IR 05000445/1985016
| ML20199L020 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/04/1986 |
| From: | Barnes I, Ellershaw L, Hale C, Andrea Johnson, Will Smith, Wagner P, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20199K948 | List: |
| References | |
| 50-445-85-16-01, 50-445-85-16-1, 50-446-85-13, NUDOCS 8604100278 | |
| Download: ML20199L020 (34) | |
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APPENDIX D COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report: 50-445/85-16 Permits: CPPR-126 50-446/85-13 CPPR-127 Dockets: 50-445 e Category: A2 50-446 Applicant: Texas Utilities Electric Company (TUEC)
Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES). Units 1 & 2 Inspection At: Glen Rose, Texas Inspection Conducted: November 1-30, 1985 Inspectors: e d Y / 76 L' E. Ellershaw, Reactor Inspector, Region IV Dalfe /
CPSES Group (paragraphs 1, 5, 6.g - 6.h, 6.k. 7.f - 7.t)
3htf86 W. F. Smith, Resident Reactor Inspector (RRI) Date Region IV CPSES Group (paragraphs 1, 6.c - 6.f)
ck$t s +/Wh6 Date
[ C. J. Hale, Reactor Inspector, Region IV CPSES Group (paragraphs 1, 2, 3, 4, 6.b, 6.1 - 6.j)
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9 C.uk e P. C. Wagner, ReactTr Inspector, Region IV ahus6 Date CPSES Group d ,
(paragraphs 1, 6.a. 7.a - 7.e)
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p A. R. Johnson, Reactor Inspector, Region IV Date CPSES Group Consultants: EG&G - R. Bonnenberg, J. Dale, L. Jones, A. Maughan, W. Richins, R. VanderBeek Parameter - J. Birmingham, D. Brown, J. Gibson, K. Graham, D. Jew Reviewed By: % w4//J%
I. Barnes, Group Leader, Region IV CPSES Date Group Approved: ' //hj/C T. F. Westerman, Chief, Region IV CPSES Group Date Inspection Summary Inspection Conducted: November 1-30, 1985 (Report 50-445/85-16; 50-446/85-13)
Areas Inspected: Nonroutine, unannounced inspection of applicant actions on previous inspection findings, Hilti bolt inspections, and Comanche Peak Response Team (CPRT) issue - specific action plans (ISAPs). The inspection involved 2008 inspector-hours onsite by 6 NRC inspectors and 11 consultants. A summary of NRR and IE audit / inspection activities is provided in paragraph 4 of this !
appendi i Results: Within the three areas inspected, four violations (unacceptable design basis for grouting Richmond inserts, paragraph 5; failure of QC inspectors to detect undersize welds, paragraph 6.k; failure to verify confomance to procedure requirements for Hilti bolt installation, paragraph 6.k; QC inspector acceptance of an HVAC duct system exhibiting damage and an unacceptable gasket gap, para-graph 7.k) and three deviations (failure to comply with approved instructions in '
performance of reinspections, paragraphs 7.a. 7.b 7.e. 7.1, 7.1, 7.n, and 7.q; inadequate quality instruction (QI) for liner measurements, paragraph 7.1; inadequate review of reinspection documentation, paragraph 7.n) were identifie .
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DETAILS Persons Contacted
- S. R. Ali, TUGCo Staff Engineer, TUGCo Nuclear Engineering (TNE)
W. Bailey, ERC Supervisor, QA/QC Reinspection Engineering
- C. T. Brandt, TUGCo Quality Engineering Supervisor
- D. W. Braswell, TUGCo Engineering Superintendent, Plant Operations C. I. Browne, Project Manager, R. L. Cloud & Associates, In (RLCA)
R. Brown, ERC Lead Civil / Structural Engineer
- R. E. Camp, Assistant Project General Manager, Ur.it 1 (Impell Corp.)
J. Cardoza, TUGCo System Engineer J. D. Christensen, ERC Deputy QA/QC Review Team Leader
- S. M. Franks, Special Projects and Technical Support Lead (Impell Corp.)
E. L. Gastenel, TUGCo System Test Engineer
- P. Halstead, TUGCo Site QC Manager
- J. L. Hansel, ERC QA/QC Review Team Leader J. Honekamp, TERA TRT Issues Manager
- C. R. Hooten, TUGCo Project Supervisor, THE Civil
- R. A Jones, TUGCo Manager, Plant Operations D. M. McAfee, TUGCo QA Manager G. M. McGrath, TUGCo Licensing / Compliance Supervisor
- J. T. Merritt, TUGCo Assistant Project General Manager, Unit 2
- C. K. Moehlman, TUGCo Project Mechanical Engineer
- A. A. Patterson, ERC Reinspection Engineering Supervisor
- F. L. Powers, TUGCo Unit 1 Building Manager C. M. Puffer, TUGCo System Test Engineer
- G. R. Purdy, Brown & Root (B&R) QA Manager J. G. Red, TUGCo Technical Support Supervisor
- R. B. Seidel, TUGCo Operations Superintendent
- J. Streeter, TUGCo Executive Assistant to Executive Vice President P. Streeter, TERA Senior Mechanical Engineer P. Turi, TEPA Issue Coordinator
- I. Vogelsang, TUGCo Coordinator, Electrical and Instrumentation and Controls
- C. H. Welch, TUGCo QC Services Supervisor
- D. W. Westbrook, TUGCo Project Control Supervisor, Pipe Support Engineering M. J. Wise, CPRT Testing Review Team Leader
- Denotes those persons who attended the exit intervie The NRC inspectors also contacted other CPRT and applicant employees during this inspection perio .
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2. Applicant Actions on Previous Inspections Findings (Closed) Unresolved Item (445/8514-U-19): Certification to QI-QP-11.8-7 could not be located for a TUGCo inspector who performed original inspec-tion with respect to instrumentation installation Verification Package No. R-E-ININ-060. Additional documentation was located by the applicant i
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during this report period which resolved the question concerning the TUGCo inspector's certification to QI-QP-11.8- . CPRT Program The applicant's responses to the detailed NRC staff coments on the CPRT Program Plan, Revision 2, were forwarded to NRR by TUGCo letter of November 22, 1985. This submittal included a preliminary copy of the umbrella QA program; i.e., CPRT Third-Party Quality Assurance Progra . NRR and IE Audit / Inspection Activities NRR: A site inspection was performed on November 5 and 20, 1985, of the Stone and Webster (SWEC) walkdown. An audit was performed at Ebasco, New York, on November 8, 1985, to review specifications and design documents related to cable tray / conduit supports. A site audit was performed on November 11, 1985, of the construction adequacy program as it relates to the SWEC piping and pipe support effort. A CCL test of conduit supports and components was observed at Charlotte, North Carolina, on November 13, 1985. A site inspection was performed with Region IV participation during November 18-22, 1985, of as-built drawings for Unit 1 cable tray supports. An audit of homogeneity of design activities was performed at TERA, Bethesda, Maryland, on November 4-6 and 12-13, 1985. An audit was performed on November 25, 1985, at SWEC, New York, with respect to nonseismic piping effects on seismic design pipin IE: Inspection activity which was performed, in part, in November 1985 Es previously documented in NRC Inspection Report 50-445/85-14; 50-446/85-1 Copies of reports for these activities will be placed in the Public Document Room upon completion. The results of the Unit 1 cable tray support inspection performed by NRR and Region IV will be documented in a Region IV inspection repor . Hilti Bolt Inspection An independent measurement inspection was performed by NRC Region I personnel during September 9-19, 1985, which was documented by Appendix F of NRC Inspection Report 50-445/85-13; 50-446/85-09. This inspection included examination of 124 installed Hilti anchor bolts with respect to
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embedment depth, bolt spacing and length, and diameter of individual bolt One bolt was identified by ultrasonic examination (UT) during this inspec-tion as appearing to be underlength. Separate subsequent reexaminations by applicant and Region IV personnel confirmed that the questioned bolt was, in fact, of the correct length. Applicant personnel noted, however, during their verification activity that six other Hilti bolts used in the support installation were identified by their marking (i.e., star stamp) as being a Super-Hilti type, although the drawing required use of only a regular Hilti type. UT by applicant personnel of these bolts identified that the bolts were misidentified, in that they were established to actually be regular Hilti bolt As a result, nonconformance report (NCR) M-18708 was initiated on September 26, 1985, in order to properly document and correct this
, condition. Concurrently, corrective action report (CAR) 058 was initiated
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in order to: (a) identify Super-Hilti design required installation loca-tions which were installed prior to March 1982, and (b) to perform UT on a randomly selected sample of 60 supports. March 1982 was the date on which application of the star stamp, designating Super-Hilti type bolts, became a QC controlled operation. The CAR further stated that any identi-fied deviations from design would be cause for expansion of the sample to 100% of all Super-Hilti installations made prior to March 198 Because of the potential for installation of misidentified regular Hilti bolts rather than the design required Super-Hilti bolts, NRC Region IV initiated an independent inspection. A total of 64 ASME component supports, which were located inside containment and containing 247 anchor-bolts, were selected for UT. Of the 247 anchor bolts examined, 246 were identified with the star-stamp marking. All of these were verified to be of the Super-Hilti typ UT of the one unmarked anchor bolt revealed that this bolt was not a Hilt The original construction / installation documentation package was reviewed in order to assess the condition. The package did not reflect usage of anything other than the required Hilti bolt. Discussions with applicant personnel resulted in their review and subsequent identification of Component Modification Cards (CMCs) which had been misfiled. The CMCs revealed that a Richmond insert had been substituted for a Super-Hilti bolt. Further investigation revealed that Design Change Authorization (DCA) 10633 dated July 20, 1981, had been issued which allowed the use of a shorter Super-Hilti than what was originally called for; i.e.,11 inche This apparently was the result of an interferenc The 11-inch Super-Hilti was installed between July 20, 1981, and August 24, 1981. Subsequently, DCA 13349 dated May 17, 1982, was issued allowing the replacement of i.he Super-Hilti with a Richmond insert. An associated Concrete Chipping Request (CCR) dated May 24, 1982, indicated that the Super-Hilti had pulled out. Required calculations to support the modifica-tion were performed on June 19, 1982. The CCR provides the following instruction: " Chip out concrete 5 inches dia. x 8 inches deep for 1 inch Richmond insert." A handwritten note on the CCR states, " Complete 5-26-82."
An inspection report (IR) No. IRC-7542 dated February 10, 1983, attests that all grouting pre-placemeat, placement, and inspection attributes were satisfactor *
6 During the NRC inspector's review of the above documentation, it was noted that DCA 13349 failed to provide instructions or procedures for the accomp-lishment of the modification activit It was further noted that the
calculations failed to consider the shear capacity of the grout-concrete interfac These conditions constitute a violation of Criterion III of Appendix B to
, 10 CFR Part 50 (445/8516-V-08). s 6. CPRT ISAPs (Excluding ISAP No. VII.c) Inspection Reports on Butt Splices (ISAP No. I.a.2) and Butt Splice Qualification (ISAP No. I.a.3)
Status of CPRT Activity Phase II actions for ISAP No. I.a.2 have been completed and Phase III reinspections are in progress. The splices involved in the reinspec-tions are environmental butt splices, and uninsulated splices covered with heat shrink tubing. The applicant has completed the reinspection of 38 of the 76 cables listed in NCR E-85-1006305, Revision Status of NRC Inspection Activity The review of CPRT ISAP Nos. I.a.2 and I.a.3 has been completed and the review of the Phase III program is in progres A review of the results of 10 cable reinspections, Work Orders C850003404 and 3441, showed that the following NCRs were generated:
NCR N Item (s) Identified E85-101532 One conductor was twisted and the cable bend radius was violate E85-101533 Butt splice " shims" were not installed as had been indicated on a previous I E85-101534 The flexible conduit had a cut in the outer jacke E85-101535, Revision 1 Two torminal blocks were broke E85-101536, Revision 1 Butt splice " shims" were not installed as had been previously indicated in an IR and the heat shrink tubing was not installed in accordance with the manufacturer's instruction E85-1016575 The heat shrink tubing was not installed per the manufacturer's instruction E85-101762 Seven terminal blocks were cracked or broke ..
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NRC inspectors witnessed reinspections of cables E0119863A, E0119865A, E0100821Z, E0100822Z, and EG100861 During inspections of cables E0119863A and E0119865A, it was noted that the length of the conduits between the end device and the associated junction box was longer than allowed by Drawing 2323-EI-1701, Revision 11. This is an unresolved item pending completion of review of the applicability of the drawing detail to the installation (445/8516-U-09).
No NRC violations or deviations were identifie b. QC Inspector Qualifications (ISAP No. I.d.1)
Status of CPRT Activity The Special Evaluation Team (SET) is evaluating information received in TUGCo memorandum TUQ 3426. This memorandum was a response to the SET evaluation of historical electrical and all current non-ASME inspectors' qualification If this additional information is determined to not establish the qualifications for the inspectors, a letter detailing the specific area of inadequacy is sent to the QC manager requesting additional response. Discrepancies not resolved advance the inspector to Phase III of ISAP No I.d.1 for reinspectio Reinspection activity for the seventh inspector placed into Phase III of ISAP No. I.d.1 has been completed and the results report is in preparation. Reinspection activity for an A5ME-related inspector identified for Phase III has not begun and is awaiting inspection packages from B& Status of NRC Inspection Activity The NRC inspector reinspected 33 conductor terminations as part of a continuing check on the adequacy of ERC reinspection effort conducted for Phase III of ISAP No. I.d.1. The NRC reinspection results were in agreement with those obtained by ERC. The SET transmittal and TUGCo response pertaining to qualification status of non-ASME inspectors has been reviewed. Further SET evaluations will be monitored as they are mad No NRC violations or deviations were identifie c. Hot Functional Testing Data Packages (ISAP No. III.a.1)
In order to maintain a correlation between areas inspected and the applicable sections of the ISAP, this inspection report will address each area using the ISAP paragraph number assigned by the applican During the inspection period of August 1-31, 1985 (see Appendix E of InspectionReport'50-445/85-11), paragraphs 4 1.1 thru 4.1.6 were followup inspected, and paragraph 4.1.7 was started but not complete During the inspection period of September 1-30, 1985 (see Appendix E of NRC Inspection Report 50-445/85-13), paragraphs 4.1.7 and 4. '
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were comple ing this inspection period, the remaining paragraphs i No. III.a.1 were followup inspected as indicated below:
4. In accordance with the sampling plan guidelines established by the applicant for the remaining 139 completed preopera-tional test data packages, the applicant committed to sample 60 items comprising test deficiency reports (TDRs), test procedure deviations (TPDs), and FSAR commitments to demonstrate the capability of systems to function as designed. These items were reevaluated utilizing the attributes in Attachment 1 of ISAP No. III.a.1. A followup inspection was conducted by the NRC inspector to ensure both that the results of reevaluations were consistent with the guidelines delineated in Attachment 1, and that the dispositions were consistent with regulatory requirement The NRC inspector sampled 20% of the list of items identi-fied by the applicant. This sampling consisted of seven TPDs, three Tuus, and two FSAR commitment No NRC violations or deviations were identifie .1.10 The applicant committed to incorporate the guidelines of ISAP No. III.a.1, Attachment 1, into the applicable startup administrative procedures to assure that the concerns expressed by the NRC Technical Review Team (TRT) would be addressed in a consistent manner during future test results review The NRC inspector reviewed the Startup Administra-tion Procedures Manual and verified that the above guidelines were incorporated into Revision 6 of CP-SAP-11, " Review, Approval and Retention of Test Results," dated July 8, 198 In addition, the applicant incorporated an improved method of Joint Test Group (JTG) reviews. The procedure now requires all JTG members to document their review comments and submit them to TUGC0 Startup for resolution. The resolutions are then to be documented and redistributed to all of the JTG members, so that each has an opportunity to evaluate the resolution to all comments before approving the data package. The NRC inspector questioned whether or not the comments and resolutions would become a permanent part of the JTG-approved data packages. The response was that the intent of Section 4.2.1.5 of CP-SAP-11, which describes supporting documentation requirements for data packages, is to include the JTG comments and resolution .1.11 The applicant committed to determine the root cause(s) and evaluate the potential for generic implications related to the issues and findings in ISAP No. III. When asked by the NRC inspector to produce evidence that this had been done, the applicant indicated that the final results report would contain the information, but it had not been completed yet. As such, this shall be tracked as an open item (50-445/8516-0-10).
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Followup inspection of ISAP No. III.a.1 is completed pending closure of the above open item and those items identified in Appendix E of NRC Inspection Reports 50-445/85-11;50-446/85-06 and 50-445/85-13; 50-446/85-09; i.e., unresolved item 445/8511-U-02 and open items 445/8511-0-02, 445/8511-0-03, 445/8513-0-07, and 445/8513-0-0 No NRC violations or deviations were identifie JTG Approval of Test Data (ISAP No. III.a.2)
During the 1984 TRT inspection of testing programs, the NRC inspector noted that if a preoperational test is deferred into the Initial Startup (ISU) program, which commences after_ initial fueling, the completed results data would be reviewed by the Station Operations Review Committee (SORC) in lieu of the JTG. The version of the FSAR in effect at the time of the inspection did not provide for this shift in review responsibility; i.e., the FSAR stated that the JTG is responsible for reviewing preoperational test data. Deferring,this testing to another time frame, or incorporating the deferred preoperational tests in ISU procedures, did not in itself relieve the JTG of this responsibilit The action required by Supplement to Safety Evaluation Report (SSER)
No. 7 and accordingly the commitment in.ISAP No. III.a.2 was to revise the FSAR. During the followup inspection, the NRC inspector verified that the FSAR had been revised (see Amendment 54,'Section 14.2) t clarify the division of responsibility between the JTG and the SOR The FSAR now supports station procedures which prescribe the method of deferral of preoperational tests from the preoperational test program, which is the responsibility of the JTG, to the ISU program, which is the responsibility of the SORC, a similarly qualified group. _ This issue is close ~
No NRC violations or deviations were identified, Technical Specifications for Deferred Tests (ISAP No. III.a.3)
During the TRT inspection of test programs in the preoperational test area, the NRC Operations resident inspectors expressed concern that the orderly progress of ISU testing may be hampered by Technical Specification (TS) limiting conditions for operation, due to the nature and extent of the preoperational tests which had been deferred.-
In order to achieve the plant conditions (i.e., hot plant at normal pressure and temperature) to conduct the deferred preoperational
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However, operability cannot be verified until preoperational' testing is completed. Since then, the applicant conducted another hot' testing
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sequence in November and December 1984, at which time most of the deferred tests were completed. In a letter dated January 24, 1985, the NRC closed this issue and thus the concern did not appear in SSER No. ~
There is no followup inspection required. This item is close f. Preoperational Testing (ISAP No. III.d)
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During the TRT inspection of the preoperational testing program, conclusions were reached indicating that none of the related allega-tions and findings had either safety significance or generic implica-tions, except that past document control system problems may have affected the testing program. Details of these conclusions and findings are in SSER No. 7. The primary concern was that past preoperational testing may not have been conducted using fully updated procedures because of the difficulties system test engineers (STEs)
had in obtaining design document update In response to the TRT's concerns over possible past document control impacts on testing, the applicant committed to actions that establish measures to provide greater assurance that current design data was utilized in testing, and to determine whether or not past document control system problems did not adversely affect the testing progra In the ISAP, this is broken down into three action categories:
4. Assessments, administrative procedural changes, and training to ensure an adequate program is in place to maintain test procedures curren . Detailed record reviews to determine the effect of Document Control Center (DCC) problems on the testing progra . Determinationofrootcause(s)andevaluationofthe potential for generic implication The NRC followup inspection of actions taken in accordance with this ISAP commenced with 4.1.1 during this inspection period and will continue during subsequent periods. For the sake of clarity and tracking, the ISAP No. II paragraph numbers are indicated belo .1. The applicant comitted to revise CP-SAP-21, " Conduct of Testing," to include instructions for STEs to review test procedures approximately two weeks prior to the scheduled test date to help facilitate timely updates and thus eliminate last-minute complex reviews. The NRC inspector verified Section 4.9.3 of CP-SAP-21 (Revision 3) as having this requirement as of January 11, 198 .
4.1. The applicant committed to instruct STEs on the new requirements of CP-SAP-21. This was verified to be complete by the NRC followup inspector by review of documented evidence that the training had been completed by January 14, 198 Sections 4.1.1.3 and 4.1.1.4 of ISAP No. III.d involve a review of the CPSES document control program and interviews of STEs to help assess the adequacy of existing procedures and method When the NRC followup inspector attempted to review related documentation, there were only a few rough, hand written notes showing evidence of STE interviews, but no results or actions
, from the review and interviews were available. The applicant
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explained that the final results report would address this, therefore this part of the followup will be conducted late For tracking purposes, this is an open item (445/8516-0-11).
No NRC violations or deviations were identifie g. Plug Welds (ISAP No. V.d)
Status of CPRT Activity Reinspection of the new random sample of 57 ASME Code,Section III supports by ERC has been completed. No unauthorized plug welds were
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identified. This new random sample was required as a result of the f
NRC identifying that the original sample of supports included unauthorized non-ASME Code,Section III support Status of NRC Inspection Activity
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(1) The NRC inspector has witnessed a total of 13 ERC reinspections from the new random sample, of which the following 5 were performed during this report period:
Component Support N Unit N SF-X-002-021-F43S Common SI-2-105-404-052K 2
CC-2-204-421-C53R 2 CC-1-065-007-533R 1 MS-2-RB-004-2 2
During the above reinspections, ERC did not identify any conditions to the NRC inspector as subject to evaluation as potential deviations. The NRC inspector also witnessed the macroetching of four component support base plates which exhibited indications that suggested the possible existence of plug welds. Two of these base plates were identified during the October inspection period. The macroetching confirmed that plug welds did not exis No NRC violations or deviations were identifie i
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(2) A total of four independent inspections has been conducted by the NRC inspector, of which the following three occurred during this report period:
Component Support N Unit N CS-2-AB-067-013-3 2 CC-2-050-700-A43K 2 CS-2-564-701-A33R 2 No NRC violations or deviations were identifie (3) Documentation packages for the 13 reinspected and 4 independently inspected supports were reviewed. No discrepancies or missing documents were identifie No NRC violations or deviations were identified, b. Installation of Main Steam Pipes (ISAP No. V.e)
Status of CPRT Activity The status of CPRT activity has not changed from the last reporting period. The results report is being reviewed by CPR Status of NRC Inspection Activity The preservice inspection documentation; i.e., UT and magnetic particle examination reports are currently being reviewed. In addition, the results of the four UTs performed on the highest stressed areas of loops 1 and 4 will be reviewe No NRC violations or deviations were identifie i. Nonconformance and Corrective Action Systems (ISAP No. VII.a.2)
Status of CPRT Activity A review of current and historical procedures that controlled the processing and documenting of deficiencies has been completed. This review was made to determine if programmatic deficiencies existed in these procedures. Sub populations of nonconformances have been selected from the various systems used to document deficiencie These sub populations were based on-type of documentation, method of processing, and time of occurrence in plant constructio Addition-ally, ASME and non-ASME related deficiencies were divide Random samples have been generated for each sub populatio Review of the documentation is complete for approximately 360 NCR Review of the remaining sub populations is ongoing. If programmatic deficiencies are found, root cause and generic implication will be determine s
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Status of NRC Inspection Activity Checklists used by ERC to evaluate nonconformances were reviewed by the NRC inspector. It was noted that no evaluation of the dispositions for adequacy was made on the checklists. This omission may be resolved by an ERC proposed review of dispositions for technical adequac This is an open item (445/8516-0-12, 446/8513-0-08).
No NRC violations or deviations were identifie j. Audit Program and Auditor Qualifications (ISAP No. VII.a.4)
Status of CPRT Activity The draft of the results report for this ISAP has been written and is undergoing review and revisio Status of NRC Inspection Activity The NRC inspector reviewed background data for verification during a future NRC audit of the corporate audit file No NRC violations or deviations were identifie '
k. Pipe Support Inspections (ISAP No. VII,b.3)
Status of CPRT Activity The reinspections being performed under ISAP No. VII.b.3 deal with pipe supports located in Room 77N and the 42 pipe supports previously inspected by the TRT. All other pipe support populations and their samples are being reinspected under ISAP No. VII.c, " Construction Reinspection / Documentation Review Plan."
(1) Room 77N Pipe Supports Reinspection of the 178 pipe supports in Room 77N, identified as being nonconforming by TRT, has been completed. Of the 238 devi-ations identified, 234 have been evaluated with 229 determined to be vali (2) TRT Issues - 42 Pipe Supports Of the 42 pipe supports identified by TRT as being nonconforming, 17 have been reinspected by ERC. Physical reinspections _ are being accomplished using QI-058, Revision 0. Twenty-six deviations have been issued with 22 processed as being vali _
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Status of NRC Inspection Activity (1) Room 77N Pipe Supports (a) The NRC inspector has reviewed QI-037, Revision 0. To date, seven reinspections have been witnessed. The following seven independent inspections were performed by the NRC inspector during this report period:
Verification Package N Support N Unit N I-S-PS7N-190 SI-1-039-044-S42R 1 I-S-PS7N-031 CC-1-131-010-S43R 1 I-S-PS7N-038 CC-1-155-011-S43R 1 I-S-PS7N-039 CC-1-155-012-543R 1 I-S-PS7N-095 CS-1-158-033-542R 1-I-S-PS7N-129 PS-1-SB-006-004-2 1 I-S-PS7N-143 SI-1-SB-043-008-2 1 (b) During the above independent inspections, the NRC inspector identified the following conditions:
I-S-PS7N-031: The welds joining a wide flange (item 8) to a plate (item 9) consisted of a fillet weld on both sides of the wide flange of approximately 22 inches in lengt Approximately 20 inches of the welds were undersize by a minimum of 1/16 inch with respect to the 1/4-inch _ fillet required by Drawing CC-1-131-010-543R, Revision 4, and a consecutive 2-inch segment was 1/8-inch undersize. The vertical welds on the outside of the wide flange joining two plates (items 9 and 10) were also undersize by a minimum of 1/16 inch for more than 25% of the weld lengt Paragraphs 5.1.2 and 5.3 of B&R Procedure CP-NDEP-200 require-plate and piping welds to be inspected'for siz Review of the applicable operation traveler, CC-1-131.010-S43R, and associated weld data cards showed that the welds had been previously inspected and accepted. As a result of this condition being identified, B&R-initiated NCR XI-70 The failure to identify undersize welds is'a violation (445/8516-V-13).
I-S-PS7N-190: The NRC inspector measured a center-to-center spacing of 10 1/2 inches.between a 1 1/4-inch Hilti bolt and a 1-inch Hilti bolt on adjacent fixtures of support SI-1-039-044-542R. It was ascertained that this installation had been inspected and accepted on December 21, 198 'However, review of Attachment l'in Revision 7 of B&R-Procedure CEI-20 revealed that a minimum center-to-center-spacing of 11 1/4 inches is required between 1 1/4-inch and i 1-inch Hilti bolts. This procedure further stated that this
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~m inimum spacing applies to Hilti bolts detailed on separate
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adjacent fixtures and that violation of_ minimum spacing must be approved by issuance of design change documents by the applicable Comanche Peak Project Engineering design group There was no evidence of any design change documents approving this minimum spacing violation.
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This failure to verify conformance to procedure requirements is a violation (445/8516-V-14).
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(2) TRT Issues - 42 Pipe Supports (a) The NRC inspector reviewed QI-058, Revision 0, and QI-061, Revision 0. To date, three reinspections have been witnessed with the following two performed during this inspection period:
Verification Package N Support N Unit N I-S-PS42-25 CT-1-013-011-S22R 1 I-S-PS42-41 RH-1-020-003-522K 1 (b) During the above reinspections, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations:
I-S-PS42-25: (i) No lock nuts were present on clamp balts, and (ii) location of bolt hole in relation to base plate edge was incorrec I-S-PS42-41: (i) Paint was observed on a spherical hearing, and (ii) material was incorrectly identified.
, Dispositions of the above findings are open items (445/8516-0-15 and 445/8516-0-16).
No NRC violations or deviations were identifie (c) The following five independent inspections were performed by the NRC inspector during this report period:
Verification Package N Equipment N Unit N I-S-PS42-06 AF-1-035-029-S33A 1 I-S-PS42-024 CT-1-013-010-522K l'
I-S-PS42-034 RC-1-052-016-C41K 1 I-S-PS42-033 RC-1-035-700-C41R 1 I-S-PS42-08 AF-1-059-003-S33R 1 (d) During the above independent inspections, the NRC inspecto identified the following conditions:
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16
- I-S-PS42-06
- The NRC inspector observed that three 1 1/4-inch Hilti kwik bolts (from a total of eight), that were used to attach two base plates of support AF-1-035-029-S33A to the wall, had been installed through an embed plate. It was noted that this ir.stallation was inspected and accepted on IR No. 15042 dated March 30, 198 B&R construction Procedure CEI-20, applicable to this installation, was reviewed. Attachment 3 of CEI-20 allows Hilti bolts to be placed as close as practical to the edge of an embedded plate, without damaging the plate, as long as there are no attachments to the plate within a minimum of 12 inches on both sides of the proposed Hilti bolt locatio Subsequent to this report period, applicant personnel showed the NRC inspector that insertion of Hilti kwik bolts through the embed plate had been authorized by DC The adequacy of the engineering basis for the DCA is considered an unresolved item pending NRC review (445/8516-U-55).
7. ISAP No. VI Electrical Cable
> Status of_ CPRT Activity ERC has completed 87 reinspections and 88 documentation reviews of sampled electrical cable as of November 25, 198 Status of NRC Inspection Activity (1) NRC inspectors have, as of November 25, 1985, witnessed 21 ERC reinspections and performed independent reviews of 10 documenta- ;
tion packages. The following three independent reinspections of sampled electrical cable were performed in this report period:
Verification Package N Cable N Unit N I-E-CABL-014 ER140509Z 1 I-E-CABL-063 E9123380 1 I-E-CABL-102 EG139517 1 (2) During the above independent reinspections, the following condition was identified: -
I-E-CABL-102: Reinspection revealed that ERC inspectors did not identify the disagreement of the physical routing with the cable and raceway schedule, as required by Section 5.6 of QI-014, Revision 0, dated July 18, 1985. The cable physically routes into tray T13GCCP80 and then tray T13GCCP81. The cable schedule routes this cable into T13GCCP81 and then T13GCCP80. This is an NRCdeviation(445/8516-D-17).
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i b. Cable Trays j Status of CPRT Activity ERC has completed 89 reinspections and 83 documentation reviews of sampled cable trays as of November 25, 198 Status of NRC Inspection Activity i (1) NRC inspectors have,'as of November 25,19C, witnessed 11 ERC reinspections, performed independent reviews of 7 documentation packages, and performed 6 independent ieinspections of sampled cable trays. The following independent reinspection was
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performed in this report period:
Verification Package N Cable Tray N Unit N I-E-CATY-077 T14BREC28 1 (2) During the above independent reinspection, the NRC inspector identified that F.RC inspectors did not identify a missing bolt and locking device on the splice plate joining tray section ,
T14BREC28 to T14BREC27 as required by Section 5.3.6 of QI-016,
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Revision 1. This is an NRC deviation (445/8516-D-18).
c. Electrical Conduit Status of CPRT Activity ERC has completed 80 reinspections and 80 documentation reviews of sampled electrical conduit as of November 25, 198 Status of NRC Inspection Activity (1) NRC inspectors have, as of November 25, 1985, witnessed 14 ERC
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reinspections, performed independent reviews of 15 documentation packages and performed 5 independent reinspections of sampled electrical condui (2) The following two independent reinspections of sampled electrical conduit were performed in this report period:
Verification Package N Conduit N Unit N I-E-CDUT-036 C12909546 1 I-E-CDUT-048 C16WO9519 1
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No NRC violations or deviations were identifie ,
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4 (3) The following documentation review was performed for an electrical separation inspection in this report perfod: ,
Conduit N Room N Un_it N C12G03270 100 1 During the above review, it was identified that the electrical inspector who signed the " Electrical Separation Punchlist" and
" Electrical Separation Deficiency Report," which were attached to IR E-1-0013528, had been certified for "All QI-QP11.3" as a *
level II inspector, despite having failed the written examination for QI-QP-11.3-29. This condition was ascertained to have been previously identified by the TUGC0 Audit Group (TAG) cnd is being evaluated by SET. Thi's is an open item pending review of the SET 9 evaluationandaction(445/8516-0-19).
No NRC violations or deviations were identifie ,
d. Electrical Equipmegt Installation l Status of CPRT Activity ;
ERC has completed 59 reinspections and 20 documentation review packages of sampled electrical equipment installations as of November 25, 198 ,
Status of NRC Inspection Activity (1) NRC inspectors have, as of November 25, 1985, witnessed 11 ERC reinspections, perforned independent reviews of 10 documentation packages and performed 3 independent reinspections of sampled electrical equipment ir.stallation ,
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I (2) The following ERC reinspection of sampled electrical equipment installation was witnessed during this report period:
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Verification Package N Equipment N '
Unit _N I-E-EEIN-062 1E35 1 During the above reinspection, ERC identified the following i condition as subject to evaluation as a potential deviation:
Nuts on the studs for the penetration were not engaged flush with !
top of stud thread ,
Disposition of the above finding is an open item (445/8516-0-20). ;
No NRC violations or deviations were identifie .
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(3) The following independent 'teinspections of electrical equipment installations were parformed during this rep 6rt period:
Verification, Package N Equipment N Unit N I-E-EEIN+050 CPX-ELDPEC-06 1 I-E-EEIN-055 CPI-ELOPEC-10 1
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No NRC violations or deviations were identified.
'. (4) Independent documentati4n reviews were performed of nine verification packages during this . report perio The results of these reviews are open items per. ding comparison with ERC findings ;
when they become available (445/8516-0-11 through 445/8516-0-29),
e. Instrumentation Equipment _ Installation Status of CPRT Activity ERC has completed 80 reinspections and 97 documentation reviews of !
sampled instrumentation equipment installations as of November :25,198 Status of NRC Insnection Activity
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(1) NRC fr.spectors nave, as of November 25, 1985, witnessed eight ERC reinspections, performed independent reviews of five documentation packages and performed six ir, dependent reinspections of sampled instrumentation equipment installations.
(2) Of the six Independent NRC inspections performed, to date, the
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following four occurred during this report period:
Verification _ Package N Eguipment N Unit N I-E-ININ-051 1- LT-932 .1 I-E-ININ-041 1-LT-930 1 I-E-ININ-049 1-FT-425 1 1-E-ININ-059 1-PT-124 1 During the above reirspections, the following conditions were
identified by the NRC inspector:
I-E-ININ 051: The ERC inspector failed to identify and inspect the required mininum bend radius for Bend No. 5. This berd was accessible for inspectio I-E-ININ-041: Bend No. 5 which was identified by the ERC inspector as being inaccessible for measurement was found to be accessible and inspectable.
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1-E-lNIN 059: '(a) A swagelck fitting rear support C-24-04-51 was observed to be touching the wall, thus violating the air gap requirement; and (b) an air gap violation was identified between '
tee tubing arid the wall penetration at the inside face of the excess letdesn heat exchanger orifice roo I-E-ININ 049: (a) Installation identification tag for the low pressure root valve was incorrectly marked with respect to appitchble instrument identity, i.e., the tag on val e 1-RC-80618 which was assctiated with 01strument 1-FTe425, showed instrument 1-FT-424; (b) less than the required 1/84f nch air gap existed between the high pressure sensing line and a steel member adjacent
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to the isolation valve location; and (c) a loose bolt was observed at the lov pressur6 sensing line flange attachment to the differential pressure type instrumen The above failures to inspect required attributes and identify non-onfor' ming conditions constitute a deviation (445/8516-D-20h 00 ring the abote inspection, the ERC inspector additionally noted that tags on immediat'ely adjacent lay pressure root valves were also incorrectly marltd with retpect to applicable instrument identit Tlie tag on valve 1-8C-80598, which was associated with -
instrument 1-FT-424, showad instrument 1-FT-426. The tag on '
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valve 1-RC-8060B, which was associated with instrumsnt 1-FT*426, ~
showed instrumeht 1-FT-42 ,
(3) irdependept documentation reviers were performed on three '
verification packages during this report period, The l'esults of these rev$ews are open itehis pending comparison with ERC firdings when they becone available (445/85M-0*31 through 445/8516'0-33).
f- pipi.ig Syr*.em Bolted Joir.ts/.Materialp ;
Statys of CFET Activity ERC has completed 72 reinspectlons of piping system bolted joints / materials as of November 23,19Q5, from a total random aird engineered sample size of 73. Seyeo valid deviation repoFts (DRs)
were g'anerated as a result cf the above reinspection ERC has also cQmpleted 65 docm.ent revien on these packages. Eight valid ors have been generated as a result of the above documentation review Status of NRC Inspection Acti_vity i
(1) The NRC inspector has performed five independent inspections, to l date, of which the following occurred during this report period: j Verification Package N Drawing No, Flange N UMt-1 I-M-PBOM-035 BRP-D0-2-0G-056 5 ?
i No NRC violations or deviaticns were ident.ifie :
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(2) The NRC inspector performed independent document reviews of the following packages during this report period:
Verification Package N Drawing N Flange N Unit R-M-PBOM-018 BRP-SW-1-SB-003 1 1 R-M-PB0M-031 BRP-CS-1-AB-001 1 1 R-M-PB0M-042 BRP-SI-1-SB-012 1 1 No NRC violations or deviations were identifie (3) The following independent NRC inspections were performed during September 1985, but were not specifically identified in NRC Inspection Report 50-445/85-13; 50-446/85-09:
Verification Package N Drawing N Flange N Unit I-M-PBOM-003 BRP-CC-1-RB-038 4 1 I-H-PB0M-054 BRP-CC-1-RB-056 1 1 No NRC violations or deviations were identified, Small_ Bore Piping and Instrumentation Tube Welds / Material Status of CPRT Activity Reinspection of a random sample of 60 small bore pipe and instrumentation tube welds and material from Units 1, 2, and common is in progress. To date, 45 small bore piping welds have been rein wected by ERC. No deviations havo been identifie Status of NRC Inspection Activity To date, the NRC inspector has witnessed seven reinspections performe by ERC, none of which occurred during this report period. The following two independent inspections were conducted in this report period:
Verification Package N Pipe and Weld No_ Unit N I-M-SBWM-004 WP-X-073-151R3, 3 Common I-M-SBWM-005 MS-1-221-1303-2, 16 1 No NRC violations or deviations were identifie Large Bore Piping Welds / Material Status of CPRT Activity Visual reinspection of a random sample of 60 ASME Code,Section III large bore piping welds hnd material from Units 1 and 2 is in progress.
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To date, 45 large bore piping welds have been reinspected with one deviation being identified. The deviattor,was evaluatcd as being valid; however, it was determined to r.ot have safety significanc Status of NRC Inspection Activity To date, the NRC it.spectcr has w'itnessed eight reinspections by ERC, none of which occurred during this report period. Tne following independent inspection was conducted in this report period:
Verification Package N Pipe & Weld N Unit N ,
I-M-LBWM-073 CS-X-010-151R3, ISA Comon
No NRC violations or deviations were identift.e . Large Bore _ pipe Supports - Rigid Status of CP_RT Activity j
Reinspection / verification of pipe support installations by ERC is in
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' rocess p with approximately 96% of the population sar.ple completed. A
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total of 164 deviations have been identified of which 136, to date, have been determined to be valid. ERC has determined that 70 of the -
valid DRs are not safety significant, while the reminder are currently being reviewed for safety significanc Status of NRC Inspection Activity (1) To date, five ERC reinspections have been witnessed to assure
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compliance with QI-027, with the following being witnessed during this report period:
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Verification Package N Pipa Support N Unit _N .
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j I-S-LBSR-217 CC-1-197-008-C52R 1 During the reinspection, ERC identified the following to the NRC inspector as subject to evaluation as potential deviations:
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(a) clearances between the pipe -and the support were out-of-tolerance, (b) undersize welds were present, and (c) component n: ember lengths were not shown or) the design drawin Dispositionsoftheabovefindingsareanopenitem(445/2516-0-24).
No NRC violations or deviations were identifie i
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(2) Five independent inspections of pipe support installations have been performed, with the following three inspections performed :
during this report period:
Verification Package N Pipe Support N Unit N I-S-LBSR-006 CC-1-146-008-S43R 1 I-S-LBSR-013 DD-1-016-016-S33R 1 I-S-LBSR-041 CC-1-126-702-F43R 1 ,
During independent review of ERC Verification Package No. I-S-LBSR-041 and the original installation documentation package for pipe support Mark No. CC-1-126-702-F43R, a deviation ,
from commitment (445/8516-D-35) was identified. Section 5.6. '
of QI-027, Revision 0, states, " Verify welds are located as shown on design drawings. Record any welds that are in addition to those specified on the drawings (attachment 6.6)." ERC did not identify or document the existence of two additional field welds which were not specified on the drawings, but were identified by the issuance of " Vendor Supplied Component Modification Records" that documented the performance of field weldin ,
J. Large Bore Pipe Supports - Non-Rigid Status of CPRT Activity Reinspection / verification of pipe support installations by ERC is in process with approximately 83% of the population sample completed. A total of 234 ceviations have been identified of which 187, to date, have been determined to be vali ERC has detennined that 72 of the ,
valid DRs are not safety significant, while the remainder are currently .
being reviewed for safety significanc ,
Status of NRC Inspection Activity (1) To date, six ERC reinspections of pipe support installations have been witnessed to assure compliance with QI-029, with the
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following being witnessed during this report period:
Verification Package N Pipe Support N Unit N I-S-LBSN-043 MS-1-150-033-C52K 1 1-S-LBSN-240 CC-1-040-019-E33S 1 (2) During the above reinspections, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations:
I-S-LBSN-043: (a) Component member length and location were out-of-tolerance, (b) locking devices were missing, (c) spherical ,
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I bearing gap was out-of-tolerance, (d) safety lockwire on snubber capscrew was broken, (e) paint.was present on spherical bearings, r (f) welder identification was not visible on pressure boundary welds,and(g)snubberinterferencewithinsulationwasobserve I-S-LBSN-240: (a) Component member identification was incorrect, (b) bill of material items were not within fabrication tolerances, (c) component member location was out-of-tolerance, (d) shear lug
- to pipe clamp clearances were out-of-tolerance, (e) pipe clamp bolts did not have full thread engagement, (f) locking devices were missing, and (g) one Hilti bolt violated requirements for perpendicularity, l
Dispositions of the above findings are open items (445/8516-0-36 and 445/8516-0-37).
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- No NRC violations or deviations were identifie (3) To date, five independent inspections of pipe support
installations have been perfomed. During this report period, the following inspection was performed to assess the adequacy of i ERC reinspections:
i Verification Package N Pipe Support N Unit No.
j I-S-LBSN-003 SI-1-008-003-S42S 1 This effort revealed that ERC had perfomed the reinspection in accordance with the requirements of QI-02 No NRC violations or deviations were identified.
i k. HVAC Duct Supports
Status of CFRT Activity
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A total of 89 HVAC duct supports were randomly selected from a population of 2580 supports representing Units 1, 2, and common. To i date, ERC has reinspected 55 supports and initiated 142 DRs, primarily in the areas of undersize welds and configuration discrepancies. Of l the 142 DRs,106 have, to date, been established as being valid.
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Status of NRC Inspection Activity (1) To date, the No.C inspector has witnessed seven ERC reinspections, I with the following four being performed during this report period:
( Verification Package N Duct Support N Unit No.-
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l I-S-HVDS-029 SG-785-1H-RIF 1
[
I-S-HVDS-089 CB-810-IN-2BB 1 r I-S-HVDS-103 CB-810-1N-2BD 1 l I-S-HVDS-109 CB-854-2N-C30/C30-1 2 i
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(2) During the above reinspections, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations:
I-S-HVDS-029: (a) Weld symbols and weld locations were incorrect, (b) welds were undersized, and (c) a Hilti Kwik Bolt violated required embedment length.
l I-S-HVDS-089: (a) Member dimensions were incorrect, (b) welding configuration was incorrect, (c) weld sizes were incorrect,
(d) incomplete fusion was noted in welds, and (e) weld undercut was observed.
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I-S-HVDS-103: (a) Dimension violations, (b) duct dimension was
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incorrect, (c) incorrect orientation was observed, (d) welds were undersized, and (e) an unsatisfactory weld profile was note I-S-HVDS-109: (a) Weld location was_ incorrect, (b) welds were undersize, (c) welding was not performed per weld symbol, and (d) minimum thread engagement was unsatisfactor Subsequent to the inspection, DRs were initiated for the above condition Dispositions of the abc/e findings are open items (445/8516-0-38 through 445/8516-0-40 and 446/8513-0-09).
(3) During the witnessing of ERC's reinspection of support CB-854-2N-C30/C30-1, the NRC inspector observed what appeared to be significant damage to Flange Nos.-17 and 18 of Battery Room Ventilation Exhaust Duct System EMD-3. This observed condition was not an attribute being reinspected by ERC at this time, and was therefore not identified. Further examination revealed that this condition most likely was caused during installation, in that the bolted flanges were force bent upwards approximately 30 degrees in order to preclude interference with an adjacent concrete wall. The force bending created a gasket gap of 1/4 inch
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in the trough of the bend which is in excess of the maximum allowable gap of 5/32 inch. A sealant type material was used to fill in the excessive gap. Review of the original installation and inspection documentation revealed that this field modification was neither reported nor documented on a Bahnson Installation Interference Report or a Bahnson Deficiency & Disposition Repor Further, the Bahnson QC IR dated April 1, 1983, which required ductwork inspection for visual damage, reported that joints 1 through 18 of Duct System BRVE-EMD-3 had been inspected and l accepted. This failure to document field modifications and l identify nonconforming conditions is a violation (446/8513-V-10). '
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(4) The NRC inspector conducted the-following five independent ~.
inspections during this inspection period:
VerificationiPackage N Duct Suppor.t N Unit N I-S-HVDS-010 AB-886-1L-WP2 1 I-S-HVDS-066 SG-773-2H-WP5 2 I-S-HVDS-057 SG-852-1J-1E 1 I-S-HVDS-065 CB-830-2N-1CV -2 I-S-HVDS-122 DG-810-2K-PS1 2 i
No NRC violations or deviations were identifie . Reinspection of Containment Liner and Tank Stainless Steel Liner
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Status of CPRT Activity A tank stainless steel liner was 100% reinspected representing 29 weld seam package Sixty-two weld seams were randomly selected from Units 1 and 2 containment liners incloding both dome and cylindrical liners. ERC reinspections and document revie'ws are 100% complet However, changes to QI-031, Revision 0,.are contemplated and may require additional reinspectio Eighty-two valid deviations have been identified by ERC which are currently being reviewed for safety significanc Status of NRC Inspection Activity .
(1) The NRC inspector had previously witnessed 9 reinspections representing approximately 10% of the random sample of 9 The NRC inspector independently reinspected the following three containment liner and tank stainless steel liner weld seams during this report period
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Verification Package N Joint N Unit N !
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I-S-LINR-08 8D 1 l I-S-LINR-12 P88
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I-S-LINR-61 PS2 2
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(2) During the independent reinspections, the NRC inspector noted the following conditions:
I-S-LINR-61: Excessive reinforcement up to 7/32 inch was identified for approximately 80% of the weld length. This weld seam is between the 3/8-inch cylindrical liner plate and a pipe penetration with a 3 to 1 tape QI-031, Revision 0, does not provide specific instructions for the measuring of reinforcement ,
of welds connecting a tapered item to a uniform thickness ite l However, Section 5.1. A3c states, .in p' art, " Verify that the height .
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of the reinforcement on each face of the seam does not exceed 3/32-inch." All NRC measurements were taken from the liner plate to the center of the weld seam. The ERC inspector accepted this attribute without comment or obtaining special instruction This is an NRC deviation (446/8513-D-11).
I-S-LINR-08: The NRC inspector rejected attribute A.1.d of the checklist regarding contour measured from a 10-foot straight edg Section 5.1.Al of QI-031, Revision 0, states, in part, with respect to attribute A.1.d, "The following local contour devia-tions are to be verified: . . . A maximum of 3/4 inch deviation from a 10 foot straight edge placed in the vertical direction between the horizontal weld seams." The NRC inspector measured a 1 1/4-inch deviation from the straight edge. The liner plate-in this location is apparently somewhat convex near the center of a vertical cross section. The NRC inspector measured the 1 1/4-inch deviation by placing the 10-foot straight edge in contact with the liner plate for approximately the top 30% of the vertical cross section and measuring at the bottom of the cross section just above the lower horizontal weld seam. The ERC inspector stated that he measured the deviation from the 10-foot straight edge by placing the straight edge in contact with the greatest inward vertical deviation and adjusting the position of the straight edge until equal maximum deviations exist for the upper and lower portion of the vertical cross sectio The ERC inspector measured a maximum deviation of 3/4 inch using this
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method and accepted the attribute. Values of measurements obtained by these methods are not precise and in this case varied by as much as a factor of two. QI-031, Revision 0, fails to provide concise instructions for the measuring of this attribute,
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This is an NRC deviation (445/8516-D-41).
I-S-LINR-08, -12, and -61: It was noted with respect to the base material local contour attributes for cylindrical liner verifica-tion packages that the ERC inspector had entered "N/A" (not applicable) and " dome only" on the checklists. Section 5.1. in Revision 0 of QI-031 states, in part, "The following local contour deviations are to be verified: A maximum of 1-inch gap between the cylindrical liner or dome shell plate and a 6 feet long template curved to the required radius . . . ." Thus, the local contour attribute is applicable and does apply to the cylindrical liner. The failure to inspect the required attribute is an NRC deviation (445/8516-D-42).
The NRC inspector noted that attribute A.1.b was not applicabl Paragraph 5.1.A.1 of QI-031, Revision 0, states, in part, with respect to attribute A.1.b, "The following local contour deviations are to be verified: . . . A maximum 1 1/2-inch gap when the 6 feet long template is placed across 'the dome weld l
seams when measuring horizontally or vertically." Therefore, l attribute A.1.b applies only to the dome weld seams. Review of the completed checklists revealed that the ERC inspector had
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accepted this attribute for these three verification packages
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which are weld seams on the cylindrical _ liner. The.NRC inspector then reviewed the ERC Description Memorandum QA/QC-RT-293 which lists Gibbs and Hill (G&H) Containment Liner Specification 2323-SS-14, Revision 4, dated January 10, 1979, as a reference for developing QI-031 Revision 0. Paragraph 8.2.2.1.2.b in G&H Specification 2323-SS-14, Revision 4, states, in part, "The -
i following deviations are acceptable: . . . A 1 1/2 inch gap when
- the template above is placed across one or more welded seams,"
and applies to both the cylindrical liner and the dome line ; This conflict between the G&H specification and attribute A. i
.of QI-031, Revision 0, is an NRC deviation (445/8516-D-41).
- Structural Steel
! Status of CPRT Activity
$ Reinspection of the first random sample of 60 structural steel members is approximately 25% complete. Twenty-five valid deviations have been identified. The second sample, which is related to safe shutdown l systems, has not yet been selected.- Documentation review procedures
! have not been issue Status of NRC Inspection Activity
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(1) Seven reinspections have been partially witnessed (welding inspection is not complete), representing approximately 12% of the first random sample. The following four ERC reinspections were witnessed by the NRC inspector during this report period:
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Verification Package N Equipment N Unit'No.
- I-S-STEL-059 AFCO-MK-F180-1-RB 1-
, I-S-STEL-007 liK-12 1 I-S-STEL-066 DCA 16019 MK-10 Common
- I-S-STEL-010 AFC0-C70-3-SA 1-I (2) During the above reinspections, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations
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[' I-S-STEL-059: Numerous attributes _were rejected including bolt hole coverage and edge distance, bolt size, and weld locatio Paint removal was requested to allow for adequate surface inspection of the weld 4 - !
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I-S-STEL-007: An extra bolt hole, not identified in the field performed alterations, was~noted. Bolt contact was also. rejecte ~
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i . Verification Package No. I-S-STEL-007 involves the reinspection i of a sump screen in the Unit 1 reactor building. The screen is a
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vendor assembled frame bolted to a -structural steel framewor ! The screen is-included in_the ERC Population Description under
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" Vendor assembled frames and bents," but is not actually a
- structural member. The validity of the structural steel population is being evaluate I-S-STEL-066: Hilti bolt size and field installed associated details (size of components) were rejecte I-S-STEL-010: Numerous attributes were rejected including bolt spacing, configuration and edge distance, connection orientation and location, limit of alterations, and location of membe This package is a monorail support member that is installed at an angle of approximately 60 degrees between the monorail and the support member. The drawings indicate an installation angle of 90 degree Dispositions of the above findings are open items (445/8516-0-43 through 445/8516-0-46).
No NRC violations or deviations were identifie n. Concrete Placement Status of CPRT Activity Reinspection of the first random sample of 60 concrete placement packages is approximately 98% complete. Reinspection of the second sample related to safe shutdown systems is approximately 40% complet Thirty-one deviations have been identified related primarily to unfilled holes, voids, and debris in the concrete surface. Of the 28 deviations which have been evaluated, 25 were identified as valid.
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These are currently being reviewed for safety significanc Documentation review procedures have not yet been issue Status of NRC Inspection Activity
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(1) The NRC inspector has witnessed a total of 12 reinspections' to date. The following three ERC reinspections were witnessed by the NRC inspector during this report period:
Verification Package N Concrete Placement N Unit N I-S-CONC-079 IRCN-CPC-201-4822-007 2 I-S-CONC-076 IRCN-CPC-201-6885-010 2 I-S-CONC-069 IRCN-CPC-101-8805-001 1 (2) During the above reinspections, ERC identified the following conditions to the NRC inspector as subject to evaluation _a ,
potential deviations:
I-S-CONC-079: The locations and sizes of installed concrete !
cast-in place Richmond inserts were out-of-tolerance. Embedded plates were installed too close to cast-in place insert I l
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I-S-CONC-076: The locations of installed concrete cast-in place Richmond inserts were out-of-toleranc Dispositions of the above findings are open items (446/8513-0-12 and 446/8513-0-13).
No NRC violations or deviations were identifie (3) The NRC inspector independently reinspected the following five concrrte placements during this report period, representing approximately 5% of the first and second samples:
Verification Package N Concrete Placement Unit N I-S-CONC-017 IRCN-CPC-003-4860-023 Common I-S-CONC-003 IRCN-CPC-002-5852-025 Common I-S-CONC-016 IRCN-CPC-205-6810-010 2 I-S-CONC-015 IRCN-CPC-002-4790-040 Common I-S-CONC-057 IRCN-CPC-002-E852-370 Common (4) During the above independent reinspections, the NRC inspector identified the following conditions:
I-S-CONC-015: During review of the ERC inspection checklist subsequent to the NRC inspection, the NRC inspector observed that attribute 3.A of the checklist (surface inspection of walls, etc.)
was not signed off. Therefore, it could not be established whether or not ERC had performed the required reinspection of this attribut Section 5.2.4 of ERC Procedure CPP-009, Revision 1, requires the lead inspector (Level III) and the lead discipline engineer to ". . . ensure that reinspection /
documentation review results are clear, accurate, and complete."
The incomplete checklist for Verification Package No. I-S-CONC-015 had been approved by both the lead inspector and the lead discipline engineer. This is an NRC deviation (445/8516-D-47).
I-S-CONC-057: The NRC inspector identified dirt in the construction joint and a void with a depth of at least 11/2 inches. The void and dirt were not identified by the ERC inspector. Further review of the inspection checklist revealed that the ERC inspector had entered "N/A" (not accessible) and
" coated" with respect to attribute 3.A. Section 5.3.A of QI-043, Revision 1, states with respect to concrete surface inspection,
" Inspect all accessible surfaces for honeycombing and void (Inaccessible surfaces are those cast against earth, backfilled, or coated)." The NRC inspector observed the concrete placement associated with this verification package and found that it was not coated on any surface and was accessible. This is an NRC deviation (445/8516-D-48).
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o. Small Bore Pipe Supports Status of CPRT Activity Reinspection of the first and second samples of small bore pipe supports is approximately 97% complete. A total of 67 valid deviations have been identified related primarily to Hilti bolt embedment, hole spacing and edge distance in base plates, and pipe clearance Documentation review is approximately 99% complete with 31 valid deviations identifie Status of NRC Inspection Activity Six reinspections were previously witnessed by the NRC inspecto There was no NRC inspection activity during this report perio p. Pipe Whip Restraints Status of CPRT Activity ERC has completed 28 reinspections of pipe whip restraints out of the planned sample size of 11 Nine valid ors have been identifie Status of NRC Inspection Activity (1) The NRC inspector has witnessed four ERC reinspections, to date, of which the following occurred during this report period:
Verification Package N Support Identification Unit N I-S-PWRE-057 -M40-S1-0588 1 I-S-PWRE-053 FW-1-018-906-C67W 1 (2) During the above reinspections, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations:
I-S-PWRE-053: (a) Gaps existed between the plate and the top of the washer (0.164 inches) and between the bottom of the washer and the nut (0.140 inches) on the upper right anchor bolt of the reactor side plate, (b) a gap of 0.122 inches existed between the washer and the top of the nut on the middle left anchor bolt on the reactor side plate, and (c) the capture plate on the reactor side was 1/16 inch out of location from drawing requirement Dispositions of the above findings are an open item (445/8516-0-49).
No NRC violations or deviations were identified.
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q. Instrument Pipe / Tube Supports Status of CPRT Activity ERC has completed 46 out of the planned 102 reinspections of instrument pipe / tube supports. Twenty-eight DRs have been validated from a current total of 29 that have been reviewed by the population engineer. Two hundred and sixty-three deviations have not yet been reviewed for validit Status of NRC Inspection Activity The NRC inspector has performed, to date, four independent inspections of which the following occurred during this report period:
Verification Package N Instrument Tag N Unit N I-S-INSP-010 1-PI-4770 1 I-S-INSP-033 1-LT-462 1 While performing the above independent reinspections, it was observed and noted with respect to support 33A, that the serrated grooves on the spring nuts did not align with the channel clamping ridge as required by attribute 4.5 of QI-05 However, the ERC inspector signed off the attribute as being acceptable. This is an NRC deviation (445/8516-D-50).
r. Category I Conduit Supports Status of CPRT Activity A total of 110 Category I conduit supports were randomly selected from a population of 5500. The number of supports inspected, to date, is 7 Physical reinspections are being accomplished using QI-053, Revision 0, and are approximately 64% complete. Nineteen deviations have been identified and are being reviewed t,y ERC for validity and safety i significance. Two have been processed and were found to be not vali '
Status of NRC Inspection Activity (1) The NRC inspector reviewed QI-053, Revision 0, and QI-054, Revision 0, and witnessed the following three reinspections during this report period:
Verification Package N Equipment N Unit N I-S-COSP-046 C03609956-04 1 I-S-COSP-073 C-140-06419-01 1 I-S-COSP-071 C-14W-13102-05 1 (2) During the reinspections, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations:
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I-S-COSP-046: A 3/8-inch Hilti, on south end, had a 1/8-inch gap
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between unistrut and wal I-S-COSP-071: (a) Plate size was incorrect, and (b) a nut was
. bottomed out on Hilti bolt thread Dispositions of the above findings are open items (445/8516-0-51 and 445/8516-0-52).
No NRC violations or deviations were identifie s. Documentation Review of Fill and Backfill Placement Status of CPRT Activity Documentation review of the sample of 120 fill and backfill placements is approximately 92% complete. A total of 254 deviations have been identified and are being evaluated for validit No physical reinspections are planne Status of NRC Inspection Activity The NRC inspector reviewed Revision 3 of QI-05 No independent document reviews have yet been performe No NRC violations or deviations were identifie t. Field Fabricated Tanks Status of CPRT Activity The population consists of eight tanks which were fabricated on site, four of which are inaccessible. Reinspection by ERC is in process and is approximately 60% complete. A total of 54 deviations have been identified which are being reviewed by ERC for validity and safety significance.
a Status of NRC Inspection Activity (1) The NRC inspector reviewed QI-041 for accuracy and adequacy, and witnessed 10% of the ERC reinspection effort on the following four tanks: l Verification Package N Unit N l I-M-FFTA-01 Common (1)
! I-M-FFTA-02 Common (1)
I-M-FFTA-03 Common (1)
I-M-FFTA-04 Common (1) ,
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(2) During the above reinspections, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviations:
I-M-FFTA-01: (a) A stitch weld was used where a full length
- weld is required, (b) weld size was indeterminate on lap joints, (c) a 3/8-inch fillet weld was specified on 1/4-inch thick material, (d) Bill of Material item 6 to 11 fillet weld had an
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insufficient weld throat size,.(e) seismic restralit gussets had
! insufficient weld throat size, and (f) anchor bolt ring chairs had undersize weld '
, I-M-FFTA-02: (a) A stitch weld was used where a full length weld is required, (b) weld size was indeterminate on lap joints, (c) undersize fillet weld was present at nozzle locations No. 1 and 15, (d) Bill of Material item 11 to tank shell had an undersize fillet weld, (d) Bill of Material item 11 to item 6 fillet weld had an undersize throat, (f)-fillet welding on the davit bracket was undersize, and (g) anchor bolt ring chairs had undersize weld Dispositions of the above findings are open items (445/8516-0-53 and 445/8516-0-54).
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No NRC violations or deviations were identifie (3) Due to the small population, the NRC inspector performed
- independent inspections of approximately 15% of the defined
{ attributes on the four accessible tanks. This effort revealed that reinspections were performed in accordance with the 1 requirements of QI-04 No NRC violations or deviations were identifie . Exit Interview
- An exit interview was conducted on Dec0nber 4,1985, with the applicant representatives denoted in paragraph 1 of this appendix. During this interview, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the findings.
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