IR 05000445/1985018

Insp Repts 50-445/85-18 & 50-446/85-15 During Dec 1985. Violations & Deviations Noted:Inadequate Design Change Control Measures & Noncompliance W/Approved Instruction in Performing Insps

ML20198E859
Person / Time
Site:	Comanche Peak
Issue date:	05/06/1986
From:	Barnes I, Ellershaw L, Hale C, Will Smith, Tomlinson D, Wagner P, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198E698	List: ML20198E692 ML20198E838 ML20198E850 ML20198E853 ML20198E859
References
50-445-85-18-01, 50-445-85-18-1, 50-445-86-18, 50-446-85-15, 50-446-86-15, NUDOCS 8605280309
Download: ML20198E859 (26)

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APPENDIX D

COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT U.S. NUCLEAR REGULATORY COMMISSION

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REGION IV

i NRC Inspection Report: 50-445/85-18 Permits: CPPR-126 50-446/85-15 CPPR-127 I

Dockets: 50-445 Category: A2

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50-446 Applicant: Texas Utilities Electric Company (TVEC) ,

Skyway Tower s 400 North Olive Street

! Lock Box 81 j Dallas, Texas 75201 i

Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 & 2 >

Inspection At

Glen Rose, Texas Inspection Conducted: December 1-31, 1985 Inspectors: M I" l' I4 L.'E. Ellershas, Reactor Inspector, Region IV Date

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CPSES Group j (paragraphs 1, 5.e, and 6.e-6.r)

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! W. F. Smith, Resident Reactor Inspector (RRI) Date i

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Region (paragraphs IV CPSES Group )

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0 C. , Reactor Inspector, Region IV s/dsk Date '

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, CPSES roup (paragraphs 1, 4.a. and 5.b)

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&%W P. C'. Wagner, Reagtor Inspector, Region IV S/t/64 Dat'e i

l l CPSES Group i (paragraphs 1,3,4.b,5.a.and6.a-6.d)

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GROS 200309 860512

! G ADOCK 05000445 ,

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A &W D.'P. TomWs6n, Reactor Inspector, Region IV S~-o Gb6>

Date (paragraph 5.d)

Consultants: EG&G - J. Dale,

A. Maughan, i W. Richins, R. VanderBeek, V. Wenczel Parameter - J. Birmingham, J. Gibson, K. Graham, D. Jew Reviewed By

ba e s 6/5/d'd I. Barnes, Group Leader, Region IV CPSES Group Date Approved: - -

! - 4 T. F. Westerm'an, Chief, Region IV CPSES Group Date'

Inspection Summary Inspection Conducted: December 1-31, 1985 (Report 50-445/85-18; 50-446/85-15)

Areas Inspected: Nonroutine, unannounced inspection of applicant actions on previous inspection findings, Comanche Peak Response Team (CPRT) issue - specific action plans (ISAPs) and assessment of allegations. The inspection involved 1718 inspector-hours onsite by seven NRC inspectors and nine consultants. A summary of NRR and IE audit / inspection activities is provided in paragraph 2 of this appendi Results: Within the three areas inspected, four violations (failure to certify inspectors in accordance with procedural requirements, paragraph 5.b; excessive conduit length between an end device and its associated junction box, para-graph 3.a; inadequate design change control measures with respect to assuring performance of required actions, paragraph 6.d; absence of required identifica-tion on thermo-lagged raceways, paragraph 6.b) and three deviations (failure to document, disposition, and track drawing change discrepancies with respect to effect on preoperational tests, paragraph 5.c; failure to comply with approved instructions in performances of inspections, paragraphs 6.d, 6.f. and 6.n; 1 inadequate engineering review of piping isometric for applicability of an inspection attribute, paragraph 6.r) were identified.

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-3-DETAILS Persons Contacted C. T. Brandt, TUGCo Quality Engineering Supervisor

• R. E. Camp, Assistant Project General Manager, Unit 1 (Impell Corp.)

J. Cordoza, TUGCo System Engineer

• G. Counsil. Executive Vice President, TUGCo C. G. Creamer TUGCo Mechanical Engineer S. M. Franks, Special Projects and Technical Support Lead (Impell Corp.)

E. L. Gastenel, TUGCo System Test Engineer

• P. E. Halstead, TUGCo Site QC Manager B. Holmes, TUGCo QC Electrical Supervisor M. Keathley, ERC Lead Electrical QC Inspector R. R. Komrow, TUGCo Senior Project Engineer J. T. Merritt, Jr., TUGCo Assistant Project General Manager G. M. McGrath, TUGCo Licensing / Compliance Supervisor C. K. Moehlman, TUGCo Project Mechanical Engineer A. A. Patterson, ERC Reinspection Engineering Supervisor C. M. Puffer, TUGCo System Test Engineer J. G. Red, TUGCo Technical Support Supervisor J. E. Rushwick, CPRT Issue Coordinator

• A. B. Scott, TUGCo Vice President, Nuclear Operations B. Shair, ERC Lead Electrical Engineer M. Shealey, ERC Lead Mechanical QC Inspector J. C. Smith, TUGCo Operations QA C. Spinks, ERC Inspection Supervisor P. Stevens, TUGCo Electrical Engineer

• J. F. Streeter, TUGCo Assistant to Executive Vice President

• T. G. Tyler, TUGCo CPRT Program Director W. I. Vogelsang, TUGCo Electrical Coordinator C. H. Welch, TUGCo QC Services Supervisor J. R. Wells, TUGCo Director QA 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 . NRR and IE Audit / Inspection Activities NRR: An audit was performed on December 6, 1985, at Stone & Webster Engineering Corporation (SWEC), New York City, New York, with respect to status of piping and pipe support efforts, results of Procedure CPP-8 engineering walkdown, and approach for resolution of special technical issues. An audit was performed on December 10,1985, at TERA, Bethesda, Maryland, of the system used to track CPRT statu A site inspection was performed with Region IV participation during December 12-13, 1985, of as-built information for Unit 2 cable tray

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i-4-f supports. The results of the site inspection will be included in a Region IV inspection report. A copy of the SWEC and TERA audit reports will be placed in the Public Document Room upon completion, IE: No inspection activity occurred during this report perio . Applicant Actions on Previous Inspection Findings (Closed) Unresolved Item (445/8516-0-09): Apparent excessive length of conduit between an end device and its associated junction bo Additional review confirmed that the maximum conduit length require-ment of Drawing 2323-El-1701, Revision 11, was applicable to this installation. The failure to control the conduit length between the end device and the junction box is an apparent violation (445/8516-V-01). Additional information on this subject is contained in paragraph 5.a of this appendi (0 pen)OpenItem(445/8511-0-14): Fire wrap damage. Additional examples of damaged fire wrap blankets were observed on conduits C15W11989, C15W11119, C15W16160, C14G19934, C14G19936, and C14Y1121 The applicant has issued nonconformance reports (NCRs) E86-100003s through E86-100008s for the above deficiencies. This item will remain open pending NRC review of the Unit 1 area closecut procedures which will, in part, require inspection for damaged fire wra . Assessment of Allegations A-34 (AQ-166): Inadequate Certification Testing of Electrical Inspectors It was alleged that inadequately structured tests were used to certify electrical inspectors. The program for electrical inspector qualification, training, testing, and certification has been previously assessed by the NRC and is documented in NUREG-0797, Supplement No. 7. The results of the NRC assessment are provided on page J-58 of Appendix J, Supplement No. 7. The NRC found evidence that the electrical QC inspector qualification program lacked pro-grammatic controls and required the applicant to accomplish the following: (1) evaluate the electrical inspector testing program and develop a program that includes procedures for scoring retests, and question disqualification; (2) justify bases for visual examinations; (3) review all electrical inspector files for compliance with require-ments;and(4)assessthegenericimplicationsoffinding The applicant responded to these NRC findings in Appendix C of the CPRT Program Plan in ISAP Nos. I.d.1 and I.d.2. In ISAP Nos. I. and I.d.2, the applicant commits to, among other things, review the qualification / certification of all current and historical electrical inspectors and to reassess the total prcgram for inspector

-5-qualification / certificatio NRC is currently evaluating the responsiveness of the applicant's proposal and is inspecting the implementation of the applicant's commitment In summary, the NRC substantiated the subject allegation during earlier assessments and the applicant has initiated corrective and preventive measures, which the NRC is continuing to inspec b. 4-85-A-103: Electrical Bonding Clamps and Improperly Rated Pump Concerns were raised that: (1) the electrical cable tray grounding l

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wire clamps were not acceptable because they were not Underwriters Laboratory (UL) approved, and (2) the motors for the emergency diesel generator (EDG) fuel oil (F0) transfer pumps were not of the explosion proof design required for this applicatio The concern over the acceptability of the cable tray grounding clamps was based mainly on the fact that the devices were not marked with identification which showed that they were acceptable to UL. NRC inspector review of the grounding clamps in use showed that they are

[ Thomas & Betts Corporation, Catalog No. 10103, Grounding Connectors,

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made of malleable iron with a "Tabolite" finis Additional information from the manufacturer described "Tabolite" as a tradename for electrozinc plating applied to the connectors and showed that the connectors were UL listed in File E3066. Accordingly,

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the installed grounding clamps appeared to be acceptable.

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The concern over the acceptability of nonexplosion proof motors for l the EDG F0 transfer pumps was also evaluated by the NRC inspecto The National Electric Code (NEC), which is committed to by Section 8.1.4.7 of the Final Safety Analysis Report (FSAR), was reviewed to determine the normal industrial requirements for handling flammable liquids. Since the EDG F0 is normally confined within a closed system (from an underground tank through pipes to the transfer pump through pipes to another tank), the NRC inspector determined that the appropriate NEC classification for the EDG area was Class I, Division 2. Article 501-8(b) of the NEC specifically allows the use of nonexplosion proof mechanisms for handling flammable liquids in Class I, Division 2 application Therefore, the NEC would not require the use of explosion proof motors for the EDG F0 transfer pump The NRC inspector reviewed additional documents to further evaluate the above concer A review of the FSAR showed the EDG FO was specified as No. 2 F0 (paragraph 9.5.4.2.2.5), and a review of the National Fire Code produced the following additional information: (1) the flash point for No. 2 F0 was indicated to be 126 F to 704 F (NFPA 325M); and l

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% (2) a flammable liquid was defined as a liquid with flash pc.nt below 100 F, while a combustible' liquid was one with a flash point above 100 F (NFPA 321).

Based on the above information, it was ascertained that the'EOG F0 was considered to be a combustible and not a flammable liqui Therefore, the electrical equipment installed to handle the EDG F0 was not required to meet the special precautians contained in Article 500 of the NEC,,such as the use of explosion proof motor Accordingly, the use of nonexplosion proof motors for the EDG F0 Transfer Pumps was found to beJacceptabl In conclusion, the concerns / allegations were not substantiated, nor were areas of safety significance identifie A copy of the inspection report will be providcd to the individuals associated with these concern . CFRT 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 I and Phase II of the butt splice review have been complete TUGCo is presently performing Phase III of this issue under NCRs E8S-100588s and E8-100630s. The required inspections and procedure revisions for the butt splice qualification issue have been complete The draft results reports for these actions are being prepare Status of NRC Inspection Activity The NRC inspector performed a followup inspection of Unresolved Item 445/8516-U-09 during this report period, as referenced in paragraph 3.a of this appendix. The noted condition was observed during witnessing of a reinspection of cable butt splices for two solenoid valves, IHV-4631A and IHV-46318, for.. the primarytcoolant sample supply return and isolation valves. . Detail 18C of ,

Drawing 2323-El-1701, Revision 11, which limits conduit length to -' -

15 feet between an end device and.its associated junction box, was determined to be applicable to the cable for these solenoid valve ,

The observed installed conduit length of approximately 30 feet is an apparent violation (445/8518-V-01).

A reinspection of a field installed butt splice for electrical penetration assembly IE76, for the Unit 1 containment spray isolation valve tank, was witnessed during the period. The NRC inspector noted during this inspection that the heat shrinkable tubing over vendor -

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-7-installed outboard penetration conductor splices appeared to be shorter than required by the tubing manufacturer. Additional review raised questions in reference to the qualification and acceptability of this assembly and other assemblies supplied by Bunker Ramo. This issue is an unresolved item pending completion of an NRC special inspection on this subject. (445/8518-U-02; 446/8515-U-01).

b. Guidelines for Administration of QC Inspector Tests (ISAP No. I . d. 21 Status of CPRT Activity The Special Evaluation Team (SET) reviewed a sample of inspector certificatiors which were given since the issuance of Revision 18 of TUGCo Procedure CP-QP-2.1, "Trainirg of Inspection Personnel."

These certifications were reviewed to assess the implementation of recent changes in the inspector certification program. Concerns relative to certification of four inspectors were transmitted to the TUGCo QC Manage The TUGCo response is under evaluation by the SE Status of NRC Inspection Activity The NRC inspector's review of the four SET questioned certifications identified an apparent violation (445/8518-V-03; 446/8515-V-02). A field performance demonstration was noted to have been administered by a Level III who was not certified for that activity and on-the-job training waivers were observed to have been granted without identifying those procedures which formed the bases for the waivers, c. Preoperational Testing (ISAP No. III.d)

During the NRC Technical Review Team (TRT) inspection of the preoperational testing program, conclusions were reached indicating that none of the related allegations and findings had safety signifi-cance or generic implications, except that past document control system problems may have affected the testing program. Details of these conclusions and findings are in Safety Evaluation Report Supplement No. 7 (SSER-7) dated January 198 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 impat.ts 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 had an adverse affect on the testing progra In the ISAP, these commitments are 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 O-8-4. Detailed record reviews to determine the effect of DCC problems on the testing progra . Determination of root cause(s) and evaluation of the potential for generic implication The NRC followup inspection of actions taken in accordance with this ISAP commenced with 4.1.1 during the previous inspection period of November 1985. The results of this inspection are documented in Appendix 0 of NRC Inspection Report 50-445/85-16; 50-446/85-1 For tracking purposes, the paragraph numbers that appear in ISAP No. III.d are indicated below. In this report period, inspection continued with 4.1.2, which is a determination of the impact DCC problems might have had on the testing progra .1. A random sampling program was established by the CPRT to determine if DCC problems adversely affected the testing program. First, the CPRT established the time period in question, which was from the start of prerequisite testing (prerequisite testing commenced before the start of preoperational testing) until May 15, 1984. The May 15 cutoff date was set on the basis that CPSES Monitors Team monitoring reports reported no significant DCC problems that could affect testing past that dat Documentation reviewed during this folloWJp inspection and TRT findings reported in SSER-7 support this approac .1. A review was performed to define the set of items to be evaluated in the prerequisite testing and in the preoperational testing areas. This review yielded a population of potential test impact changes to design documents from which to sample in accordance with the sampling plans described in the'ISAP attachments. The NRC inspector reviewed the documentation supporting this review and found no problem .1. The CPRT committed to perform a review of all prerequisite ,

test procedures (XCPs) to identify those which require the use of documents controlled by DC All design documents of this type were to be included in the prerequisite' test population. The NRC inspector reviewed the documentation population from which the random samples were drawn was about 78,000 documents. There were no discrepancies foun .1. The CPRT committed to perform a review of preoperational test procedures (pts) and retests to obtain a list of all DCC-controlled flow diagrams and electrical schematics that applied to preoperational testing during the period of-interest defined in 4.1.2.1 above. Those tests that were completely reperformed after the period of interest were to be eliminated because any changes in_ design that

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-9-might have been missed during the period of interest would have been picked up by the subsequent reperformance tes The resultant population of DCC-controlled documents represented approximately 1100 items subject to change without the Startup Organization being aware of it so that the affected pts could be updated and/or retesting performed. The NRC inspector reviewed the documentation of the CPRT's review and sample population generation and found no discrepancie .1.2.5 As committed in the ISAP, the CPRT Task Force developed detailed sampling plans as reflected in the attachments to ISAP No. III.d. Upon reviewing the documentation files supporting this action, the NRC inspector found no problem .1.2.6 Examination of testing records was conducted on all 60 XCP and all 60 PT sample items as evidenced by the signed evaluation sheets which were reviewed by the NRC inspecto The NRC inspector conducted a detailed inspection on 20 percent of the sample items. There were no problems found in the XCP sample items; however, the PT sample items showed that the STEs had failed in many instances to update the pts prior to performance to show the current reference drawing revisions. Section 4.9 of CP-SAP-21, " Conduct of Testing," requires the STE to update the procedure prior to performance to ensure the PT will adequately test the current as-built design. Probing this further, the NRC inspector checked all 60 PT sample packages and found that 34 of the packages contained data showing that pts were conducted without evidence of having updated all of the references. This finding was not identified and documented by the CPRT as a discrepancy as committed in Appendix E to the CPRT Program Plan. However, in all but three sample packages, the CPRT conducted and documented a review of all revisions since the tests were performed to ensure the as-built systems were properly tested. No discrepancies were identified. In the three cases where such a review was not documented, the applicant's representatives assured the NRC inspector that the review was performed in the same manner as the other Since some of the samples referenced the same pts (because many drawings are referenced in each PT), an actual total of 26 pts were performed withcut the references updated in accordance with CP-SAP-21, Section 4.9. Failure of the CPRT Task Force to document and track this discrepancy is a deviation from the commitment in Section D of Appendix E to the CPRT Program Plan (445/8518-D-05).

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-10-The issue of STE failures to fully update the referenced drawing section of the pts was the subject of an unresolved item (445/8502-08) and an open item (445/8502-12) in the January 1 through February 28, 1985, NRC Inspection-Report 50-445/85-02. These items were both closed in NRC Inspection Report 50-445/85-14 (Appendix C) on the basis that the drawing changes had no impact on the test. To prevent this type of issue from emerging in the future, the applicant has undertaken administrative control change Review of these changes for acceptability by the NRC shall be tracked as an open item (445/8518-0-06).

Twelve of the 60 sample items for pts did not have the screening check lists fully completed. Screening check lists were utilized by the CPRT to develop the minimum sampling of 60 documents which have the highest probability of impacting testing as a result of possible DCC problem The sample item numbers were P53, P104, P272, P298, P399, P426, P432, P515, P518, PS20, P525, and P535. These items included those discussed above which did not document a CPRT Task Force review of all revisions made since the pts were performe Actions taken by the CPRT to complete these records shall remain an unresolved issue pending future discussion and followup inspection (445/8518-U-07).

The committed actions of 4.1.3, that is, the determination of root causes, evaluation of the potential for generic implications, and resultant corrective actions could not be inspected during this report period because the final results report was not yet availabl Accordingly, the inspection will be performed at a later date and shall be tracked to completion as an open item (445/8518-0-08).

d. 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 draft results report is being worked on by CPR Status of NRC Inspection Activity The CPRT performed repeat radiographic (RT) and Section XI ultrasonic (UT) examinations on two welds in Loop 1 and two welds in loop 4 to further support the analytical conclusions that the quality of piping and welds was not affected by installation practices. NRC inspection of these examination records confirmed CPRT findings that the quality of the piping and welds was not affected. The NRC inspector also verified that the RT and UT examinations were performed by personnel certified to at least Level II in accordance with SNT-TC-1A-requirement No NRC violations or oeviations were identifie ______ __

e-11-e. Pipe Support Inspections (ISAP No. VII.b.3)

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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 Rainspection/ Documentation Review Plan."

(1) Room 77N Pipe Supports Reinspection of the 178 oipe supports in Room 77N, identified as

, being nonconforming by the TRT, has been complete Of the 238 deviations identified, 234 have been evaluated with 229 determined to be vali (2) TRT Issues - 42 Pipe Supports Of the 42 pipe supports identified by the TRT as being nonconforming, 40 have been reinspected by ER Physical reinspections are being accomplished using ERC Quality Instruc-tion (QI) QI-058, Revision Of the 87 deviations identified, to date, 46 have been evaluated and 44 were determined to be vali Status of NRC Inspection Activity (1) Room 77N Pipe Supports To date, seven reinspections have been witnessed, none of which occurred during this report period. Eight independent inspec-tions have been conducted with the following one being performed during this report period:

Verification Package N Number System Unit N PS7N-061 H-CS-1-SB-054-013-2 Chemical 1

& Volume Control No NRC violations or deviations were identifie (2) TRT Issues - 42 Pipe Supports There were no NRC inspections performed in this area during this report perio e

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-12- ISAP NO. VI Electrical Cable Status of CPRT Activity:

ERC completed 88 reinspections and 89 documentation reviews of sampled electrical cable as of December 30, 198 Status of NRC Inspection Activity:

(1) NRC inspectors have, as of December 30, 1985, witnessed 21 reinspections, performed independent reviews of 10 documenta-tion packages and performed 6 independent reinspections of sampled electrical cable. The following three independent reinspections of sampled electrical cable were performed in this report period:

Verification Package N System Cable N Unit No.

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l I-E-CABL-025 Main Steam EG145713 1 I-E-CABL-026 Chilled Water Recirculation Pump EG111199 1 I-E-CABL-092 Steam Generator Loop 3 EG100475 1 (2) During the above independent reinspections, the following conditions were identified:

I-E-CABL-026: (a) A cable run between T13GCCD71 and TBGCCM01 was not identified on cable schedule 2323-El-1700, and (b) stainless steel banding had not been installed within 2 inches of the end of the separation' barrier material on conduit C13G084248 as require These items were identified in the ERC reinspection and two deviation reports (DRs) have been validated. However, I-E-CABL-026 has been declared invalid by ERC based on incorrect random digit selection and is being superseded by I-E-CABL-10 Dispositions of these findings are an open item (445/8518-0-09).

I-E-CABL-092: (a) Conductor wire to terminal 3 at valve 1-HV-2493B had frayed insulation,-and (b) terminal lug connections to the conductors connected to terminals 1 and 2 at a

valve 1-HV-2493B were,not in accordance with procedures.

Items (a) and (b) were identified in the ERC reinspection and NCR

E-85-101387 sx has been issued to_ correct these problem !

Dispositions of these findings are an open item (445/8518-0-10). i No NRC violations or deviations were identifie .

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b. Cable Trays Status of CPRT Activity ERC has completed 90 reinspections and 84 documentation reviews of sampled cable trays as of December 30, 198 Status of NRC Inspection Activity (1) NRC inspectors have, as of December 30, 1985, witnessed 11 ERC reinspections, performed 7 documentation reviews, and performed 6 independent reinspections of sampled cable tray (2) During this report period, an NRC inspection was conducted with respect to compliance of cable tray and conduit identification marking with program requirements. This review was initiated as l a result of encountering difficulties in establishing the j identities of certain cable trays and conduits during previous inspections and was not specifically related to ERC inspection The following conditions were noted during this inspection:

(a) No identification or color coding existed on the following'

thermo-lagged cable trays (designated by letter T) and conduits (designated by letter C):

o T14GADG02-03, T13GACN02-03, and T12GABQ15-16 in Room 214 of the Unit 1 Auxiliary Building; o conduit near conduit C1301S570 near the entrance to Rooms 78 and 79 of the Unit 1 Safeguards Building; o conduit to cable tray T130 SCC in Room 88 of the Unit 1 Safeguards Building; o T13G'ACD99 in Unit 1 Safeguards Building at elevation i 790 feet (additional numbering problems existed in the adjacent tray section); and o conduit (which was partially identified as C14Y14) in the Unit 1 Safeguards Building at elevation 832 fee (b) No color coding existed on the following thermo-lagged cable trays and conduits:

o Located in the Unit 1 Safeguards Building:

T120SBC33 C13015570 T12GSBG10 C1305968 T12GSCE10

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-14-o - Located in the Unit 1 Auxiliary Building: .

C13G13636'

t C13615200 i C14930881

, T13GACD10, 24, 26, 38, and 99

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T12GABF33 and 36 ,

L T139ACA35, 42, and 75

T129ABA13 and 17 i T14YAEH19,-20, and 25 l

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T14WAEF 19 and 20-

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The above examples are an apparent violation of Gibbs.and Hill (G&H)

Specification 2323-ES-100, Revision 2, and Brown and Root (B&R)

] Procedure CP-CPM 10.3, Revision 9 (445/8518-V-11).

, Electrical Conduit i

Status of CPRT Activity ERC has completed 72 reinspections and 72 documentation reviews of ,

sampled electrical conduit as of December 30, 1985. The decrease

. from the numbers reported in NRC Inspection-Report 50-445/85-16;-

50-446/85-13 resulted from the invalidating of a number of selected sample items because of inaccessible attributest The' packages which-

{ were determined to be invalid are being replaced with valid samples.-

j Status of NRC Inspection Activity

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i- The status of NRC inspection activity is unchanged from the previous i

report period;.i.e., NRC inspectors have as of December 30,_1985, j witnessed 14 ERC reinspections, performe'd 15 documentation package i reviews and performed 5 independent inspections.of_ sampled electrical *

j conduits.

, Instrumentation Equipment Installation-

! Status of CPRT Activity i- ERC has completed 80 reinspections and-102 documentation reviews of sampled' instrumentation equipment installations as of_ December 30, ,

198 ;

Status of NRC Inspection Activity

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(1) NRC inspectors have, as of December 30, 1985, witnessed 8 ERC~

reinspections, performed 5 documentation package reviews _and-performed 7 independent-inspections of sampled instrumentation equipment installations.

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-15-(2) During this report period, one independent inspection was performed of Verification Package No. -I-E-ININ-053 (main steam pressure transmitter 1-PT-2325, Unit 1) with the_following inspection results:

(a) The tubing near the first " tee" from the instrument appeared to have potential damage resulting from " weld spatter";

(b) the tubing was not marked for size by color coding; (c) the tubing was not marked for separation; (d) the identification tag on the root valve was stamped 1-MS-020, 1-PT-2335 instead of the correct stamping of 1-MS-020, 1-PT-2325; (e) the tubing had inverse slope at a point near the root valve connection; (f) separation spacing was not maintained on the tubing routing; and (g) the gland not was loose on the 3/8 inch globe drain valv Items (c) and (f) were identified in the ERC reinspection repor Dispositions of these findings are an open item (445/8518-0-12).

Items (a) and (g) are not attributes currently addressed by the

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applicable ERC QI; i.e., QI-01 The failure of QI-012 to-address these attributes is considered an unresolved item (445/8518-U-13).

Items (b), (d), and (e) were not identified by the ERC inspectors and were within the scope of QI-012. The failure to identify these conditions is an NRC deviation (445/8518-D-14).

m (3) During the NRC inspector's review of G&H Instrumentation )

Installation Specification 2323-MS-625, resulting from independent )

inspection activities for CPRT ISAP No. VII.C, it was observed i that an incorporated design change authorization (DCA) required I action by inspection personnel. DCA No.13,023 dated April 20, 1982, revised Section 9.0.g.10 of Specification 2323-MS-G25 to add, " Tubing of instruments which are safety-related redundant counterparts shall not be installed in contact with galvanized material (zinc) wherever the tubing for these redundant counter-parts is routed through the same fire zone. In all other instances field erected tubing may contact galvanized material ~

(e.g., Unistrut Supports)." The engineering justification states, mu

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"The concern here is fire precipitating zinc penetration into stainless steel resulting in tubing failure. This could only be a problem if safety-related tubing for redundant counterparts was routed through the same fire zone. These instances will be identified by a damage study walkdown of safety-related tubing in fire zones and corrective action will be taken at that time."

However, a review of site documentation files, and discussions with applicant personnel, revealed that this damage study walkdown was not performed. Additionally, no information was made available to indicate that it would be done. Subsequently, the NRC inspector reviewed the following documents:

(a) TUSI " Field Design Change Control Procedure," CP-EP-4.6, Revision 7, dated November 13, 1980; (b) TUSI " Design Change Control Procedure-DCRP's," CP-EP-4.7, Revision 0, dated November 30, 1979; (c) TUSI " Field Design Change Control Instructions,"

CP-EP-4.6.1, Revision 8, dated February 22, 1982; and (d) TUGC0 " Design Change Verification" Procedure, CP-QP-15.4, Revision 0, dated August 17, 198 The review of these documents revealed that measures were not established to assure the performance of design adequacy verification / inspections required by DCA statements /justifica-tions. The lack of such design change control measures is an apparent violation of Criterion III of Appendix B to 10 CFR Part 50 (445/8518-V-15).

e. Piping System Bolted Joints / Materials Status of CPRT Activity ERC has completed 73 reinspections of piping system bolted joints /

materials out of the total random and engineered sample size of 7 Eight valid DRs were generated as a result of the above reinspection ERC has also completed 68 document reviews of these packages, with 9 valid DRs being issued to dat )

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.o-17-Status of NRC Inspection Activity The NRC inspector performed document reviews of the following packages during this report period:

Verification Package N Drawing N Flange N Unit N * System R-M-PB0M-34 BRP-SI-1-RB-048 1 1 SI .

R-M-PB0M-46 BRF-CH-1-SB-021 3 1 CH

• SI - Safety Injection System, CH - Ventilated Chilled Water System During the above document reviews, it was noted that ERC had identified the following as subject to evaluation as a potential deviation:

R-M-PB0M-046: No heat number, lot number, or color code for the studs were recorded on the construction operation travele Dispositions of the above findings are an open item (445/8518-0-16).

No NRC violations or deviations were identifie Inspection of Non-Pressure Boundary Welds for a Supplementary Evaluation of Visual Welding Inspection Techniques Status of CPRT Activity The purpose of this inspection activity is to provide information that will supplement the conclusions previously reached concerning visual reinspection of nonpressure boundary coated welds. Randomly selected samples of previously ...spected and accepted safety-related nonpressure boundary welds obtained from ISAP Nos. VII.b.3, ISAP VII.b.5, and ISAP VII.c are being inspected in accordance with the applicable code, before and after removal of coating Status of NRC Insnection Activity The NRC inspector has reviewed QI-062, Revision 0, " Evaluation of Non-Pressure Boundary Welds for a Supplementary Evaluation of Visual Inspection Techniques," and witnessed, to date, the following 11 ERC reinspections of coated welds:

/

s N-18-Verification Unit Pkg. N Equipment Tag N System N I-S-NPBW-021 VA-X-005-702-A73R HVAC Common (1)

I-S-NPBW-035 AF-1-043-001-Y43R Auxiliary Feedwater 1 I-S-NPBW-053 CS-1-241-010-A42R Chemical / Volume Control 1 I-S-NPBW-048 CS-1-058-701-A42R Chemical / Volume Control 1 I-S-NPBW-007 D0-1-DG009A-004-3 Diesel Oil 1 I-S-NPBW-063 AF-1-001-021-Y33K Auxiliary Feedwater 1 I-S-NPBQ-059 MS-1-RB-010A-013-2 Main Steam 1 I-S-NPBW-042 P-18/CMK-D22(SG) Structural Steel 1 I-S-NPBW-075 SW-1-007-700-J035 Service Water 1 I-S-NPBW-030 SI-1-104-001-C425 Safety Injection 1 I-S-NPBW-023 CS-1-SB-053B-008-2 Chemical / Volume Control 1 At this time, no welds have had paint removed, which is required for implementation of the second phase of the inspection. While witnessing ERC's performance of weld inspections, the ERC inspector identified that a fillet weld attaching item 1 to item 2 of pipe support CS-1-SB-053B-008-2 was 1/16-inch undersize for 25% of the joint length, and that two fillet welds attaching item 29 of pipe support SI-1-104-001-C425 to existing pipe support SI-1-051-008-C42R were each approximately 1 inch underlengt The NRC inspector's review of documentation associated with these supports revealed that they had previously been inspected by ERC as required by ISAP No. VII.c, "Small Bore Pipe Supports," and "Large Bore Pipe Supports Non-Rigid." The documentation further revealed that ERC failed to identify the undersize and underlength welds during the previous reinspections, as required by Revision 0 to QI-019 and QI-02 The failure to identify discrepant weld conditions is an NRC deviation (445/8518-D-17).

g. Large Bore Pipe Supports - Non-Rigid Status of CPRT Activity ERC has completed 75 reinspections of non-rigid large bore pipe supports out of the combined random and engineered sample size of 8 A total of 268 deviations have been currently identified of which, to date, 210 have been determined to be vali Documentation review of 80 original installation packages has been completed, resulting in the identification of 8 valid deviations. ERC is reviewing the valid deviations for safety significanc Status of NRC Inspection Activity The NRC inspector did not witness or perform independent inspections during this report perio No NRC violations or deviations were identifie a

-19-h. Large Bore Pipe Supports - Rigid Status of CPRT Activity Reinspection /ve'.'ification of the combined random and engineered sample consisting of 89 pipe support installations by ERC has been complete A total of 180 DRs have been issued, 129 of which have been determined to be valid while the remaining 51 are being evaluated. Seven previously validated DRs were voided as a result of ERC's safety significance evaluation establishing from evaluation of field conditions that the DRs were, in fact, invali Documentation review of original installation packages by ERC has been completed. A total of 150 DRs have been issued, 4 of which have been determined to be valid, while the remaining 146 are being evaluate ERC has determined that 79 of the total valid deviations (reinspection and documentation) are not safety significant while the remainder are being evaluated for safety significanc Status of NRC Inspection Activity To date, six independent inspections of pipe support installations have been performed, with the following inspection being performed during this report period:

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! Verification Pkg. N Pipe Support Mark N System Unit N I-S-LBSR-009 SW-1-004-015-A33R Service Water 1 No NRC violations or deviations were identifie i. Reinspection of Containment Liner and Tank Stainless Steel Liner Status of CPRT Activity Reinspection of the combined sample of 91 containment liner and tank stainless steel liner packages is 100% complete. Eighty-two valid deviations have been identified during physical reinspection. Document !

review of the 91 packages is also 100% complete with 28 valid deviations identified. Valid deviations are being reviewed for. safety significanc i Status of NRC Inspection Activity I

There was no NRC inspection activity during this report perio l j. Structural Steel i Status of CPRT Activity Reinspection of the 107 structural steel packages in the combined first and second samples is approximately 16 percent complet Twenty-seven

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-20-valid deviations have been identified. -QI-046, Revision 0, for documentation review has been issued; however, review activities have not yet been initiate Status of NRC Inspection Activity

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(1) The NRC inspector has, to date, witnessed nine reinspections representing approximately 8 percent of the combined first and second samples. The following two ERC reinspections were witnessed by the NRC inspector during this report period:

Verification Package N Equipment N Building Unit N I-S-STEL-117 MEDC0 Mk No.D2 Reactor 1 I-S-STEL-236 MEDC0 Mk No.C7 Reactor 1 (2) During the above reinspections, the ERC inspector identified the following condition as subject to evaluation as a potential deviation:

I-S-STEL-117: Bolt material was rejected due to incorrect markin Disposition of the above finding is an open item (445/8518-0-18).

No NRC violations or deviations were identifie k. Concrete Placement Status of CPRT Activity Reinspection of the combined first and second samples consisting of 97 concrete placement packages is approximately 70% complet Twenty-six valid deviations have been identified relating primarily to unfilled holes, voids, and debris in the concrete surfac Documentation review procedures have not yet been issue Status of NRC Inspection Activity

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(1) The NRC inspector has, to date, witnessed 14 reinspections l representing approximately 14 percent of the combined first and i second samples. The following two ERC reinspections were witnessed by the NRC inspector during this report period: 1 l

Verification Package N Concrete Placement N Building Unit N I I-S-CONC-080 IRCN-CPC-002-9792-008 Auxiliary Common I-S-CONC-130 IRCN-CPC-002-6873-003 . Auxiliary Common i

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-21-(2) During the above witnessed reinspections, the ERC inspector identified the following condition as subject to evaluation as a potential deviation I-S-CONC-080: Anchor bolt projection was out of toleranc Disposition of the above finding is an open item (445/8518-0-19).

No NRC violations or deviations were identifie (3) The NRC inspector has, to date, independently inspected six concrete placements representing approximately 6% of the combined first and second samples. The following concrete placement was independently inspected during this report period:

Verification Package N Concrete Placement N Building Unit N I-S-CONC-019 IRCN-CPC-205-9810-034 Diesel 2 Generator No NRC violations or deviations were identifie . Small Bore Pipe Supports Status of CPRT Activity Reinspection of small bore pipe supports is 100% complete with 76 supports reinspected. Eighty-three DRs have been issued with fifty-nine valid deviations identified to dat Clarification of embedment requirements has resulted in a reduction in the number of valid deviations from the 67 reported in NRC Inspection Report 50-445/85-16; 50-446/85-13. These deviations relate primarily to Hilti bolt embedment, bolt hole spacing and edge distance in base plates, and pipe clearances. Documentation review of the 76 supports is also 100 percent complete with 31 valid deviations identifie Status of NRC Inspection Activity l (1) The NRC inspector has witnessed seven reinspections representing approxinately 9 percent of the combined first and second sample The following ERC reinspection was witnessed by the NRC inspector during this report period:

Verification Package N Pipe Support N * System Unit N I-S-SBPS-284 CH-2-AB-008B-002-3 CH 2

• CH - Ventilated Chilled Water System No deficiencies were noted by ERC or NRC inspectors with respect to this verification packag ,

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l-22-(2) The NRC inspector independently inspected during this report period the following five small bore pipe supports representing approximately 7% of the first and second samples:

Verification Package N Pipe Support N * System Unit N I-S-SBPS-051 GH-X-AB-051-004-3 GH Common I-S-SBPS-067 CH-1-SB-004-013-3 CH 1 I-S-SBPS-003 CH-1-SB-014-002-3 CH 1 I-S-SBPS-254 CS-1-111-703-C425 CS 1 I-S-SBPS-017 CC-1-EC-006-005-3 CC 1

• CC - Component Cooling Water System CH - Ventilated Chilled Water System CS - Chemical and Volume Control System GH - Gaseous Waste Processing System No NRC violations or deviations were identifie m. Pipe Whip Restraints Status of CPRT Activity ERC has completed 47 reinspections of pipe whip restraints out of the planned combined random and engineered sample size of 11 Nineteen valid DRs have been identifie Status of NRC Inspection Activity (1) The NRC inspector has witnessed five ERC reinspections, to date, of which the following occurred during this report period:

Verification Package N ' Support Identification * System Unit N I-S-PWRE-536 MS-1-12-903-T57W MS 1

• MS - Main Steam System No deficiencies were noted by ERC or NRC inspectors with respect to this verification packag (2) The NRC inspector performed the following two independent inspections during this report period:

Verification Package N Support Identification * System Unit N I-S-PWRE-528 FW-2-019-912-C47W FW 2-I-S-PWRE-545 SI-0590 F30 SI 1

• FW - Steam Generator Feedwater System SI - Safety Injection System

0-23-During the prior ERC reinspections, the following condition was identified as subject to evaluation as a potential deviation:

I-S-PWRE-528: Location of the bumper on the baseplate was out of tolerance from what was shown on the drawin Disposition of this finding is an open item (446/8515-0-03).

No NRC violations or deviations were identified, n. Instrument Pipe / Tube Supports Status of CPRT Activity ERC has completed 83 reinsp6ctions of instrument pipe / tube supports out of the combined random and engineering sample size of 102. Three hundred and ninety-eight DRs have currently been issued. One hundred and forty-two DRs have been validated from a total of one hundred and seventy reviewed by the population enginee One document review has been performed by ERC, with one valid DR being issue Status of NRC Inspection Activity (1) The NRC inspector has performed, to date, a total of five independent inspections of which the following occurred during this report period:

Verification Packaoe N Instrument Tag N * System Unit N I-S-INSP-023 1-PI-978 SI 1

• SI - Safety Injection System (2) During the prior ERC reinspection of this verification package, the following cor.ditions were identified as subject to evaluation as potential deviations:

Baseplate die stamp was not visible through the paint and the fillet weld between the baseplate and the structural tubing was undersized by 1/16 inc Dispositions of the above findings are an open item (445/8518-0-20).

(3) The NRC inspector noted during independent inspection with respect to support 0230, that the bolt on the Unistrut clamp was not torqued to the value specified by attribute 4.7 in QI-05 Signoff by the ERC inspector of this attribute as being acceptable .

is an NRC deviation (445/8518-D-21). l

O o-24-Upon review of the ERC inspection checklists for Verification Package No. I-S-INSP-023, it was noted that supports 023A and 023C had been marked as "N/A" with respect to attribute This attribute deals with the use of spring nut Independent inspection showed, however, that spring nuts were used on these two supports for a bolted connection. The failure to inspect attribute 4.5 is an NRC deviation (445/8518-D-22).

o. Documentation Review of Fill and Backfill Placement Status of CPRT Activity Documentation review of the sample of 180 fill and backfill placements is approximately 66 percent complete. A total of 317 deviations have been identified and are being evaluated for validity. No physical reinspections are planne Initially, two populations were identified: (1) 719 placement packages for the safe shutdown impoundment (SSI) dam for the period April 21, 1976, to April 29, 1977; and (2) 101 placement packages associated with other fill and backfill activit Sixty sample packages were randomly selected from each population by ERC. TUGCo identified the packages for each population. An additional 219 packages were discovered during the document review process that should have been included in the second population. The original 101 packages in the second population are TUCGo inspection reports subsequent to July 12, 197 The 219 additional packages are B&R inspection checklists for the period August 18, 1977, to July 12, 197 An additional 60 packages were randomly selected from this third population, increasing the total number of fill and backfill packages from 120 to 18 Status of NRC Inspection Activity To date, no independent NRC inspections of documentation have been performe p. Field Fabricated Tanks Status of CPRT Activity Reinspection / verification of field fabricated tank installation has been complete A total of 14 DRs have been issued of which 8 have been determined to be valid. Documentation review of original i installation packages by ERC has been completed with a total of 46 DRs )

issued, none of which have currently been reviewed by the population engineer for validit .

e e-25-Status of NRC Inspection Activity Planned NRC physical inspections were documented in NRC Inspection Report 50-445/85-16; 50-446/85-1 No NRC violations or deviations were identifie q. Large Bore Piping Configuration Status of CPRT Activity ERC has completed 75 reinspections of large bore piping configuration out of the combined random and engineered. sample size of 82. The sample size has decreased from 99 to 82 due to the random selection of common verification packages in both.the random and engineered sampl Forty-one valid DRs have been identifie Status of NRC Inspection Activity (1) The NRC inspector has witnessed, to date, seven ERC reinspections of which the following occurred during this inspection period:

Verification Package N Drawing N * System Unit N I-M-LBCO-091 BRP-CS-2-AB-035 CS .2 I-M-LBCO-092 BRP-MS-1-BB-002 MS 1 I-M-LBC0-127 BRP-CC-1-AB-008 CC 1

• CS - Chemical and Volume Control System MS - Main Steam System CC - Component Cooling Water System (2) During the above reinspections, ERC identified the following conditions as subject to evaluation as potential deviations:

(a) I-M-LBCO-127: Valve did not have an id'entification tag or a flow direction ta (b) I-M-LBCO-091: Clearances between the pipe and other pipes and supports did not meet the required dimension ,

Dispositions of the above findings are open items (445/8518-0-23 and l 446/8515-0-04).

No NRC violations or deviations were identifie r. Small Bore Piping Configuration

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Status of CPRT Activity- l ERC has completed 73 reinspections of small bore piping configurations out of the combined random and engineered sample size of 88. The

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-26-combined sample size was reduced from a previous figure of 95 to 88, because of the random selection of common verification packages in both the random and engineered samples. Thirty-four valid DRs have been identifie Status of NRC Inspection Activity (1) The NRC' inspector has, to date, witnessed seven ERC reinspections of which the following occurred during this~ inspection period:

Verification Package N Drawing N * System Unit No.

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I-M-SBC0-083 BRP-MS-1-RB-021 MS 1

• MS - Main Steam System (2) During the above reinspection, ERC identified the following condition as subject to evaluation as a potential deviation:

Required clearances were not met between: (a) the pipe and an adjacent pipe, and (b) the pipe and an adjacent hange '

Dispositions of the above findings are an open item (445/8518-0-24).

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No NRC violations or deviations were identifie '

(3) The NRC inspector performed the following independent inspection during this inspection period:

Verification Package N Drawing N * System Unit N I-M-SBC0-022 BRP-CH-X-AB-055- CH Common

*GH - Gaseous Waste Processing System

On the above verification package, ERC identified during their reinspection the following condition as subject to evaluation as a potential deviation:

Required clearances between the pipe and adjacent pipes were not me Disposition of the above finding is an open item (445/8518-0-25).

While performing the above independent reinspections, the NRC inspector observed that a socket welded coupling, with a specific ,

> location shown on the piping isometric drawing, was covered with i I insulation. Consequently, verification of this linear dimension l

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could not be performed. However, attribute 1.d which deals with '

linear pipe dimensions shown on the piping isometric drawing was signed off as acceptable.

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-27-This incorrect designation of acceptability is an NRC deviation (445/8518-D-26).

Upon review of the ERC inspection checklist for Verification Package No. I-M-SBCO-22, it was noted that N/A was inserted by the population engineer for attribute 1.1, Mechanical Joint Location. This attribute dealt with bolted flanges being dimensionally located in accordance with the piping isometric drawing. Independent inspection revealed, however, the presence of four bolted flange connection The failure of the engineer to designate applicability of mechanical joints is an NRC deviation (445/8518-D-04).

It was additionally noted that the ERC. inspector failed to identify the engineer's error during reinspection of this sample ite '

7. Exit Interview An exit interview was conducted on January 7, 1986, with the applicant representatives denoted in paragraph 1 of this appendix. Dur.ng this interview, the NRC inspectors summarized the. scope and findings of the inspection. The applicant acknowledged the findings.