Eulletins, and pro-curement and six were of construction field activities.
Thirty-two audits were performed in 1982. Only nine of s the audits were of constructicn field activities, the VIII-3
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j . I other 23 audits were perfor ed of engineering activities Q and other support areas. Of the audits of construction . field activities: one audit was performed of eachanical
] piping activititts, one of restraint and snubber instal-i
; lations, two of electrical work, one of civil work, one
; of instrument ar.d controls, and three of protective coatings application.
The frequency of audits of construction activities has been '
' very low and may have contributed to the problems in the technical disciplines identified in Sections II III, and IV
. , of this report.
1 (c).AuditEffectiveness - j Areas of the construction activity were audited; hcwever*
; the audits did not identify major construction pregram j problems, for example:
Bahnson Services was audited yearly since 1980. The i{' last audit was in April 1982. Although fabrication and 1 i' installation activities and persennel qualifications were in the scope of the 1982 audit, such NRC CAT
- identified items as undersized welds, out of tolerance dimensional characteristics, and an inadequate struc-i 3 -
tural welding inspection program were not identified
; J
, and resolved.
The electrical area of construction was audited only fcur times since 1980. The audits did not identify the cable separation issue as discussed in the Electrical Constructicn Section (Section II) of this report. Ineffective corrective action has been taken as a result of aucit findings; for example: Ecuipment maintenance was audited in August 1979 (audit numeer (TCp-5)). An audit finding identified that venc:r instructions were not being incorporated into engeing
; maintenance instructiens. The July, 1981 QA audit of ! startup activities (TUG-5) and the June 1982 Quality Surveillance Sumary, QSR-82-023, identified adoitional 1
problems with ensuring that manufacturers recuirements and qualification report requirements had been incer-porated into the maintenance prcgram. An Oct:bar 1982 audit (TUG-14) identified the concern that equip: ent qualificttien reports were not reviewed during t::e J process of establishing maintenance requirements. The 0 VIII-4 D - f n p *t <' = I 2'a L .. _
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l t 1 problem was identified in 1979, and it has not been I T resolved as evidenced by the 1982 audit. Thus, the -
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effectiveness of the corrective action system for audits is not effective.. I i The NRC CAT inspector's' ccnclusion is that weaknesses j exist in the established audit program. These weaknesses l include the scheduling and frequency of audits, the lack of - i effective constmetion program monitoring, and in lack of - I effective resolution of seme audit findings,
- c. 0A Precram Interfaces The NRC CAT inspector reviewed the QA organizations' overview of documents that prescribe actions taken by engineering, construc-tien, and quality assurance personnel. A planned and systematic program is in place with one aspect being procedure review.
Interviews and document reviews revealed that: (1) The QA/QC manager or a senior representative reviews all j inspection procedures.
} (2) The QA/QC manager or a senior representative reviews con-struction c:ntrol procedures te ensure the proper construc-4 t ., tion-inspection interface exists.
1 i ' (3-) Engineering centrol procedures are not reviewed by the QA/QC manager or a representative of the QA organizatien. The lack of pr:per inte'rface with engineering may have c:ntri-buted to the issues discussed in Sections II, III, and IX of this report. These issues relate to the final engineering design and the final inspection reports not being reflected in the har:,.are.
- d. Ccnstructien Menitorine A program of construction monitoring was established. The program censisted of: menitoring the ASME construction and installation activities perfomed by Srewn and Rcot (S&R), anc 1
! surveillance of c:ncrete anchor bolt installaticns. i ihe m:nitering of ASME construction activities c:nsis.ted of a systematic review by two individuals of B&Rs c:mpliance to j approved instructicns, precedure.s and/or drawings that implement the recuirements of the B&R ASME QA manual. The monit: ring was scheculed in advance and provided a review, althcugh less formal than aucit, of engoing ASME work activities. The surveillance of anchor bolt installatien was perfomed in accordance witn TUGC0 precedure CP-QP-11.2 Rev. 4, which indicates that 10 VIII4 _ ama m e + + + +e* ** - - esur g
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i i installations should be monitored each snift for each discipline.
.l 3 A review of the menitoring record since September 1982 revealed
; ;j
. that not nearly that many installation: were monitored. In September 1982, 35 to 40 installations were monitored. From October 1982 through January 1983, 30-40 installations were monitored each month. This is an average of monitoring one
- installation each day instead of ten each day.
Interviews revealed that, although the installation activity had . decreased, inspectors were assigned to inspect completed work and
> ' that the surveillance requirements of the procedure were not l being met. The anchor bolt monitoring program is not being
- performed as required by the implementing procedure.
- l. . e. Documen't Control I Document control includes the control of all documents associated with the design and construction program. This includes drawings, procedures, specifications and manuals. Drawing control was selected for review as an indication of the
.I implementation of document control.
( Controls had been established to femally log drawing and revi-l sion numbers into a card system and subsequently into the compu-ter. Document control group personnel reproduce the drawings and
')
l revisions for distribution. Distribution is made to a central pickup area. Each major construction organi:ation has assigned , personnel to distribute the drawings from the pickup point to I drawing control points and to work areas throughout the site. A master drawing revision list is issued every three months and each organi:ation is required to audit their areas to determine that all drawings are of the correct revision. The control'of drawings was reviewed in the control and distri-butien centers for the pipe shop, welding engineering and the electric shop. In addition to these office areas, drawing control was reviewed in construction work areas of the auxiliary building, the cable spreading recm and the centrol rocm. These reviews revealed that: l (1) The drawings in the control and distributien centers were of i the latest revision. ,
.i
- (2) On February 3 and 15, 1983, in constructicn work areas, cut of 70 drawings checked by the NRC CAT inspector, 16 were not of the latest revision.
l (3) On February 22, 1983 constructicn areas were toured by the
' NRC CAT inspector. It was fcund that improvements had been made in drawing centrols. One drawing to an out-of-date VIII-6 f
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! O revision was found during the tcur, however there were still
' drawings in the areas that had damaged or missing title
- l. -
blocks. i \ Interviews with TUGC0 personnel revealed that drawing centrol had l been an ongoing problem that required frequent attention. Based
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on this sample, document control still is weak. j f. Control of Measurino and Test Ecuicment . i ] The system of control of measuring and test equipment was yI reviewed. The review included equipment calibration, issue, and recall. During 'a tour of the calibration facility the following areas were reviewed; the use of certified equipment during the cali-bration process and the relationship of the certiYied equipment to national standards; the storage and separation of calibrated equipment from equipment out of calibration or defective; and the
) general condition of the facility.
{ It was found that the equipment used during calibration was i traceable to national standards and that equipment was properly i stored. Other coments concerning the facility and some specific j instruments checked are contained in the Electrical Ccnstruction
} Section (Section II) of this report.
TTie methods of control and issue of electrical cable crimping tcols in the storage area, and condition of tools in the electri-cal construction tool issue station was reviewed. The storage area and the control of termination equipment was satisfactory. 4 The equipment recall was' computerized which allowed prompt notification of craftsmen and inspectors when the tool calibra-tion due date was approached. The control of measuring and testing equipment appeared satis-factory. J 4 E 4 VIII-7 I n .- . - - -.
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, IX. DESIGN CHANGE CONTROLS AND CORRECTIVE ACTION SYSTEMS I . A. OBJECTIVE i j ]'
The purpose of this assessment was to review program implementation
.j with emphasis on actual safety-related hardware installed in the field, i as well as records including design change controls and.any identified 7 noncenferming conditions related to installed hardware.
i
- Samples were selected in the technical disciplines to check program implementation, as well as to ensure design control, design interface. .
; and design verification procedures satisfy NRC requirements and -
i licensee connitments. Additionally, a sample of records were reviewed L to determine how nonconforming conditions were identified, disposi-
! tiened, and the extent to which corrective actions were taken.
- 3. DISCUSSION , .
- 1. Design Change Control Procram
- a. Orcanization The organi:ation of the general site engineering, construction, and procurement efforts were defined in procedure CP-EP-3.0, Rev.
- 5. By this procedure, the Engineering and Construction Manager i is responsible for the Comanche Peak Steam Electric Station-(CPSES) design, engineering, and procurement. These activities
! are nomally delegated to Gibbs & Hill, Westinghouse, and other 3 contractors / vendors. However, Texas Utilities Services, Inc.
~> (TUSI) has been designated by Texas Utilities Generating Company (TUGCD), the licensee, to retain overall responsibility for these
, activities and to perfonn design functions as necessary, i
The TUSI Project Engineering Manager is responsible for the i general direction of engineering activities. These duties and responsibilities were implemented thrcugh the Comanche Peak- , Project Engineering (CPPE) staff and crgani:stional structure managed by the Cemanche Peak Project (CPP) Discipline Engineers. The CPP Discipline Engineers were responsible "to administer an orderly design change program which complements construction anc assures design adequacy",
- b. Discioline Encineerine Reviews (1) Civil Encineerine Most of the design changes in this area were processed via Design Change Authori:atien (DCA). Previcus design enanges processed prior to the current precedural requirements were processed via the Design Change / Design Deviation Autneri:a-tien (DC/DDA). A total of thirty of both of these types of design changes were reviewed. Ten, initiated as a resuit of a.nenconfoming condition, and were reviewed and c:mcared to the associated ncncenfomance report (NCR). Ten were tracec IX-1 r-__. _ m Ne"27 . X~ 7"N 7"'~* ~^
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-f by the NRC CAT inspector to the latest drawing and/or '
specification. The final ten were initiated based on a licensee field inspection effort. These last ten were compared by the NRC CAT inspector to the drawing and/or 3 specification in effect at the time of the inspection. _
- Design changes reviewed in this area were found to be i
processed in accordance with procedural requirements. l The NRC CAT inspector noted that some original designs in this area were processed via Component Modification Card
; - (CMC). The CMC, which is a design change document, was '
, processed in accordance with design change control procedure -
~! CP-EP-4.6, Rev. 7. However, these CMCs showed no evidence of l Gibbs and Hill review, which is necessary to satisfy ANSI l j N45.2.11 requirements. ANSI N45.2.11, " Quality Assurance Requirements for the Design of Nuclear Power Plants" requires
! that field changes be justified and. subjected to design
- i controls connensurate with the original design. The respon-sible licensee engineering representative indicated these CMCs would be treated as a field change, and hence, would receive Gibbs & Hill review to satisfy ANSI N45.2.11.
A selected sample of Engineering Evaluation of Spacing
; Variance Reports (EESV), used in pipe support base plate
! installations, was reviewed. The expansion anchor bolt i installation program was reviewed to the requirements of NRC
, ? Bulletin 79-02 Rev. 2 " Anchor Bolt Base Plate Flexibility Analysis." It was found, from the samples reviewed, that the 3 licensee's program satisfies the Bulletin's requirements.
t J (2) Field Structural Encineerina Most of the engineering effort in the TUSI Field Structural Engineering Group at the time of this inspection involved design of conduit supports. The original design of these suoports was performed by Gibbs & Hill to Revision 8 of the
- J322-5-910 drawing "' package". From- this point, the design effort was delegated to the TUSI organization at the site.
Installation was ccordinated between engineering and con-struction, wi*.h installation performed to the 2323-5-910
" packages". After installation, the support design was then ,
sent to Gibbs & Hill for review to satisfy ANSI N45.2.11 requirements. TUSI personnel prepared no DCAs to the "S-910" , 4 drawings, only CMCs wnere design or design changes were )
- necessary. , I f
Location of conduit supports were determined by the use of criteria established from "Locatien of Support" (LS) drawings and the requirements of the site Electrical Specificatien ES-1CO. Cable raceway supports were installed to Gibbs & Hill ori-ginal design drawings. TUSI personnel issued DCAs to the support drawings for generic design changes, such as the IX-2 w . 7.... 7 7, _, m . s,_ , _.., _ .
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addition of a hanger to the raceway configuration. They issued CMCs for design changes affecting an individual 1 support. o J The NRC CAT inspector reviewed two structural calculations for cable tray and conduit supports with the responsible
~ licensee's representative. The design input.. verification, i and output (information provided by the Field Structural i Engineering Design Review Log) were reviewed. Stress levels, 1 as defined in FSAR _Section 3.8.3.3.3.1 ard FSAR Section .
- 3.8.4.3.3.1 were properly incorporated irto the support .
designs reviewed. The NRC CAT inspector sampled and reviewed sixty CMCs and
, fifteen DCAs. About thirty of the CMCs and DCAs reviewed had not received the appropriate review and approval by the original designer, Gibbs & Hill as required by ANSI N45.2.11.
Installations to the design document had been perfomed or were in-process, but the design document had not been ' final' reviewed. A review of the Gibbs & Hill " CMC Master Index" (structural) indicated there were on the order of four-to-five thousand of such changes that had been generated but had not yet been " final" reviewed by Gibbs & Hill. It was determined that proper verification of such changes might ultimately be accomplished. However, the volume of CMCs and DCAs remaining to be reviewed by the original designer, as well as those designs that have as yet to be 3
; performed in the structural area, is of concern to the NRC
, CAT inspector. The concern involves the adequacy of review which will be provided considering the approaching Septemaer,
; 1983 Fuel Load Date.
During this same review of CMCs and DCAs, there was evidence of a problem relevant to what revision of the design docu=ent a c:moonent or an activity has been inspected. CP-CFM-6.10, Rev. 6, " Inspection Item Removal Notice Form" addresses subsecuent inspection following removal of an item, but not for addition of an item to a c mponent. Furthermore, c:n-4 structicn and/or engineering rather than quality c:ntrol - determine when an item is to be reinspected or when so=e type of inspection is required. The NRC CAT inspector deter =ined that inspections perfor=ed and c:mpleted were not always to the latest issued design i docu=ent. For example, supports for twenty cable tray and c:nduit installations were examined. Of these twenty, twelve were not " final" inspected to the latest issued design docu=ent, even though records in the QA vault indicated
" final" inspection had been performed. Later CMCs c:vering
, design changes existed for all twelve of these installations.
In accition, the licensee's QC inspections were performed in six instances to CMCs with earlier revisions than the latest revision issued and in effect g the tire the ins:ection was 6 IX-3
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1 performed (Similar conditions were discovered and discussed in tne Electrical and Instrumentation Constructicn Section of the report Section II)]. I .
.! 3 i .J ANSI N45.2.11, Section 8. states that procedures shall be
- i. provided which " assure that the impact of the change is carefully censidered, ...and information concerning the 2
change is transmitted to all affected persons and organi- .I zations." As a result of the procacures and records reviewed
! relative to this area, the NRC CAT inspector considers ' ? -
existing procedures have not assured that the infomation .- concerning the change is transmitted to.the apprcpriate organizatien; i.e., the Quality Control organization responsible for the inspection of the cable tray and conduit
. supports. This was substantiated by records in the QA vault.
(3) Electrical Enoineerino -
- a. Prceram Review ,
Original design in the electrical area was performed by I Gibbs and Hill. Design changes were process,ed via the DCA 1 in this area.
. The NRC CAT inspector reviewed approximately thirty DCAs i in the electrical disefpline. As was the case in Field !
Structural Engineering, reviews to be ecmpleted by the j s original designer in accordance with ANSI N45.2.11 are
'j usually only perfomed after construction or installation )
l{
. has been performed. DCAs reviewed were processed in accordance with CP-EP-4.7, Rev. 7. Du-ing this same review, the NRC CAT inspector also noted a prcblem similar to that in the F.ield Structural Engineering relevant to what revision of the design document a cc. penent or activ-ity has been inspected. As a result, the NRC CAT inscec-ter proceeded with a review of the site "Jesign Change i Verification Group". ,
- b. Desien Chance Verification Groua Review in tne Electr1cai Area CP-QP-15.4, Rev. 3, " Design Change Verificatien" provided criteria...(for) review of design anc inspecticn cecumencs
, to assure incorperation of design changes into the pnysi-cal plant.
This procedure required that design documents be reviewed by the TUGC0 Design Change Verification Grcup (DCVG) to ascertain whether or not incorporaticn of the latest i design document had taken place, and if further inspection was recuired the DCVG "shall perform" it. , 1 Also, per procedure, the DCVG was retuired to select a i representative sample of design changes per drawing IX-4
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l (thirty percent or three design changes, minimum, which-ever is greater) for verification. j
. A review by the NRC CAT inspector of the "DCA Verification
. ' ,1 Log" indicated that of some four-hundred elever. design changes verified, fift/-three had not been incorporated into the actual design documents used for QC inspection.
Due to the high number of unincorporated changes, licensee representatives indicated that the procedure would be changed from the current thirty percent sample to a one-hundred percent sample. ,- i However, the NRC CAT inspector had other additional i concerns with the licensee's program at the time of this assessment. These were as follows:
- i i . With the approaching Fuel Lead Data, .and the numbers of I bCAs to be verified, the thoroughness of the review by
- j DCVG may be jeopardized due to pressures frem the con-1
; struction completion schedule.
t i '
. Procedures for the DCVG in some cases required physical 4
verification by inspection of design incorporation. It was unclear as to who was to perfom the required inspec-tion, a DCVG individual or a QC inspector. Additionally, licenses representatives could not assure the- NRC CAT inspector that the individual who would perform the inspection function would satisfy the applicable qualifi-cation requirements as defined in ANSI N45.2.6, "Qualifi-
~
cation of Nuclear Power Plant Inspection, Examination, and Testing Personnel" in accordance with the licensee's FSAR commitments.
. Unsatisfactory conditions discovered during the verifica-l tion process were not documented on an NCR but rather on a f " Request for Information of Clarification" (RFIC) fem '
since conditions were considered to be only ";otential" nonconfor ances. As the component or activity may not have received the " final" inspection, the licensee stated: 4 "it was not considered to be a nonconfor=ance."
. Documented deficiencies relative to installation were not documented on the Master Punchlist for " turnover", as the licensee representatives indicated only NCR items were referenced on the master punchlist. These deficiencies
. were applied to a separate " deficiency" list, and then
; were tracked by the DCVG.
. It appeared from this review that the DCVG did not include in their review electrical systems " turned over" for test or electrical systems which have been energi:ed. The NRC CAT inspector could cetermine no basis why these systems should be excluded in the sa=ple for design verification.
e IX-5 ) - 9
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The responsible licensee representatives, during the discus-f- sion of these inadequacies, comited to revise the program i w by the addition of a tracking system which would co
- They further reiter_ated their intent design change document.to ensure that all safety-related compenen ties have been or will be inspected to the latest design document to satisfy NRC requirements.
L At the time of this inspection, as no work has been essen- .. tially fully completed frem the design and construction - standpoint for these areas, the NRC CAT. inspector cannot datemine from a sampling review whether or not the activity or installation was performed to the approved design and that an adequate inspection was performed to this approved design. However, from a sampling review of documentation from the program in-place, including the " final" quality inspections and the latest design documents, the existing design verification program would not satisfy the licensen's FSAR i' connitments (Further discussion of inspection' documentation is in the Electrical Construction section of this reportWhether (SectionII.B.8)]. revisions to the program are adequate to accomplish the desired objective in the alloted time span cannot be detennined. (4) Instrumentation Encineering Instrumentation installation activities and documentation
-reviewed by the NRC CAT inspector indicated that these installations had received an appropriate inspection to the latest design document. Supports for instrumentation were usually designed in-place. From a review of fifteen design change documents, the numbers of design changes as c:mparec to the installations . completed were considerably less than those in other dist:pline areas reviewed.
Mcwever, adequate engineering reviews to the design changes were usually made after installation, similar to the process described relative to other installation activities discussed thus far in the report. (5) Picine Succort Encineerinq Two contract pipe design groups (ITT-Grinnel and NFSI), anc the site Pipe Support Engineering (PSE) Group, were respon-sible for the design of large bore pipe supports. These tnree greu:s prepare a design for each pipe support. This cesign is then incorporated into the " Brown and Root Hanger Drawings (ERHLs)", which are the drawings used for installatien pur;cses. If the pipe suoport installation persennel deter-mine that a support cannot be installed as designed, FSE field engineers are notified and make changes as necessary to produce a design that can be installed.
- IX-6
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1 4 j When tha pipe and some of its supports have been installed, ~ the Quality Control program starts its "as-built" inspection. documenting the as-built dimensions of the pipe and installed pipe supports. The drawings for the pipe and pipe supports
'N are revised to reflect the as-built configurations, and are -
stamped "as-built verified." When a significant portion of the supports on the length of pipe have been "as-built verified," a package is assembled and forwarded for a preli-minary stress analysis. A stress analysis is performed to determine new stresses in i the pipe and new loads on pipe supports. If the design *
- requirements are appropriately satisfied, the drawings are then stamped " vendor certified" (VCD).
- i For small bore piping designs, the pipe support design j
activity commences when small bore piping is installed and is
! designed on location. PSE then issues the small bora support i
- drawing. Installation then proceeds, with necessary changes 4 i performed as recuired. After incorporation of these changes, j
the drawing is "as-built" reviewed and a Design Review Drawing (DRD) is then issued. Class V hangers are " vendor certified" only when a stress problem becomes evident in the performance of the stress
- analysis. Otherwise, Class V hangers receive a review equivalent to the original design and incorporation of the l
latest change to the design.
. Design changes made to any of these designs are processed via , CMCs. Approximately seventy-five CMCs were reviewed to
, program requirements by the NRC CAT inspector. The review of these CMCs and inspection documentation in the ASME area by the NRC CAT inspector also revealed that design changes are apparently initiated as a result of the perfor-mance of QC inspection. These changes are then processed to - accept the "as-built" configuration, rather than modify the
. support to actually . satisfy the design document in effect at i
the time of the inspection. These practices do not provice incentives to the crafts to properly construct in strict 4 _accordance with the design dccument. ! (a) NRC Sulletin 79-14 Encinetaine Walkdewn
~
This CPSES program was com;ared to the requirements addressed in the NRC Bulletin 79-14. " Seismic Analysis for As-Built Safety-Related Piping Systems." CPSES engineering program requirements were also defined in CP-EI-4.5-1, Rev. 8, ! " General Program for As-Euilt Piping Verification." Discus-siens with the responsible licensee engineering personnel indicated that a detailed "as-built" inspection is being
- perforred and is being analyzed in accordance with the engineering requirements of the bulletin.
9 IX-7 a 4 E d '
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; The responsiblo engineering representativa for the "79-14" t program was interview;d, and the actual mechanics of the walkdcwn were discussed in detail. Basically, the program . requirements regarding large bore hangers were discussed.
3 Also, ten selected calculation packages were reviewed rela-J tive to this type of pipe support. Approximately fifty-five percent of the "79-14" verification program was completed for CPSES Unit 1. A very small number of " packages" have completed the required reviews and are
. considered " final." Thus, it was not possible for the NRC
- CAT inspector to determine from a sampiing review whether or .
! not the activity or installation was performed to the ap- '
proved " final" design and that an adequate inspection was l performed to this approved " final" design. t
! (b)VCDPrecramWalkdownbyOCInsoectors l From this review, it was difficult for the NRC CAT inspector l to determine the thoroughness and adequacy of'this walkdown 1 and/or inspection. Interpretations of the procedural '
requirements by licensee personnel ranged from a detailed inspection of many attributes to a " location-only" walkdcwn. Additionally, the NRC CAT inspector could not determine when a component was " final" inspected. The NRC CAT inspector considers that these inspections do not necessarily provide adequate assurance that the elements / components have been installed to requirements. As indicated in the Mechanical Construction Section (Section III.B'.2) of this report, numerous examples of hardware accepted by VCD walkdown were found not to comfonn to design by the NRC CAT inspectors, the ASME Authorized Nuclear Inspector (ANI), and QC during subsequerit inspections. However, the VCD drawing does define a stopping point in the iterative design process, a control not present in the other disciplines reviewed. Licensee representatives again stated their intent to satisfy the necessary NRC requirements, and also expressed confidence in their VCD program. (6) Picine and Mechanical Encineerine To review the design change control precess in this area, approximately fifty DCAs/CMCs were reviewed. Several trave-1er and installation packages were compared to the program requirements for piping installations. As. referenced in this recort, few deficiencies in the review of safety system piping and ASME Code radiography for this piping were found by the NRC CAT inspectors within the hardware areas. Few design changes were fcund relevant to this area. Several traveler an installatien packaces were reviewed to
, the program requirements for mechanical ~ installation.
i IX-8
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Similar observations relevant to the processing of design , ' changes and documentation of nonconfomances were made. These were discussed in previous paragraphs of this section T 3 of the report as to electrical equipment, electrical sup-
' ~ ports, and pipe hanger / support installations. Discrepancies l relevant to inspection procedures are discussed in tne- ,i Mechanical Construction Section (Section III) of this report.
i
,I
- c. Sum.ary Coments Concernino the Desien Chance Process i
The design change process at CPSES is complex, and at times,
- l*
cumbersome. The NRC CAT inspector's review of design change pro-cesses in the various disciplines revealed a design change 3 program with controls incorporated under a " design-construct-design review" philosophy. This philosophy resulted in a large l1 number of design changes and a repetitive inspection process. (NOTE: .There are approximately 70,000 CMCs and 15,000 DCAs that
;' have been issued. This number does not include revisions).
Although this design change process may be difficult, there is i nothing in NRC requirements to discourage or prohibit the use of such a system. In general, design change controls at CPSES satisfied the applicant's FSAR connitments and the ANSI standard requirements. However, with this type of system in-place, actual ! verification of hanger, support, electrical, and mechanical i equipment installations to the appropriate design requirements cannot be perfomed until " work activities" have been completed.
- Few, if any, installations could.be verified as few have been 1 designated as completed under the licensee's context of
" completion." Thus, the final adequacy of these controls could not be determined by the NRC CAT inspector.
- 2. Corrective Action Systems she CPSE3 FSAR requires a nonconformance report be "utill:ac for the identification, documentation, dispositioning, and verification of deficiencies in characteristics, documentation, or procedures which render the quality of an item unacceptable or indeterminate". The i FSAR also requires procedures for trending of nonconformance reports i
to identify trends adverse to quality and for the initiation of corrective action requests for significant and repetitive ncncenfor-mances.
.CP-EP-16.1, " Processing Nonconfomance Reports" and the ap:licable references were implemented at the site to meet these recuirements to satisfy the license:'s FSAR comitments. ,
A review of approximately one-hundred selected nonconfor=ance reports (NCRs) indicated that identified nonconformaning c:nditions (decumented on NCRs) were dispositioned and processed in accordance l
! wf th procedural requirements.
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- As discussed 'in Sections II, III, and IX of tnis report, overall findings indicate numerous instances in the electrical and mechanical areas where nonconformances were identified. Mcwever, varicus matheds (e.g., punchlists, inspection reports, verbal, and
, other infermal matheds) were used to address and resolve these nonconformances, providing nc collective evidence of appropriate corrective acticn and/or justification. Additionally, the NRC CAT inspectors discovered that the Mechanical / Civil QA/QC Supervisor directed his supervisors to document nonconforming conditions en an unsatisfactory Inspection Report (IR) only, contrary to the
- licensee's FSAR comitments and QA program requirements.
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. .. m ATTACHMENT A A. Persons Contacted The following list identifies by title, the individuals contactd during this inspection. .
Cercorate Office: Vice President, Nuclear Operations . Manager of Quality Assurance . Quality Assurance Audits Supervisor Regulatory Interface, Program Review, and Training Supervisor Comanche Peak Site: Vice President, TUSI Construction ' Manager, TUSI - Resident Ccnstruction Manager, TUSI Project Construction Manager, B&R Project Engineer. TUSI Project Discipline Engineers (4), TUSI Engineering Unit Sucervisors (8), TUSI Startup Manager, TUGC0 Quality Assurance Supervisor, TUGC0 Quality Assurance / Quality Control Inspection Supervisors (3), TUGC0 Quality Assurance Manager, B&R Quality Control Inspector Supervisors (3), B&R Welding Engineering Unit Supervisor, B&R Pr:curement and Control Manager, TUSI Product Centrol and Warehouse Manager B&R Autheri:ed Nuclear Inspector (2) NOTE: In the c:urse of the inspection, numerous craftsmen, inspectors engineers and supervisory personnel were also interviewed who are not specifically listed. B. Documents Reviewed The d:cuments listed below were reviewed by the inspection team cammers to the extent necessary to satisfy the inspection of objectives stated in Secticn I of this report. The specific procedures in the re; ort are listed by title and revisien nuet:er, if applicable, when they first a: pear.
'I. Final Safety Analysis Report (FSAR)
'2. Quality Assurance Program Policy -
- 3. Quality Assurance Procedures 4 Cuality Control Procedures
- 5. General ConstFJCtion Specifications
- 6. Cuality Assurance Procadures
- 7. Engineering Precedures
- 8. Pr:curement, St: rage, and Material Traceability Precedures
> ~ 9. Audit Re orts v 10. Trend Analysis Reports i 1
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l U. S. NUCLEAR REGULATORY COMMISSION REGION I 50-445/83-15 Report No. 50-446/83-09 50-446 Oncket No. 50-445 CPPR-126 License No. CPPR-127 Priority -- Category C Licensee: Te<as Utilities Generatino 2001 Bryan Tower Dallas Texas 75201 Facility Name: Commanche Peak Units 1 and 2 i Inspection At: Glen Rose, Texas Inspection Conducted: April 18 - May 6, 1983
- - - .ces : &\ bEli0 j Harry w. 9fcL Aeactor Engineer i cate I
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~ dichard H.' Harris, NOE Technician -
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,hg Ran .Campbe/,NDETecnnician / (a ~e Approved by: r au 4/_1/[X7 gJ.P.Ourr, Chief,Materialsand / cif te Processes Section Insoection Summary: Insoection on April 18-May 6, 1983 (Recort No. 50-445/33-15.
55134/83-09)
, .. Inscected: A routine, announced NRC independent measurements inspection
- enstruction. The purpose of this inspection was to verify the adequacy of tne licensee's OA/QC and NDE program. NRC Mcbile NDE Van and three regional A f fdNi s t. ~1 i
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2 L. sed personnel assisted by two subcontracted NDE personnel were utilized during this inspection. The inspection involved 600 onsite hours and 120 cffsite hours.
~2;;!*s: Two violations were identified, failure to issue proper weld repair
- . :entation (50-446/83-09-03), and failure to meet code required radiographic sensity (50-446/83-09-02). The following unresolved items were identified.
Docket No. 50-445 83-15-01 Preservice ultrasonic records , 83-15-02 PSI procedures 83-15-03 NDE Level III certification 83-14-04 Vendor radiographic film problems Oceket No. 50-446 53-09-01 NDE Level III Certification 83-09-04 Vendor radiographic film problems 1 I I l
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Details 1.0 Persons Contacted i i Texas Utilities Generating Company i j -l j "J. T. Merritt, S/V Mgr. l j "R. G. Tolson, QA. Supv. Brown and Root M . P. Optiski, NDE Level III J R. Durdy, QA. Mgr.
. McCurtain, RSO U.S. NRC
- "W. Kerch, NOE Engr.
'R. H. Harris, NOE Technician
*R. M. Camobell, NDE Technician "R. G. Taylor, Resident NRC
" Denotes attendance at Exit Meeting 5/5/83 2.0 Independent Measurements - NRC Nondestructive Examination and Quality Records Review of Safety Related Systems i During the period of April 18 through April 22, 1983 quality records received from Commanche Peak Nuclear Power Plant #2 were reviewed in the
! regional office for completeness and compliance to the licensee's FSAR connitment to applicable codes, standards and specifications. Subsecuently, an on-site independent verification inspection was conducted j during the weeks of April 25 through May 5, 1983 using the NRC Mobile i Nondestructive Examination (NDE) laboratory. This inspection was conductec ! by regional based personnel in conjunction with NRC sub-contract personnel. , l The purpose of this examination was to verify the adequacy of the Itcensee'.s l welding quality control program. This was accomplished by duplicating those examinations required of the licensee's by the regulations and evaluating the results. In addition to the required examinations, several 1 I additional confirmatory examinations designed to verify conformance with t 1 material specifications were performed and compared to quality assurance l records.
- ' An NRC inspector made a random selection of welds. These were intended to t
provide a representative sample of piping systems, components, pipe size,
- materials, shop and field welds to AWS and ASME Class 1, 2, and 3 Codes.
l The items selected were previously accepted by the licensee based on ! vendor shop or onsitt NDE records. !+ j j
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.1 Material Traceability Twenty-two document packages were reviewed for the following:
) -- Material Certification, including weld wire NOE results
- Fabrication record - shop and field '
Orawings (Isometric) i Physical properties Quality Procedures .
/
f Results: All areas examined were acceptable per applicable criteria. / l i j 2.2 Nondestructive Examination Examinations were performed using NRC procedures with addenda written ~
- specifically for compliance to the Licensee's PSAR commitment to ASME B&PV Code, for onsite fabrication. The intent was to duplicate to the extent practicable the techniques and methods of the original examinations.
l l The following examinations were performed: l Radiograchic Examination - Twenty-five welds were examined by radiography I using an Iridium 192 source per NRC Independent Measurements Procedure NDE-5, Rev. O, addenda CMP-1.5-1. Welds examined were ASME Class 1, 2, and 3 cardon and stainless steel. i
/
j Results: All areas examined were found acceptable per applicable pro- / cecure and acceptance crtieria. i Maonetic Particle Examination - Sixteen safety related pipe welcments and structural supports were examined per NRC procedure NOE-6, Rev. O and addendum CMP-1-6-1. Samples included ASME welds and AWS Code welds. Results: - All areas examined were found acceptable per applicable procecures and acceptance criteria.
' Muid Penetrant Examination 1< *.nree safety related pipe weldments were examined per NRC procedure j 1. 4ev. O, and addendum CMP-1-9-1. Samples examined included ASME Class ;. *
., and 3 nelds.
j Results: All areas inspected were acceptable. / a ; : Visual. Examination - Forty-six weldments and adjacent base material were visually inspected for weld reinforcement, overall workmanship and surf ace ( condition per NRC procedure NDE 14, Rev. O. ' Oesults: All areas inspected were acceptable. _
> Ultrasonic Examination - Forty-four Hilti anchor bolts were inspected
- ' ultrasonically, for length only per NRC procedure NDE 9, Rev. O.
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3 H ults: All bolts examined were found acceptable per applicable criteri: )
,9. ,'feasurement - Fourteen weldments, and adjacent pipe material
. c e examined per NRC procedure NDE-11, Rev. O using a NORTEC NOT thickness gauge. Minimum wall thickness was determined by using ASTM standard pipe sizes and nominal thickness chart.
Results: All areas examined were within tolerance requirements. Ferrite Measurements - Six pipe welds were checked for delta ferrite content using a Type II Ferrite Indicator (Severn Gauge). Results: All Measurements were within acceptable limits. Hardness Measurements - Three welds were checked for hardness (base material adjacent to welds) using the Equo-tip hardness tester per NRC procedure NDE-12, Rev. O. Hardness numbers were converted to Brinnell values and the approximate tensile strengths were determined by use of conversation tables. Results: All areas examined were within acceptable limits.
/
Alloy Analy:er - Six pipe welds and adjacent base metals were examined using a Texas Nuclear Alloy Analyzer. A qualitative chemical analysis was made on four stainless steel 304 type and two stainless steel 316 type material.
/
Results: Areas examined were within 2". of chemical analysis indicated on corresponding certified mill test reports. Attachment - Attachment #1 is a tabulation of the specific areas examined anc results of tests. 3.0 Verification of Nondestructive Examination Film Intercerters The inspector reviewed 51x film interpreter's qualification and certifica-tion records. The records met SNT-TC-1A and the American Society of mechanical Engineers (ASME) code requirements. However, the licensee had ' 1 committed to the site NDE Level III certification by examination. One of the site NDE level III personnel had not been certified by examination. 9 7-
; The individual's record indicated he had once successfully completed the j required examination.
This item is unresolved pending recertification or removal of the existing certification. 446/83-09-01. . 4.0 Review of Licensee Radiographs
, The inspector reinterpreted licensee radiographs to verify the adequacy of ine radiographic program at this facility.
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4 s Thirty-nine welds from Unit Number 2 and nine welds from Unit Number 1 were radiographically reinterpreted. These welds were acceoted by the licensee. The welds selected for reinterpretation were field welds and shop welds. ; Unit 2 Weld RC-2RB73 FV17, Film area 6-8, had a density problem in that the $ l penetrameter density was 2.87 and the weld had densities of 2.31, 2.43 and 2.05. The ASME Code requires film densities to range between -15'.' and
-?C'.' of the density of the penetrameter, in this case 2.44 to 3.73. The
- lere to maintain radiographic densities in accordance with ASME code
.;utrements is a violation (446/83-09-02). ,'
Unit 2 Ultrasonic test report A3146 describes an under wall condition for weld FW ' 2RB-025 SW2RI (W8) in the base metal 2 1/2" x 2 3/8" area. Weld 8 had been cut out from the system and replaced with a new weld W8A. The weld g data card was voided out on 7-15-82. The back side of this weld data card contained a documented base metal repair which was also voided out. No Nonconformance Report (NCR) was issued for this base metal repair. Site ' procedure Q1-QAP-16.1-2 Rev. 4, dated May 20, 1982 paragraph 3.1.1, requires a NCR to be issued for base metal repairs. The failure to properly document repair welds is a violation of 10 CFR 50 Appendix B, Criterion V (446/83-09-03). The quality of worluaanship of the weld is not in , question. 5.0 Review of preservice Ultrasonic Examination The inspector reviewed the ultrasonic preservice inspection (PSI) records for comoliance with 10 CFR 50.55a and 'ASME XI Code requirements. During the review of PSI data for the reactor coolant piping welds, the notation,
" volume not examinable was 60% -2, 5, 7, and 8," was found on data reports.
The licensee's staff was unable to explain the meaning of the notation and subsequently contacted the PSI subcontractor for clarification. The notation means that 60*. of the bottom 1/3 of the weld volume, 360' around the pipe weld, in the four ultrasonic directions (2, 5, 7, and 8), were not inspectable. i The inability of the licensee's staff to understand the ultrasonic test -! reports and the failure to adequately report the extent of examination ! . implies an inherent weakness in the PSI program. Further, the inspector noted that the PSI-NDE procedures did not have provisions for quality assurance review and acceptance. Lastly, the licentea could not provide evidence that the PSI subcontractor's Level III examiner is qualified and certified. ' .I The foregoing items are considered unresolved pending completion of licensee actions and review by the NRC (445/83-15-01). Y d
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5 t 6.0 Vendor Radicaraph Review { l Based on previous industry problems related to valve radiographs, the inspector selected 25 vendor radiographs for review. The review was performed to verify compliance with ASME III and V Code requirements. The following Borg Warner valve radiographs were reviewed. Valve Serial No. Finding
#14116 Film area 2-3, 4-5 has density problem.
Penetrameter 3.19, center of weld density 3.85.
. #25-425(weld 13) Radiograph report indicates some film areas were accepted on 4/7/81; however, those film areas had a R2 marked thru and were dated 4/19/81 indicating they were not the film for the reports of 4/7/81. -
Film area 3 does not have a lead identifying number 4, it has a scribed 4 on the radiograph.
; #27934 Penetrameter in weld area of interest for film
- reviews 1-2, 3-4, 5.
d44107 Density problem in film area 4-5. Penetrameter i density 2.93, area in weld 2.14 density.
~3:03 Penetrameter in area of interest for film j view 7-8, 9-10 i
l The valve radiograph problems were previously identified by the NRC at J another facility and are currently under investigation by the Vendor l Inspection Branch. ' l The above items are unresolved pending completion oE the licensee's 1e' ' i corrective actions and the NRC review (445/83-15r-02,and 446/83-09-04). . 7.0 Exit Interview An exit interview was held on May 5, 1983 with members of the licensee's staff. The inspector summarized the purpose, scope of the inspection, and the findings. i l
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!!i iEtiDEllT HEASU : iT PROM CDMANCitE PI AK UNIT 2 (I' ! ! pcge i .:s Attacte . /
CLASS DATA THICE H.T. R.I. U.T. P.T. IIARDriE55 VISUAL REllARKS WELD fiu.mLR 1 . Line/ ISO l __ RC-2-520-001 FW-3 1 38" Accept N/A N/A Accept N/A Accept N/A Accept FW-4 1 31" Accept N/A N/A Accept N/A Accept N/A Accept l i
; Fn Range 3.5 to 7.5 1 FW-5 1 31" Accept N/A N/A Accept N/A Accept Accept Accept ', RC-2-RB-021-1 Fn Range 3.5 to 5.0 ! W-F 1 12" Accept Accept N/A Accept N/A Accept Accept Accept Alloy Test - Accept 4 i l fn Range 3.5 to 7.5 i l Tw-4 1 12" Accept Accept N/A N/A N/A Accept Accept Accept AlloyAnalized-Acceptf i; !
l 1-2 1 12" Accept N/A N/A Accept N/A Accept N/A Accept ;
. . 3 RC-2-RB-072 W-15 1 6" N/A N/A N/A N/A N/A Accept N/A Accept W-16 1 6" N/A N/A N/A N/A N/A Accept N/A Accept [
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$ W-17 1 6" Accept Accept N/A Accept N/A Accept N/A Accept W-18 1 6" Accept Accept N/A Accept N/A Accept N/A Accept i
W-19A 1 6" Accept N/A N/A Accept N/A Accept N/A Accept i Ril kti-uu j FN Check 3.5 to 7.5 TW-1 , 1 12" Accept N/A N/A N/A N/A N/A N/A Accept Alloy Analized-Accept 1: 'j Ril-2-il t.'b f I i W/-- ; 2 1.*
- 4 cept fl/A ft/A Atept fl/A Act ept fi/ A Accept
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'JELD !c *EER CLASS SIZE DATA TillCK H.T. R.T. U.T. P.T. IIARD:- .'I SUAL REMARKS -
Line!!50 SI-2-58-44'a l u-12A 2 4" Accept Accept N/A Accept N/A Accept N/A
- Accept 1
l IW-17 2 4" Accept N/A N/A Accept N/A Accept N/A Accept : k;
. 51-2-RS-060 fn-Check 3.5 to 7.5 j l l W-22 1 6" Accept N/A N/A Accept N/A Accept N/A Accept
- l fn-Check 3.5 to 7.5 :
FW-21 1 6" Accept Accept N/A Accept N/A Accept N/A Accept t l SI-2-RB-070 Alloy Analized - Accept , , W-8 1 10" Accept Accept N/A Accept N/A Accept N/A Accept
- CC-2-A8-001 !
lJ FW-12 3 24" Accept Accept Accept N/A N/A N/A N/A Accept I I W-A 3 24" Accept N/A Accept N/A N/A N/A N/A Accept .! CS-2-Aa-080A Alloy Analized-Accqpt 'j FM-2-1 2 3* Accept N/A N/A N/A N/A N/A N/A Accept
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W-2 2 3" Accept Accept N/A Accept N/A Accept N/A Accept W-3 2 3" Accept Accept N/A Accept N/A Accept N/A Accept Sphere weld Alloy I, F- 3 2 10" Accept Accept N/A Accept N/A Accept N/A Accept Analized - Accepted '! C5-2-RB-027 fn Check - Accept 1
, fu-3 2 3* Accept Accept N/A N/A N/A Accept N/A Accept t , t C1-2-ku-Out l '
[ 1 u W-3 1 o A.Tept N/A FI/A fi/A N/A fl/A [ _, - - l ': u -;-a-.ee
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p Sy 3 og A . r: t i INDEPENDENT ttEAsto- .NT PROGRAM j Cosianche Peak Unit 2 (Ten. ) - WELD tit 2TER . CLASS .IZE DATA TillCK H.T. I:. T. U.T. P.T. IIARDNESS VISUAL REllARKS Line/150 TW-2-RB-003 G-2 R t. " Accept N/A N/A Accept N/A N/A N/A Accept I- ,: fu-1 2 6" Accept N/A N/A Accept N/A N/A N/A Accept I I
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'! FW-2-RB-025 il-ll 8A 2 6* Accept N/A N/A Accept N/A N/A N/A Accept i;
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; 10A 2 6* Accept N/A N/A Accept Accept N/A N/A N/A [
,$ MS-2-RS-021 .l TM-1 2 32* Accept Accept Accept Accept N/A N/A N/A Accept j'. l V { MS-2-RS-024 j W-A 2 32* Accept Accept Accept Accept N/A N/A N/A Accept
- +
'I l ,.[ Cy(11) r Various Suppo Various Accept UT examination of Hilti- [1
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N/A N/A N/A N/A N/A N/A Accept bolts for length Aux 9 pj3,,, R1 dn /lini t 7 44 Anchor Bolts w I O y (12) Unit 2/ Aux. 81dg I Support Plate -- Various N/A N/A Accept N/A N/A N/A N/A Accept Elev 813 Room 204 ) Welds Room 195 : 3 1 5
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asis ni.. samm- - i 3dise:: Camrte 7 eat !serfal levier Tese lacert I 1 . Est!ssed is to !am:fal Reder Tees lesort eest multad fms se s twim amasced aring ce pe-fed of Isr:13-L1, L984 at ::e m Punt
- stta. De purpose af as twiw as ts:
- 1) enlan me carrut tasiment.
t!m of en asplicist's mangmat emersi of the mestrue:fe, impac:fe and ture programs, 2) ,irwide a innese murstanding ad infor=- mets in as E mangemst tem established by en Eme:r!n'reemrt for
- Oserstfans, and 3) aktain favorurtim seensary is stablish a mangm
, pla fer russistfe,of all asernading replatsry actims.
. 3e twfu isuseffted a maner of as:fon to be ?olfand by the imbricai 4-We iam saalismed ;wanst to me manaement plan. Additimally, three -
preertfal arternames as:fais are temettled dar ng tse rwim, ihasm ic: tans
. vill he rTferrad to De Amisistratar of legte i7 for aspreprian a I
The !ascial levier Taas famed during this 15ttad twier *at yerll man aartrol aver the cuatrus:!a, imanceta, and tarttag ;rsgrims is genro effec:.'re ad is rieriffnq presse ansagemst at:astfm. The lascial Xeriew Tem ennelmed that yer programs are teing ist?'ciertly cartrolled to
- vf 12e facility.tuttanas plast car:nct.'m mile the E ::ssicas its ruim t g di3 Ems 3mfvi$ B.2mid yes W any surtfans w.i cis rwim, a vill sincerely, ;
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- .tecuttye Summary and C:nclusi:n 4a sa xgr:unc .
eea aeview A:=r:aca " IV Review Fincings A. - Management Organi:a:1:n l..-gualt:yAssuranca/Cua11:yCente:1 D. ~ 5:ut: ment Turn:ver anc Prte: era:1:nal Testin9 1oc.rical j.-CesignAcfvities/C:ntrol
. " - ~w!vil installation v, ens: ve:1:nof Safety Ae14:ac Fluid syst'..is '.
3 4 - r:rma ' ten:11a: 1:n, anc Air Conc 1:foning Systams
," heatirf;at.
arviews wita CA/CC Ptetennel (General) l l
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s e i 3 ==. I. E(ECUTIVE SU*ARY NRR stra. in forsec rs c:cedinatten a team with
- :ne Direc ce of IE and :ne Region II & IV Ac=ini-Peak.
The cur:cse of tne review was of 1) avaluata the <:urrent immlem
- sicatas anc of me acclicant's management control cf the construc-ica, inspection,-
infomaticaprograms, ts the NRC2)new provide an indecth uncerstanding anc backgrcund sanagement Otett ce for Ocerations memorandum of Marchteam 12, 1984,esublished cy the Executive tion suncing necessary licansing to acticas. esualisa a management plan fer resclu 1cn of all cut-and 3) cauta in The team c=nsisted of eight reviewers, a team leader and : sam The manager reviewers and taas teacer were selectac from the Regica II s.aff. . The sanager was ce NRR C manene 7eak Projec- Director. in Regica II heaccuar.ars wnert it was oriefec by NRR, IE and ELO.The taam was assem The wasofc:acucted c:nsistac an auct: of itssignificant enview from Acril 3 to Acril 13, 1954 The review elemen s anc cr casses of the 4:011-unt's systems management imect.an to safety.cont These1 in construction, incluced: inspections anc tasting cf 1.
- 2. C enonent anc satarial receist inspection and control.
- 3. Str cturn, systems, and c:mconent fabrica:
Structure, 1cn anc insullation. testing. systas, anc c:mocnent accamunca, and proccerational 4. Quality itans 1 tarcugn assurance anc control documanution and procacures to effect itas 3 acave. The ;cnians of us system evaluatec inclucec piping , pice and c:mconen succens, tray suc;c ns, instr.:menutica c:m enent anc c:ntrol, electrical caole secaratica and caele areas. cualificasicas, and allecaticas nlating .a mesa The reviews als: inta-views with CA/CC, Occument C:ntrol,personnel. effer anc craftinclucac managemen; anc briefings frem The seul cocumen.a.ica was c:ncuctac wiu li :le er no acvance notica of, areas
.: te reviewec. persennel ce Eac memcer ;f :nis taam was cr.csan because he nac :::.. any years ex:eri-enca a wice in , rangece ciscisline cf nuclearna was reviewing, anc ne hac cerfcrmed evaluations at facilities.
forming Ois Ptview. The team s:ent The fellcwing is a list of un ever SCO neurs ser-special nyiew team
=emcers, ceir :csiticas, anc fielc of expertise:
3aul Eemis, Section Chief, Managemen- Criani: Training 2: ten, Cuali fica:1cn anc Eill Cr:ars, Senter Resicen:, Arte=eratica ent anc1,1:ar.u: Paul F sc Kim VanCoor:, Sonice Resican , MV4C and CC ins:ecter intarviews
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Al Ruff, Rean:r Ins:acu r, Electrical Vinsun Liu, Reacter *ns:scur, Cesign Ac:tyt:tes/C ntrolL:uis Jac Ec Girarc, Reacur Ins:ecter, 'nelcing anc Meullurgy Joseca Lenanan, Rea n :r Ins ecu r, Civil anc Structures
- ne teams fincings incicatec tha:
the anclicants management c:nte:1 over :ne unstruetten, inspectien, and recaiving procer management atten: ton. testing pr: grams is generally effecive and is
- stential enforcament actions (See Sections Tne fincings identi fied these 3&2);
esquiring Acclicants management attention; (See See:two areas of weanness wnere See: tens Acclicants A, 5 & E). ac tvities exceeded normal and accanted prac: tee (See1on 3
- etween == cur int CA/0C nemanagement team tiso found imer=vements in Me relationshio causec c:=munication :r:clems (See See:and ins ect rs wnich in the :as: has tsults sanner. of this limiuc rev1w reveal 1cn I). Tne
- ne plant team believes tha: :na is being built in a safe nec:nstruec
- e fincings as ancresolving enclusicas any of of this re: ort of we teams review snoulc ac:
nearings, allegaticas, Or ne issues icentified by :ne ASLS alant. suff c ncarns of the casign adecuacy of the II. Sackgrounc Cn licensing March 17,1S34, cecistens the EChak f r C:manene cirsced NRR to manage all NRC actions lea and Water':rd. The purpose is u
- ry ac:1:ns anc acnieving unir resolutica price u a licans Tnis tiens issues. eff:r. is = enc:= ass all licensing," hearing, ins:ec ten anc ega-all Seca cert was certattar, a netc =e :: newly esuolished Cemanene Peak pr:
Onti: 1 Of Oe c:nstruni:n,1) =uin cut tat information -elative Ject team fcunc =at to me management ins ecian anc test inf:mation necessary to esunlish a sanagement pian f;r: grams anc 2) ccuin
- utsuncing licensing ac-icas. :r resolutten of all anc Ocjectively 1
- lans was necassary.was cacicec cat an unannouncac riview of C Regica !! anc IV Ac=inistraurs fermac a review taamAs a c:nsecuence, NRR itmiutiens in Region IV, ue .
aam was suffed Because of resourca , Tne team was was':rtefec assesclec in Regien II Heaccuanars en1954 ca significan: Acril 2wiu Regten II :ersonn Ptview, ne aam
=e hearing =ntanttens anc =a allegations.1ssues rsisec as a unsecuenca c e tviewers were 30: Tne taas leacar anc assure sneir c:aficantiaitty.:r.vicec wie me names of we aliegers in cecar u u Acril II, l~34 The team c:ncuctac :neir review f em Acril S 99 gwme wM*'*
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/ III. Review A::reaca The teams' review accreacn was :s first cetata an understancing of Comanene Peak management and management c:ntrol systams.
i briefing from ce A:plicants management. This was ac::m:lisnec by With this uncerstancing, the team reviewers c:mmenced their effer.s. These included examination of aspeceriate dccumentation, formal and informal intarviews of plan c eir areas. =ers=enel, and specific technical allegattens related :s in me tsul The allegaticas were not reviewee separately but wert suesumec review in orter to provide fur.her cenficentiality and not. c=marcaise any on going or future investigations. assuranc In addition :s :ne nytew of the Quality Assuranca.oregram, frem a =rogram-satic =cin: of view, each of the riviewers examinec the inclemenutica of icentify any treakccwns sna csuld exist in a narrow area.:ne CA IV Review Fincings The team c:ncuc ed its review of the following areas: A. - Management Criani:ation r E. - Quality Assuranca/ Quality Centrol
\ C. -- Equi;
- 0. ment Turnover anc Precoerational Testing Electrical E. - Casign Activities / Control F. - Installation of Safety Related luid Systems G. - Civil Constraction H. - Heating, Ven:11atica, and Air Cenci:
I. - Permal Intarviews with CA/CC Personnel 1cning Sysums Tne review, telcw: fincings anc c:nclusions in eacn of these areas are pr videc A. Management Crgani:ation Tne c:nstracti:n worting eslati:nsnig anc enerations criani:ation were reviewe wi: Min between :ne organi:ations as well as func-icnal elati:nsat:s eaca cesant:atien. incivicuals in :cstticas of auncrity wert Ftviewec againstTne regulat cualifica: ry ten suncares anc :ne aanlicant's c:mminants. tiens, a=ain.
- .w.anc review was mace of the interfaca to: ween all levels of theIn ac T9e a:: tarlimitac
- = meetetview rtvealed that in all anas, incivicual cualifi:stiens recuirements,
- erati:ns a:: ears :: =e interface to ween ::nstractica anc between all levels :f :ne management:e functiening in a wortacle manner anc in i
n an ac:::n:le canner. Tners accears to have been a c:=municatienena j _ ,,_. - _ . _ e .yp qqK ,,,,n, .w _. w v ~ F
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- nis review i c:r e::ac. the pr:Olem nas anc is :etag i '
This review found the management and craft at C:manene Deak accear :: . be ::m:etent anc management :: :essass a positive attituce wnten is a ' strengu at mis cr: Ject. Managemen exhibited a sufficien: level of . c:nsciousness f r :otn safety and emnicyee c:ncarns. These managemen-a tituces were c:nfirmec by :ne attitudes they manifestad in :neir ( emelayees anc :ne a: tan:1cn := catail in the requirse quality of werx, S. Qualt:y Assurance /Cuality Cente:1 - Tne of f=11owing areas were reviewed primarily from a programma-t: point view: acility anc none:nformance retr'evanility c:ntr:1; training, audits; ete:rcs (mainuin-handling of matarials; anc )=r;ecurement. c:ntrol; receipt, s rage anc cccument W12in :ne areas reviewed, cert were several fincings icentifiec. Tne f=11cwing is a brief cascription cf eacn ac::rcing := catagory:
- 1. pesantial inf:rearnen: Issues. ~
a) ASME firt proof ree:rd packages were not being mainuined in a
- nutner.
b) At .least two vencer aucits had not been perd ersec witnin the escuired time pericd.
- 2. Weaknessas a)
Car.ai n drawing pacy. ages issued to the fiele c:ntainec non a::licante CCAs anc/or CMCs, whien hac :een cele:ac ty engineering.
- ) Many ncn-ASME See:
1:n 3 crawings c:ntainec a large nu==er of CCA's anc CMC's
- sing inc:r;cratac by tvisien. (over 300 in same cases) Outsuncing witacut
- 3. 1 rtngus i a)
Tne CA/CC trainirg pr: gram is exiansive anc c:mertnensive. i
- )
The use of a escan-ly assas11snec ::=cutar systam crawing
- nt si
=anges.
instaac of sum:ec crawings ref erencing :asign
- ) Tne vencer wi nessing r: gram is ex:ansive in its aucits and scurta ins:ec-1:n of Our=asac matarials
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1 :) The acility :: ex:editicusly Iccata and retrieve esecres, f j wi= ut ;rt:r nc f ca, fr:m permanent rec:rcs vault. 1 i Overall the current CA/CC pr: gram accears to be fune:1cning sati sf acterily.
! The recant management enanges seems to have
- 4 c:r sc ac past c mmunicatica preolems. ,
C. Ecui: men: Turncver and Pnc=erational Testing The = recesses Of turnover of safety related ecutement fr:m c:nstruction r to star.us as well as pre-requisita and art-ocerational tests of the equi; ment were reviewed ta datarsine adecuacy of: methcdology employed in :urnover of ecut; ment to s.artuc, rtturn ecuf; ment := c:nstruction for etwors., and ultimate. release of ecut ment .c c eratiens; tecnnical
; anc acministrative c:ntreis over proccar;ational tasting; anc recaera-1cnal tas:
c:nt==1. precacurts, teth taennical c:ntant and acministrative t This review fcunc the majcrity of the tasts to be :erformed are estas:s 1 cr encerfem's ini-tal tast. Theand, c uld be c:nduc:ac in parallei with the remaining
- erd an Cc= er 1984, fuel Icac casa.ermance of the remaining tast should not immac:
( anc c:ntr:1 of the proccarational test pr: gram a omars adequata.In acc j 0. Electrical The assessment i in this area was to desarmine accac: ability of the I safety relatac electrical ecuicment ins.allec anc ins ectac in ac: rc-anca f thewieverall
.a NRC pr:recuirement anc a: licant c:mmitments.A review was mace gram u incluce:
=nt :1 ins:ections, and nc:rcs. crawings, pr:cacurts, quality j
The etview f:unc tha iasul1oc anc inspec:ac as escuired.:ne safety-relatac elec rical ecui: ment is being i' E. Cesign Activities /C:ntrol i Ms Ptview f:cusec en :ne follcwing areas: e== n-la: A1:arnata Analysis for small tertneut rements of IE3 79-02;
- 1:ing systam, riger us analysis f:r safety relatec 1;teg systams; etview =f casign calcula- ,
I
- 1cns fer :i;e su :cets; review of stress analysis for stoing systems; 3
fiele innecti:n anc verifica:1cn; anc the itart:1ve cesign ;c:cass . A M an~.ial enf rcamen su::cP s weien Sac cets ac:ica 13 was icantt fitc in :na cartain 01:e ins:ec:ac anc acca::ac wert not installec fitc acOrcanca wi u casign crsuings. There was also a strong,n igen: 1
, in ca: Oe Onsiderati:ns a:01fcant in many artas ofwas f:uncanc design :: have usac Onsarvative analysis !ce te saft y
, s tiatac :1:ing systams anc ;1:e suc:cris.
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- =ee: c:nclucee :na: :ne casign :r: gram and its im:lemenutien d i er excesc recuirements, excact as n::ac accve.
',- F.
Insullatt:n of Safe:y Related Fluid Systams i i The review of this ana was cirectec ::vares assessing the acecuacy of -
~
insullation anc shute:wn of of safety estatec fluid systems used for safe coeration the plant. ' tica of systems by me reviewer; This review c:nuined: examining first hanc c:ntrol of ceserva-satarials; examination of piping supcor.s, welds anc ete:rcs.welcing The reviewers c:ncluded that the applicants program appears to assurt c:mcitance wf:3 requirements, i practica. commitments anc goed engineering 3.
. Civil Constraction Activities Exa. tina:
1:n of sita civil design activities, including design =ange precass, =recacurts anc QA ete:rcs of c:meleted work activities (sucn as me SSI dam, cacle tray supper.s and wnip and moment etstraints), anc pr:cecures anc woric, activities for ongoing worx, (such as acpitca-tica of protective coating) was performed. q The in these limited tview fcund uat the acclicant was see ing recuirements areas.
; Two areas of nota: (1) protac-ive coatings anc (2) therso lag, accear :s be progressing in a ? manner such tha: :ney will not iscact an Ccu cer fuel 1 cad.
H. HVAC This effers felicwec un on previcusly identi fied Comanene peak anc ciner sites wnich usac the HVAC vencer.ciscre=ancies at is have accressed the preoles either througnTherework e HVAC systam accears :n :e acequata. . I. Formal Intarviews with CA/CC Perscnnel ' Fermal intarvi ews twenty sign (23) of five (5). management /su:ertisery ;ertennel anc i assassing quality of wort ins:ect:rs were c:ncucted u assis :ne tatm ir '
; felt anc sanagegent su::cr of :ualt:y. It was ; insignciscussicas wiu inscoc ten personnel would give a c:nservative int:
- ne quality of sita c:nstraciten.
The personnel majcrhac inras; any cf me intarviews was := ce aem ne if; (1) :ne
- lant safety ce cuality c:ncarns; (2) intimica:1cn
, , was ex:eriencec: freely ulk u NRC; (5) management (3) training was acecuata; (1) ins:act:rs c:uic i (6) was nert fete:acx en icentifiac ;r: lem evalua:1cn.su=:cetac =r:cles icentificatt:n; 7~ yv7K~~~ i? Y- - ' - ~ ~ ' ' ~ ~ ~
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; Wita :ne exca::ica of two f asceq.:rs wne were "unsurt' cue :; lacx of kn:wlec;e, all :ersonnel inta-viewec fel: the plant was being :uti: in
; a safety anc cualit will be femarcee ::y =anner. Tners were s:me c:ncerns raisec wnien in some cases, Regica :neIVC:manch Peak P-eject Otract:r f r evaluatten:
was alreacy Per#ceming fc11cwuo. aware of the c:ncerns and Tne major preoles in :ne past appears to have . been c:mmunication between ins:ectors and their sucervision, but 1 is
; accarent that for the is being accressed prpas c:u=le of months and presently, this preciam perly.
j In acdition to formal interviews , each reviewer performec numerous informal triterviews to cetermine problem areas. The overall conclusien j fr:m all interviews was that the Comanche Peak Project is being buti: safely anc with quality. V. Conclusien he :ursese of i assessmen ne s ecial team review has been me in :nat (1) an
, . of :ne a:alicant's current management c:nzr:1 of :ne
?
- nstrue:f=n, inssecti n anc tes: pregrams nas been mace; (2) an in desta uncerstancing has coen acnievec and (3) information has been octainec :s licensing Outstanding es-ablish a management plan for the resolution of all actions.
3 d With res ec . :: the assessment of the anglicant's management c=ntrol of the esnstruction, inspecticn and testing programs, ne special review team has cetermined that based on the nuscer and significance of the strengths vs weaknesses icentified in this review, that the accif canz's
;regrams are being sufficiently contrelied to allow c:ntinuec clant
- nstruc.icn
- ne facility. wnfle the NRC ::moletes its review and inscacticn of urtner, anc ne review previced a sufficient netr , strength anc weakness := assistunders'.anding of these =r:grsms
.:manene tax Plan for in the develesment of :ne This plan was as reved for innlementatica en June 5,1984Me C:. cletien of 1 .
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- 1. Entrance Meeting Tne afterne:n of ApM13 the special review team arm ved cnsite .-
unanncuncec. The team scent the afte-neen of Acril 3 anc :ne morning D of A MI ath meestag with the applicant's Senior Cormorate Management,
, Site Management, Site CA Management, and Occumen- Centrol Sume-vision .
being 3Mefed en the cegani:ation, functions, and locatica of areas uncer : heir :=:rol. I 2. Managemen: Organi:ation i
,! The nuclear cr ten of Texas Utilities Generating C s any is cegani:ed i in ne following manner for its senior management: ;
{ a)
, The highest level executive is ne Presican of ue :: meany,. The t Presicant has recen.ly turnec over all :ossible non-nuclear cuties 3
- s his Executive Vice Presican -clan: Onerations. Tne Presicant's Maary res:casibility is :s c:molete me C: marche Peak Steam Elec: Mc Station as safely anc expecitiously as passible.
b) Re orting dirtctly u ce President are tne Execut.tve Vice Presicent Engineering 1 s Ocerations. anc Csnstructica and the Vice President
~)
built in the system anc the licensing organt:stica resorts Executive V.P. Engineering and Constructica he scenes between 50-80 of his time at the Comanene Peak Site. He has also colegated his aca-nuclear resconsibilities in an eff=r. :s focus en =e CPS.) (V.P. nuclearsconcss.ationamorex:imately
'c mulation. TheEC% Vice Presican--0:erations of his availacle time on cirec-ly coserving the oce?ations gr um pre:aratica s uke over ce alan: usan 0:nstrue:1en c: mole:1en. He is also an actiye partici: ant in c:nstractica anc star.u: seetings anc :ne decision making Or cess.
A few manus ago -us V.P. CPS was movec frem his ace" recer.ingJai repor.ing pa.h u Execu ive V.P.-Plant ccera 1cas, cirec .ly
- the Presicent. '
) i Rescr ing to the Execu ite Vice P esiden: Engineerin and ;
- nstra::1:n is the Vice P esicant Engineer:ng anc ' ens:graction !
Isite V. since P . E.LC. ) . The V.P.ELC. nas teen locatec en me C 1977 and duMag us same year ne assumec c:manene Pean ti:1e :f 3:Jec- General Manager !=r C: man =e Peak. e actitional ' in
'anuar/ .534 he colegatec nis non nucitar res ensibilitfes in <
- rter u cavete nis full a. entien :: C: man =a Pean :==letica. !
- ) he Assisun- P :
V.P.ELC anc ne V.P. CPS.Jec; General Manager (APGM) rece-.s u ec h :ne Of unstrae:1:n He re er.s :: =e V.P.ELC. in =e areas sursus (5/U). This anc ensita engineering anc = =a V.c.0Ps f=r csitien is wnere :na 0 mmen sie :eceeen i _ - _ . -- . . _ . _ . . . . , _ _ . _ . _ ~ - - - - 7 ~~ - - ~ P T"~ 1E i.-- -,
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! l i c:nstruc.jert and :eraticas is most cecisiva. The APGM has been en site since 197'/. e) ! i In aeditten to the APGM, the V.P.0PS has reecr.ing := him: The t manager of Nuclear Gnora: Manager of Quality Assurance wna1cns, who is locatec at :ne site, and the .. is located in ths c:rporate j office but has a Quality Assurance / Quality Centeel Manager on site
> wna is ressonsible for all QA/QC on site.
j The curnnt positive management attitude is a strength exnibited at Comancae Peak from both the coerations and the engineering and construc-ion sides of the company. This positive attituce appears
- s manifests anc itself in theforattitudes in its consciousness quali:y. of the workers, the training, j Cne acdittenal strength was noted in tha c erations' maintenance crocacures *c perd the acclicant is ustng i
I equi: men: in the clant, and :n= anclicant em :ericcic maintenance on
> anc rescira:ces for we craft (for : raining)is using :: perform full Anti-C maintenance crossou: ! ac.1vities so wnen the acuisment, cec mes cen .aminated the wors. ors will be use to the esafining clothes and equipment.
This 3rac 1ce should significantly recuce exposure and therefore cese received by these incivicuals after =e plant is opera:1onal.
- 3. Project Management Meeting
.) .
tvery Saturday morning a project management meeting is held , wherein cwort verage activities, pr:gress, star up anc test preolems, and QA/QC is discussec. Management; including This meeting is a:.anced by Senice Corscrate Comnany, anc c e Senior management ue P esicent of Texas Utili:1es Generating , is also attencec by me site management of construc-ion .uc. anc star-from c Several 1984 Themes=ers meetingofa:-he review eared u beteam well attenced this meeting en Acril 7 managec, viu pr clem areas, being ::enly won in attendance ciscussac (even though senior =mcany manage: ment anc NRC su:ervisors was no , tened the dialogue down . between incividual managers and wnica was discussac was ceAnc:me)letion
=atings in me c:ntainment.
examole of an efana
=ecfa=licati c:ncarn n f pr::ac-i It was :ne general c:nsensus ca:
ac:itional mancewer was nouirec :s =muleta me wert effer..An be ava11Lble wiuin one week.accittenal 100 peente were au= ri:ac wie ce i During this meeting it was cecicac = =ange me c:cca:: =a was
- nsently :ef ag usec f:r plant c: mule-icn. The a=l i can- na using a Suilcing =moletica mececology, :ut aftar :een reviews :y an acxnewlecgec incus- y ex:er. is -as cecicec ::
ensulta-fen anc systems Omulati:n, wita :uilcings to felicw, er run in :arallel ,,nen Orieri-1:e
;cssi:le .
e
, ,e s ee-w*- --*2P*-- _ .,,..,.3g-e w-
.- - . .. .. . . ._- _ .- . . ~ ' ' + " ' _*_ _~ - ,.
.k o- .
. . . . . . . a. a - . . =
-r---~.. - .
3 D
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The highest level of the Comcany's management in attendance at nts
.o meeting pricritiesalicws for i=meciate cecisions to te mace for the next weeks for plant ecmoletten. This methcc of helcing pecject meetings accears to projectec fuel lead dace. have kept the acclicant in positten to meet :nei r
- 3. Quality Assurance /Cuality Centrol l 1. Nonconfersance Centrol
References:
CP-CAP-16.1, R20, Control of Nonconfoming Items
; CP-QP-16.0, R13, Nonconfermances
' CP-QP-16.1, RS, Significant Construe:1cn
, Ceficiencies
; CP-CP-17.0, R3, Corrective Action CP-QP-15.7, R2, Tracking of Audit Recer.s/Correc-tive Actica Recer.s
- a. General i This scr.ica of the review was performed to veM fy taat:
\ -
nonconformances are being identified *
- items were consicered for recer.acility to NRC
- corrective action preventec recurrence
} the licensee has an adequate trencing program
- 5. Review Effer.
The reviewer verify selec ed NCRs f em varicus safety relatec systems to ne following: Icggec numerically for con rel
- maintainec even wnen later cancelled
- consicered for reper.acility to NRC
- cor?te-ive action initiated wnica preven ac recurrence .
consicerec in a trencing program The felicwing NCRs were reviewed: C-34-01030 M-B3-31152, R2 M-34-00965 M-1157F.N M-!?-01522, R2 M-1156CN
. M-53-01454, R1 H 11575N M-04729, R1 M-115E7N M-05559 RO E-34-31031 M-352?a, R1 M-0153EH !
M-09765 M-01592 ! M-09756 M-09B123, R1 i l
,,_,,pp.-,, pN6' '"Yt 4h*' * , , ,payanc.+-- """M*f?' '
. . . . _ . _ _ . -s- -
- - - -. , e -
.-._ m_ _. _ . _ . - __
N--- - A - -' 4 The restensibility for closing NCR M-09812 5, R1, has been
; ransferrec :: TUGC0 startu: :ecause these Westingneuse valves are :
recuirac are :: to be disasseccled curing system flushing. The valves Valve ce reassemclec stroke time testing uncer a startum of these valvesworkwill beautneri:atien verified uncar (SWA). the S'n'A. , we t recuired Tne relief valves listed en NCRs M-05765 anc M-09755 - { to be reset because the venece had nct been 4 furnisnec the c:rrect back pressure informaticn to set the valves.
- c. Conclusten The limited review found that nonconfermances were being written
' j wnen
- na icentified, the items were c:nsicerad for rt:cr.acility ic NRC, j anc items c:r tetive wert action ceing trancec. to ;rtvent recurrence was being initiated, 2.
Quality Assurance /Cuality Con:rcl Training
References:
CF-CAP-2.1, R10, Ptesennel Training an Qual i fica-tien i QI-0AP-Z.1-1, RS , Nondestructive Examina:1cn .:ersonnel i QI-0AP-2.1-5, R5, Certification
! Training and Cer:ffication of
- Mechanical Inscoction Personnel s s
- a. General :
j The licensee ;urposehas: cf :nis part of the review was to verify that the a fersal training program
- c ncucrec recuired training to qualify personnel
- recuirements for an~:ne-jcc training
- c:jective evidence of personnel cualifica-icns Orior := certificationevaluated the cancicate's ecucarica, ex;erien
- etevaluatec persennel en a mericcic basis rec:rcs of personnel cualificaticns
- 5. Review Eff:r.
A tview was mace ef the c cuments 1isted aceve, anc :ne reviswer neld discussicns verify na with res:ensible c:r; crate anc site :ers:nnel :: prececures arti c:nsis en with qquia..ry ments. tcutre-UI-I*-3-3, ET-II-3-3, anc MT-II-3-F;A Ptview was e. ace Of Gene , MT-II-:-CA and T-I -F-07 aise Practical Examina:1cns
- mee These examina: ices c:nfi- ee ne :ss:s rec:r s :ne recuirements Of ASNT-TC-1A, Rec:m encec :ractice. The cantainedof seven CC ins:ec crs were reviewec. The ete r:s j
- jec-ive evicence of CC ins:ectors cualificaticns Oy !
i i l
-_ --- ~rge{ *Fu , _ . . , _ _ * * * " ~ ' '
r - '"
_ . . _ . . . ~ ~ ~ ~ ~ "~ ~ ~ ~ ~ ~ ~ ~ ~ _ 5 i m r central anc =ractical examina:fcn, on-the-jec raining, classrecm, 5:eciali:ec training, ecuca:icn, anc work ex:erience rec rds were available := c:nfim CC ins:ectors meet ene recui rements of ASNT-TC-1A and ANSI Na5.2.5-1978. C nfirmation of annual documented evalua tens of qualifications of inspectors was veri fi ed. ~
- c. Conclusica The training recuirements for CA/QC personnel listec in tne j prececures anpear :s be complete. When personnel were ques .icned as to ce training tasy were actually receiving, they c nfirmec the depth of training which the precacures required.
- 3. Aucits
References:
QI-CAP-2.1-4 CQI-C3-4.5, R6, Aucit rs Certifica-ica Concuct of Internal, Prime anc Succ:nzrac:ce Audits
- a. Genera,1 The TUGCC CA audi program is based en FSAR See:1cn 17.1.2 which I accresses ANSI N45.2.12, Oraft 3, Rev. O. TUGCC Corporata Office is res casible for audits both internal and external. The aucits spannet ' contractors, engineering, construc:fon and corpora:e.
Aucits are listed in five areas, Site Construciton/ Engineering /' Quality Control, Operations /Startup, Vencor, Pre-awarc Surveys, and Vendor Surveillance. Audits seneculed in ce five areas were 107,153, anc 30 curing 1382, 1983, and 1984, res:ectively.
- 2. Review Effer A review was made of ce licensee's isolemented aucit program :s verify wnether 1: meets the recui rements of the accactec CA ;
Pr: gram anc ANSI Na5.2.12 (Oraf 3 Revisten 0 - 1972) as enecrsed by sne CA Program. ! assec s of ee acci , program: The reviewer also verifiec :ne f=11cwing l The se:ce of ce aucit =r: gram has :een cefinec anc is
- nsistent wita FSAR c:mrsi:nents
. Res:cnsibilities nave ::een as'si gnec in wri ting for :ne overall management of Me auci pr: gram Hecocs have been definec fer tax,ing c:- sc-ive ac ,1:n wnen ceficiencies are icentifisc curing aucits i The aucitec aucit fincingsc Tani:ation is escuirec to rescene in writing :
d
, , , w e ,epp - H **7 f *'* W *'*'#~~
f lt S '
__,'......~. ~ ~ - - - - - - - " - ~ ~~'
~ ~ ~ ' ~ ~~ . . _ _ . _ _ . ._ua-5
\ m
- ? -
~
Distributica recuirements f:r audit re: r.s anc ::rrective
""Teiten res;cnses nave seen cefinec Checklists are recuired c be used in :ne perfemance of auc1:s
- The reviewer selected audits TFC 40, 43, 56, 57, 61, 69, 70, anc
; TUG 22 performed during 1982 and'1983 fer review. The audits were ; preslanned to enver specific functions and were c:ssrenensive.
The reviewer notec that some audits had not oeen districutec in accorcance with ANSI N45.2.12-1977; however, proper corrective action had been taken by CA audt: suoervision and was cocumented by memorancum dated August 16, 1983. Sucsequent re: cess were di stributed in a timely manner. program is ciscussac in paragracn B.7. Review of the vencer audit i The recorcs of four lead aucitors and :no auci:ces were reviewed. The cualificaticas of auditors and lead audit:rs were verifiec :s be in ace:rcance wita the recuirements. of ANSI N45.2.23-1978. C nfimation of annual cocumented evaluations of qualifications of aucit:Ps were verified.
- c. Conclusion As a result of this limited review, the ruiewer concluded tha TUGC3 Car: orate Management, site QJ /0C, and engineering auct:
activities are accentamie. 1 Recorcs
References:
(a) C7-CP-13.2, R2, Imolementatica of sne Femanen: Plant Rec:rcs Management System 3 ' (b) C7-07-13.3, R2, Pemanen: Plan: Rec:rcs System Organi:ation (:) C7-GP-13.4, R2,
- Femanen: Plan: Rec rcs Recnic Centrol anc 5:: cage (d) C7-07-13.5, R2, Au :matic Racerts Macagemen:
. System Immle.ientasien
(*) C.-07-13.5, RC, i Rec:r. Turnover := UGC3 C:eraticas Grouc (f) CP-07-13.7, RO, N-5 anc N-3 C:ce Ca:4 Recer.s (;) CF-07-13.3, R1, Rec:rcs Verification . 3 i
_m_~._, . . _ _ _ _ - . _ . _ _____ -
,7 l .
, , 7 t t . (h) CP-0AP-11.1. R3, "abricaticn and Installa icn Ins:ection of Cem:enents, Ccmcanents su:por:s, anc
, Piping (1) CP-QAP-16.1, R20, Centeci of Ncnconforming
- b i Items i
(f) CP-CAP-12.1, RS, Insnection Criteria and
. Occumentation Recuirements Prior to System N-5 i Certif! cation i (k) CP-CAP-18.1, R2, Pr: cessing CA Rec:rds (1) CP-CAP-18.2, Ra, CA Review of ASME III Occumen.a:1cn
- a. General The cuality assurance recorcs program is based on PSAR Section IA
! (3) which acdresses ANSI N45.2.9 (Draft 1, Rev. O,1973) for the - cesign and constructica of Comsnche Peak. The .stte reccres 1 program is managed uncer the enntrol of.the Site CA Manager. The Permanen: Plant Records Vault (PWRV) houses most of tne c'esign and canstrue:1on perdermed. records for comolated work and have had final review of the operations Ccmoleted records are being turned over to the control receres control system on a regular basis. Temocrary storage of records is also :ngoing at several working 1cca:1:ns at the site utili:ing one-neur firecreef cacinets. Rec:rcs, wnere possible, are filec, by system anc c:m:enent. Tne i PPRV rec r:s fireuses smote catec.srs protection; tiedadjacent a water hose into tne site fire station for
- s the main PPRV door provicesinfire ex.inguisners *heextinguishing area. ca acility, as cc par.acle fire A c:2: uter is used to af c rec:rc retrievacili y, .
essential, as rec:rcs are maintainec in haec c::y. but is not Recorcs flew is na an A3ME78RV =a:n.thr:ugn toth a regular sita ::nstruction/CC =a:n and
- 3. Review Eff:r:
A review was cace of varicus Or:cicures :: verify tha : visions nac
- nat :een mace tc maintain varicus ty:e= Of cuality rec:rcs, anc s:cragerescensibilities nac teen assignec to car y cu :ne records re:utrements. Rec:rcs st rage ;tecactres were 41sc reviewec ::
filing sytismsensura :nat ney cascritec :ne s:Orace facilities, the Of ne rec:rcs.usec, meinecs of recti:t, anc handifng anc ciscosal The Erewn anc Rect (3&R) ;r: grim f:r flow of A3ME wen 9A+ Y ? _ .,.. - ,- -.- -- ~ ~ ~ '
}
, := =n" * * # ^ ~ ~
i .
. l S
t - J Sec-1:n !!! records :: ue P:RV was reviewed. verifisc retrievacility of racercs from ne P:RV.Tne reviewer also To verify general rec:re retrievability, the reviewer selectec several general c:nstrue:f on and insnection packages such as weic ,- casa, c=ncrete placements, ecuipment packages, and equipment travelers. 4 78RV. All records were retrieved in a snort period from the Curing the review, other records were retrieved of specific design /censtruction/inscection activities. No significant
- i difficulties were identified the records retrievacility system. curing these real-time ena'lenges to locate and retrieve records is identified as a streneta.Tne This ability to ex ability appears sa be primarily due to indexing anc s : rage of
! recordstype.
rec:r: by component er material, wnen oossible, insteac of by To review ne B&R ASME rec r s flow, the receres associated with safety injection isometric SI-2-RE-12-a; Core Soray C5-1-53-032; Chemical anc Volume C:ntrol CT-1-SE-14; C enonent Cooling CC-I-55-042; Baron Recycle ER-1-58-05 Spool 103; 3R-1-55-004 Scool 1Q3, BR-1-58-006, and Main Steam MS-1-58-050 .were reviewed. These recares contained the insnacter's identification, the type of inspections the ac:entability, acoraval, anc w,on reactly retrievacle. verification of eview and j installed in the field were recordedHeat curing nuncers on sa:erials a sita : ur. , i Certi fied Materials Test Reger.s (CMTR) were recuested and furnishec curing tas wnich tour. verified traceability for those items recarced . Also CMTRs verifiec := meet ASME coce re,cuirements.for selected sucassencif es were Review of ree:r:s for ce sucassemslies listed above c:nfirmec tha: Design Change
- Autneri
- a-tons incorporated (CCAs) anc Comoonent Moci fica .icns (CMCs) were ,
stame :etng analied into the ts as-cuilt systems.drawings crier s == ASME coce , a=oroval and turnover feca S&R, This program of recares review, ' ce ASME "N" s.amn holder, to TUGC3 accears to b work ;erfcesance :e very thercugn, incugh c:molex. Recarcs for y B&R are assemeled, reviewed, anc accreved, men sucatttec review, :nen su mitted :: the Auceri:ec
.o TUGCCNuclear for filing. Ins:ector (ANI) fr c:merised cf E&R A task fer:e !
tasse rte:r:s. Anyanc TUGC0 personnel, then make anctner eview cf discrocan ! E&R anc TJGCO. Tnese rec:r:: are cies then noted are een red labeled, ancresolvec can net between be ! i
, 2eracy, preventing loss of CA nc:r:s.recevec frem de vault w1:nc A
, review was mace of the tamcorary s:crage of nc:r:s in ce fi eld. Alta:ugn rec - s are bes: s::Page in acecLtate fin pr of ca:iness Orc:actac in un 7:RV, rec:r: is all:we: rec:r: asec :n =e
- ases fires:Orage acut: ment cualificatica in NF:A No. 132-1975, wnica Ai ucugn :nearetec-1:n enviewer cic ennet exterice fire leae :alculations.
- enecx, any fire leac calculations i
.m -,
'
- _ . -._____ .- ; _ , _ _ . ,_ .. - - - - -.- - ,- ; 7 - _ _ . ,
t
'O o
9 w Jus:t*ying the use of ene-hour fire cacinets, incse caciness
- se vec a::tarec :: be acecuately =r::actac. During :nis review, na c:se vation was made snat several c:meletec ASME moment es: aint rec:rc =ackages being maintaf ned in a non-firecreof ca:ine in :ne ASME Safeguares Euticing QC trailer. This failure s::re :uality assurance ree:res in a firecreof caminet is a *
=csee ial enf: tement issue. Prior to conclusion of the review, .
nese receres were relecated to fire:rsof cacinets. Based on the
, aseve Orcelem, the reviewer noted some c:nfusion at the site en
- ne c:n:rel of "cocumen s" as iney progress thr ugs cesign/c:n-s uction/GC and as to when they became "recorcs." This was i evicen as little distinetten appearec to be made for the s:crage of "decuments" or "reeneds" in the field. Working " documents" wert :revided scual to or better =rotectica : nan " rec:rcs" in some instances.
Ortelem wasOtner icenti: fied. Man the examnle stated, ne etner s:crage Comanene Peak hac estaclisned, en Mar:n 30, 1584, recares monitoring teams to review the rec:-cs flew Or: gram. The clarification of ne c=cument/ rec:rcs in arface f:e st: rage m: niter teams. centrol is a weatness anc 1s to be accressec ey the This weakness is consicerec ;sr. Of the Potential enf: comen- issue accressac above. 2 . The :nysical c:nstrue:fon of the PPRV was reviewed. tien of the PCRV is satisfac.ory for pr tec.ica: fromThe camage. c:ns: uc-exterior fire For insico originated fire camage, the P8RV has a fire cesec-ica system but does not have the incustry stancard water er haica automa:1c fire suppression system. The system for unattencac PPRV firs control .was reviewed. Wita the fire detec-tien alarms annunciating in the close-cy fire station, the fire stati:n erscnnel having ready access
=f a fire hcse reel cuisica the P8RV coor, the PCRV anc the lccation
^ a:: ears acecuate. Verification was mace nane fire protec-ten the operations vault, ints wnten all the PORV receres will :s transferrec, c:ntains an au::matic fire suppression system.
- c. Cenclust:n t 1
The rec:rcs wita suicient c:ntrol of the PPRV a : ears to meet all recuirements, staff := c:ntrol the ac f vi y. Rec res ficw :=
- ne 374V tien. neecs clarification, but a : ears acecuate in im=lementa-c:eration. Receres :ersonnel a :earec kncwlecgeacle as to PCRV S. CcCum9n: COntr:I
, Refe ences: (a) CCP-3, R17, CPSE3 Cecu=en: C n:r:1 (t) CET-12, RO, CCC/ Task For:e Inarf ace i J 9,-.eWF"'**** p-p pc ,,we
.-' i- -
- - - -,-----u -y.-nn,,n,w -=-~~enn-ns--v---------r,- =- - - -
i I. *
~~
10 4
- a. General Controlled documents, primarily crawings, scacift'ations, c anc procedures are maintainec and centrolled by the site Occument Control Center (CCC). The predominance of document centrol within the schen those of the CCC relates to crawing c:ntrol and enanges to drawings.
The OCC has established satellite cocument control documents. centers which control and distribute most of the working crafts anc the Unit 1 Taskprovide These satellites controlled cccument cocies .o Force Paper Flow Groues (7:G). Centrolled documents- and changes are previced := the satellites from the - OCC. The OCC also pnvides controlled documents to several " controlled nuscer recipients" dinctly. The PFG provides c:ntrolled cocuments to craft working in that scocific building task force. Revisions to controlled crawings and documents that affect conte:lloc drawings, (CCAs) or component modification cards (CMCssuch as design change a receipt to tne satellites and controllac num)cer arerecipients. distributec unen For drawings, a ccacuter system keens track of drawings and the CCAs and CMCs that affect those dfawings. revisions, CCAs, or CMCs are generated tne c:mouter is uncated.Wh i When the satellites nceive a new drawing revision, CMC or DCA, any controlled crawings checked out to the crafts or under the l - control of the PPG are updated by the satellite CCC personnel. This maintains current the controlled drawings in use ey insuring that drawing CCAs and CMCs.packages emntain the correct revision with amplicaele directly feca the Orawings checked out to the craft from the PPGs or working day. satellites are returned at t.'le end of the Prior to checking out drawings from a satellite directly to the craft, a computer run is mace = insure that CMCs and CCAs. drawing packages c:ntain the appropriate revision anc acc tne satellite or PFG, a drawing, CMC and DCA eneckWhen cra performed to verify return of the controlled cocuments. is again .
- 5. Review Effort A review wasofmade of the references listec to verify taey met the recuirements l
verifiec that ne accepted QA Program. .The reviewer also acministrative controls nave teen asuhlisnec 'er tne c:ntrol of crawings and that incices are mainuined for
, crawings, cur manuals, soecifications, anc pr cacuns whica indicate ent revisiens.
In orcer to verify tne c:ntrol of crawings, the nviewer selectec several crawings to cetermine if the cur ent Orawies revision with 4 a:sitcable tne cen .r:1CCAs and CMCs locatec in tne CCC, was also ennanc in anc auxiliary butiding P 3s. Two crawing ciscre-
- l cancies were noted. Cravings 2323 81-2011 '
Sheet 1, R6 mainuinec in :ne PcG nac sever,al CCAs in the pacI I ! l i i I t e wm WW'** ,,,_a..-.. .e .e = ns ~ ' " ^ " *
- 1_.-------- ~
1 __ . __ __ -- . 2 :- - - - . - -~ * ~ ~ __._.-:.----1 s 1
. 1
. 1 11
~
cat were sissing fr:m *ne current crawing package c::: Uter i sein::ut. The verifica ten was :erf rmec on Acril 12, 1934, using a current crawing status. This =recies a : ears :: te fecm engineering eliminating CMCs and CCAs from its ca:a case a: lic-asle t: part.icular drawings witncut informing CCC of :ne enan Althougn the c:m: uter enange ket s sa allite issues carren , ge. nc .
" trigger" cavice causas satellita persennel to remove the CMCs and CCAs frem the PFG drawing package. A review of ue en meenanism for updating the casa base founc the =recacugineering a satis-fact:ry and a review of having non-a:pitcable. CMCs or CCAs in the crawing package revealed that wnile possibly c:nfusine. ne practice is not a tecnnical problem. .;
l -
~he cem:utar assisted drawing c ntrol program was reviewec.
Scecifically, rin :ut : with me sole relianca on :ne cu- tn: c:m uter casarmine crawing pacxage acecuacy, ce c:n:r:Is =f c :utar insus and enanges were reviewec. Accass c:ces navn been estanlisned so that a personnel have access to affectlimitad .numcer of engineering anc CCC their respective ca a base. A
=recaccre anc training exists to define acerceriata c:mputar
=anges authori:ed for each greus. The systam a: pears to be acacuately centrolled anc use of a c moutar systam versus s.amped Crawings referencing CCAs and CMCs is identified as a streneth.
j
-- :- a t-~ % 6.+229 r.:s WM&::;,WdS* s .
n -m _ - - . ...~.%,.-..... cnanoasi;;- m. .
= *W*
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. n g . g.,. r-i... e F.4.@:aWt..t=. ia . . . _
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-u W-.".h P M O 44s = "T.DFVW E4:=r
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- c. Cenclusten
'he sy::am limitac 2:: tars review reveaiec :na: 2e current cec; men- c:n.r:1 2 .c :e functi ning sati sf ac crily. All CCC anc anc G new =arsennel
- netr jec was intarviewec perf:rmec. were aware of :neir rescensicili:1es reviewec a:pearec ::
The CCC, satelli as, anc P:Gs te acecuataly s affec. l l l t w=up O""* p..p.-- 'WM* * * , n.s.n.-
. ~ _ ._.
, u. .= , u. - -- -- ~ ~^ ' ~
12
- - " Tne use of the crawing c:n r:1 ::ecuter at: ears :: Lee: :ra' personnel u:-::-cate in an ex:ect:icus manner.
5. Receipt, S: rage, ar.c handling of Materials
References:
(a) CP-CPM 3.1, R1, of Receipt, 5: rage, anc Issuance . Items (2) CI-CPM 8.1, R1, C: lor C ding of 71:ing Materials (c) CI-CFM 8.2, RS,
, Control of Scare Par.s (c) MC7-10, R7, 5: rage and 5:: rage ,
Maintenance of Meenart:a! anc Electrical E ut:=en (e) IC?-5, R3, Cent :1 of pemanen Plae: Ins: unents:icn t (f) CP-CA;-8.1, R7, Receiving Inssection (f:r ASME items) (g) CP-OP-8.0, R2, Receiving Inssecsten
- a. General
'Services warehousing activities are managed under the Pmfect Su:ccc:
organt:stion. Safety-relatec material is s::re in several warenouses and also in an outsice layc:wn yarc. c All material is received at amorcariate st rage location.one warenouse anc :nen moved :: :ne Shipoing camage ins:ecticas are
- ncucted by warehouse personnel and recaf:: ins:ecti:ns are perdermed by CC insnect:rs. Envirenmentally sonst:
st: red in a tamperature and humidity c:n r'ellec s::ca1ve materiai is A reventive anc electrical maintenance equipment se gram exists := insure :na:ge ic:ssi:n. meenani:a1 wnile in st: rage. is maintainec in an ccera:le ::nc:-icn
- h. Review Effer,
~
A Ptview of nandling cf ecui the ifment censee's program for tne recaf::, s : race , anc anc material with res:ect :s elements review was : of One licensae's ac:enac CA 7 gram was :erfer ac.sel'e The
- ac tstacifshed c:ncerr.ing verify that acministrative c:ntr:1s nac :een receit:
' nssection of safety-re;4 ac i
materiais, pre:aratica anc retentien of recuired c:cumenta:1:n, c:ntr:1 of 1: ems cf none:nforming in s rage. anc ::ndi-ional rtitase items anc ::n:r:1
\
Imolementa .1:n of ne r: gram was rev'twec
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13
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g l by selecting several safety-rela ac items in s : rage anc verifying cecument anc item c:ntrol to te in acc:rcance with :ne pr: gram. Tne reviewer also : ured .the wareneusing locaticas. Stcrage di;cre:ancies were act teen 1fied. The QC receipt inscoc icn pr1 gram was also reviewed. CC inspecticas accearec to be
- c:ncucted in a satisfac cry manner.
- c. Canclusien Sased on :ne limited review of the warthcusing and receipt inscoctica program and implementation, both programs appear
- acecuately managed. Storage locations accear adequately staffed.
Wartheusing anc CC perscnnel were knowledgeacle and professional in their respective areas.
- 7. Procurement
References:
(a) CP-i.:-i.0, R7, PecacureforFbdPrecurement (b) 007-C3-2, R6, Precurement ' (c) CCP-C3-4, R9, Procecure s Accly Establish anc A System'of Pre-Award
' Evaluations, Audits, and Surveillances (c) CQI-C3-a.1, R3, Vencer CA Manual Reviews (e) CQI-03-4.2, R3, Generating and Maintaining the Tl)GCC Appe:vec Vencors List
( f) CQI-C3-4.3, R4, Vencer Systear Perf:rsance Evaluation (g) CGI-C3-4.4, R4, . Ccncuc of Vencer Pro-Awarc Evaluattens (h) C01-03-4.5, RS, ~
. :ncuc of Venc:e Aucits (i) CCP-VC-1, R7,
. Final Inscac.1en anc Release 1 for TdGC3 l
(j) CCP-VC-2 R7, Wit::essing Tri: (k) CCP-VC-3, R3, Initiating Yellcw : lag Sheets (1) CCP-VC-4, RS, Guicalines fer Car.ifying s Vencer C meliance Ins:ection Persennel
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14
- (m) 'CP-07-5.0, R1,
- Quality Assurance Review of Site Generatec pre gremen:
Occuments
- a. General
, Safety-relatec purchase noui sitions are generated by WGCC engineering at ne site anc are converted to purenase or ers by
- un site procurement and subcontracts section.
Tecnnical and CA t recuirements are cetermined by engineering. A CA mytow of all safety-related purchase orcers is conducted on site to verify CA requirements and use of an approved vendor. Each pur: nase order requires snio. the vendor to inform WGC0 when a product is reacy to WGCC CA cetermines wnetner to perform a pre-sniement , t ins:ection at ne vencor's location or to waive this inspection, Accreximately inssected. one- Mirc of all safety-related snissents 4re source WGC3 also maintains a vencer aucit =r: gram s insure
- nat vencors can mee :ne recuirements imposec by i
or:ers. ne urenase Tne vencers saat are satisfac ,crily aucited are placec on ue a: revec venc:rs Itst. review of sucolier perfomance.WGCC has also initiated an annual ;
- b. Review Effor:
A review was made of the licensee's procurement program wt n resoect to selected elements of the - accepted QA Program. review was s verify Tne that administrative controls had been estacif shec for Or:cu ement c=cuments. the prestration, review, soproval and revision of vertfy :na: A review of the licensee's procacures to wnica stevice cuality goces or services; that these pr:ce recuirecanc auct:s; ue :na maintenance of receres of supplier qualifica:1cas anc ressensibilities hav ce vencer cualification program was e been assigned to perform cr:ers at ne site anc at erformed. Several Ourenases eviewec. S the WGC0 offices in Callas wers ;
- :s nanclec satisfactorily.ure. ase or ers, based on tne limited a:cearecreview, Also reviewed was tne source isolementec f em sne WGC3 QA office. insoection er wiuessing pr: gram Tne ; : gram is :uite extensive anc a:: ears is te very effec-ive at :erf:rming material ins:ections cifficult t: at me sour:e anc icentifying potential pr: clams catect, by a receiving ins:ec-ion alone.
2 A :or.icn =f : Mis =r: gram, snougn, needs clarification > + De wiuessing pr:cecures cascribes how . Altneugn ins:e:-ica, criteria is not :s cerf:rm :ne source ,
;ur=ase creers are source inspected anc wnica are Tni waivec.docum !
; is unsicerec a Or cecure weanness, but not a :r: gram weaxness.s !
.no entire witnessing ;r gram is a s: ve n. l J
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Also reviewee was the vendor audi: =r: gram, wnica is used to 1 s matnuin :ne accr:vec vencers list. The reviewer selectec several : vencors on the current list and reviewed their most current aucits. All audits reviewed were consicerad satisfactory. Two of
- ne vender audits, Dresser Incustries and Fceney Engineering were r last aucitec in 1978. The licensee, througn the 75AR, utili:es ANSI N45.2.12, Oraf 3, Rev. 0 to deveJap tne audit program, a '
= art of which is the vencor audit program. Paragrann 3.4.2 of '
this stancard requires the performance of annual aucits or at least one audit curing the lifetime of Me activity. NRC Regulatory Guide 1.144, Revision 1. Auditing of Quality Assurance Programs for Nuclear Power Plants, whicM the licensee has not encorsed, clarifies this annual requirement with resoect to vencor aucits, in : Mas vendors may be aud1:ac triennially providing that annual tortly. evaluations continue to snow :ne vencor performing satisfac-j The TUGC3 vencer auct: program does not provice for an
, annual, triennial or any periodic vencor audit senecule. Vencors 1 are reauditec primarily on a usage and performance nist:ry basis.
I This failure .o esuolish measures to auci: vencors at leas triennially is consicered a potential en1'ercement isju{e,. s The insnec or found no incication :nat a failure to aucit periodically resulted in maintaining an unsatisfactory vendor on the approvec i vencors list. Also, althougn the vencor witnessing program does
. not review the vendor's CA program, and is not a sucstitute for a- ,
- TUGC3 audit, the large nuncer of source insoections would mitigate the possible consecuences of not performing periodic vencor audits.
- c. C nclusion The procurement i program appears to be satisfactory. The vencor t j witnessing
- nan program is an asses and accears well managet. 0:ner i :ne missing timetacle for the vencer audit program, sne i 4
c:ncuct of audits anc vencer annual evaluations accears to se well managed. j Personnel in :ne precurement CA staff accear t: be knowiecgeacle anc professional in :neir wort. C. I:ui: ment Turnover and Precoerational Testing neferencas- -5 p-3, Cust:dy Transfer of Sutton C:mo:nents 1 einal accomunce of Su:1on Systams, i gp.pp t :Ciures,, ang {2Wigment l 4
-, wncuct of iesting !i ; i f
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- 4. Generai The pr: cesses of turnover of safety relatac equipment fees c:ns.raction to startup as well as pre-recuisite anc cre-0cerational tasting of saic equipment were reviewed in order te determine if:
(1) The method emolayed for transferring custody of comoonents, partial suesystems, sudsystems or systems from construction to startus; the return of equipment to canstruction for rework or socification; and the ultimata release of custacy from startuo to coerations.are tecnnically and acministratively acequata. (2) The administrative controls over proccerational tasting are tecnnically anc acatnistratively acequata, I t (3) The greenerational test procedures botn performec and yet to be perfomes are tecnnically viaale and acministratively sufficient.
- 3. Review Eff:rt (1) E:uipment Turnover The turnover of safety related equipment from Censtrue:1on to Startus is acministra: 1vely controlled by Startu'; Administrative Procedure CP-SA7-3, Cusaey Transfer of Station Components. This procedure estaclishes the requirements anc responsibilities for transferring or systems from: custacy of camponents, partial suosystems, suosystems (a) Cans:raction ta Startuo i
(b) Star us back to Constrae fon for reworn or socification ('c) 5Ar*.us ta Operations The Startuo grous cetersines the turnover bouncartes neesssary :
- serform see coerttional tasting ac-tvities.
The C:molations Gr:u (aecutcment, af suegrous valve, of Star.uo) pipingassancies and ins: usent the turnover =ackages c:nsis ing lists, crawing lists r sucn as flow instramentatt:n and c:ntrol ciagrams as ,recuirsc to sufficiently cas,crice no c:ntantanc aux 11 tary ent-line < bouncaries of the turnover. anc The C:mclesion Greus is also ressonsible 'er initiating and processing turs=ver package, turnovers suenc:nsistant as to: witn esta:lisnec senecules in :Me i (a) icentify the ecut; men ,
,(b) s incicata :ne sc::e of Me turnover l
__ __-__x___ - - - . - - - - - - - - - - . _ . , _ _ _ _ - - _ , _ - - - - - ~~"^ '"~~ ~ ~
i[' 17
-- " (c) assemole the late revistens of the a::re:riate diagrams /
prints anc a:clica:1e casign enange dccuments (CCA's) (d) list deficiencies, inclucing .cesign changes sna: have not been isolemented The Comoletion Groun c:cedinates all requi red pre-surnover walkcowns and punenlist activities f:e the pur,,ose of estan11shing the sutus of equipment to remaining startue. work to be done prior :s turnover of that ' Startup corsonnel review the packages and perform a walkdown of sne ecuipment/ system to determine if the equipment icentified in the package is reacy for turnover. resolution prior to turnover are resolved prior ::Any deficiencies esquiring oeficiencies not recuiring pre-turnover resolutiontransfer; are acced :s those
- ne Master Dau Ease (a c mouteri:ed tracking system) tate future disposition. Upon comoletion of ne sur.uo walkcown to f acili-anc c:r te:1on of recuired deficiencies, cust:cy/ turnover of :ne ecuiomen: is transfer sc to sur un.
Custody of station comoonents may be returned to construe: 1on for cerforsance of work such clearing of c:nstruction deficiencies.as major modifications, recai r or The return of ecuipment to c:nstruction voids all precoeration testing on said equipment. " After the esspletion of toolicable prerequisita tests, (construc-tica tests), including initial operation of the ecuipment, startuo may relinout sh "coerational c ntrol" :s Coera: tons yet mainuins cust:cy testing. of the ecuipment pencing esmoletica of precoerational The turnover packages for the following systems wers reviewec: (a) Com enent Cooling (b) Auxiliary Feecwater (c) C nuinment Seray (c) Chemical anc Volume C:ntrol (e) Resi ual Heat Removal ( f) Safety Injec:fon (g) Hyce: gen Rec:m:1ners (h) React:P Prc:ac.icn System _ , , , , , e . ** t 8'" " * " " -
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The turnover of' equi; men: fr:m Star.u: to Ocerations is castiled in Station Acministrative Pec:scurt e Statten Systems, Stra ures anc E:uiceens.STA-302 Final a :eetance of Pursuan. to sna: Precacure, Ccert: tens int::atas a ce: ailed review of the turnover package anc walks cown the accitca=le equi; ment. Following sue:assful accepts tnec:meletion of the reviews eeutseent/arta. At anc walkcowns. Opera-ions ' that equipment lies with operations.:nis time all responsibility for There has been no safety related equipment transferred to coerations, programmatic sufficiency. thus the review of the peccess was in terms of (2) Patccerational Testing Program The preocerational test progrits was reviewec in orcer to verify snat the tests to be perferned have been icentified anc :na eacn of the identiff ec tests entailec at a minimum, test etjectives, sumary cri teri a. of tne tas., necessary prerequisites, anc ac:::tanca The linestest organization of autacrity edwas reviewec in order ta verify that the responsibilities of test personnel are saecified and that weert interfacts exist between organt:ations-involved are clearlyinestablished. tne test program, that organi:ational responsibili:1es The acministration of the test program was reviewed in order :s verify that methocs art estanlishec to enceive (from c:nstraction) the jurisdic f on over systems befort censnencement of testing . The ac=inistrative mechanisms of systems befort, during, establisnec and after tasting. for Jurisdiction were reviewec in c orcer to verify tnat c:ntrol of system status cefortthose mecnanisms adecuataly provide for: the ne c:moletion esturn of system of acequata prert:uisite (c:nstraction)proccarational tes.ing; - testing to Constraction if astcassary :: sucscr. ecci sucsecuent fications anc/or reger.s; the c:ntrol of system status invalication of testto testing including measurts necessary :: ;rtvent results; :ne ::ntrol of tne system curing testing; may onlysystem
- ncuct :ne asstgnec tasting. Systam Tes- Engineer er nis casignata The
- ncuct of tasting was reviewec in accouate acministrative measurts provice for:orcar :s verify :na:
tas 3recacurt me:nces :: :nange a inter u= tion of a tes: curing :ne ::ncuc of tes-ing; :ne critaria for and emn-inuatica of an intarrastac tast; metaccs is :: rcinate ne ::ncuct of tes-ing; metaccs :s cc:tment signi ficant events, unusual c:ncisions er in ar uctiens s tasting; me:nces for teen 1fying ceficier,cies, ::cumen-ing :neir
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resolution current 'tastand 'cocumenting retesting; metnoes fer =reviding the peccecure to ocerations anc c:ordinating test activities wt:M the shift supervisor; me: nods to ensure that ne systems test engineer has the acer criata latest revision of sne required cocumen:4:f on/ references.
\
The program for evaluation of test results was reviewec in cecer ' to cetermine that: ceficiencies are clearly identi fied and l auprsortate corrective action proposec, nyiewed and c:moletac; sunsequent to corrective actions or socifications have been cerruletec, tests or portions of test have been rerun as necessary to ensure that tests of the as-cuilt system are adequate; :ne results of the evaluations were reviewed by the apprcpriate licensee personnel responsible for amoroving the original prece-dure. l (3) prerequisitas Tests Selectec prerecuisite tests were reviewec in arcar to ce:e mine if tne tests or0vice anc adequate mechanism of ac:cmplisning vital testing anc reviewed coeration of the associated equipment. The tests appeared technically and acministratively sufficient. The prerequisite tests when performee in comoliance wita 5:artus Acministrative Procecure CP-SAP-21, Concuct of Testing, and as requirec Dy the ass 11 cable proccarational tests, annear to provice operation. an acequate mechanism for inittal equipment chectout and (4) Preoperational Tests Selectec artcoerational test procacures for tas s wnica are yet to be performec, were reviewed in orcer to ascertain acequata isolement4:1on of the following: (a) Management review anc approval (b) Precacure format wita empnasis on clarity of tasting etcutenc (c) Clarity of test objectives (d) Pertinent prericuisites icentifiec, e.g.
- 1) required plant systems are scocified
- 2) pr:cer facility precocures saecified and uniously icentifiecanc c:Mer referencas art
- 3) ::moletion of calibration enect.s, limit protective device setting, incluced wners acclicaoleswitcn sening 4) 5:ecial'sunglies, anc test ecui: ment s:ecifiec.
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Scecial envfrenmental c:nditions, if any, icentifisc. i (f) i Ac:aptance cetteria are clearly identified and the prece:ure t i requires ccm: arisen of results with acceptance critaria. j- it (g) Tine source of the ac:setance :riteria is identifiac, i.e. , - 4 F5AR, T/5, Reg. Guice, engineering crawing, etc. (h) 4 Initial tas c:nditions are saecified
- 1) Valve Ifne uns
- 2) D octrical power and conte:1 recuirements 3)
Tem =crary ins,.allattens (instrumentation, electrical, anc piping)
- 4) Temceratures, pressures, ficws (1) The precacurt incluces reference :s app coriata .:5AA see:1cas, T/S, crawings, spect ficarica, c:ces anc ether requirements.
(j) Step-ty-stac inst uctions for the performanca of the preca-dure cojectives are comcleta are met.:s the extent necassary to assure taa tas: ( k.) Pr:visicas art available for documenting . hat all items, inclucing formed. artricuisitas, are verified as having :een p er-(1) Pa vision is made for eteceding details of :ne c:ncuct of test :ne ratest. including cosarved deficiencies, snetr resciution, anc (m) P cacurt Pseutres ina: tem crary c:nnecti:ns, cisc:nnecticns ce jum:ers :n restored procacure. to normal er rifers u anc:ner (n) P Ocacure the tasting =revices anc fee identification evaluating ne tes f :ersonne; c:ncue ng i precacure. cau er Ptfers :s anctner
* (c) P Ocacurt stacs ce parameters, inclucing CA hoic::ints.=rovices f :-isicai for inde:enc These precacurts inclucac =c:
were ac: 11misec :: ne f:11: wing: 1-CF-:T-ll-31 1-07-47-29-2 Cam:enen: C: cline 0/G Cen:r:1 & Functi:nal e-l l i y n
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-e ' -) 1-CP-PT-48-01 Cenuineen: Scray 1-CP-97-49-02-RT-1 i CVCS - Seal Watar & La c:wn i 1-CP- T-49-05-RT-1 Performance Retest j CVCS - Chemical Control Purification and Makaus Retast 1-CF-PT-57-01-RT-1 SI Pumo Performance Re:est -
Selected c:molated proccarational etter to ascaruin, at a minimum that:prtescures were reviewed in (a) The ifcansas results is performing an adequata evaluation of tas-(b) All tast da.a are either within previcusly esublished l accacunca dis ositioned. critaria, or that caviations art cr:perly (c) The licensee's retasting methocs for correcting caficiencies anc for are aceouata. (c) The acequacy of the licensee's administrative practicas in maintaining tast altaration, pr:cer test rec and tast disciplins
=rds. concerning test execution, t
(e) The licansas is following his precacures for review, evaluation, and acceptance of test results. These peccacures included, but were not ifmitad ts: 1-C7-PT-57-06 RHR - ECC3 1-CP-PT-67-01 1-07-87-64-02 Hycr: gen geec=einer 1-07-77-57-02 Reactor Pretac-ion Systam 1-CP- T-57-01 Centrifugal Charging Pume 1-C7-87-4-01 SI Pumo Performanca 1-C7-8T-29-04 Containment Scray 1-C7-3T-02-08 0/G Secuencing Class I m Switengear (3) Systams Status Systam walkcewns were ced:rmed in crear tc Ottarmine one cup g
, sutus of safety relatec ccmoonents/systams. The n,
, systams, ment: a cng others were selec-ively reviewec in tnatfollowingassess-(a) Resicual Keat Removal (c) Chemical (b) Volume anc Cent 31 Safety Injection (C) Canuinment Scray (e) Auxiliary tecwater
( f) Com:enent Cooling i I q
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i 22 I i y( ' 9J proccarational test status esecess were also reviewec and inte/ views and c:ncucted remaining testing.in orcer := assess ne current sutus Of c:m:leted The review revealed ca: Of :ne 198
, crigiaal perd precoerational tes: =recacures, 45 have yet to be i ~j to be perfomed; that of me 39 =rsocerational/recerform croc ducts, 37 have yet to be performec. '. ; Thus of 271 :: al procedures, 115 or 42 have yet := te perfemee. It should be notee newever cat the " Retests" and "Re:erfems" art, less in scnce than ce original arsonerational testas a general rule, much shoule recutes less time := complete. anc as suen Fur.her ce "Re:ests" anc "Reperfoms" will be run en essentially "decuggec" systems, thus snould run much smoother than the original tasts.
(Note: The ratests and reperfoms were necessitated by extensive electrical etwork and sution accifiutions.) There is no proccarational testtag =rrently engeing, nor has tnert been any significant tasting in the cas 10 menus, One result of cations. tne aforementtenec electrical rewort and c=er socifi-plans art cu-rently uncerway to rec:mmence proccera-i :1:nal testing during the month of April 1984, A . sutistical analysis of the preccerational tasting. which 'has teen psrformec, spanning the period of July 1982 to June 1983, in q essencar the period immediataly proceecing a vte:ual snuscown of
-s testing necessitated revealed that by the socifications es aforementioned, !
tests were performed. in that 11 month perioc,177 ef the 198 criginal tas:s c:moleted per month.Thts calculatas to be an average of 11 Analyin ue total tasting remaining,115 :g ut sit rata ssts, to uke woule c:moietica of accc xi-l mataly 10 months to esmolete me orten program. If, newever, ene assumes that rate would analy only u .he original praccerational tests, not the retasts or etcerfems, and a valic assumssten that ce least rttas:s curing anc/cr the timeetterfoms tan te run in c:njune-ton wiu er at remaining original artens can be nn in aframe of :ne :nenpreen the 45 tests, mentns. Assuming prec: tasting resumes in Acril 1984 as :lannec, ;rtcp tasstag c:uld c:ncatvacly pr:cles concluce :y August 1934, if no major uncisclosac is iden:1fied. It sncule te notac ca j utility :s facilita:a urncvers, is mata meenanis=/mence new em racec :y ne
- cvers seme in c:njunction wie One ecui: ment of c:cm/builcing turn-
.i anc c:ulc incact Artecerational testing. insica. This is cum =er-Prec:erational tasting is c:meleta, is perf yetmec en a systam etlatec basis, thus if a syst em (i.e., painting, tne reem in wnien :ne system is clacec is not uncer ne current etc.), :rtc:erational tasting may Oe, anc i s +
See Sec-ton A f:r enanging c:.:sie:icn me==celegy). (Note- prot; ram, ceiay
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- c. Conclusion ' '
t i 3 I Eased were en fomed: the above limitec review, we following =ncl us, ions , (1) The to beacministrative acesunta. process of cust:cy transfer of systems appears . (2) The preoperational test acequate. pr gram ascears :: be inuet, viacle and (3) Pesonerational acequate. tests annear to be technically and ac=inistratively (4) Pescoerational testing c:uld'cencluce by August 1984 3
- 3. S ectrical t
References:
QI-CP-11.2-3, Ter:uing anc 5: acing of Concrete Anener s Bolts CI-OP-11.3-23, QI-QP-11.3-25, Class IE Conduit Raceway Insmection QI-CP-11.3-27, Doctrical Caole Insullation Insoec-ion QI-CP-11.3-ZS, Class 1E Power Caola Meggering QI-;P-11.3-29.1, Class 1E Cable Teminaticas s
.QI-;P-11.3-38.1, Verify Doctrical Separation J Installation Equipment of Class 1E Doctrical QI-QP-11.3-ao, Post Construe:1on Inspection of QI-GP-11.3-a2, Electrical Esuipment anc Raceways Electrical Ins:ection of Seisate Category 1 Instrumenution Racx, Assemolies QI-QP-11.10-1, Inssec-icn of Seismic and Restrain Systems D octrical Sucoces CI-OP-11.3-iic ,
Camle Grip Sus =or Insutla ten Insoectica
- a. General The assessment in mis area was to catamine ff saft:y relatec wiu NRC recuirements andelectrical ecui: ment was ceing insulled anc i licensee c:mmitments anc := catamine if Texas prececurts, Utilities cuality Services c:ntr:1 Inc., (TUSI) programs wnien incluces crawin ,
etc:rcs art acecuate to ac=molisn work in =1s activityanc c:nstructicn inssecti:n Ciscussions we t n' ele viu craf ,smen Electric 5:a:1cn anc c=er C:manene peak Steam ' anc kn:wlecge ::(CPSE3) car y cu :neir incivicual := catamine sneir acility pr: Ject :ersennel evaluateroject. nuclear unir scrale anc coinion wiu regarc scres:ensibilities ue anc :: Ne acversa c:mments were mace y :ne manene Peak .
- Cuanene Peak
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) project emcloyees c:nstruction. anc all censicerec the pr: Ject to be of high cuality
- ' Tne licensee recently organi:ed his man:ower into a Builcing Management Organi:ation (E*0) to make the most efficient use of project resources.
There are four main EMOs - Centainment Builcing, Safeguards Builcing, *. Auxiliary Building, anc Doctrical Control Suilding. Each organi:ation t ' is an grous This integrated succor.sgroupthe of engineering, effort construe:1on, anc QA personnel. i to esmolete the construe:1on in neir area Director. of assignment uncer the direction of a Suilcing Management ! The deoartment sumervisors are resconsible for the technical
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cirection of their personnel, and QC personnel reser. to the amplicacle QA Decartment manager. i There is an exchange of proolems and resolution I of pesolems among the creject personnel and bi weekly SMO meetings. As a room or area is consicered nearly c molete an Electrical Seoara-i' f on area. Verification (QI-OP 11.3-29.1) is cerformed on :ne room anc/cr Senart:fThe esmoletion1:orems on Verification near c=moletion usually triggersofthe thePostfinal Electrical Const uc-ion Inssectien of Doctrical E:uipment and Raceways (QI-QP-11.3-a0). When i both these prececurts are c:molete, or essentially c:mplete, and/or as
- ne discretion of :*e BM0 cirector, the room and/or area bec:mes 4
controlled. cies or Access is limited to correct' minor outstanding deficien-esmclete other known outstancing work. Tne SMO Director-
) cetersinos when this room and/or area is 10 be turned over for an inscoesion and acca:unce by the Stations Sur.us anc Test Group. Tnis ceficiencies 11.3-40.
founc during the performance of QI-QPturnover us 11.3-29.1 and QI-QP An ins:ection walk cown was per#crmed on many of the recas/ areas sna the showed EMO that Of rec.se considered : be essentially ::enle:n. Tnis walke:wn secaration, the rooms / areas were clean, that electrical /meenanical inclucing barriers, cable tray at.actments, icentification of eacle trays, c:ncuits, and cables, :::le tray fill anc cacle s: acing (wnert a:clicable) ecuivalent) in trays, anc cacle su:: orts (Kellen gri:s or wert satisfac.:ry. j
- 2. Review iffer:
(1) Review of Cuality Assurance I. clementing precacurts ' 5 i l Tne referenced
=r cecurts were examinec to assurt :na: FSAR j recuirements relating :: anc ::mmi.=ents wert :eing ::m:11ec wi:nin he areas ment anc c:mucnents.the insullation ancf ins:ec. electrical tene uip-Tnese CC :r::acurts r:vicec :necy. lists anc ac:e:unce criteria f:r ins:ee::r.
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; } (2) Electrical Cacle Installation 1
The following installed safety-relatec (S/R) electrical cabies that had been accessed as satisfactory by site c:nstruc-ten QC ins:ec:ces were examined. A anysical examination was made to
- casemine c moliance with amplicamle design and installation .
criteria at relative to type, location / routing, toentification tags
, - termination points, minimum bend radius (wntre acclicable),
- cable calor connatible with designated raceways and se aration of
, trains, exclucing barriers , wnica are perfomed prior :: or j c=ncur en: with QI-QP-11.29-1, " Veri fy Electrical Secaration."
a 1, The routing was enecked by using a signal generating cevice, Cable No. Tyne E em Tc 4 l M100483 3/C No. ICAWG EG113625 MCC1 E2-1 MCV IHV5540 9/C No. 12AWG MCC1E2-1 EG113646 CP1ECFRT 03 - , 9/C No. 12AWG MCCIE2-1 EG112219 CF1ECFRTC05
; l 2/C No. 12AWG MOV 1HV4759
' EGIC0497 CPIECFRTC05 i 3/C No. SAWG MCCIEZ-1 EG112216 MOV 1HV4759 5/C No. 12AWG MCCIE2-1 E100009 1/C No. 4/0AWG MCV 1HVa759
! SWGRIEA-1 E0112206 5/C No. 12AWG TEXCSAPCH01
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.. EC112207 MCCIE3-1 MOV 1HV4758 77C No. 12AWG MCCIE3-1 s
s 3 EC112209 2/C No. 12AWG C71ECPRTC04 C71ECPRTC04 MOV 1HV4733 The cable identification is acccaglished by an alphanumeric cocac tag alphanumeric the and by :ne color esce of the cable jacket. The first enaracter of i incicates whetner the cable is safety =r nannel orientec (E), associatec train (A) er non-safety (N). The see:nc caarac.or icentifies the color of the cable jacke* anc with resnect to"G"safety (Orange), relatec (S/R) aanlica:1cas they are "C" (Green), "W" (White), "S" (51ue), (Yellcw). All cables are to be tagged with"R" their (Red) anc "Y" unicue al phanumeric junction boxes.nuncer at temination points in ecui: ment anc Cables that are not enter anc leave a junction Ocx cut teminatec in tnat junc.icn box are not icentiff ec in nat cox witn their alsnanumeric numcerrequirec :s be acove camle were properly identified. . All of 'One ;
~
Using :nis methodine.r.uting of me acove cacies was enecxed with signal trac i.j *
=a--t ers anc c:ner, June-ton box covers, cable tray c= vers, fire snewec that cacle tray itemssystems cic not nave anc c:nduits to be nmovec.a:: eared This enecx r :erly installec wita cr:cer at.acnments an: su:: r.s. s :na: te
- nese systems were ;recerly icenti fi ec, anc :na: :ne caoles travellec ce r ute incica ac :n =e cacle ;ull carcs.
CC wita me rec:rcs snewec felicwing acclicaele ins:ections wers mace in ac::r:a
;r:cecures:
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, :lectrical Cacle Installa:icn Ins:se:fon (b) 01-0P-11.3-27, Class 1: Power Ca le Meggering :
3 (c) QI-07-11.3-25, Class II Camle Temina-f ans 7 (3) Electrical Cacle Temina:1cn I A physical examination was mace on terminattens of selected class 1E electrical cables in :ne Het Shutdown Panel on elevatten 832' of the unit 1 safeguarcs tuilding. The examination verified that i termina-ions were in c: mci t anca with requiremen s, including
.! proper lug material and si:n, accurate location, and identifica-
- sten of terminal block 'and c:ncuctor. The cable wiring ciagram
{ was icentiusec to determine the crecer termination scints anc conductnes fication. j Cable Taminations that were checxed were for j caules E104556, E111148, 5104551, 5139204, E0104791 E01047?0, E0122101 E0104742 E0130596, and E12:103.
' The CC receres snowee ua ins ections were made en =ese termina- ' ' -'ns.*
tions in ac=rcance wiu 01-OP-11.3-ZS, "01 ass IE Camle Termina-
-I QI-0P-11.3-40, "Pos: Construe:1on Inscoesion of Electrical Ecui mont anc Raceways" sutas:
; recuncant "Senaration between field un j q a canine Class 1E caeles and Class 1E/Non-Class 1E caties witnin
./
sneci fica-t shall on. be mainuined in acesrdance with na ecuismen: If the specification gives no separat. ton recuire-ments, the minimum separttion disunce between recuncan: Class 1E and 5 Class 11/Non-Class IE cables snall be grea ar than or equal s inenes. mainuined, In cases wners :ne acove sacaration c-1: aria canne- be
!=c:acusie :arriers barrierinclude snall be :Meinsulled following: between ce ca:1es."
(a) Meullic c:ncuit c:ncuit; inclucing Servicair Cem=any . C 33 flexible (b) Two snetts of fire retarcant material sa:arauc Oy a minimum of " of air s:aca er :nermal insulating =atarial (c)
- A single bar-ier with a 1" sainuined air s
- aca or :nermal
.:ar-ier insulating matarial between :ne c:meonents er cavicas anc :ne l i
l Curing :ne cable termination ins:ec. ten in the Het Shu =wn panel, it was notec that bar-iers were insulled bu , care still existac s me sacara:1on =r:clems. l i
=a: 0!-07-11.3-40 ins =ection Thenac licansae's no: :eenre:resanutive incicatac anc =at ;erf: mec en u e. an met: =e remaining arriers would te insullec as neeca=c :el:
- for wa . -com or canel.
- ne sacaration cr1 aria cafere Q!-OP-11.3-40 was signec M
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-q i j 73 ' ] To insure taat internal electrical se aratten in :anels was being adnerec tc, several canels in which CI-07-11.3-40 was essentially c:mmlete were examinec. These panels were located in the cable screading room sad con rci room. The panel examined incluced s
terminatten caniness TC-22, 23, Auxiliary Relay Panels 1, 2, and
- 5. .
These panels showec that internal secaraston was satisfactory even though work was s:fil in process in some of :nese,fpanels. During panels itthe wasinsoectica noted that for electrical seoaratten in the amove j . scitcod. This was was determined sa bescossatisf
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caeles in the actory and sanels meets were meing
! r5AR c=amitments which state in paragraph 8.1.5.2.5., " Wire
{ salices are used in limited a:plications on field casles snat terminate in certain Class 1E canels, cacinets or racks. The i normal solicas. cesign is :s :arminate fiele cacles wi:Mout the use of wire The wire solices are only usec where accisional lenge is recuired for :ne field wire and it was not jucgec reasonable to j :ull a new field cable. The use of suen wire s=licas nas :een ' sinimi:ec. The wire splicas are butt salicas. The criacing tecnnique, device and materials to those used for the terminal lugs in that panel. used for the solices are identical The wire salicas are only allowed on low power analica-tons such as con:rci casles. . Sine previously accessed crimping metaccs anc sacerials (, Q' are used, the spitees are limited to low Mwer circuits and ts field cables that alreacy terminate in the panel, and :ne required
~
wire separation and wire bundles suppor is maintained.. .." Interviews with CPSE5 project personnel which were conducted by c:ner seccles memoers with of this review team indicated tha :nere may be a I These terminalcaele terminations blocks emoloy a to Weicmuller screw Terminal Elecks. clamo c:nnection. The
- manufacturer's literature for these terminals biccxs statas, "The '
screw clamo" refers to a c=nnection in wnics :Me wire is strippec of its insulatica to a recommenced length and classed without any fur.ner preparation. A screw clamp and curren: tar are used to insure -he connection; and since Me clasting screw coes not make cirect emn.act on the wire, damage is preventec.* As inszectors were making inscoe:icns for QI-QP-11.2-40, " pes: Construction
': Inscection of Electrical Ecuisment anc Raceways," tney wculd tug anc flex the csncuc se :s insure tha: ; E115 action causec the concuctor wire strancs ::the c:nnec-icn slign:ly screac was tight.
anc :Meracy reducing saa sign ness of the screw clamo c:nnec-ion. Since nese c:nnections were previously verifisc as satisfac cry
- er fac:01-0P-11.3-22 " Class 1E Catle Termina-ten" ins:ac: tens anc
- na visual inscaction wi:n regarc toecuipment may te energi:ed. :ne licenses 4
01-07-11.3-40 :ar=1 nation enecks. 1"Se Weicmueller Terminal 31ccks used at CPSE3 8
- ualified art :er
- ne manufacturer envi ronmental qualifica icn. s literature for nuclear a:clica icas inclucing i Tests fer this cualifica:icn were i
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.g performed cy Franklin Resenren Center anc are cccumen:ac cn :netr reccess FC 4959 and 5205.
(4) Electrical Cencuit and Cable 7 rey Installa:1cn i Concuit and cable tray raceway systems were inspected in eccms -
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anc/cr areas in which both QI-CP 11.3-29.1, " Electrical Seoaration 4 j Verifica ica" and QI-CP 11.3-40, " Post Construe:1on Insmection of
,1 Electrical Ecuipment and Raceways," were essen:4 ally c:moleted and access to 1
Mese rooms and/or areas were centro 11ed. Tnis 1 insoection was to verify concleteness of work, in the electrical j area, inclucing electrical separation, power cable scacing in trays and cacle supports on vertical runs of cable systems. All items were concidered to meet construe: ten criteria. Soecific Concuit System checked inclucing sunscr. anc scacing were: Concuit No. Location Remarts , C13CC5319 Safeguards S1cq #1, Elev 773, Room 565 Access Centro 11ed { C1304C36 Safeguarcs Slcg #1 Access Controlled I 3 Elev 773, Room 565
' .J i C13012998 i
Safeguards 81dg #1 Access Centrc11ec Elev 773, Room 565 C13010777 Safeguards Eleg #1 Elev 773, Rcom 565 Access Contreilec Cl?013679 Safeguards Eldg. "I Access Centre 11ec Elev 773, Room 54 C22GC2133 Aux. Sieg. Elev. 790 Only Rece 170 was Various Rocms Access Centre 11ec C22GC8129 Aux. Eldg. Elev. 790 Only Recm 170 was Varicus Recms Access C:nte:11ec Tne inscoction of Mese c nduits snowec sna: :ney were insta11ec to ne c:nstructicn requirsment anc that elec rical secaratica was satisfact:ry. CC rec:rcs fer these concuit systems snewee sna a:D11 cable inscecticn were made in ace:rtance with the fcilewing
=rocecures:
0I 11.3-23, Class 1E C:ndui: Raceway Inscec:fon QI 11.2-3, 7ercuing anc Spacing of C ncrete Anence Ec1:s l
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i 29 QI-QP 11.10-1, t Inscec: Restrain tenSystems cf Seismic Electrical Sucece: anc QI-;P 11.3-29.1, Verify Electrical Secara:1cn (:ce Reem 565, ! i
; Inscoctice Recert (I.R)# E-1-00134E5/3-34;
,' fer Roem 54, IR# E-1-0013a40/3-34; for Roem . .
170, IRi E-1-0017514/1-34] ! .; Several aeditional cenduit runs were examined in the field to i verify electrical secaration. These conduit runs were located in
- ne cacle spreading area and are identified below:
(a) Conduit C12019632, orange safety train, goes uncer ladoer - 4 tray 716GCCM02, green safety train, at one point and secara-ston is amoreximately 6 inches. At another ceint it goes over laccer tray TlaGC Hal, green safety train, and seoara-f on is aspecximately 2" with a barrier installed between :ne two. (b) Concuit C15R10537, red cr::ac: ten channel, at one cein gces uncer laccer tray 713GC215, green safety : pain, anc secara-1 tion is aspecximately 2 inches.
! (c) Conduit C15311396, blue crotec.icn channel, at ene maint goes uncer laccer tray 7130CCMO, erange safety train, and secara-
, tion in apareximately 2 inches.
- i (d)
Concuit C12G21191, T140CN31 oran green safety train, goes uncer solic tray sately 3 inenes.ge safety train, and separation ts accroxi-d Tne accve are accactacle ser QI-3P 11.3-29,1 " Verify Electrical Secaration" anc Gf bes and Hill Scecification 2323-i3-100 See:1cn 4.11.3.2. Scacing cf power cacies in trays is to felicw recuirements of Gibcs anc Hill Scecificatten 2323-Ei-100 sec-icn 4.2.1.4. , wnten i in essence, states :na; minimum scacing between ;cwer cacles sna11
- e a minimum of one cuarter of the ciameter of the largest cacle,
$ ice scacing of caoles in :ne follcwing trays anc recms were censicerec :s met: this recuirement: " Tray Numneas Lccatien Electrical Secaratica . Veri fica:1cn < co- O!-3c il . 3-2g T120AEA05-12 Reca 174, Aux. 31cg'. T120AEE01 Recm 174, Aux. Elcs. Nc ccmolete 7110AA01-05 Nc: ce=slete Reem 171, Aux. 31cg. Nc: ccmolete T'.105AA30 Rocm 5a, Safeguarcs ileg. Cc=clete 1 i , i
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,~s T120A8 96* Room 219, Aux. B1dg. Agorax. 90".
complete T11GAA511* Room 214, Aux. 31dg. Complete T120ASA9a* Room 241, Aux. 81dg. Approx. 90% complete . ' T120ASA47-50 Room 241, Aux. Bldg. Approx. 90% complete T120ASE93 Acom 219, Aux. 31dg. Approx. 90%
+
comple a . t i
" supported Asterisked- trays contained verti' cal" runs of cable. Cables were ' properly by Kellem Grips in accordance with Q1-QP-11.3-50, "Canle Grip Support Installation Inspection."
t A review of some of licensee Inspettien Recorts (irs) tha were performed for QI-QP-11.3-29.1 " Veri fy Electrical Separation" f showed that I.R E-1-0024985 of 2/28/84 and IAE-1-0036072 of building. applied 4/12/84 to the same room (room 219) in the auxfitary
'~
Neither of these reports indicated that Mey were performed as a result of a specific job or Inspection Item Removal Notice (IAN). Both were. designated as final inspections. It is. recognized that the Itcensee can perfornr re-inspection as deemed
- necessary; however*, it is considered that there snould be only one final inspection for post construction work. If additional final
(- inspections are required irr this area for IAN's, Design Change Ausnorizations (CCA), etc. , they should be referenced in the remarks section of the IR. The one " final" electrical seoaration inscoction, which could be performed concurrent or before QI-CP-11.3-40 " Class IE Electrical Post Construction Verifica-tica," would indicate snat electrical work in tais area in almost ecenlete and would aid in triggeriny the performance of QI-CP-11.3-40. The Itcensee stated Mat tnis area would be reviewed clarified. to see if the " final" inspection in this area could be
- c. Observation and Conclusions
- There annears to be a good working interface between construe fon inspectors and the craft. For the most part the electrical construc-l tion inspectors wars areas. aopear to be knowledgeaole and conscientious in their The inscector encountered no cases of hostility or harassment with the Comanche Peak Project employees.
E. Design Activities / Design Control .
References:
QI-QAP-11.1-23, Rev. 23, l Fabrication, Installation Insoections of ASME Comoonent Suncerts, Class 1, 2, and 3 [ '_n- m,~r~rm*m*7 . gpeeseeN" '* ^~" - "l 2_f- & 'J' ~
.. ~ ~. .._ . . . ... - . . - . . . . - -
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i n ~ OI-CAP-11.1-23A, Rev. 5,
-" Installa-icn Ins:ections cf ASME Class 1, 2, anc 3 Snu:cers P cecur AB-5, Rev. 5, A Simelified Metacd for Casign anc Analysis cf Small $1:a **
Piping TUSI Engineering Guideine, Section IV, Base Plates, Rev. 11 CPSES, XCP-ME-10, Rev. 1, Pipe Sumpc-. Adjustments TUSI CP-EI-4.5-1, Rev. 9, General P : gram for As-Euil: Piping verifica:icn TUSI Engineering Guiceline, Sect:sm II Sec.icn II, General Engineering __ Criteria for 71:e Su=:ce. Design, Rev. 3 Specifica:1cn 2323-MS-46A, Nuclear Safety Class Rev. 5 Pipe Hangers anc Su::cris Construceden P-:cacure Field Surveys 35-11SS-CCP-9, Rev. 4, TUSI CP-EI-4.5-9, Rev. 1, Perfermance Instrue:1cn for Piping Analysis by SSAG TUSI Engineering Guideline, Hilst Cencreta Anence Section V, Rev. 3 Ecits AOL3IPE, Artnur Sta:1cInc., O. Little, and May Dynamic1981Pi:e Cesign anc Stress Analysis,
- a. General !
The criani:a:1cn precurement effor*.sof the weregeneral definecsitsin engineering. ::ns: uction, anc
- recocure, the P- =recacure CP-E.;-S.C. By :n1s Staam Electric Station (CPSES) design anc engineering. Ject ties are ncrmally colegated :s Gibcs and Hill, WestingneuseThese , ancac:1vi-c:ner
. criani:a:1cas. Hewever, the licensee, (TUGCC) re:Ates overail rits:en-
- sicility for casign activities anc :erf:rms casign func-icns as necessary.
general cirection The TUGC3 Enginesring of engineering Manager is res:enst:1e f:e :ne act.1vities. i FSAR Chacter 3 :revicec the licansee's recutrements structures, ::meenents, ocui: ment, anc systams. The reviewer selectac in off:r ne ces sam:les in at:e su :cr. casign, :1:tng stress analyst s, anc casign
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'l precacure a:olications to verify tregram imclementation, to ensure site 3r:cecures, site interface precacures, anc cesign interface procacures satisfy NRC recuirements anc if censee c::msi:ments.
- b. Review Effer
- The reviewer held discussions with the design engineering personnel in i the sige succort group to cetermine whether they understcod the
{t anclicable cesign design control parameters that procacures; wnether they were acte to verify were wicin :Me applicacle criteria and/or
! design' specifications; was independent and whether the person doing the design review reviewer from the individual who perfomed the casign. The , also held discussions with the engineering personnel in ce !' piping system Site Stress Analysis Groun (SSAG) to detemine whetner cey pe formed ceir worr, activities in accorcance with es.atlished ! instructions, procedures, and saecifications. The seismic response ssectra vith resoect to coerating tasis ear.houake (CEE) and safe snutecwn earthouake (SSE) were discussed wita :ne res:ensible engineers.
It was noted cat :nese seismic ressonse scoctra were furnisned by :ne A/E's (Gibes anc Hill, Inc.) home office to :ne site stress group to be used for the piping system analysis. The followi g stjar areas were reviewed to determine a conclusion: ' (1) IE Bulletin 79-02, Pipe Susport Ease Plate Designs Using Concrete
' Expansion Anenor Bolts, Aequirements I
J (a) Fac.or of Safety for Concrete Expansion Anchor Bolts Design A review of the Pipe Support Engineering Guicelines Manual, Section V, revealed :nas a factor of safety of five (a c=re esnservative value) has been used for estaaltsning the allowable loacs (tenston and shear) for :ne wecge bolt calculation. In accorcance with the vender (H11:1) design manual and the NRC IE Bulletin 79-02 requirements, the fae:ce of safety of four esuid be used (Comanene Peas, pine succer. i installations use Hilti wedge bois only). I
- ne safety factor usec exceecac the requirement.As noted acave, l (b) Pipe Suncor Ease Plate Design .
IE Eulletin 79-02 states that pi:e su::=r. tase place flexibility be acesunted for in ne calculation Of anchor tol: 1 cads. Discussions with ue ressen.st ble en incicated cat the :1:e succor grcus :ersonnel c: gineers ::nsicer base slate fl exibil i ty ints :neir dest;n calcula:icas. Finite element me nod (base plate flexicility ::nsideration) has :een usec f:r non-typical (otner nan f:ur ancnor :olts in ene plate) base : late analysis. FUB II pase olate pr: gram nas
- late)teen :aseutill:ec plate for all typical (f:ur anener =c1:s in one analysis.
The FUE II =r: gram generally i
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- Or: duces loads which are acout 25'll higner than the leads
~ gen'eratec by :ne Finite Element Method. In fact, many base , plates were analy:ed y the more conse-va:1ve pr: gram, PUB II commuter accifcation (developed by ITT Grinnell Corp.). This 1 acornacn exceecs the NRC requirements.
(c) Anchor Bolt Tension - Shear Interaction *
, IE Sulletin 79-02 permits a formula to be used for calcula-sten of bolt tension-snear interaction. Tht s formula can ce interpreted from a linear di stribution to an elliptical di stribution. Comanene Peak pipe support group has electec i
to all use a linear concrete distribution expansion anchor (a boltconservative accroach) for calculattens. 1
' (2) IE Bulletin 79-14, Seismic Analysis for As-Guit: Safety-Related Pining Systems, Requirements This bulletin states that :ne seismic analysis input infomatica conforms to the actual configuration of safety- elated pising systems.
t.icensees are reques ed to verify: pipe run geometry; succort and restraint casign, locations, function and clearance; emoocnents; ic:ations anc wei pipe at.acaments; and valve and valve coerator site pipe supper gnts. To ace:molish the acove recuirements, sne grous and the site stress analysis groues are
- resoonsible for verification based on as-built configuration. The
- i as-cuilt configuration is identified by a field survey team. This i field survey team, which consists of snres surveyors anc one QA ,
- inspec.or, t s to perform field measurements by utfit:ing ecutoment 1
such as transits, levels, theodolities, etc. The nign accuracy of j :ne information odtained through the field survey is a hignitgns for isolementing the IE Eu11 sting 79-14 requirements. (3) Alternate Analysis for Small Sore Piping Systems The reviewer examined :ortions of procedure AE-5, A Simoiifisc Meuce 1382. for Design and Analysis of Small Si:e Pi:ing, Rev.1, May i It was noted that me precacurs was develocec :y Gibcs and Hill, Inc., in a very conservative manner in tems of :nersal loac
! and seismic load calculations. Furtnermore, accrextmately 3C'. of ; small bore (2 inenes anc uncer 1 anc 1C". in Unit 2 are analy:ec) by : low energy pi:e lines in Uni I Me Alternate Analysis !de nce (i.e., a simolified moucc for cesign and analysis of small si:e picing).
c:mouterThe balance of small bore sizing is analy:sc by :ne acclication. (4) Rigorous Analysis f:r Safety-9elatac Piping Systams Mos of the riger ys analysis me:ned. safety- ela:ec :intng systems are analy:sc by the i
, analysis is one of ue typical The c:msuter 2rogram involvec in the programs :eing usec fn sne I
,, , . %m egws- e W9 *WM*** N _ ,_,_ _ ..- - -.-
~
__.__f; _
-- .. ~~
34 m incustry. Cesign This c:m: uter er: gram, ACL?IFE Static anc Oynamic Pice., .. anc 5:ress Analysis, has caen covele:ec anc u:catec :y Aruur D. Lt :le, Inc., since ne early 1960s. i (5) Iterattve Design Process 3 l j . -
; The reviewer held discussions with resacasible licensee remresent- t
< . atives systems. in the area of safety-related pipe succorts and piping I It was noted that the Iterative Design Process was
' utilised for isolamenting the casign of pipe suopor.s anc the analysis of piping systems.
In accsedance w1:n the Itcensee's
, i cascription: ' "ue process for the design of piping and supports is iterative in nature. It is unrealistic to expect to design
![ # piping and supports to satisfy all apolicable requirements the j first time thr ugn the process. Suca an iterative design asproacn is employed urougnout the nuclear incustry, anc is utili:ed in ne casign of other nuclear c:moonents as well." The reviewer noted that ene practices at Comanene 8eak are not unusual c:=narec t= practices at ouer nuclear facili-f as in tems of using un iterative casign pr= cess in the area of cesigning pipe su;:: orts and piping systems. (6) Review of Design Calculations for Pipe Suoper: < Suonor- No. Pine 51:e pisine System AF-1-002-705-533K, Rev. 3 10" dia. Auxiliary Feecwater CC-1-152-701-A43Ri Rev. 2 16" dia. Comoonent Cooling SI-1-031-709-A32R, Rev. 2 12" cia. Safety Injection i SI-1-029-702-5323, Rev. 2 24" cia. Safety Injec-icn BR-1-A8-001-005-3, Rev. 1 2" dia. ! Heren Recycle
- The acove design calculations were rancomly selectec anc were
- par.ially aole c
- ces reviewec for conformance s analysis cri eria, a: cite-
] Furuermore,, NRC requi rements, and ue licensee c:mmi nents. nese calculations wert for uorouganess, clarity, consistency,evaluatec anc accursey. curing ue *eview Gefl ec-t en i criteria usec for succort easign were ciscussac with the reston-sible tion engineers and were partially verified. Welc site calcula- t i acecuacy. snuccer si:e determination were also veri fi sc f:r and In general, One cesign calculations a::tarec s ce t acecuate in terms of using casign intut, e f erence, units (cimension, force, anc mcment), acuations, :acles, anc 54etues. i
! . )
j 1 y ,. esp. w - , , - F . ""'
" " ' ' ~
. ._ mm - - - - ' - - ~ ~~
, _ - t .:x . . :. w ,
\
s 1
-. i 35 i
(7) Review of Stress analysis for piping Systems Calculatten No. Afcine System A8-1-19A Safety Injection ) 1 A8-1-30 Centainment Spray t A8-1-59 Residual Heat Removal and Safety Injection AE-1-135E ,Auxfitary Steam and Main Steam AF-1-SB-006 Auxiliary Feecwater AF-1-53-007 Auxiliary .:eecwater i Tne acove at:ing stress analyses were partially enviewee for c:nfemance :s casign s:ect fica:ica, anoitcaste c:ce NRC recuirt-s6nts, anc the I tcensee commitments. These analyses were also evaluatec for snorougnness, clarity, consistency, and ac:uracy. The NRC reviewer examined portions of ne seismic' incuts to be used in the stress analysis. These seismic inputs in tems of pe-ices versus ac:eleraticas fr ar the carrssoonctng floor essnonse
- spectra curves uncer CBE and SSE concisions were partially verified for accuracy. Fur.hermore, the reviewer held discussions with the responsible engineers to ensure that seismic anchor movement, noz
- le themal movement, and valve crientations were preserly consicered in ce stress analysis.
)
Curing the review the reviewer examined piping system AF-1-58-006. This 3/a" diameter ven: and crain sige was analy:sc for succor. Ptquirteents. Results frem tne analysis revealec that no pice succor.s were neeced for the pipe. However, ce reviewer notec
- na a C in ne pipe moonen: Mocification 24: a piece of tee pipe Carc (CMC) No. 90557 was issued :s crain system. The pipe succor.(greus) was accec to :ne vent anc serf: ming catailed evaluation. Tne responsible ac:ac:ec :nis CMC witacut engineer stated ua cis CMC was reviewed by a well cualified engineer. Easec on
- i bis engineering jucgement, no detailed calculattens weet escuired.
The ins:ect:r indicatec cat a catailec evalue:f on f r :nis CMC was neecec.
- s ensurs sna: In accision, a samoling program snoule te initiated
' no c:ner similar CMCs were ac:actac wicou
- e'"': ming ::ct sentative detailec evaluation. The ressonsible i f cansee et=rt-for ue vent ancimmeciate crain sizingaction system := cerf0m cue todetailec calculations
- ne accitica of sne CMC (No. 90557). Fur.ne mo rt ,
initiatec to review 50 c:ner similar :acxages.a This sameling sattar cr:gess will was i= ec i
- e icentifisc :: :ne C manene Peak Enject Cirect:r for followuc.
\ .] i.
.--a
,pp.D et" I'h'.#*"**N- - - ~
ss - -
-.,_,-9-...,-9+ ~ ~. '
9'
' ^ ~ ~
y-- --] l . ? l l - 36 m Results fr:m de cata11ed calculations revealed that no ;isa ' su:mor.s were recuirec original evaluation incicated. f:r ne vent anc crain piping system as the snewec that Results from the samcling program t similar packages. no discrenancies were tcentifiac for :ne 50 einer i Piping system AF-1-58-007 was partially reviewed. It was noted that portions of the calculations were not performed in accordance
' with esaolished procecures.
noted. Some sinar satnomatical errors were reviewer. One CMC was not addressed arcoerly by tne licensee The pipe sunoort grouc reanaly:sc this 3/a inen piping system by hand calculations (alternate analysis) and c:sputer application (rigorous analysis). Results' fr:salso the two by analyses were consistent and conservative. were required by ne analysis. Loads used forFour pipe supports + succor. cesign were verified and were found conservative. Tht s sa-ter will be fcmarced :s ne Comanene Peak Project Of rector for followuo. (5) Field Inspection /Verifica:icn The NRC reviewer performed a field walkdown at the l'91 1 esntainment building area and noted the following c3screcanc:ies: Sumoor No. Status ' C"-1-218-012-C33X Sauceer cannection coster keys missing
- C 295-005-C33R Sway strus installed over 5 sclerance C7-1-038-456-C52X
{ Snucher c:nnection entter keys cissing; t no washers in rear cracxe: C~-1-117-405-C52X Snucher connection estter key sissing C~-1-117-415-C52X Snuccer safety wire treken CT-1-053-444-C52X The south snuceer was ins:alled improcerly CC-1-046-020-C55R Snuceer ::::er keys missing ; 4 1-096-705-C52X Snuceer safety wire brenen F+1-102-002-C52k Snutter c::$er key missing; neecs i relative acJus =ent en snuceer F*l-102-002-C32X Snu:cer :: ter keys no: :en: MS-1-151-025-032X Inu:cer instatlec over 5 salersace )i - CO-1 82-056-003-3 J Sauccer esld setting over :ne limit l l I f*.w.. *** * " * "' _ - - _ - - - . _ _ _ , _ . _ , - - - ~ ~ ~ ~
e t 37 - 3 CC-1-RE-055-CC7-3 Snu::er cele se::ing ever the Ifmit CC-1-RE-053-007-3 Spring hanger :sid setting ineserect
, (15 lbs. versus 11 lbs.)
l The acave eine suonorts discrocancies were verified w1:n the . licensee's CC inspecur in accarcance wita detailed crawings. All
- us amove pine suonorts were vencor.cenified and were previously i tnssected my the Itcensee QC insnecurs. The licensee moresenu- ,
. tives sutee taa: a final waltcown insoection/ verification for all i Dine succorts is to be isolemented in ac:srtance witn procacure i C7-CAP-12.1, Inssection Criteria and Occumentation Aequirements Prior to System N-5 Certification. .
i The majority of the discrepancies anneand u te since arctiems wnich
.s ne esuld to easily reoaired curing :ne final insoection prior system pressure test.
Two of sne discrecancies were more serious in that rework or reanalysis of sne support woulc be. recuired crice s ac:entance. These i suonans are M5-1-151-025-C32K, were not Rev. 3 and CC-1-Z95-005-C13A, Rev. 4, wnich insulled in accorcance with the cetat ted crawings. The fact that these two sumoons were inspectea by CC is considerec as i a setentf al en1'ereement f em. j ' (9) Gesign Consideration for Piping Systems Between Safety-Related and Non $4fety-Related Buildings, , t 3 The NAC reviewer held discussions with the Itcensee represanu-stves in the area of piping stress analysis and pice suoso n design. I Stress Analysis No. AS-1-135 I for the Auxiliary Steam ! ! anc Main Steam System was partially reviewed and discussed with !
- re'soect ta design considers
- 1ons between safety-relatec anc non safety--elated tu11 dings. ,
i hign energy line and safety-related.The piping The pipe system run sur was s from classiffec Me as l Turzine Builcing into tne Doctrical Centn1 huilding. Since ! seismic classifications for tne two buildings are ,cifferent, we cri different. . aria used for the pising system analysis snoulc also te The fatture of the pipe in :ne Turcine Euticing may if the siziny system was not procerly analyzec
-esconsible The and ce
- . evaluation wita regard to no amove cancerns.iicensee ascrosenutiv i
icentifioc u :ne Comanene Peak Project Direct:r f:r resslution. This matter will :s (10) ( Inte :reutica of Tolerance for Snuceer Insu11atf =n Ouring ne field review, i three reviewers interviewec :ne licensee's CC inssecurs wie res:ect s ueir inter:reu:1cn five cegrees tolerance recui rements for stru anc snu::erof { insul!ation. These CC ins:ectors angearec :s te c:nfusec wi:n 3 t ( .)
.no interproution of ue talerances en the ceuitec crswings,
) i m_ pg1,-4en % *
.._ . . _ _ - w -- - - - - - -~ -------,wm-mm----cr--- - - - - - - - + - - - - , --r- ----s- ,- -n,-a,e----nn -+ ,-.----,--,---.--v - ,+r-,m,-- re-w -me- ,w--
e,sm",w+~m---- 4, w
.q wm -
n ___a ..a._
. _ _ _ . . ..__m .~. -- ---
33
- I N ,
The reviewers he'ld discussiens with wit: regarc c ce accve c:ncerns. ne licensee recrosentatives licensee will revise :ne inscoc tonItcrececure was caserminec :na ce
- = clarify the i
s: ut/snut:er installation :clerance and will c:acuct a training for allsatser This CC ins:ee:ces will be uno a o involved nice sucoce: inssections. teentified :: :ne Cemanene Peak Project
- 1 Direc:ce for felicwuo. *.
(11) < Final Acjustments for $sring Hangers and $nuncer Settings I The reviewers held discussions w1:a the resconsinle licensee recensentatives w1:n regarc to isolementing the final adjustments i for soring hange s and snuccer settings. It was cetermined that, i after the fuel loading, the Itcensee CA startuo greuc will perform , the final walkcown inscoction to ensure that all spring hangers anc trougn:snuceers te acjusted s premer cosition. This matter will be followus.to :ne attention of C manche Feak Freject Direcise for (12) 7ecanical Training The reviewer held discussicas with the essnonsible pies succort engineering
- neir wort (PSE) personnel to cetermine wnether : hey performec activities in accartance with estaclished crececures and scocifications, and wnetner :ne casign engineering personnel I
received anc proper training with respect .a tecnnical applications NAC requirements. 4 A review of the training recsed revealed that since 1980, one PSE personnel have received extensive training activistes in terms of
- ecanical soclications anc c:ce inter,.retaticas.
Par.icas of :ne training c:urses are 11sted as fc11cws: QEt Ceurte 4 Attencanes (Enetneers) 1 (a) C6/16/80 Inte cuction to Nuclear All ! Coces anc Stancarcs,
- CA for Engineers (5) 10/13/30 ASME C ce Seminar
\
10/14/30 Ali (NF Cesign Shiloseny)
' ' (c) 04/12/31' Alternate Analysis we ece 25 for Small 51:e afcing 4
' (c) C5/21/31 Vent anc Orsin afstag
- 3 Seismic Cualifica ica (e) C5/1*/32 Oasign Verifica:ica C1/13/32 Pr: cess la J
i
------- - - -^ ~
gw _. m ._ . . a._ x ,_. . _ -
~
19
. l t . .
- 39 (f) 07/la/22 3
Pi e Su::ce. Snuccer 2a 07/15/32 Installatien (Instructec by ~ ~ ~ ~ Manufacturer) ' (g) 07/27/82 Analysis of A!ME Class 16 2 and 3 piping * (h) 11/12/82 Seismic Analysis of 65 1
- 11/15/82 Pipe Suceerts.
11/17/82 4 (i) 06/14/83 Finite Element Method thru 19
, (including ASME 1, 2 & 3 ;
C4/06/83 piptn analysis) i
! (j) 06/29/83 Current Version of AOLPIPE 9 '
Comeuter Coce (Stess: i Analysis) (k) 11/17/83 Cuality - It's Your Joe All ' (1) 03/08/84 Sauncer Recuction Program , . 6 (s) 02/19/34 Stability P=celes in the . 26 i Design of' Pipe Sunsorts ; The ateve training activities in the area of pipe support designs appeared as be effective and.well administered. Tais osservation was succortec by the extensive discussions with the esssonsible ! of the design calculations. engineering sersonnel anc by reviewing u
- c. Conclusion 4
Discussions ring personnel with the responsible personnel revealed that ne enginee-involved systems and at:e succorts anneared to be knowledgesele.in A review cf ne ari ' por. ions of the alternate analysis criteria and rotated documents was performed. It was noted uat were conservative. ce setMods and pr cecurts usec in :na i criteria ! i A review of the eleven calculation pacxages incicatec uas c:mouter anoticasicas wert extensively usec in ce stress analyses ' expansion ancnor co,lt calculations. pine succer. cesigns anc, base slate anc.cen; were geoc. Oestgn calculations, in general, ( Quring the enview, 3 I tions were found in many arias of cesign and analysis.ce NRC revi ! t tive c:nsicerations inclucec: facter of saf aty usec for c:ncetta These c:nserva- l exsanston ancace soit '
, calculatica, c:mouter program (PUS II) usec f:r
% ase plate analysis, wete striss allowacles for weieing c:nnections, 4
I I I
-, _ _ _ . _ . . . -----~ ~ ~ ~ " ~ ~
~ ~ ~ , . , . . -n~- , - n-
m
- -=
m. _- - - q
. v--
\
40 I l 6. i alternate analysis for small bore pising. and set:mic loacs used in casign and analysis. Tnese c:nsecutive cesign ::nsictra:icas are c:nsicered strene:ns in :ne acclicants pr: gram. Finally, :ne reviewer ; nc:ed sna: :ne geogra:Mic loca:1:n of Comanene Peak site has ne lowest
- seismic risk specified in Unifersin
- neEutiding Unitec Cece. States in ac::rcance wita :ne critaria i A field walkdown f aspection perfomed by the reviewer has resulted in various discrenancies for la pipe succor.s that had been creviously i' insoected my :ne licensee's QC inspectors. This item will :e referred to tne Comanene Peak Project Of rector .o perfom subsecuent followun to ensure taat i safety-related pipe suoports are installed in ac:orcance with design drawings and to verify tnat c:rrective actions witn resne-- ;
t to the aforementioned discrepancies are acequately implemented in ac:arcance with estan11sned procacures. ' 1 14 Installation of Safety-Related Fluid Systems
~
References:
(a) CA-CAP-11.1-25, Rev. 14, "ASME Pine Fa rication anc Int.:s11ation Inscoc~ tions* (t) CI-CAP-11.1-23, Aav. 23 "Facrication, Installation Ins:ecston of ASME Componen: Supports, Class 1, 2, and 3" (c) CI-CAP-11.1-25A, Rev. 5 "Insta11atton Insmec:fons of ASME Class 1, 2
' and 3 Sauccers" i j
(c) C7-CAP-12.3, Rev. 3 i
" Testing Phase Quality hssurance Func,1ons 1 l Prior to ASME C:de
- Certiffca:1on anc ;
Stamning" - (e) CP-CAP-12.2, Rev. 7, " Inspection paccacure and
- Ac:astanca Cetteria for
' ASME Pressure Testing d
- a. General q 4 T9e review c:nstruc.
of tais arta ionwas direciad as it23 assessing the adecuacy of the [
- {
11:ansee's program safety-relatec :er.atnec := insta11atten of sne slant. fluic systems recuired for safe coeration an: shutd wn 4
' Of
- 1:n of insta11ec Thesyssams assessment was uncer aken :nreugn selective examina- ,
Otter.ine wne:ner :ney wereanc insta114: snec ten in rela:ac ac:tvities to ac::mcit ac: rtanca wita gcad engineering practi:a anc with licenses ::mi:=ents and NRC recuire- ! l ments - inclucing :ne recuirements of :ne acclicaole c:ce. ASME T
* * * * " ' * " ,,,,n,, -,e , + **L * * * " * * * * ' ' " " " ~
--..z _ -.. .;
+ -. - . . _ - . . - -
. _ - - -- -----A e
41 l Sectica III. The enview in :nis area cic act uncertake :: evalua:a :ne If eensee's final chects anc analysis of system piping in ac::rcanca Inscacticn and Enforcement Sulletin 79-14, anc cic not examine attacn-
- sent of the fluic systams to concrete building structurns.
- b. Review Effer. *
(1) Tour of Areas Can.aining Safety-Related Fluid System Cocconents Tne reviewers scurec ne Sa feguards, Auxiliary, and Reactor Su11 din'gs and the Service Water Pumaing Station :: ocserve installed safety-estated fluid systas esmoonents for any visually assarent signs of unsatisfactory or questionable items such as visual weld defects, undersize welds, imorecerly or insufficiently succor.ad piping, camage to more suscactible succort camsonents (e.g., snacars, snuceers), etc. cor esion, missing or 1cose fasteners anc icentified curing the tour.Only one item of c:ncarn, escuiring follow us, was A spring can piping sue or. was found to have a significant buildup of rust insica the can on ene spring. TheSerial iCantified licensee was informed of this sering can, wnich was No g42-12. The rusting in this item cid not assear to be so severt as to significantly incair fi;s function but the course of the rusting and its significanca to the functioning snould be evaluated further by the ficansee.
- i (2) Control of Welcing Ma arials Tne reviewers examined the satarials used in installation of safety-et14:ad piping system 11canse
, c:moonents escutrementsatanc thegoceissuance staticns is verify c:molianca witn ::ce practice.
- s :ne acequacy of the licensee's:Scecific attention was directac segregation, identification, including c:nsumacie inser.s and contret of filler metals, pick-upeven s:crage of low hycr: gen electreces to limit mois ure prenaration af issuance rec r:s hancling of returnec filler metals tecumentation of cur *en welcer qualifica:1cn limitations The reviewers critec in (2) acave, also ccserved anc plantactas : urse in :ne clant, as das-areas en ,artc for s:ecific itam inscoctions catari al s. for evidence of inacacuately c:nte:11ec filler
.eleing matarials No evicence of uncan r:11ec or immrecerly c:ntrollec as ceservec. The ficansas welcing matarial
-3 l
l
-o : ... ...~.n~... s .:..:.. =a- --~--w m.u - . - -- - .
_ , e .v .-
. .m - m.
42 3 s . c:ntrols ecservec cy the reviewers met or exceeded c:ce require-ments anc ge:c prac tce. ! (3) Piping and Su:perts The reviewers visually examined examoles of insult ed runs of safety-related sicing and associated supports to verify sney wert in accarcance wie good engineering practice and taat they were in esen11ance with c:ce recuirements and with Itcenset crawing and stococure nouirements. Three runs were selected which hac most or all of sneir final ' acceptance inssections c:mpleted. Two of these were nearly ready for the final cede review esquired for ASME certification (referred to as N-5 certification) that the installations comniete. certification were in accordance with the ecce. The cied had the The licensee cantracted the piping and sue:or. insultation wort to 3rown anc F.oot, Inc. This contractor was rescensible for assuring c:meliance with c:de requirements, including octaining
- ce inssec.or car.ification therefor (on N-! Cata Re:or.s),
t.icensee procacures applicable to and utiti:ec by the reviewers in the examination of piping and succorts were examined for c:mnit-ance with coce riguirements. The precedures were as follows: i (a) CA-CAP-11.1-25, Aev. 14 "ASME Pine Fabrication and Installation Inspections" (b) OI-37-11.1-25, Rev. 23 " Fabrication, Insta11ation Inscoction of ASME Comconen: Suncor.s, Class 1, 2, anc 3" (c) QI-CAP-11.1-23A Rev. 5,
" Installation Ins:ections of ASME Class 1. 2, anc 3 Sauncers d (d) C F AP-12.3, Rev. 3, " Testing Phase Cuality Assur-
- ance Funettons Prior to ASME Cece Car.ification anc Stamningd (e) CF.AP-12.2, Rev. 7 "Inssectien 7-:Cacure anc
; Ac:entance Criteria for ASME
( Prissure Testing" l t
- , - . .. - . . . , . m. ., ,.m m. ,,q, , _ , . . . . . , , , , . p,.,.... _ . .: ._n.. .
e - o 43 1
' i
~
The runs of :toing anc succorts installed tnat were examined by' i :ne reviewers were cascritec on isometric crawings. The runs examinec, icentified by the crawing numcars, and the examination l caects sace py the reviewers are as folicws: k: 3" Containment Soray (ASME Section III, Class 3), Orawing
- BR7-CT-1-58-019, Rev. 6 -
The reviewers visually selectively examined the insulled ' safety related pining ta verify the following in ac:orcance with the crawing, c:ce, procedures; and good engineering practice: s : configuration apparent pipe si:e 1 - valve identification visual appearance of welds heat nummers on pieces 2,10, and 18 anc serial nummer on valve piece l' were traceaole tarcugn insu11ation recarcs ta original receipt and accesunca recarts
! The reviewers examined the records for the above piping ta verify the following in acesrdance with cace and procecural ! roovirements: -
l i proper all installation and inspecst'on steps c:sslated for components I - i - mill *.est reporta for all materials hydrostatic testing . ' M: 1" Reac.or Csolant (ASME Section III, Class 1), Orawings SR7-RC-1-RS-10, Rev. 4 and SRHL-RC-1-R8-10, Rev. 2. The reviewers visually examined the insulted piping anc suocerts ta verify the following, in ac:arcance wita the artwings, c:de, precoeures anc good engineering ; ractice: configuration assarent pipe size snuocer and seeing can si:es l
- offset for snumeer RC-1-015-707-C11X saring can settings "
- visual amoearsnes of welds 1
si:e of piping welds succort serial numoers 19010,17791 and 1~739 tracescle
- ts insu114 tion anc receiving recorcs heat nuncers on material pieces 1 and 12 inat were i
- traceaole to ac:acuole mill tes . es:or.s serial numoers on valves 1RC-1057A anc -50!!A :nat wers traceanle insoection recarcs to insu114 tion anc ac:estacle receiving
{ 4 _ , _ ..,, , - . . . . - - - - - - - ~' "' ' ~ - ' ~~~ ~ 3
.?
__ -.- ~ ~=- - M """' W :" ""~~ ~ ~
. o "
44
~
r s visual accearance of fastaners _. .-- snu::er = ins and washers evicence of camage to or catarieration of any ::mconents The reviewer examined the rec:rds for tne 400Va 212ing anc succorts :s verify the following, in ac:oreance with c:ce and . procecural requirements:
- procer installa: ton and inspection stans ::moleted for piping hycrostatte testing 3gn: 3" Auxtlf ary Feecwatar (AS'ME Sec ten III, Class 3),
10" Drawings 8AP-AF-1-SB-006, Rev.17 and SRHL-AF-1-!B-006, Rev. 3 The reviewers visually examined the installed 2131ng and - succorts to verify ne following. in ac::rtance witn the ' crawings, coce, or:cedures anc gocc engineering ;ractica: c:nfiguration accarent pipe si:e
- snuncer si:ss and setztngs visual appearance and si:e of welds serial nuncer on valve 1AF-031 traceacle to accantacle receiving recards '
snuccer sins and washers evidence of camage ta or caterioration of any c:mconents Note: Heat nuncer traceanflity c:uld not te enecked on the saterials and weld qua11 y c:uld not be caected entirely satisfac crily as ecs: of the c:moonents were painted. The reviewers examined the recorcs for the acove piping anc sue orts precacural srequirements: verify the following in ac:se:ance witn c:ce anc ' preser installation and inspectica stans c:moleted for piping
- nycrestatic tasting I
The licansee's precacures and installation accearec :s generally meet or exceed Me acclicaele recuirements anc were in ac::r:ance with gocc engineering 2Pactica. Recorcs provec reacity retrievacle anc ::molete. Licensee CC insmect:rs wna , 1 ac::scantee installations sne NRCknowlecgeacle. a:cearec reviewers in :nete examina:f ns of :ne Cne tsam of c:ncarn was notec - it was not clear waa; scleranca was accliec to snu::ers anc sway struts 134: were instal 1ec wt:n sffsets or l
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- aragracn E (10) . .
(4) Residual Heat Removal Heat Exenangers (RNR Hxs Suggorts) The reviewers recuested the licenses to icentify anc se:vice for
- review the molting requirements, the crawings and the installation
- recarcs for the RHR Hxs The drawings and some of :ne installa-tion recores were prov.ided. The colting requirements were not icentified and the welding rocceds were not provicec ey the esmoletion of the inscoctor's visit. The etcseds anc information Mad been requested about 1 to 2 days before the end of the visit and Itcensee personnel indicated insufficient time was allowed to provide all of what was requested.
The reviewers examined the RHR Hx sun ce.s for visual weld cuality (size and location were not checked) and insu11ation of bolting. The weld cuality acceared satisfactory (in acc:rcance witn ecce requieteents). A few nuts were seen to be ve y icose, witn many tarsacs exacsed netween the nuts anc tar surfaces against wnien they would signten. Also the threads between :ne icosa nuts anc tigntening inadvertently). surfaces were ,noted to have coen painted (ascarently N The status of the final inspections is be performed on the Hxs was unclear, but the reviewers wert informed tnat a final inscoction of welds be performed. and to verify that bolting was in place and remained to As already indicated above, the installation etcceds for n e Hxs did not accear to e reactly retrievacle and bolting etcuirtments were not react ly identified by the licensee. This accears to to c:ntradictsry to the findings of the general finding of sne team.
- c. Conclusions Based on sneir examination and findings cascribed acove, tne etviewers generally conclucac snas sne licensee's pr: gram for insul t ation of safety-estated fluic systes c:moonents assures c:mpliance with escutet- .
wents, c:Immitments anc good engineering practica. As tneir assessment
.as ine:molete rtlative insu114 tion of tne Hxs describec & cove, ine reviewers eslative etc:mmenc to suca accitional evaluation u c:melete tne tytew c:ssonants.
Peak 7 eject Of ractor for followus.This will ce tcentified is tne C:manene J
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44 G. n CivilCens:ue:denActiviites , 4. General The ecjective of :nt s por.ica of :ne review was to cessemine the adecuacy of the framlementa:f on of taa 11:ensee's cuality control / , quality assurance program for civil construest:n activities. During
- the review selectec cuality assurance recoms were examined to verify the recares were esmolete and res.-ievante. honasts was also placec on '
examina: ton of sne coc.mont control system. The reviner examined si civil design activities, including :ne design c ange crecess, pescate cures anc CA records for comolesse worn activistes such as ne SSI dam, selected caele tray suoports, and wnia and acment restraints; and procecures and wert activities for ongoing wars inclucin of sectactive esatings and testtag of Ricnmenc teser.s. gThe anolication reviewer also intervi ned CC inssection personnel.
- 5. Revtw Effor.
(1) Safe-Shutacwn Imecuncment Cam, Units 1 anc 2 (4) Review of Construction and Quality Con r:1 Procecures The reviewer examined saecifications, crawings, and quality cantest precacures for construction of sne safe-shutdown issoucement $$I) dam. Accentance criteria utt11:sc by the reviewer apoe (er in FSAA Section 2.5.4.5 and NRC re Construction of sae 53I das was c:moletec in $oring of 1977. The can was designed by Fruse anc Nicact s, enginu es, and was c:nstrue ec ey.Er:wn anc Root.c:nsulting cuality The castte c:ntesi inssection activities were serf:rmee by 7 sese and Nicnols anc :ne firm of Mason-Jonnsson and Associates. Quality site cuality assurance assurance was 3Mviced by fr:wn anc Root grous anc :e Texas Ut111:tes Ser<1ces, Inc. , (TUSI) site CA survet i t ance greus. Occuments examinee were as follows: Freese and Nicac1s
. FN-13I-7, Safe Shutcown Isocunemen: Cam drawing numceas FN-!$I-I th Freese anc Niencls scocificast:n P155I-1. C:nsract Saecification for Safe Shutccwn Im:cunement Cam trewn anc Acc: Cons: uctt:n s ::acure 35-1195-C:7-2 :nreugn C 7-8 numoors irewn and Acc: Cuality Cse ret : ::acure C7-CC7-7.1, Survet114nce of $3I Cam Activities
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; anc Asscciates Cer: crate CA Manual ,
t anc Masen-Jennst:n field anc laccrat ry testing prece-cures j (b) Review of Quality Rec:rcs The reviewer exisined selected records watch cocument cuality control instection and quality assurance activities curing construction of ?ne SSI cas. Ac:egeance criteria utitt:ec by ne reviewer are ne procedures listed accve. ; examined were as follows: Records j Records of OA workshoss concucted by Freese and Nichols and Masen-Jannsen and Associates. These wortsaces were , c:nducted personnel. sc provice . training for field ins:ection Weekly fleic c:rrective action recer.s for Acril - July 1976 anc Janua y - Maren, 1977 Results of :uality control tests perfemed en filter satorials, April anc innervious and July 1976. can materials placec between These records inclucac results of
/
' A::er: erg Limits, fi:1c const y tests, anc prec:ce tests perfomec on the imonvious cars materials, and results of field constty, relative censity and seenanical analysiss.tests performed on the Type A anc 5 filter sacerial Stoo wor wrcers Brown anc Roo CA Audit Aecar.s Training recsrcs of CC ins:ection perscnnel i
Cesign Change /Cesign Deviatica neues: num:ers cl-!!, ! r3-52 anc FH-BA 3asec en review of t.5e necets, the nyiewer conclucec : Mat One cam was c:nstructac in ac:creance wita :ne of :ne c:nstraction crawings anc scocificaticassoutrements anc. as sticulatec in the . FIA A. The c:molete, anc Ntrievacle.
- rec:rcs were neas, legible, (2)
Unit 1 React:r !uticing Internal 71:e Whis Aestraints (a) Review of Quality Centrel anc Constrac, ten P cacures The reviewer examinec s ecifications crswings, anc quality
- nt o1 ;recacures for c:nstructi:n
;f:e wais restesints in :ne r anc ins:ec:f on of ne eact:r uilcing. Accactance l
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utili:ed by the reviewer accear in Section 3.3 of The pipe wnf a restraints are ncn-ASME since sney are not attacnec to the ciping. i as part of sne reacter builcing internal The restraints are treated ' structure anc are ccnstructed in accorcance with the American :nstitute of - ' Stael Ccastruction (AISC) Stancard Practicas, as is all otner
- non-ASMS structural steel memcers .
structural steel buticing frames, (cable tray su:ccrts, stai rwell s , non-ASME equi: ment suegorts) in :na power block. incustry practice. This is stancard sne Chicago artege and Iron (C3&I) Comoany.The Oest a installa-wnin restraints tion was performed by Brown and Root. Cocuments examined by the reviewer were as follows: Gf bbs anc Hill Scecificatien 2323-53-153, Structural Steel (Category I) Gfbes and Hill Drawing numcers 0554, and 0535, Aeac:ce Euilcing Internal 2323-51-0521, 1 rue:ure, 0531-01, Pipe Whis Aestrafats TtGC3 Instruction Numcer QI-CP-11.14-1Ins ection of Site Fabrication Miscellaneous Stael and Installation of Structural anc The reviewer also examined the outstanding (unincorocratad) designwere There enanges29 CCAs against againstshe acove specification and crawings . crawing nuncer 0531, 3 againstthe soecification, 12 against crawing numcer C541-01, 1.1 against crawing aumcer 0544, anc 11.agains: crawing 0545. Satellita 3C6 for tae above scoctfication and craw verified snat they were ccmolete and c:ntained (cur ent) revisions of the crawing and casign enanges. :ne laust (b) Ffold Inscoction of Whip Restraints T. er, a wais f ed by a CC c:ce, o n- '2 and M pipe ge. moa . *: are 1 in n 90 mcers 4 s q escac:$bsk :Me on uti. the r ea '
'cing. icca ca crf ~
amin these a. e 4 acumen 1?seJJ . acog anc emf an t. fed levas
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3 i insuse ce ect:r cisclosed of Jam nuts was that there was s me c:nfusien as Ptquirsc. to weert In accitien, ce reviewer ecserved > several loca icas wnert jam nuts had nc: een 3 installed hanc signs. en anchor belts where nuts had only been installed This itam will be turned over : ce C man =ne Peak Pr: Ject Otractse for fellewup. * (c) Review of Cuality Rec:rds The reviewer examined cuality ete:rds c cumenting c:nstruc-tien (site arte:f on) anc CC ins:ection of whip restraint nuncers M22, M25, and M-37 on elevatten 900 of the Unit i reacter building. These records included weld travelers, QC ins:ection of strue::ral statt belting, CC ins:sc*.icn of welcing, eleva:1cnand andas-cuilt 1cca:fondrawings for nesnowing as-cuilt dimenstens,
- acted ina restraints. The reviewer
;er CCA 1*.313 ins:ecticas for insallation of jam nuts recuirec' packages. There was ac res:ciutica decumentac in ne ofR2, wasins:ection nc review, Peak thertf=n, this 1:am will te refertd : Mis itam curing :ne Preja:: the C:manene Otete:Or for fc11cwup and risolutten. The reviewer ree:rds. cid not examine the CEI whip restraint fa:rica:icn
(
) (3) Review of Nanc:nfermance i (NC?) 10453 The reviewer examined NCR 10453 which was d cumentwrittan and :
cis:esition
- ne Uni a are:rlem whfen coveloced curing field e 1 Safeguards Building.
c:m:cnents, art similar = pt:e whi: The sucscr.s, wnten art ASME tne su::cris, wnica wert res.raints. The :ur:csa of limit sevement of the pi:es curing pipe breax ac:1 cants.ersc.ad The around Ptstraints are fabrica:ac effsita by CMI.c:nstructac fr m heavy beams anc ::l' umns wnien wert Ptstraints (wnich Curing field ersc;1:n of :ne was ac::melisnec by Er=wn anc Rect) cracks cavelocec in welds wnica attached small (6 inch Oy 9 inen) gussat: platas .
- nnectionsthe c tercued.
lumns and teams wnen the belts in ue :aam-: lumn I were with CC ins:ecticn persennel.one reviewer exa:sinec the NCR and discu 1ve ac-i had been revisec Review of the NCR cisclosac :na:on
' . :s =anges :: five times. SCme of nese rivisiens resultadit u e ;rt:lem.
C:ner revistens wert:ne ::r testve ac.icn aftar fur..ee eva as a rssult of enanges :: :ne acministrative Mancling of we NCR, e.g. , ::a et: ate all f ur Ptstraints tacn restraint.un:ar one NCR is lieu of writing se:arata NCR f:r cis:esitica of NCRs. These ty:esofof revisions art acrmal :uring Review ne NCR anc ciscussiens wi u etscensible ins:ec :Ps discicsad ca :ne =reclem was resolvec =y removal of :ne camagec gusset platas (i.e., un platas wnern welcs
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,"3 Mad cracked) from the team and columns, acn-castructive examina-tica (NCE) cf tne base metal in the teams anc celu=ns a :ne i scints new wnere the gusset platas had teen attacnec, fabrica icn of gusse:
beam eclumns. plates, and rewelcing of the new gusse clates to the The reviewer examined selected qualt:y roccess
- i i
tr.velers, 77 inspection nece:associatec with repairs of one of :ne restrain - cocuments including CMC 96050 and Brown and Rocs drawing numc MSa-0653-C3I. i The cce ective comoleted in Maren 1984 action to resolve inis NCR was i (4) Unit 1 Camle Tray Supports k (a) i Review.cf Quality Control and Construction Precadures I
> The reviewer examined scocifications, crawings, anc cuality
. centrcl peccecures for construction anc inscectica of canie tray succerts.
fcilews: Occuments examinec by ne reviewer were as G&H Orawing Numeee 2323-El-0713-01-5, Cable Tray Succer. {
' Plan, E!. 792'-0"& 790-6", Aux & Elect. Centrcl 31dgs.
. G&H Orawing numbers
} Tray Support Details, Sheets 1-32323-5-0901, 0902, and 0903, Catle G&H Specifica:1cn (Catescry I) nunce:- 2323-55-158, Structural Steel Erewn and Rect drawing aber FSE-00135, Sheets 1-3, Reference Drawing for Cable Tray Hangers 3rewn and Rect crawing numcer FSE-00159, shee numcers 527, 12500,537,12508. 557, 2S95, 2198, 2904, 2905, 2908, 12580, the camle tray hanger These an the faerica:1cn crawings for succer.s.
cerrascends w1:b :he hanger nuacer. The snes numcer
; cesign enanges agains:The reviewer also examinec the cuss.an 244 CMCs anc 19 CCAs against crawing:ne Then won aceve G&H craving.
~3 CCAs agains: 0713-01-5, 6 CMCs and i crawing 0901, & CMCs and 10 CCAs agains-drawing 0902, and 25 CMCs anc 29 CCAs agains: erawing 0903 The reviewer examinec :ne occument ackages mainuinec in CCC .
! Satellite 206 for the above crawings anc veriff ec :na::ney
.- were the casign ccaclete enanges.and Curingconuined examina: the la.ast (current) revisions of
- ne reviewer notec tha: 1cn cf :ne casign enanges as a result of minor constructica cr: clams.the majority of them wen ori Fer examcle, mes: cf ::;e casign cnanges c crawing 0713-01-5, wnten is the 0
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1 I I cable tray su::ce. loca.1:n lan, were as a result of
! interferences enc: ente-ec ct.rtag c:nstruction anc were } eteuestec by c:nstruc-1:n ;:ersonnel.
requirec reiccasion of scme of :ne su::cr.s These interferences
! shown on : Mis i crawing.
inches. Oftec :ne reieca ec su=: cess were only sevec a few i . t . (b) :
.ield Inscaction of Cacle Tray Su::ce.s i The raviewge, ac::meantec ey a QC inscoc :r, examined i ranecaly selectec cable :-ay su:: r:s 1cca:ac en eleva-tiens 790'-6" anc 792"-0" of ne electrical c:ntrol cuticing.
The 4 suonorts and the ac:entance criteria utili:ac by the reviewer a: pear in the table calcw. I, IBM
' Su=ocr Necer" Acclicacle Su:: -. Tne Cesfen Chance l
i 527 t E-2 (Cwg 0901) CMC 8250 l I 537 ' 0-1 W/Erace - (Owg 0901)-
; N 557 ' # A-1 (Owg 0901) i CMC 9462S CCA 1946 CCA 2537 2295 SP-2 (Cwg 0903) CMC 5047A 2398 57-2 (Owg 0903) CMC 4521 CMC 2546 , 2904 57-2 (Cwg 0903)
CMC 52173. R2 CCA 3494 2905 57-2 (Cwg 0903) CCA 5299-R7 CMC 2516 2903 3-2 (Cwg C903) - 12530 '
! 3 (Cw's 0501-015) 2 CMC 61731 125C0 A (Cwg 05C0-04-5) C4C 67023 l
125C8 l 17-7 (Cwg 0903) CMC 63292 CMC 1969 C"J 19973 "Su:::r. FIE-00135nummer anc 1::a:1:n sacwn :n !?J crawing numcer d g,yg MW .
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Curing the field ins ection 3 the reviewer veri fi ed the follcwing were casign crawings: in acc:rcance ,with recuirements s:ecifiec or metacd of attacament of succor , ocprocer wall anc/or ceiling, dimensions, elevation si:e of structural steel mem:ers joint c:nnectica desatis, and canfiguration af su:nor*.. , " The reviewer also walked down other areas in the auxiliary 1 and electrical centesi building and examinec camle tray sunports for general configuration anc qualt y of workman-ship. 1 i During examination of succor:s in the Uni: 1 camle i spreactag room, the reviewer noted that six and eight inch i siderails had been acded to ' cur inen coep trays. The i grac. ice of increasing the heigh of siderails en cable trays and its effect on the design of cacle tray succorts was examined by the reviewer.
, discussac in paragrann G.b.(7).: Details belcw.of this review are i
i (c) Review of Quality Rec:rds . l The reviewer examined cuality . scards documenting constr :c-tionparagrash and QC inspec. ion of the cuale tray suogorts listec .in the acove. These recrds included construction . 3 travelers, inspection weld filler material legs, and cadie tray J recorts for installation of camle tray hangers, camle tray clamos, and installation of ex:ansion anchors or Rienmond Inserts. Based on . review of the records, anc the walkdown that insoection discussed acove, the reviewer concluced i in acc=rcance tray the cacle suscor.s were canstruc ad anc insmectec w1:n :ne crawings. The recuirements of the construction retrievacle. recorcs were neat, legible, c:moleta, anc (5) Ins:ec fon and Testing of Richmond Inser.s . (a) Review cf Pa L Ricamenc Inser. gram Soltsfor Veri fica:1cn of Insta11atten of Curing review of rec =rds, ne licensee catarmined na: cocumentation ticas of Ricamonc ofInser. CC ins:ec to' lts .icas wert inc:moitta for installa-In creer s verify tha: . j bolts Inser,ofsleeves,
- ne procer leng:n were. insta11ec in :ne Aichmonc i
- ne licensee carriac cut a reins ection pregram for :ne Ricamenc Inse-t selts. The reviewer examinec TUGC3 prececure numcer CI-CP-11.11-5, Veri fica: ion of Ins.alia:1cn of Rienmenc Inser: Solts, wnica was used to c:nteci :ne reins:ac-icn Or: gram. Curing na reins:ec: ten
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! gram, CC inspectors veriff ec the length of :ne bolts j eitner threugn ultrasonic tasting or anysical measurement, i anc caeckec telt diamatar, minimum emcecment length, and
" snug tign " c:ncision of the bolts. Tne reviewer ciscussac the reinscection program with mechanical CC inscacters
- resconsible for its imolemenution in the electrical control building. -
l
; Based on review of the procedures and discussions with the CC perscnnel, the reviewer c:ncluced tna: the !
- .i reinssection program t
- verify insullation of ne Richmond Inser bolts was c mprenensive.
I j (b) Chservation of Testing of Richmond Inserts 4 The licensee is perdersing extensive ansita testing of the Richmond Inserts s c:nfirm the strength values used in casign of structures using this type of ancnorage. Tne
.I reviewer examined TUGC0 Engineering Instruction numoer ! C7-i!-13.0-13 wnich specifies ne setnoc of tasultation of test smecimens, and cascribss the tas: accaratus anc i specifies the tachttique used in anolication of the tas:
loads. i Tne reviewer examined the tasting apparatus anc
! veri fied that the test equipment had current calibration stickars.
i The reviewer cesarved the tension tast of specimen i' " 28, a 1 inch EC-ZW Richmond Insert, and the shear-tansion - ! . test of saecimen 6, a 1 inch EC-iiw Richmonc Insert. Curing the tasts, the reviewer verified that application of the test load was acc:molished in accordance with the precadurs recuirements and that the test cata was accurately recorded. Following comoletion of the above tasts, the revi ewer examined hac tne results been previously of tension c:mpletec andancnotedshear-tansion tests that that those essults were c:nsistant w1:n the results of ne tas s witnessed by i ne reviewer. The ma,fority of the modes of failurt resultec in failure of the hign strength bolts, not the c:ncreta or insert sleeve. cylincer unesaffned Thec:mpressive revi ewer also examined tas; data c the c:nc t a veri fy sne stringen of sne =ncreta was ete:rded for us.e in evaluation of the tas results. (5) P*: gram f:rSui C:nuinmen: Acclicati:n 1cing of pretactive Coatings in :ne Uni: 1 (a) Review P cadurts of Specification and Quality Centr:1 Ins:ection t Tne reviewer examinec saecifications and :uality c..ntro l precacurts for acclication and ins:ec-ion of Servica Lavel I pretactive polar cranec:atings, and linerf:Pplata, staelinsice structures, inclucing the l builcing. ne Unit i reactor 1 Ac:agunca cri taria utill:ac by :ne reviewer 9 , '
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coways g i s >;s>. %rvepcurs i an be imole . i ~ orts leec seimikdlnsigne tocry vogtty ia htt macQ
; ne th'e
'. % '*he T:intictic. ,b mbina%4g tt the. is
- ofsand cemg,Titt,e
' tr weigh of the watgs,/.
the trap . :nel % es . t 'at ' the . of 35* . wiTht*, %t i ex l the maxianzmissign alTowestei caduh.? w he ali"' e tlines s ' epa:s be f&Qks di,. th .' thish , , n lia$caosee anup". th' It engineersNwnes s a:an excee s cut' ' e cadTd trays to ac= cent for ttni;' in llaEf is Af ce*as oftiding thin, i.pruchat-wilP!ikin in the neK futuga&T tn comoleced, ce evalugtiers'af
~~~ f:Eadermelagen'tah,cadh will be T tr fact se . .s . This a It'accitionak'^
rmec n ; s being ref~eigred [#:t ' ComaneneI-4.0-49 esqgs ure'*phe P cJect Dincter' ollewuo. Fy k i p Evaluatica of Increases to Heign: cf Ca:le Tray Sica Rails ( Curing :ha fiele walkeewn et scussed a:cve, :ne nyiewer rancemly selectec for eview :nree fcur-inen ca:le trays in :nerails. sica Unit 1 camle screacing recs whicn hac c or 3 inen ~ T-12-3CC-MIO, anc These wen tray nu=cers T-12-CCC-207, T-12-3CC+.33. inctes wice. The aseve :rtys are 20 drawing nu=cer The reviewer examinec sneets 1 anc 12 of 2323-51-0712, anc the 133 CCAs acains: sneet I and 4 CCAs against sneet 12. These crawines catail ine laycut anc si:e/ type of :ne aceve cacie trays. The reviewer aisc examined :ne cec;=en: eacxaces 1 1 L l - - -
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=ain ainec in CCC Satellite 307 fer :ne acove crawings anc verified tha: :ney were cceslete anc cenuinac ne lates (current) revisions of the casign enanges. Frem
! - review of :Me design enange documents, the reviewer
- verified that accision cf the 6 or 8 inch sica rails to the & inch doen trays was authori:ec by CCAs. For .' i examole, tne acdttien of 8 inch side rails to caole tray -
13-CCC-007 was authori:ec by CCA 15207. ' i j The reviewer ciscussed the effect that raising the side ; rails of caele trays has on the tray and supper. cesign I load of 35 psf with project civil and electrical - engineers. These discussicas disclosed that the side rai! decths were increased because cable extended above
. the sica ratis of the 4" caos trays. This often occurs j as intersecticas (TEES) of trays and is a result of cacle pulling preolems. The engineers stated snat
, wnenever the heigns of sicerails is increased, tne Octal leading of the trays is enecxec te verify it is celow
.no casign allowaole of 35 asf. TMe cacle load for each tray is documented in the GM Cable Raceway Schacule, 2323-i-1-1700.
Various a:Mer schecules' saintain the identity eacn cable. of each cable in each tray and the weight of
~
- The raceway senedule exsresses casacity of the trays as percent filled.
Review of ne senecules cisclosed the casa shown in the Table below: IdEnE Trav Nemcer Numeer of Cables Peacen Alled T-13-300-C07 198 23 T-12-3CC-M10 238 31
, T-13-GCC-M33 217 23 Fmm review of the cacle senedule, sinec :na the average weigns of :ne reviewer casei-ne cacies in tray feet. Therefere :ne cacle Icac in :nisccunes i-13-CCC-;07 was accreximately O.'11 ser linear
- ray is (numeer s.3 PSFof caeles)(w -/ ca=lel = (193)(.11) cound/f =
Wicth cf tray = 2.5 F: I This is well belcw :Me cesign allewacle Icac value. l Sasec en review of the ab=ve schacules anc ciscussions wita resscasible sngineers, One reviewer cenclucac :na:
- ne cesign values usec :s cetermine One structural i i
.- aceouacy of cacle tray succor.s are censervative. I l
l L _, .. _ - - - - - - - - - ~" * ' ~ ~ --;----
e - { . 1 e . . 58 e 7 . (3) ~ Personnel Interviews The reviewer meenanical c:ncuc:ac informal interviews with nine civil CC inssectors. and six Subjects coverec curing the interviews
. were the inscector training program, ability to discuss tneir .
safety esacerns with their management and/or the NRC, ccoceratica i between craft and CC personnel, , assistance from engineering personnel.andFrem availability of tecnnical the interviews, the i reviewer their concludec that the QC inspect:rs felt freeces excross i i inspec:cessafety cancerns to management anc/or the NRC, that tne felt ! that craft personnel were aware of the require-ments to do the work properly, and that the craft recsgni:ed the i importance inspectors. of CC inspection activities and esoperated with the The inspectors stated that engineering assistance in , resolutien of problems was available whenever they recuestec it. The interviews al: i training program whicn 3 disclosed that ces the inscoc the licansee has an extensive are required to c:melete prior to becoming cartified anc being able to ins:ec. anc accact work. The training program invoTves classrecm training en tne joc training, anc passing writtan and practical exams (,tne exams c ntain essay typc cuestions not multiple choica). program for the inspecurs , performing inspection of structuralThe training steel protective esating involved 40 hours of classroom training and 80 hours of on the Job training. The inspecurs did state tnat the large numeer of unicarporated design changes against some crawings maca cair joes more difficult at times, but most said that aftar working in an area for a period of time they became familiag with the enanges and were able to overe:me this procles.
- c. Conclusions l
(1) The licensee has effectively inclementac the CA program recuire-ments in the areas examined by the reviewer. (2) CC ins:ectcrs are knowiecgeable of their inscoction recuinmen s anc :erferm utir ins:ec*. ton in ace rcanca with ne licansee's CC pricacures. (3) The licensee's CC inscoc.or training pr: gram is c:merenensive. (1) The licensee's =rtsent cocument c:ntrol system is g:cc. Thcugn
. =e nuncer of uninear oratec design changes agains: scme crawings is large, the availacility of a package c:ntaining a c:melete set of u eciffculty euen c=cuments mace review to an exceriencec of the cccumen s : ssible wi ccu ins:ect:r. The licansee's new unicue
.e area. CCC systas (use of c:meutars) excaecs NRC tcuirements in J
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59 (. w (5) The cuali;y rec'cres examined by the reviewer were neat, legib.ie, retrievabTa', anc ccmclete. (6) One negative scint noted by the reviewer is the larger numcer of ! l Unincer; crated design cnanges against scme crawings. This results ! in a cumcerseme package to be reviewec when performing work or , i inspections. This item alicws apper: unity for ereces and requires ~ aeditional time to be censumed for work to prevent these errors. The reviewer did not identify any hareware proclems resulting from the Itcensee's system, except fer the 1:em icentifiac in paragraph G.b.(2) above. 3 a [ (7) The design change pr oc s is centrolled and complies with NRC requirements. The "dt-ri sk" design enange process described in paragrach G.b.(7) above is act unique since it has caen usac en ciner nuclear construc-icn pec.1ects. The casign enange program is laid out, but could allow for implemenu:1cn proclems if not meticulcusly fc11cwec. M. Review of Heating Ventilation and Air Conditioning Systems (HVAC) Refe ences: Crawings, standarts, and scocifications aspitcacle to this ecuipment are as follows: Manger bwg. SG-750-2J-IR,. Rev. O Hanger Owg. SG-790-2J-1V, Rev. O Hanger Owg. SG-730-2J-RIS, Rev. O Hanger Owg. SG-790-1J-RIL, Rev.1 - Manger Cwg. SG-730-1J-10C, Rev. O Hanger Cwg. SG-790-1H-RIG, Rev. 0 Hanger Cwg. RE-532-15-1A, Rev. O - Hanger Gwg. RS-332-15-1L, Rev. O Cwg. 2323-82-0651-9N, Rev. 2 Owg. 2323-"2-0551-HESC, Rev. 1 t Cws. 2323-M1-0551-HAN, Rev. 6 l Cwg. 2323-M1-0651-5SC, Rev. 6 ' Cwg. 2223-81-0551-SSC, Rev. 10 Cws. 2323-dl-0551-4.AH, Rev. 9
- Cwg. 2323-M1-0554-5SC, Rev.12 Cwg. 2323-81-0554-uAN. Rev. 7 Cwg. ~~~JS-0010-4 N, Rev. 5 Cwg. 2323-51-0500, Rev. 17 Cws. .*C-134-i2CC -
Cwg..vC-143-4E9C Cwg. CCA 3252, Rev.1 Cwg. MS 01.1 Scecifict:1cn 2223-uS-55, Rev. 2 P ocacurs 'aP-7USI-001, Rev. 0 7 Ocecure Cec-TUSI-003, Rev. 3 FF$Y"9*jP"" '8N", *W -.,y
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- a. General The reviewer c:ncucted scurs of c:ntainment, auxiliary uilding, safeguarcs tuilcing, and contret building f.or be n units :s generally
. 4 observe cuality, wert in progress, material centrol, anc cretaction of HVAC ecutoment, as well as weld roc c:ntrol . Discussions were neld with craft anc ins:ectica
- erscnnel curing these : urs relative to plant cuality. '
4
- 3. Revi'ew iffert Previcus discrepancias identified by NRC regarcing HVAC installation served as a driving force for this review effort. A review was made of
; evaluations and calculations performed as a result of the :reviously identifiec ;r:blems. In additica, :ne reviewer
' anc succor.s for conformance to applicaele cra casertec HVAC cucting wings, specifications, and s-ancards.
2 The tviewer generally cbserted cucing in various areas Of the
- ntainments, auxilit.ry building, safeguarcs tuficings, anc c:ntr:1 builcing for both units for ;reper bolting, precer gaskets structural integrity. In additien, the ins:ec=r ocservec cu,=and and equi ment sucocr:s for conformance to requirements. Su:certs reviewed incluced unit 2 duct hangers 2J-1R, 2J-IV, and 2J-R13; Uni: 1 duct Train A Containmenhangers IJ-RIL, IJ-1CC, IE-1A,1~-IL, and 1H-RIG; ficce mount Safety injection Puso5Accagray Fan Pumo Roca Coil unt fan ceil unit; and :ne two unit 1 hangers.
- c. Conclusion .
No significant preciens were icentified relative :: ducing. Caly since sreclems, well within previous ciscrecancies evalua:ac, were f:une in cuct su :cr.s. Dimensienal variations were actec in the hangers for Safety Injec.icn Pumn Rocm Coolers. These cavia:1:ns wer analysoc curing the review indicating snat these nangers were ac:so e acle. c:rrectec Several curingminor drawing ern es were also ac:ac wnica . were ne review. The evaluaticas anc c:r active ac: tens performec as a result of previously icentifisc pe==lems wita HVAC ins,.allatica a:cear :c to acequate. I. Fermal Intar/1ews f CA/CC Personnel a. Fermal intarif ews were c:ncuced Of CA/CC persenaei in cr:er := assis: in assessing site qualt:y anc management was fel: :na discussions with ins:ection su::cr. cf sita cuai t y. It c:nsertative insign into wne:Mer er not One ersonnel woulc give a s cc Pue ac :re:erly. plant was :eing ::ns:- Intersiews eignt ins:ect:rs were c ncuctad. of five management corsennel anc :,,enty-Ins:ecers wita :ne excae: ten. Electrical ins:ecters were primarily were selectec at cancem a gr:u: selectec f em cf ins:ect:rs wnien Mac recently been involvec in a ;ersennel
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61 8' ' incicent invciving a cross c:de "(Tee Shir;)" issue in orcer := assess wnetne these persons had significant tecEnical cencarns. In acdi:1cn, ! two electrical inspect rs incicated a cesire to talk to NRC anc wert intarviewec. i Several adgitional electrical ins ectors were chosen in accitien to inscac:ces in various other disciplines. >t . The grouc included inspectors working for eight different sucervisort. .- Ex:erience of these personnel ranged fr:s persons who had been in OC
; less than a year, to persons who had been at Comanche Peax from early ! c nstructica (hid 1970s). Most had scme previous experience suen as 4
site craft, non-nuclear industry or military experience. Some had workec at other suelear facilities. The major thrust of the interviews was to datarsine if the personnel hac any plant safety er quality c:ncerns. solteited from all : nose interviewed. Discussions Concerns in these areas were of c:ner sucjects were also held with most of the individuals interviewed. These sucjects inclucec intimidation, succor: for identi fying . acility :s nave =reeless evaluated anc cor te:ed as necessarycreolems, feectack en saisevaluation wita NRC. of secclems, acequacy of training program, anc r,elatien-i All but meant two inssectors stated they felt the plant would'be safe which ney had no significant quality proolems which they felt would comerosise safe aceration. One inspec ce, wne was not sure of :Me plant's safety, s.ated he was assigned to an area whicht was less
- controlled than he was used tc, e.g. , non-ASME coce work versus ASME csce work (which has the most stringent requi rements), and was unc:sfor.acle wita the leeway allowed in :nis arsa. This person also .
indicatec he hac ccucts about CA at ciner incivicual wne was unsure of nuclear plants in general. The satisfiec with quality wita one exception. plant safety indicate he was l 4 procles wnica he was not sure was adecuately evaluatec.Tnis involved a specific ! This item was descriced :s ne NRC:RIV Senior Resicent Inssee:ce forwantec inscoct:rs wne stated they had cocidec on :neir own that they Two
. fc11cwuo ::
talk := NRC, ex ressac vety strongly tha: the plant qualt y was "excalient" anc :nert was no plant safety c:ncarn. ' with ever twenty years' exnerience, who was at his fifth nuclear glantAno:ner in
. saic Comanene E ak was :ne "bes." plant he had seen.
t Seven ins:ect:rs exDrtssed one or more s:ecific ::ncarns. T1ese c:ncarns ment involvec questicas en wnetaer a car *.icular precacure recuire-or wnetner a sar.icular tecnnical evaluation was acert:riata, . l whe ner car.ain :ersonnel transfers wereinaccuracies ciscriminat:ry,co{ in scme written None:nfermanca Racer. (NCR) evaluati ns, anc :ncarns ; wnica licensee. nac recently caen 3rcugnt un anc were ye: s ce evaluatad :y :ne ! All c:ncarns have :een forwartec Oc the C:manene .3eak j
- eject Cirect r for followus for review anc evaluatica as necassary Several c:ncarns wert given :s NRC:RIV :ersonnel curing :nis inscection anc fellewuc sacwee :na:
- ners was no :sennical pr:cles icanti fi ec.
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.' s Tne URC Resiben:
hac alreacy evaluatec Ins:ecter :ne was c:nditien familiar with one ofac: as technically the::2:le. cen: erns anc Sever'aT acci icnal c:ncerns were given to RI'l perscnnel ve*: ally en the las: i i cay of this ins:ectica for ifmely fcilowup. l The s:ecial. team interviewer reviewed the concern regarding transfers - of six of seven indivicuals mentioned in the personnel transfer concerns. - Tnese transfers acpeared to be non-discriminatory.
' It snould be noted that in all cases of concerns involving s:ecific '
l harCware discrecancies these discrepancies hac teen identi fied to angrenriate licensee personnel and had been or were teing evaluated. i All in:nectors questioned (21) as to their ability ta identify =reslems such as via NCEs, indicated no sucaression in this area. Several ins:ecters anc c:m:lete indicated in scae cases. that NCR written evaluations c:uld be more clea
. eecheck regarding pr:blems, such :s ria ex:lanations of NCR evalua-I tions, was c:nsicered good by L9 of the incivicuals cuestioned. One incivicual indicated he did not always receive c:molete faeccack cut these items did not involve significant tecnnical c:ncerns. Two incividuals s.ated evaluations. One sta they felt unc:sfortable with scme "use-as-is" NCR for procecure enanges.tae that more feectack was neeced as to reasons '
Many of the in of tne assignment cectors the newindicatec that communications were incroving and improving c:mmunica:1cas. site QA manager was a positive step in It was clear that some communications greeless had existed in the past and rapport between inspectors anc their management hac coen strained previously in same C mmuni-caticas in positive. the ASME c:ca c:nst uction area accearec := anas. te excectionally All but a few inspect rs won questiened ngarcing craft. No significant intimication by 2 problems were identifiec al:ncugn two incivi-when ;rceless wen founc.cuals sentionec two incicents wnen the craft w No nreats were mace curing utse incicents. Generally, 1:cc. the rancor. to: ween craft anc ins:ecticn a:: eared :s te ve Adequacy
- f One ins:ect:Ps. Of the training pr gram was discussac wi= 4:ce ximataly half better, f.e., :u Several incicatec cat ne femal training c:ulc te training, plus ongner (not necessarily more extensive) ut formal ins:ectten fune:1ons.tae-jem training was acecuate t: perfers the Many stated that ne training was excallent.
Twenty incicatecins:ectors
- na: :ne freec:a felt no hincrance
- talk witnatNRC all :s talking with NRC anc stressac by managemen . Several has been c:ntinually talking wita NRC wnica a::earec s te a naturalincicatec some a::renensica accu fear of :ne,positica
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N NRC haics. they mus Several were uncer the im:rtssten for a sher. wnile ua i but acw a:cearnave ueir "act : ge:ner" if :ney were going :s set :ne NRC, to feel ac nincesaca. Most indicatec they saw NRC ins:ect:rs regularly in the fiele but a majority incicatec :na: they hac . c; talkec cirectly with NRC in the field. Inta* views of management indicated, they were very succortive of . insmect:Ps and sensitive to inssecter concerns. There appeared to be a str:ng enc uragement for personnel to come f:rward witn any csncerns,
~
as evicencee :y a memorancum catec Maren 22, 1984, to all CA/CC persennel from the Site CA Manager. Postings indicating management sunoc-. for ins:ec ces and other personnel in identifying proclems were prominently displayed along with NRC Fors 3, NRC Inforsaticn Notice 84-07 anc 10 CFR 21 information. In suantary, at: hough some c ncarns were ex:rtssed requiring further review, nese c:ncerns cid no: accear ts be excessive in numcer er sericus ancthe Generally, would ecs: be nomally expected curing tne interview ;recass. t cuality of me slant.excerienced ins =ectors hac a hign ::nficance in ne Pas preolems in c:mmunicatien and seme as: accrenension accut management succort had existec tu :nere :: ems :s have teen a marted improvement in tais area. No one indica:ed snat past c:mmunication pecclems had caused them to net perfors inspections preserly or not to icentify problems icentify ,preolems and freeces when found. Insmec cr freeces to strongly stressed. s talk with NRC has accarently been Management agneared to be sensitive s emnlo c:ncerns anc acpeared sc to seriously evaluating existing c=ncerns.yee
- 5. In addition :s fcesal interviews, numerous informal discussiens were held etween the NRC team personnel and s1:a managers, craft, ins:ac-tars, engineers, and office eersennel as incicatac previcusly in c ner sec-icns of this riscr.. Tne c:mrtents received frem wese incivicuals were c:nsistent wita those receivec during the femal inte-views.
Tnese ciscussions covered unics such as plant quality, training, management su:scrt, anc cccument c ntrol. Accencix A, wnich felicws, is a saniti:ed listing of c:nca-ns raised by incivicuais curing the interview process. The c:ncerns art only ucse wnich will requiet f=11cwun by the Comanche Peak P ject Cirec;:r. The intarviews were sani:1:ec only so far as c:nficen tality is-relatac. I l , i
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4 64 t' s . a.- AF:ENDIX A Inspector Name: A-1 Cate Interviewed: General iackground:
- Interviewee Comments: .
Unc sfortacle w1:n less s:ructured program for non-ASME versus ASME: e.g., seem to enange cwg. wnen structurn consn't met: original, can add welcs in field and he coesn't think it gets incorscrated into dwg., QC lead can accreve changes to travelers for non-ASME structures, not sucn CA favolvement in :nis area. Soecific: Precacure QICP 1114-12 electrical moun tng ::acxfit, craft c:enlainec so procacare was, revisec to es:uce numse- of inscoctions, a revisions mace to colete recuirements (:ol: :tg :- ening,etc.) Has the imoression saat CA has been generally ceficient at nuclear plants anc CC has not been supper.ed at Cemanche Peax in :ne :ast. 3 - j Incicated main procles f s probacly his being able to adjus to non-ASME worx: ts not aware of code violations taking place. i e f a G f i I J i
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a =._= . a =- -- = w - =" ~~-~ ~~ " " x . , 65-t f Inspect:r Name: A-2 Data Interviewed: General iackge und: 1 i Interviewn C:mments: . Has some c:ncern with use-as-is NCR situations, use-as-is seems
- articularly prevalent when using Specifica:ica EI-LCO.
Saecific Technical Concern: NCR was writter when cable camage occur ed during Siso Seal removal using a thetaced red. Tni s
=ccurred in Auxiliary Butiding, elev. 532'. NCR said no damage was done := caole but some insulation had been scracec off by red.
Feel fur.nar evaluation may me in crear for these cables and cert say be similar proclems elsewners. 5:ecific: Wrota 2 NCR's regarding tracaamility of futa clocr.s. 31ceks were not marked "Q". NCR said Clf blocks were purenased via arcar MS-405. as-1s becausa no non-Q Fuls other similar non-Q blocks have :een purcnased via different surenase orcer ( and c:uldpreolem. paperwork have hun installed as Q. Thinks thts a possible Soecific: Wrcta recent NCR (not yet evaluated) on GE Mc:ce Control Centars. Comortssien lugs have benes as mucn as 130 degrees (mort than nomally cone d:ne by sita construe:1cn). Can't :nink GE can violata escutesmants and may :e a pr:bles elsewnere in GE MCC's. Also have s me brenen wirt strancs wnica we are fixing as we find. 5:ecific: Had previcus paperwork c:nflict pre:1em in selving rework of :arminal biccxs. 6 cage RRC invcivec anc Prec. SAP-4 involved. awart, CeuxWr ::1ceNRC 2 NCR's. ins:ector NRC ins:ect:rs Taylor, Taylcr ::lcC.tes and Johnsen we nave an answer. := Never got fetebacx as :: results. ' 3:ecific: Peak inRenaired a sciencid, sher.ly aftar :: ming :: Cemanent craft, witneu a:er.crt. Ocn' t knew i f i t was sa f ety rela:ac. Scod jed. Nc: ::ncarned wita sciencid taennically cic a Notas: The s ecific c:ncah s wert given vertaily ::
' on ?/12/34 f:r fur her followue. I: as incicatac curing :ne SRI - C:nstrue:1:n woulc ge: ert s:ecifics fer SRI. w :ne intarview ne suggest alicwing the licenset :: .CC pr:cles was still teing evaluatac. I
- Prec:1ve ac:fon. evaluata anc :non felicwu: f:r acecuacy :f
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Ins:ict r Name: A-3 ~
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Oate Interviewec: General lackge und:
- Interviewee Comments:
Generally concerned w1 M finding numer us =rcolems curing ::ast canstructica inspection and procedure being changed ts colete inspection, e.g., loose terminations found in lighting. !; Some NCR's are answered simply that the preolem is not addressed a
! in Saecifica:f on E3-100.
Recent NCR written because restraint cable (lighting) crimo gages were worn & taerefort, ins:ection was inacecuate.
- etng evaluated. Tnis is still j Wires of two cifferent gages were teminatec at some lugs and many teminations are loose. -
Have more pressure not to write NCR's curing turnover. - Founc loose t.S's (elbow temination fittings) 3 East & 5:uth ends of Unit 1 01esel Generatsrs, wrote two NCR's, was accentec as is. } -
-cune cables no i
Screac Rcem 3 junction boxes 1053 and 1059. trained (routed) in worua NCR said CK because cacle facius was CK but cid not acmit workmanship pre:lem. Feels post retaliation for finding pr:clems.c nstruc.f on insmectors were transfer tc is Un 4 Heard sec:nc hand th4: IR's (inscoc-ion recorts) were ceing )
, written falsely (witneut estascaction) s clear IIRN's (ct scren- t ancy esecrt) on cacle trays. Heart frem lacy in Dacer Ficw Grouc (P8G) anc lacy in vault. Said he woulc get :ack :s NRC with more 5:eci fics.
Notes: Scme Nview of the lignting temination issue anc : cst eneck
=rececurs was c:ncuctec by team memcer Ruff.
incicatec he hac :sid The site inssector evaluating. of most of :nese issues anc CA was ,i 1 taxes :: RIV:I f rwarcec c:ncern estative ts 1053 & 1059 junction anc sees ac tecnnical Martin ge.cles. anc he incicated he ins:ectec :nese boxes t i atec in mest Resicent Ins:ect:r: Smi:n par.ic-i i of :ne andinterview anctecnnical incicatecprecies. he was aware of {
- :Me 0/G lecsa fit-ings sees no I evaluatec l! reascns wny 6 :ersonnel inclucing )
Unt: were transferrec :s 1 anc 031s scve coes not 10: ear to ::e c1scriminatery. l i -{. f . . . , , e- -
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l *., ~ i l t . .. i i 67 ' l l . Ins:ect:r Name: A-4 . Cate Interviewed: General 3ackgr und: " Interviewee Comments: Une:afer:acle with some use-as-is situations, e.g., cable se=aratien arceles found in fuel building during walkeewn dic not meet procacure but was evaluated as use-as-is. He can show someone wnere it is. Wrote NCR on lack of 5-thread engagement en a c:ncui fitting scar evaluation in tha: sec:nd NCR was written en :they timely saic that c ulcn't see it; a looking .for a way to buy tai s-4rea eff, Mis t:ckarea twofortries cacle damage, seemec every:ning evalua ac. s get knows accut :nis but dicn't get :ack
- = nimascects.
nical en fa:: :na: NCR's were acerly narcled, i .e. , non-tecn- . Feels discriminated against in :na wnere there is no ever.ime. Got grille he was transfer *ed :s Unit 2 the on cable damage NCR at , same a:cea: ed time as being esunselec on a personnel issue so 1: Management thatishis aware transfer of this had c:ncern. sometning to de wita NCR. Ncte: I did not review this person's transfer situatten. l 4 of _ , ,m,,- ,
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u._.-----.-- --~ ~ - __ ._. t t 68 (~ m . l Ins:ec :: Name: A-5 Cate Interviewed: l
} General Sackgrcund: * . Intarviewee C mments: ,
i Had problems witn post check, e.g., f eose lignting taminations
- and junction boxes. Teck lighting cut of peccecure and mace 1:
more difficult to look at junction boxes. Management was made aware of these concerns. (Has no significant safety c ncern) Mere tencency t: ward usa-as-1s wnen =ressure is en (safaty requirements are ceing met, however) Has had some fear of talking wita NRC, c:dn : :nink re ce ing 8 en-sita woulc ever get off-sita, doesn't have NRC RIV ;hene numcar Feels disc-iminated against by being transfsr se to Unt: 2 Some NCR evaluations are inaccurate or unclear, e.g., statement that workmansnia was not comoremised wnen in fact warkmansnig was ( _ peer but the item was tecnnically ac:eg aele Notas: I reviewec the transfer situation; annears s be reasonacle but not as clear as ressaning on other 5 transfers. NRC Fem 3 appears well costad so I'm not sure wny ne coesn't have ne nuscer. He does not accear to fear :alking with NRC now. Alsacugn, he stated he coes not have significant sa fety/cual i ty i c:ncerns, his c:mment en NCR answers is interesting. Similar i general c:mments were received fr m ether ins:ect rs anc this c:uld i incicate a neec for better answers on NCR's. An examcle would te that if a wortunanship questien was act accressac procerly nen gernacs wculd not get perfor-nec.needec retraining of pers:nnel as preventive ac-icn n1s area. Fernaos the licensae netcs := imcreve in I 1 h l% .
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- Cate Interviewec:
General Eackgieunc: Interviewee Comments:
- Adced higner sides to scme caole trays to keen cacles in trays Alse there may me cacie cansity/comcac: ton precies f n :Mis area
.It's taugh := keep pecele off trays to keep from damaging them Have nac pr =lems with clearance of mice and cacies, have es actei insulatien, place metal ben.een insulation anc trays Den is ale: cf rowerx, :s get pre:er secara:1cn -
Notes: Tnis man was questioned primarily to get incut for RIV reviaw of
- c2cle scread r:ce as to wnere there could te preolems. He personally has little Di sclam with plant quality. RIV - Mar.in
- t. was incicatedat Methat interview the situationsahc vercal werefeectack cn the first Wo 1:ams acceptacle. ,
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('- 4 Ins:ector Name: A-7 i Cate Intarviewed: General
Background:
Interviewee C:.ments: Had pr blems with Pacer Flow Group (FFG), when first inclemented, with c:moleteness of packages. Getting bestar and coes not know of safety preoles involvec - Some inaccurata NCR answers Sita has preolem with los: encercs, 2 secole are assigned full time in the vault, NCR's are not wri ten en los; rec rcs, reinspect wnen record is lost sut this reinsoection say be very cifficult or very imoractical. He has no evicance that reinspections are not getting done. This problem could pocole, i.e., maybe thty lost recares. relate to esanotance of PFG f Nota: l Various are Results scocial taan in the team semcers esport.looked quite extensively at records.
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OFFICE MEMORANDUM qA/QC-RT-139 TO: Roger Brown FRCM: Chuck Spinks - l l DATE: 06/07/85 SUB.TICf : Adequacy Review - Filler Mat'1. Preheat /Incarpass Temperatures, and Welder Certification 4 As requested we have reviewed the appropriate specifications and procedures for adequacy of; filler material control, preheat and interpass temperature control, and Walder Qualification and Certificaciou. Control of filler materials was adequately prescribed by the applicable procedures (see attached list of procedures reviewed). Weld rods are , identified by rod and coating type, heat / lot number, and size and stored in the manufacturers hermetically sealed cans until placed in holding i ovens at the issue point. The holding ovens were to be marked with the above stated information, to avoid inadvertent mixing of dissimilar Wald Red. End issue control was. adequately prescribed in that the issue point was required to verify that the issued rod was correct for the application as specified by the Wald Procedure /s and Design item specified.on the issue request and Weld Data Sheets. The welder was required to maintain the rod in portable ovens, limit exposure of the i red to ambient conditions prior to use, and return all stubs and unused i red to the issue point. The issue point was required to return the red to the appropriate holding even in a timely manner.The above stated procedures were in effect from a time prior to receipt of "Q" (safety reinced) filler material, until present. Control of Preheat and Interpass temperatures was adequately prescribed in that each Welding Procedure Specification (WPS) specified the camparature requirements when applicable, and Welding Engineering was j required to monitor implementation of those taquirements on a I l , surveillance basis and document the surveillance results. QC was . required to monitor the implementation of those requirements also, either on a surveillance basis or on each veld inspection. The Quality procedure did not consistantly indicate either, but rather reflected the i changing philosophy of which method provide the required verification. QC was also required to document surveillance results on a surveillance report during the times that " surveillance" was stipulated by the procedures. The QC procedures stipulated these requirements from 8/6/75 until present. i ht@mM O L )( h
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e l An ade.quata welder qualification and certification,, program as in effect from 10/2/75 to present. The Procedures were reviewed for compliance to code requirements. Q Chuck Spi.%s 7f/1f cc: J. Christensen M. Shealy M. Tapani . i CS/sp d e e
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l l 1 PREHEAT & INTERPASS TZMP. REFERENCES
REFERENCES:
106 A - Fabrication & Z: ction of ASME III Component Supports 106 3 - Pahrication & Erection of Structural Steel (AWS) , 107 A - Shop / Field Erection of Piping Systems & Components (ASME) 107 B - Field Erection of Piping Systems & Components (30P) WES-26 Welding Parameter Guides CP-CPM-9.9 NNS Seismic Cat. II Supports CP-CPM-6.9 General Piping Procedure CP-CPM-6.9D Welding & Relatad Processes WCP-3-Administration and Organization of Pield Welding Technical Centar CP-QCP-8.1 - Surveillance of Welding Activities CP-q $ .11.1 - Fabrication & Installation Inspection of Components. Component Supports & Piping QI-QAP 11.1 Pahrication & Installation Inspection of Safety Class Component Supports
- QI-QAP-10.2 Visual Examination Neldaents QI-QP-11.21 Requirements for Visual Wald Inspection j
QI-QP-11.14 Inspection of Site Fabrication and Installation of Structural and Miscellaneous Steel QI-QP-11.14 Inspection of Structural Miscellaneous Steel Welding l QI-QP-11.16 Installation Inspection of NNS Seismic Category 11 Supports for Class V Piping E
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I , TILLER MATZRIAL REFERENCES BROWN & ROOT PROCEDURES Acril 18. 1975 to Aug. 10. 1975 Cont:o1 of welding materials 35-1195-WC7-3, Rev 0 . Ana. 11. 1975 to Oct. 5, 1978 Control of weldin$ materials 35-1195-WCP-5. Ravs O chrough 5 Note: Title of Rev 5 is " Control of Wald Filler Material" Oct. 6. 1978 to Feb. 5, 1980 Genersi pipins and Inspection Procedure CP-CPM-6.9, Rev 0 Feb. 6 1980 to Sep. 20. 1984 I Weld Filler Material Control CP-CPM-6.93, Rev 0 and 1 Sep. 21, 1984 to Present Weld 7111er Material Control CP-CPM-6.95. Rev 2 (DCN 31 and #2 Notat Changes were made to the above procedures by interim change noticas or document change notices and incorporated into the next revision. l
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.G 1A 5-52.01-105 (10-28-75 through 7-21-81) (Rays 0, 1 & 2) 13 Wts-031 (7 21 81 through present) (Revs 0, 1 & 2) t i
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85601/PFW/mt INTEROFFICE MEMORANDUM $$$$ 4 ees.as 15297.00 SUBJECT NCR REVIEW - ANALYSIS OF SAMPLE RESULTS DATE June 18, 1985
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FROM PFWilson TO HFraery cc Rasurns JEHuston C0Lundin WHGrieves Chrono File /JGalla PFWilson/mt - The following analysis is provided regarding data supplied to QSD concerning a sample of 500 NCR's taken to identify weld related deficiencies at the Comanche Peak Nuclear Power Station. The following deficiencies were noted in the sample taken: Weld Deficiency All Welds Support Related Welds-Cracks 4 0 Porosity 4 1 Undercut 4 2 Lack of fusion 3 2 Based on these results, 95 percent ' confidence statements were constructed regarding the estimated maximum percentage of these deficiencies in the unexamined balance of the populatiori.
- 1. Cracks, porosity, undercut. or iack of fusion 2
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It can be stated, with 95 percent confidence, that each of these deficiencies represent less than 1.5 percent of the problems reported at the Comanche Peak NPS.
- 2. Support related weld deficiencies l
It can be stated, with 95 percant confidence, that each of the above listed deficiencies related to support weld: represent less than 1.0 percent of the problems reported at the Comanche Peak NPS. The results above are not significantly different in a statistical sense from those obtained in the previous TRT inspection. Further details, if required, are availab om the undersigned.
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m .n & j QA/QC-RT-114 T0: Roger H. Brown FROM: B.P. Singh OATE: May 29, 1985
SUBJECT:
Inspections of Painted Welds The tacie on attached page gives materials and paints used in the construction of Pipe Suoports, Cable Tray Supports, Conduit Supports and H'/AC Ouct Supports. This information is considered applicable to majority of the supports at CPSES. If it is determined that meaningful inspections of painted welds are feasible, the pertinent information should be verified for the particular joints selected for inspection. 3.P. Singh . dkb/SPS
, cc: Dennis Alexander ER: Fi1e e
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y- -- -- TABLE I: MATERIALS & PAINT FOR SUPPORTS AT CPSES I I 1 TYPE OF SUPPORT BASE MATERIALS WELOS FILLER METAL PAINT Pipe Support SA36, A500 Gr3 E7018 (REF.2) Primer: Carbozinc-11..' SA515 Gr 65 Topcoat: Phenoline-305 ~ SAP 40 Type 304* (REF.3) (REF. 1) Cable Tray Supoort A36, A500 Gr8 E7018 (REF. 2) Same as above A588 GrA or 8 (REF. 3) C:nduit Support A36, A500 Gr8 E7018 (REF. 2) Same as above A588 GrA or 8 (REF. 3) HVAC Duct Supcort A36, A500 GrB (REF. 5) E7018 (REF. 4) Base metal galvanized, Weld areas sprayed with Zincilate 810-C (REF. 5) Used for Pipe Lugs only
REFERENCES:
- 1. TUGC0 Pipe Support disign guideline,'Section II, General Engi7eering criteria for Pipe Support design; Rev 12, date 5/2/85
- 2. Brown & Root memo fecm W.E. Baker to B.P. Singh,'WPS and Filler Metal Use',
date 5/23/85. (Attached)
- 3. TUGC0 memo CPF-18406,'CPSES Construction Adequacy; date 5/28/85. (Attached)
- 4. Sahnson Service Co. memo BSC-TUSI-2515,' Subcontract No. 35-1195-0525, ERC ,
Request, date 5/28/85. (Attached) . l S. a) Gibbs & Hill, Inc. , Specification 2323-MS-85, Rev. 3. b) Gannson Procedure DFP-TUSI-003 ' Duct Support Faorication & Installation Procedure; date 5/6/81. (1 ' 7 .J
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.- May 23, 1985
- TO
- 8.P. Singh FROM: W.E. Baker SUBJFCT: WPS and Filler Material Use -
For the majority of the work conducted at CPSES to join plain carbon steel (P-1) used in NF supports, the filler material used was E-7018 with the Shielded Metal Arc process. The WPS used to deposit this material was WPS 11032. There are some exceptions to this where bimetallic welds or welds between P-4 or P-5 materials were required. Cenduit and Cable Tray supports were fabricated using E-7018 electrodes and WPS 10046. In some instances, WPS 11032 was substituted for varic;.- reasons but still the filler material used was E-7018. If you have any other questions, please feel free to contact me or the Welding Engineering staff. RECEIVED gg 231985 l s r' # A - ~ W.E. Baker Sr. Project Welding Engineer WE3/SCW/tn l
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! ! BAHNSON SERVICE CO.
' BOX 1123 I -Q Gl.EN ROSE, TEXAS 75043
'# : ESC-7JSI-2515 1
. To: J. C. You geloed Date: May 28, 1985 i
From: Bruca E &ards copies: J. Gore D. llcreen
Subject:
Subcentract No. 35-1195-0526
. ERC Request On May 28, 1985, M: . S.P. Singh of the ERC Group requested 6e type of weld re al used en the majority of Fager/supperts.
Mr. Sin @ requested I put this inforacica in writting to him. The weld nucal raterial used by Ba'T.sen Service Ca::pany is E-7018. SPcdd you require additicnal inferratica, please advise. 3 Thank you, _ WN
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Bruce Ed:eards, Project Prager 3E/d6 i i i i i
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' Iansas Gas and Z1ectric' Company
'~ P. C. Box 309 4 Burlington, Kansas 66839 i i
Ra: Visual Inspection of Painted Fillat,Walds ,
Dear Mr. 3a11ey:
' Dr. 71aber and I have reviewed the paper prepared by Bechtal Power Corporation regarding thei: position on the visual Inspection of Painted , 7112ar Velds". Dr. Ten of our semif L elao reviewed tats and, providad comments on the paper. We all agree that the important characteristics of the velds can be avslustad with the paint thickness of 14 mila Q) on the asabers. , I
'The avAlu.Llos must be made on the basis that certain probisas that could occur ' in welding can be ruled out because they do not asiat i '.. ' or are not important,for the type of welds a'ad asterials involved.
i /, . ars hencarned only about inspoesias itama that 1.14ht reduos she strength Wa* . y of connections. Tasts u de'on walds from the Espe Creek Flant (Fritz Ingineering Laboratory 7. aport 200.81.240.3) revealed that even very large amounta of porosity in the welds reduced the strength of connections by only a vaall amount. Lnrte porosity of ska syya peasant in walda f h Lhe j Bopa Creek Plant could be detected through paint. 71na porosity of a s1== ; that could not hii observed through paint is of no importance in evaluating tha' strength of these connections. i : i We feel confident that the inspee Lon results to data demonstrata that the qualiry of welding on the buildings was more than adequate To provide the strength required in the building connections. If there ara inspect 1dn items such as fine porosity, ainor undercutting or crack 1ng in welds produced by join restraint that can not be datacted through paint,
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these items are not apt to reduce the strength of connections sufficiently
, to ha of conearn. The radundancy in the completed structure is also avail-able to provide alternaca load paths if necessary in the evene that a
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con =aceton of lower than expected strength exists. e' RCS/df ec: Echard Ivy Rosar G. Slutt'er fftI!l , John W..Fisherw ., m gangn,,g a m p m . Ap/c e x /2.
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- INTEROFFICE MEMORANDUM g, *d o ese.as SUBJECT Removal of Paint From DATE June 3, 1985 Welds to Allow Inspection Ra'ssued: June 17. 1985
- . of the Welds FROM R. L. Martin
- 3. P. Singh CC DEEllis BRNewmark MJSchnieder MED. Files T.8.0 HF?aarv_ .
Reference:
Telecon between B.P. Singh and R.L. Martin on
- May, 20, 1985.
l Ar re discussed in the referenced telecon, there are chemical products available which would remove the existing CarboZinc 11 l and Phenoline 305 coatings from welds. However, the use of such I chemicals is not recommended. A preferred approach is to mechani- ' cally remove the coatings. The basis of this recommendation is as follows. Chemical products which would remove the Phenoline 305 include stripping compounds such as Wellco Chemical Company's "TS-60" and "Polystrip". Each of these compounds is formulated for hot sogk or het spray cleaning at preferred temperatures of 175 to 205 F. i Removal of the CarbcZinc 11 requires the use of a 20% aqueous solution of sodium hydroxide which must remain in contact with the paint for approximately 8 to 12 hours to disbond/ dissolve the paint. Some scrubbing with a brush may still be required to remove tenacious CarboZinc 11 and a repeat ap sodium hydroxide may be necessary in some cases. plication of the Problems involved with each of the above chemicals include control of use, cleanup, personnel safety, ar,1 prevention of exposure to austenitic stainless steel and nickel alloy surfaces. For continued contact with the paint (soak), containment devices are necessary. On flat horizontal surfaces ,this could be accomplished through the use of caulking barriers or similar methods. The difficulty arises with inclined or vertical surfaces. Soaking components with the Wellco products at the required temperature is easily performed in stripping tanks; however, soaking a weld on a vertical surface located overhead inside containment becomes a near impossibility. Cleanup of these chemicals requires rinsing with clean water, l Even with the use of sponges or other devices, rinsing, like soaking, is difficult to c*ntrol. Personnel safety must be considered when using these chemicals. Caustic soda can burn the skin and eyes. Suitable protective
, gear is required to prevent personnel exposure.
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Because the stripping compounds are strong alkaline products, they , like the sodium hydroxide, cannot be allowed to come in contact surfaces. with austenitic stainless steel or nickel base alloy Any of the chemicals which come in contact with th e surfaces and is not completely removed could result in stress corrosion cracking. Complete removal of the chemicals would be particularly difficult on installed systems and components due to crevices and other inaccessible areas. . Any use of chemical cleaners woul'd first require the development of detailed procedures for the use, handling, removal, and disposal of the chemicals. To overcome the above discussed problems associated with the use of chemical products, it is recommended that the paint be removed by mechanical means. The preferred method is power tool cleaning. Acceptable devices include the 3M Clean'N Strip Discs and abrasive l flapper wheels. These tools can be used to remove the Phenoline 4 305 and the CarboZine 11. If there is concern that these tools may modify the surface condition of the weld, a fine wire brush may be used to remove the CarboZinc 11.
. Ik i R. L. Martin Materials Engineering i
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Docket Nos : 50-445 and 50-446 MEMORANDUM FOR: James C McKnight, DMB/TIDC/ADM FROM: Vincent S Noonan, Director Conanche Peak Project Division of Licensing, NRR ,
SUBJECT:
PLACEMENT OF A DOCUMENT IN THE PDR AND LPDR a The attached memorandum, Visual Inspection of Painted Support Welds, dated
- August 13, 1985, is to be placed in the Public Document Room Attached are' two copies of the designated original Vincent S Noonan, Director Comanche Peak Project
Enclosure:
Memo: VS Noonan to J P. Knight,
" Visual Inspection of Painted Support Welds", August 13, 1985 ,
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