IR 05000445/1986007
| ML20207E151 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/10/1986 |
| From: | Barnes I, Ellershaw L, Hale C, Will Smith, Spessard R, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20207E070 | List: |
| References | |
| 50-445-86-07, 50-445-86-7, 50-446-86-05, 50-446-86-5, NUDOCS 8701020074 | |
| Preceding documents: |
|
| Download: ML20207E151 (49) | |
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. APPENDIX C'
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NRC COMANCHE FEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT.
I , 'U.S. NUCLEAR REGULATORY COMMISSION
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REGION-IV , g- . l.NRC Inspection. Report: 50-445/86-07 Permits: CPPR-126 {c
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.50-446/86-05' CPPR-127
. Dockets : . 50-44 Category: A2 lE '50-446 s; ' + .. ,
y Applicant: Texas Utilities. Electric Company Construction Permit
= Skyway Tower .
Expiration Dates: 400 North Olive ~ Street Unit 1: August 1, 1988 Lock Box'81'. .. Unit 2: August 1, 1987
. Dallas, Texas 75201-i Facility Name: . Comanche ~ Peak Steam Electric Station (CPSES), Units 1 & 2
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Inspection At: . Glen Rose, Texa . A
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: Inspection: Conducted: April 1 - May 31, 1986
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: Inspectors:-
L. E. Ellershaw, Reactor, Inspector, Region IV Date s CPSES Group (paragraphs 2.a. 2.e, 2.j-k, 4.c, 5.e, 5.1, 6.b, and 6.c) l 2 C. J. haw Reactor lii5pector, Region IV
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Date' IO h ' CPSES GrdtTp
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(paragraphs 3.a-b, 4.a-b, 5.d. and 5.h-k)
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(*2.l\ 0 l6 b P. C. Wagner, Reactog Inspector, Region IV Date CPSES Group
.(paragraphs 2.f-1, 3.c. 5.a-c and 6.a)
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Sw /2. //o/6*4 A W. F. Smith, Resident Reactor Inspector Date Region IV CPSES Group (paragraphs 2.b-d and 5.f-g) Consultants: EG&G - J. Dale (paragraph 4.c) A. Maughan (paragraphs 2.f-1, 5.a-b, and 6.a) W. Richins (paragraphs 4.c, 5.e, and 6.b) V. Wenczel (paragraphs 3.a-b and 4.a-b) ' Parameter - J. Birmingham (paragraph 5.d and 5.h-k) J. Gibson (paragraph 5.c) K. Graham (paragraphs 2.a. 2.e, 2.j-k, and 6.c) D. Jew (paragraphs 4.c and 5.1) Reviewed By: C Nh/!N R. L.'Spessard,(/ Deputy Director, Director Fate Division of Inspection Programs, Office of Inspection and Enforcement Approved By: 8w /2/ro/p4 I. Barnes, Chief, Region IV CPSES Group Date Inspection Summary Inspection Conducted April 1 through May 31, 1986 (Report 50-445/86-07; 50-446/86-05) l Areas Inspected: Nonroatine, unannounced inspection of applicant actions on previous inspection findings, assessment of allegations, Comanche Peak Response Team (CPRT) QA program, and CPRT issue-specific action plans (ISAPs).
Results: Within the four areas inspected, six violations (design basis for criteria for base metal defect inspections not generated, paragraph 2.e; design changes nct reviewed by thase responsible for the original design, paragraph 2.k; temporary modification to cables not properly documented, paragraph 5.c; terminal blocks not identified, paragraph 5.c; drawing errors were not identified during reviews and checks, paragraph 5.c; and Corrective Action Report (CAR) was closed before corrective action was complete,
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3-b ,. , paragraph.5.h) and ten-deviations (corrective action not implemented as committed, paragraph 2.a; error made during reinspection by Evaluation Research
: Corporation (ERC), paragraph 2.i; ERC QA manuals not maintained current, paragraph 4.a; failure of Senior Review Team (SRT) to assure quality of CPRT activities, paragraph'4.a; the documented Overview Quality Team (0QT) program is'not' definitive, paragraph 4.a; ERC audit status and action logs not-maintained current, paragraph 4.b; five examples of errors made in the overview inspection function,: paragraph 4.c; failure of CPRT to identify all, authorized '
spliced cables, paragraph 5.a; spare conductors were inappropriately included in
' reinspection sample, paragraph 5.c; no criteria for valve disassembly / reassembly for five months in 1983, paragraph 5.1) were identifie .
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't DETAILS ~
1; Persons-Contacted-
' ~ ***J. W.'.Audas, Licensing Engineer, Texas Utilities Generating Company, . (TUGCo)
E. Bajada.-QA' Director, Evaluation Research Corporation (ERC)
*L. B. Barker,-Executive Assistant, TUGCo- ***J.-W.l Beck, Vice President,.TUGCo ***R.'S.-Berk. Licensing Engineer, TUGCo . *C; T. Brandt, Quality Engineering (QE) Supervisor, (Ebasco) . ., JJ.; Burgess', As-built Verification Supervisor, TUGCo Nuclea'r Engineering-(TNE) , *R. E. Camp, Assistant Project General llanager, Unit 1 (Impell' Corp.)' , * G. Counsil, Executive _Vice President, TUGCo ~~n S. M. Franks, CPRT Projects (Impell Corp.)
, *P._ E. _Halstead, Site Ouality Control (QC) Manager, TUGCo
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4 F. R. Hodges, Lead Auditor, ERC e ~
.B. Holmes,.QC Electrical Supervisor, TUGCo -
M. Keathley. Lead Electrical QC Inspector, ERC -
**0. Lowe, TNE ~ '
J. Mallanda, CPRT Electrical Review Team Leader J. Martin, Calibration . Lab Supervisor, Brown & Root s(B&R) < .
**J. T.~ Merritt, Jr. . Assistant Project General Manager,'TUGCo'
C. K. Moehlman, Project Mechanical Engineer, TUGCo
*L.-D. Nace, Vice President, Engineering and Construction, TUGCo A.- A.1Patterson, Reinspection Engineering Supervisor, ERC ***L. M. Popplewell, Unit 2 Safeguards Building Manager, TUGCo **P. Reilly, Engineer, TNE J. E. Rushwick, CPRT Test Programs Review Team Leader ***A. B. Scott, Vice President, Nuclear Operations, TUGCo B. Shair, Lead Electrical Engineer, ERC M. Shealy, Lead Mechanical QC Inspector, ERC R. Sievers, Mechanical Inspection Supervisor, B&R R. Spangler, Assistant-QA Manager, TUGCo P. Stevens, Electrical Engineer, TUGCo *J. F.' Streeter, Director Quality Assurance (QA), TUGCo *T. G. Tyler, CPRT Program Director, TUGCo W. I. Vogelsang, Electrical Coordinator, TUGCo C. H. Welch, QC Services Supervisor, TUGCo J. R. Wells, CPRT Overv sew Quality Team **D. R. Woodlan, Licensing Supervisor, TUGCo 'R. Zill, Onsite QA Representative, ERC * Denotes those persons who attended both exit interview ** Denotes those persons who attended the May 8, 1986, exit interview onl *** Denotes those persons who attended the June 3, 1986, exit interview only.
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iThe NRC inspectors also contacted other'CPRT and applicant employees-during
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this inspection. perio [" ( ApplicantActionsonPreviousNCInspectionFindings
[,".+ fa. V (Closed) Unresolved Item (445/8601-U-21): This item dealt with a v a #, seismic arrestor bracket being welded over raised cast identification m -
letters on an the actuator barrel-assembly, resulting in a weld which
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.c iexhibited incomplete fusion and overall poor workmanshi During the review of.this item, it was identified that TUGCo, by w~ , letter to the NRC dated April 21, 1983, had reported this condition
. - N- under 10 CFR Part 50.55(e) and had committed to immediately n discarding and replacing the arrestor brackets. The failure to
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implement the committed corrective actions.is a deviation (445/8607-D-01).
. - - (Closed) Open' Item-(445/8516-0-11): In November.1985, the NRC
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inspector attempted to review documentation related to commitments in
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-ISAP II Sections 4.1.1.3 and 4.1.1.4 of the ISAP committed the CPRT to review the CPSES document' control program and to interview system test engineers (STEs) to-help assess the adequacy of existing procedures and methods of obtaini_ng current design information for test procedure updates. There were only a few handwritten notes with no results indicated. The CPRT indicated that the final results report for ISAP III.d would address these items. The results report
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m was published on March 13, 1986. In Section 5.2.2 and 5.2.4 of the
, results~ report, the CPRT reported having' reviewed the history of the
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Startup Document Control Center (DCC) satellite and the evolution of the methods.by which the Startup and DCC organizations attempted to
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, provide convenient STE access to current design documents. The results of thiscreview, as indicated in the results report, revealed that. prior to April.1983, the control and distribution of design
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; documents-was centralized in the main DCC facility. The STEs found
, the task of obtaining current design.information time consuming, L-burdensome, and the DCC was> unresponsive to their specific needs. In F
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. April 1983, the first satellite of the DCC was established in the Startup facility. .After about a year, a review was conducted to
- evaluate the control of design information. The review found that
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o " the system was working; however, it was cumbersome and continued to
, be a burden on the STEs. In April 1984, satellite libraries it maintained by the DCC were established for various key Startup office areas. . The'CPRT concluded from (1) their review of the evolution of
. - - the document control program, and (2) the results of the ISAP random
. . sampling and evaluation, that STEs, after April 1984, were no longer ,
working with a burdensome system and could obtain current design
- information in a timely' manner.~ With regard to STE interviews, Section 5.2.3 of the results report documented the fact that eight
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Q [[ ,,, , , , , . 1 2 5 0 7 2 % , "STEs 6representingiarious systems 11n the plant, were'. interviewed to
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2% requirements;to useTcurrent' design.dacuments and'to further assess y r g& a
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Lthe need 'to upgrade' existing procedures and. methods. . After-m interviewing 18;of;the;approximatelyz60<STEs. the'CPRT concluded that ~
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wg? J *& ' t document? review; offered more'usefulfinformation than STE-interviews
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frelativ'e'to^the! issues;beingl addressed.iprincipally o_n the basis'of-
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Linterviews.%The- NRC;inspectorzconducted similar interviews with a p& .;j 4 ~ u
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M fewlSTEsrselected from di. verse. disciplines', and came to a similar:
, conclusion.?Thoseinterviews?weredocumented11nSSER-7,PagesJ-94 ge(c m - T "andi95.s This.. item ~1snclos'ed..
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.. - ack \(Closed) Open Item (445/8518-0-06):~ In December 1985, the NRC ~
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41nspectorfidentified a concern that STEs were not fully updating the
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' , , -l referenced drawing. section of preoperational itests (pts). - The '
3 applicant cossiitted to make administrative. procedure changes which MN * (would implement. tighter controls.in,this area, because the existing
+ . s f y* ' , . gg ^; controls di.d not providelspecific-instructions on how to document PT ~
G< . = procedureiupdates. ; CP.-SAP-7, "Formatzand ' Content of Test 5 L 7 ^ " Instructions / Procedures," was revised andLissued on July 8, 198 mgp, 4The new. revision requires :aispecific: prerequisite s.tep to be placed HP
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. , . jiniall pts for th'e STE to update" test procedure drawings, and then
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+c, the STE must. sign the step off priorito commencing the tes v 7_
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y g i(Closed)0 pen 11 tem (445/8518-0-08): . This item was initiated for the t c'e;,, . purpose of tracking the~_ issuance of a final results report for
:ISAP III.d.,iThe report was issued on March 13, 1986. This item is
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close :
. "y' - d e.1 '(Open)f0penItems.(445/8516-0-53and443/8516-0-54): During '
review of.these items pertaining to discrepant weld conditions that
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Dexist on Boric' Acid Storage Tanks, CPS-CSATBA-01 and -02, the NRC m i,_ ' inspector identified:that TNE provided base material inspection
* acceptance criteria to ERC on a-Technical Information Request (TIR)
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' dated September 25.-1985. The TIR response states,."The maximum ~
e allowable for a material defect for above tanks shall be 1/16" (one f
- > isixteenth of an -inch)."' Discussion with TNE personnel revealed that
,the' basis for base' material inspection acceptance criteria were
' calculations; performed using data obtained from the. original design
.c s s e documentation.' However,'as of May 15, 1986,.the supporting y ' calculations had not been formally completed and reviewed. The m^ failure to implement design control measures with. respect to the w ' delineation of acceptance criteria is a . violation (445/8607-V-02).
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')l , (Closed)OpenItem(445/8514-0-12): The comparison of ERC's document t '
review results,'for Verification Package R-E-EEIN-001 with the NRC's C ', -
-results was completed during this report period with no differences '
L identified. This item is closed.
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g.~ . L(Closed)T0pEnItem-(445/8516-0-31): The comparison of ERC's document x 93 ' review results for Verification Package R-E-ININ-016 with the NRC's N ~. :results was-completed during this report period with no differences identified. JThis item-is close L (Closed) Open Item (445/8516-0-32): The comparison of ERC's document
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review'results for~ Verification Package R-E-ININ-072'with the NRC's results was comp 1eted during this report period with no differences
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~ identified._=This item is close ! >
11. . '(Closed) 0 pen Item (445/8516-0-33): .The comparison of ERC's document R 1 review results for Verification. Package R-E-ININ-079 (for pressure
~ ~ -transmitter IPT-4520).with the NRC's was completed during this report iperiod. The ERC inspector had failed to identify an inspector who + -was not certified when he' signed an-Instrumentation Tubing
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- . Manufacturing Record Sheet. This item is a deviation '(445/8607-D-03).
n "N ' f '(Closed) Unresolved Item (446/8505-05): This item dealt with the
. unavailability of a site prepared installation drawing and specification with respect to reactor pressure vessel (RPV) +: placement.
, The'NRC inspector performed a review of documentation associated with installation of the Unit'2 RPV. The governing rocedure for ,
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installation was Brown & Root Procedure MCP-1, p' Installation of
' Mechanical Equipment." Paragraph 4.1.1 in MCP-1 requires that
< equipment installation travelers be prepared in accordance with site
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Procedure CP-CPM 6.3, " Preparation, Approval, and Control of Operation Travelers." ' Operation traveler ME79-248-5500, Revision 0, was issued which described the field instructions for installation of the Uni.t 2 RPV. The operation traveler incorporated the requirements recommended by Westinghouse Nuclear Services Division (WNSD)
. procedures for this activity;'i.e., " Procedure for Setting of Major
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NSSS Components," Revision 2, dated February 13, 1979, and " General Reactor Vessel Setting Procedure," Revision 2, dated August 30, 1974.
1 These WNSD procedures were not made a part of the traveler package, in that they are generic and have been used by WNSD at several site .However, the specific guidelines were utilized during the traveler preparation. All of the necessary installation steps were reviewed and approved by site QA/QC personnel and by a site WNSD representativ While there was no site specific installation procedure, an operation
- traveler was prepared, reviewed, approved, and issued; thus it became the controlling documen (Closed) Unresolved Item (446/8505-06): This item dealt with no documented engineering evaluation onsite justifying the final
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tolerances-'of Unit 2 RPV clearances between support brackets and support = shoes. This item was considered unresolved pending receipt of documentation validating the final installation tolerance ,
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l The original tolerances specified on operation traveler ME79-248-5500,
' . . Revision 0, were extracted from the WNSD generic procedures. The . ' ' operation traveler's installation tolerances were subsequently revised ' '
cto reflect site specific field condition Westinghouse concurrence
. with the revised tolerances was documented by signature on the operation traveler. In addition, . Westinghouse Water Reactors Division provided the basis for the Unit 2 RPV shin installation tolerances in - ' letter WPT-8148 dated January 10, 1986, which was in response to 'TUGCo's letter CPPA-48113. As a result of the receipt of documentation-validating the final installation tolerance This item is resolve Concurrent with the evaluation of this unresolved item, the NRC inspector reviewed documentation for shims installed between the Unit.1, Loop 2,. reactor coolant crossover leg and crossover leg restraint ' Construction operation traveler ME84-4715-5500 references Design Change Authorization (DCA) 21,116,' Revision 0. This DCA addresses a . problem with respect to clearance between interior shims and ; crossover piping that occurred during hot functional test. The solution required the addition of shim stock as necessary to maintain zero clearanc The listed supporting documentation shows the acceptance criteria to be a letter from Westinghouse dated April 26, 198 Review of the Westinghouse letter revealed that it does not address '
the stated problem in the DCA. Paragraph 2.4.1 in Revision 6 of TNE Procedure TNE-DC-8-1, " Design Verification of Field Design Changes," states, in'part, "If the field design change, had been transmitted to Gibbs & Hill and Gibbs & Hill has stated that it is not within their scope of work, then the field design change shall be design verified as per-this instructio "If design verification can only be performed by the vendor . . . , the Verifier shall transmit the change to the vendor requesting the specific vendor action require Resultant documentation from the vendor shall be included as a part of the design verification documentation prepared by the verifier."
The DCA was submitted to Gibbs & Hill (G&H) for review and approva . Subsequently, G&H responded on change verification checklist dated September 28, 1984, for the above DCA, "G&H documents are not affected. Vendor review is required." It was determined that the DCA was not routed to the vendor (Westinghouse) for review and approval. While the required vendor review and approval was not , performed, the DCA was implemented by traveler ME84-4715-5500. In , I f { N - . - _ _ . _ _ - _ .
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,7 addition, the trave.ler documented the need to^ shim two locatio'ns
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:nine-locations were shimme '
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_ and approvalsof changes is a violation (445/8607-V-04).
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l Assessment o'f Allegations ,
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AQ-159 and AQ-162~(4-85-A-31): ~ Poor Communication Between QA and QC
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, It was alleged that'there;were very few interfaces and little
. communication between the site' surveillance group, the Dallas-QA
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. audit group, and the operations audit group, even though their '. 'functionsiare basically the same and such interfaces and * ^ '
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communicationsLwould increase the effectiveness of each of the _igroup [ , i Thsfallegation' lacked any specifics or consequences resulting from
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- . this41ack of = interface and communication, but was based on the
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. alleger's subjective perception of conditions arising from contacts
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Ewith Dallas audit personnel, operations audit personnel, and QA/QC
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; management. -The NRC assessment of.this allegation is based
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~, principally on an evaluation of NRC assessment of other allegations Land recent inspections in the operations QA, Dallas QA, and
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_ surveillancelareas. The following are items noted during these
: previous assessments and inspections that are related to this . ,
allegatio E During NRC assessment of allegations in the operations QA area, it "
(was noted that the operations QA program is structured in a similar
. manner to other operations QA programs; however, with the CPRT and F '
other similar efforts causing numerous modifications to equipment within the scope of operations responsibility, this QA program is being forced into' functions and programmatic areas for which the programLwas not structured to operate in an efficient manner. As a result, these equipment modifications are being made by the site
, construction force, and in most cases the inspection function is performed by the construction QC inspection group (both groups functioning according to the construction QA program), while overview
~is being provided by the operations QA group functioning to a-different QA program. Even though both the construction and operations QA programs may be in compliance with regulatory requirements, there is no assurance that these programs are compatible and they, of course, are not interchangeable. One example of incompatibility is the difference in construction's and operation's treatment and processing of NCRs that was identified in NRC Inspection Report 50-445/86-01; 50-446/86-0 ,
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During an inspection of the Dallas-based QA group, it was found that the internal audit group is the principal interface with the personnel on-sit Essentially 100 percent of the internal audit group's efforts consists of audits of onsite activities; however, under the most ambitious conditions of planning and scheduling these personnel would be on-site 40 percent of their time. Thus, their accessibility to site personnel for discussion / interface is limited, and even then under conditions that exist during the conduct of their audits. As further noted in NRC Inspection Report 50-445/86-03; 50-446/86-02, the interface between the internal audit group and the site surveillance group is limited to an informal review of the surveillance group's monthly report even though this surveillance group is the one onsite group whose responsibility it is to assess the effectiveness of the implemented site construction QA progra NRC Inspection Report 50-445/86-03; 50-446/86-02 provides the results of thc NRC inspection of the onsite surveillance group. Of note during that inspection was the absence of any required interface of the surveillance group with the Dallas QA personnel. Except for a 3 monthly report by the surveillance group to the site QC manager, to whom this group reports, no other sunmary of surveillance ~ findings are documented. The QC manager and others in his organization evaluate these monthly reports and generate trend reports and initiate corrective action activities, again without formal input
- from the Dallas QA grou Considering these observations and findings of conditions during 1985-1986, this NRC assessment tends to substantiate the allegatio Since this allegation was of conditions and an organization that existed during the 1984 time period, the conditions alleged to~ exist appear to be plausible and potentially accurate. While a major change in organization and personnel in mid-1985 did improve these conditions, interface and communication between these groups is still lacking, which is consistent with the allegatio During discussions with QA management concerning these observations and findings, it was identified that additional changes in the program and organization have been or are being made which recognize these weaknesses. On April 29, 1986, the President of TUGCo approved a major restructuring and reorganization of the TUGCo QA/QC function that is to be implemented in three phase Phase 1 to be implemented by July 1, 1986, includes the followin (1) Operations QA would report to the Director of Quality Assurance; this will place all CPSES QA/QC functions in one organizatio (2) The Manager of QA and the Dallas QE staff will L; moved from Dallas to the site, while the Assistant Manager of QA will provide continued supervision for the QA staff remaining in Dalla _ __ -_ _
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^. ;(3) 'The si% surveillance group. will begin reporting to the Manager s _ >
" of QA instead-of the Manager of.Q <: $ , ' iTh'eLtime prior to July 1, 1986, will be used to relocate. personnel
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; .and_ revise the: procedures.necessary to accommodate these change , - , '
4 Phase 2 will begin July 1,=1986, and be completed by September 1, r 1987. ;This phase, when fully implemented, will place all QA/QC p.' , x . personnel and functions on-site and in one organization; i.e., those-
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-QA personnel not relocated to the site in Phase 1, principally the-
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l internal and externa 1' audits groups, will be moved on-sit #
' 'e Phase 3 will be implemented at the time of Unit 2 fuel loading and , '
will represent the final organizational structur This structure
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-will. focus on the major QA/QC program areas of development,
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In summary, conditions that existed in 1984 and to a lesser degree in 1985 tend to substantiate this allegation. -Organization and program m changes made in 1985 improved these conditions, but changes proposed
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for.1986 and 1987 have the elements necessary to resolve conditions
;allegedtohaveexiste .
No violations or deviations'were identified during this assessmen } , AQ-139 and AQ-140 (4-85-A-14): Improper Revision of Audit Reports It was alleged that audit reports were changed to reflect what management wanted the report to stat Reports identified were r * TCP-66 and TCP-7 The subject of audit findings being rewritten by supervision to
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change the intent of audit findings was previously assessed by the NR This assessment is documented in NUREG-0797, Supplement 11 in Appendix 0 beginning on page 0-233. The NRC reviewed 23 TUGCo QA audits for changes to auditor findings. The purpose of the review was to determine if initial findings were revised to the extent that the intent or significance of the finding was no longer the sam Included in that review was TCP-66. The NRC assessment concluded
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that audit reports were changed by supervision / management, but the changes'made were not inappropriat . Since TCP-76 was not included in the previous NRC assessment, it was reviewed for substantive changes that may have been made by other than the auditor. Two such changes were identified. The first was c the deletion of a " comment" concerning a skewed weld. The second
- change was a downgrading of a " deficiency" to a " concern" reprding ..
calibration of a protracto No documents or notes were found in the TCP-76 audit file to explain . the deletion of the skewed weld " comment." The NRC inspector
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e : N , ~ contacted the Assistant TUGCo QA manager who was a member of the !
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1special review team'that performed the 1983 investigation of TCP-66 '
, . and TCP-76 for TUGCo. This individual stated that their , investigation had found that this " comment" was deleted by the - ' auditor after discussions with two QC welding inspectors. On m ' April 16, 1986, the NRC inspector was able to contact the former TUGCo auditor by telephone who confirmed the information described -
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Labove~and indicated that he was satisfied with its dispositio '
: ,
The revision to the audit finding concerning calibration of
-
protractors was made by QA management which included discussioas with
+ the responsible auditor. The NRC inspector agrees with the be. sis for the change (i.e..' protractors are instruments not subject to periodic <
rz calibrat on) and also agrees with the finding as revised. Notes in the audit file also provided evidence that the auditor was aware of ; the change and did not disagree with the revisio ; Based on the documents reviewed and the personnel interviewed, the NRC inspector found no additional information that would alter the NRC. conclusion documented in Supplement 11 as stated abov '
: ~4-86-A-031: Alleged Iaproper Electrical Cable Installation A concern was raised that the electrical cable associated with a < . power operated valve had been improperly installed. The valve in question (2-LV-2478) is a 3-inch, air operated level control valve which is located in the discharge piping from the Condensate Transfer > Pump. The' valve is the Domineralized and Reactor Makeup Water System - , fill control valve'and,is controlled by the Condensate Storage Tank level transmitter. The expressed concern consisted of two parts: (1) The flexible conduit for two cables could be pushed into contact lwith each other, and (2) the outer jacket of one of the cables had been' stripped bcck, out of sight, into the conduit connected to the limit switc An NRC inspection of the valve installation verified that the .
flexible conduits connected to the valve limit switches could be
. pushed into contact; however, the conduits (and the enclosed electrical wiring) are all of the same electrical separation train,
, =and, therefore, no separation needs to be maintained. The limit switch installation in question was observed to be a closed (completed) assembly. The NRC inspector did not request that this assembly be opened for visual inspection based on the review of , applicable requirements related to cable jacket removal. TUGCo Quality Procedure QI-QP-11.3-28, TUGCo Installation Procedure EEI-8, and G&H Electrical Erection Specification ES-100 were all found to , contain requirements on the process to be used to strip back the
' outer jacket, but no requirement on the maximum acceptable length of the stripping process. Since the electrical cable is en;10 sed in conduit and the outer jacket is for protection of the conductors , during installation of the cable, the removal of the outer jacket ! i
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m * - back into 'the conduit is not significant from either'an electrical or i % ' safety' standpoint. _ Accordingly, the allegation of improper
; jelectrical cable installation was not substantiated. ' " - CPRTQAProidam * - :' t T Program Establishment and Implementation [~ ' - ' ,
The purpose.of this inspection was to determine *if the 0QT'as-established was being implemented. In reviewing requirements-
' " ^
governing the 0QT, the CPRT Program Plan was essentially silent concerning the 0QT except for Appendix G, Figure-2, an information flow diagram. No definitive requirements for the.0QT could be found
'
- in any CPRT documents (i.e., Procedures, Guidelines, or Policy statements). However, in an August 15, 1985,. letter to the NRC, x .TUGCo described the establishment of the.0QT as a quasi audit 1, ; function. Its purpose was to provide additional assurance to TUGCo's
' '
, ,
'
unagement that the CPRT has achieved CPRT objectives and properly
, responded to and resolved the open items identified. Currently the -
only document that describes the 0QT" activities is the OQT Program dated February 20, 198 '
~
In a February 28, 1986, letter to the NRC,-TUGCo redefined the
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'
description of the'0QT. The scope of the 0QT was limited to surveillance:of the QA/QC (ERC) and Design Adequacy (TERA) quality
. assurance program In lieu of formal 0QT auditing of CPRT activities, surveillances would be accomplished by reviewing the ERC . '
and TERA audit reports and their followup of corrective action resolution. . Traditional audits by 0QT would be conducted only when
'
di.rected by the SRT.
r Various versions of the 0QT Program were reviewed by the NRC and
' compared to issued 0QT reports and supporting documentation to -
evaluate the implementation of the 0QT program.
(1) -00T Program
. The current 0QT-Program is described in an uncontrolled document
-
not approved by the SRT. It delineates the 0QT's: charter; objectivities; general description of methods for performing activities; and structure for reporting audit and surveillance results. -Since September 1985, the program has been revised and reissued approximately five times.
'
,
. (a) Changes to the 00T Program. Originally, the 0QT reported to the Executive Vice President of Nuclear Engineering and
' Operations. In November 1985, this was changed to the 0QT I reporting to the SRT with their reports going concurrently
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e,n - -In10ctober 1985,LthelscopeLof-the 0QT review activities was
;gg, . J 4% changed:tooinclude only the.ERC and TERA quality prograns,.
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s thus1 eliminating the review of electrical and testing s
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a cactivities. Other changes included the deletion of the y t /" ,
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Tword "shall'.': and . replacing it1with words , such as "may be";
,
' ; thus :providing nonmandatory guidelines as opposed to K: ~g.f - '
'
4 . establishing requirements; :. Activities relegated to r-; '
,
'nonmandatory,were- direct observation of work 'in progress; l g.. , -for example,;rather than performing these activities
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* : routinely,they will-be performed only when QA activities
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:are in question orLwhen directed by the SRT. Taken m.,
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collectively, these shortcomings represent a deviation in
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ithat the_SRT is not fully util.izing-one-of the elements 2 available to them for assuring the quality of the CPRT ZN:
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Jeffort:(445/8607-D-05).
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+ :Other examples of weaknesses that currently exist in the !
r0QT Program description include:
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, a ^ 1)- Section 3, " Typical Checklist Approach," states that
,
most evaluations by the 0QT will be performed using a , n , checklist; however, no criteria exists to identify
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when a checklist'is require " ' 2) Section 5, " Reports," does not have clear enforcement
, * ,
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provisions for findings, observations and open item + y .
. Further,Lno definition exists to correlate the
,. significance of findings (i.e., observations and open items)'to'the required corrective action ' '
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Section'4, Task Definition and Assignment", describes
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3)' -
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'the OQT review of QA personnel qualifications, QA
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procedures, and QA work products; however, no commitment is made to actually perform in process
, audits'(inspections) to verify effective procedural implementatio It is not evident nor is there a requirement in the ~ .
4)
., A 0QT program for systematic planning and scheduling of their activities that is correlated with CPRT activities. For example, Section 5.3, " Final Report,"
states that~ the final report shall include a matrix E showing the identification of each QA activity that b was reviewed and evaluated by the 0QT for compliance
"d ' '
to specific requirements, but no trention is given of a
&, matrix of quality elements to be audited that would '
O- assure the entire CPRT QA program was evaluated for implementatio t i) c V
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.(2) Implementation of- the 0QT Program In comparing published 0QT reports to the 0QT program for ,
compliance, the following were noted:
' - (a)' Sections.2.4 and'2.5 requir'e additional audits or 'l inspections be performed by direct observation of work in progress when QA activities are in questio ' .
In January 1986, a stop work order was issued by the SRT t a ,
.
ERC for the questionable performance of CPRT reinspection '. The 0QT did not perform any direct observations, audits, or inspections as required by Sections'2.4 and 2.5 when these reinspections were identified as. questionabl ' (b) :Section 3 states.that most evaluatione will be. performed
, ,
using checklists which are to be attached to the 0QT report Of the.six 0QT reports reviewed, two were accomplished
* ' using checklists. A checklist was attached to only one of the report (c) Section'3 requires followup on the resolution of findings and open items identified in 0QT report A finding that inspectors had been certified to perform -
inspections prior to verification of their experience, training, and education was reported to the SRT on October.23, 1985; however, as of April 30, 1986, the SRT has not commented on the acceptability of the corrective action taken nor has the OQT conducted a followup inspection of these certification activitie In summary, the present 0QT program appears lacking in the following areas: (1) no definitive procedure describing the responsibilities and authority of the OQT and similar functions; (2) no clear review and audit responsibility pertaining to CPRT activities, particularly
- those relating to the resolution of those CPRT ISAPs not primarily-directed.to the construction (ERC) and design (TERA) review team leaders; (3) no procedural controls for the SRT concerning timely followup and resolution of identified deficiencies; and (4) no master schedule of activities related to 0QT reviews and audits that correlates to CPRT schedules and statu The' conditions described above have been identified as a deviation (445/8607-D-06).
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_ .$ . ItL.was noted during this' inspection that the ERC site QA manual was M ' S not being maintained current. . Controlled copies of this manual had
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Jk incorsetrevisionoftwoprocedures. This lack of proper manual' control-is a deviation (445/8607-D-07).- -
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.@ 3 $ / @ !bh ERC Corporate Audit of the Onsite QA/QC Program
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'/ tfW$ .The QA/QC review team's quality program is monitored by ERC using two methods;;(1) the performance of surveillances'and overview inspections by onsite representatives of ERC's Manager of Quality,.
and.(2)' periodic; programmatic. audits of the quality progra , During:this inspection, the.NRC evaluated the conduct of programmatic y audits.as governed.by ERC: Procedures ERC-QA-18, Revision 0,
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. ."Adefnistration of Quality Assurance Auditing," and ERC-QA-20, l Revision' 0, " Conduct' of Programmatic Audits." The five published
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' audit. reports.and supporting documentation were co.npared to the
- require:nents of the governing procedures to assess the adequacy and .
11mplementation of the audit program. The areas of the audit program '
~
inspected included; scheduling, planning,- personnel, performance, 7 m1 @- -
: reporting,fresponse and follow-up, audit closure, and record . ' -a W. : , .' " (,, (1)) Audit Schedules
' mg * Procedure ERC-QA-18, Revision 0, requires both long'-range
, V (annual) and, quarterly schedules for conducting audits to be
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prepared, approved, and issued prior to the beginning of the year:or quarter covered by the schedule. The 1986 annual and _
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first quarter (January through March) schedules were issued :
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January 13, 1986. The issue date of the second quarter (April through June) schedule was May 20, 1986. Even though the audit
! schedules were issued after the beginning of the respective ,
quarter,'this had-no significance since audits were not
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conducted prior to,the publication of audit schedules. These schedules were found to be consistant with procedural requirements for documenting scope of audit, identification of product oc-system, date of audit, team leader and auditors, and
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applicable remarks.
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(2) Plannino and Preparation Procedure ERC-QA-20, Revision 0, requires preparation of a detailed plan, checklist, or questions and notification to the organization involved in the audit be accomplished prior to conducting the audit. E:ch reviewed audit file contained a '
comprehensive plan, checklist, and documentation of advance notification to the audite These documents were found to have been prepared, reviewed and distributed in accordance with procedural requirement ,
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(a) Qualification / Certification: Audit personnel qualification
.and certification files were reviewed and compared against
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'" - itheLrequirements of: ERC-QA-23, Revision 0, " Personnel
, certification." Auditor files' contained: CPRT objectivity
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: questionnaire, education / experience verification summary, .
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current: qualification / certification data, certifying exam ' with results,-required reading,-training records, past qualification / certification records, and applicable reading . p assignments. Their; qualifications were verified to assure '
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'the technical specialists had experience and training'
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F' Y commensurate with the scope, complexity, or special nature
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_'of the to activities being audite The auditor files were ,
- , .found be in conformance with the requirements of
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ERC-QA-2 T
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- (b).: Audit Team Selection: .When teams were used to perform an
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audit, members were independent of the activities being
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' audited.. Team leader, auditors,.and technical specialists '
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G ~! y were. qualified and certified in accordance with ERC-QA-2 (4) Performance
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The NRC, inspected the following elements, relating to audit
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. performance,.by comparing five published audit reports to the
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. ' . procedural requirements: >
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> ' (a) -Preaudit Conference: Preaudit conferences were conducted in accordance with ERC-QA-20 and documented in each audit repart. . Subjects covered were audit scope and plan,
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: establishing. lines of communication, access.to
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organizational areas and personnel, and schedule for the
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postaudit conference.
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(b)' Conduct of Audit': Audits were conducted using audit plans ;
i _ and checklists. ' Objective evidence was examined by the f, auditors to verify compliance and implementation of
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' prescribed requirements and'any deficiencies were documente _
' (c) Postaudit' Conference: At the conclusion of the audit, a
' postaudit conference was held as required by procedure. An
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overall' summary of the audit findings as well as each individual finding was presented to the audited
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organization. - Clarifications were made where e.ppropriate
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to prevent any misunderstandings. A request for immediate , initiation of corrective action was made where deemed
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necessar n m
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,/ 1(5) . Reportin '
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After the completion.of each audit,'a report was written to the-
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a .QA/QC_ Review Team Leader to formally communicate audit finding , . ,
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Major sections of the report include:: i f ._(a) Audit scop ,
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_ f(b) Personnel - identification of audit' team and persons contacted during pre and'postaudit activitie '
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(c) Preaudit conference.- summary statement of audi m
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f & 1): Summary of results - highlight of positive and-lW ' ~
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negative finding J54 _
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2) Details of findings - findings of conformance and
' deviations; deviations were'also reported on Audit ' x y" , . ,- - Action' Requests-(AARs) as an attachaaent to the audit report (AARs'are used to resolve and track required ,, %, s ~ ,'- corrective action items).
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(e) :Postaudit conference'- summary statement of-audit result '
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^ -(6)' Response and Followup
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.For each AAR,'ERC's management scheduled corrective action and
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, measures to prevent recurrence, then notified the lead auditor
. in writing'of actions taken or planned. The audit' team
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. evaluated each AAR response of proposed or completed action and either accepted or rejected with comment the actions planned or
.taken.,
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Procedurally, follow-up action'.by the audit group included:
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~(a) Maintenance of an Audit Status Log to reflect the current status of each audit (for example; scheduled, report issued, responses received, evaluated and approved, and closure).
, (b) Maintenance of an AAR status log indicating the current status of issued'AARs (open or closed).
'(c) Maintenance of a working file in which documentation - g supporting each aud.it was collecte The maintenance of working files was found to be current; ,' however, the closed date entered on the Audit Status Log for audit ERC 85-01 was missin For audits ERC 86-01 and
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, .ERC'86-02, the AAR. log was not maintained. Log entries were not-
'made for findings from these audits. Even though these' log '
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.were not.maintaiaed per procedure, the evaluation of. responses '," '.g to findings, verification of corrective actions taken, and '
lypropriate audit closures were performe The. failure to maintain the audit tracking and AAR legs in
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'accordance with'ERC proceduresjis a deviation-(445/8607-D-08).
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#- Following the verification that each identified deviation was
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corrected..the respective audit was closed and correspondence to the QA/QC Review Team Leader documented the audit closur The Jstatus' logs and working files were updated to-reflect closure of
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s q.~~ .y 1the; audit, except as noted above. In reviewing the working files;for completeness, the files were'found to be in accordance
- 'with the status of;the audit. Closed audit files contained o Lrequired records. Open and inprocess audit files contained- -
up-to-datefdocumentation.' Typical records found in the files were:
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s Audit. schedule-
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9~ Notification of audit
. Original of audit plan and check sheets .y ^- , ;Preaudit conference Draft summary and findings Supporting material from the audit
- , , Audit report and transmittal of request for corrective
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action Audit responses
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Postaudit conference
' Closure statement, disposition ~
, In summary, except as noted above, ERC's corporate QA audits were planned, scheduled, and performed on a periodic basis to
<
. < evaluate the effectiveness of the QA/QC review team quality
< -
; program. The audits were performed in accordance with written
, . procedures and checklists by personnel who did not have direct responsibility for activities being audited. Audit results were documen9ed and reported to and reviewed by responsible management. Follow-up actions were taken where indicate Overview Inspections
,
The-review of the ERC overview inspection (01) activity by NRC inspectors is based on ERC Quality Assurance Procedure ERC-QA-28, Revision 2, " Performance of Overview Inspections." OIs are to be performed on a selected sample of ISAP VII.b.3 and VI reinspection / documentation review packages previously completed by ERC Inspectors. The OIs duplicate the initial reinspections using
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, ;ERC Quality. Instructions (QIs).and essentially identical verification ,
m : packages (VPs). A comparison of the initial -reinspection with the OI
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cis documented on an Overview Inspection ~ Report, which is completed
~
for _each . verification package that is. in the sampl b NRC inspectors independently inspected the following eleven overview
- . VPs during this report period:
s . 42-I-S-INSP-033 2-I-S-PS7N-011
' : 38-I-S-PS7N-056 ~
38-I-S-PS7N-060
.24-I-S-PS7N-146 ~ :2-I-S-PS7N-163 , .35-I-5-STEL-140 4-I-S-STEL-146- - 35-I-S-STEL-164 35-I-S-STEL-197 k 13-I-M-LBCO-14 ~
D'e tails on the NRC review of the ERC initial reinspection for the
'above VPs are identified in the appropriate ISAP_VII.c section of :this or previous NRC inspection report The,ERC overview inspector and overview supervisor signed the n Overview Inspection Report.as acceptable for all of the above . packages, indicating agreement between the OI and the initial reinspection.' Subsequent NRC inspections identified the following conditions:
42-I-S-INSP-033: The NRC inspector identified a deviation in NRC Inspection Report.50-445/85-16; 50-446/85-13 against this initial ERC reinspection package in November 198 Subsequent to the NRC inspection'and prior to the OI, the ERC checklist was changed and a deviation report (DR) was issued to reflect the NRC identified
-
condition. . When the overview inspector compared the VP with the initial reinspection package, he found no unsatisfactory decisions on the part of.the initial ERC inspector. The fact that the NRC had identified some unsatisfactory decisions against the initial ERC
' inspector was not reflected in OI's VP. The impact of the overview inspector not identifying these unsatisfactory decisions on the part of the ERC inspector is not known at this time. This finding is an
, , unresolved item (445/8607-U-09).
13-I-M-LBCO-148: During an NRC inspection, three cases of pipe to i pipe clearance in violation of Section 5.2.6.2 of QI-025, Revision 3 were identified. However, the initial ERC reinspection as well as the OI failed to identify these three deviating conditions.
! Specifically, the lines which were in deviation of QI-025 were I-l- i Lm
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k m dVl"'~ conditions:is a-~ deviation (445/8607-D-10);
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% 2 2-I-S-PS7N-011: 7A n'ERC DR'was: issued by the. initial ERC Inspector cea ^ : for; unsatisfactory pipe' clamp ht alves parallelism. ' Attachment 6.1 of-yg y:., ' ' 'QI-037. Revision 1, specifies acceptance criteria and states, in
~
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part,:"S dimensions on'the same side of the elamp,at points 1,l2, and-
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f 3 shallgbe4within 1/16" ;of = each other '. ~. . .": Measurements are
, ; ~y% ( - < . recorded;for each side of-the clamp (S1 and S2);on Attachment 6.1 of- -
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. .f : t;> 1 Measurements = for Sl~ recorded by the initial 'ERC inspector show a .y s , 6 difference'between points 1 and'2:of 5/32", between points 2 and 3 of .
9 y. T> M(1/8", and_between points?l1 and.3 of 1/.4". The overview inspector 1
; R.; $ trecorded measurements,which show: differences between the'above points JL i , f of 3/32",1/16", and;1/16", respectively. TThe~ initial ERC . ,
M~, . ; reinspection and the overview inspection measurements both indicated
"
'S1 was out of tolerance; however,.the actual measurements showed up
@ - 'toia 1/4" discrepancy:between the two inspections. Similar s ~ ." ': measurements 1taken during ;the initial .ERC reinspection. .showed S2 to u M' ' '; , -
. be out _of! tolerance bycthe- same amount identified for Sid The
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_ overview , reinspection identified -S2 as being within- tolerance. The-
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"ERC DR-issued by the initial:ERC inspector concerns only measurements lp_ " ifor 51 7The overview inspection failed.to identify and resolve these
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sTh'eNRCEindependent; inspection showed that measurements for Si and S2 :
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.ff (were within the~ tolerance criteria and.no DR'was warranted.- A Y subsequent' reinspection by, overview inspectors and th.e(NRC-inspector
'
J Jconcurred with the results of'the NRC independent inspection.. The ' '
" '
1 failure.of,the overview' inspector to identify and resolve;the' above
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c f aeasurement discrepancies -is a deviation l(44,5/8607-D-11). - m ;* r '
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'E" , '38-I-S-PS7N-056:."The.NRC inspector observed that two cotter pins on
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W :the clamp side of the ' strut were approximately one' half the diameter m 'that the procedure specifies. A review of the ERC initial -
, W reinspection package and the overview inspection package indicated an unsatisfactory condition for locking devices; however, no DRs'were , ' < U
.: ilisted or written for undersize cotter pins. The failure'of both the_
,
b * 11nitial'ERC and 01 inspectors to identify the presence of undersized CY J ' cotter pins is a deviation (445/8607-D-12).
zw m 24-I-S-PS7N-146: 'The initial ERC inspector signed off as acceptable < @p Attribute 3 on the reinspection package regarding spherical bearing
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'g'ap. 'The required measurements were taken on spacer thickness and G resultant' gap, with the results recorded on Attachment 6.2 of the
_
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_ reinspection package. The overview inspector also measured the
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: spacers and resultant gap, accepted Attribute 3 on the reinspection
- checklist, recorded the results on Attachment 6.2 of the reinspection
,
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l package,Eand noted'no unsatisfactory decisions. The.NRC inspector-
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.was unable to check _ the resultant ' gap and spacer thickness due to the J1 : amount. of. paint found on the ' spherical -bearin <
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Subsequent to discussions with'NRC, a-second OI was performed which tagreed with-the initial ERC-reinspection. The NRC inspector ~
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(participated:in a third inspection with a group of overview
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sinspectors.and identified that a' quantity of paint had been' remove The overview ~ inspectors stated that they had removed-a small amount s
'
of paint in-the course of. reinspection. The NRC! inspector confirmed
.; -some paint had been-. removed but with the' amount of paint remaining, %r ~
an accurate measurement, as required by.the procedure, was still unobtainable. . .The overview inspectors stated that an educated guess e P . lwas;made on theseLeeasurements due to the presence of paint. No out 3of scope observations were written by ERC. The absence of an-
'
n-
;' '
accurate sphericalEbe'aring gap measurement is a deviation
'(445/8607-D-13).
J 4'-I-S-STEL-146: Gusset plate C10-17 was not installed as shown on
,
Design Drawings 2323-S-0799, Revision 1, and MAB-0799-0C8, sheet 1, ,
'
Revision 3. Connection orientation is delineated as Attribute B3 of _QI-045, Revision 2. This attribute was accepted by both the original
, -F.RC inspector and the overview inspector. The gusset plate was, 6 *
however,1 incorrectly installed; i.e., installed at the base'of
' -
member C9-4 instead of at the top. The failure of both the original or ,
-
.ERC_ inspector.a,nd the overview inspector to identify this condition i Tis'a deviation (445/8607-D-14).
. 1 .CPRT ISAPs (Excluding ISAP VII.c)
. 3 .
l Inspection Reports'on Butt Splices (ISAP I.a.2) L' The NRC inspector reviewed ERC menos, NCRs, TUGCo work orders, and
: performed inspections related to this ISA .. Review Inspection Reports on Butt Splices (NRC Reference No. I.a.2.01)
- As described in NRC Inspection Report (IR) 50-445/86-01; 50-446/86-01, the program proposed by the CPRT for butt splice
' '
inspection consisted of three parts, Phases I, II, and II The c -Phase I activity required a-CPRT review of the 12 butt spliced cables that the NRC's Technical Review Team (TRT) had reviewed to determine if' addition project inspections were required. Phase II inspection
+
: activities were to be initiated by ERC of splices in panels, if the result of the Phase I activity determined that additional inspections
- were require Phase III inspections were to be conducted by TUGCo of all other essential circuits where the AMP insulated splices may have been used.
'
,
The NRC inspector verified that the Phase I reviews had been
.,
completed and that, as a result of those reviews by the CPRT, that f r w e+--+ wn - " we-i-,w e-. -,,www-.yy e,,-,w--+4-,-~ w w-y +-g---*%-- e 1 - w m 9 , - - - ----- +m i 9 t
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~ Phase ~II! inspections!had1been initiated. Therefore, the requ'irements
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~ -v4.of this; activity have been
? activity:isicomplete.11No fulfilled or violations and NRC inspection deviations were identified of this ' .,
W ,; a r ,g ~ ~ M;@ g Drawing and Design' Change Reviews'-(NRC Reference'No. 01.a.02.02)
.
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.
4 , . . .. . . .
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u ,Sectionl4.'1.2'ofLthis ISAP. required a~ review of 'all drawings and-H- f' fdesign change docuaents involving butt-splices in safety-related
.,
_ "cablecfto assureithat the splices were documented. During NRC M - . inspections!ofpanels1toverify:thestatusofbuttsplices,theLNRC' t gg" :.t in_spector found that; cables A0102707..E0106963, E0106993 'E0111093,
.
6 ; << land E0111179. contained _ splices which were'not shown on the' drawings.-
, ;T < W H
~
~
^
Followupiinspections' for these splices showed they had been authorized
^ ; by DCA :17',762. Revision 2,~.and that irs exist which documented the '
W . 4 splice) installations.'.None of these-' splices were,,however, identified
-
fduring;the:CPRTtreview of drawings and design change! documents. .The ~ c% y . failure of CPRTs to review all' design change documents and identify 1y e .all. authorized' spliced cables is a deviation (445/8607-D-15).
^ '
?- ~ 'In'spection~of.' Cables (NRC Reference No. 01.a.02.03) < . _
e , The ISAP/ required the initiation of Phase II inspections-for all.of ' ' ~
.
'
.
;the cables identified:in the CPRT documentation reviews discussed
' '
'above. NRC~ inspector review of thesCPRT; irs for 32. compartments
.
'
. located inL11 Motor Control-Centers (MCCs) showed, (1) no splice'
<; staggeringfdeficiencies:we'reidentified,(2).6ofthecompartments
- '
~ - cdid'not contain-the splices that were indicated on drawings, and - ~> ' ' L(3)L11 compartments;were identified, each of which contained 1 , _
,
' ~ ; unsatis' factory splice. -Of these.it unsatisfactory splices, 4 were 4not shown on' drawings.. Thr_ee of these were removed for pullout s C
ftestingandradiographicexaminatio ~ i - . ,
:NRC Review 'of NCR Dispositions- . . *
JA sample 116 NCRs', which were part of a total of 37 NCRs generated as i *
'
la result of Phase'II inspections, were reviewed by the<NRC to assess
-
' .the final disposition of Phase.II inspection deficiencies.,~The NCRs "
reviewed were: ' >
; --
,
t k
'
NCR No.: . STATUS CABINET No'.. -
~
'
, , I E85-100059s Closed CP1-ECPRCR-03 ,
.E85-100068s Re Closed CP1-ECPRCR- 03 ,
i%*.' E85-100115 C1osed TBX-ESELSP-01
; E85-100054s - Closed TBX-ESELSP-01 m , 'E85-100117s.- Closed CP1-ECPRTC-04 < , 85-0061(OPS) Open CP1-ECPRTC-0 . - , E85-100118s Closed CP1-ECPRTC-17 .. .
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' E85-100122s-Re Closed - CP1-ECPRTC-42 x . E85-100119s Rev.1- C1osed CP1-ECPRTC-15
-
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:E85-100073s .
'
. Open - CP1-ECPRTC-16
~.
E85-100123s Re Closed CP1-ECPRCR-0 : Closed
'
-
:E85-100075s. . . CP1-ECPRTC-26 4 :
E85-100121s.Rev.3' Closed: CP1-ECPRTC-41
~
E85-101231sx '_ Open CPX-ECPRTC-03
. E85-100034 Re Closed- CP1-ECPRCR-27 E85-100058s ' Closed CP1-ECPRCR-03 -
g~ Eight of the!NCRs identified seven conductors with damaged
, .. insulation, six of which have been repaired. Five NCRs identified 44 ' :
conds. tors that had' installed butt splices that were.not authorized
*
by design. documents; the drawings for.38 of these conductors had been updated and_ verified by QC. Three of the NCRs identifled 111
'
>
- conductors as not having the butt splices which were.shown on the
:-' idrawings; the drawings for_these. conductors have been updated by
-
'
- removing the-splices. Seven of the NCRs identified 42 splices that
,
'
have no inspection reports documenting that the installation was
' c~ ~
-
witnessed;^34,of these splices have been reinspected. Four of the
- NCRs identified 34 splices that were found unsatisfactory after reinspection. 'Three NCRs identified splices for 15 spare conductors
. which were remove '
, NRC Inspection The NRC inspector performed an inspection of two conductors 2
'
, identified in the CPRT inspection reports as having the splices
'
removed and-then being reterminated without splices. These two
, conductors, EG109862(W) in Unit 1 termination cabinet CP1-ECPRTC-17
>
and E0106204(8) in Unit 2' termination cabinet CP2-ECPRTC-41, were observed to be-terminated witheat obvious splices; however, the cable
',
bundles containing these conductors were not opened to determine the
>
existence of splices-inside the bundl . NRC inspections were also performed in the following six cabinets, which had been previously inspected by ERC in Phase II, and which
'
were known to contain butt splices: CABINET N DRAWING N REVISION N CP1-ECPRCR-03 2323-El-0155 CP-8 CP1-ECPRCR-04' 2323-El-0156 CP-7
. CP1-ECPRCR-13 2323-El-0158 CP-10 CP1-ECPRTC-16 2323-El-0172-16 CP-5 2323-El-0172-41 # '
CP1-ECPRTC-41 CP-4 CP1-ECPRCR-03 2323-El-0172-42 CP-3 The NRC inspector identified three splices in cabinet CP-ECPRCR-13 which were not shown on the appropriate drawing. These splices were
- ) , in cables E0111179 and E0106993 located in a cable bundle with other t -
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* ' Tplices ihich had[beenfinspectdd by.ERC. 'ERC_had' inspected-W .ccable E0106993 and identified only- the white. conductor. as being DJ 'M
.
g spliced;;however. the black conductor of this cable was.also found to"
~,2be spliced by the.NRC inspector.' ~The ERC inspection procedure _did-
.
g, e 28p7 J gnot require;the opening of: cable bundles, but the~NRC inspection
~ - e e sincluded opening the'bundlese '
cd C -
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l ( ,1 EInladdit' ion'to th above :ERC: inspections'. TUGCo' inspectors
' - ,
-
reinspected' cables;E0106993 and-E0111179 as required by CAR-05 ;
. <
o.- W . ~., t 2These inspections were also. performed without opening the cable m- ; bundles, and TUGCo inspectors also failed to identify these splice s_, - "(TheiCAR-050 inspections-were performed to assess;a. previous TUGCo
, _
'
, _ '
! inspector's._ performance in the area of terminations 4and butt
m2 1 splicing.)' p q ,_
^ ' - - I ?The NRC inspector'also ' identified' that 21tconductors;were terminated ^f '
sin' cabinet CP1 ECPRCR-13 that were not shown'on the drawing. Further-
. ' ' . J Lreview showed that these conductors were to1be removed under wor 'q , ,
icontrolled by Packa'ge Process: Form'(PPF)-158. 'The drawingtwill.be n ,
; updated to; include these.conductorsjin'accordance:with* plant a
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' CablelE0111169"was identified'by .E,RC =as not meetingist'aggering .
-
-
. .. requirements and NCR E85-100124s was< written. . The NRC inspector -
1 verified by . inspection: that this ; deficiency had been corrected;asb < -
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'
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< documented in operation traveler EE85-11,462-8904 which;placed_ cable; ,
a
-
ijacketing material:between. adjacent splices to keep'them from '
,w , : pressing against each othe . : y -
.
,
"
,
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'
,' 1 Based on th'eLabove NRC. inspector actions, Ahe=CPRT activities to s 4 ' '
.
-
. resolve this^ISAP requirement were'! determined--to be acceptable except- _
?R ' 'V for the-adequacy.of.the methods'.used to determine splice location and . : staggering within cable bundles.- The adequacy of the inspection of fe
~
' adjacent ~ splices will.be addressed under NRC Reference "
& s; ,No.J01.a.02.09. _The~ adequacy of the above ERC and TUGCo butc splice v
'
- ; inspections is .ar unresolved item pending clarification from NRR as ye ~ f
*
to the purpose _of these inspections (445/8607-U-16).
Since'theiCPRT required inspections were performed in accordance with
~
gj ;the:ISAP_ connitments, NRC inspection of this activity is complet y_ ; - n Ti -No M olations or. deviations were identifie v ..
. . _
C ' Documentation Review of irs (NRC Reference No. 01.a.02.04)
~
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~
(TheISAPrequiredtheCPRT,asapartofthePhaseIIinspections,to perform a. documentation review of spliced cable irs to ensure the
. 9 ,
. splices 'were inspected and reflected on the appropriate drawings. As
-
-
: stated above, the CPRT inspections were acceptably performed with the
.,L~ exception of_ the: deviation described under Reference No. 01.a.02.02.
'i In addition, the NRC_ inspector did not identify any splices which _
*
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were either not;already shown on the' appropriate drawing or where the
' drawing _was. not'~ properly revised as-a result of CPRT findings (see , ,,' "~ NRC Reference No. 01.a.02.05). Therefore, the NRC inspector has C i ' ; determined that the-requirements under this activity have been f acceptably implemented and NRC inspection of'this activity is- : complet , ~ , .No violations or deviations were identifie s -
Revise Drawings (NRC Reference No.- 01.a.02.05).
p ;
' . J The ISAP required.that the plant drawings;be revised to show the @_ ~ ~ -actual--butt splice' configurations disclosed during the Phase II -
inspections. The NRC. inspector selected a sample of the involved
' , ; plant drawings to ensure that appropriate revisions had been ' , incorporate The:NRC. inspector's' review of Drawings 2323-El-0155, 0156, 0158,~0172-16,-0172-16, 0172 41, and 0172-42 verified that all '
n required revisions h'ad been completed. Based on the acceptability of Lthe-NRC inspectors findings, NRC inspection of this activity is
=' ' - ' complete.
b,
~
No violations or. deviations were identifie ' Replacement of Rejected Splices-(NRC Reference No. 01.a.02.06)
The ISAP required butt splices, which are determined to be
~ ,, . unacceptable; be replaced. The NRC inspector verified, by physical inspection, that the 88 splices, which were rejected by the CPRT, were removed and had been replace NRC inspection of this activity ;is, therefore, complet . :No' violations or deviations were identifie ' Tests of Replaced Splices (NRC Reference No. 01.a.02.07) :The NRC inspector verified that pullout tests and radiographic ' examinations.were performed for 32 splices. (Twelve of these were standards for comparison.) The r;csults of the pull testing and radiographic examinations are documented in a pull test report which
_* .
.was reviewed by the NRC inspecto Electrical continuity of each splice was measured before and after
- the pullout test. All splices removed from the field were radiographed prior to pull testing. The pullout tests were performed in accordance with Underwriters Laboratories (UL) Test Procedure 486C.'Section 13. If a splice passed the UL test, it was then pull tested until it faile Three of the field splices tested failed the UL test. Two of the failed splices had underinsertion of
'the wire into the wire barrel and continuity could not be measured prior to the start of the pullout tes The other splice that failed
. - . - - - . _- . - _ . - - - - _ . . - - _ __
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. .had:the wrong size splice connector installed for the wire size. All
,
* , 1the other-field splices passed-the UL tes '
,
Since the removed splices were tested in accordance with the ISAP
. requirements, NRC inspection of this activity is complet ~
, - No violations or. deviations were' identifie ~
~
Inspectio'n of Adjacent Splices in Same Wire Bundle (NRC Reference
, No. 01.a.02.09) ,' N :As1 discussed in Reference No. 01.a.02.03 above, the adequacy of the ~ ~ ~ ~ inspections performed by both ERC and TUGCo.is under NRC evaluatio ' ~ . This activity will be discussed in a subsequent report (see ,
unresolved item 445/8607-U-16).
L - Identification of- Sp1' iced ' Cables (NRC Reference No. 01.a.02.-101
' '
The ISAP required the identification and Phase III inspe'ction of other essential circuits where AMP insulated butt splices may have been used for equipment terminations; e.g., pigtails on solenoids, electrical devices. The NRC inspector review of the CPRT files verified thatfappropriate plant drawings and related documents were reviewed by the CPRT to identify locations in which the AMP splices may have.been used. Based on this review,-the NRC inspector
; determined that the actions required by this activity were acceptably-completed. Therefore, NRC inspection of this activity is complet Review of NCRs (NRC Reference No. 01.a.02.12) ~
Paragraph 4.1.3 of this ISAP required NCRs be issued to initiate the
~
Phase III inspections of-essential cables that could have the AMP butt splices installed.- The NRC inspector verified that the cables identified in the above activity were included in two NCRs. The NRC inspector further eviewed one of these NCRs (E85-100588s) and found that TUGCo inspections for 22 of the 25 cables in Unit 2 have been completed. These 22 cables all contained uninsulated splices covered with heat shrink tubing. Two of the splices were found to be unsatisfactory; one splice was in a spare conductor.and was removed, the other splice was not shown on the drawing. The drawing has been updated to show this splim , Based on the finding that kHs had been issued as required by the ISAP, NRC inspection of this activity is complete. The results of the Phase III inspections (NRC Reference No. 01.a.02.11).will be-discussed in a subsequent report.
, , No violations or deviations were identifie .at g -
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- - - - -
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' ? 28 g, . - , # . - Butt-splice Qualification (ISAP'I.a.3) '
s iRevise Procedure EEI-8 (NRC Reference No. 01.a.03.01) C-E iThe NRCLinspectors reviewed Construction Procedure EEI-8, " Class IE
. . ' ' and Non-Class IE Cable Terminations,t' Revision' 5, dated June 13,
% -
-1985.1 The. procedure contains instructions ~for continuity checks and e ~ .' : staggering ~ attributes for preinsulated environmentally sealed (PIES)
splices while uninsulated splices with heat shrink sleeving are not included. The acceptability of not including these. attributes for
- uninsulated splices.is an unresolved item (445/8607-U-17).
. No violation or deviations were identifie <
' Revise Procedure QI-QP-11.3-28 (NRC Reference No. 01.a.03.02) ' - 'The NRC inspectors also reviewed Quality Inspection Procedure QI-QP-11.3-28, " Class 1E Cable Terminations," to verify othat the attributes for splice continuity checks.and staggering were : included.: A continuity check is only required for PIES splices installed in control panels. Staggering of splices is only specified for PIES splices and device pigtails. There is no continuity check '
cattribute' included for uninsulated splices or PIES installed outside
- of control panels; e.g., in MCCs. .Similarly, there is no requirement
~
>
,
for staggering uninsulated splices'at other than device pigtails; -
- .
e.g.,' electrical penetration assemblies, control panels, MCCs, et ~ Theprocedurelacksinstructionsdescribingtheaccept/ reject
' . attributes for a_ proper crisp connection for either PIES or uninsulated splices and instructions for splicing #6 AWG through 1000 MCM cables. This subject is an unresolved item pending completion of procedure revision and NRC review (445/8607-U-18).
Train Craft Personnel (NRC Reference No. 01.a.03.03) Section 4.1.2 of.this ISAP required the applicant to train craft and inspection personnel using the revised procedure The NRC inspector verified by review of training records that 43 electrical craft - personnel have been trained to the appropriate procedure (EEI-8) and ' that these 43 are the only personnel authorized to install butt splices. This activity has, therefore, been acceptably implemented and NRC inspection is~ complet No violations or deviations were identifie . Train and Certify Inspectors (NRC Reference No. 01.a.03.04) Training and certification of QC inspectors for butt splicing has also been completed. Currently, there are 37 inspectors certified to perform work in accordance with the applicable procedure (QI-QP-11.3-28). All 37 are certified as Level II inspectors. The training records for nine of these inspectors were checked to verify _ - _ - ,_ _ __ _ . . . . - _ _ _ __ . _ . _ _ _
.
_-
, __ $ ):L ~ i y ' - ,
_ ir R :29-
'
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.
% 'they,were. certified.to QI-QP-11.3-28, Revision 28. Since the NRC-inspector-has verified that the requirements of the ISAP to train and
, certify the project QC inspectors.have'been completed, NRC inspection
'of.this activity-is complet No , violations or deviations were identifie E' Repair of Adjacent Splices (NRC Reference No.- 01.a.03.05)
'
~
.. The requirement that any splices found during ISAP I.a.2, Phase II
inspections, which are adjacent to and pressing upon one another, be repaired has been deleted from this ISAP by an Action Plan Change , Request (APCR) dated April 16, 198 Review of the APCR shows that
'all inspection / documentation review activities for splices will be included in~ISAP I.a.2.. Therefore, no action is now required for this activity under the ISAP and NRC inspection for this activity is complet No violation's or deviations were identifie Data Qualification Package'(NRC Reference No. 01.a.03.06)- 'The NRC~ inspectors verified that a data qualification package, which consisted of AMP's Equipment Qualification Report 110-11004, Revision A,.and TUGCo's Equipment Qualification Review Report TNE-DC-15.la, had been prepared.' The TUGCo report is not included in the ISAP working file, but is in TUGCo's TNE Equipment Qualification Group's files. The compilation of the required data completed the CPRT required action for this activity; therefore, NRC inspection of this activity is complet No violations or deviations were identifie Third Party Review of Data (NRC Reference No. 01.a.03.07) '
The NRC inspector verified that the data qualification package was reviewed by a third party engineer for compliance to the following equipment qualification standards: IEEE Std.' 383-1974 4 / NRC Reg. Guide 1.131 G&H Electrical Specification 2323-ES-100, Revision 2 IEEE Std. 323-1974 The third party engineering review report of the data qualification package for PIES splices stated that the splices were qualified for the service requirements at CPSES. The completion of the third party review fulfilled the ISAP requirements; therefore, NRC inspection of this cctivity is complet No violations or deviations were identifie _
'
_ _ _ ______ ._ _ __ _ _
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fr m Replacement'of-Unqualified Splices-(NRC Reference No. 01.a.03._03J
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.
e - LSincePIES. splices-[havebeendeterminedbyboth'CPRTiandTUGCo' f, '
-personnel to be qualified.1no splice' replacement is required per this f ~ s ISAP. nTherefore, no actionis,. required and NRC. inspection of this
'
,
~
J - activity is complet ~~'~
-
"' ~~
.
~No violations:or deviations were identifie ,
"
~ >
. Root-CauseandCorrectiveAction(NRCR'eferenceNo.01.a;03.09}
'
. ,
The;ISAP required that'"the results of the: actions.under this' plan
:were to be evaluated to establish root causes and to. identify _
+
. appropriate corrective action,'if required." fAs stated in the
- ~
. 'results report (RR) dated April 29, 1986, for this ISAP, no safety-significant deficiency was' identified; therefore,'no root
-
' '
~
cause or generic _ implication evaluations were conducte Based on
.the NRC inspector review of the various activities of this ISAP, no basis was found to disagree with the above determinatio '
. 'Since the CPRT determined lthat a root cause evaluation was not required, the' requirements of this activity are moot and NRC
. inspection is complete.
. Agreement Between Drawings and Field Terminations (ISAP I.a.4)
..._
The NRC, inspectors reviewed the CPRT files to evaluate the sample
. selection process and the. inspection activities as well as the
_ '
^
results of these. activities. The NRC inspectors also performed inspections to evaluate the agreement between drawings and field termination Establish Sample Plan (NRC Reference No. 01.a.04.01)
-
.
-
Section '4.1.1, " Inspection Prograin," of CPRT ISAP I.a.4, " Agreement
,' '
between Drawings ~and Field Terminations," Revision 4, dated
. January 24, 1986, states "An inspection program employing random sampling will be initiated which will enable a determination to be made with reasonable assurance of whether the essential Class 1E *
conductors in the control room and cable spreading room which interface with the Alternate Shutdown Panel are terminated in accordance with the applicable drawings." Paragraph 4.1.1.2, " Random
- . _ Sampling," of this ISAP states, in part, " Based on the preliminary determination of a population size of 3812, the minimum sample size
'
according to Appendix D is 300 with-a rejection number of zero . . . ." Although the initial field inspections were conducted prior to Revision 1 of Appendix 0 to the CPRT Program Plan, the NRC inspector verified that the sample size was determined in accordance with the requirements and procedures outlined in Appendix D. The NRC
r we :
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mP ' ' l inspector (also verified that: sample ~ size determination of, subsequent _ <
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inspections was injaccordance with: Appendix D. 'The population size
,1 , ; ;was.. verified to:have teen established by a" review of applicable ' '
u. T
'
ischematic . diagrams:and' panel wiring ~~ diagrams by TNE personne '
' 7 - f Although the- population. identification.(list of/ cables) was provided '
~ .
- < lby_the. applicant, the NRC inspector determined that third party Ng -
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.-l independence was maintained through CPRT compliance with Appendix D;
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'i.e.,*the;actualLconductors-to be inspected were determined on a=
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statistica1Lbasi y ,
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m; '4 m# s . . iThe'NRCJinspector did not 7 identify' deficiencies in the establishment k4
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of:the; sampling; plan; however,'the identification of the individual
'N ^ icablesland conductors to be included in the sample,did not appear to- . , ' gomply with'the ISAP requirements. 'Specif,1cally.iof the1338' ;u -
J conductors selected for inspection. in accordance. with, Appendix'D,
-p r approximate 1y'50.were " spare" conductors which werefnot-terminated.'
"?, 1As. stated'above,-the conductors to beLinspected,were(to be -
~" essential" conductors for. safe shutdown. Spareiconductors,do not '
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f . satisfy this criteria 'and this ~1 tem has been identified as 'a wP
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deviation (445/8607_-D-19).,
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,It?should be noted-that after identification of'this item by the NRC
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inspectorf theCPRT..: inspected an. additional 34 functioning
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conductors, ~ selected in accordance.with' Appendix D, to,en.sure"thate
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Lthe required sample size consisted of " functioning"s conduc or ,
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Sinc'e the NRC inspector' verified thatithe sample selection was-
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_ accomplished inLaccordan'ce with the ISAP~ requirements, except as
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> inoted above, NRC inspection of this activity is complete. The NRC ~
, . inspector will follow up on'the applicant actions taken in response '
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' to.. deviation 445/8607-D-1 .~
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Inspection of Terminations.to Design Drawings (NRC Reference N m ,y M f . 01.a.04.02)
'
- , ' Review of ERC Inspections
- .:: ~
~ _ The NRCLinspector. verified that the inspections performed by ERC P, . personnel were ,n accordance with QI-001, " Procedure for Class 1E
, ; <
o Cable Terminations' Inspection - CPRT Action Item I.a.4," Revision 3 "
' dated December 28, 1984. No special qualifications were required of ~ ~
the. inspectors in tha.t termination point and conductor n, ,
.. identifications were the-only attributes requiring inspection. The
, , , inspection attributes of QI-001 were verified by the NRC inspector to
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tsatisfy the requirements of the ISAP.
7, . Review of the-CPRT inspection reports disclosed that the ERC L ~" ' _ inspection personnel identified 31 " unsatisfactory" items relative to
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t agreement between drawings and the "as-built" configuration. A discussion of the resolution and analysis of these findings is
.
L - - contained in the following section.
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i ? NRC Inspections for ISAP I. ' ~
. The NRC inspectors performed an inspection during April' 21, 1986, - . . _
through April 24, 1986,_of all terminations in five control room and two' cable: spreading room. panels in Unit 1. The drawings utilized and
>'
1 . the panels inspected were: . 2323-El-0107, Revision CP-1, " Solid State 4 Protection. System Train 'A' Output Cabinet No'.' 2"; 2323-El-0112, ~~
'* , ~
Revision CP-4, " Solid State Protection System Train 'B' Output
:
Cabinet No.' 1";'2323-El-0139, Revision CP.-3,." Solid state' Safeguards
. Sequencer Cabinet A";.2323-El-0156, Revision CP-7, " Balance of Plant
'
- Auxiliary Relay Rack Nc. 2"; 2323-El-0171-03, Revision CP-6, " Main
- Control Board"; 2323-El_0172-17, Revision CP-4, " Termination Rack
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? s LECPRTC-17"; Land 2323-El-0172-41, Revision CP-4, " Termination Rac !ECPRTC-41."'.These inspections resulted in the identification of 52
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" unsatisfactory" items by the NRC inspectors. Discussion of the
,
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: resolution and: analysis of these findings is also contained in the following sectio :During the inspection performed by the NRC inspectors, it was identified that except for TB-53, 54, and 55, all of the terminal
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. , 'n blocks in panel CP1-ECPRCR-01, were not identifie A review of '
7 Drawing 2462-1005, sheet 1, Revision CP-1, showed that identification
~'y is required. adjacent'to the components. The failure of the applicant 9 to follow drawing instructions / requirements is a violation of 1s
"
. Criterion _V..of Appendix B to 10 CFR.Part 50 (445/8607-V-20). It
- should be noted that, upon identification of this out-of-scope
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finding by the.NRC' inspector, the applicant initiated NCR E86-101727
- to resolve this issu Related Inspection Activities The NRC inspectors also conducted an inspection of the disposition of
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. the'out-of-scope findings germane to ISAP I.a.4, which were
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- . documented during the CPRT ISAP I.a.2 inspections. An inspection of
- Unit 1 Cable Spreading Room, Termination Cabinet No. 42 (CPI-ECPRTC-42) showed that the appropriate drawing had been updated to incorporate a completed design change; however, the inspection
- also disclosed a lugged, but unterminated, white conductor, labeled
! - EG123389, near the No. 4 terminal board. The conductor did not have ! electrical tape covering the ring-tongue terminal lug, nor was the , conductor tagged to indicate the purpose for its not being connected to the appropriate terminal strip.
- -
i- The NRC inspector discussed this situation with the applicant's QE representatives to determine the purpose of the unterminated Lt conductor and if records existed to explain why it had been disconnected. The applicant subsequently issued NCR E86-102070 dated May 15, 1936, to evaluate the proble The conductor was determined to be an electrical lead to the limit [ switch on the Safety Injection System to Hot Leg Loops 1 and 4,
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i G- . p r 33 p_ Containraent Isolation Valve MOV 1-8802 The limit switch provides the. control room with valve open indication. The applicant had not,
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las 'of. the end of this report period, provided an explanation on how or why this conductor was disconnecte In addition, while evaluating the above condition, the NRC inspector was informed that a similar condition had been discovered during the-CPRT inspections required by ISAP I.a.2. . The conductor was
> identified as EG106004(B) located in Unit 1 Relay Rack No. 2; it was subsequently reconnected.but remained an open item in the CPRT '
tracking system as of the end of,this. report period. This failure to
. control modifications is a violation of Criterion V of Appendix B to 10 CFR Part 50 (445/8607-V-21).
Conclusion
': .Since the NRC inspector.has verified that the ISAP required inspections have been performed and documented by the ERC inspectors, the NRC inspection of this activity is complete. The NRC inspector will report on the applicant actions in response to violations (445/8607-V-20'and 445/8607-V-21) in a subsequent repor Reconciliation of Differences with Drawings (NRC Reference N .a.04.03)
Review of Inspection Finding Dispositioning a Paragraph 4.5.1, " Inspections," of the ISAP states, in part, "The acceptance criterion for the termination inspection is that either:
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The termination is physically in agreement with the drawing . . .
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The termination is not in agreement with the drawing but is functionally correct . . . ." Paragraph 4.3.3 of QI-001, Revision 3, states, in part, "The shall be reviewed for legibility, accuracy aad completeness and approved by the ERC Level III. The completed I.R. shall be submitted to the Electrical / Instrumentation Review Team Leader for review / approval of satisfactory items and for evaluation referral of unsatisfactory items to TUGCo Nuclear Engineering (TNE) for disposition."
The NRC inspector observed that the following unsatisfactory items were referred to TNE for disposition:
. For samples 234, 295, and 151, the drawing and tha field
, installation showed the cables to be E0110638, E0110631, and l E0110630 in lieu of EG110638, EG110631 and EG11063 _
- _ . .. . . . . . .. _ .. .. .. . . . . . . . . . . _ _ _ .
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. For sample 337, the blue coiductor of cable EG113293 appeared to be greenish gray. The inspector remarked that it was indeterminate as to colo g . For sample 290, the blue conductor appeared to be greenish gra . For sample 192, cable EG120248 was incorrectly shown on the drawing as cable EG2024 For sample 56, cable EG145725 was incorrectly tagged as cable EC14572 ( -
Conductors were not terminated in accordance with the current - design drawings. The conductors were landt.! on poin' that the -
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drawings showed to be vacan Of the 31 unsatisfactory items identified by CPRT, 23 pertained to : spare conductors. The conditions identified included: conductors il$jf not landed per the drawing and not tagged; conductors not pl.ysically " tagged; conductors not present; conductors retired inside a wireway and therefore, not accessible; and conductors landed but not shown on N< the drawings. Of the approximately 50 unsatisfactory items identified by the NRC inspection, 30 were related to spared conductors. The response to these findings by THE was that there are no site or procedural requirements to either tag spare conductors, or to show them on interconnection drawings. During these inspections, similar conditions were identified relating to jumper wirin Review of Drawing and Design Change Controls ' In addition to the conditions stated above, the NRC inspector also found that: (1) drawings may be revised by THE and issued plant wide [ with the actual work accomplished at a later date; or (2) an ,. Engineering Change Notice (ECN) may be issued by TNE to the . Operations Department (at their request) with the work tracked ana performed by Operations (Maintenance and Operations Support
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Departments). The drawings are then updated and issued by TNE aftei - being notified by Operations of the completion of the wor The various methods of drawing revision appeared to the NRC inspector to . be directly related to design control at CPSE To assess this area, g _ the NRC inspector began a review of numerous design modification control procedure i Initial review by the NRC inspector indicated that the design change ; process was quite complex as result of the number of organizations s involved, the use of differen change mechanisms, and the numerous I interfaces. Additional review of this process was performed by the ! Senior Resident Reactor Inspector, Operations, the results of which are documented in NRC Ir.spection Report 50-445/86-09; 50-446/86-0 _
.
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R'eview of Reconcilia' t ion'of Differences with Drawings
^
During-tne NRC inspector's review of-the THE response to unsatisfactory items identified during the NRC inspections, it was observed that drafting errors were involved on two of seven drawings utilized by the NRC inspectors. Paragraph 2.1.3 of THE
' Procedure TNE-DC-7, Revision 16, dated' February 14, 1986, - , " Preparation and Rev_iew of Design Drawings," states , in part, " . . . completed drawings shall be checked for accuracy and compliance . . . ." . Paragraph 2.1.4 of this procedure also requires an engineering review for technical accuracy upon completion of the drafting / design check. Although it cannot be stated that the . required reviews / checks were not performed, it was apparent that the drawings were not appropriately reviewed / checked for accuracy'as indicated by the following NRC inspection findings:
_( 1)
' Drawing 2323-El-0156, Revision CP-7, showed the green conductor of cable EG118347 landed at terminal block TCA, point 5; the conductor. physically installed was white with a black strip This drawing also showed the orange conductor of cable EG130012 landed at TCA-7; the conductor physically installed was the biack conductor of cable EG118347A. The drawing was not " clouded"'to indicate that this was a design chang ~(2) Drawing.2323-El-0172,' sheet 17, Revision CP-4, did not identify-the color of the conductor to be landed at terminal block TB-2, point 31; ,
The following additional findings were identified during the NRC inspector review of CPRT's inspection per QI-001:
(1) . Drawing 2323-El-0172, sheet 17, Revision' CP-4, identified cable EG120248 as EG2024 ~(2) Drawing 2323-El-0156, Revision CP-1, did not show the physically terminated white conductors of cables EG109964, EG109975, EG109963, and EG10976 The lack of appropriate reviews / checks of drawings by the applicant .is a violation of Criterion V of Appendix B to 10 CFR Part 50 (445/8607-V-22).
The NRC inspector, however, did not identify any instances in which the ERC inspection of sampled terminations disclosed a deficiency as defined in the ISAP. Therefore, NRC inspection of this activity is complet Root Cause and Corrective Action (NRC Reference No. 01.a.04.04)
. The CPRT results report for ISAP I.a.4, Revision 1, dated March 13, 1986, paragraph 5.4, " Root Cause and Generic Implications," states, i
I
. _ _ _ _ _ _ _ _ _ . - _ _ ,
_
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"Since the activities carried out during the implementation of this action plan did not reveal any deficiencies, neither a root cause nor a generic implications evaluation is necessary."
NRC Inspector Review of the Results Report for ISAP I. i The ISAP I.a.4 Results Report, Revision 1, dated March 13, 1986, was transmitted to the NRC by TUGCo letter dated April 4, 198 The NRC inspector review of the RR disclosed that only limited mention was made of the unsatisfactory findings from the ERC ISAP I.a.4 inspections and the germane 'indings from ERC inspections for ISAP I.a.2. The unsatisfactory findings from the I. ' inspections were discussed under NRC Reference No. 01.a.04.02, abov NRC inspector review of the CPRT files for ISAP I.a.2 disclosed the following findings which relate to this ISAP: ,. Drawing Conductor Unsatisfactory Item jgg 2323-El-0156, EG106004-black conductor lugged but CP-7 not landed 2323-El-0159, EG145739-blue green conductor spliced
'
to blue conductor 2323-El-0172-42, EG016578-white & drawing deleted these CP-2 black terminations which were connected EG118297-black conductors tagged as
& white E0118297 2323-El-0172-41, E0016586-black deleted on drawing but CP-3 & white physically landed SP119728-white and cables not shown on
' SP119730-white the drawing E0119690 green conductors not shown
& red on the drawing
.
2323-El-0160, E0118484-blue gray-black spliced to L CP-8 -black blue-black 2323-El-0150, A0016200-black gray spliced to black : CP-8 2323-El-0155, E0146397-white gray spliced to white CP-6 E0146450-white gray spliced to white
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The NRC. inspector did not, however,. identify any deficiency which
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would alter the conclusion stated in the RR. Therefore, NRC
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inspection of this ISAP activity is complet , d.L ;QC Insoector Qualifications (ISAP I.d.1) During this1 reporting period, the ISAP activities identified by NRC'
' Reference Nos.-_01.d.01.03 and 01.d.0LO6 were inspecte . ' ~ SET-Evaluation of ASME and non-ASME Inspector Qualifications (NRC Reference No. 01.d.01.03).
-
~During this reporting period, the NRC inspector reviewed ten inspector qualification files from the ASME group. The ASME group
, . ;had previously been evaluated by the QA/QC Review Team with the stesult that of 72 ASME related inspectors, 3 shall have their qualifications further evaluated under Phase III of this ISA A
-
; fourth . inspector, whose. qualifications had been questioned by the
. SET, was reviewed and accepted by the QA/QC Review Team. The reasons for.this acceptance were documented on ERC Memo QA/QC-RT-179 The NRC inspector reviewed ten qualification files from those inspectors found acceptable by ERC. The files were reviewed to establish acceptable verified education and experience levels, acceptable examination scores, required reading and indoctrination completed, sufficient on job training (0JT), completed technical
~ training outline, and passing eye examination. The results of the
, NRC-inspector's review were in agreement with results of the ERC review;
,
No violations or deviations were identifie ' _3 Further NRC inspections are planned for non-ASME inspector qualification , Evaluation of Results (NRC Reference No. 01.d.01.06) The NRC-inspector reviewed the Comanche Peak. Project Procedure Manual for the procedures that required the results of I.d.1 to be factored into the collective evaluation of the construction QA/QC program, and the collective evaluation of the quality of ccnstructio The procedures which provide this requirement and the details by which it is to be achieved are CPP-013, Revision 1, " Collective Evaluation of the Quality'of Construction," and CPP-014, Revision 2, " Collective Evaluation of Construction QA/QC Program." These procedures require the QA/QC review team to evaluate the results report from ISAP I. and to factor its results into the collective evaluation program NRC inspection of the collective evaluation programs will be reported under a separate headin .
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. * ' 'No further NRC inspection"is pl'nned a for this ite No violations or deviations were identifie Maintenance of Air-Gap Between Concrete Structures (ISAP II.c)
LThe following activities for ISAP II.c were reviewed by the NRC
: inspector during this report period: .
Removal of Debris or Rotofoam (NRC Reference No. 02.c.02.00)
.The NRC inspector has witnessed cleaning and repair of both single and. double walled gaps on numerous occasions. This includes witnessing the use of a variety of tools used for debris removal and a review of the overall proces During this report period, the NRC inspector observed air gap cleaning along; (1) the LA-AF wall gap between the auxiliary building , and the fuel. building, (2) the gap between Unit 1 reactor building and.the fuel building, and (3) the gap between Unit 1 reactor '
building and the auxiliary building. Activities were observed primarily by using remote video equipmen The NRC inspector observed the test of a' high pressure water jet system, " hydro-laser", operated by Hydro Nuclear Systems. Actual
. conditions in the building air gaps were simulated by placing
. 5000 psi strength concrete in a gap formed by two large concrete blocks placed 2 inches apart. The concrete was allowed to cure for approximately 7 days. The water jet used had a nozzle pressure of approximately 10,000 psi at 22 gpm. No damage occurred to the side
. walls when the concrete in the gap was' remove ~ > .The NRC inspector witnessed the use of the hydro-laser system for concrete removal at the 3A line along the LA-AF wall. A vacuum system was used for debris and water removal. An air arc system was used to cut an angle, approximately 2x2x1/4" to allow for remova No apparent damage to the side walls of the gap was observed during inspectio NRC inspections will continue during subsequent report period , ,
No violations or deviations were identifie Analyze Final As-Built Condition (NRC Reference No. 02.c.03.00) The NRC inspector reviewed G&H Calculation LIS-100c, Set 19, "Effect of elastic joint filler or fire seal at top of secondary walls during a seismic event." The methodology and assumptions used were found to be in agreement with the design commitments contained in Section :
, - - " , - , . . . .-. - - - - .
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,-r "4 39 { of the Comanche. Peak FSAR.' Numerical calcul'ations were spot checked for accuracy. No numerical errors were discovere Additional review will be performed during a subsequent inspectio ;No violations or deviations were identifie Joint Test Group (JTG) Approval'of Test Data (ISAP III.a.2)
'
The NRC inspector reviewed the; central file containing documentation in support of' actions taken under ISAP III.a.2. Tne followup inspec-tion of this ISAP was~ closed in NRC Inspection Report 50-445/85-16,.
-dated April 4, 1986; however,'a statement has since been added to the
'M- file indicating that no results report will be issued. (Similar
~
statements were found in the files for ISAPs III.a.3 and III.b)
-Failure to do-so would be a deviation from the CPRT Program Plan, Section VI which states, "Each ISAP and each DSAP will-produce a results report."' _When questioned about these statements, the CP(P -
_
-Program Director stated that the statements were in error and that r'esults reports would be issued for each of_these ISAPs. The CPRT Test Programs-Team Leader stated that the erroneous statements were subsequently removed from the file This ISAP is closed pending NRC staff acceptance of the results '
report.- Containment Integrated Leak Rate Test (CILRT) (ISAP III.b) Revision 3 of ISAP III.b contained commitments that were not included in Revision 4. When questioned by the NRC inspector, the CPRT-indicated that the items were completed, and thus, it was moot to commit to actions already completed and followup inspected by the NR This practice is acceptable, because the NRC inspector compared all revisions of the Test Program ISAPs to ensure previously committed actions were carried forward and/or continued to be tracked by the NRC staff. Thus, all previous and current commitments have o been, or will be verified complete by review of documentation in the central files maintained by the CPR In ISAP III.b, Revision 3,-Section 4.1.1, the CPRT committed to compare the FSAR and ANSI N45.4-1972 with CILRT Procedure 1CP-PT-75-02 to identify any differences, other than the calculation method, that may have been caused by the unauthorized use of ANSI /ANS 56.8-1981. The NRC inspector verified by review of documentation that the review was satisfactorily conducted and evaluated by the JTG. This issue is close In ISAP III.b, Revision 3, Section 4.1.2, the CPRT committed to respond to the NRC letter dated August 27, 1984, from NRR to the applicant, which requested additional information on the CILRT conducted on CPSES Unit 1. The NRC inspector verified by review of documentation that the respanse was transmitted to NRR on
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) December l21,1984.-NRRacceptanceoftheresponseis'documentedin CPSES Supplemental Safety Evaluation-Report No. 12 dated October 1985
,
-(SSER-12). This: issue is close ,
m !In ISAP III.b, Revision 3, Section 4.1.3, the CPRT committed to
'
: conduct evaluations to determine whether,PT procedures were designed
=
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-and performed in a manner-which complies with FSAR commitment x .Section-4.1.4 addressed.an evaluation of administrative controls and
procedures utilized at CPSES on the same subject. Sections-4.1.5 and
, '4.1.6 committed to expansion of the reviews if programmatic
. deficiencies or FSAR deviations were found during performance of
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-Sections 4.1.3 and 4.1.4, respectively. All of the above was deleted iby ISAP.'III.b, Revision'4, and moved.to ISAP III.a.1, Revision Actions taken will be inspected concurrent with ISAP III.a.1 followup reviews by the NRC staff.- For tracking purposes, this is an open item (445/8607-0-23).
In ISAP.III.b, Revision 4, the CPRT indicated that, based on NRC acceptance of the CILRT.as. documented in SSER-12, TRT concerns with CILRT methodology had been resolve '
.
Based on a satisfactory review of supporting documentation and the transfer'of FSAR commitment review to ISAP III.a.1, this ISAP is closed pending-staff acceptance of the results repor Nonconformance and Corrective Action Systems (ISAP VII.a.2.) ! During this report period, the ISAP activities identified by NRC Reference No. 07.a.02.06 were inspected as follows: i Review of CAR Implementation (NRC Reference No. 07.a.02.06)
, -_To assess the adequacy of the ERC review, the NRC inspector reviewed
'six TUGCo and six B&R CARS that had been previously reviewed by ER l
- This review was conducted using the ERC prepared checklist. The NRC i j inspector found no discrepancies in the ERC review. During !
' performance of the NRC review, it was noted that documentation ; supporting closure or verification of corrective. action completion - was not always included in the CAR packag Subsequently, the NRC inspector reviewed four CARS for this attribute since it was not included specifically in the ERC checklist. The four CARS were
. chosen because each referred to corrective action not supported by
documentation within the CAR package. It was found that, CAR-049, r was closed before corrective acticn was completed, which is not in ! compliance with procedural requirements. This is considered a violation (445/8607-V-24).
The ERC review of CARS is similar to its review of NCRs, except a L . technical review of the adequacy of the disposition as implemented is $ ' being performed for NCRs. In view of the above violation and noted similarity between the two systems, an evaluation of the adequacy of , .
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CAR' dispositions and implementations of corrective action may be t
, , . desirableL This. subject is considered an open. item (445/8607-0-25).
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t . Audit Program-and Auditor Qualifications-(ISAP'VII.a.4) ' T* , - 1 -
. . . . .-
. . . . - .
, i . :During this-report period,.the ISAP activities identified by NRC f Reference No. 07.a.04.02 were inspe,cted as follows:
~
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_~ = Review of Documentation-Related to QA Audit Program (NRC Reference
~ * -
No. 07.a.04.02).
( ' ;" ,
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TheNRC: inspector.. reviewed 27. audit [filesandbackupdocumentation~
;from the Dallas Audit Group's files. This review was iniaddition to ,
the 12 audit files previously-reviewed in January. The reviews were
~
-conducted to establish a basis for verification of~ERC. review- .
,
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fresults. Items inspected were audit: planning,-audit scheduling,
:
- . ~ ' audit plans and checklists', audit reports, ~ audit deficiency followup,
. audit team makeup, auditor-qualifications, and audit coverage of
'
vendor I Following review of: the audit files, the' NRC inspector . inspected the
.
fresults of'the.ERC review ~of' planning and scheduling for~TUGCo s ' internal' audits. 'The NRC inspecter found audit scheduling to have n . .been performed-from the.beginning of the internal. audit program. A ,
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calendar matrix of internal audits, training schedules, and vacation r sche'dules was.used in the early audit program. . This finding agrees Ewith the ERC' review results.~ The planning'was deficient in its
'
; commitments to ANSI N45.2.12, Draft 3, Revision 0, 1973, because it failed to. provide information to assure all elements of the QA
{ program were audited to an adequate depth, nor did the audit planning _
,
11dentify all-activities requiring auditing. This area-has been - previously. inspected ~and reported.in NRC Inspection !' Report 50-445/86-03; 50-446/86-02 ao an open item.
h_ p The NRC inspector also inspected the results of the ERC review of audit. plans and checklists for internal audits. The NRC inspector found from review of audit files that the scope of the audit plans l was not well defined during the early years of the internal audit p- . program.- The checklists were prepared from the procedures ' controlling the activity being audited; however, no attempt was made l . to' assess if applicable QA program commitments were included in the procedure. Audit plans and checklists reviewed for 1985 do reference 'l' the higher tier documents and indicate what criteria from 10 CFR Part 50, Appendix B, are. applicable to the performance of the audi Results of the NRC inspection agreed with the results of the ERC
. review in this' are The NRC review of audit performance substantiated the ERC review '
results, in that audit checklists were prepared for each audit,
.
n i objective evidence was reviewed to establish compliance, pre and lm postaudit meetings were conducted, audit deficiencies were documented
and submitted to the audited organization.
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, V NRC review of:a concern regarding TUGCo's' use of an acting team leader.found that in all-audits reviewed a qualified lead auditor ,
participated. During NRC. interviews,. audit personnel indicated that 1 p the qualified lead auditor would overview the activities of the
:Y acting team leader, this being a learning experience prior to being *
certified as~a. lead. auditor. This appraisal is in agreement with the
- ~res41ts of.the ERC revie . NRC. review of audit deficiency followup found that deficiencies were < :P identified in the audit reports and copies issued to the audited , ' organization. . When responses from the audited organization were not-received in the time specified, letters of " overdue response" were sent in accordance with procedural requirements. However, verification of corrective action implementation often did not take ' place for 6 months to a year after the report was first issued. This finding is in agreement with the ERC revie It should be noted'that TUGCo QA attempted to address the problem of closere verification by issuing specific audits, such as TCP-111, " Closeout of Open_ Construction Audit Findings," conducted in 198 TUGCo is continuing to reduce the. tine required to verify implementation of corrective action. One action being taken is the , relocation of the Dallas audit group to the Comanche Peak site, which
should increase auditor awareness of site QA status and reduce the O amount of time required for verification of corrective actio '
'
The qualifications of current auditors were reported in NRC Inspection Report 50-445/86-01; and 50-446/86-01. The qualifications of historic auditors were reviewed by the NRC inspector during this reporting period. Results of this review agreed with the ERC review results, in that, the Dailas audit files contained documentation _ appropriate to commitments at the time of certification (ANSI N45.2.12, 1973, Draft 3, Revision 0, prior to June 1, 1983; and ANSI i:45.2.23,11978, after June 1, 1983).
No violations or deviations were identified. Except for followup of
, the identified open items,_no further NRC inspection is planned f this are . Housekeeping and System Cleanliness (ISAP VII.a.7)
During this reporting period, the ISAP activities identified by NRC Reference Nos. 07.a.07.04 and 07.a.07.05 were inspected as follows: ERC Overview of Plant Surveillances (NRC Reference No. 07.a.07.04) The NRC inspector has accompanied ERC in their overview of two TUGCo plant surveillances in the safeguards building, Unit 2 reactor area, the millwright shop, paint shop, electrical warehouse, and electrical and mechanical laydown areas. To assess the implementation of ERC overview in areas not accompanied by the NRC inspector, the notes and
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recorded data from these ERC overviews were inspected. The NRC Linspector determined that these overviews by ERC were accomplished in accordance with subparagraph 4.-l.2.4 of this ISA No violations or'.' deviations were identified and no further NRC
[inspectionis_plannedforthisreferenceare ' : Review of-Documentation on Housekeeping (NRC Reference N , 07.a.07.05)
During this reporting period, the NRC inspector redewed ' documentation' utilized by ERC to assess the effectiveness of the current:TUCCo housekeeping and system cleanliness progra All of the.ERC notes and data sheets for this activity were reviewe .
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Additionally,:the following documentation was reviewed in depth: B&R audits CP-16,'CP-17, and CP-18; B&R CAR-35; TUGCo surveillance reports C-85-007, C-85-021, C-85-036, C-85-032, C-85-047, S-85-048, and S-85-016; flush plans FP-56-09, FP-55-02, and FP-55-08; and swipe tests J-198 and J-24 :This documentation showed that housekeeping and system cleanliness for the current program are surveilled frequently and that deficiencies noted are properly documented. The present surveillanc " program requires surveillances to be performed at the determination ofthe'surveillancesupervisorinresponsetositeactgvities, previously identified areas of deficiencies, and the Project Trend
.; Report.- The results of the NRC review agreed with the notes and data sheets of ERC's reviews of performanc ERC's assessment of -
effect.iveness of the program will be in the results repor No further NRC inspection activity is planned for this ite No violations or deviations were identifie Receipt and Storage of Purchased Material and Equipment (ISAP VII.a.9) During'this report period, ISAP VII.a.9, Revision 0, was forwarded to the NRC for staff review. As a result of NRC concerns regarding the scope of the ISAF, inspection of implementation has been deferred until after issue of a staff respons . Valve Disassembly (ISAP VII.b.2) Review Construction and QC Procedures to Determine if They Provide Adequate Controls of Materials During Disassembly / Reassembly (NRC Reference No. 07.b.02.03) The CPRT, by virtue of the issuance of the Results Report, Revision 1 on April 3,1986, has completed all planned work on the subject LiAP.
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K2 ' Np% M - ;Section 3.14 of ProcedureCP-CPM-6.9E, Revision 5, clearly defines upp . - ' iwhatlactions1and' precautions should be taken by the Mechanical AW # < ESuperintendent when disassembly or reassembly l of valves occurs. When
:Designichange Notice (DCN) No. 3.was issuad on January 28(1983,
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:SectionT3.14Jwas Tchanged to read, "The Mechanical Superintendent (MS)-
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'W . : Procedure CPM-9.18." Procedure CPM-9.18 was approyed'on: June;7, .
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l, procedure in existence between January and June '1983 1sla deviation " , 'M i t -(445/8607-D-26).^ '
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.With[ respect to storage of valve parts, the present A ' Procedure ~CP-CPM-9.18, Revision 0, states the following, " Valve
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parts shall be packaged-and identified with the ' valve number to
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NRC in'spections of the Millwright shop, Warehouse C, and Unit N m , i reactor buildingLindicated that this procedure is being adhered to at ,
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. -Improperly Assembled Valves-(NRC Reference No. 07.b.02.03)- (1) . The- results report states, "While the potential for switching -
non-ASME and ASME Code class bonnets did nxist, there'is no implication that switching of non-ASME and ASME valve bonnets
, , could be safety-significant."
In that-CPRT has identified a potential for switching non-ASME
' ;and ASME Code class bonnets, the NRC raised the question as to " -
how'the results report considered the differences between non-ASME and ASME Code requirements-with respect to material identification and traceability, welding and weld repairs, p" - ^ nondestructive' examinations, and personnel qualifications. As of the.end of this reporting' period, the NRC has not received a satisfactory' response from CPRT. This subject is an unresolved item (445/8607-0-27) pending receipt of additional information _ from the applican (2) The CPRT issued DRs on Valve Nos. XSF-179 and 1-7046 stating
.that valve bonnet identification numbers did not match up with the numbers specified on the ITT Grinnell NPV-1 form. The , .
results report stated that even though documentation was not
.found to identify the pressure / temperature rating and code class of inaailed bonnet, markings stamped on the bonnet verified it as an ASME code class component. The bonnet, therefore, must be equal.to or better than the required ASME Code Class 3 bonne > <
The results report ~does not, however, address what other ramifications may result from the fact that the NPV-1 Data
- . Report is not consistent with the installed bonnet. This subject is an unresolved item pending additional NRC review (445/8607-U-28). .
6. Construction Reinspection / Documentation Review Plan (ISAP VII.c) Electrical Equipment Status of CPRT Activity
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ERC has completed 79 reinspections and 83 documentation review , packages of sampled electrical equipment as of May 31, 198 Status of NRC Activity
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The NRC inspectors have, as of May 31, 1986, witnessed 14 ERC reinspections, conducted 5 independent inspections, and performed 15 documentation reviews of sampled electrical equipment. These totals remain unchanged from the previously reported total A question was raised about the seismic mounting / restraints of MCCs 1EB3-2 and 1EB4-2. These two MCCs were not part of the sample p l _
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to be inspected by ER ' Inspection showed that the MCCs were
- - ^L 1 attached to two steel plates embedde.d in the floor and that no other mechanical attachments' existed. A review of the design documents and - . equipment qualification review repoics showed that these MCCs were installed as designed and that the design meets. seismic requirement The NRC' inspector had no further questions in.this are Structural Steel-Status of CPRT' Activity Reinspection of structural steel is.approximately 80% complete with l110 of an estimated total of 138 packages reinspected. ERC has
< identified 278 deviations and processed 262 for validity. To date, ! 234 or approximately 90 percent have been determined to be vali : Attributes with 10 or more valid deviations included (1) member location, (2) location of connections, (3) size of connections, '
~ (4) weld size, (5) structural bolting material, (6) bolt hole coverage, (7) bolt / nut tightening,-and (8) bearing between bolt head / nut and outer. connecting plies. Valid ' deviations are currently being evaluated for adverse trends and safety significance. ERC inspectors have reported out-of-scope observations to TUGCo regarding this population, including numerous observations of deficiencies in (1) a platform in Room 153 beneath the Unit I reactor vessel, x~~ (2) monorail supports and base plates, and (3) a jet protection structure in Room 113 associated with a steam generator blow down ' heat exchanger in Unit 1- .
Documentation review is approximately 65 percent complete with 90 packages reinspected. A total of 106 valid deviations have been
. identi fied. An additional 30 verification packages from the sample cannot be reviewed at this time due_to the fact that the original construction and inspection records have not been locate Status of NRC Inspection Activity ~(1) The NRC inspector has previously witnessed nine reinspection In addition, the following four structural steel members were ,
independently inspected by the NRC inspector during this report period: Verification Equipment N Building Unit Package N No.
1 I-S-STEL-140 MK C9-22 Auxiliary 1 (MAB-0799-0C5,SH1) I-S-STEL-146 MK C9-4 Auxiliary 1 (MAB-0799-0C7)
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, ?T .I-S-STEL-197 MK B176-1-SA- Safeguards 1-(2) During the prior ERCLreinspections, the following conditions were identified as subject to evaluation as potential .
deviations: I-S-STEL-140: Member location was out of tolerance and some Twelds;were undersize I-S-STEL-146: . Member location was out of tolerance, some welds-were undersized, and all A-490 bolts lacked required washers '
.under the bolt head w I-S-STEL-164: .Some welds were undersized, weld undercut was - excessive.for at least three locations, alterations were ~
identified that.were not on the design drawings, bolt material was not as specified on the design drawings, and the location of field installed associated details was out of toleranc I-S-STEL-197: Excess gap between the base plate and concrete was identified, and member location was out of toleranc .
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Dispositions of the above findings are open items (445/8607-0-29
;_ through 445/8607-0-32).
(3) During the independent inspection of Verification
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Revision 3, plate C10-17 is to be installed at the top of member C9- As-built, plate C10-17 was installed at the base of member C9- In addition, angle C9-33 and a second gusset plate at the opposite end of C9-33 were installed incorrectl A similar assembly located approximately 5 1/2' north of the above assembly was also installed incorrectly. Orientation of connections is delineated as Attribute B3 of QI-045, Revisions 1 and Connection orientation was accepted by the ERC inspector and no out-of-scope observations were reported. Acceptance of this condition is a deviation (445/8607-D-14).
NRC is deferring further inspection in the area of structural steel pending a response from the applicant with respect to the large number of identified deficient conditions.
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" Evaluation-of Visual Welding Inspection Techniques
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To'date, 62 randomly. selected samples of. weld joint's_ obtained from
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. coatings for:the following reasons: (1) I-S-NPBW 023, the, weld joint-
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.following:10 samples weresinspected during this report period:
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I-S-NP8W-11 'FW-1-019-902-C57W- FW 1-
.I-S-NP8W-119 <CS-1-078-013-C42S CS 1
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I-S-NPBW-10 CP1-VAFNAN Structural 1 I-S-NPBW-112 CT-1-097-402-C52R CT 1 . I-S-NPBW-078 AB-900-1M-4G .HVAC 2
'I-S-NPBW-120- CPX-VAFNCB HVAC Common (1)
A I-S-NPBW-113 MS-002-903-905-C77W MS 1
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*FW-Steam Generator Feedwater; CS-Chemical and Volume Control; Y
' SF-Fuel-Pool' Cooling and Cleanup; CT-Containment Spray; HVAC-Heating, Ventilation,,and Air Conditioning; MS-Main Steam ., ~To date, 45 of the randomly selected weld joint samples have been 4 - inspected _after removal of coatings. The following 18 second phase Linspections were performed during this report period: Verification Equipment Tag N System * Unit N :Pkg. No.- I-S-NPBW-09A B-810-1L-WP23 HVAC 1
I-S-NPBW-066 18" x 14" STR HVAC 1 o --I-S-NPBW-050 FW-1-018-901-C57W FW 1 I-S-NPBW-042 P-18/CMK-D22(SG) Structural 1 _ I-S-NPBW-068 FW-1-017-912-C47W FW 1
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I-S-NPBW-097 EMD-2 HVAC 1 I-S-NPBW-085 CP1-ELDPEC-05 Structural 1 I-S-NPBW-098 MS-1-RB-036-007-2 MS 1 i I-S-NPBW-033 54" x 38" STR HVAC 1 [.. I-S-NPBW-111 AF-1-101-001-S23K AF 1 ? !
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Status of-NRC' Inspection Activity
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v - ,. The~NRC"inspectorhaswitnessed100percentof'theinspections performed, to date, of welds in the coated and uncoated conditio ' '
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. No.NRC violations Lor deviations-were identified.'
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? Exit Interview Exit interviews were conducted on May 8 and June 3, 1986, with the applicant's' representatives identified in paragraph 1 of this appendi During there interviews, the NRC inspectors summarized the scope and
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-findings.ot the inspectio The applicant acknowledged the finding ,
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