ML20236L925
| ML20236L925 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/05/1987 |
| From: | Barnes I, Ellershaw L, Hale C, Wagner P NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20236L871 | List: |
| References | |
| 50-445-87-18, 50-446-87-14, NUDOCS 8711110125 | |
| Download: ML20236L925 (45) | |
See also: IR 05000445/1987018
Text
t
a .
I
APPENDIX.C
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF SPECIAL PROJECTS
NRC Inspection Report: 50-445/87-18 Permits: CPPR-126
50-446/87-14 CPPR-127
Dockets: 50-445 Category: A2
50-446
Construction Permit
Expiration Dates:
Unitf1: August 1, 1988
Unit 2: Extension request
submitted.
Applicant: TU Electric
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texcs 75201
Facility Name: Comanche Peak Steam Electric Station (CPSES),
Units 1 & 2
Inspection At: Comanche Peak Site, Glen Rose, Texas
Inspection Conducted: September 3 through October 6, 1987
b
Inspectors: h '
/ M
L. 2. Ellershaw, Reactor Inspector /Date
(paragraphs 2.c-f, 1, n, q-s and x-y, 3.a-f, 1-1
and n, 5.a and c, 8, and 9)
,
'
N ]
C. J. Hale, Reactor Inspector ' Dade
(paragraphs 2.t, 3.p, 4, 5.b, 6, nd 7)
8711110125 871105
O ADDCK 05000445
_ 1______
F- 1
1
- *. .-
CA_^) M A
P. C. Wagner, Rehctor Inspector
tilsle7
Date
'
)
(paragraphs 2.a-b, g-k, m, o-p, u-w and z, 3.g-h,
m and o, and 10)
Consultants: EG&G - J. Dale (paragraphs 2.c-d and n, 3.c, f, k
, and n, 5.c, 8.a, and 9)
V. Wenceel (paragraph 6)
Parameter - J. Birmingham (paragraphs 3.p and 5.b)
K. Graham (paragraphs 2.y, 3.1, 5.a, j
8.a, and 9) J
, D. Jew (paragraphs 2.e-f, 1, q-s and x, i
3.a-b, d-e, i and j, and 8.b-c) {
Reviewed by: b e eo udr/s 7
I. Barnes, Senior Project Inspector Date
Inspection Summary:
~ Inspection Conducted: September 3 through October 6 1987 (Report
50-445/87-18; 50-446/87-14)
Areas Inspected: Nonroutine, unannounced inspection of applicant ;
'
actions on previous inspection findings; follow-up on items of
noncompliance / deviations; applicant action on 10 CFR Part 50.55(e)
deficiencies; Comanche Peak Response' Team (CPRT) issue-specific
action plans (ISAPs) V.d, VII.a.4, and VII.b.3; review of
'
allegations; inspection of NCR process; corrective action program;
and general plant tours.
Results: Within the eight areas inspected, four violations
(documents listed on the package inventory card did not agree with
the docwnent package contents issued by the Paper Flow Group,
paragraph 6; engineering evaluation not performed on an i
inaccessible weld due to erroneous acceptance by a QC inspector,
paragraph 8; nonconformance report (NCR) not issued for failed
capscrew on a pipe support, paragraph 8; and actions required in
the disposition of an NCR do not appear to have been accomplished,
paragraph 4) and one deviation (several departures from the
criteria of the post construction hardware validation program not
identified, paragraph 8) were identified.
_ _ _ -
. , .
.
_.
..
Y- ,+ '
Q44 > < 3' - ,'
7, . ,,
' '
'
M '
,
,
3
l
, 4
y
i
DETAILS j
' '
L1.- JPersons-Contacted
M - *R.E P. ' Bakerj : Engineering Assurance! (EA), Regulatory Compliance
' Manager, TU-Electric. . .
,
, ,
'*J. .L.-Barker,-Manager,jEA, TU' Ele'ctric !
L*J. W.-(Beck, Vice! President,:. Nuclear' Engineering,c TU Electric
s*W. H. Benkert,; Staff? Assistant Manager, Operations Quality
'
%. ' Assurance-(QA),ETU Electric
s
'
,
- RL.D. Best, Nuclear Operations Insp'ecti'n o Report Item
' Coordinator, TU1 Electric; ,
. . .
"
< *D. N. Bize,.Regul' atory Compliance,iTU, Electric.
' ' "
- M.LR.1Blevins, Manager,LTechnical Support, TU. Electric
' '
- R.aCL Byrd,-Quality Engineering:(QE) Supervisor, TUl Electric
.
j
'
- W. G.'Counsil, Executive'Vice President,;TU. Electric '
- R. D. Delano; Licensing Engineer,'TU Electric
- D.1E.
'
Deviney,' Manager, Operations QA, TU ElectricL j
- M. D. Gaden, CPRT,'IT Corporation'
- T. . L.'Heatherly,'EA Regulatory CompliancouEngineer, ;
TU Electric ( '
.* D. A. Hodge,.CPRT. Interface, TU. Electric. .
-
- C. R...Hooten, Comanche. Peak Engineering (CPE)-Civil ;
,
Engineering UnittManager, TU Electric ,
~*J.1J.lKelley, Manager', Plant Operations, TU Electric
- 0.<W.'Lowe,iDirectorlof Engineering, TU Electric I
- C. K. Moehlman, CPE-Mechanical Engineering, TU. Electric
'*D. Moore, Administrative Assistant,' Operations, TU Electric
'*L. D. Nace,.Vice President ~, Engineering & Construction, j
TU Electric
l
- D; E. Noss, QALIssue Interface Coordinator, TU Electric _
-*M.4J.fRiggs,_ Plant' Evaluation Manager, Operations, TU Electric I
- S.xF. Sawa, Assistant Project Manager,-Unit 2, TU Electric! !
- A. B. Scott, Vice President, Nuclear Operations, TU Electric
- C.:E. Scott, Manager, Startup, TU Electric
- J.fC. Smith, Plant Operations Staff, TU Electric '
- M. R.-Steelman, CPRT, TU Electric-
< *P. B. Stevenc, Manager, Electrical Engineering, TU Electric
- T. G.JTyler, Director, Projects, TU Electric
- R. D. Woodlan, Supervisor, Docket Licensing, TU Electric
The NRC inspectors.also interviewed other applicant employees
during this inspection' period.
- Denotes personnel present at the October 6, 1987, exit 1
interview.
!
1
-
I
l
a
l
/
1'
.._L.-
-
y
L 1
,
I
'
.. . !
4-
t
'
h' ,
2. Applicant Actions on Previous Inspection Findings (92701)
, f
a. (Closed) Open Item (445/8511-0-06): Loose ground
conductor connection on cable tray T140CDJ17. Earlier
follow-up by the NRC inspector disclosed that a deviation .:
report (DR) and resulting NCR had been written for this
and related conditions; NRC follow-up was' documented in i
50-446/86-01. Additional
Inspection Report
follow-up during 50-445/86-0q;rioddisclosedthatthe
this report pe
j
earlier NCR had been transferzied to NCR CE 87-5400X. The l
new NCR was dispositioned but hot closed. The NRC
.
inspector checked the condition of the grounding
conductor connections for this cable tray node and ;
approximately 20 additional nodes of this cable tray run j
and found them'to be acceptable which indicated the
portion of the NCR dealing with the loose grounding
conductor was complete.
b. (Closed) Open Item (445/8511-O-32): Lack of required
separation distance between Train A cable tray and
lighting system conduit. This separation problem was
identified by an Evaluation Resaarch Corporation (ERC)
inspection which was witnessed by the NRC. The NCR
written for this problem, as documented in NRC Inspection
Report 50-445/86-22; 50-446/86-20, was transferred to I
Construction. Deficiency Report (CDR) 87-2581EC. This CDR
was subsequently closed becausa NCR CE 87-4577 requires
the removal of all separation ba rrier material (SBM) in
the Unit 1 security boundary. Since the separation
distance problem was caused by the attached SBM, the
problem was corrected when the SOM was removed. The NRC
inspector verified that the SBM ? tad been removed and that
the existing configuration meets the present separation
criteria.
c. (Closed) Open Item (445/8513-0-09): During a reinspec-
tion of Verification Package I-S- PS7N-015, the ERC
-
inspector identified a broken cot ter pin as a potential
deviation. This was later identified on DR
I-S-PS7N-015-DR1 which in turn was documented on NCR
M-23368N.
NCR M-23368N was dispositioned as being not a j
nonconforming condition for the following reason.
" Cotter pin is acceptable as installed since only one leg !
is missing and the remaini.g leg is fully extended and !
would require a mechanical device to dislodge it." l
l
The NRC inspector has reviewed Verification Package j
I-S-PS7N-015-DR1, NCR M-23368N and inspected the 1
applicable support and agrees with this disposition.
]
i
q
l
1
--
r:
E,.- ..
5
.,
d. (closed) Open Item (446/8513-0-13): During an NkC
>
witnessed reinspection of concrete placement Verification
L
Package I-S-CONC-076, the ERC inspector identified that
L the locations of cast-in-place Richmond inserts w6re out
! of tolerance. This Was subsequently identified on DR
'
I-S-CONC-76-DR1 which was determined to be not valid for
the following reason: " Location of Richmond Inserts has
been deleted per Change Notice 001 to QI-043,
Revision 1." Justification for this change was given in '
the memorandum for reinspection of concrete placement
which states, in part, " Location of Richmond Inserts
should not be considered as a significant attribute since
Gibbs & Hill (G&H) drawings allow contractor to relocate
inserts where assigned location is p_evented by
interferences with rebar or other embedments that are
impractical to move." The source for this information
was G&H Drawing 2323-SI-0565, Note No. 7.
The NRC insp,ector has reviewed QI-043, Revision 1, Change
Notice 1, the identified memorandum, and G&H Drawing
2323-SI-0565 and concurs with ERC that the item no longor
constitutes a DR.
e. (open)'Open Item (445/8513-0-21): This item dealt with
ERC identifying a stud with loose nuts during the piping
flange inspection for Verification Package I-M-PBOM-048.
This particular ERC inspection, which was witnessed by
the NRC inspector, occurred on flange No. 1 for Drawing
BRP-SW-1-SB-003. Subsequently, DR I-M-PBOM-048-DR1 was
generated ar_d which resulted in the issuance of NCR
M-23317N dated May 8, 1986.
The NCR initially required the reinspection of the
nonconforming condition (loose nuts on the stud) by
Brown & R6ot (B&R). During the B&R reinspection, the
nonconforming condition identified by ERC could not be
detected; i.e., all of the nuts on the studs for the
applicable pipe flange were now tightened. The NCR was
subsequently voided without additional action occurring.
NRC review of all available documentation nssociated with
the verification package revealed that there was no
record of work being performed by craft in which the
deficient condition was corrected. This item will remain
open until the NRC inspector can ascertain the facts with
respect to the nuts being tightened without apparent work
orders or records.
f. (Open) Open Item (445/8513-0-22): This item dealt with l
ERC identifying a piping flange where two of the studs 1
did not have the required one thread past the outer face !
of the nut. This particular inspection, which was I
witnessed by the NRC inspector, occurred on flange No. 3 ;
!
_ _ _ _ _ _ _ _ _
,_ __ _ _
1
. .. j
6 I
on Drawing BRP-CH-1-EC-004B. Subsequently, DR
I-M-PBOM-062-DR1 was generated which resultea in the
issuance of NCR M-23356N dated May 5, 1986. The NCR
initially required that the condition be reinspected by ,
B&n.to verify that it was nonconforming. After the
reinspection, B&R identified in the inspection report
(IR) that this condition was not a nonconforming
condition c.nd the NCR was subsequently voided. Upon ;
'
review of the IR, however, the NRC inspector determined
that the IR did not adequately address the problem; thus,
the WCR should not have been voided. Upon further j
investigation, the NRC inspector determined that. j
Corrective Action Report (CAR)-070, which is beinC {
implemented by the B&R ASME QA/QC croup, addresses SCRs l
which have been incorrectly voided and had already I
identified NCR M-23356N as one which falls into this
category. This item will remain open pending resolution
of CAR-070.
g. (Closed) Open Item (445/8513-0-29): Incorrect
identification tag and flange bolt installation on
electrical. penetration assembly (EPA) 1E-15. The vendor !
attached tag identified the EPA as 2E-15, indicating a
Unit 2 assembly, and one of the flange bolts did not have
proper thread engagement. The NRC inspector verified
that the bolt in question had been replaced with one of
the proper length and observed that an additional metal
identification tag had been added which specified the EPA
as 1E-15 per design change authorization (DCA) 6881. I
J
h. (Closed) Open Item (445/8513-0-30): Electrical conductor
seal assembly (ECSA) longer than allowed. The ECSA is
designed to provide an environmental seal between an j
electrical device and its connecting wiring. These ;
assemblies consist of the actual seal device and a length {
of connected, flexible conduit. The length of the
overall assembly had been specified to be 20" plus or ,
minus 1"; the ECSAs in question (1HV-4169-1, 2 and 3) {
were observed to exceed the allowed 21" requirement, {
Follow-up by the NRC inspector disc]osed DCA-55665 )
revised both the length and bend radius (see below, j
. paragraph i) requirements for the flexible conduit q
portion of the ECSAs. The maximum overall length was ;
increased to 24" as measured along the seal assembly l
because of the construction of the flexible conduit. The j
allowable bend radius of the conduit was revised from a
set 5" minimum to a value determined by vendor ,
recommendations based on the size of the conduit. The I
NRC inspector found the revisions to be acceptable.
l
l <
_ _ _ _ _ _ _ _ _ _ _ _ ~
I. i, j
. ..-
,
7
m
l
l
The NRC inspector' observed that the NCR documented ini )
Inspection Report 50-445/86-01; 50-446/86-01 for this 1
open item had been dispositioned "use-as-is" based on l
DCA-55665. Since the observed length had been 22", the ;
NRC inspector agreed with this disposition. )
1. (Closed) Open Item (445/8513-0-31): ECSA exceeding j
allowable length and minimum bend radius. Follow-up on j
the DRs and NCR documented in Inspection Report 3
50-445/86w01; 50-446/86-01 disclosed that NCR f
E85-1012593X had also been dispositioned "use-as-is" i
based on DCA-55665 (see above, paragraph h). The NRC
inspector physically verified that ECSA 1HV-5561 met the
revised requirements.
) 1
j, (Closed) Open Item (445/8513-0-32): ECSAs 1HV-4725-1. )
-2, and -3 had a loose: fitting and exceeded the allowable {
lengths. The conditions identified during the above i
inspection were documented in DRs and an NCR which the
NRC inspector listed in Inspection Report 50-445/86-01;
i- 50-446/86-01. j
The NRC inspector determined that the loose union fitting
DR was cancelled by ERC memorandum QA/QC-RT-3131 dated j
August 5, 1986, because the union was not considered a j
part of the ECSA, and that the observed lengths DR was '
cancelled by ERC memorandwn QA/QC-RT-3124 dated August 5,
1986, because the lengths (22", 23" and 23") met the
ravised criteria of 24". The NRC inspector physically
checked these three ECSAr and found all unions to be at
least hand tight and all .engths to be acceptable. The
ECSAr were mounted on the solenoid valve, and the cpen
and close limit switches for valve 1HV-4725.
k. (closed) Open Item (445/8513-0-34): The three ECSAs for
1HV-4172 had loose union fittings, excessive lengths
and/or inadequate bend radii. The NRC inspector verified
through physical inspection that the condition cited in
the open item were not nonconforming based on the
memoranda and DCA as discussed above (paragraph h). The j
inspector did note that the union for the solenoid valve
ECSA was not hand tight but acknowledged that sufficient
thread engagement existed to ensure mechanical integrity
which is all that would be required.
,
1. (Cloced) Open Item (446/8515-o-03): This item dealt with
ERC inspection of Verification Package I-S-PWRE-528. The
bumper restraint location was out of tolerance (not
installed) based upon the criteria contained within
CI-051.- Prior to issuing a DR, it was identified by ERC )'
that bumper restraints were to be inspected under
separate IWRE verification packages; therefore, this
.
___ -_ 1
g--
. ...
8
bumper restraint could nottbe inspected within the scope )
of this verification package. Further evaluation 1
revealed that construction of the portion of the pipe l
" whip restraint that this bumper was to be inspected j
under, had not been completed. Therefore, no
nonconforming condition existed. j
The NRC inspector, based upon a subsequent field I
inspection and review of applicable documentation, 1
concurs.that the bumper restraint should not be
reinspected and that no nonconforming condition exists.
'
m. (Cloned) Open Item (445/8516-0-20): EPA, flange stud nuts ;
not fully engaged. 'This condition, which was identified !
by an ERC inspector, was further discussed in Inspection
Report 50-445/86-03; 50-446/86-02. The NCR which s
documented this and related conditions that was l
identified in the later report was transferred to new NCR
CE87-6895X. NRC follow-up during thin report period
disclosed that the NCR had been dispositioned but not ~
closed. j
The NRC inspector physically verified that the studs
and/or nuts had been replaced on the EPA 1E-35 header
plate flange and that the existing installation was !
acceptable, thereby completing the actions necessary to
resolve and close this item.
n. (closed) Open Item (445/8516-0-38): Du' ring reinspection
of Verification Package I-S-HVDS-029, the ERC inspector
identified potential deviations concerning: (1). weld j
symbols and locations, (2)' undersize welds, and (3) a
Hilti Kwik bolt embed violation. These conditions were
I documented in DRs I-S-HVDS-029-DR1 and DR2 and i
incorporated into NCR M-85-102014X.
The disposition of NCR M-85-102014X stated that the
nonconforming conditions will be addressed by CAR-111
I which deals with identified hardware and documentation
f deficiencies. CAR-111 is to be resolved through the ,
'
implementation of CPE-FVM-CS-029, which is the " Field I
Verification Method Procedure for Seismic HVAC Duct and
Duct Hanger As-Built Verification in Unit 1 and Common
Areas." The NRC inspector has reviewed CAR-111 and
,
I- ,J
CPE-FVM-CS-029 along with the corrective Action Program
j
(CAP) that implements the reinspection and as-building of
- the HVAC population, and finds that it adequately
( addresses the above deviations. The NRC will be ;
f performing inspections pertaining to the adequacy of j
l implementation of the CAP; therefore, this open item is i
!
closed.
I
) l
l
1
l
l
_
'
[
, p. 3,
,
,,
~
q
'/- -
.
- .2 -. : gg ,
'
.a r, , 9
e i
'
-)
'
'
s o. (Closed) Open' Item-(445/8518-0-09):. ' Incorrect SBM , k
installation. An NRC' inspector noted that1thel steel; 1
J zbanding~usedit'o hold'the.SBM~in place on conduit ]
C13G084248'was not=within 2" ofsthe-end of'the SBM. J
'
> Follow-up by'the NRC inspector disclosed that'NCR
JC87-4577.had been dispositioned to remove all offth'e.SBM '
l
from Unit'l because of-its questionable qualifications.
Since the SBM will be removed, this installation question !
.is - moot.- s j
Improper motor' lead 1
p.' (Closed)lOpen Item (445/8518-0-10):
connectors.' An NRC inspector identified two'problemst '
t
=vith the wiring of the motorioperated valveJ(MOV).
"' :1HV-2493B motor leads, frayed. insulation;and. improperly:
installed terminal 11ugs. 'Insaddition,Lthe ERC inspectors j
- had identified an;out-of-scope (OOS)' finding'related to
stretching of'a' vendor. connected lead.- All three of thef
problems.were' documented:on.NCR E85-101387SX.; The
disposition of;the NCR wa's to determinate, remove the D L
unacceptable-portion of the threctleads, relug the leads, 1
and determinate themiin accordance'with the. proper
' '
.
'
procedure. 1TheLNRC inspector found this,to bs an- '
P' acceptable resolution.
q. (Closed) Open' Item (<45/8518-0-16): This item' dealt with I
i
ERC identifying during their document review of .
< : Verification ' Package E-M-PBOM-046, that no' heat number,
'
lot number, or. color code was recorded for the stud
material on construction operation traveler (COT)
MP-31-2831-310D. One of the three must be present to
. assure proper traceability of the stud material. ERC
generated DR R-M-PBOM-046-DR1 and this subsequently 4
resulted in the issuance of NCR M-23315N. .The NCR
disposition determined that this condition was not a
nonconforming condition based upon the fact that the
appropriate stud material color code was depicted on
Material Requisition '(ER) 117796, which was included as a !
-part of the. COT MP-81-2831-310D package. j
t
'
The'NRC inspector reviewed the COT MP-81-2831-310D
package, which included MR 117796 and concurred that this
is not a nonconforming condition. There was sufficient
traceability of-the stud material because the' correct
color coding w&s shown on MK 117796, the proper Quality 1
Control (QC) sign-offs were on the MR, and the MR was a ,
part of.the COT package. =
r. (closed) Open Item (445/8518-0-23): This item dealt with
an ERC reinspection of Verification Package I-M-LBCO-127,
- where it was identified that there was no identification
tag attached to a valve and that no flow direction was <
indicated on the valve. Subsequent ERC review of QI-025,
y
s'
s--.. - - _ _ - - _ - _ _ _ - _ . - -- , _ _ _ . _ n _ - - . _
< ]
> ;
.. .
j
10 l
Revision 0, determined that there was no requirement for i
an11dentifi' cation tag as long as an ASME name plate was <
attached. It was also determined-by review of the vendor l
drawing, that this type of valve is not sensitive to flow
direction; therefore, DR I-M-LBCO-127-DR1 was ;
invalidated. The NRC inspector, upon review of QI-025, ]
Revision 0, and the four subsequent revisions, and the l
vendor drawing for this valve, concurs that these
conditions did not warrant the issuance of a DR.
s. (Closed) Open Item (445/8518-0-25): This item dealt with a
4
an ERC reinspection of Verification Package I-M-SBCO-022 ;
in which it was identified that the required clearances
between the inspected pipe and adjacent pipes were not
met. Subsequently, DR I-M-SBCO-022-DR2 was issued which
resulted in the issuance of NCR M-23460N dated March 20,
1986. The NCR disposition required rework to be i
,
performed where the piping insulation would be notched so
that the clearance requirements would be met. Upon
completion of this rework, the NCR was closed on 1
August 25, 1986. The NRC inspector, upon review of the l
NCR, concurred with the disposition, and a follow-up
field inspection revealed that the rework required by the
disposition had been adequately performed by the craft.
t. (Closed) Open Item (446/8602-0-05): The surveillance
inspection function reports organizationally to the site
QC manager creating the potential for a violation of
Criterion I of Appendix B to 10 CFR Part 50.
This area of concern was inspected further by the NRC in
May 1986 and reported in paragraph 3.a of Inspection i
Report 50-445/86-07; 50-446/86-05. As identified in that
report a major restructuring and reorganization of the
QA/QC function had been approved on April 29, 1986.
Those activities associated with construction were to
begin implementation in July 1986 and be completed by
September 1987. This reorganization is now complete and i~
has been inspected by the NRC. A brief description Of
the organization now in place follows, particularly as it .
relates to the surveillance inspection function.
l
1
On June 30, 1986, office memorandur QQM-54 was issued i
establishing an organization which placed the I
surveillance inspection function under the Manager, QA, a
group totally independent of the activities being
inspected. Also included under the Manager, QA, was the
internal and external (vendors / contractors) audit
programs. Under the Manager, QC, where the surveillance
inspection function was located before this change, are
the QC inspection function and the balance of j
construction QA/QC onsite functions. In addition to j
l
1
I
M uwm mm.w- . - - ------,-
- _ _ -
. .
11
,,
" '
these functional changes, the total Dallas-based audit
staff was to be relocated to the site by September 1987.
All these organizational changes and personnel moves have
been accomplished, which resolves the concern of this
open item.
u. (Closed) Open Item (445/8603-0-09): Insufficient
clearance for instrument tubing. The condition of an
instrument impulse' tubing.run having less than the
required 1/8" clearance to adjacent tubing runs was
identified by an ERC inspector to the NRC inspector and
documented on DR I-E-ININ-030-DR1 during a witnessed ISAP
VII.c inspection. Subsequent.to that inspection, DCA
25006 revised the required clearance from 1/8" to an air
gap. Since an air gap had existed, this condition is no
longer nonconforming. ,
!
v. (Closed) Open Item (445/8603-0-11): Insufficient
clearance for instrument tubing.- This clearance i
condition was also identified by an ERC inspector but. j
since DCA 25006 has revised the requirement, the
condition is no longer nonconforming (see paragraph u).
w. (Closed) Open Item (445/8603-0-12): Insufficient
clearance for instrument tubing. This clearance ,
condition was also identified by an ERC inspector but j
since DCA 25006 has revised the requirement, the
];
condition is no longer nonconforming (see paragraph u).
}
x. (closed) Open Items (445/8702-0-02; 446/8702-0-02): This j
item dealt with the lack of documentation explaining why
ERC had created the VII.c population Pipe /Neld Materials ]
1
(PIWM) by combining the Large Bore Pipe Welds / Material !
(LBWM) and'Small Bore Pipe Welds / Material (SBWM) l
populations.
ERC memorandum QA/QC-RT-7879 dated July 7, 1987, was i
generated by the appropriate QA/QC Discipline Engineer to l
the ERC file. The memorandum briefly explained that the j
reasoning for combining the populations was that the ERC l
philosophy had shifted from one considering strictly
hardware type (i.e., large bola pipe welds) to one
l
considering a combination of hardware type and the
homogeneity of the work process involved (i.e., pipe
welds). The generation of the PIWM population resulted. 1
The NRC inspector reviewed this memorandum and concurs {
that this documentation adequately addressed all l
concerns.
y. (Closed) Unresolved Item (445/8713-U-02): The MRC
inspector identified that Union Pump Drawing S-C8135, i
part Nos. 643-6 and 643-8 (capscrews) are designated in
- _ _ _ _ _ - _ - _ .
i .
12
the owners manual as being subsection NF,Section III of
[' N
- the ASME Code. These capscrews had been installed
l 'without hardened washers, which is a requirement for i
compliance with the ASME Code when the calibrated torque
wrench installation method is used.
Subsequent NRC review of Westinghouse equipment i
specifications and design qualification reports provided d
by the Generating Technology Division of Westinghouse
Electric' Corporation, determined that the owners manual
drawing was not a part of the' governing design
specification. NRC inspectors ~ performed a review of the
design data and determined.that all applicable design
requirements for equipment. support bolting had been
included in the design qualification report for positive
displacement charging pump TBX-CSApFD-01, and that field
installation of the pump met those requirements. j
. - i
'
,
'
z. (Closed) Unresolved Item (445/8713-U-04; 446/8710-U-01):
Qualification unknown'for electrical splices' located
inside static inverter cabinets. The NRC inspector had
held the issue of the qualification of splices discovered
inside the inverter cabinets as an unresolved issue t
pending receipt of documentation for verification.
Westinghouse Electric Corporation letter WPT-9137 dated
August _10, 1987, stated that the splices were installed I
on the inverter cabinet.which was qualified; therefore,
the splices were considered to be qualified. The NRC
inspector also observed the existence of the splices on
the photograph provided with the letter. -.
3. Follow-up on Items of Noncompliance / Deviation (92702)
a. (Open) Deviation (445/8601-D-19): Based upon an ERC
requested B&R field curvey, ERC failed to identify that q
the distance frgm field weld No. 18-A to the working j
point of the 76 bend was out of tolerance. The survey
determined this distance to be 10', 5 7/16" while the
specified distance on the applicable drawing, {
BRP-CC-1-RB-046, was 10', 8 1/8". The allowable !
speciffed tolerance was 2". This occurred on
Verifir.ation Package I-M-LBCO-144..
'i
corrective actions taken included issuance of DR j
I-M-LBCO-144-DR2 on March 14, 1986, which led to the l
subsequent generation of NCR M-23475N, Revision 1. j
Actions to prevent recurrence included discussion between i
the ERC inspector of record and his lead discipline i
engineer with respect to this finding. Additionally, the
ERC Overview Inspection (OI) Group reinspected a sample
of each inspector's work.
_ _ _ _ _ _
- . _ .
- _ -. _ _ _ _ - . - _.
.
% '
'
Y
'kh. r
to
i \
,
13'
l
. r '
A review performed by the'NRC inspector. verified that ERC
s
had corrected the reinspection checklist to reflect the l
-out-of-tolerance condition and that DR I-M-LBCO-144-DR2 H
'had been issued. The NRC' inspector-reviewed and
concurred with the' disposition of:NRC M-23475N,
Revision'1, which,requiredithat.the'BRP drawing be.
L -
revised to reflect the actual field conditions. It was
, :further concluded that;such a small change in-linear ;
dimension (11/16" when'considering the 1: 2" tolerance)
would have no-effect on the1 function of the system.
n-"
Since undocumented. discussions occurred between the-
inspector of record and~the lead' discipline engineer,
they could not be verified. It,was verified, however,
i that this inspector .had' a low error rate as determined lur j
o
The NRC inspector retrieved the latest revision of
Drawing BRP-CC-1-RB-046 (Revision CP-1) and determined
'
thatLthe changes committed to have not yet been'made.
" This item.will remain open pending revision.to the'BRP
'
,
reflecting the' actual field dimensions as determined-by
the B&R field' survey. ,
'
b.. -( Open ) Deviation (445/8601-D-20): This item dealt with
the failure on the<part of the ERC inspector to identify
that no air gap existed between the pipe line being
"
inspected and a rod hanger just above it, as required by
> QI-025. This occurred on Verification Package
I-M-LBCO-144. Corrective action included a reinspection
of the line'for this finding and the subsequent issuance
of DR I-M-LBCO-144-DR3. This led, in part, to the
generation of NCR M-23475N, Revision 1, which
dispositioned this finding by requiring that the pipe
insulation be notched to alleviate the condition.
Actions to prevent recurrence included a documented i
discussion relative to this finding between the inspector j
of record and his lead discipline engineer. !
Additionally, the ERC OI group reinspected a sample of l
the identified inspector's work.
The NRC inspector verified that the appropriate DR had I
been issued, and concurs that satisfactory disposition of l
NCR M-23475N, Revision 1, would remedy this situation. l
Also, documentation addressed to the file concerning
discussions between the inspector of record and the lead
'
discipline engineer, relative to this finding, was
reviewed and verified. A subsequent field inspection by
'
,the NRC inspector determined that the committed rework
s.
has not yet occurred; therefore, this item will remain
i open pending verification by the NRC inspector of the
rework.
I
pg ; '
.
>
'
n ;;
q
.,y}l- { e
'
,
, x
p. 4y +. .*;
.
.
+
.;
(- '
i 4
L. 14 , 4
o .
_
e J.
1
L '- c .. ~(Closed) Deviation _(446/8602-D-12)-: During anEinspection- L
of'HVAC Verification Package,I'S-HVDS-075, thelNRC;.
-
l
inspectorJidentifiedLthe following condition: . Revision 0. ;
]
'
,
'.
to-QI-035-instructs'the inspector to ." Verify member
-
1 '
olengths and all other dimensions that describe the
(- ,
lengthsJand positionscof the members of the support frame 1
'
(111/2")." iFor VerificationJPackage:I-S-HVDS-075, the j
, ' ERC inspector signed the' checklist that.this~ attribute j
'(2 D) was acceptable..~However,-the.NRC inspector found
cit-impossible to_ verify some member lengths and "
- positions. ,
.!
Asia consequence of ERC's' inspection'results'and
subsequent recommendations, TU Electric has initiated a
'I'
CAP)which includes a 100% reinspection of HVAC: duct-
'
supports. This reinspection will be" implemented by;
. - - Procedure CPE-FVM-CS-029 which is the " Field Verification l
Method: Procedure for. Seismic HVAC Duct and Duct Hanger _.
'
As-Built Verification in Unit 1 and Common' Areas." The 1
NRC inspector.has reviewed this procedure and considers- !
Lit to adequately address the issues identified by.both
the NRC and ERC.. The'NRC inspector will inspect the
' implementation of this procedure during subsequent
inspection periods. l
Because of'the CAP. reinspection of HVAC, this deviation
is closed.
-d. .('o pen) Deviation-(445/8603-D-13): This-item d'ealt with
three cases where the pipe to pipe clearances did not
meetEthe specified criteria of QI-025, but were not
identified by ERC during' reinspection of Verification l
Package of I-M-LBCO-148. Corrective action included a j
'
reinspection to. confirm the NRC findings and then the
. issuance of DR I-M-LBCO-148-DR3 to document these
conditions. This subsequently resulted in the generation
of NCR M-25340N. The disposition of the NCR required
that the piping insulation be notched to meet the _l
specified criteria. Action'to prevent recurrence
included a documented discussion between the engineer.of
record and.the lead discipline inspector relative to the
NRC finding. Additionally, the ERC OI group reinspected
a sample of each inspector's work.
The NRC inspector verified that the appropriate DR had
,
been issued and concurs that satisfactory disposition of
NCR M-25340N would remedy this situation. Also,
documentation addressed to the file concerning ,!
discussions between the inspector of record and the lead i
discipline engineer relative to this finding was reviewed j
and verified. A subsequent _ field inspection by the NRC l
inspector determined that the committed rework has not
'
s
' _ _ - - - - - _ _ _ _ _ _ _ _ _ _ _ _ ____9
O, s
v ,
' '
.? .. (
,
15
yet occurred; therefore, this item will remain open
pending rework and NRC verification of the rework.
e. (Open) Deviation (445/8607-D-10): This item dealt with )
'
OI Package 13-I-M-LBCO-148 not identifying' unsatisfactory
decisions made>during the course of the initial ERC
reinspection. It dealt with the three pipe to pipe,
'clearanc'e deficiencies identified by the NRC inspector in
the above previously mentioned deviation (445/8603-D-13).
Corrective action included revision of the OI checklist
- to reflect actual field conditions and issuance of the !
appropriate DR and NCR. Actions'to prevent recurrence
included documented discussion of this finding with all
overview inspectors and a documented discussion between
the overview inspector and the initial ERC inspector of
record. j
l
As mentioned above, the NRC inspector reviewed the J
resulting DR'and the subsequent NCR. The NRC inspector
has'also verified that the OI checklist was corrected and-
now reflects the actual field conditions. This finding
was discussed with all overview inspectors and
discussions occurred between OI and the ERC inspector of f
record relative to the findings. This item will remain
open pending rework and NRC verification of'this rework.
I
f. (Closed) Deviation (445/8607-D-11): During an inspection
of Verification Package I-S-PS7N-011, the NRC inspector
identified that Attribute 2, which addresses pipe clamp
parallelism, was rejected by the initial ERC inspector as l
being out of tolerance by 3/16". The OI rejected this
same attribute but noted that the out-of-tolerance
condition was 1/16". The OI, during comparison of his
inspection results with those of the initial ERC {
inspector, failed to identify the inconsistency with
respect to the out-of-tolerance measurement differences. l
Subsequent to the identification of this deviation, ERC l
performed an independent inspection on May 30, 1986, for i
Verification Package I-S-PS7N-011 and confirmed that a
difference of 1/4" existed in the measurements made by
the ERC inspector and the OI. It was determined that the
ERC inspector had made an error by documenting the
"outside" caliper scale for these measurements in lieu of
the "inside" scale.
An OI Inspection Report 2-010(A) was transmitted to ERC <
QA/QC engineering and instructed that ERC inspectors' f
measurements be checked and any necessary changes be made j
to the verification package. Discussion of the deviation f
was held with all OI inspectors. Emphasis was placed on I
the comparison of measurements and the need to question f
4
l
l
._ ___-_______A
--
,
,
. .
.,
16
\
,
, . ' differences when limits were exceeded for field
measurements.
ERC performed a review of all completed overview and
associated reinspection packages _to ensure that
inconsistencies identified between verification packages
were addressed. The NRC inspector reinspected
Verification Package I-S-PS7N-011 for Support
BR-013-009-S43R and determined that the ERC inspector had j
made the error by resding the incorrect side of the
calipers. The NRC inspector also reviewed OI Inspection
Report 2-010(A) and the revision to. Verification Package
I-S-PS7N-011. He also reviewed the training records for
OI and noted that the training discussed above had;taken f
place. The NRC inspector concurs with the action-taken !
' for this deviation,.therefore, this item is closed. I
g. (Closed) Deviation (445/8607-D-19): ' Spare conductors
r were included in sample population of essential Class 1E
conductors. TU Electric prcvided their rationale'for
having included the spares in the ISAP I.a.4, " Agreement
Between Drawings and Field Terminations" population in
the February 18, 1987, response'to this deviation. This
letter also explained that the sample size was expanded ;
to include sufficient functioning conductors to eliminate
any spare conductor influence on the sample. The NRC
letter dated September 11, 1987, found this corrective
action to be acceptable. .
In addition, the applicant's July 22, 1987, response to ;
deviation 50-445/8702-D-03; 50-446/8702-D-03, stated.that j
the ISAP VII.c population engineers would rereview their
population items listings to ensure the completeness of
those populations. l
h. (Closed) Violation (445/8607-V-21): Lifted electrical
leads. The applicant's March 6, 1987, response to this j
,
violation stated that while no cause for the condition of ]
conductor EG123389(W) being disconnected could be
determined, they considered this to be an isolated event.
A work order (WO) was issued to reconnect the conductor
and appropriate personnel were retrained on the i
requirements for temporary plant modifications. The I
applicant denied that the second cited example, conductor
EG106004(B), was a violation because documentation
(Wo C85-1221) was subsequently located which showed that {
the conductor was reconnected on June 19, 1985, which was {
. prior to NRC documentation of the condition.
'
The NRC inspector verified that Wo C87-0723 documented
that EG123389(W) was reconnected on March 6, 1987, and
that Wo C85-1221 documented that EG106004(B) was i
!
I
___ - -__ _
y, . - -
-
- - -
,
,- , _ ;
g,
,
.,
,
a .
,
}.' d'
,
5
}'
m- ,
m
,
.
.
. ,
-17 J
+ '
, .\
,
j:
0
M_y reconnected on June:19, 1985. 'Thesinspector.'also
['F
.
w reviewed'the record for the instrument
p 7,
>
'
technician's: training session.on March,and 24,1 control: 1987, and the. ,
6 memorandumidocumenting electrical maintenance. personnel
l' training:on'. March- 23,,1987. TheiNRC inspector then
L physically verifledEthat EG123389(W) had been properly
j
.
' t
,;~
reconnected to point:76.on terminal board (TB)-4 in Unit-
L ,
l cable spreadingiroom' termination cabinet No. 42
'
!
'
'
-(TC-42).
'
l' ., .
'
While checking TC-42 on September 24,S1987,1 the'NRC: j
inspector. observed the following: ]
s
>
,
'
'
.
3
A paper tag was taped to the' door stating,'" Work in 1
l
Progress Wo'C86-0003950." .f
u
. Conductor EG109550(B)'was< lifted;'.the lug taped, and 'j
, ,,
a, paper.' tag; attached 6 indicating, " Work in Progress, !
c ,
, C85-0003448.". y
I
<
.. Cond'uctors'EG104591(B) and (W)~were lifted, tape'd
l
and tagged with a red' Construction Work in Process 4
e Tag which.listedtwo C87-0001201. .
.
4
. ' Conductors EG104511(B) and (W) were lifted, taped
" and. tagged with a red, Construction Work in' Process
Tag which also listed WoiC87-0001201. ,
~
i s . . Conductors EG123550(B) and;(W)'wereilifted and the
~1ugs. taped but.no tag was attached-
-
.
' '
The NRC inspector' reviewed,the WO' packages'and the
< interconnection wiring diagram l(2323-El-0172, sheet-42,
Revision CP-3)'to determine'.the status of the work in
'
,
' progress:
<, .
1 .
.
. , WO C85-0003448 contained.a page showing that
EG109550(B)ihad been lifted on May 28, 1986,-'and'was
awaiting reconnection.
. . ,
+
. WO C87-0001201 was written for the rework associated J
with the Train B 6.9kV switchgear; the connection
diagram showed EG104511(B) and (W) and EG104591(B)
and (W) to be connections to this switchgear' f
(1EA-2). :
-
. WO C86-0003950 contained a page' indicating that l
EG112298(B) ar.d (W) had been lifted from TB-2,
I points 15 and 16 in TC-41, iThe leads were actually
,
,
in TC-42 and were later verified by the NRC ]
inspector to have been " soft landed"; i.e.,
connected to the TB with plastic screws.
'
l
I
.
1
I
_ _ _ _ . _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
r- -
1
f .
'
- - .
,
, 18
on September 29,,1987, applicant' personnel explained that !
conductors EG123550(B) and (W) had been disconnected in
accordance with WO C86-00039Sl.- A review of this WO
disclosed that these conductors were part of the position
indication circuitry fcr MOV l-8811B, the sump to
residual heat retcoval (RHR) pump #2 isolation valve,
which had been disconnected on February 13 ', 1 9 8 7 , to allow l
Since the EG12355'O conductors were not tagged in
accordance with Procedure STA-402, the NRC inspector
requested information.concerning the control of startup
and maintenance work activities; i.e., how disassembled.
equipment is tracked and controlled to ensure it is
returned to normal. This is an open item pending receipt
of this information (445/8718-O-01). i
1. (Closed) Deviation (445/8607-D-26): This item dealt with j
a CPRT review of historical procedures for ISAP VII.b.2, i
" Valve Disassembly / Reassembly" being deficient in that
the CPRT did not identify that between January and June j
1983, a discrepancy existed in Procedure CP-CPM-6.9 i
" including Appendix E (CPM-6.9E). This procedure l
controlled the onsite process of disassembly / reassembly i
of valves.
!
TU Electric concurred that this procedure discrepancy j
existed and had not been identified by the CPRT during ;
review. The corrective actions taken included assessing i
what impact the procedural discrepancy had on the valve 3
disassembly / reassembly process during the identified time
frame and the effect it would have on the conclusions
arrived at in the ISAP VII.b.2 Results Report. It was
found that during the time frame in question, valve
disassembly was still accomplished utilizing COTS and l
that review of a sample of pertinent COTS revealed that J
they were similar in context and format to those utilized i
prior to this time frame. Also, the applicable QA I
procedure (QI-QAP-11.1.26, Revisions 9 to 12) in effect '
during this time span, included the requirement for a
traveler to govern the disassembly / reassembly process. 1
The use of the COT and the fact that the appropriate I
QI-QAP was still in effect provided adequate controls for
the valve disassembly / reassembly process. This would,
therefore, have no effect on the conclusions contained !
within the ISAP VII.b.2 Results Report. No further :
'
actions were performed.
The NRC inspector reviewed procedure QI-QAP-11.1.26,
Revisions 9 to 12 as well as five applicable COTS for the
time frame in question and concurred with the
TU Electric's conclusion that adequate control of the .
i
_
i
.. .
,
'
19 >
.
valve disassembly / reassembly process was maintained even
though there was:a procedure discrepancy. ,No revision to i
'
'the ISAP VII.b.2 Results Report was required; therefore,
this item is closed.
j. (Closed) Deviation (445/8615-D-03, Item B.1): This item !
dealt with the failure ofsOI to identify unsatisfactory :
decisions (pipe to pipe clearances) made by the initial i
ERC inspector with respect to Verification Package l
12-I-M-SBCO-078. Inspector error was determined to be ]
the cause of this deviation. Corrective action taken
included reinspecting this attribute and revising OI '
Verification Package 12-I-M-SBCO-078 to reflect the NRC
' identified clearance problem. This subsequently resulted
in the revision of the original ERC inspection checklist,
issuance of DR I-M-SBCO-078-DR2, and the issuance of NCR
M-2893N to address the hardware problem. The NCR
disposition required that the piping insulation be
notched to alleviate the clearance problem. The actions
taken to prevent recurrence included a documented
discussion of.this finding with all applicable OI i
inspectors and documented discussion with the initial ERC :
inspector of record.
The NRC inspector confirmed that the corrective actions
committed to had been satisfactorily implemented and that
proper disposition of NCR M-2893N would resolve the
Jhardware issue. NRC inspection revealed that the rework
specified.within the NCR disposition had been adequately i
performed. The NRC inspector also reviewed the )
documentation of the discussions with the appropriate OI I
inspectors and the ERC inspector of record relative to
this finding. The corrective actions were adequate to
resolve this issue.
k. (Closed) Deviation (445/8615-D-04): During an inspection
of OI Package I-S-PS7N-095, the NRC inspector identified
that the measurements associated with the parallelism of
pipe clamp halves in the verification package did not 1
coincide with the measurements listed on DR I-S-PS7N-095- l
DRl. After measuring the pipe clamp halves, the NRC ]
inspector observed that DR I-S-PS7N-095-DR1 incorrectly )
identified the degree of out-of-tolerance and further, !
that the overview inspector had failed to identify and i
l
resolve these discrepancies.
ERC reviewed DR I-S-PS7N-095-DR1 and found that a !
mathematical error had been made by the ERC inspector l
,
which resulted in an inaccurate description of the ]
'
condition. The failure by the overview inspector to note
'
l this condition was considered an oversight.
,
I
- -- - 1
_
'
J- y
<
. ..
20 ;
-
,
I
ERC has performed an independent review of all' completed
overview inspection packages'to assure that,all
inconsistencies between the OI packages and regular ERC l
verification packages have been resolved.
..
DR-I-S-PS7N-095-DR3 was initiated to supersede
'I-S-PS7N-095-DR1 and provides a more accurate description
of the out-of-tolerance condition. Additionally,:all
overview inspectors received additional training on i
July 9, 1986,'and July- 31, 1986, addressing the concerns
identified by the NRC and similar ERC' findings. !
The NRC, inspector has reviewed DR iI-5-PS7N-09b-DR3 and j
determined that it correctly identifies the problem. He ,
!
has reviewed.the training records and the results of the
review conducted by ERC and, considers that this problem ,
has been adequately addressed.
1. (Closed) Deviation (445/8622-D-09): Tnis dev.ation
i dealt '
with ERC engineering's failure to provide inspection
instructions for the verification of all safety-related j
attributes associated with verification Package l
I-M-MEIN-107.
TU Electric letter TXX-6396 dated April 27, 1987, in
-response to the deviation, states that a~ review of
documents describing repair or modification work
performed on TBX-CSAPPD-01 (I-M-MEIN-107) has been
conducted and the verification package reissued for
reinspection after appropriate supplemental inspection
-instructions were added.
The NRC inspector performed a review of documentation
describing work (COTS, DCAs, maintenance action requests, 1
1
etc.) associated with ERC population sample I-M-MEIN-107.
This review confirmed that additional work activities had I
been identified and were either included in the MEIN
package for reinspection or were within the scope of j
other VII.c populations. NRC review and inspection '
identified no other deviations from commitment. j
m. (Closed) Deviation (445/8626-D-01): Failure to write an j
OOS memorandum for an electrical cable pulling rope-left i
in a conduit. The' applicant's June 5, 1987, response to j
this item stated that an OOS memorandum had been written )
in response to the NRC concern and that NCR E86-103883S 1
had been issued to correct the problem. Tne NRC l
inspector verified the existence of these two documents i'
and noted that additional inspection in this area will be
conducted as part of the follow up for Violation
50-445/8626-V-02, which includes this electrical pulling I
aid problem. I
i
- _ - - _ - _ - - _ _ .
m.
N
I
'
,
H
. o l
< +
21 ,
l
,
n. (Closed) Deviation (445/8626-D-07): During a review of ,
t
QI-035, QI-036, and applicable Bahnson Service-Co. (BSC) f
installation and inspection procedures and drawings, the j
"
NRC inspector identified the following conditions: BSC
inspection reports were dated as much as five years prior
to the initial issue of the detail. drawings, and there
was no evidence of inspections performed by BSC QC to
verify that the duct support. configuration conformed to
the detail drawing. It was further determined that BSC
QC used typical drawings for'their inspections which can
-
be dissimilar to the detail drawings provided to ERC.
l
The applicant responded to the above deviation with the
following explanation:
1
"The ERC population engineer has reviewed documentation l
provided by the HVAC contractor' including NRC Inspection
Reports 50-445/83-12 and 50-445/86-18. During the course
of this review, it was determined that the BSC response j
to both the NRC inspection reports and the ensuing
corrective action reports was somewhat less than
adequate.
'
"ERC has determined that no corrective action is
necessary with respect to this deviation because numerous
other deviations were identified and evaluated, and they
clearly established the existence of hardware and QA
deficiencies. Furthermore, there is no action to prevent
recurrence required because the ERC reinspection is
complete and an unclassified trend has been identified
for all attributes in this population. As a result, a :
recommendation was made that requires a complete l
reinspection and reanalysis of'all HVAC duct supports." i
The NRC inspector reviewed all of the applicable CARS 3
which deal with hardware and documentation deficiencies, ;
'
and will review the TU Electric HVAC reinspection program
when it is made available. The NRC inspector concurs
with the ERC recommendation regarding this deviation.
NRC inspections will be performed during the TU Electric
HVAC reinspection program.
o. (Closed) Deviation (445/8702-D-04; 446/8702-D-04):
Incomplete file for electrical cable population listing.
The NRC inspector identified four pages which listed
electrical cables that had not been included in the cable
population file. Tne applicant's July 22, 1987, response
to this problem explained that although the pages had not )
been included in the permanent files, the cables listed l
thereon had been included in the sampling and inspection
process. Since this was an administrative omission and
_ __ _
4% y 3 ]
yf p,pe
. ,
%(m
L' $M '
i
, -;
% s$7i M , q..@y jh , py),, O 4N r 22
gk
,
'
m
- 4 g
W'
, ,%
h '
q
. L (,% hce the missing'pages-were added'to.the file, the'URC
'
q- i
-
.m ;
' 4
j{ % Q.y pqctor considers this' item closed.
~
A s.
s N,f'p. '(Closed) Violation.-(445/8706-V-12; 4'6/8705-V-06): 4 This ,
lvi.olation concerns colored.cebles. stored in the? cable 1
0W4
C*
rifal yard which were-improperly' protected. from exposure
- toLsunlight.
'
l
f .y
y 'T .T51e NRC : inspector; verified that' bhe corrective l actions of '
phovidinghie. exposed cables with an opaque plastic.
~
s <x covering ltMd been implemented. .. The NRC inspector also l
g.
'a< '
- verified-th.it.the applicant had taken the additional -1
4, . Y,y x . measure:of s.tapling the, opaque plastic covering.to;the :!
' twooden cable reels to prevent the~ cover from being easily
,
't dislodged.- The NRC inspector toured the/ cable' reel-yard I
k. g[Jc4 n and found nofother' storage' violations. The NRC" inspector-
'
i
< [M4
.
^
.
reviewed'NCR CE-87-9190 which>had:been written:.to obtain 1
an'engineeringLdisposition'for the cables which were j
, ,If' #'n < ' faded. :The'NCR addressed the concern and noted.that. 1
>/ Specification 2323-ES-100, Revision 2' allows jacket
,
j
4
- I * color imperfections provided the cable color can be
.
iI
_,f discerned within'any 15Efeet of; cable.: The NCR also 1
'*
\ ' lnoted that the. cable is designed;to withstand. radiation
and-therefore exposure to. sunlight'would not cause .
i , deterioration of the cable. jacket. 1
g
Thecorreo$1veaction.cfstaplingthecoversinplaceand
g( an ongoird' daily surveillance by. the cable reel yard area
k. 4 L ' supervisor should be: sufficient to preclude recurrence-of >
b , );,. this deficiency.
l
1 wy ' <
L 4q = Action on 10:CFR Part?50.55(e) Deficiencies' Identified by the
s Applicant - ( 9 27,0_0_},
i ,, ,
(.Open)1 SDAR CP-8649:. The_ applicant's review of NCR
.
dispositions indicated that some NCR dispositions may be
technically inadequate.
I :s
NRC inspection of this activity was initially reported in NRC
, Inspection Report 50-445/87-16; 50-446/87-13. In that report, j
h the NRC inspector Icported. that ' the applicant had initiated a i
l program.to review the dispositions of those NCRs and ]
TU Electric' design deficiency reports'(TDDRs) which had been
~
j
, dispositioned prior to the issuance of' Nuclear Engineering and
j
Operations (NEO) Procedure NEO'3.05, " Reporting and Ccntrol'of
Nonconformances," which became effective on December 22, 1986,
1
The Epplicant.has informed the NRC that the program is being' ,
'
implemented.in three phases. Phase one, the screening of NCR
and TDDR' dispositions, has been inspected by the NRC and the
results reported in the above referenced report.- NRC
inspection of phases twe and three was conducted during this
report period. The results of the NRC inspection follows.
-
l
l- _
'
3
-
!
.. . ,
4*"
k.7
. y M. - l' %ba- 3 4
,
,
-
.
,,
t
, 1
- "
.: / i- ,, -q
<
"" 23L ' '
@
' ^
,
w ,
,
9 - :l
1
'
,
'
'Asistated_inLStonejand Webster Engineering. Corporation (SWEC)~ d
'
' proj ect i Procedure J PP-041', L phase < two of : the - program -required '
'
SWEC/to_ evaluate the technical adequacy of~NCR and TDDR. .'
'
dispositions.which have been: determined by the' phase one '
screeningJto involve engineering requirements. -Those NCRs and
TDDRs.found to be in the scope of other engineering validation
. efforts are to be evaluated by those groups. . The.NRC
-inspector reviewed 20 NCRs.and 20'TDDRs from the phase two'
evaluation.toLverify that the SWEC review had~been-properly.
l] j
,
. perfor'med.' The following items were addressed byuthe SWEC ,d
- . review and were documented on SWEC NCR Technical Review q
Sheets.' ,j
>
L ( a)' Is the statement of nonconformance adequate?
]
~(b) _Is the disposition. classification' correct? I
-, -)
(c)
'
'
Does"the disposition fully address the nonconforming
condition?
(d) ,Is a tochnicalireview (by SWEC) required? l
1
(e) Is.there sufficient documentation to support the 1
disposition? {
-
1 '
~(f) Is'the rationale of the disposition technically correct?
,
-(g) Is the disposition adequate?
'
.The NRC inspection results,showed, that.with one exception,
SWEC had correctly performed the phase two review. The ,
p7 exception occurred in the review of NCR M-13186. The SWEC 1
review had' classified the disposition of that NCR as " repair" 1
and had provided additional. justification for the disposition. '{
The NRC inspector's review found'the proper' disposition
classification to have been " rework" and that no further ,
justification was required. The NRC inspector determined that I
the error was not significant since the error was conservative l
in providing additional.justificablon. All other attributes
of the SWEC phase.two review were found to conform with
procedural requirements. . .
The' third phase of the SWEC review consists of the resolution
of disposition inadequacies identified by the phase two
review.- The NRC inspector reviewed the actions ~taken by SWEC
for six NCRs. The actions taken were found to be appropriate.
i
No violations or deviations were noted for the'SWEC NCR j
review. Further inspection of the corrective actions taken
for SDAR CP-86-48 are planned including additional inspection
'
of the-SWEC NCR review program and inspection of actions taken ]
r
'
L.
E_=
= _ - - - _ .
.
py
-
m
.
,
.. .r
4 24
'
l
'
'
,
.
.
i
, for those NCRs. determined to be in the scope of other j
,
. engineering validation efforts.
During the above inspection of the SWEC phase two review, the'
NRC inspector identified concerns relative to NCR M-2320,
Revision 3.. NCR M-2320 documented several problems' associated
with the installation of hold-down. bolts for the Unit 1 and 2
Y The' disposition of NCR M-2320, Revision.3, required'that for ]
the 3"' steam generator hold-down bolts:
(a) Bolts with gaps greater than .010 inch shall be shimmed.
(b) The tabs on stainless steel shims shall be held up
against the bolt head with 3/4" wide-carbon steel banding
The banding shall be tight enough to prevent removal by I
'
hand.
(c) A copy of the material documentation for the shims shall ;
l be attached to the NCR.
Disposition of NCR M-2320 was completed and verified complete
by QC inspection on November 25, 1981.
Contrary to the disposition of NCR M-2320, Revision 3, the NRC i
inspector found the following not accomplished during a field !
inspection on September 11, 1987: (1) shims required to be i
installed under two of the Unit 2 steam generator hold-down i
'
bolts were found to be missing; (2) banding required to be
~
installed to hold the shim material in place for the Unit 2 ;
steam generator. hold-down bolts was found to be missing from
two bolts and was improperly placed for an additional six
bolts; (3) documentation of the shim material identity was not i
included in the NCR M-2320 package as required by the NCR ;
disposition.
These problems have been documented in this report as a
violation of Criterion XVI of Appendix B to 10 CFR Part 50
.
(445/8718-V-02; 446/8714-V-01).
The NRC inspector had other concerns relative to NCR M-2320
and the installation of the hold-down bolts. The concerns
'
were: (a) was the installation of shims to make up the gaps
under the hold-down bolts reviewed and approved as a design ;
change; (b) was the installation of shims identified or
incorporated into the original design document; and (c) was
the heat treatment and mechanical testing performed on the ~,
bolt material in accordance with the design requirements.
These concerns have.been expressed to the applicant and are
considered an unresolved item pending the further inspection
(445/8718-U-03; 446/8714-U-02).
I
1
)
_ _ _ _ _ - - _ _ - a
_ _.. . ________ _-
. .- t
25'
[
'
5. CPRT ISAPs
)
a. Plug Welds (ISAP V.d) (37050)
Third Party to Provide Overview of Reinspection Effort. l
(NRC Reference 05.d.08.00)
The NRC inspector verified, by review of the ISAP working f
i
l
files, that the Third Party (TERA Corporation) had
performed the following activities during implementation
of the ISAP:
.. Review of action plan and Sample Selection,
i
. Review of Past Initiative and Evolution of Plug Weld
Issues.
. Evaluate QC-Inspection Methods & Documentation 1
Requirements. l
. Review of TUGCO Engineering Evaluation..
!
. Recommend Procedure Changes if Applicable.
i
. Preparation of Results Report.
t
~
. . Evaluate-Cause and Applicability. !
!
The NRC inspector, verified that TERA had performed an I
adequate review of the above activities and no further
NRC inspection is planned,
k
However, it should be noted that TERA initiated j
Discrepancy / Issue Resolution Report C-0097, Revision 0, ;
.to document the lack of clarity and consistency in l
criteria (design and construction) for unused holes in j
cable tray supports, cable trays, and conduit supports.
l
9
These issues are being evaluated and are to be resolved i
by TERA upon completion of DSAP VIII, and through the f
implementation of the post construction hardware l
validation program (PCHVP). )
b. Audit Program and Auditor Qualifications (ISAP VII.a.4)
(35060)
l
Resolution of Identified Program Deficiencies (NRC
Reference 07.a.04.03)
Section 5.3 of the ISAP VII.a.4 Results Report (RR)
summarized all of the audit. program weaknesses identified
during implementation of ISAP VII.a.4. The findings were
'
,
__ __ _ . _ . _ _ _ . _ _ _
, -
e . .. ,
'
26 l
> 1
i
. documented as program deviations and-were' transmitted to f
E TU Electric for corrective action. Each'of the program 'l
-deviations were evaluated by;the-CPRT to determine if j
- actions beyond those alreadyfrequired by ISAP VII.c, !
" Construction Reinspection / Documentation Review Plan,"
were necessary. 'The CPRT concluded that, "Although audit
program deviations and weaknessesfrelated to construction
activities were identified, it has been determined that. f
no action is required beyond that specified in
ISAP.VII.c." (ISAP VII.a.4, RR Section 5.5)..
]
The NRC inspector reviewed each of the 14 program
deviations identified by the ISAP VII.a.4 Results Report j
"
and determined they do not identify any concerns for
s
installed hardware. Since no hardware concerns were i
identified, the CPRT determination'that no additional '
hardware review programs other than VII.c were required.
is proper.-
The CPRT provided recommendations for each of the 14
' deviations. The applicant has notified the NRC that all
of the CPRT recommendations for ISAP VII.a.4 had been
evaluated and that the appropriate procedures and ,
i
programs had been revised. The NRC inspector has
verified by inspection each of the actions taken by the ,
applicant.. The actions included: (1) amending the CPSES ~
EFSAR-to define the responsibilities of the audit program;
(2) revising the corporate QA program and the site QA
plan to include the requirements of ANSI N45.2.12-1973
regarding access of audit personnel to facilities,
documents, and personnel necessary to'the planning and 1
performance of the audit; and (3) revisions to the
implementing procedures to address specific issues such
as annual performance of vendor audits and timely follow
up.for audit deficiencies. The NRC inspector determined. ;
from the inspection of the program revisions that i
TU Electric had properly responded to the recommendations
and.that the 14 program deviations were resolved.
No violations or deviations were noted during inspection
of Reference 07.a.04.03. No further inspection of this
reference item is planned. l
1
1
i
!
l
l
l
4
-
. 4
27
,
c. -Pipe Support Inspections (ISAP VII.b.3) (50090)
This Action Plan is to be Conducted in Accordance with !
Existing Procedures and Inspector's are to be Qualified I
to Applicable Procedures and ANSI N45.2.6. (NRC Reference !
07.b.03.12), and Additional Procedures to be Developed as j
Re_ quired (NRC Reference 07.b.03.13)_ j
Where tests and or inspections require the use of !
certified inspectors, qualification certification was to
the applicable requirements of ANSI N45.2.6. Third-party i;
, ~ inspectors obtained from'outside sources.such as
Scientific Applications International Corporation (SAI), fW
Butler Service Group, SWEC, and Daniels Quality &
I
Technical Services, were certified to the requirements of
their respective organizations which included ANSI
N45.2.6. All third-party inspectors were trained to the
b requirements of the procedures developed'under this j
program plan. ]
Records for certifications, qualific&tions, and training i
are retained by ERC and include the following: resume,
eye examination, education, ERC certificates, site
certificates, training, required reading, prior
certification, and prior training.
1
'
Inspection procedures developed for this plan are QA/QC
Review Team Quality Instruction QI-037, " Reinspection of
Pipe Supports; TkT Issues - Pipe Supports in Room 77N,
Safeguards Building, Unit 1," QI-058, " Reinspection of {;
Pipe. Supports; TRT Issues-42 Pipe Supports," and QI-061,
" Documentation Review of TRT Issues-42 Pipe supports."
No further procedures were developed or required. The
NRC inspector has reviewed the ERC files for these items
and as a result of his own inspections concurs with the
ERC results. NRC inspection of these reference items is
complete. g
6. Review of Allegations (99014)
(Closed) Allegation (OSP 87-A-0080): It was alleged that the 1
'
electrical Paper Flow Group (PFG) was releasing to the field
documentation packages that were incomplete, out of date, and l
incorrect, due in part to a lack of effective personnel l
training. -
The purpose of this inspection was to assess this allegation
'
and to verify implementation of the electrical PFG programs
for the initiation, preparation, and issuance of document
packages (DPs) required for electrical construction activities
on Units 1 and 2. The NRC inspector reviewed PFG activities
from December 15, 1986, to the current time. This time period
_
e
y ,y - 7
-
,
- ~ - - - - - - - - - - - ----- - - -
4
'
J i ;.
..
b' '
28. q
'
1
4
)
,
L
corresponds to tbne of .the 'alligation and the consolidation' of
, .
.the separate Unit'1 anda2 t PFGs into'one PFG.
y- + s-
,
.The procedure governing PFG activitiesLwas CP-CPM-7.1',
4
"
i
L Revision 3, dated December' 12, 1986) " Package' Flow Control,"
L -including ~ appendices. Provided below is'a summary of the PFG-
.
process for1the initiation, preparation, and issuance of ~
N construction-DPs, the method used by-the NRC to inspect-the ]
PFG process, and-the inspection results. i
i
a.: Summary of the'PFG Process-
~ (1). Initiation of Construction' Document Packages - Each
~e lectrical. design ~ disclosure document,.such'as, new i
- drawings, DCAs, or NCRs, all'of which affect' design, 4
are reviewed by the PFG design review group. This- 1
~ review is to. determine if DPs.are required to be !
prepared'for new or additional construction and
j . inspection'to implement'the design document. This i
'
freview is' performed.in accordance with CP-CPM-7.1J
(Appendix J): Revision.1, dated January.8, 1987, .
- " Review of Design Documents," and documented ~on l
Design Review-Sheets-(DRSS), Attachment 1 of i
CP-CPM-7.1J. .The'DRS identifies, among other.
things, components affected, type of design
' . document, discipline, and if any backfit'_.is
required.- Initiation-of a DP is accomplished by j
forwarding the applicable DRS to thelrespective E
Unit 1 or Unit 2 PFG coordinators. 3
'
(2) Construction DP Preparation - The Unit.1 and Unit 2: 1
,
PFG' coordinators use the DRS as the basis'for DP' E
preparation, which is performed in accordance with !
'CP-CPM-7.1A (Appendix A), Revision 3, dated !
December ^15, 1986, " Documentation Package
,
Preparation," and CP-CPM-7.1B (Appendix B), ,
" Electrical." These procedures provide the type of !
documents the DP should consist of, such as, COTS, l
-( startup work permits, irs, Weld Filler Material i
Logs, Weld Data Cards, repair process sheetst
drawings, DCAs, electrical cable cards, chScklists,
and/or construction work orders, and a package
inventory card (PIC) which itemizes documents "
contained in the DP. Upon completion of the DP, it
is transmitted'to the'PFG Distribution Satellite
(DS) to be-filed until the DP is requested by the
organization responsible for the field activity.
4
(3') Issuance of the DP to Field Personnel - Prior to the
issuance of the DP to the field, the DP is checked
against the PIC by DS personnel to assure the
required documents are present and to the current
8
!
^
l
1
= _ - _ _ _ . . _ _ _ .1
_ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ .
x.
-
'
.
29
revision. A copy of the PIC remains with the
~
package'at all times and the original PIC is filed
i in the DS. Upon return, the package.is inventoried
again to assure all documents issued are returned.
As documents are added to the DP or revised,'both
the original PIC and the copy are updated by DS
personnel.-
b. Inspection Methodology :
The NRC. inspector developed an inspection plan and
checklist which detailed requirements identified in I
o CP-CPM 7.1,'7,1.A, 7.1.B, and 7.1.J for the-initiation,
l- Preparation, and issuance of construction DPs. Further,
i
'
documentation of the training given to PFG personnel was
inspected. To verify-implementation of the above -
procedures, a sample-of packages prepared from DRSs and
DPs being issued to the field were inspected. The NRC '
inspector reviewed 21 DRS8 for proper processing,.
11 packages for proper preparation, and 30 DPs being
issued to the field for completeness.
c. Inspection Results
(1) Review of Design Disclosure Documents to Initiate -
DPs - In reviewing the 21 DRSs, the.NRC found that
PFG personnel had properly identified those design
~ documents which~ required new or additional
construction and inspection activity. DRSs were
found to identify the type of design disclosure ' . #
x
document (i.e., original drawing, DCA, or NCR),
components affected, and whether a backfit was
required. Based on the review of the 21 DRSs, the
NRC inspector' determined that design disclosure
documents were properly reviewed and that the
packages were initiated containing the required
documents. .
(2) Construction DP Preparation - The NRC inspected
'
11 DPs, 8 for Unit 1 and 3 for Unit 2. Of the 11,
7 were initiated based on design changes and 4 by
NCRs or CDRs. In each DP the following types of - p.
documents were found: completed PICS, drawings,
DCAs, NCRs, CDRs, DRs, irs, COTS with associated
- documents, and other documents required by
CP-CPM-7.1A and 7.1B. From the review of the
l 11 DPs, the NRC inspector determined that the DPs
were prepared in accordance with prescribed
instructions and requirements. 3
(3) Issuance of DPs.to the Field - Initially the NRC
inspector reviewed 20 DPs to evaluate if package
Y
l
.
- _-L.____-__.-_-_- _ _ _
~s
R i
V :
':
. i
.
30 l
2
1
'
l
contents were consistent with the PIC and if the
controlled design documents were current prior to l
package release to the field. These 20 packages i
contained a total of 413 documents. Based on
inspection results of the initial 20 DPs, the sample
was expanded by 10 to evaluate package contents.for
selected documents. A total of 30 DPs were
reviewed. The mix of the first sample of 20 DPs ,
.were: 10 inventoried by the night shift, 3 night
shift packages reinventoried by the day shift upon .
package return from the field and 7 day shift 3
packages inventoried prior to release to the field.
>
In reviewing'the DPs, the NRC inspector found each
package contained the required documentation, and
that controlled design documents were of the current i
revision. However, in two packages the inspector ,
found an inconsistency between the number of d
documents listed on the PIC and the number of
documents contained in the DP. The problem was
accountability of one type of form (megger data
sheets) required in the DP that was common to EPAs,
specifically Attachment 1 to Procedure EEI-22,
" Installation of Conax Feedthrough/ Adapter Module
Assemblies for Amphenol Sams Penetrations." For
each EPA module in the DP, the package preparer was
required to insert a blank megger data sheet.
Should supplemental sheets (continuation pages) be
needed to record megger test results, the field
requested additional sheets. To determine if the
noted condition was isolated, 10 additional EPA DPs
were inspected. The contents of two of the ten DPs
were consistent with the PIC. The remaining eight
either did not list the megger data sheets on the
PIC or the number of cata sheets in the DP did not
correspond to the quantity listed. Even though
inconsistencies existed between the PIC and the ;
contents of the DPs reviewed, each still contained
the correct number of megger data sheets; one for
each EPA module, with continuation sheets as needed.
Nevertheless, a violation of CP-CPM-7.1,
paragraph 5.7 occurred which is a viclation of
Criterion V of Appendix B to 10 CFR Part 50
(445/8718-V-04; 446/8714-V-03).
Based on inspection results, it was determined the a
DP inconsistencies found were isolated to EPA DPs. {
L (4) Review of PFG Persorinel Training - The NRC inspector ,
reviewed the procedural training records (reading )
l' and classroom) for 22 PFG personnel of which 12 were j
DS personnel. In each case, each individual was
l
'
i
l I
I . _ - _ - . _
' '
fF
- .~
3 2.' ,
i
-i
, . .. .
-
l
given the. required procedural training.
',
'Furthermore,' based on interviews with PFG personnel,-
'
the'NRC. ins'pector' learned that.each new hire was ,
tgiven both procedural training and on-the3 job-
training.(OJT). 10JT occurred.untillthe-individual's.
supervisor judged that the>now' individual'was
comoetent in~ job performspee,'
(5) TU Electric audits.of the-PFG During August'10-25,
1987, TU Electric's audit group performed an audit, ;
of the Unit 1;PFG;asl reported'in, Audit Report'
TCP-87-28 dated September 9., 1987. . The scope of_the 3 i
audit was the review of botn mechanical and
electrical,DPs prior to issuance to the field and- <j
maintenance _of DPs during'the construction process.
Further, the. training records of selected PFG
personnel:were reviewed to verify that_ training of
PFG personnel conformed to requirements.- The audit- 1
identified no deficiencies. ]
In summary, during~the NRC inspection of the initiation,.
preparation,iand distribution of DPs for Unit 1 and Unit 2
activities, the following w.as found. . Design disclosure j
' documents were properly reviewed to initiate and prepare !
construction DPs. The review of 30 DPs released to the field
disclosed that'each package contained'the required ~ y
f
,
'
documentation and that controlled design. documents were j
'
current. Inconsistencies-between the PIC and DP contents were !
. identified asian NRC violation-(445/8718-V-04; 446/8714-V-03). (
Training'of~22 PFG. personnel was. assessed and found to be in- a
accordance with requirements. From'the results of this.
~
l
inspection','the NRC concluded _that the allegation that the PFG j
was releasing to.the field DPs which were incomplete, out of 1
'
'date, and' incorrect, due in~part to a lack of effective
training, was not substantiated. This item is considered r
closed. l
7. Inspection of NCR Process (35061)
This is the conclusion of an inspection which began in July g
1987 and was reported in NRC Inspection Reports 50-445/87-13; 2
50-446/87-10 and 50-445/87-16; 50-446/87-13. The inspection l
during this report period considered the NCR process
implemented by B&R under the jurisdiction of the ASME Code. ,
I
On December 22, 1986, TU Electric Procedure NEO 3.05, j
" Reporting and Control of Nonconformances," was issued for 1
implementation of a revised process of documenting and j
controlling identified nonconforming conditions.
L
L Implementation of NEO 3.'05 and NEO 3.06, " Reporting and
l Control'of' Deficiencies," in the operations and construction j
(non-ASME) areas had been inspected and reported in previous l
l
=- -
- _
l
l
. .
l
32
!
inspection reports. Implementation of NEO 3.05 and NEO 3.06
by B&R construction (ASME) was accomplished from December 1986
!
until July 1987 by procedures: ,
3
CP-QAP-16.0, " Reporting Construction Deficiencies"
CI-QAP-16.0-8, " Processing Construction Deficiency Reports"
.QI-QAP-16.0-10, " Initiating and Processing Nonconformance l
Reports"
{
,
The NRC inspector has verified that these procedures implement
( the requirements of NEO 3.05 and 3.06. The B&R procedures j
l listed above are similar to the TU Electric procedures d
(non-ASME) whose implementation was inspected by the NRC and
reported in Inspection Report 50-445/87-16; 50-446/87-13. On f
July 10, 1987, B&R revised their programs with the issuance of
AAP-1E.1, " Controlling Nonconforming Items," and AAP-17.3, '
" Deficiency Report," which superseded the procedures listed
above. Given that the NRC had previously inspected the
) implementation of the non-ASME construction activities and the
similarity to the superseded B&R tKR process, the current
inspection was directed at the implementation of AAP-16.1 and
AAP-17.3.
B&R Procedures APP-16.1 and AAP-17.3 were reviewed for
compliance with the requirements of NEO 3.05 and 3.06. These
procedures implement those requirements. The most notable of
the changes from the previous procedures was the elimination
of the CDR, its features being incorporated into the new NCR
form. The following is a brief description of this B&R
process, in effect since July 10, 1987.
Any B&R employee who identifies a nonconforming condition may ;
[ initiate an NCR. The process is initiated by the originator ]
obtaining an NCR form and completing the upper portion of the j
1
form; e.g., unit number, component and system identification,
location, documents violated, applicable ASME C, ode section,
discipline involved, and a complete description of the .
i
nonconforming condition. The originator then obtains the next
sequential NCR number (e.g., 87-A01208, the "A" being an ASME
designation) from the NCR Group-ASME (NCRG-A) and enters the
number on the NCR form. The NCR form thus completed is sent
to the NCRG-A which obtains the affected document package from l
the PFG, the NCR had already been logged in the NCRG-A {
tracking system. A B&R QE then reviews the NCR for j
.
completeness, accuracy and validity. Any problems identified )
with the NCR at this step is resolved with the originator or
i the NCR is invalidated and the NCRG-A logs are so noted. l
Conversely, the QE will approve (validate) the NCR and send it {
to construction management for proposed disposition, at the I
same time sending a copy to the Regulatory Compliance Group
for deportability assessment. Construction management ;
proposes a disposition and returns the NCR to the B&R QE for 1
- - _ _ _ - _ _ _ - - _ _ -
,_
, 0: W ,
,
<s, s
33
concurrence. Depending on the disposition, the NCR can take
one of two paths:
(a) If the disposition is " rework" or " scrap," the
disposition is accomplished, QC verifies the disposition
by inspection, the completed'NCR and applicable documents
are reviewed by the B&R QE supervisor for acceptability,
any required review by the ASME Authorized Nuclear
Inspector is assured, and the NCR is closed.
(b) If the disposition is " repair" or "use-as-is," both of f
i
which require engineering involvement, the NCR form
referenced in NEO 3.05 is generated to document the
nonconforming condition. The NCR form thuc completed is
sent to the NCR Group where it is validated, legged, and
the next sequential NCR number is assigned; e.g., CM
87-7401. The NCR is then processed as described and l
inspected in NRC Inspection Report 50-445/87-16;
50-446/87-13.
The NCRG-A began operation following the issuance of AAP-16.1
on July 10, 1987. During this inspection, the NRC inspector i
reviewed the log books of all NCRs generated since the
issuance of AAP-16.1, beginning with NCR 87-A0001 issued July
13, 1987. From these log books, the NRC inspector selected 65
NCRs for further inspection. Of the 65 NCRs selected, 29 had
been invalidated, 15 were completed (closed), and 21 were i
in-process. During t'ne inspection of certain NCRs it was
necessary to review related CDRs, NCRs, DRs, drawings, design
changes, and other documents obtained from the PFG or the
Interim Records Vault (IRV). This inspection included
verification that the NCRs were processed, dispositioned, and
closed in accordance with the applicable procedural
requirements.
No violations or deviations were identified. The following is ;
a description of certain of the items inspected that warrant j
further inspection.
NCR (, A1287: This NCR was invalidated, but it appeared l
to have involved an engineering review. If engineering !
had invalidated the NCR, this would be contrary to the i
controlling procedure. The NRC inspector examined the DP l
from the PFG and found engineering had only been !
consulted and had not been involved in the processing of )
this NCR. During the review of this DP (DO-1-090-701- j'
C65R), the NRC inspector found a form titled, " Problem
Identification Sheet." The form appeared to be used to J
document construction problems identified by craft and/or i
engineering. Another of these forms was found in a DP in ;
the IRV (DO-1-047-020-533R). The NRC inspector was able i
to obtain only limited information about the control or
l
GT l
, ,
)
'>
t 34 i
l
!
- !
use of this form during this inspection report period. l
This item will be inspected further in subsequent i
inspections (445/8718-0-05; 446/8714-O-04).
NCRs 87-A0317 and 87-A0922: These NCRs documented . l
procedural violations: (a) the ASME Aut:horized Nuclear 1
Inspector's review of a multiple weld cata card was ,
bypassed, and (b) craft removed and reinstalled items i
without QC verification before removal. Both of these ;
NCRs were dispositioned and processed to correct the !
nonconforming condition and documentation.in accordance l '
with procedures. DRs were not iniuiated, but appear to
'have been warranted for each of these NCRs since :'
programmatic weaknesses are-indicated. . These are further
examples of a previously identified violation <
(445/8716-V-02; 446/8713-V-01) and will be followed by
the NRC in this report as an open item (445/8718-0-05;
l
g
446/8714-0-05). 1
1
This report completes the NRC inspection of the NCR process
that was implemented from Dacember 22, 1986, to October 5,
1987 The process for documenting and controlling
nonconforming conditions was revised and implementation of the
revised program began October 5, 1987. The NRC inspector 1
attended two TU Electric training sessions ccncerning the
revised program. The changes appear to be improvements on the g
previous program. The most significant change appears to be l
the incorporation of the CDR process into the NCR process.
This change eliminates the CDR, which in many cases in the
. previous program was transferred to an NCR anyway. The NRC
will inspect this revised program during a future report
period.
One further observation was made by the NRC inspector that
applies to both the previous NCR program and the current
October 5, 1987, prcgram. When an NCR is dispositioned
"use-as-is" engineering involvement is required. This type
disposition is similar in many respects to the invalidation of
! an NCR, in which case NEO 3.05 requires a copy of the
invalidated NCR be returned to the originator. Such a copy is l
not'provided to the originator if the disposition is j
"use-as-is." Because of the similarities of these two types
-
of dispositions, and the potential for the nonconforming
condition observed by the originator not being found by others
involved in processing the NCR, the NRC inspector will be
' inspecting this potential further during subsequent
inspections-(445/8718-0-07; 446/8714-0-06).
l
l
-
y . 3
1
y .: i
9
8. Corrective Action Program (CAP)
The.NRC inspectors are performing inspections in order to-
verify.the applicant's activities associated with the PCHVP.
-l
The following NRC inspection activities related to PCHVP were
conducted _for the following CAVs during this report period.
a. Small Bore Pipe Supports (50090)_
The NRC inspector performed a documentation review and j
field installation inspection of the following pipe
supports _to determine whether the applicant is adequately
preparing, reviewing,~and maintaining a system of quality !
records:
Support Drawina No. Pipe Isometric No.
WP-X-AB-050-003-3 R/2 WP-X-AB-050
WP-X-AB-049-003-3 CP-1 WP-X-AB-049
SI-1-SB-023A-018-2 R/4 SI-1-SB-023A
CT-1-SB-027-013-2 CP-1 CT-1-SB-027 ;
CT-1-SB-027-010-2 CP-1 CT-1-SB-027
CC-1-SD-001-011-3 R/1 CC-1-SB-001
CC-1-SB-001-002-3 R/1 CC-1-SB-001
DO-1-DG-008A-005-3 CP-1 DO-1-DG-008A
CH-1-SB-005A-010-3 CP-1 CH-1-SB-005B
CT-1-SB-025-013-2 R/2 CT-1-SB-025
DO-1-DG-009B-009-3 R/2 DO-1-DG-009B
DO-1-DG-009A-005-3 CP-1 DO-1-DG-009A
DO-1-DG-017-013-3 R/2 DO-1-DG-017
SI-1-SB-024-011-2 R/1 SI-1-SB-024
DO-1-DG-016-003-3 R/1 DO-1-DG-016
DO-1-DG-012-030-3 CP-1 DO-1-DG-013
CH-1-SB-029-007-3 R/1 CH-1-SB-029
CH-1-SB-029-005-3 R/1 CH-1-SB-029
FW-1-SB-035-003-2 R/0 FW-1-SB-035
WP-X-AB-258-002-3 CP-1 WP-X-AB-258
CC-X-AB-011-005-3 R/1 CC-X-AB-011
FW-1-SB-035-004-2 R/1 FW-1-SB-035
FW-1-SB-026-002-2 CP-1 FW-1-SB-026 1
l
CC-1-SB-001-001-3 R/2 CC-1-CB-001
'
CH-1-SB-011-007-3 R/1 CH-1-SB-011
CH-1-SB-009B-004-3 R/0 CH-1-SB-009B
j During inspection of pipe support CC-1-SB-001-001-3,
Revision 2, and DCA 5113G, Revision 0, the NRC inspector
noted that one of four high strength cap screws, item 15
(1/2" diameter x 2" long, SA-193 Gr. B7, Ht. Code #PF-33) J
had broken prior to achieving the design preload torque i
! of 110 ft/lbs. This condition was noted on the Component l
! Support Structural Inspection Report dated" July 13, 1987. l
l
!
i
N ,
,
1
-
.. ..
'
36
Craft personnel-obtained a replacement cap screw and QC
subsequently accepted ~the preload1 torque requirement for
the replacement ~ cap screw, NRC review of site Procedures
ECE 2.26-06, paragraph 6.14.2, and CP-QAP 12.17
Lparagraph 6.1.2, determined that an NCR should have been
issued-to evaluate'the indeterminate material quality.
The failure to document nonconforming material is a s
violation of Criterion XV of Appendix B to 10'CFR Part 50 l
(445/8718-V-08).
>
During inspection of pipe support WP-X-AB-050-003-3, the ;
'
NRC inspector noted that the Hardware Validation Program I
Adjacent Weld Checklist had been completed and accepted 1
by QC, This checklist is required to be completed when
the configuration of the support is such that the pipe
may move axially, independent of the support movement. i
For this pipe support design, QC was required to field ;
verify that a minimum of a 2" distance exists between the j
'
outer face of the restraint and any adjacent socket
welded fitting or circumferential piping butt weld. This
inspection criteria was incorporated into the
construction operation traveler to implement corrective
action in response to CAR-96X.
The NRC inspector was unable to field verify the required
adjacent weld distance of 2" for pipe support '
WP-X-Ad-050-003-3 due to the installation of Bisco seal
material in wall penetration No. 7003781000, located in i
Room 192 of the auxiliary building. (NRC inspection of '
pipe support WP-X-AB-049-003-3, located adjacent to
WP-X-AB-050-003-3,' revealed that Bisco seal material had
}- ,
been removed from wall penetration No. 7003881000 to
permit the required adjacent weld distance inspection.)
The inspector who documented the inaccessible attribute l
as " satisfactory," and his supervisor were contacted in q
order to discuss the inspection results. The inspector i
stated that he could not remember performing the I
inspection. The inspection supervisor replied that a j
review of the manufacturer's record sheet for the piping !
spool section passing through the penetration might have
been the method of verification used by the inspector. j
-i
Site Procedure ECE 9.04-04 requires that final acceptance i
attributes be validated by field verification or
engineering evaluation. If an attribute is found to be l
inaccessible during field inspection, it shall be subject i
to engineering evaluation. By not documenting the 4
adjacent weld distance attribute as being inaccessible, I
the required engineering evaluation could not be
performed. This failure to document the existing
condition of an inspection attribute is a violation of
]
l
l
!
- - - -
ny n: ,,
'
' >
'
, -
m-
.a , , ,
'
>
<a .'
b; .c . $' .!* ' l ',? \ .tl e
l5 >
s _
- 'jflf '
'
[f , ,
.h
i:;
Q
'
37,
4
>
j '
,
'
3l
'
, ' y ... .p c
' ;
- Criterion c X Lof; Appendix 'B .toi.1'0"CFRIPart L50 Linspection . '
~
E ,
requirements'(445/8518-V-09).
'
d The'NRC1 inspector' discussed the twoLviolations'with.
TU Electric site: personnel 2pri'orfto the exit' meeting. DR
'
.C-87-3884'was issuedito document theiviolation of
l validation requirements f or an' inaccessible %attrAbute. "
N> . 'DR C-87-3885:was.issuedito document the violation'of:
2
nonconformance reporting requireme'nts7for the broken cap. q
screw.- i
L;
b. : Conduit 1 Supports A &~B Train a5d C Train > 2" '(48053)'
n . .
'
X
'
During this inspection periodb the NRC' inspector selected !
a sample.of1eight' completed conduit walkdown-packsges to :!
. verify the.accuracyiand' correctness of the'EBASCOh . l
~
collected data. The following is a list cf the NRC
~
l
Linspected packages:
'
.' Conduit No'. ' Size ~ ~
Room * Area ** Number of ~
]
Supports '
-i
V n >
, C12G03522- 1" 66 SG1 6
C13G07686 1" .
155A RB1 9
,
Cl3G12434 1 1/2" 100A. SG1 5
C13K08062 3" 96/103 .
SG1 ~B
C13006009 -3/4" 154/155A RB1 8 ")
Cl3011615 5" 133 ECB 4 >
m C13017936 1" 74 SG1 7
C13019932- 2" 155A RB1 15
- ECB -Electrical / Control Building
- ,, .
RB11- Unit l' Reactor Building
'. SGl.- Unit 1 Safeguards Building j
', ** Number of supports includea conduit, junction box, and
pull box supports. , ;
The NRC inspector's walkdowns were performed while ;
adhering tofthe critaria of the appropriate' field i
verification method (FVif). Even though certain data j
recorded by the NRC inspector may not have matched that l
recorded by the"EBASCO field'walkdown engineer, it was- !
'
O deemed to be acceptable since the difference in recorded I
dimensions was still within the tolerances specified in j
the applicable FVM.
'
While performing the walkdown on conduit run C13006909, ,
the NRC inspector noticed that the size of a type LBD l
condolet (LBD) was incorrectly recorded by EBASCO during
their walkdown. This pertained to the LBD located at the
conduit bend at elevation 833'. The conduit isometric
1
_ _ .
p % ,
7
k. -
..
)
38
2
i
<<
1
showed the size of this LBD to be 3/4"; however, the NRC
inspector determined it to be 1 1/2". The ramifications 3
of an error of this nature'are that an incorrect lump -
mass would be utilized by EBASCO's design verification i
group (DVG) when seismically analyzing the conduit run.
In this case it would yield nonconservative results.
When notified of this finding by the NRC inspector,
EBASCO did'some research and then conveyed to the NRC
inspector that'when the DVG analyzed this conduit run,
the correct LBD size was used. The NRC inspector was
'
infornted that subsequent to the field walkdown and prior
!
~
to vaulting the conduit run package (DVG will have access
to a conduit run package after it has been vaulted), the
TU Electric Civil Construction Engineering Department l
informally reviewed the conduit isometric in the field.
This review was performed by electrical craf t and checks
for span lengths, bend radius, and other critical
' dimensions that may be necessary if the conduit is to.be
reworked. It was revealed during this review that the
incorrect LBD size was depicted on the isometric. The
NRC inspector was also informed that subsequent to
EBASCO's field walkdown and prior to vaulting, all
conduit runs within EEASCO's scope will undergo an
informal review of this nature. Upon discovering that
the incorrect LBD size was indicated on the isometric,
the civil construction engineering personnel entered the
correct size on the isometric. Therefore, at the time of
final vaulting of the package, the correct information
was contained on the isometric. I
NRC review of the isometric and the EBASCO DVG
calculation package confirmed that the appropriate size
LBD was utilized during the analysis of the conduit run.
No violations or deviations were identified.
c. Conduit Support'C Train Less Than or Equal to 2" (48053)
i
During this inspection period, the NRC inspector
completed the review /walkdown with respect to4 Impell's
scope of work in Room 206 and Room 54 in the Unit 1 i
!
safeguards building. The NRC inspector had initiated the
inspection of Room 206.during the last inspection period.
Room 206, Unit 1 Safeguards Building
The remaining scope of Impell work that the NRC inspector
reviewed in Room 206 involved Level 5 (Seismic Dynamic
Analysis) walkdowns/ engineering evaluations and the ;
performance of a final room walkdown to determine if any j
i
Train C conduit, within the Impell scope, had been
inadvertently omitted from their review. The following
1
I
_ _ _ - _ .
I
ff;: ' '.Qy . Q ^ , %,
w j y:y ; (;. na '
9
p yw vn ,
-
,
-
~
.
t ,
. . .
Q.?
'
'l' ' '
' '
T
l .;
,
-
}
o , w, '
' '
"
" ,' s , .
39' d
'A ' 4
.M i.t
\' '
7
L
,
'
pp
i
x.. ,
- "
b" , ? calctilation'/.walkdown packages ' completed' the ' NRC . -
ii
Lp ' , 4
l inspector'sJreview:of4 Room 206: .
<>
V t , l
p @; a
- Calculation No. ,
,.
, Title)- a_
'
I
,
,
.
.1
l
I f
,
,
l, a- ' ' ,
1 iA-02851- Level 5fsupport Evaluation
l' 46 'A-02938" ? Level'5 Support Evaluations ,
,
Level ~ 5 ~ ~ Support' Evaluation t Lj
'
E
2
.A-02950 -
, ,
- . 'While performing the-field walkdownTon conduitGrun
AB3-14,36,Ewhich.was'asscciated with calculation: ;
' ' No.o A-02950, '.'Levelf 5. Support : Evaluation," the NRC - i1 !
.
,
Linspector identified-the"following1 discrepancies with' :!
Y1 W >
.
regards.to the Impell walkdown:
i
~<
(1).'For analysis. tag A-03173,fImpell had. incorrectly .
1
-recorded thellength designator on the<end.of:a.1/4"
, ,
diameter Hilti Kwik holt asfan'"E" stamp
-( 3 ' l/ 2" long) ~. . The.NRC inspector observed the- .
i length designator tolbe a'"D" stamp.(3" long). -
'An' :j
Lerror-of this' nature could be' detrimental-when' -
!
determining what Hilti Kwik boit allowable loads.to
]j
,
t
utilize'during the conduit support analysis and
whether the Hilti Kwik bolt minimum embedment is i
met. 1
(2) For analysic tag A-03173, Iit: was determined cduring
,the'NRC inspector's inspection that an~1/8"Lgap
exists betweansthe 3/4" diameter' conduit and the
conduit support shim plate. This was'not; detected
during.the Impell walkdown. Further review of.the
'Impell conduit. support : analysis by .the cNRC inspector
revealed that this particular-support.was analyzed j
'
as a three-way restraint (vertical, longitudinal,
and axial directions). 'With the existence of this !
gap, the conduit support'would.not be effective as
an axial restraint. Any analysis where this j
three-way sripport was included would be affected, i
3
'
(3) For analysis tag A-03177, Impell had recorded that
the projected length of the 1/4" diameter'Hilti Kwik'
bolt (distance from the surface of the concrete to .
I
the end'that protrudes out) was 3/4". The
,
subsequent NRC inspection determined this length to
be 1 1/8". An error of this nature could be
detrimental when determining what Hilti Kwik bolt
allowable' loads to utilize during the conduit l
support analysis and whether the Hilti Kwik bolt (
minimum embedment is met. l
I
~ i;
)
.l ;
_ _ _ _ _ _ . _ _ _ . _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ . _ _ _ . _ . _ . _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ . . _ _ . _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .____..____.____________]
- _ , . . .
_
-
)
N f it *
.
I j
l
5! 40 l
l
i
These three examples of Impell's failure to accurately. l
' identify existing. conditions constitute a deviation .!
(445/8718-D-10). j
i
The final room walkdown by the NRC inspector did not
identify any Train C conduit or supports less than or
j equal to 2" in size that had been inadvertently omitted
by Impell'from their scope of work. ;
Upon notification of the three NRC identified l
discrepancies,.Impell implemented corrective actions and 1
actions to prevent recurrence. These actions were ;
transmitted to TU Elecnric on September 25, 1987,.via- 1
Impell memorandum IM-T"0210-052-412. The following d
describes the contents of the memorandum. ]
(1) Corrective Actions,
Malkdown forms and calculations have been revised to
reflect the NRC identified discrepancies. The l
qualification status of the conduit support was not d
J
affected; i.e., supports are still good.
(2) Root Cause'of Finding
Since all three discrepancies.were on one,walkdown
package, they could be attributed to one team of 1
walkdown engineer / checker. One of the involved is ~{
no longer on the project and was involved in only i
six other walkdowns, while the other, who is still i
on the project, was involved in 39 additional )
walkdowns. This was, however, the only walkdown in j
which the two were involved together. l
(3) Generic Implications of Finding
Three additional walkdowns for e.ach of the two
involved individuals were randomly selected and
Impell performed a complete rewalkdown. No
additional discrepancies were discovered and it is
concluded by Impell, that this was-an isolated case )
with no generic implications.
, (4) Actions Taken to Prevent Recurrence
All Impell site personnel who are involved in the
Level 5 screening process have had a subsequent
documented training session in which the importance
of documenting walkdowns accurately was emphasized.
At the present time, the NRC inspector has not verified t
nor reviewed the above mentioned actions implemented by
_ - _ - _ _ _ - . _ _ _ _ _ _ _ -_
f'
i
s
, l
C
y ..; . .
'
41
1
This will occuriduring a subsequent inspection
-
i
Impell.
period. , i
Room 54, Unit 1 Safeguards Building
i
The scope of Impell work for this room involved Level 5
support walkdowns and engineering evaluations, Level 2
(Support type) and Level 4 (Seismic l Capacity versus
Seismic Demand check) evaluations, and conduit support
modifications. The following calculation /walkdown . i
packages relevant to Room 54 were reviewed by the NRC'
inspector:
,
Calculation No. Title
L2-S-1-SG-54 Level 2 Conduit Support Evaluation (
L4-S-1-SG-54 Level 4 Conduit Support Evaluation
, A-03138* Level 5 Support Evaluation
A-03139* , Level 5 Support Evaluation
A-03142* Level 5 Support Evaluation
A-03443* Level 5 Support Evaluation
A-03448* Level 5 Support Evaluation.
A-03451* Level 5 Support Evaluation
A-03452* Level 5 Support Evaluation
L6-1-SG-54 Level 6 Train C Conduit Interaction '
1
Evaluation
0210-C13K14438-01* Train C Conduit Support Deletion
0210-C14K30965-02* Train C Conduit Support Modification
Calculation i
0210-C14K30965-01* Train C Conduit Support Modification
'
Calculation-
RCO-1-SG-54 Room Closecut Calculation /
Documentation
- Denotes those packages where engineering calculations in
conjunction with field walkdowns were required by the
Impell project instruction,
i
While performing the field walkdowns, the NRC inspector 1
identified the following discrepancies with regards to
the Impell walkdown:
(1) For calculation A-03451, Impell had recorded on'RFI j
'
No. RFI-E5-1-1043, that Hilti Kwik bolt No. 1 was
located 4 1/2" from the top edge of the Unistrut
channel. The NRC inspector, however, determined the i
bolt to be located 3" from this top edge. The 1
allowable: tolerance specified in Table 1 of Impell j
Procedure PI 021-052-004 was 1/4". j
l
(2) For calculation A-03138, Impell had recorded the j
projected length of the 1/2" diameter Hilti Kwik l
l
I
!
1
-- -w _ _ _
,_ _ _ _ _ _ _
7 -- ,
g "' ,' 3..
, , ,
'
<tV
M:
(
e c,...v . ,
t
'
g 42"
L* <
.
.-
~~
\
x ;) -
'
t : ,- . .
F
" '
' boltL(distance from.the' surface of"the'concreteito
!! lthe end'that: protrudes.out)'for; support'
k -A-03145/NQ-08290 wasDl"h The subsequent NRC, ,
f '. p ~walkdown, determined this' length to'be 111/2"; . : The 1
- .specified' allowable tolerance from the above
, ,
mentioned. Table'l is 1/4". LAn error of this nature
"
could:be: detrimental when. determining what Hilti' 4
'
l' ' '
' Kwik bolt; allowable loads to utilize during,the
' conduit ^ support analysis'and.whether the'Hilti. Kwik'-
,,
. bolt minimum embedment is met.
,
.
These two findingsLare additionallexamples of deviation
(445/8718-D-10).f ' .
.The~finalLroom walkdown by the NRC inspector:did-not- ,.i
identify any Train C conduit or supports less.than or' H
i
,
aqual to 2" in size that.had'been inadvertently omitted
from the-initial walkdown. . q
9. -Visual ~ Examination of Welds ~(57050)
i
For a: description of'this program, including the: criteria'used
to establish the 11' separate population groups, see'NRC !
Inspection Report 50-445/87-16; 50-445/87-13. I
i
The inspections of. coated welds are being performed toLaid.in
- the: resolution of .outstandingfissue No. 38 ( Application of
];
-visual weld. acceptance criteria to' coated welds) identified in
Safety Evaluation Report Supplement No. 12. This' activity is-
being implemented by Procedure CPE-SWEC-FVM-ME-102,
" Reinspection of. Coated Welds Quality Control Reinspection."
Deviations'from weld inspection requirements will be j
documented'on NCRs per NEO 3.05, " Reporting and Control of i
Nonconformances."~ Dispositioned NCRs will be reviewed by the
NRC. inspector after' completion of the-weld inspection program.-
During this report period, a single weld joint on each of the
following supports was examined by the NRC in the delineated
condition:
Conduit Supports Before and After Coating Removal
C22G08183-01 C23G10002-01
C23G28511A-01 C23G06150-03
,
Conduit Supports Before Coating Removal
E
C22G08133-01 i
!
1
L L . -- a
{y"? =~ l
F -
i
. .. .
43 i
)
Chble Tray Supports Before Coating-Removal 1
i
CTH-1-3959 CTH-1-6127
' Pipe Supports Before and After Coating Removal
i
CC-X-116-012LA75R CT-1-057-031-S53R
CC-1-138-711-A63R DO-1-023-703-S43R
BR-X-035-700-A53R DO-1-DG-007-016-3 J
WP-X-157-001-A55R DO-2-DG-007-009-3
CH-1-AB-024-011-3
Pipe Supports Before Coating Removal ,
1,
CS-1-079-017-C42R
Pipe Welds (GTAW) Before Coating Removal ,
VA-X-AB-019-FW-2 CC-1-EC-013-FW-17 q
VA-X-AB-024-FW-2 MS-1-SB-007-FW-28A
GH-X-AB-066A-FW-9A AF-1-SB-010-A-FW-17
No violations or nonconforming conditions were observed.
10. Plant Tours
,
The NRC inspectors made frequent tours of the facility and
observed such. items as in-process work activities,
housekeeping, and equipment protection. The following
observation was considered significant and was brought to the
applicant's attention:
Emergency Diesel Generator (EDG) (51053_1
On September 23, 1987, the NRC inspector observed two
capacitors with their leads soldered together and then
connected to panel wiring by preinsulated splice connectors.
These capacitors were located inside the Unit 1,_ Train B, EDG
control panel. The inspector verified that a similar
condition existed in the Unit 1, Train A, EDG control panel,
but upon inspection did not observe the capacitors in the Unit
2 EDG control panels.
Since the capacitor installations did not appear to the NRC
inspector to be a permanent type arrangement, the inspector l
requested information from applicant personnel. On September i
29, 1987, the inspector was informed that no information
existed to explain the capacitors, but the applicant assumed !
' that they were installed by the EDG vendor; Test deficiency l
report (TDR) 5597 was written to document this situation. !
This is an unresolved item pending further explanation by the
applicant of how and when these capacitors were installed and l
u___
v y
a
x
l
. r e. , i
s
44
i
,.
_E'
verification that they are qualified for this installation
'(445/8718-U-11).
11. Site Audit
.During the week of' September 8-11, 1987,1D. Terao of OSP-HQ
staff and NRC consultants reviewed the as-built process for. ;
HVAC, cable tray hangers (CTHs), and conduit supports at the
For HVAC, the staff (D. Terao) and consultants from Teledyne
Engineering Services (R. Wray and R. Rose) reviewed the
as-built procedures.and their implementation related.to HVAC
in-line equipment such as plenums, air handling units, and
fans. They also reviewed the QC inspection procedures and ,
process as defined in FVM-CS-029 for HVAC duct systems.
For CTHs-and conduit supports, the staff (D. Terao) and
consultants from Brookhaven National Laboratory (P. Bezler, G.
Breidenbach, G. DeGrassi, and J. Braverman) reviewed the
as-built procedures and their implementation related to the
development of red-line drawings. .A sample of CTH and conduit
'
supports were field inspected.
The purpose of the reviews was to ensure that the as-built
drawings' identified all important attributes needed by CAP
contractors to adequately perform their design verification ,
activities. Staff firiings will be included in a supplement
to the CPSES Safety Evaluation Report upon completion of staff ,
audits,
t
12. Management Meetings (30702) j
On September 16, 1987, J. G. Keppler, C. I. Grimes, and R,c F.
Warnick met with M. D. Spence and W. G. Counsil to discuss !
current plant status, progress of construction, the schedule {
for completion of the CAP and the PCHVP, and other topics of
current interest. l
1
On September 16, 1987, J. G. Keppler, C. I. Grimes, and R. F.
Warnick met with J. W. Beck, J. D. Redding, J. L. French, and
other Senior Review Team (SRT) members to review results of ,
I
the CPRT/SRT and third-party independent inspections.
13. Other Significant Meetings (30702) l
On September 30, 1987, R. F. Warnick and C. J. Hale met with
J. L. Hansel and D. Boydston to discuss the handling of .
"other" kinds of documentation of nonconforming conditions. j
On October 6, 1987, R. F. Warnick met with W. G. Counsil and
L. D. Nace to discuss NRC concerns arising from September
l c
1
L__
'
![f "' ' ;, y j; q
'
, , , ,, ,
m
~ *
qw *
,
. ;, .. :c 3 ,
'
- jf- fe ' ' l
'
-
.
.
.
,
+ '
u
'
, , .
. ~4 5
,
'l .
.r ,
.;
n' > ' W
.,
' .
'.
"
,
^
inspection findings. -These; concerns were again' expressed?at
3 ithe exit meeting (see paragraph 1.5).; .
.
,
,
,
I '
14. ' Unresolved' Items ,
<l
l
a Unresolved items are matters.about which more information'is 1
'
PJ 0 required"Jn order to. ascertain:whether they.are_ acceptable
5 - 11tems, violations,: or1 deviations. Two unresolved items o -
jl
l r w Tdisclosed'during.the inspection.are' discussed in >
, paragraphs 4:and'9.
"
15. .Open Items
.
Open <iteras are fmatters which have 'been discussed with the
! licensee, which will_be reviewed.further by the: inspector, and'
.wnich involve some action on the part'of the NRC or licensee
or both.. Open items 1 disclosed during the inspection are
discussed!in paragraphs-3 (one item) and~7 (three items).
..
16. Exit Interview (30703)
>
1
e An exit-interview.was conducted October 6, 1987, with the 1
. m applicants representativesLidentified in paragraph 1 of this
report.-
.
!
During this interview, the NRC inspectors summarized the scope- l
andifindings of the inspection. The applicant' acknowledged 1
the findings. l
At:the-conclusion of the exit meeting, R. F. Warnick 1
. summarized the months inspection efforts (also see NRC
Inspection Reports. 50-445/87-20, 50-446/87-16; and-
50-445/87-21).- The7following points were made: (a) InLthese l
three. reports, 44 items were closed and 13 items were opened.
Although~this represents 'an improvement in the NRC rate of
closure of open items, the NRC inspectors are limited by the
- number of open issues that the applicant has ready'for
closure. '(b) For the most part the September findings reflect
1
current problems which were identified by the NRC. (c) Some
of the findings reflect poor work by applicant and contractor
staff. (d) Other findings raise questions about the
appropriateness of the applicant and contractor documentation
of "indetertJnate" findings. (e) Mr. Warnick also discussed
- ' TU Electric changing a commitment (in this. case changing
conduit sleeve cable fill criteria from 40% to 65%) without i
submitting an FSAR amendment or a letter to Office of Special
~
4 projects - Licensing.
>
6
-
_ - _ - -__ _ - - - - _ _ _ - _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ - _ _ - _ . - - _ - - .
- - _ _ _ - _ __-
i
~1 ( '
.
DISTRIBUTION:
. , ~ , . - , , , .
e,,:womy?
NDocket Files,L(.50e,45/n.....$7, 4 . . . . 4461;; ~
NRC PDR !
LPDR. *
.OSP Reading ,
,
-CPPD-LA
'CPPD Reading'(HQ)
- Site Reading
- CPRT Group
- SRI-OPS
- SRI -CONST . )
AD~for Projects
- MIS System, RIV
"RSTS Operator, RIV
RPB, RIV. . ,
I
RIV Docket File
- DWeiss, RM/ALF ;
JTaylor' -
'
JKeppler/JAxel' rad
CIGrimes
PFMcKee ,
JLyons
'AVietti-Cook
MMalloy
JMoore, OGC
JGilliland, RIV ;
FMiraglia i
EJordan I
JPartlow
BHayes 1
- w/766 !
!
n
i
1
9