ML20206H533

Informs of Closure to Allegation Because Person Calling in Allegation Did Not Expect to Receive Response & Did Not Leave Address

ML20206H533
Person / Time
Site:	Comanche Peak
Issue date:	09/01/1988
From:	Gower G NRC OFFICE OF SPECIAL PROJECTS
To:	NRC OFFICE OF SPECIAL PROJECTS
Shared Package
ML20206H498	List: IA-88-472, Informs of Closure to Allegation Because Person Calling in Allegation Did Not Expect to Receive Response & Did Not Leave Address ML20206H494 ML20206H517 ML20206H533
References
FOIA-88-472 NUDOCS 8811230223
Download: ML20206H533 (12)

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September 1, 1988 MEMORANDUA 70s Allegation File OSP-88-A-0051 FROM: 8eorge C. Gower Project Allegation Coordinator CPPD/OSP This allegatinn is being closed on AMS without the usual feedback to any alleger. This allegation was received by OSP site staff and follow-up was carried out aleost lesadiately. The person that called in the concern stated that she did not expect to receive a response and did not leave an address.

The substance of the concern is stated in the attacheo inspection Report, 88-51/44, page 11, which also provides the basis for closure action.

George 8ower PAC /C OSP Enclosures NRC 1R 50-445/446,88-51/47 8811230223 001110 PDR FOIA PDR DAUMAN80-472 g\

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I Attachment 1 TXX-62'85 Page 1 of 3 EQJ.[CF OF VIOLATIDH ITEM H (446/8602-V-101 Criterion IX of Appendix B to 10 CFR Part 50 states, in part, "fleasures shall be established to assure that special processes, including welding . . . and nondestructive testing, are c.oatrolled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."

Section CC-5521.1.1 of Code ACI-359, states, in part, "If the 12-in radiograph in the 50-ft long increment of weld does not meet the acceptance standards, two 12 in films shall be taken at other locations within the 50 ft. long increment .... If either of the second radiographs does not meet the acceptance standards ... the remair,ing portion of the 50-ft. increment of this wcld shall be radiographed."

Contrary to the above, the required radiography of the remaining portion of a 50' increment of weld was not performed even though one of the two second 12" radiographs (No. 146T2) at seam P84 in the Unit '2 containment liner did not meet the acceptance standards.

RESPONSE TO ITEM H (4a6/8602-V-101 We deny the 7.lleged Violation for the reasons that follow.

The film referenced in the finding,146T2, was originally evaluated by the CB&I radiographic film interpreter who determined that the area needed to be re-radiographed to clarify an area of the film. The area of interest was re-radiographed as 146T2 RSI with the radiographic source centered over the area of interest, not over the entire 12 inch length of weld contained in the original (146T2). This was done to increase the radiographic sensitivity in the area of interest and enable the CB&I interpreter to clearly evaluate the indication in the area of interest. The film (146T2 RSI) was interpreted to be acceptable by both CB&I and a Brown & Root Level III exaniner We have recently had four other personnel who were independent from the original reviewers evaluate the film. All of thes personnel are currently certified as Level Ill RT by their respective employers, and all four interpreters have accepted the film for this area. Based on the initial evaluations and the substantiation of those evaluations by our independent i reviewers, the film in qucttion (146T2 RSI) met the applicable accentants standards; therefore, additional radiography was not required. To further assure that no defects are present in the area, the paint was recently removed and the area in question was examined by ultrasonic testing (UT). This additional testing also confirmed an absence of rejectable indications.

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Attachment 1 TXX-6285 Page 2 of 3 Suno1emental Information on Related Issue Although not noted as an issue in the NRC Inspection Report, the details of the finding appear to identify an open item involving the CB&l practice of "pick-up and reshoot." The following is submitted to provide clarification regarding this item.

Radiographic examination requirements for weld seams of the containment liner are specified by Gibbs & Hill Specification 2323 55-14, "Containment Steel Liner," and Regulatory Guide 1.19, "Nondestructive Examination of Primary Containment Liner Welds." These requirements provide assurance of a uniform quality level consistent with the safety function of containment liners, i.e.,

to assure continued satisfactory welder performance.

The area originally radiographed as area 146 was rejected for slag inclusions and unacceptable porosity. Two tracer areas, 146T1 and 146T2, were .

subsequently radiographed as a result of the original rejected radiograph.

146T1 was determined to be acceptable. 146T2 was determined to be unacceptable and marked "pickup and reshoot"; however, the RT report does not note any weld defect as the reason for rejection, e.g., porosity, slag, lintar indication, etc. The CB&l film interpreter erroneously marked the RT report unacceptable. The RT report should have been marked ungradeable and further surface conditioning of the weld was necessary to properly interpret the film, and to ensure that the area of high density in the film was neither a rejectable indication itself, nor masked another rejectable indication due to its density.

ASME Boiler and Pressure Vessel Code interpretation V-77-05 clarifies that surface defects such as undercut are not criteria for rejecting a radiograph.

These defects may, however, mask or hide an internal weld defect. To remove doubt of hidden defects, C8&l's practice was to eliminate the underi:ut condition by performing "pickup." CB&I defines a "pickup" as a surface weld on materials or welds which do not require excavation to remove defective material or weld metal. The weld pass fills in low surface areas such as weld undercut, Jcars or similar surface conditions. This practice is consistent with contract requirements. The optimal time to identify and perfonn such surface conditioning is prior to the original raflograph, thereby aliminating the need for subsequet.t radiography to clarify atrupt density changes in the film.

The surface of the weld radiographed as area 146 had been visually examined and accepted by CB&! prior to radiography thus verifying the weld undercut was not greater than 1/32". Had CB&l felt that the undercut would have precluded proper interpretation of the radiograph, the surface "pickup" would have occurred prior to performance of any radiography, the film would have been graded as acceptable dJe to the lack M internal (volumetric) defects, and there would have been no additional radiography required. In this case, wjlat appears to M at iss'se is the timing of the surface conditioning because the N t A M s r , ns t Cen.+ n e a pc m ,w g. ,s. , g w,,. . ,

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Attachment 1 TXX-6285 Page 3 of 3 weld was submitted for radiography with the visually acceptable undercut present. The ability of the welder to make welds of a uniform quality level should not be at '.ssue, M r '-consi 4e<.- t . es tir e < >sse u or s s:s . . . . . : . .

To ensure CB&! did not misapply its practice of "pickup and reshoot", we have ,

reviewed all areas for which C8&l indicated "pickup and reshoot" which were  !

not subsequently 100% radiographed. In all cases, the "oickup" was required to provide additional surface conditioning to allow proper film interpretation, ,

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FDe: Boi61to Quest' >n: Cm additforu to Article 2 of SectIon V be~tande so that 1 ufacs Indicattens s

1. icetptab!c we:d unducut nr.d sctatches or pitting in pia.te re.sterial ba ac4cpuble to furn Inte 5 Reply: It ts the latent of the Code that notface tedicitfons tAat etn be shown to be s refessocing Code sunderds challt.ot be cause for tsjecuco of the isdiopsph.

Interpretat!an: Y7706

• Subjectt Sectica V.T 292,baluatlon by Manufacturet .

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. July 28.1977 .

DateIescedt ,. , . .

R: BC 76.$46

' Does T.292 of Se:tjou V isquise Code act; table flaws or defacts to be neerdad er docu Q.iciden: ,,

incated by th< manufacture 7 ,, , . .

Reply:

It is the bient of T.292 of Section V thatit requbts tist the reewd of the n:!!opsph of jtles, etc. need en!y !bt de tsdiepaph si being

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,6 THE R AOiOGR APHY COVERtc SY THl1 REPORT H A 8ttN AL. ' sTIONS H Avt ettN EVALVAf t0 tN f t Ap10F APPLi F0284t0 IN ACC04 DANCE WITH THE APPLICA8LE PR c 81 CA8e TA C STANDAAOS 1

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ve.<cm R A DtOGR APM AND E V ALV ATIONS H AVL 8 L E N P' N'0"UL U IE MY SAf a5F ACTION .

' /' R AOlOGR AP M E RISI M3. FILMS.THIS P AGt - ACCEPTED /* R JLCTto -- O O

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vette RADIOGRAPHIC EXAMINATION PROCEDURE eacc so. 4 or 10 Paoovc7 CONTAINMENT LINERS a cv. so. 8 custowca BROWN & ROOT - TUSI av CNS care _10-3-81 5.0 TECHNIQUE FOR RADIOGRAPHIC EXAMINATION: -

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'g3ghatio1).-MhNaltriople.s weldsurfac$

re at:.ttes _ onWtOi!1sJf92pg4,,gt,g (wtyere

1. pgegsib4m ,...g %AB4 hbh a'4d gree'plJibai removed,My,, thaY~ tte%radlographi9.

.tc.atnyA USB.g gask/ or be confused. with the g 5.1.1 The finished surface of all butt-welded joints may be flush with the base material or may have reasos.able uniform crown.

5.1.2 V4T8365 sea reinforcement not to exceed:9 Mb 1/8 in.

Plate Thickness up to 1/2 in.

Over 1/2 in, to 1 in.

3/16 in. ,

Over 1 in. to 2 in.

5.2 Penetrameter Placement:

5.2.1 Standard source side penetrameters shall be used.

The Penetrameter shall be placed adjacent to the weld on the side nearest the radiation source, except where the weld metal is not similar to the base material, in which case the penetrameter may be placed over the weld.

5.2.2 If configuration of area under examination prevente

, placing penetramete en source side, a film side penetrameter may be placed on the film sido, and a lead letter "F" equal in height to the identificat number shall be placed ad]acent to the penetramete 5.3 Nurter of Penetrameters:

At least onc penettameter shall be used for each radiograpr Where more than one film per exposure is used, a penetra-meter image shall appear on each radiograph except where the source is placed on the axis of the object and a ecmp; circumference is radiographed with a single exposure in w..

case at least three equally spaced penetrameters shall be A

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IDENTIFICATION ,,

RTP- ( 7 4 - 2 4 21/ 8 ) _

Titi. RADIOGRAPHIC EXAMINATION PROCEDURE emot No. 8 op '10 ', s pacovet CONTAINMENT LINERS a rv. No. 8 .

custouc a BROWN & ROOT - TUSI sv CNS

• ave 10-8-81 9.2 When a spot, 'radiographed in accordance with Paragraph 8.0, and graded in accordance with Paragraph 10.0, discloses '

welding which does not' comply with the minimum requirements two additional radiographs (tracers) shall be taken at least. -

l' removed on each. side.mf the originalvspot ,within ,the 50.'

long. increment.

9.2.1 If the two additional radiographs (Tracers) show welding which comply with the requirements of Paragraph 10.0 the entire weld incre nent represented shall be acceptable and only that portion of unacceptable weld &'ill be repaired.

9.2.2 If either of the two additional radiographs YTracers) do not meet the requirements of Paragraph 10.0, the entire unit of weld represented must be rejected. #

rejected unit must be either completely removed and rewelded and re-spot radiographed in accordance with 9.0; or the rejected weld unit may be 100% radiographe and only weld areas rejected per paragraph 10.0 will be repaired and re-radiographed.

10.0 ACCEPTANCE CRITERI3j 10.1 Acceptability of E.mii@ examined.,by.. spot [, radiograph! will be in accordance with the following: .

10.1.1 Radiographs which show welds with any type of -

crack, or zone of incomplete furlon or penetration

,shall be unacceptable. 's 2o1829baidikuet'4;&nwM .

stdfRnewiaGaEaiOmWsui&J.*t/ . . .g NQliil8Eth#nWI 1/3 T for T fro.n 3/4" to 2-1/4" 3/4" for T over 2-1/4" inclusive l

Where T is the thickness of the thinner portion of the weld.

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FOR NORMA 110N ORY

NUCLEAR otyt7:04 4 CONSTRUCTION QUAtlTY ASSU;1ANCE MANUAL Sesta.l4 (Nonconform-

. F03 e it iO S. &. .Co rrec t ive Am n ., s .. _6,__ , o ,,, 4-3 73_

% A$ME SECTION ill PRODUCTS P we: . 3 .#__,[L_

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14.3.4 Nonconformities found in parts and appurtenances sup-plied by other than CDI and items which bear an N-Symbol Stamp shall be re ferred to the designated CNCA Super-s visor and the Construction Welding and 0% Manager for cesolution.

'11.4 NONCONFOPMITIES FOUND DURING CONSTRUCTION AND FINAL INSPECTION:

)> 14 . 4 .1 Except for the following, all nonconformities and potential nonconformities found during construction and final inspection shall be reported to the Erof ect Welding and QA Supervisor for documentation per 16.4.2:

14 4.1.1 Surface irregularities, including those found during the course of examination, which are eliminated by surface condi-tioning need not be reported, i 14.4.1.2 Corrections made to welds or to weld over-lays during the course of deposition (except those indicating a fundamental material or process out cf control) need not be reported L }>examinationdocumentas a nonconformity provided the comple

(}gg eg,g3,3 (R( odes indicates conformance.

> Deposition is defined as : welding performed 9G do e e , j gwA- prior to inteial oA accepeance signoff on q Cd4 ca c4{pN*cu_ the Travelar or Check List.

If""h 14.4.2 All nonconformities and potential nonconformities await-ing resolution that are found during fabrication (except

]>' Category II repairs which have been entered oa a Tratel'or or Check List and repairs to radiographed seams of products on which the "Field Check Lis'c System" is being used) shall be entered by the Project Welding and QA Supervisor, on the 'Nonconformance Contro? List" (App. A, page 19).

14.4.2.1 Under the "No. " column , enter the number e assigned to each nonconformity (and potential nonconformity). Nonconformities shall be numbered consecutively for each contract at each location.

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/ 14.4.2.2 Under "Discovery Reference," list traveler,

check list, or other sources disclosing the non con f o rmity .

14.4.2.3 Under "Description of Nonconformity," enter a general description including location.

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OUALITY A $U NCE MANUAL , 7!0 N ees F0R . . . . ..

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ASME SECTlON lit PROOLD P. ,. 6 .s ,, , ,

7.5.3 (continued)

a. Welders were qualified

b. Requirerents of the Welding Procedure Specification have been met.

[> 8. . sTne initials of. the. Projegt_ Hejding & QA Supervisor in the

? Finished Joint Checked" column is his certification that e,the;/ surf ace and configuration 'of the ' completed"weld ineet s:

(

l applicable requiremant's, t The initials of the Project Welding & QA Supervisor in the column (s

[>9 covering NDE is his certification that the examinations were per-formed in accordance with requirements, reports (9.5) have been made and are traceable from the record drawing entry , and any nonconformitles have been resolved.

[> 10. The initials of the Project Welding & QA Supervisor under "Complete d indicates his acceptance of the completed joint.

7.5.4 Detail Check List - GE 682 (App. A, page 28)

In the "Description" column, the item, joint or assembly w the required operation, inspection or examination is te be ente re d (by the Dis trict Engineering Group, see 7.5.9.3).

References to drawings or Check List Sketches GE 683 (see 7.5.5) may be made.

The nondestructive examinat'.on required will bn uuf ficient. -

l described in the "Instructions" block Dy the 31s trict Eng;

, eering Group - sec 7.5.9.3), so that joosite QA can dent- i

. ify the appropriate authorized procedures in the QA Hand-

. book. Jobsite QA shall enter the identification of the l authorized procedure to be followed in the "Procedure" col umr.. When chotee of nondestructive examination is auth-crized, such will be indicated in the "Instruction" block.

For AI hold points, 3obsite QA or the AI vill write an H in t'he AI column. (Also see 7.5. 3.1) 7.5.5 Check List Sketches - GE 683 (App A, page 29) may be in-cluded with Detail Check Lists, when it is necessary to i provide a pictorial reference for the location of process operations or examinations to be performed.

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M C BI Services. Inc.

n o so nt C emmam a'atama J5201 . , , ,

205 $95 U91 , <{ ,

March 13.1986

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Mr. Carl Elmer v.

TEXAS UTILITIES GENERATING COMPANY

- Brown & Root, Inc. 5 Comanche Peak Steam Electric Station m F. M. Road H P. O. Box 1002 Y.i Glen Rose. Texas 76043 RE: INTERPRETATION OF PICK-UP b' ON WPS & RADIOGRAPH REPORTS .i 7/{

'- R ADIOGRAPH #146-T2. REPORT 824 '

p' s CONTRACT # 74-2428U ,'f;

{ Dear Mr. Elmer y't y.,

o Pick-ups are surface imperfections that require additional Work for cosmetic purposes, on the area in questlon to comply _ With_Sgtecificationsi _ Code'and/or CBI requirement'st, and Customer /CDI Evaluators interpretations. Trev can be on base metal and welded joints. Good examples are slight undercut on '.he plate surface of attachment fillet welds f

L and along the edge of butt welds. ,,

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• Undercut is not a criteria for rejecting radiographs. However, sometimes Code acceptable <%.

I undercut by visual examination doesn't look good on a radiograph to the customer and/or. ~ j p'. CBI E saluator and is "picked-up" and re-radiographed. yg Radiograph No.146-T2 on Report No. 24, Contract No. 74-2428U was recognized by *,[f I+ the CBI Evaluator to have an area (acceptable undercut by visual) that could possibly( ;p mask a heat affected zone defect. To eliminate any doubt. t5e area was titled with metal (picked-up), surface conditioned by grinding and re-radiograpSed. No tracers or e.

d further investigation was required. since it was not a Code or Specification repsit.

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%As Film 146-T2 should not have been graded in the grade column of the radiogtoph repo'rnpA -

A straight line or N/A should have been entered in the grade celumns. The next ent,r .

' No.146-T2-RSI is correctly entered and graded. j.

I Should there be further questions on this, please advise Dennis Williams.  ; . e'N 5

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Sincerely, .  ;.;,

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lp. BBC WELD /QA MANAGER ,

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q n Reply Refer To:

Dockets: 50-445/86-03.

50-446/86-02 Texas Utilities Generating Company ATTN: Mr.;U. G. Counsil Executive Vice President 400 North Olive. L.8. 81

Dallas, Texas 75201 Gentlemen

This refers to the inspection conducted by Mr. I. Barnes and other members of the Re ton IV Comanche Peak Group during the period December 11, 1985, through 3

March 1,1986, of activities covered by NRC Construction Penmits CPPR-126 and .

CPPR-127 for the Comanche Peak Steam Electric Station. Units 1 and 2, and to the

discussions of our findings with members of your staff at the conclusion of the

various parts of the inspection, l Areas examined during the inspection included Comanche Peak Response Team

activities during February 1 through March 31, 1986. Also included in this l report are special Unit 2 as-built inspectiuns of cable tray supports, HVAC i duct supports, and conduit supports that were perforud from December 11, 1985, j through March 29, 1986. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector. The inspection findings are

documented in the enclosed inspection report.

3 During this inspection, it was found that certain of your activities were in violation of NRC requirements. Consequently, you are required to respond to tliese violations, in writing, in accordance with the provisions of Section 2.201 of the NRC's "Rules of Practice," Part 2 Title 10, Code of Federal Regulations. Your response should be based on the speciff.;s contained in the Notice of Violaticit enclosed with this letter.

Also during this inspection, it was found that certain of your activities appeared to deviate from consnitments made to the NRC. These items and references to the connitments are identified in the enclosed hotice of Deviation. You are requested to respond to these deviations in writing. Your response should be based on the specifics contained in the Notice of Ovviation enclosed with this letter.

Eight unresolved items are identified in paragraphs 2.e and 5.d of Appendix C; 4.6 and 4.b of Appendix 0; 5.a and 5.b of Appendix E; and 4.a and 4.b of Appendix F of the enclosed inspection report.

RiV:RI k R1 Rl:2~4 C: TG.:ZS C:R$8 /0:0R$ MR /h i IE11ershaw:cg CHa e MWagner !Barnes TWesterman #EHJohnson VSNoonan de id / /986 fp/){d86 to //g/86 /0//4/86 ) / /[/86 'ft/7/86 f (o//f/86 AC th t j R ibh M Q  ?'h jgoj,

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Texas Utilities Generating Company ,

We have also examined actions you have taken with regard to previcusly identified inspection findings. The status of these items is identified in paragraph 2 of Appendix C of the enclosed report.

The responses directed by this letter and the accompanying Notices are not

) subject to the clearance procedures of the Office of Management and Buyet as 1 required by the paperwork Reduction Act of 1980. PL 96-511.  ;

j Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

'NO >

E. H. Johnson, Director j Division of Reactor Safety and Projects ,

i

Enclosures:

J

1. Appendix A - Notice of Violation

2. Appendix B - Notice of Deviation

3. Appendix C - NRC Comanche Peak  !'

Response Team Activities Inspection Report 50-445/86-03 ,

50-446/86-02

4. Appendix 0 - Special Unit 2 Cable Tray Support As-Buile ,

i Program Inspection Report

! 50-446/86-02 Teledyne Trip Report 2200 *

5. Appendix E - Special Unit 2 HVAC Duct

> Support As-Built Program Inspection Report  !

50-446/86-02  ;

1 6. Appendix F - Special Unit 2 Conduit

Support As-Built i j Program Inspection Report l i

50-446/86-02 i

4 cc w/ enclosures:

Texas Utilities Electric Company

.i ATTN: G. S. Keeley, Manager  ;

Licensing

! Skyway Tower l 400 North Olive Street Lo:k Box 81 Dallas, Texas 75201 1 i j i

Texas Utilities Generating Cornpany -3 f

cc w/ enclosures: (cont'd)

. Juanita Ellis President - CASE 1426 South Polk Street >

Dallas, Texas 75224  ;

Renea Hicks -

Assistant Attorney General Environmental Protection Division P. O. Box 12548 Austin, Texas 78711 - 2548 Administrative Judge Peter Bloch U. S. Nuclear Regulatory Consission Washington, D. C. 20555 Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory P. O. Box X, Building 3500  :

Oak Ridge, Tennessee 37830 l I Dr. Kenneth A. McCollom 1107 West Knapp

Stillwater, Oklahoma 74075 Dr. Walter H. Jordan .

881 Outer Drive Oak Ridge, Tennessee 37830 l Anthony Roisman, Esq. -

Executive Director.._-- ---

! Trial Lawyers for Public Justice

! 2000 P. Street, N.W., Suite 611 Washington, D. C. 20036 Texas Radiation Control Program Director bectoDMB(IE01) ,

bec distrib. by RIV: i

• RPB iMIS System

• RRI-0PS *RSTS Operator  !

*RRI-CONST

• RASP 8  !

• T. F. Westerman, R$8 DRSP NRR R. Martin, RA ,

Y.

S. Noonan, Treby, ELD *RS8 i

• RIV File J. Taylor, IE  :

a *D. Weiss,LFHB(AR-2015) J. Konklin, IE

! *!. Barr.es, CPTG M. Emerson  :

I *w/766  !

i

4 APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Ccmpany Dockets: 50-445/66-03 Comanche Peak Steam Electric Station 50-446/86-02 Units 1 and 2 Permits: CPPR-126 CPPR-127 During NRC inspections conducted on December 11, 1985, throng:. riarch 31, 1986, violations of NRC requirements were identified. The viviations involved implementation of an electrical Design Change Authorization (DCA) in a manner different to that specified, failure to take corrective action with respect to Inspection Process Control group findings, inadequacies in performance of Unit 2 conduit support inspection program and omissions in engineering documents, inadequacies in performance of Unit 2 HVAC duct support inspection program, inadequate DCA resolution of a nonconforming condition, inadequate drawings and inspection performance with respect to Unit 2 cable tray supports, failure to cocply with ACI-359 requiremcnts with respect to radiographic examination of a liner weld, and incomplete site operations trend analysis. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are 4

listed below:

A. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGCo Quality Assurance Flan (QAP), requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings.

Paragraph 2.5 of TUGCo Procedure CP-EP.-4.6, "Field Design Change Control,"

Revision 10, dated April 16, 1984, states, in part, "Design changes / deviations to specified engineering documents shall be documented by revision initiated by an Engineering Change Recuest (ECR), a Design Changu Autnorization (OCA) er a Component Modification Card (CMC)."

DCA 18,016 required removal of wire strands using a wire stripper to reduce wire size from #16AWG to #18AWG.

Contrary to the above, wire size reductions were implemented for Unit 2 termination cabinets, 2-TC22 and 2-TC23, by construction operation travelers in a manner different than specified on DCA 18,016; no revision to the DCA had been initiated, nor were either an ECR or CMC initiated.

This is a Severity Level V violation (Supplement !!) (446/8602-V-08).

B. Criterion XVI of Appendix 8 to 10 CFR Part 50, as implemented by Section 16.0, Revision 0, dated July 1, 1978, of the TUGCo QAP, states, in part, "Measures shall be established to assure that conditions adverse to quality, such as . . . deficiencies, deviations . . . are promptly identified and corrected."

h0 k k N k !!b00445 PDR

l i

• . i i.

Contrary to the above, the measures established did not assure that the  !

following described condition adverse to quality was promptly identified  ;

or promptly corrected. The NRC inspector reviewed a sample of 70 Sample  :

Recheck Request / Report forms, completed by the Inspection Process 4 Control (IPC) group since July 1985, and identified 80 examples where QC inspectors had entered "SAT" inspection attributes in inspection reports ,

where "NA" (i.e., not applicable) was the correct entry. This condition was identified in the monthly IPC reports beginning with the September i report dated October 11, 1985. Subsequent IPC reports (October and ,

November) characterized this condition as both "a generic problem" and a  ;

significant deficiency and requested that corrective action be taken as  :

early as December 13, 1985. However, no apparent action has been taken to

establish how long this condition may have existed before September 1985 j nor has corrective action, in a generic sense, been taken. [

ThisisaSeverityLevelIVviolation(SupplementII)(A46/8602-V-06). I

, C. Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section 10.0, Revision 1, dated July 31, 1984, of the TUGCo QAP, states,  !

i in part, "A program for inspection of activities affecting quality snall l j be established and executed . . . to verify conformance with the o j documented instructions, procedures, and drawings for accomplishing the  !

activity."

[

Contrary to the cbove, the following conditions which had been inspected 6 i and accepted by the applicant's inspection program, were identified as t l being nonconforming during independent inspection of Unit 2 conduit  ;

j supports:

l 1. Section 3.3.1 in Revision 7 of TUGCo Instruction Ql-QP-11.10.1A i states, in part, "The QC inspector shall inspect the support for the  !

following: Member (s) shape . . . size and dimensions." j t inspection revealed a 1/2" thick shim plate installation on one  !

support and a 5/8" thick shim plate installation on another support i for which the applicable drawings required the use of a 5/8" thick j l and 1" thick shim plate, respectively. .

t i

i 2. Section 3.5.1 in TUGCo Instruction QI-QP-11.10-1A, Revision 7, i

! states, in part, "Conduit spans shall be as indicatad m the l isomotric drawing. Conduit span Tolerance is a3 (wnes). . . ."

l l Inspection revealed a measured span length of one conduit run as l being 3/4" over the allowable tolerance shown on the isometric i i drawing, f

3. Section 3.4 in Revision 20 of TUGCo Instruction QI-QP-11.21 i specifies that where embedded plates are occupied by attachments  :

i within 12" of a Hilti, the minimum clearance between a 3/8" and 1/2"

! Hilti bolt and a Nelson stud will be 5-7/8" and 6-1/2", respectively, j i

1 i i

k

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Inspection revealed two supports in which the Hilti bolts were within 12" of an attachment but the minimum clearances between a 3/8" and 1/2" Hilti bolt and the Helson studs were 5-3/8" and 4-3/8",

respectively.

4 Section 3.2.3 in Revision 7 of TUGCo Instruction QI-QP-11.10-1A states, in part, "Each support inspected on a raceway system shall be assigned a number shown on the engineering isometric drawing included in the conduit system work packages . ..

Inspection revealed one support in which its identification number ,

did not match the applicable isometric drawing support identification number.  !

5. Section 3.9 in Revision 7 of TUGCo Instruction Ql-QP-11.10-1A states, in part, "The QC Inspector shall verify the conduit supports have been installed in accordance with the requirements of the . . .

isometric drawing . . . ." It further requires the use of an inspection report to document inspection results. Step (V) 1.b in the inspection report states, "Verify conduit configuration."

Insnaction revealed a conduit span bend opposite to that which was shown on the a pplicable isometric drawing, and step (V)1.b had been

signed off as aving acceptable. ,

f This is a Severity Level IV violation (Supplement !!) (446/8602-V-20).

l 0. Criterian of Appendix B to 10 CFR Part 50, as implemented by

, Section 5.0, devision 3, of the TUGCo QAP, requires that activities i i

affe.cting cuality shall be prescribed by and accomplished in accordance  !

i with documented instructions, procedures, or drawings.

3 .

Contrary to the above, the following conditions were identified with t 1 respect to Unit 2 conduit supports in which the prescribed activities were j not accomplished *

1. Section 2.4 in TUGCo Procedure THE-AB-CS-2 Revision 0, states, in '

part,"TheFieldEngineershallprepareafieldisometricindicating i

the general routing and location of supports, and . . . shall include  !

! span lengths and configurations . . . decision points and r locations . . . . Decision points are considered as places on a typical drawing for which two or more options are acceptable for the c same location."

! Inde endint inspection reve41ed a decision oint which had not been incl ded in the isometric drawing by the Field Engineer. One support was observed in which a 3/8" Hilti bolt had been installed. The  ;

1 applicable typical drawing specified a 1/2" Hilti bolt with the option of using a 3/8" Hilti bolt, provided the support capacity was reduced. The absence of this information could possibly preclude the ,

,l required reduction in support capacity by the Design Engineer, i I

l

~

2. Section 3.3.1.1 in Revision 14 of TUGCo Instruction Q1-AP-11.21-1 requires that the welding symbol for an intermittent fillet weld be -

in accordance with standard welding symbols o dAWS 2.4-79.

t Inspection revealed the existence of intermi .ent fillet welds on 11 conduit supports.in which the applicable, ti,l cal support drawing did not depict an intermittent fillet weld symb'ol.  ;

This is a Severity Level !Y violation (Supplement II) (446/8602-V-21).

E. riterion X of Appendix B to 10 CFR Part 50, as implemented by [

iection 10.0, Revision 1, dated July 31, 1984, of the TUGCo QAF states, in part, "A program for inspection of activities affectint. quality shall

)e established and executed . . . to verify conformance with the ,

focumented instructions, procedures, and drawings for accomplishing the j ictivity."

Contrary to the above, the following examples from Unit 2 F,AC duct I lupport inspections were observed where the Bahnson inspec. ion program failed to identify nonconformances with the documented ins: ructions, stocedures, and drawings: l

'.. Section 9.1 in Revision 1 of Bahnson Procedure VP-TUSI-001 states, in part, with respect to intermittent welds, "Weld 'ncrements shall  :

begin and terminate within 1/8" of the ends of the joints or dimensioned length . . . ." Seven HVAC du;t supports, however, inspected by the NRC h0d intermittent fillet welds which did not begin or terminate within 1/8" of the ends (f the joints.

. Section 6.5 in Revision 5 of Bahnson Procedur6 QCI-CPSES-Oli states,  !

in part, with respect to welding, "The Quality Representative shall make certain that the size, length, and locatica of all welds conferm to the requirements of QCI-CPSES.014 and OFP-TUSI 003, and to the detailed drawing . . . ."

Independent inspection identified the following canditions in three HVAC duct supports:

a. A 2" long, 1/4" fillet weld required by the drawing was reasured as being 1/8" for the full length. ,

b. Two, 2-1/2" lcng, 1/8" fillet welds required by the drawing j betweer the two lateral braces and the main support were  :

missing. l r

c. Two, 1-1/2" long, 1/8" fillet welds required by the drawing were [

measured as being 1-1/4" long. l l

i l

I i

(

3. Section 6.6 in Revision 5 of Bahnson Procedure QCl-CPSES-011 states, in part, "Weld profiles shall meet che following requirennts:

The faces of fillet welds may be slightly convex, flat, or slightly concave . . . Welds shall be visually examined to determine if the following defects are evident: . . . Undercut shall not exceed 1/32" for materials thicker thsn 1/4"."

One support was identified in which two welds exhibited 1/16" undercut for 50 percent of the held lengths on members which were 1/2" thick. The support also had a 1/4" and a 3/8" weld in which grinding of the weld produced excess convexity, resulting in an unacceptable weld profile.

4 Note 2 in Attachment 4 of Revision 10 to Bahnson DFP-TUSI-004 states, in part, "Where the embedded steel plates are occupied by attachments within the minimum distance shcwn above (12"), the minimum clearance from 1" 9 Hilti anchors to . . . the edge of the embedded plate is 7-1/2"."

One HVAC duct support was identified which haJ a 1" diameter Hilti bolt located 11" from an attachment on an embedded plate and only 3/8" from the edge.

This is a Severity Levei IV violation (Supplement II) (446/8602-V-17).

F. Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section 3.0, Revision 4, cated Novertar 20, 1985, of the TUGCo QAP, states, in part, "Measures Mll be established to . . . include provisions to assure that ap,,.opriate quality standards are spacified and included in design documents and that deviations from such stan ards are controlled . . . The design control measures shall provide for verifying or checking the adequacy of design . , . Design changes, including fielo.

changes, shall be subject to design control measures cormnsurate with those applied to the original design . . . ."

Contrary to the above, verification or checking of a design change, initiated to resolve a deviation from design documents, did not assure the adequtcy of either the design change or the disposition of the nonconformancereport(NCR)whichdocumentedthedeviation. NCR M-80-00161, initiated un Noverter 6, 1980, addressed the drilling through of a "probable" template bar, a rebar, and notching another rebar. The ,

disposition was "Use-As-Is" and referenced DCA No. 9091. The solution in the OCA stated that, "The condition as described is acceptable." However, the described condition addressed just one cut bar.

This is a Severity Level IV violation (Supplement 11)(445/8603-04).

G. Critarion X of Appendix B to 10 CFR Part 50, as implemented by Section 10.0, Revision 1, dated July 31, 1984, of the TUGCo QAP states, inpart,"AprogramforinspectionofactivitiesaffectingqualItyshall

6-be established and executed . . . to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."

Paragraph 2.0 in Revision 0 to TUGCo Procedure TNE-AB-CS-3 requires walkdown drawings to reflect history and methodology to produce as-built drawings. It further requires the walkdown drawings to depict all the necessary information required for subsequent QC verifications; i.e., -

support configuration dimensions and material sizes.

Paragraph 3.2.3 in Revision 5 to TUGCo Instruction QI-QP-11.10-2A requires the QC inspector to verify that the completed support is in accordance with the as-built drawing.

Contrary to the above, the following cenditions were identified with respect to seven Unit 2 cabi tray support drawings:

1. Walkdown drawings neither depicted all required information nor included correct dimensional information necessary for subsequent QC verification.

2. QC inspectors accepted support dimensions which were different from those specified on the walkdown drawings.

This is a Severity Level IV Violation (Supplement II) (446/8602-V-14).

H. Criterion IX of Appendix B to 10 CFR Part 50 states, in part, "Measures shall be established to assure that special processes, ircluding welding . . . and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specificatinns, criteria, and other special requirements."

Section CC-5521.1.1 of Code ACI-359, states, in part, "If the 12-in, radiograph in the 50-ft-long increment of weld does not meet the acceptance standards, two 12-in, films shall be taken at other locations within the 50-ft-long increment . . . . If either of the second radiographs does not eeet the acceptance standards . . . the remainin portion of the 50-foot increment of this weld shall be radiographed."g

]

l Contrary to the above, the required radiography of the remaining portion

! of a 50' increment of weld was not performed even though one of the two i second*2"radiographs (No.146T2)atseamP84intheUnit2 containment liner did not meet the acceptance standards.

]

]

ThisisaSeverityLevelIVviolation(Supplement!!)(446/8602-Y-10).

I  !. Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGCo's j Final Safety Analysis Report (FSAR) Section 17.2 Ouring the Operations phase," dated July 19,198$,"Quality requires that Assurance

l i

. . .- i 1

I tetivities affecting quality be prescribed by and acco plished in i dCCordance with doCunented instructions, procedures, or drawings of a type I appropriate to the circumstances. l Operations Administrative Control anc. Quality Assurance Plan Section 3.9 states that, "Deficiency Reports-(DRs) ard nor.conformance reports (NCRs) shall be reviewed periodically for adverse trerd: . . . Results of trend analysis shall be reported to the Manager, Nuclear Operations, Manager, Plant Operations, and Manager, Quality Assurance."

Contrary to the above, site operations trend analyses were performed on ors only for 1984 and 1985. Consequently, trend analyses for problems

, identified on NCRs were not performed and thus r.ot reported to the required levels of managerent. Further, site procedures de not clearly i describe the conditions under which a DR or an NCR is to be written, nor were DRs reviewed for potential conditions requiring an NCR prior to a 9

June 1985 revision to the deficiency reporting procedure STA-404 l This is a Severity Level IV violation (Supplement II) (445/8603-V-02).

pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Compar.y is hereby required to submit to this office within 30 day 9 of the date of the lettertransmittingthisNotice(1)thereasonfortheviolationsifadmitted,a including for each violation: written statement o the corrective steps which have been taken and the results achieved, the corrective steps which will be taken to avoid further violations, and the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

Dated at Arlington, Texas this j7.tb day'of Q A 1986

i APPENDIX B NOTICE OF DEVIATION [

Texas Utilities Electric Company Dockets: 50-445/86-03 i Comanche Peak Steam Electric Station 50-446/86-02 i Units 1 and 2 Permits: CPPR-126  :

CPPR-127 I

Based on the results of an NRC inspection conducted on February 1-March 31 -

1986, deviations fnm comitments to t!e NRC were identified. The deviations '

consisted of incorrect review of a revision to a Quality Instruction (QI) with respect to impact on inspection perfomed to a prior revision, cmission of a i required inspection attribute from a QI, failure to identify an unacceptable I weld surface condition after coating removal, inadequate engineering review for l applicability of an inspection attribute, and failure to comply with approved 1 instructions in perfomance of reinspections. In accordance with the "General [

Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2 '

Appendix C (1985), the deviations are listed below: l A. Paragraph 5.3.5(A) of Evaluation Research Corporation (ERC) QI-019.

Revision 3, states, in part, "Verify that the clearance meets the following criteria: , . . Where design shcws 0 ina.h on one side and 1/16 inch on the ,

< other side, the sum of both gaps may not exceed 1/8 inch or be less than  ;

1/32".*  !

l

• Where design shows 0" on bottom (in the gravity direction) then it shall i be such with no allowable variation." {

Section II of ERC Description Memorandum QA/QC-RT-1436 addresses changes,  !

reasons, and effects incorporated in Revision 3 of iRC QI-019 and states. [

i in part, regarding paragraph 5.3.5(A), "Added clarifying infomation on allewable clearances for dead weight and 0" clearance supports . . . ." i Attachment A to the abcVe ERC Description Memorandum lists previously I issued reinspection packages and states that package I-S-SBPS-051 is not  !

affected by changes incorporated in Revision 3 of ERC Q!-019. [

l

In deviation from the above, independent inspection identified that ,

clearances which had been correctly accepted by ERC for Verification [

Package No. 1-5-SBPS-051, when inspected to Revision 1 of Q1 019, were no  !

longer acceptable to the requirements of Revision 3 of QI-019. Drawing  ;

i CP-AA-040. Revision 0, shows clearance in the gravity direction of zero.  ;

i Independent inspection reasured a gap of 1/16" in the gravity direction, [

and thus detemined that the changes in Revision 3 did, in fact, affect  :

1 the previous inspection of Verification Prickage No. !-5-SBPS 051 l

! (445/8603-0-14).

I B. Paragraph 5.1 of ERC Procedure CPP 007 Revision 2 states, in part, t

"Responsible QA/QC discipline engineers review the latest . . . Brown &

! Root . . documents relating to the population. Subsequently, the l engineer develops a list of safety significant attributes that are comon l to the population and which can be reinspected . . . . "

t 0 0

m

.2 .

Paragraph 3.4.4.3 in Brown & Root, Inc. Instruction QI-CAP-11.1-28, Revision 31, identifies requirements for base material inspection and  :

states, in part, "The depression depth produced by grinding shall not i exceed . . 1/32" for material less than 3/8" thick (structural shapes)."

in deviation from the above, the responsible QA/QC discipline engineer failed to identify and incorporate into ERC QI-029 this base material inspection attribute. As a result, ERC inspection of Verification Package No. I-$-LBSN-065 failed to identify that grinding on base mate ial in excess of 1/32' existed on item 3 of pipe support MK No. CT-1-008-001-5225

(445/8603-0-18).

7 C. Section 5.2 of ERC Procedure CPP-022, Revision 0, states, in part, "Paint  !

shall be removed from the weld connections which have been inspected '

through paint . . . . f)esults of these visual inspections shall be documented and include, as a minimum, criteria utilized, (and) any

, discrepancies." Section 5.2.0 of ERC QI-062, Revisic 0, states, "Verify surface of welds are sufficiently free of overlap, ab upt ridges and l ripples so proper interpretation of radiographic and/or other requireo PDE could be acecmplished."

In deviation from the above, ERC quality it:tpection personnel documented  !

in ' M fication Package No. I-S-NPBW-014 that the surface of welding which att nn d item 1 to support steel identified on Drawing FW-1-019-901A-C57W i

, was acceptable. !i. dependent inspection identified, however, that after  :

removal of coatings the weld surface was unacceptable. Subsequent to the L HRC insp(ction, ERC personnel issued a deficiency report documenting tne rejectableweldconditier.(445/8503-D-17).  ;

D. Section 5.1.1 of Revision 2 to ERC Procedur:t CPP-008 states, in part, l

". . . should an attribute appear on the generic checklist and not ba (

i 1

applicable to the specific item, the angineer indicates 'N/A' and provides l . . reasonable justification for the entry."

J In deviation from the above, an independent inspection of Verification  !

Package No. I-S-HYDS-075, support DG-844-2K-1J. revealed that Sections 2F.1, 2F.2, and 2F.3 in the checklist'for QI-035, dealing with l embed plates and spacing violations, hed been "N/A'9" by the engineer. [

furthe , the noted justification for this entry was "No Embedded PLs."

However, indr. pendent inspection identified the existence of an sbed plate with dimensions of approximately 20' X 8" (a46/8602-D-13).

i E. Section 4 of Revision 3 to ERC Procedure CPP-007 states, in part, "Qualified Q*/QC Review Team personnel specific hardware items and reviews o' perform appropriate field reinspections documents in accordance of [

with approved instructions . . . ."

4

t In deviation frem the above, the following examples were noted where field reinspecticns of hardware items were not pnformed in accordance with .

approved instructions

!

- .~ . . _ _ - - . _ . . - . _ _ . - . .- . . _ - _ _ _ - _ - - . . .

1. Attribute 20, in Section E.0 of Revision 0 to Ql-035 states, "Verify member lengths and all other dimensions that describe the lengths and positions of members on the support frame (: 1/2")." For Verification Package No.1-5-HV05-075, Support 06-644-2K-1J, the ERC inspector signed the checklist that this attribute (20.) was acceptable. An independent inspection revealed, however, that there were several mcnbers for which no dimensional information was provided in the drawing thus making it impossible to verify required member lengths and all other dimensions that describe the lengths and pcsitionsofthosemembers(446/8602-0-12).

2. Attribute 3B. in Section 5.0 of Revision 0 to QI-035 states, "Verify l that weld sizes meet the requirements of the duct support detail  ;

drawings." For Verification Package No. I-S-HVDS-037, the ERC  !

inspector signed attribute 38. as being acceptable and noted that all welds had been measured with a Fiber Metal Fillet Gauge. During ,

an independent inspection, it was noted that there were two skewed i fillet welds on this support in which one leg of the fillet on each j weld could not be measured with a Fiber Metal Fillet Gauge or any -

other conventional method (446/8602-0-11),

t 3. Attribute 1.f in Section 5.2.6.2 of QI-025, Revision 2, states, in .

part, "Ensure that a minimum of 2 inches clearance is maintained,  !

Including pipe insulation, with respect to other siping when one or  !

both lines have an operating temperature of 200* : or '

greater . . . ." For Verification Package No. 1-M-l.BCO-148, th9 ERC  !

inspector signed off this attribute as acceptable, even though there were three cases where the minimum separation criteria were not met '

and no documentation existed justifying this condition. The three instances were as follows: ,

a. Line 2-CC-1-0CO-152-3 was in contact with the inspected line at a location 6' 6" north of wall 7-S and 10' sest of wall D-S. l The two lines were parallel and were in contact for about 4'.

s b. Line 2 CC-1-061-152-3 was in contact with the inspected line at a location 12' 6" north of wall 7-5 and about 8' west of '

I wall 0-S.

c. t.ine 1-CC-1-062-152-3 was closer to the inspected line than .... i allowable 2" at a location 6' 6" north of wall 7-5 and 7' 6" i west of wall D-S (445/8603-013), (

r Texas Utilities Electric Company is hereby requested to submit to this office, I within 30 days of the date of this letter transmitting this Notice, a written  !

i statement or explanation in reply, including for each deviation: (1) the j reason for the deviation if admitted, (2) the corrective steps which have been  :

i taken and the results achieved. (3) the corrective steps which will be taken to I

! l i

' i k

4 avoid further deviations, and (4) the date when full compliance will be achieved. Where good cause is shcwn, consideration will be given to extending the response time.

Datedatprlingtoni Texas this /7I day of O&&fu;1986 .

l

( .. _

N. - - _ _ , - . _ _ _ . . - - - , . - . -

APPENDIX C COMANCllE PEAK RESP 0llSE TEAM ACTIV111ES !!;SPECT10N REPORT U.S. NUCLEAR REGULATORY C0t411SSION REGICN IV NRC Inspection Report: 50-445/36-03 Ptrmits: CPPR-126 50-446/86-02 CPPR-127 Dockets: 50-445 Category: A2 50-446 Licensee: Texas Utilities Electric Company (TUEC)

Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201

, Facility Narna: Comanche Peak Steam l E ectric Station (CPSES), Units 1and2  ;

l Inspection At: Glen Rose, Texas Inspection Conductap February 1 through March 31, 1986 j i d

Inspectors: 1 N

L.E. Ellershaw, Reactor Inspector, Region IV Date i CPSES Group 4 (paragraph 6.,7.,8.e-g,8.j,9.g-m) l

• k_RQ j

. lDll(cb(fo l

C.J. HJ1(, Reactor Inspector, Region IV Date CPSES1 roup (paragraphs 2.f-j,3.,4.,5.a-c,8.c-d,8.h-1) f r

Sw to//Wrd.

p P.C. Wagner, Reactor Inspector, Region IV Date ,

CPSES Group r (paragraphs 2.a-o,5.d.8a-b,and9.c-f) '

l Consultants: EG8G - J. Dale (paragrephs6.,9.j) [

A. Maughan paragraphs 2.c-d 9.b.-d) i W. Richins V. Wenezel I[ paragraphs I,,paragriphs 5.b 8.e} 8.f 9.k 9.1[

Parameter-J. Birmingham (paragraphs 2.h-1,3.d.8.c-d,8.h-1)  ;

Q >

t

2 J. Gibson (paragraphs 2.e 9.e.)

K.' Graham (paragraphs 7., 6.j, 9.m)

D. Jew (paracraphs 8.g, 9.g-1)

Teledyne - J.Malonson(paragraphs 4.,S.c)

Approved: b-I. Barnes, Chief, Region IV CPSE5 Group

<sv4//4 Date IF.spection Summary Inspection Conducted: Fcbruary 1 through March 31, 1986 (Reports 50-445/86-03:

50-445/85-02)

Areas Inscected: Nonroutine, unannounced inspection of applicant actions on i previc9s inspection findir.gs, Comanche Peak Response Tean KCPRT) issue -

specific action plans (ISAPs), applicant management of QA activities, CPSES QC surveillance program, assessment of allegations, pipe supports, and followup on NRR liner plate concerns.

Results: Within the seven areas inspected, five violations (failure to take corrective action with respect to Inspection Process Control grou) findings, paragraph 5.a; inadequate site operation trend analysis, paragrapi 5.b; inadequate control of a design change, paragraph 5 d; inadequate resolution of anonconformingcondition, for radiographic examination paragraph of a liner 6;failuretocomply)withACIrequirements weld, paragraph 7 and five deviations (failuretocomplywithapprovedinstructionsinperformanceofreinspections, paragraphs 9.g and 9.j; incorrect consideration of impact of a resision to a quality instruction (Ql) on previous inspections, paragraph 9 k; inadequate engineering review for applicability of--an-inspection attribute, paragraph 9.j; omission of a required inspection attribute from a Ql, paragraph 9 n; and failure to identify an unacceptable weld surface cerdition, paragraph 9 m) were identified.

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DETAILS

1. Persons Contacted D. L. Anderson, Supervisor of Audits TUGCo -

• • J. L. Barker, Executive Assistant to Executive Vice President. TUGCo

• • J. W. Beck, Vice President. TUGCo A. K. Bordine, Operations Q-List Engineer. TUGCu

• • C, T. Brandt, TUGCo Quality Engineering (QE) Supervisor (Ebasco)

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

• • W. G. Counsil, Executive Vice President TUGCo ,

D. E. Deviney, Operations QA Supervisor, TUGCo

• P. E. Halstead Quality Control (QC) Manager. TUGCo ,

M. Keathly, Evaluation Research Corpcration (ERC) Lead Electrical QC Inspector P. Leyendecker, Surveillance Supervisor, TUGCo ,

J. B. Leutwyler, Brcwn & Root (B&R) Electrical QC Sup:rvisor J. Ma.landa, CPRT Electrical Review Team Leader -

D. M McAfee, Quality Assurance (QA) Manager, TUGCo

• J. T. Merritt. Director, Construction TUGCo H. Obert ERC !ssue Coordinator

• • • J. Redding. Executive Assistant, TUGCo ,

B. C. Scott, Supervisor, Vendor Audits, TUGCo i P. Stevens, Electrical Engineer, TUGCo Nuclear Engineering (TNE)

• J. F. Streeter. Director, CA. TUGCo l *

• • • T. G. Tyler, CPRT Program Director, TUGCo J. Ziemian, ERC Lead Mechanical QC Inspector -

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• Denotes those persons who attended the March 4, 1986, exit interview.

• • Denotes those persons who attended both the March 4, 1986, and the i April 4, 1986, exit interviews. l i

• • • Denotes those persons who attended the April 4,1986, exit interview. {

The NRC inspectors also contacted other CPRT and applicant employees  ;

during this inspection period.

I

2. Applicant Actions on Previous Inspection Findings i

a. (Closed) Unresolved item (445/8518-U-02; 446/8515-U-01): Electrical penetration assemblies (EPAs) not properly qualified. Further review  !

of this unresolved item disclosed numerous problems which nave been documented in a separate inspection repert; i.e., NRC Inspection Report 445/86-04; 446/86-03. This item is closed. i I

b. (Closed) Open Item (445/8513-0-02): Lack of inspection procedure for ISAP No. I b.4. The adequacy of the provided procedures to conduct l ISAP No.1.b.4 was further evaluated by a review of ISAP Nos. I.b.2. j

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-4 Revision 4, dated January 24, 1986, and 1.b.4, Revision 4, dated January 24, 1966. The inspections recuired in 1.b.2 include the issues addressed in 1.b.4; therefore, procedures for inspection are not required b 1.b.4. This item is closed. ,

c. (Closed) Open N (445/F$14-0 49): Comparison of ERC with NRC review results ' e @e" mtstior packages. Cceparison of ERC and NRC documentation r. e ,f ow n v rification packages was deemed to be ineffective bec u .i dsich to the applicable procedures. The NRC inspector rev ryf a9 3 tce ivolved packages; the results tre discussed elsewhei w t.his report. This item is close:1.

d. (0 pen)OpenItem(4 MM- Potential deviation regarding underinsertion of E k.ture i ',ge stud in hut. The condition of the nuts not being e. .ged fiu with the ends of the closure studs was documented in ERC e tatt.m Report (DR) 1-E-EEIN-062-0R-1. This DR was incorporated into nonconformance Report (NCR) E85-102021SX.

This item remains open pending NRC review of the disposition of 'he NCR.

e. (Closed)OpenItem(445/S518-0-12): During an independent NRC inspection in December 1985 of instrument 1-PT-?'25, Verification Package No. I-E-ININ-053, it was observed that tubing associated with the instrument was not color coded to identify its assigned separation group (train / channel), and that separation spacing was apparently not maintained on the tubing run. ERC inspection personnel, similarly identified thase conditions on DRs 1-E-ININ-053-DR1 and DR2; the corresponding TUGCo NCRs are I-85-1012775X and I-85-10127851 dated October 3, 1985.

Gibbs & Hill, Inc (G&H) Pressuro Instrument Specification Sheet No. 05.14, indicated that 1-PT-2323 is a "0" item (class 1E connected to a safety class 2 system). The TUGCo "Q" list, 10-L151-MS-0323, indicates that 1-PT-2325 is safety class 1E, seismic category I, has two component functions, and must remain functional during and after a Safe Shutdowr, Earthquake (SSE). The CPSES FSAR, Figure 10.3-1 (SH-1), shows that 1-PT-2325 controls the power operated atmosphere steam relief valve (1-MS-259) associated with the main steam line from steam generator #1. Also, Se: tion 7.4.f of the FSAR lists this relief valve, controlled by 1-PT-2325, as an essential component under hot standby conditions. Hot standby is defined in this section as, ". . . a stable condition of the reactor achieved shortly after a programed or emergency shutdown of tha plant and is the safe shutdown design basis for CPSES . . ."

The TUGCo disposition of NCRs I-85-10127775X and 101278SX stated that no nonconformance existed because the instrument was "non-Q," and did not fall within the scope of the QA program. Subsequently, ERC initiatedTechnicalInformationRecuest(TIR)No.130 dated October 31, 1985, requesting further clarification of color code identification for separation groups 1, II, 111, IV, A, or B. The I

T TUGCo response to TIR 130 stated that color coding of instrument impulse lines was required only for thote instruments annotated by a diamond symbol on drawings of the 2323-M1-2500 series, because these ,

were the only nuclear safety-relatep instruments designated by G&H  !

Specification F323-MS-625.

I The NRC invector's review of the instrument tabulation sheet, 2323-M1-2505-03, Sheet 3 of 5, revealed that 1-PT-2325 was assigned to separation Train "A", but was not associated with the diamond symbol. Drawing 2323-M1-2500-N, Sheet 1 of 1 indicates that the .

diamond symbol is used to identify field mounted instruments which, '

because of their safety function, require the connecting impulse tubing to have separation from similar tubing runs en the redundant,  ;

ccunterpart instrument. On February 13, 1986, TUGCo redispositioned NCRs 1-85-1012775X and 101278SX, to state that no nonconformance existed because the instrument was nonsafety-related (i.e., not

• required for safe shutdown). On February 20, 1986, TUG 10 revised the response to IIR 130, to state that cevices that did not have '

redundant counterparts were not color coded, and did not require inspection for separation.

Because 1-PT-2325 did not appear te have a redundant counterpart, this open item pertaining to maintaining separation color coding and spacing of the tubing run is closed.

The FSAR listing of the power operated atmosphere steam relief valves [

as essential components for maintainirg hot standby, brought into '

question the definition of safe shutdown as identified on the j disposition of NCas 1-85-1012775X and 101276SX, and as depicted in ,

4 de. sign documents and implementing procedures / instructions. This item '

1s considered unresolved oending clarification of requirements by the j applicant (445/8603-U-01; 446/8602-U 01).

f. (0 pen) Violation (445/8432-02;446/8411-02): Procedures were not  :

i established for regular management review of the status and adequacy .

of the construction QA program nor was it apparent such reviews were l made. Actions taken and being taken by Tl!GCo include the following:

Procedure DQP-CQ-5, "Senior Management Overview," Revision 0 I September 23, 1985, has been implemented and two comittee meetings have been held. The following ranagement personnel are me:bers of

this committee

Vice Presidents of Operations, Engineering /

Construction, and Licensing /QA; Director of QA; the Managers of QA and QC; and the Operations QA Supervisor. The Executive Vice l President of Nuclear Engineering and Operations has attended both l

. meetings thus far. Based on the NRC review of the minutes of these j meetings, it is apparent that senior plant management is being i appraised of QA/QC problem areas and their input is being provided to corrective as well as preventive action programs. In addition, an i l INPO audit was conducted in the sumer of 1985, and the CpRT onsite r

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activities are directing more management attention to existing and potential problem areas and weaknesses. Further independent management assessment of the plant will be provided by annual JUMA  ;

audits, the fir;st scheduled to begin February 24, 1986.

The subject of management assessment is still being evaluated by the CPRT in ISAP No. VII.a 5. TUGCo will respond to this violation when the CPRT effort is complete. This item remains open awaiting that j responsa.

g. (0 pen) Violation (445/8432-03;446/8411-03): Four examples of failures in the program audits of safety-related activities:

(1) iradequate audit procedures; (2) failure to verify proper implementation of all elements of the safety-related program 1

annually; (3) Westinghouse site activities were not audited in 1977,

1978, 1979, 1980, and 1981; and (4) since 1978 vendors have not been audited annually.

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(1) At the time of this tiolation, the audit program for internai and external audits was prescribed in Procedure DQP-CS-4, "TUGCo QA Audit Program." Subsequent revisions and new procedures ,

describe in more detail how TUGCo's comitments are being i irplemented. Curiently, the TUGCo audit program is being implemented with several procedures that are topically specific. I These procedures include: 00A-QA-2, "Indoctrination and a Training of TUGCo QA Dallas Personnel"; DQP-QA-15, "TUGCo QA ,

Audit Program"; DQP-VC-14," Conduct of External Audits";

DQP-AG-2, "Conduct of Internal Audits"; DQP-AG-3, "CPSES 0serations Phase Audit Program"; DQP-AG-4, "CPSES Construction P1ase Audit Program"; and DQP-AG-6, "Internal Audit Deficiency Folicwup/Closecut."

(2) TUGCo was comitted to audit annually all applicable eierents of >

the QA program. This internal audit program is based on an

annual schedule of audits in areas of continuing and ongoing l

safety-related activities. Organizations, disciplines, and areas or activities to be audited are based on review and evaluation of site procedures. Subactivities within a given organization, discipline, or area are audited on a sampling basis determined by the current site schedules. Therefore, site procedures and instructions form the basis for the majority of the audit programs; however, there is no intent that all

' implementation activities of all procedures and instructions  ;

will be audited annually. Based on the NRC's inspection of the t internal audit program (paragraph 3 of this report), TUGCo is  !

complying with their internal audit program comitments. ,

(3) Westinghouse (W) site personnel's principal responsibilities  !

' were to coordinate construction site activities relative to the W equipment and to provide advice and consultation on testing and startup programs. While rest of the necessary audits of l

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t these W site responsibilities are perforced through TUGCo audits-of the~M corporate offices (e.g., Pensacola or Monroeville),

periodic audits onsite are necessary. Such an onsite audit was

, conducted in November 1984 The scope of this audit included the review of the qualifications of the site personnel and resulted in one finding. Then in Seatember 1985 an evaluation of the W site activities was made, witch concluded that a 1985

, audit was not merited based on the absence of problems and no changes in the W scope during the previous year. In sumary, limited items are auditable onsite and these items are now considered for auditing each year; most W site functions are controlled by the offsite evaluated,orbothannually)(.organizationi and these are audited, (4) Amendments 52 and 54 to the FSAR were submitted to the NRC on August 27, 1984, and January 21, 1985. These amendments -

proposed the adoption of Regulatory Guide 1.144, which comitted l TUGCo to a minimum of annual evaluations of vender performance and triannual audits of sendor QA programs. By NRC letter (Noonan to Counsil) dated September 30, 1985, this proposal was accepted with certain changes in the wording. These word ,

changes were made in Amendment 57 dated December 20, 1985. l Currently, the NRC finds that the vendor ?udit program is in compliance with TUGCo comitments. (See paragraph 3 of this appendix.)

The subject of the audit program and auditor qualifications is ,

continuing to be assessed by the CPRT in ISAPs VII.a.4 and VII.a.5, '

and the NRC is inspecting this activity on a continuing basis. TUGCo '

will respond to this item when efforts on these ISAPs are complete.

Accordingly, this item remains open. ,

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h. (Closed) Violation (445/8432-05;446/8411-05): One of six inspec. tors l training files reviewed had not completed the required eddy current i testing course.  ;

The procedural requirement in violation was deleted before the end of the subject inspection on the basis that eddy current capabilities were not necessary for these inspectors. An NRC review of several TUGCo audit reports supported this TUGCo position,

i. (Closed)UnresolvedItem(445/8432-04;446/8411-04): Without the nurter of required annual audits clearly defined, it could not be determined if there existed an adequate audit staff to effectively implement the committed audit program.

The scope of the internal audit program is more clearly defined currently, and there are presently 12 internal auditors. Additional support is available through contract personnel and TUGCo plans to

.s.

qualify other QA personnel as auditors to supplement their staff as necessary. The scope and staffing of the internal audit program is addressed further in paragraph 3 of this report.

j. (Closed) Unresolved Item (445/8432-06; 446/8411-06): The onsite surveillance program appears to lack sufficient purpose, direction, coordination, and feedback to the overall QA program, in late 1984, the site surveillances were performed by one group of four individuals and a supervisor. Currently these surveillances are conducted by four groups with a total staff of 29. The surveillance groups functional areas and staffing are: documents, 4 people; startup/ turnover, 5 people; construction, 8 people; and inspection, 12 people. The surveillance program is defined and controlled by six proctdures. These procedures address the concerns expressed in the previous NRC inspection. A more detailed NRC inspection of the total onsite surveillance program is provided in paragraph 4 of this report.

3. Applicant Management of QA Activities

a. Organization and QA Program The NRC inspectors reviewed the QA comitments describsd in FSAR Section 17.1, "Quality Assurance During Design and Construction,"

through Amendment 56 dated October 15, 1985. Since the NRC's last inspection in this area (50-445/8432; 50-446/8411), several changes have occurred in the QA program (e.g., adoption of triannual audits of vendors discussed elsewhere in this nport) and organization.

A Director of QA has been added to the QA organization who reports to the Vice President, Nuclear Fuels and QA. Re

- are the managers of-QA (Dallas) and QC (site) porting

.- The to this functions director and responsibilities of the Manager of QA are essentially the same; however, reporting to this manager are an assistant manager and four supervisors; vendors, audits, QE and administration. Exce)t for the changes in titles, the functions and responsibilities of tie QC Manager are the same; however, a QC Services Supervisor and a QC Surveillance Supervisor have replaced the QA Supervisor, and a QC Coordinator has been added.

While the division of QA/QC functions and responsibilities remains essentially the same between the site and corporate office, the organizational changes have divided some activities and provided additional management control. In addition, a number of personnel changes have been made in the past year including new QA and QC Hanagers. The corporate QA staff has increased slightly, but the site QC staff has increased more than 50 percent. This increased staff has provided among other things, more attention to product quality through surveillances of QC inspector effectiveness and hardware.

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The aforementioned chcnges in staff and QA/QC emphasis has resulted in revision and restructuring of the implementing procedures. The NRC inspectors reviewed several of the revised and new procedures.

The results of these reviews are provided in subsequent paragraphs of i this report. l Revision 15(October 15,1985) of the Corporate Quality Assurance Program was reviewed. This program continues to provide the corporate policy concerning QA and a description of comitments to assure that all phases of design, fabrication, construction, testing, and operation are consistent with quality requirements, f

A QA program cha'ge intended to involve utility management more  !

closrly in QA mat;ers was the formation of the Senior Management l Overview Comittee (SMOC) in September 1985. The functions of this h comittee are described in DQP-CQ-5. This cemittee, which meets at  ;

least three times per year (more of ten as necessary), is cocposed of I the following members: the Vice Presidents of Operations,  !

Engineering / Construction, and QA; Director of QA (chairman); Managers [

of QA and QC; and Operations QA Supervisor. The minutes of meetings  !

conducted thus far were reviewed by the NRC inspector. These were i consistent with the controlling procedure. [

f In this area of the inspection, no violations or deviations were identified. [

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b. Reviews of QA Program Effectiveness  !

The CPRT provides management with an ongoing view of the quality and i effecti w ness of the QA pregram. The NRC assessment of CPRT efforts l are provided in renthly inspection reports. Management programs in addition to the CPRT include the periodic SMOC meetings, audits by INPO in 1985 and JUMA scheduled fcr-outsideorganizations(e.g.fNCR' 1986), and trend analyses o sand"UNSAT"inspectionreportsfor i construction activities and deficiency reports for operations  !

activities. l t

The construction trend reports for November and December 1985 were i reviewed for compliance with Procedure Ql-QP-17.0-1, Revision 1, "Preparations and Distribution of Trend Reports." Potentially ,

adverse trends and conditions were identified in these reports. The -

responses to the November and December reports were reviewed to assure proper actions were taken. Corrective actions in the November report response included the replacement of a craf t foreman in the  ;

electcical discipline with a request for additional monitoring in that area. The management evaluation of the December report is still  !

in process. -

Two SMOC meetir The first SHOC j meetingwason.pshadbeenheldbytheendof1985.

ieptember 25, 1985, with the second in November. TN 3 minutes of bcth meetings were reviewed by the NRC inspector. This  :

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forum provides a means of resolving CA issues and developing QA positions by management with diverse organizational interfaces. Two procedural weaknesses were noted concerning the minutes of these meetings: attendees were not listed nor is there a means of "

identifying the sequence of the meetings; e.g., sequential nuttering by year,

c. Procurement Control Purchase orders (P0s) to seven currently active vendors were reviewed by the NRC inspectors to verify that appropriate cuality requirerents were included based on QA reviews, vendors were properly on the approved vendors list (AVL), ar.d vendor audits /cyaluations were current. These P0s were processed in accordance with cornitments except for the following.

Two FDs were issued to Itotal Bellcws (for flexible metal hose)

CPD-0320 in May 1980 (with three supplements in November 1980, January 1981, and April 1982) and CPD-0322 (with supplements in Decer.ber 1984, P.ay, September, and Octcber 1985). The preaward survey (PAS) was performed April 23-24, 1980, and the vendor was placed on the AVL; however, no audits or reevaluations, as required by DQP-QA-15. "TUGCo QA Audit Program," and DQP-VC-11 "Vendor Evaluation !!ethods," were conducted until the audit of January 23-24, 1985, which was required at least every three years, and a reevaluation performed August 16, 1984, which was required annually.

This is a further example of the vioiation identified during a previous NRC inspection (445/8a32-03; 446/8411-03). The action taken by TUGCo (the January 23-24, 1985, audit) brought this item back into compliance with the current TUGCo vendor audit program.

The F0 with Stone & Webster Engineering Corporation (S&W),

CPF-12658-5, issued in July 1965 and presently containing four supplements, was reviewed by the NRC inspectors, which procured engineering services for pipe stress and qualification activities.

The PAS was scheduled for July 9-10, 1985, but was cancelled and $&W was placed on the AVL based on the NRC letter from the Vendor Inspection Branch dated August 1983 approving the S&W QA topical report, SWSQAP 1-74, Revision D. The PO nor any of its supplements impose this QA topical on S&W, ner is there other documentation indicating that S&W is using this topical for the activities procured in this P0. This oversight was identified to TUGCo personnel and P0 Supplemont 5 was initiated and issued on February 18, 1986, imposing Revisien D of SWSQAP 1-74 on all applicable S&W activities.

In addition to the above reviews the NRC inspectors reviewed the various revisions of the AVL from July 1983 to January 1986, comparing the vendors on the AVL with the required audits and evaluations. The AVLs prior to 1985 contained at least 18 vendors with delinquent audits. This condition was identified in NRC Inspection Report 50-445/8432 as a violation. By the end of CY 1985

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the vendors on the AVL were current based on the NRC inspecto.*'s review of vendor audits and evaluation reports compared with the "active" vendors on Revision 24 of the AVL dated January 1986. This recovered control was the result of: (1)deliberateauditand 1 (2) the re-statusing of applicable vendors to evaluation "Inactive" orscheduling;ly complete deleting them; and (3) the adoption by TUGCo

. and subsequent NRC approval of Regulatory Guide 1.144, Revis which permits triannual audits with annual evaluations of ve.1on ndor 1 perfornance.  :

d. Internal Audits and Audi_tnrj During the NRC inspection of the TUGCo QA audit program, the

following documents were reviewed: audit procedures, 1985 and 1986 1 audit schedules, audit reports, and audit records.

The "TUGCo Dallas procedures / Instructions Manual" was reviewed to verify procedural control of QA Division organization, personnel indoctrination and training, QA manual, QA records, document control, i and corrective action relative to the audit program. Procedural controls were adequate except for two areas. Methods to provide assurance that the applicable elements of the QA program were audited annually were not procedurally defined, and review of documents that input to the audit plan / schedule was not documented formally.

The qualifications of the audit and vendor surveillance staff were reviewed. The results of this review will be used in assessing the CPRT activities on ISAP No. V11.a.4 Auditors added to the staff in 1985 increased the total staff number and the average years of experience. NRC review of the 1985 audit schedule as .'rformed found the construction audit schedule had been met.

Twelve audit packages-from 1985 were reviewed to determine adequacy of audit team makeup, time spent on audits audit and audit checklist preparations,auditdocurentation,andfollowupofcorrectiveaction.

The twelve audit samples included audits of document control, engineering, procurement, QA/QC, operations, and site contractors.

In all cases, audit preparation, performance, and followup were in compliance with applicable procedures. One audit TCP 85-10, on valve assembly and installation had open deficiencies, but review showed that correspondence was timely and that an identified deficiency was receiving a higher level of management attention as required by procedure.

The 1985 audit schedule was reviewed to determine if all applicable elements of the QA prograw had been audited. A matrix of audits performed versus applicable criteria of Appendix B to 10 CFR Part 50 had been developed by the QA audit supervisor for tracking purposes.

This matrix, however, is not under procedural control and did not

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l assure that all applicable elements of the QA program were audited in i full; only that t,1e criteria identified had been audited in part.

This item remains open (446/8602-0-02).

A required document review for impact on the audit plan /schecule of documents such as: HRC correspondence, CPSES Procedures / Instructions, Construction /Startup Surveillance and Status Reports, and Quality Trend Reports was stated by the QA audit supervisor to have been performed. This review, however, was not formally documented relative to its performance, what personnel performed the review, and the outcome of the review. T11s subject is considered an open ites (446/8602-0-03).

4 CPSES QC Surveillance Program During the period of TRT activity at CPSES, and subsequent NRC inspections, the QA site surveillance program was found to be poorly structured and ineffectively implemented. In March 1985 the applicant reorganized and restructured the surveillance program, an,d revised existing procedures or provided new procedures for its implementation.

This program is conducted under the responsibility of the surveillance l supervisor who reports directly to the QC manager.

The QC surveillance program implemented at CPSES is structured to provide a vehicle by which ongoing construction, inspection and startup/ turnover related activities may be monitored by site certified personnel to assure proper and consistent methods of construction, inspection, and documentation are maintained.

Currently, the surveillance program is divided into four areas:

(a) Construction,(b)RecordReview,(c) Inspection,and (d) Startup/ Turnover, with a QC supervisor for each area.

I a. Construction Surveillance Group I

I i

Construction surveillances, implemented by TUGCo ProcedureCPQP-19.0,"ConstructionStart-up/ Turnover (CST)

Surveillances," provide for surveillances of construction activities in accordance with site construction procedures. These surveillances are performed by observation of work in progress, completed work, and/or review of documentation. The areas of activity covered by these surveillances include construction, fabrication / installation, equipment storage and maintenance, and housekeeping practices.

Surve111ances are performed using prepared checklists whose attributes are derived from the procedures that control the activity under surveillance. Personnel conducting surveillances are trained in the applicable procedures and certified as surveillance specialists.

'he NRC inspector's review of CP-QP-19.0 found that the procedure e vides adequate description and direction for the conduct of

surveillances by this group. Surveillances are unscheduled; however, the area and frequency are determined by the surveillance superviso with consideration given to the level of ccnstruction activity, the results of previous surveillances, and project trend information.

Surveillances by this current group were initiated in October 1985.

During December 1985 and January 1986, the emphasis was directed to the as-built verification of cable tray suppor cs in Unit 2 to. prevent a repeat of the problems encountered in Unit 1. These sup> ort surveillances resulted in corrective action that revised t1e as-built verification inspection procedure.

This inspector reviewed five surveillance retorts conducted in October 1985 and found that all the reports revealed compliance with the procedure; however, the checklists did not identify the specific items observed, nor were the results of cbservatiens other than "SAT /UNSAT" clearly documented. In discussions with the group supervisor, he stated that this condition was reccgnized by the surveillarce supervisor and program improvement was implemented.

This inspector's review of documentation for surveillances aerformed in January and February 1986 noted improvements and found t1at identification of items and observation results were adequately documented,

b. Records Surveillance Group This surveillance activity, implemented by TUGCo Procedure CP-QP-19.11A, "Records Surveillance," provides a review of documentation for permanently installed items to verify that Unit 2 QA records package contents are complete and documents contained therein (e.g., operations traveler, weld data cards, inspection reports, etc.) are legible, accurate, and in compliance with the applicable procedures. Reviews are accomplished using a generic surveillance report checklist of attributes comon to all record packages. Deficiencies, when found, are recorded on the surveillance checklist which then becomes the surveillarce deficiency report (SDR) issued for the required corrective action.

Followup verification for correction of SDRs is accomplished and documented within the surveillance group by the surveillance document reviewer who originated the report or the group supervisor. Closecut of the 50R is documented in either case by the supervisor's signature. If an NCR is issued, it is processed in accordance with existing site procedures for the control of nonconformances.

Verification of the implementation of the NCR disposition is accorplished by QE and QC external to the records surveillance group.

Copies of the surveillance reports are issued to the corrective action group for trending. Personnel performing surveillances are trained and certified as documentation reviewers.

-14 The NRC inspector reviewed Procedure CP-QP-19.11A and found that the procedure is sufficiently detailed as to purpose and scope, and is adequately descriptive of the attributes necessary for the performance of the reviews and detection of deficiencies.

Additienally, the NRC inspector reviewed all documentation surveillance reports for January, February, and March 1986 and found that the performance and reporting of these surveillances was in compliance with the controlling procedure.

c. Inspection Surveillance Group Inspection surveilla,1ces, implemented by TUGCo Procedure CP-QP-19.13, "Inspection Surve111ances, previde surveillances of construction-related QC inspection effectiveness by sample reinspection of QC accepted item / component and/or obstrvations of inprocess QC inspection activities. Surveillances are tentatively scheduled on a monthly basis with concurrence of the site QC manager, with consideration given to the level of QC field inspection activity, results of previous surveillances, and Project Cerrodity Trend Report information. Component reinspection is conducted on selected items, with emphasis placed on assessing hardware quality through verification of hardware and evaluation of original inspector results when unsatisfactory conditions are found. Personnel performing these surveillances are trained in the applicable construction and QC inspection procedures and certified as inspection surveillance specialists. Deficiencies detected by these surveillances are documented on NCRs that are processed under the existing site nonconformance procedure. Veiification of the implementation of the NCR disposition and closeout is accerplished by QE and QC external to the inspection surveillance group.

Although the inspection surveillance program was reorganized and restructured in late 1985, the inspection surveillance group activity has been limited due to the time reqaired for hiring, indoctrination, training, and certification of personnel and procidure preparation and approval. Inspection surveillances were well underway by March 1986.

The NRC inspector's review of CP-QP-19.13 found that the procedure provides adequate description and direction for the conduct of surveillances by this group. Additionally, this inspector reviewed thereportsforallsurveillances(18)conductedthroughtheendof March and found that the surveillances were performed and doeurented in compliance eith the procedure.

d. Startup/ Turnover Surveillance Group The startup/ turnover surveillances, impler.ented by TUGCo Procedure CP-QP-19.0, ' Construction, Startup/ Turnover Surveillances," provide surveillances of activities as outlined in the TUGCo startup administrativeprocedures(SAPS). Surveillances include the review

e

• of the SAPS for prcgrannatic requirements, the witnessing of prerequisite tests, and establishing "hold points" for witness, by this group, on all pre-operational tests conducted by the startup group. Additional responsibility includes surveillance of system turnover activities. Personnel performing these surveillances are trained in the applicable procedures and certified as surveillance specialists.

The NRC inspector's review of CP-QP-19.0 found that the procedure provides adequate description and direction for the conduct of surveillances by this group. Surveillances are unscheduled; however, the area and frequency are determined by the surveillance supervisor with consideration given to the level of startup/ turnover activity, the results of previous surveillances, and project trend report inforretion. Deficiencies detected are addressed in SDRs. Folicwup verification for correction of deficiencies is accomplished and dor cented within the surveillance group by the specialist who originated the report, or the group supervisur. If an NCR is issued, it is processed in accordance with existing site procedures fer the control of nonconformances. Verification of the implementation of the NCR dispositica is accomplished by QE and QC external to this surveillar.ce group.

The NRC inspector reviewed the reports for the months of October 1985 through February 1986 and found that, although the surveillances were in compliance with procedures, the checklists did not adequately identify the item under surveillance and the results of observations were poorly documented. This condition was recognized by the surveillance supervisor and program improvement had been implemented.

The NRC inspector's review of surveillance reports for Marc 11986 found that the condition had been corrected,

e. Trainino Qualification and Certification TUGCo surveillant:e personnel are indoctrinated, trained, qualified, and certified in accordance with TUGCo Procedure CP-QP-19.9, "Training, Qualification and Certification of Surveillance Specialists." This proceduie provides the detailed requirements for the level of activity performed by the specialists in each of the four surveillance groups and identifies the docur.entation to be retained in each employee's training file.

The NRC inspector .'eviewed the files for all surveillance personnel to determine that the documentation and file contents provide objective evidence that the procedural requisites leading to certification have been met, were in compliance with the procedure, and that there was evidence of TUGCo verification of education and previous employment. This review found that on-the-job training (0JT) was waived for three specialists. The waivers were based on prior certification as QA' specialists in startup/ turnover

surveillances and the justification was documented in their file.

One document reviswer had completed the training requirerents but hao not been certified to date. The NRC inspector found that the work performed by this reviewer was approved by the supervisor in accordance with procedural recuirements.

The NRC inspector's review fcund that the conduct of training, qualification, and certification of surveillance specialists and the supporting documentation was in compliance with procedures.

f. Review of Surveillince Reports and SDRs The NRC inspector reviewed surveillance reports to determine compliance with the applicable procedures. This review found that the surveillance chectlist attributes developed by the surveillance specialists were derived from the procedures drawings, specifications, and other documents applicable to the activity, item, component, or system and the source documents were identified on the checklist. The supervisor's signature on the checklist indicated his approval prior to use. Observations were recorded on the checklists and SDRs or NCRs, if applicable, were issued.

SDRs were processed in accordance with TUGCo Procedure CP-QP-19.10 "Surveillance Deficiency Reports." The NRC inspector's review of this procedure found it adequate in its descriptive detail and direction to control the processing of the SDRs. The NRC inspecter reviewed a sample of SDRs from each of the applicable surveillance groups and found that the deficiencies were acequately described, the corrective action was clearly stated, and folicwup verification by the SDR originator was documented. Additionally, the required review and approval signatures were entered.

All surveillance group logs reviewed were current for the issue, closure, and transmittal of the surveillance reports, including the SDRs, to the assigned records storage location,

g. Trend Evaluation and Reporting In addition to the detection and correction of deficiencies, the determination of QC inspection effectiveness, and the acceptable quality of hardware, one of the surveillance program objectives was to assess the collective output of the surveillance groups by performing trend evaluations to ascertain the need for prograrcatic corrective actions.

In interviews with the corrective action group supervisor, responsible for the trend analyses, and the site QC manager they stated that the trend evaluations of surveillance reports through March 1986 had not yielded sufficient data to establish trends.

17 The QA/QC corrective action grcup (CAG), responsible for trending, has perfortred preliminary assessments of the available surveillance data on an engoing basis. The site QC manager's evaluation of the .

preliminary assessments to date resulted in additional training of  !

personnel and procedure revisions to increase effectiveness.

Additionally, the CAG is utilizing these preliminary assessments as input to the development of criteria for establishing the trending program of surveillance findings. The NRC inspector reviewed the  ;

preliminary assessments and in further discussions the site QC '

manager stated that the initial surveillance program trending results will be included in the April 1986 trend report.

This inspection found that the trending program was implemented in compliance with the applicable procedures, although still in its formative stages. The pending inclusion of the surveillance program trends in the A (446/8A02-0-04)pril 1986NRC Future trendinspections report will will remain an open consider the item effectiveness of the. trend criteria, the evaluation process, and the trend results,

b. Summary and Conclusion This inspection found that the applicable procedures were adequate to control the surveillance process. The review of surveillance checklists, surveillance reports, 50Rs, verification of personnel certifications, and interviews with supervisors and surveillance personnel found that the surveillance program, except for the open item regarding trending, was irplerented in compliance with the applicable procedures.

During this inspection, an additional concern was identified that requires further review by the NRC. The surveillance function reports organizationally to the site QC ranager as do the QE group and all QC inspector groups. ASPE and non ASME. The majority of the output of the surveillance group activities is a direct measure of the performance and effectiveness of these groups, and therefore of the site QC manager's assigned responsibilities. Consequently, there exists a potential for violation of Criterion I of 10 CFR Part 50 Appendix B, which requires that organizations (i.e., the surveilla,nce groups) have sufficient organizational freedom to identify quality problems and initiate, reconnend, or provide solutions. This subject isconsideredanopenitem(446/8602-0-05).

No violations or deviations were identified in this area of inspection.

! 5. Assessment of Allecations

a. 4-85-A-121 and 4-85-A-131: Improper Actions Concernino the Inspection

~

~ ~

Process Control Group The following allegations were made by four individuals concerning theInspectionProcessControl(!PC) group: 4-85 A-121, QC inspectors are signing ins section reports "SAT" when the proper entry should be

~

i "NA " further tiis individual did not trust the Safeteam; and 4-85-A-131,(1)IPCpersonnelweredirectedtodocumentproblemson three-part memos, not on NCRs; (2) proper act, ion was not taken in all cases regarding problems documented on three-part cemos; e.g., NCRs not written, other papittwork not processed, or generic evaluation not

performed.

The NRC inspector reviued the IPC organization and controlling procedures. The IPC group was established in early 1985 to systematically perfom reliability assessments of the QC inspection processbyindependentlyinspectingsamplesofpost-process inspection attributes and identify ng wien process corrective action i

was necessary. Procedures reviewed controlling this activity were i IPC-1, "Organization and Administration of the Inspection Procc:s

Control Program," and IPC-3, "Reliability Assessment Program." IPC-3 required that all current QC inspectors work be sarpled at the end of every 30 day period and the results be documented in a Sample Recheck

, Request / Report (SRRR) form. The SRRR forms, when rejectable

! attributes were identified, were sent to QE who initiated the

! necessary corrective action. IPC personnel were advised of the 2 action taken by QE for infomation purposes only.

(1) 4-85-A-121 The NRC inspector reviewed the completed SRRR fonns for all QC inspectors. A sample of SRRR forms that were in process (QE review not coepleted) was also reviewed. The dispositioning of iocntified rejectable attributes for 24 QC inspectors (70 SRRR forms) was reviewed. This review included all of the at,sociated docur.entation; e.g., drawings, changes, NCRs, and inspection reports (irs).

Of the 70 SRRR forms reviewed, the NRC inspector found 80 examples where "SAT" was entered by the QC inspector when "NA" would have been the proper entry. Examples of IR attributes where "SAT" was incorrectly entered were Nelson stud spacing, but Hiltis were used; triax cable but not used; ring torque lug, butringtorquelugnotused;cabletrayrungspacing,butit was a solid tray; and supports, but no supports. In a few of the above examples an NCR was issued. When an NCR was issued, the disposition was usually to correct the documentation, nothing else indicated. When no NCR was issued, the corrective action ranged from no action to a cnsnitment that the QC

(

19 1

! inscector's supervisor would be advised. These examples l occurred from July 1985 to December 1985, when the IPC program l

was revised and new personnel assigned. The OE basis for no action in several of the examples where no NCRs were issued, was that marking "SAT" where "NA" was applicable does not render the 4 quality of the item unacceptable. The NRC inspector agrees; however, the numerous occurrences of this problem does indicate ,

a condition that is adverse to quality, which in the absence of corrective action is a violation of Criterion XVI of 10 CFR Part 50, Appendix 8. Monthly IPC reliability assessment reports to QC management identified this as a problem. The October and November 1985 reports identified this sroblem as a generic deficiency and requested action from tie CC supervisor. The QC supervisor sent a memo on January 24, 1986, to the training I supervisor to prepare a class for training personnel in the l implenentation of CP-QP-18.0 "I mention the "SAT vs NA" problem.nspection As of the endReport," but of March, did not this  ;

I training had not been scheduled. The foregoing is considered a i i

violation of Criterien XVI of 10 CFR Part 50, Appendix B I

(446/8602-V-06).

l In sumary, numerous examples were identified that substantiate i the allegation thtt "SAT" was used on inspection reports when "NA" should have been used.

Since no details or basis were provided concerning this individual's distrust of the Safeteam the NRC was unable to assess this concern. TheCPRTisevaluatingtheexitinterview pro ram established for the site which includes the Safeteam

,15 P No. Vll.a.6). The NRC will be inspecting the implementation of this effort.

(2) 4 85-A-131 - - -

The NRC inspector's review of applicable procedures did not identify any provisions for the use of three-part memos to document problems.

During the NRC inspector's review of the IPC monthly reliability assessment reports, it was noted in the Septetter and October 1985 reports that potential discrepancies unrelated to the attributes being inspected were identified on three-part memos and sent to the applicable QE group. On further review the NRC inspector found that not only were three-part memos being used to document potential nonconforming conditions, but the three-part menos were not being tracked and there was no formal followup to assure that they were properly dispositioned.

This condition was identified as a violation in a previous NRC Inspection Report (50-445/86-01). An informal log of the three-part remos was found within the IPC group, but there was no assurance that all memos had been logged.

Forty-seven remos were identified on this infor:al log; hcwever, six can no longer be found. The 47 problems referred to in the log were reviewed by the NRC inspector. The problems identified on some of the remos that were located resulted in NCRs being issued, while others appeared to recuire an NCR but none were issued. On February 26 1986 NCR E-86-200637 wts issued requiringallretrievablememo,stobereviewedandwhere nonconforming cunditions were fcund to exist an NCR would be i s'su ed.

Included in the action on this NCR will be a reinspection in the areas where the six missing three-part memos originated. The conditions identified en the informal log will be the point of focus in an attemot to identify the scurce of the original concerns. This area will be inspected further by the NRC when action on the NCR is completed. Accordingly, this natter is consideredopen(446/E602-0-07).

In conclusion, the allegations were substantiated, with one exception. Numerous examples were found where QC inspectors were ccepleting irs with "$AT" when "NA" was the appropriate entry (4-85-A-121). Tht: was recognized by T1)GCo as a generic problem, but they failed to identity the magnitude of the problem or take prempt action to correct, resulting in a violation of 10 CFR Part 50, Appendix B. It eculd not be established that IM personnel were directed to document problems on three part me e s (4 85-A-131); however, this practice was permitted and was also identified as a violation.

It could not be determined that proper action was taken concerning the prcblems identified on these three-part menos in every case. TUGCo recognized this and issued an NCR to reevaluate all of the actions taken. The NRC will inspect the

- disposition of this NCR when it le ccepleted. The lack of trust in the Safeteam on the part of one alleger could not be assessed due to the lack of specifics; however, this program is being evaluated by the CPRT and the NRC is inspecting the implementation of this effort,

b. AQ-161 (4-85 A-31): QA Deficiencies Not Documented It wss alleged that Operations QA handled deficiencies without documenting problems; thus no preventative actions were effected and, consequently,QAproblemsidentifiedbyoperationsdidnot appear to be reported to the appropriate level of management.

The FSAR comitments for centrol of nonconforming materials, parts and corponents were reviewed. Section 17.2.15 of the FSAR comits and requires that nonconforming conditions be identified, docurented, reviewed, dispositioned, and reinspected for acceptability after

o .

21 dispositioning is completed. Further, Section 17.2.16 comits to reporting significant conditions adverse to quality to the appropriate level of canagement.

To verify the implementation of the above nonconformance reporting comitments, the NRC inspectors reviewed ongoing work to determine if nonconforming conditions were documented, dispositioned, and appropriate corrective action taken to prevent recurrence. In NRC walkdowns of selected rooms, it was observed that nonconforming conditions for safety-related hardware were brought into compliance with the item's specification and/or drawing without an NCR being written. These occurrences, as well as other departures from the nonconformance reporting system discovered during NRC walkdowns, were reported as a violation in a previous Regicn IV Inspection Report (50-445/86-01).

In assessing the portion of the allegation dealing with problems not being "eported to management, it was found that NCRs were not reviewed on a periodic basis for adverse quality trends as required by the Operations Administrative Control nnd Guality Assurance Program (OAC&QAP), Section 3.9, "Nonconfo. nances, Deficiencies and Corrective .'.ction." Consequently, the comitment that periodic analysis of NCRs be forwarded to management to show quality trends did not occur. Applicant QA persont.cl were interviewed to determine why the deviation from this comitment occurred. The reply was that trend analysis perfortned in the early days of the Operations QA program did not identify meaningful trends or recurrino significant conditions adverse to quality. For calendar years 1984 and 1985, 421 and 140 NCRs, respectively, were written.

During the assessment of the operations nonconformance reporting system, it was observed that the applicant has a separate method to identify report, and take corrective action on procedural (program,atic) deficiencies that is different from the metheds used on hardware deficiencies. The deficiency repo#'t is used to document procedural deficiencies and the hCR is used to document hardware deficiencies. Each employee is required to rJport observed procedural deficiencies on a deficiency report and submit it to operations QA for processing. The NRC inspector found that for 1985 approximately 50 percent of the deficiency reports (203) were written by non quality personnel. Monthly, quarterly, and annual trend data reports were published presenting those deficiency reports. These trend reports were issued to various levels of managerent including onsite and offsite senior management. Based on trend analysis of deficiency reports, recurring conditions fcund adverse to quality were reported on corrective action requests to the appropriate levels of management. Therefore, the procedural system for deficiency repo ting does identify, document, and report progranratic problems to the appropriate leveis of management.

j Deficiency reporting procedur,t, STA-404, Revisions 1, 2, and 3. used from February 1982 to January 1986 (current), were reviewed. The NRC ,

inspector found no revision that clearly differentiated between the use of a deficiency report and NCR in the purpose, applicability, and definitions sections. Revision 2 dated June 1985 revised the  ;

deficiency report process instructions to include blocks "yes" or "no" for specifying an NCR is required in connec ion with the deficiency reports. Therefore, the deficiency reports written prior i to June 1985 potentially may not have NCRs written even if hardware '

deficiencieswerepresentasaresultofproceduralviolationsthat were reported in t1e deficiency report system. Accordingly, the deficiency reporting system used prior to June 1985 may not have caused the identification and reporting of nonconforming hardware en NCRs.

Ir. conclusion, the potential that Operations QA corrected hardware nonconformances witicut documenting them on an NCR, and thus without corrective action to prevent recurrence, dces exist. Accordingly, -

this allegation was substantiated.

The portion of the allegation that QA problems were not reported to the proper level of management was partially substantiated. NCRs were not trended to identify conditions adverte to quality and therefore not reported to management. Hewever, quality trends for j deficiency reports were reported to the applicable levels of ranagement. The substantiation of this allegation has the following implications in the Operations QA area: (1) inadequate identification and reporting of nonconforming ea,nditicns; (2) no NCR trend analysis for 1984 and 1985; and (3) no evaluation of deficiency reports (prior to June 1985) to determine if an NCR was required in connection with the deficiency reports. These itens have been identified as a violation (445/8603-Y-02).

c. AQ-156 (4 E5-A30) and AQ-163 (A "

85-A31): Impreper Processing Of l Deficiencies ,

1 It was alleged that surveillance canagement did not initiate corrective action when a sury'sillance identified QC directing craf t in the installation of ecuipment (AQ-156); ana QC inspectors allowed '

craft to correct ctficiet.cias during final QC inspections without QC i recording the "UNSFT" condition on the IR; thus, circumventing the ,

trending program (AQ-163).

The NRC inspector determined tnat & iough the allegations were f presented by different allegers they pertained to the same subject  ;

levent). The allegers referred to a recent surveillance of ,

electrical conduit installation, but did not identify the  :

surveillance report by number or date. The hRC inspector searched the surveilltare report files and interviewed the construction I startup/ turnover surveillance (CSTS) supervisor and found that surveillance report DSR 85-023 dated March 28, 1985, was consistent I

with the subject and time frame expressed by the allegers.

OSR 85-023 contained information which provided the details aad probable basis for the allegations.

(1) AQ-156 Based on the alleger's statements, the allegation was characterized that QC was instructing electrical craf t hcw to install electrical conduit. Craft had not finished the job correctly and QC was telling craf t what had been dane wrong, i.e., the junctinn box has to go this way, or this has to be over here. The alleger perceived the foregoing as a concern that QC vas instructing craft in the performance of their job and that when the surveillance supervisor was advised of this concern he did not initiate any action.

In review of the applicable construction and QC inspection procedures for this assessment; the NRC inspector did not fino any procedural constraints that would prohibit QC inspectors from providing clarification of deficiencies, nor from providing recontendations for their correction. The alleger did not identify, nor did the NRC inspector find any procedural deviations or program violations. The allager's concern was related to an activity which appeared to be an example of the i proper implementation of 10 CFR Part 50, tppendix B, Criterion I, "Organization," which states in part:

"The authority and duties of persons and organizations performing quality assurance functions shall be clearly established and delineated in writing. Such persons and organizations shall have sufficient authority and crganizatienal freedom to identify quality problems, to initiate, recomend, or provide solutions, and to verify the implerentaticn of sosutions."

This assessrent found that the procedures in place complied with this criterion and the alleged practice was not a violation.

The surveillance supervisor did not agree that the described activity constituted '0C instructing craf t." but rather was an example of QC implementing the requirements of 10 CFR Part 50, Appeedix B. The NRC's assessrent of this allegation supports the decision of the surveillance supervisor.

While the allegation was substantiated, both QC and the surveillance supervisor were acting in coepliance with requirerents.

(2) AQ-163 Surveillance report DSR 85-023 discussrd above, al:0 provided the detail necessary to the definition and assessment of this

O *

-24 allegation. This allegation is further characteriaed that during QC inspections the accompany 1rg craft would correct an "UNSAT" condition detected by the inspector, but there is a gotential that the inspector would not document the initial UNSAT" on the inspection report. If this occurred, the "UNSAT" finding would not be captured as input to the trending program.

The NRC inspector found that this allegation was identified as a concern in DSR 85-023 issued to the site QC inspection supervisor. The QC supervisor's response cited the words of '

TUGCoprocedureCP-QP18.0,"InspectionRegort,"thatrequired the GC inspector to record any identified UNSAT" condition without regard to the time or circumstances under which the

%NSAT" condition was found. The surveillance report package contained evidence that the res;onse was reviewed and accepted by the surveillance specialist wio identified the concern, and the surveillance supervisor had reviewed, approved and closed the report.

The NRC inspector interviewed the electrical QC inspection supervisor, electrical inspectors, the site QC inspection supervisor, and rechanical inspectors. The NRC inspector described the concern being assessed. These individuals were in agreement that it was comen practice fcr craf t to accorpany and correct "UNSAT" conditions identified during QC inspections. As the procedure required, the inspector w'Jld record the "UNSAT" condition, notwithstanding its imediato correction, and there was no resistance by craft to this process. These individuals also stated they were not aware of any cases of procedural noncompliance regarding the recording of this type of "UNSAT" conditimis.

Based on reviews of p-ocedures7 documentation, and ir.terviews with personnel this assessment did not find an evidence that "UNSAT" conditions were not reccrded nor that tfe construction and inspection activities related to the concern were fonducted in other than compliance with the applicable procedures. Since there was procedural compliance and the alleger did not identify or state tiat there was procedural noncompliance, there is assurance that the "UNSAT" conditions were identified as required and included in the trending program. Accordingly, this allegation was not substantiated.  ;

d. 4-85-A-130: A concern was raised by an anonymous caller that a design ~;Bange authorization (OCA) allowed the reduction of No. 16 AWG ,

sized electrical wire to No.18 AWG size, and that this was a breakdewn of the engineering controls. The DCA identified by the caller was DCA 18 016 dated July 8, 1983. This DCA affects the internalwiringoffourterminationcabinets,1-TC22and1-TC23in l

25 Unit 1 and 2-TC22 cd 2-TC23 in Unit 2. These termination cabinets are located in their respective unit's 1cher cable s' eading roem.

When a cable connector was added to each of these termination cabinets in order to connect its internal wiring to the appropriate section of the main control board, it was determined that the conctetor would only accept connection to No.18 AWG, or smaller electrical wire. Thecabinets'internalwiring,whichwasinstalled by the vendor, was specified on drawings numbeied W-TC22701 0, W-TC22702-0, W-TC23701-D and W-TC23702 0, for cabinets 1-TC22, 2-TC22,1 TC23 and 2-TC23, respectively, to be 16 AWG minimum ,

stranded, copper with 17 mil Tefzel insulation, gray. In an effort to resolve tie prcblem of the installed wiring being larger than the connector would accept, DCA 18,016 was initiated.

The OCA 18,016 solution states, "Use the #16 AWG Tefzel wire for the i internal connections from the terminal strip to the connector.

Re: rove enaugh strards from the #16 AWG, by using the #18 AhG stripper to i endofwIres.reducethesizeofthewireto#18AWGattheconnector Note: This DCA is for clarification only. Design l review is not necessary." A Field Design Change - Desi Verification Report was, however, co nleted on June 3, gn 1984 This report concluded based on a telephone conversation with the vendor, that"approvalofthisDCAisbasedontheassurancethatthe#16AWG Tefzel wire will beccee no less than a size #18 AhG when the strands are recoved."

following the hRC inspector's questioning of the feasibility of performing the OCA's proposed solution, he was inforced that tests conducted by the applicant ccnfimed the renovel of strands with a wire stripper was inpractical.

Initial inspection of this subject identified what appeared to the NRC inspector to be, less than 16 AWG size internal wiring connected to terminal board, TB-2, in the Unit 1 termination cabinets,1-TC22 and 1 TC23; additionally, these wires had orarte and green colored  :

insulation, respectively. The wiring in the Unit 2 cabinets, 2 TC22 and 2 TC23, appeared to the NRC inspector to be the correct wire size which had the specified, gray colored insulation. In an effort to verify the acceptability of the wiring in the Unit 1 cabinets, a review of the vendor surveillance, receiving inspection and installation /rodification documentation w, s conduci,ed. The MC inspector was unable to locate any record dat other than the specified (#16 AWG, gray Tefzel insulated) wiring had been installed by the vendor or any docurentation to indicate that a wiring change i had been authorized onsite. The applicant's representatives, .

however, have provided information, in response to the NRC inspector's requests, to indicate that changes to the installed wiring in 1-TC22 and 1-TC23 have been authorized by DCAs 8939 and 8940 fo't' the use of additional wire, if required, to cocplete earlier l l

wim .c N tions; however, no records had been located, as of the eno1 pcrt period to indicate which wire was actually insi> i how the #16AWG wire was reduced to #18/.kG. This matter is -

s 9d item ending completion of the applicant and NRC re, w 3603-U-03 .

The e,, . ant's representatives also provided the NRC inspector with complet e copies of the con!.truction operation travelers .

(EE85-11596-2-5202andEE85-11693-2-5202) which were used to inttall the cable connectors in the Unit 2 termination cabinets, 2-TC22 and E-TC23. Review of these documents indicated that it was recognized that the solution proposed in DCA 18,C16 was impractiesl, and instructions were included to use small, diagonal pliers to remove 6 of the 19 strands from the No.16 AWG wire so that connection to the connector could he accomplished. The DCA, however, was not revised to reflect this new solution. The failure to revise the DCA is an apparent violation of Criterion V of Appendix B to 10 CFR Part 50 (446/8602-V-08).

6. Pipo Supports During a previous pipe support inspcction, the HRC inspector observed two baseplates of pipe support No. AF-1-035-029-533A, which were attached to the wall with eight 1" Hilti Kwik Bolts, three of which were installed

, through an embed plate. Subsecuent to thi: inspection, idditional review of the documentation identifiec a violation.

A B&R memo dated October 19, 1980, addressed drilling through an embed plate and hitting a rebar at a 5-1/2" depth that appeaced tn run at a 45" angle to the vertical. The response nm the design engineer stated that ',

no structural rebar should be encounL. red at this location and depth and was probably a construction installed "Template" bar and could be cut as required.- -

On November 6, 1980, NCR 14-80-00161 was initiated, addressing drilling through the rebar and the requirements of B&R Procedure CEI-20 which  :

states that engineoring approval is requirad to cut robar. In additior.,

the NCR stated that the above mentint.ao meno gave approval for drilling through the probable template bar at the 5-1/2" depth; however, the NCR l also identified two other cut rebar. The tentative disposition of the NCR was "use as is " In support of this disposition, DCA 0091 was initiated j on November 18, 1980, addressing cne cu: rebar. The solution of tne OCA stated th t the described Condition is acceptable. The DCA also listed the NCR as being su;;,orting documentation. As a result of the DCA approval, tne NCR was closed on December 19, 1980, and it referenced OCA 9091 as support for tha "use as is" disposition.

t l

The 15:. fviolation ailure to(445 disp /864V-04).osition all of the identified nonconforming conditions l

I w . -- ,- .- -. m.

7. Followup on NRR Liner Plate Concerns A public meeting was held on November 5-6, 1985, in Granbury, Texas, to discuss licensing issues for the Comanche Peak project. The subject of deviations identified during the reinspection / verification sampling program was addressed by ERC and NRR. Personnel from ERC indicated that excessive undercut on cnntainment liner welding had been identified as a deviation from inspection procedure requirements, and documented on a DR.

The safety significance evaluation ($5E) group from ERC analyzed specific cases where excessive undercut exists and determined that the safety function of the containment liner had not been impaired. The basis for this conclusion was that the specific material properties provide a design margin that is not compromised by the depth of the undercut identified.

Personnel from NRR expressed concern that the identified deviation was a code violation (prop;ad Section III, Division 2 of the ASME Code) and questioned what actions would be taken by the applicant. The team leader for ERC's QA/QC review team responded that a minimum of three actions 1 would be taken by the applicant: determine if corrective action is necessary; determine if applicable connitments were violated; and determine reportability requirements per 10 CFR Part 50.55(e).

Due to the expressed concern identified 'uy NRR, a more comprehensive evaluation of quality of construction for containment liner plate was initiated. The NRC inspector identified that ERC Verificatio Package No. I-S-LINR-060 DR-2 documented undercut greater than 1/32", , hich h a deviation from quality standards required by paragraph CC-4542.3 in ACI-359. This paragraph states, "The surface of welds shall be free from coarse ripples or grooves, overlaps, and abrupt ridges or valleys. Abrupt changes in section thickness such as undercuts or reinforcements which do not exceed 1/32', and which do not encroach on the section thickness required to satisfy the rules of CC-3000, are permitted. The surface condition of the finished weld shall be suitable fe .he proper interpretation of nondestructive examinations (NDEs) of the weld. If the surface of the weld requires grinding, care shall be taken to avoid reducing the weld or base material below the required thickness."

In addition to tne abnve requirement, G8H Specification 2323-55-14, Revision 3, paragraph 8.4.2.3 states, "The surface of welds shall be free from coarse ripples or grooves, overlaps, and abrupt ridges or valleys.

Abrupt changes in section thickness such as undercuts or reinforcements which do ,at exceed 1/32 ia, and which do not encroach on the section thickness required to satisfy the design are permitted. The surface condition of the finished weld shall be suita)le for the ) roper interpretationofnondestructiveexaminations(NDEs)oftieweld. If the surface of the weld requires grinding, care shall be taken to avoid reducing the weld or base material below the required thickness."

As a result of ERC DR I-S-LINR-060-Oh-2 being issued and validated, TUGCo issued NCR M,85-101128SX. This NCR was awaiting disposition as of the end of this report period. Review of the disposition of this NCR is an open item (446/8602-0-09).

The NRC inspector reviewed portions of the following containment liner QA records: welding procedure specification; welder qualification records; NDE procedures; NDE personnel qualifications; Chicago Bridge & Iron Co. (CBI) quality assurance manual; CBI RT film and reports of RT examinations; and CBI record drawings, which document all containment liner weld joint fabrication activities. -

While reviewing RT film and reports of RT examination for Unit 2 containment liner welding of seam No. P84, Film #146, the NRC inspector noted that the term "pickup and reshoot" was entered in the remarks column and film grading was marked unacceptable for a line entry documenting the results of Film #146 Tracer 2. Tracer 2 was required due to weld {

inclusions identified by CBI when grading Film #146.

Discyssicr. with a CS! C' typeriptanciant ravaaled that "pickups" are surface imperfections that require additional work for cnsmetic purposes on the area in question to comply with specifications, code and/or CBI requirements and customer /CBI evaluator interpretations.

The NRC inspector reviewed the CBI RT examination procedure, RTP-(74-2427/8), and noted that paragraph 5.1 states, "The weld ripples or weld surface irregularii.ies on both inside and outside (where accessible) shall be removed by any suitable means to such a degree that the radiographic image due to any irregularities cannot mask or be confused with the image of discontinuity." In addition to the surface preparation requirsment before performing radiographic examination, a CBI inspector who was certified as being qualified for visual examination (VT), had signed the finish joint checked column on the record drawing, indicating that fabrication of the weld joint complied with the applicable specifications and standards.

Section CC-5521.1.1 of ACI-359 states, in part, "If the 12" radiograph in the 50-ft-long increment of weld does not meet the acceptance standards, two 12" film shall be taken at other locations within the 50-ft-long increment . . . if either of the second radiographs does not meet the  :

acce)tance standards . . . the remai l of tais weld shall be radiographed.,ning portion of the 50-ft increment

! Subsequent to the unacceptable film grading of Film #146 T2, CBI welders ,

l deposited additional filler material to resolve the unacceptable linear indication identified by markup of the radiographic film. The additional weld material did eliminate the marked-up indication. However, the NRC inspector identified that an unacceptable linear indication existed at l film location #146 T2 in addition to the "pickup" (additional welding) l performed by CBI to remove an unacceptable linear indication, t

i Section CC-4545.3.1 of ACI-359, defect removal, states, "Unacceptable l defects detected visually or by the examinations required by CC-5500 shall

, be removcd by mechanical means or by thermal gouging processes. The area prepared for repair shall be examined and comply with the requirements of CC-5533(MT)orCC-5534(PT)."

(

i i

- ~ , - - . _ . _ . _ - _ - -~ - _ - , . . _ _ _ ._ --

Contrary to the requirements of ACI-359, CBI did not expand the radiographic film examination of containment liner welding when an unacceptable tracer location linear indication was identified; performed unauthorized, undocumented repair welding at the tracer location; and failed to implement the required flDE examinations when repair welding was performed. These findings constitute a violation (446/8602-V-10).

8. CPRT ISAPs (Excluding ISAP Ho. Vll.c)

a. Flexible Conduit to Flexible Conduit Separation (ISAP No. 1.b.1)

The objectives of this action plan are (1) to determine by testing and analyses the minimum acceptable separation between two cable trains within SERVICAIR flex and (2) to reinspect all panels which poteatisily cculd violate the final separation criteria.

Paragraph 4.1.4 of this ISAP requires: (1) revision of Drawing 2323-El-1702-02, "Cable and Raceway Separation Typical Details," and any other related documents to reflect this final separation criteria (2) revision of the applicable QC inspection procedures; and (3); review of these revisions by the Review Team Lcader(RTL). NRC inspector review of the above documents disclosed the following: (1) DCA 21,446, Revision 1, dated October 8, 1985, approved modifications to the control board internal wiring separation criteria by providing revised and additional typical details for separation requirements to Drawing 2323-El-1702-02, Revision 2; (2) TUGCo Instructions QI-QP-11.3.40, "Post Construction Inspection of Electrical Equipment and Raceways," Revision 21, dated January 8,1986, and Ql-QP-11.3-28, "Class 1E Cable Terminations,"

Revision 28, dated March 7, 1986, both reference the revised separation requirement by drawing details and specifically discuss the Servicair flexible conduit; and (3) there were no records in the CPRT files to document the RTL review of the above changes.

Documented review by the RTL will complete this item (NRC Reference No. 1.b.01.07).

No NRC violations or deviations were identified.

b. Co_nduit c to Cable Tray Separation (ISAP No.1.b.3)

The objective of this action plan is to substantiate thu acceptability of the criteria governing the separation between conduits and cable trays, and submit the evaluation and supporting i documentation to the NRC.

The NRC inspector evaluated the CPRT files to determine which of the aspects of this action plan had been completed. The five as t involved are: (1) report submittal to the NRC, (4) qualification, personnel preparation, and (2) report review report (5) acceptance / decision criteria.

[

Review of the CPRT working files revealed that the initial analysis of conduit to cable tray separation was provided by G&H letter dated September 27, 1984. This analysis was required because no formal analysis had been perforced to justify the design and construction documents. Review of the G&H analysis by the RTL and the Third Party Advisor resulted in clarifications to, and the removal of inconsistent assumptions from, the provided analysis. These prelems were discussed in the RTL's March 12, 1986 memorandum. A final revision of the analysis was provided in the G&H letter to TUGCo dated March 6, 1986.

The RTL approved Revision 0 of the results report (RR) on March 14,  !

1986, and transmitted the report to the SRT. The SRT requested certain clarifications to the report which were incorporated into Revi.-ica 1 by the RTL, Revi:icn 1 of the RR was approved by the SRT on March 26, 1986.

The NRC inspector also reviewed the FSAR change request docurentation. (A FSAR change request is required to be initiated as part of the Action Plan.) The initial FSAR change request was submitted to TUGCo by G&H letter dated September 19, 1985; comerts by the TUGCo FSAR coordinator have resulted in a finalized change request.

Further review of the CPRT files for this ISAP indicated that appropriate personnel resumes and objectivity questionnaires were included and acceptable; therefore, this aspect of this ISAP is considered complete.

Revision 1 of the RR concluded that the separation criteria for conduit to cable trays meets the intent of IEEE-384 (1974) and Regulatory Guide 1.75, Revision 1, January 1975, and, therefore that the acceptance criteria had been met and no root cause evaluation was required.

The formal submittal of the RR will be evaluated for technical adequacy and documented in separate correspondence.

No NRC violations or deviations were identified.

c. QC Inspector Qualification (ISAP No. I.d.1)

During this report period, NRC inspections were conducted for the activities identified by NRC Reference Nos. 1.d.1.03, and 1.d.1.04 SET Evaluation of ASME and non-ASME Inspector Qualification (NRC Reference No. 1.d.l.03)

The NRC inspector confirmed that the Special Evaluation Teau (SET) had completed the Phase !! review of the remaining inspector qualifications by reviewing the sumary sheets for these inspectors.

Additional inspectors may be added as a result of other ISAPs. The summary sheets were found complete and to treet the requirements of this ISAP. Using the Phase 11 review as a basis, the SET validated the Phase I reviews conducted by TUGCo Audit Group of non-ASME inspectors and the Phase I reviews conducted by ERC of ASME inspectors. These reviews wore previously reported by the NRC inspector. Sumary sheets requiring response from TUGCo are being addressed. The NRC inspector reviewed 5 percent of the TUGCo responses that have been completed and found that the TUGCo responses addressed the SET identified problems. The completed TUGCo responses have been sent to the ERC QA/QC RTL who is responsible to determine if inspectors whose cualifications cannot be demonstrated as satisfactory will be evaluated in Phase 111. The NRC inspector will review the results of these evaluations as they are completed.

No NRC violations or deviations were identified.

Phase Ill Sample Selection and Reinspection (NRC Reference No. 1.d.l.04)

The NRC inspector reviewed the qualification records system utilized by TUGCo. The qualification records system was found to be a computerized program of required qualifications versus inspector certifications. The system provides a means of ensuring that collected qualification data can be recorded in a clear and concise form that is readily retrievable. Additionally, the system provides an effective means of identifying inspectors requiring updates to their certification files such as annual evaluations or annual eye exams. This system is in part a result of recommendations coming from the implementation of this ISAP.

No violations or deviations were identified,

d. Guidelines for Administration of QC Inspector Tests (! SAP No.1.d.2)

During this report period, NRC inspections were conducted for the activities identified by NRC Reference No.1.d.2.02.

Evaluate Recomendations and Revise Instructions (NRC Reference Ho. 1.d.2.02)

The NRC inspector verified that the subtasks in paragraph 4.1.2 of this ISAP have been completed. The daughter instructions of CP-QP-2.1 have been deleted and their training requirements incorporated into a more comprehensive CP-QP-2.1. Inspector certification exams currently in use by TUGCo have been revised to

, assure that they meet the current procedural requirements of l

CP-QP-2.1. Accomplishment was verified by review of four I

examinations and their exam banks of questions. The NRC inspector l also reviewed other TUGCo improvements made to enhance training, e.g., creation of a "tickler" system to assure updating of inspector l

l l

certifications and eye exams and centralized filing of OJT requirements. No further NRC inspection is planned for this activity.

No NRC violations or deviations were identified.

e. Maintenance of Air Gap Between Concrete Structures (ISAP No. II.c)

The following activities for ISAP No. II.c were reviewed by the NRC inspector during this report period:

Removal of Debris or Rotofoam (NRC Reference No. 2.c.02.00)

The NRC inspector has witnessed cleaning and repair of both single and double walled gaps on numerous occasions. These inspections included witnessing the use of a variety of tools used for debris removal and a review of the overall process.

During operations thisalong:

report p(eriod,

1) the LA-AF the NRC inspector wall gap betweenwitnessed gap cleaning the Auxiliary Building and the Fuel Building, (2) the gap between the Unit 1 Rtactor Building and the Fuel Building, and (3) the gap between the Unit 1 Reactor Building and the Auxiliary Building. tiost observations were made from the roof where crews were removing debris at depths of approximately 60 to 90 feet using a variety of specially built tools. Activities were observed using remote video equipment.

No NRC violations or deviations were identified.

Analyze Final As-Built Condition (NRC Reference No. 2.c.03.00)

Calculations by G&H of the minimum gaps required to preclude interactions of Category I buildings and of the internal structures and the containment wall of the Reactor Building (calculations LIS-100c, Set 1 and Set 2) were reviewed by the NRC inspector. These calculations utiliza displacement data from G&H books FMI-1R and FH1-2R, dated September 1975 and December 1976, respectively. The NRC review did r.ot extend to the calculations of the relative displacement data presented in these two books.

l The methodologj *nd assumptions used were compared against the design l comitments coraained in Sections 3.7 and 3.8 of the Comanche Peak FSAR. Numerical calculations LIS-100c, Set 1 and Set 2 and the transfer of relative displacement data from books FMI-1R and FMI-2R were extensively checked.

A third party review of these calculations was done by Hansen, Holley who l

and concluded Biggs that Inc.,the Consulting G&H approach Engineers was under contract to TERATheconclusionsof conservative.

this third party review were examined by the NRC inspector and found

! to be consistent with established engineering practices.

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NRC inspections were not perf armed on other activities during this report period.

No NRC violations or deviatic1s were ider' fied.

f. Improper Shortening of Anchor Bolts in S U .* Generator Upper Lateral Supports (ISAP No. V. d The following activities fo'r '. SAP No. V.b were revie> ad by the NRC inspector during this report :eriod:

Examine Bolts Blind Threadec Holes, and Assembly Dimensional Tolerances (NRC Reference No. 5.b.03.00)

Reinspection of the bolt hoic: and threads in the steam generator upper lateral supports for ali compartments in Unit 1 began on March 25, 1986. The followinj construction operation travelers were used for this rei.ispection:

Compartment No. Traveler No.

1 CE-86-222-8902 2 CE-86-223-8902 3 CE-86-224-8902 4 CE-86-225-8902 A total of 144 bolt holcs are being reinspected by TUGCo and/or Westinghouse personnel. The ravelers include the reinspection of the following six attributes: (1) internal pitch diameter, (2) internal minor diameter, 3) hole depth and thread length, (4)threaddamage,(5) angle fboltinclination,and(6)boltto base plate gap measurement.

The NRC inspector witnessed p.rtial reinspections of from 1 to 6 i

attributes on the following 1: bolt holes:

, Location Bolt Hole Nos.

Compartment 1 West End 1W7, 1W9 Compartment 4 West End 4W1, 4W6, 4W10, $W13, 4W15, 4W17 Compartment 4 East End 4E7, 4E8, 4E9, 4El6, 4E18 Four of the above bolt holes 5 ere unsatisfactory. Boit holes 4W1 and 4W6 had thread damage. Bolt iole 4E7 had a misaligned shim requiring repair before reinspection. Eolt hole 4W15 had excessive bolt to i base plate gap.

l l

o .

34 The NRC inspector also reviewed the reinspection procedures as specified in the abc<e listed travelers and witnessed the exchange of temporary bolts for compartment 1. Temporary bolts were installed in either 3 or 4 bolt holes, in a pattern specified by G8H to provide temporary support of the beams during reinspection.

NRC inspections were not performed on other activities during this l report period.

No NRC violations or deviations were identified.

g. Installation of Main Steam Pipes (ISAP No. V.e)

The following activity was identified in NRC Inspection Report 50-445/86 01; ;0-446/86-01 as being part of the program proposed by the applicant. This activity had not been previously inspected by the NRC.

Activity ISAP NRC Paragraph No. Reference No.

Interview Personnel Involved with 4.2 5.e.02.00 Steam Line Adjustment The CPRT conducted interviews with personnel involved with the steam line adjustmeat, in order to establish a starting point for assessing the steam line adjustment and reconstructing the sequence of events.

Discussions with the involved personnel by the NRC inspector confirred these CPRT interviews. This activity is now complete.

No NRC violations or deviations were identified.

, b. Receipt and Storage of Purchased Haterial and Eouipment

(15AP No. VII.a.9)

ISAP No. VII.a 9, issued during this report period, is a result of a concern by the NRC that verification of material and equipment compliance with procurement / design requirements needed to be l addressed. This is the initial report for this ISAP and the specific activities of this ISAP are delineated in the following table. The j activities will be reported as they are completed.

i Table of Activities for ISAP No. VII.a.9, Receipt and Storage of Purchased Material and Equipment Activity ISAP Para NRC Reference No.

Select Procured Items to be Audited 4.1.2 7.a.9.01 l

Develop Checklists for Program Review 4.1.3 7.a.9.02

' Review Program Documents for Adequacy 4.1.3 7.a.9.03 Develop Checklists for Records Audits 4.1.4 7.a.9.04 Perform Audit of Records 4.1.5 7.a.9.05 Identify Deviations 4.1.5 7.a.9.06 Qualification of Personnel 4.3 7.a.9,07

1. Onsite Fabrication ( ISAP No. VII.b.1)  ;

During.this report period, the activity identified by NRC Reference No. 7.b.1.02 was inspected as follows:

Identify and Select Samples frco ASME and non ASME Fabrication (NRC Reference No. 7.b.l.02)

The NRC inspector verified the selection of safety-related fabricated items. This was accomplished by the NRC inspector witnessing the selection activity in part and subsequent review of the entire sample selection. The sample selection was found to conform to the requirements of this ISAP, para The selection of ASME packages (principallyhangers)isgraph complete. 4.1.2.2.

Selection of non-ASME packages (principally electrical items) is ongoing and will be reported later.

No NRC violations or deviations were identified.

j. Hilti Anchor Bolt Installation (ISAP No. VII b.4)

The NRC inspector has verified implementation of the following activity by witnossing performance of ERC's reinspection / verification effort in accordance with ERC QI-063, "Reinspection of Torque for i

Drilled-InConcreteExpansionAnchors(HiltiBolts):"

Activity ISAP NRC Paragraph No. Reference No.

Torque Verification Program 4.1.7 7.b.04.07 To date, 131 of the estimated 180 torque verifications have been completed, of which the following 18 were witnessed by the NRC inspector and determined to be acceptable per QI-063:

Verification Pkg. No. Equipment Tag No. System *_ Unit No.

I-$-HLTV-010 AB-900-1H AG-01 VA 1 I-S-Hl.TV-216 AB-900-1M-4G-01 VA 1

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E I-S-HLTV-024 FB-810-1F-WP2 VA 1 I-S-HLTV-017 FB-806-1G-WPS VA 1 I-S-HLTV-060 FB-806-1G-WP5 VA 1 I-S-HLTV-037 .0G-844-1X-1AZ VA 1 I-S-HLTV-318 JB15-30130 N/A 1 I-S-HLTV-084 AF-1-043-001-Y43R AF 1 1-S-HLTV-120 AF-1-043-001-Y43R AF 1 I-S-HLTV-205 AF-1-043-001-Y43R AF 1 1-S-HLTV-074 AF-1-043-001-Yt.3R AF 1 I-S-HLTV-315 C16R09450-1 N/A 1 I-S-HLTV 203 AF-1-001-021-Y33R AF '

1 1-S-HLTV-107 AF-1-037-020-533R AF 1 I-S-HLTV-173 CTH-1-341 N/A 1 I-S-FLTV-172 CTH-1-3336 N/A 1 I-S-HLTV-179 CTH-1-5644 N/A 1 I-S-HLTV-175 CTH-1-2696 N/A 1

• VA - Heating, ventilation, air conditioning AF - Auxiliary feedwater system N/A - Not Applicable The acceptance criteria used by ERC was as follows: ,

o The position of the nut was noted prior to torquing by marking the intersection of two flats (point) and the corresponding location on the attached fixture o Torque was applied to the nut and the verification was determined to be acceptable if either the nut did not turn before the applicable test torque value was reached, or the minimum installation torque was reached prior to the nut turning a full turn. If the nut turned one full turn before the minimum installation torque value was reached, the torque verification was determined to be rejectable.

No NRC violations or deviations were identified.

9. ISAP No. VII.c A discussion of the NRC inspection activity is contained in the following subparagraphs for those populations which were inspected during this report period:

a. Electrical Cable Status of CPRT Activity ERC has completed 40 reinspections and 78 documentation reviews of sampled electrical cables as of March 31, 1986. The decrease in the above total completions from those reported in !.'avious inspection reports is the result of ERC rework required by revisions to the

+ 0 acceptance criteria and by the establishment of (and movement of some sampled cables ir.to) a new population f or plant lighting systems. A ciscussion of the lighting population is contained in a subsequent section of this paragraph.

Status of NRC Inspection Activity The completion status for NRC inspection activity is unchanged from the previous report period; 1.e., the NRC inspectors have, as of March 31, 1986, witnessed 21 ERC reinspections, performed 6 independent inspections, and conducted 10 documentation reviews.

The NRC inspector observed two unusual looking electrical cables while conducting an independent inspection related to allegations of improper electrical cable installation. (Seeparagraph5.dofthis Appendix.) The electrical cables were imprinted with "No. BAWG VULKENE SUFREME" and were covered with a brown colored insulation.

The cables had been designated safety related Train A, by the attachment of bands of orange colored tape and were located in Train A cable tray T130CCQ34 in the Unit 1 lower cable spreading room. These two single conductor cables did not appear to the NRC inspector, based on his prior knowledge of the list of approved electrical cable vendors, to be approved for use at CPSES.

Information provided to the NRC inspector by the applicant's QE 1 representatives, identified the cables as a two conductor cable numbered E0106306. In addition, an NCR (No. 82-01977 dated November 10,1982) had been written to question this cable's installation. The disposition of NCR E82-01977 states that cable

E0106306, and the Train B counterpart, sable EG106317, had been supplied by the vendor and were acceptable. A review of supporting records indicated that the cables were provided in October 1982 by General Electric Company (GE) as part of the 125VDC' distribution systems' ground detection circuitry. Review of the AVL Revision 7, dated August 1982 snowed that the vendor, GE of Plainvi,lle, Connecticut, was an approved vendor.

Based on this information, the NRC inspector had no further concerns.

No NRC violations or deviations were identified.

b. Cable Trays Status of CPRT Activity 4

ERC has completed 103 reinspections and 103 doccrentation reviews as of March 31, 1986.

O Status of NRC Inspection Activity The NRC inspectors have witnessed 11 ERC reinspections, conducted 6 indeper. dent inspections and performed 7 documentation reviews as of March 31, 1986; these totals remain unchanged from those previously reported.

The performance of the seven docurentation reviews was reported in NRC Inspection Report 445/85-14; 446/85-11, with the results being '

madeanopenitem(445/8514-0-09) pending comparison of ERC findings for the same reviews. When the comparison of findings was undertaken during this report period, it was discovered that revisions to the applicable procedure (QI-017) had affected the attributes to be verified. Therefore, to assure completeness and clarity, another indepent!ent documentation review was performed of these same verification packages prior to the comparison of review results. The verification packages reviewed were for the following Unit 1 cable trays:

Verification Package No. Cable Tray Q Location R-E-CATY-004 T140C0J17 Cable Spreading Room R-E-CATY-023 T120C8068 Room 121 R-E-CATY-024 T130RCJ28 Reactor Building R-E-CATY-036 T14050A05 Rocm 65 R-E-CATY-055 T120FBUO4 Fuel Building R-E-CATY-060 T120FBUO5 Fuel Building R-E-CATY-129 T120RBK17 Reactor Building Comparison of HRC and ERC review results produced the following connon findings:

R-E-CATY-004: An inspector signed off welding as being satisfactory, but no welding IR or traveler was found. OR R-E-CATY-004-0R01 and NCR E85-101525SX have been written for this de'ficiency. This finding isanoperiitem(445/8603-0-05) pending disposition of the NCR.

R.E-C'.f Y-024 : Using QA records it could not be verified that the Er with symbol BSY was qualified at the time he made the weld on this cable tray. OR-E-CATY-024-DR01 and NCR E85 101525SX have been writtin for this deficiency. This finding is an open item t (445/H03-0-06)pendingdispositionoftheNCR.

No NRC y,Mlations or deviations were identified,

c. Electrical Conduit Status of CPRT Activity ERC has completed 29 reinspections and 80 docur4ntation reviews of sampled electrical conduit as of March 31, 1986. The decrease in the

number of reinspections from the number reported in previous NRC inspection reports has been due to some of the samples being replaced because of selection questions, the implementation of a new population for lighting (discussed later in this paragraph) and some reinspections required by revisions to the applicable procedure.

Status of NRC Inspection Activity The NRC inspectors have, as of March 31, 1986, witnessed 14 ERC reinspections, conducted 5 independent inspections, and performed 15 documentation reviews. These totals are unchanged from those previously reported.

ERC memorandum QA/QC-RT-1626 dated Narch 12, 1986, which transmitted Revision 4 of Ql-008, was reviewed by the NRC inspector. The revisten to this procedure will require backfit reinspections by ERC to verify the proper rating of junction boxes installed in the d

reactor building. The addition of this attribute will provide assurance of compliance with the environmental qualification of terminal blocks installed in these junction boxes.

No NRC violations or deviations were identified,

d. Electrical Equipment j

Status of CPRT Activity ERC has completed 76 reinspections and 20 documentation reviews of sampled electrical equipment installations as of March 31, 1986. The decrease in the number of reinspections and reviews from previously reported totals was caused by t1e rework of completed packages to incorporate additional, new requirements.

! Status of NRC Inspection Activity The NRC inspectors have, as of March 31, 1986, witnessed 11 ERC reinspections, performed 3 independent inspections and conducted 10 docuw ntation reviews; these totals are unchanged from those previously reported.

The NRC inspector began the comparison of ERC and indepenG nt NRC documentation review results for those reviews previously reported as open items (445/8514-0-12 and 445/8516-0-29). The comparison activity could not be completed because 7 of the 10 documentation packages had been returned to the ERC engineering organization for revision in response to ERC memorandum QA-QC-RT-1382 dated February 28, 1986. In accordance with this memorandum, 21 verification packages will be revised, the documentation reviews will

be redone, and the results documented using a new checklist. The NRC inspector will evaluate the need to reperform the NRC documentation i reviews when these verification packages are reissued.

No NRC violations or deviations were identified.

e. Instrumentation Equipment Status of CPRT Activity ERC has completed 107 reinspections and 107 documentation reviews of sampled instrumentation equipment as of March 31, 1986.

Status of HRC Inspection Activity The NRC inspectors have, as of March 31, 1986, witt ised 11 ERC reinspections, performed 7 independent inspections and conducted 5 documentation reviews of sampled instrumentation equipment.

During this report period, ERC reissued all of the previously completed instrumentation packages to the instrumentation inspectors' to reinspect for certain attributes. The attributes reinspect::d included material identification, tubing size, routing, air gap, and bend radius. The NRC inspector witnessed three of these Unit i reinspections during this report period:

Verification Package No. Instrument No. System I-E-ININ-030R 1-PI-4762 Containment Spray 1-E-ININ-034R 1-PI-1094 Boric Acid I-E-ININ-046R 1-FT-918 Safety injection The ERC inspectors identified the following to the NRC inspector as subject to evaluation as potential deviations:

(1) 1-E- ININ-030R:

(a) The tubing innediately adjacent above and below the drain valve did not contain longitudinal color coding for material size, identification, and traceability.

(b) The information to verify flange material identification and traceability was n t included in the verification package.

(c) Four air gap violations (less than 1/8" clearance) between the tubing installation and adjacent tubing runs were identified and are located at: the bottom of the ceiling penetration in room 51; approximately 3'-4" upstream from

, e 41-the floor penetration in room 66; approximately 4'-4" u,nstream from the floor penetration in roca 66; and approximately 4'-6" from the root valve.

(2) 1-E-ININ-034R:

(a) The information to verify flange material identification and traceability was not included in the verification

~

package.

(b) One air gap violation (less than 1/8" clearance) between the tubing installation and an adjacent tubing run was identified, located approximately 4'-6" from the root valve.

(3) 1 F-ININ-046R:

Two air gap violations (less than 1/8" clearance) between the tubing installation and adjacent tubing runs were identified and are located at the bottom of the ceiling penetration in room 54 and approximately 3' north of the vent valve in room 67.

The above six findings are open items pending the NRC inspector's review of ERC's disposition and/or the applicant's applicable correctiveaction(445/8603-0-07 through 445/8603-0-12).

No NRC violations or deviations were identified,

f. Lighting This new population was initiated as part of the ISAp No. VII.c.

reinspection and documentation review program because of installation and inspection differences between plant lighting and other - - - - - - -

electrical systems. These differences would affect the homogeneity of the other populations, i.e., cable and conduit, if the lighting circuits were included.

The procedures that were issued for the lighting system installation required only limited QC inspection of the distribution panels and no QC inspection of the other connection boxes or fixtures.

Status of CPRT Activity ERC has completed 24 reinspections and 62 documentation reviews of sampled lig1 ting circuits as of March 18, 1986, in accordance with QI-071 and QI-072, respectively.

o Status of NRC Inspection Activity The NRC inspector was informed by the ERC electrical engineers on March 18, 1986, that ERC had completed the docttmentation reviews for 4 all 62 verification packages, with few deficiencies being identified.

ERC reinspection of 24 inspection packages resulted in 133 findings, which were documented in 49 DRs. All of these findings were located in various junction or pull boxes, which did not require QC inspection. The most prevalent findings were loose or damaged crimped splices, damaged wire insulation, and too many wires in the connection boxes. (The wire used in the lighting system, except for long rows of fixtures where stranded wire is used, is solid conductor,No.12AWG). l The NRC inspector was also informed that, because of the magnitude and significance of the findings, ERC had ceased inspection activities and was preparing a report to present findings and recommendations to TUGCo. The NRC inspectors will perform some i independent inspections of lighting systems in Unit 2 as the system is installed. i No NRC violations or deviations were identified,

g. Large Bore piping Configuration Status of CpRT Activity ERC has completed 84 reinspections of large bore piping configurations out of the planned random and engineered sample size of 85. The combined sample size was increased from a previous figure of 82 as a result of further evaluation of the engineered sample size ,

in which it was determined that three additional packages were

, - i required to meet the sample criteria. Fif ty-three valid ORf have been identified and issued.

Status of NRC Inspection Activity l To date, the NRC inspector has witnessed reven ERC reinspections and performed four independent inspections, of which the following ,

independent inspection occurred during this reporting period:

Verification package No. Drawing _NA System

• Unit No.

1-M-LBCO-148 BRP-RH-1-58-006 RH 1 RH - Residual Heat Removal While performing the independent inspection, three instances were identified where the separation criteria of paragraph 5.2.6.2 of l QI-025 were not met and documentation could not be located which l

1 i

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would justify this condition. The stated criterion is that a minimum clearance of 2" must exist between two pipes, including insulation, when the operating terperature of at least one of the lines equals or exceeds 200*F. The ERC inspector signed off attribute 1.f on the checklist, which deals with separation, as acceptable.

(1) Line 2-CC .1 060-152-3 is in contact with the inspected line at a location 6'6" north of wall 7-5 and 10' west of wall D-S. The two lines are parallel and are in contact for about 4',

, (2) Line 2-CC-1-061-152-3 is in contact with the inspected line at a location 12'6" north of wall 7-5 and about 8' west of wall D-S.

(3) Line 1-CC-1-062-152-3 is closer to the inspected line than the allowable 2" at a location 6'6" north of wall 7-S and 7'6" west of rail 0-5 These identified instances constitute a deviation (445/8603-0-13).

h. Small Bore Piping Configuration l Status of CPP.T Activity ERC has completed 87 reinspections of small bore piping configurations out of the combined random and engineered sample size

. of 88. Sixty valid DRs have been identified and issued by ERC.

1 Status of NRC Inspection Activity To date, the NRC inspector has witnessed seven ERC inspections and performed two independent inspections, of which the following independent inspection occurred during this inspection period:

l Verification Package No. Drawing No. System

• Unit No.

1 1-N-SBCO-101 BRP-CC-2-AB-044 CC 2

• CC - Component Cooling Water System No NRC violations or deviations were identified.

1. Instrument Pipe / Tube Supports Status of CPRT Activity ERC has completed 106 reinspections of instrument pipe / tube supports out of the combined random and engineered sample size of 111. Three hundred thirty-nine va14d prs have been identified and issued by ERC.

ERC has ccmpleted 34 document reviews of these packages with 4 valid DRs being issued to date.

-44 Status of NRC Inspection Activity To date, the NRC inspector has w'itnessed four reinspectinns and perforr.ed seven independent inspections of which the following two independent inspections occurred during this reporting peried:

Verification Instrument Package No. Tag lio. System

• Unit No.

I-S-INSP-107 1-PT-2326-C MS 1 I-S-INSP-126 1-PT-2328 MS 1

• NS - Main Steam, Reheat and Steam Dump No NRC violations or deviations were identified.

j. HVAC Duct Supports Status of CPRT Activity A total of 89 HYAC duct supports were randomly selected from a population of 2580 supports representing Units 1, 2, and connon. To date ERC has inspected 79 supports and initiated 253 DRs, primarily in the areas of undersize welds and configuration discrepancies. Of the 253 DRs, 233 have, to date, been established as valid.

Status of NRC Inspection Activity To date, the NRC inspector has witnessed seven ERC reinspections and performed one independent inspection. The independent inspection and results, are as follows:

Verification -

Duct Package No. Support No. System

• Unit No.

1-5-HV05-075 DG-844-2K-1J DG 2

• DG - Diesel Generator I S-HV05-075: QI-035, Revision 0, requires that verification be made with respect to weld sizes meeting the requirements of the duct support detail drawing. The checklist applicable to this verification package showed that the ERC inspector had measured and accepted two skewed fillet welds using a Fiber Metal Fillet Gauge.

The NRC inspecter found that neither a Fiber Metal Fillet Gauge nor any conventional measuring device could be used to neasure one leg of the fillet on each weld.

The ERC inspector's acceptance of these welds is an NRC deviation (446/86020-11).01-035 requires verification of member lengths and all other dimensions that describe the lengths and positions of members in the support frame. This attribute on the checklist was signed off as

, being seceptable by the ERC inspector. The NRC inspector identified that for several members, there was either a lack of, or insufficient information provided in the drawing. Therefore, verification of member lengths could not be performed.

The ERC inspector's acceptance of this attribute is an NRC deviation (446/8602-D-12),

Section 5 in Revision 2 of CPP-008 states in part, ". . . Should an attribute appear on the generic checklist and not be applicable to the specific item, the engineer indicates 'N/A' and provides reeivinable justificatlun for the entry." The NRC inspector observed that attributes 2F.1, 2F.2, and 2F.3 dealing with embed plates and spacing violations had been N/A'd by the engineer. The noted justification for this entry was "Mo embedded Pls;" however, the NRC inspector identified the existence of an embed plate with dimensions of approximately 20'X8".

The engineer's error relative to this attribute is an NRC deviation (446/8602-0-13).

k. Reinspection of Small Bore Pipe Su %o,'ts ,

Status of CPRT Activity t

Reinspection of the combined random and engi.nered sample of 76 small

, bore pipe supports is complete. Ninety-seven deviations have been identified, and to date, 53 have been evaluated as being valid.

Documentation review is also complete with 23 valid deviations identified. Thus far, a total of 56 valid deviations have been evaluated for safety significance with no safety significant deviations being identified.

Status of NRC Inspection Activity l

, The NRC inspector has witnessed 7 reinspections and independently

inspected 11 small bore pipe supports. The following three supports were independently inspected during this report period

l Verification Pipe Package No! Support No.

• System Unit No. L I-S-SBPS-031 WP-X-AB-042-010-3 WP Connon L I-S-SBPS-034 SW-1-SB-013-009-3 SW 1 i

~

I-5-SBPS-246 CH-X-FB-C09-002-3 CH Common

• CH - Ventilated Chilled Water system SW - Service Water System Wp - Solid Waste Processing Systeci The NRC inspector reviewed ERC Description Memorandum QA/QC-RT-1436 and ERC QI-019, Revision 3. Paragraph.5.3.5(A) of ERC Ql-019 includes the addition of a clarification of the requirements for clearance in the gravity direction between the pipe and the support for sm il bore box frame supports, and states, in part, "Where design shows 0 inch on one side and 1/iti inch on the other side, the sum of both gaps may not exceed 1/8 inch or be less than 1/32 inch *. . . ."

• Nre design shows 0" on bottom (in the gravity direction) then it shall be such with no allowable variation."

1 The clarification preceded by an asterisk was not included in previous revisions of QI-019.

Section II of ERC Description Memorandum QA/QC-RT-1436 lists changes incorporated in Revision 3 of ERC QI-019 and, with respect to a paragraph 5.3.5(A) states, in part, "Added clarifying information on allowable clearances for dead weight and 0" clearance

~

supports . . . ."

Attachment A to the above ERC Description Memorandum lists previously 4

issued reinspection packages and states that Verification Package I-S-SBPS-051 is not affected by changes incorporated in Revision 3 of ERC QI-019.

The NRC inspector previously measured a gap of 1/16" in the gravity

- - direction for Verification Package-I-S-SBPS-051. -Drawing CP-AA-0a0, Revision 0, for this pipe sup> ort specifies a clearance of zero in

. the gravity direction. The c1anges in Revision 3 of QI-019 do, in fact, affect the previous inspection of Verification Package I-S-SBPS-051. ThiscoriditionisanHRCdeviation(445/8603-0-14).

1. Documentation Review of Fill and Backfill Placement Status of CPRT Inspection Activity

- Documentation review of fill and backfill placements is nearly mnplete with 179 of 180 packages reviewed. A total of 310 valid deviations have been identified. ERC DR R-S-FILL-GEN DR-1 was issued to address inspector certification for the safe shutdown irrpoundment dam construction during the period April 24, 1976,Freese & Nicholsthrough Apr 1977. Inspection certification documentation for Consulting Engineers and Mason & Johnson Associates, Inc. could not be located. This OR applies to 60 of the 180 fill and backfill packages and is an open item (445/8603-0-15).

Stat'us of NRC Inspection Activity The NRC inspector performed independent documentation reviews of the following seven fill and backfdll packages:

Verification Package No. Inspectors Daily Report No.

R-S-FILL-015 1184 R-S-FILL-027 1425 R-S-FILL-035 1417 R-S-FILL-043 1191 P.-S-FILL-125 B&R Dated 12/1/77 R-S-FILL-140 BAR Dated 12/29/77 R-S-FILL-143 B&R Dated 9/14/77 No NRC violations or deviations have been identified,

m. Inspection of hon-Pressure Boundary _ Welds for a Supplerentary

, :aluation of Visual Welding Inspection Techniques Status of CPRT Activity To date, 52 randomly selected samples of weld joints obtained from ISAP Nos. VII.b.3 and V11.c populations have been inspected before removal of coatings. The following 29 were inspected during this report period:

Verification Pkg. No. Equipment Tag No. System

• Unit 1-5-NPBW-015 RC-1-135-907-C47W RC 1 1-5-NPBW 077 RC-1-135-909-C47W RC 1

< l-5-NPBW-045 1-TE-5400' N1 1 1-S-NPOW-041 MS-1-003-904-C77W MS 1 l-S-NPBW-071 CC-1-RB-004-007-3 CC 1 l-S-NPBW-008 VME-1 VA 1 l-5-NPBW-051 8"X18"-90 VA 1 l l-S-NPBW-076 RMD-1 VA 1 1-S-NPBW-086 EMD-6 YA 1 1-5-NPBW-066 EMD-1 VA 1 1-S-NPBW-033 54"X38" Str Duct VA 1 r 1 5-NPBW-026 CB-830-1N 1R N/A 1 1-S-NPBW-068 FW-1-017 912-C47W FW 1 1-S-NPBW-025 FW-1-017-913-C47W FW 1 1-S-NPBW-043 CP2-MEFT1F-01 N/A E l-5-NPBW-107 CT-1-008-001-5225 CT 1 1-5-NPBW-111 AF 1-101-001-523K AF 1 1 5-NPBW-104 CC-1-RB-033 007-3 CC 1 1-S-NPBW-101 CC-1-228-007-C53R CC 1 l-S-NPBW-109 CC-1-126-702-F43R CC 1 i

l l

l

I .

I-S-NPBW-097 EMD-2 VA 1 I-S-NPBW-085' CP-1-ELDPEC-05 N/A 1 I-5-NPBW-096 AB-810-1L-WP23 N/A 1 I-S-NPBW-098 MS-1-RB-036-007-2 MS 1 I-S-NPBW-091 BSC SUB SMD-2 VA 1 I-5-NPBW-092 AF-1-102-031-543R AF 1 I-S-NPBW-087 CC-1-EC-006-005-3 CC 1 I-S-NPBW-083 CC-1-EC-007-013-3 CC 1 I-S-NPBW-110 CT-1-Gt7-007-C92R CT 1 l To date, 27 of the randomly selected weld joint samples have been <

inspected after removal of coatings. The following second phase <

inspections (20) were performed during this report period:

Verification Pkg. No. Equipment Tag No. Sy stem

• Unit I-S-NPBW-035 AF-1-043-001-T43R AF 1 I-S-NPBW-063 AF-1-001-021-Y33K AF 2 I-S-NPBW-005 1-FI-4695 NI 1 1-5-NPBW-014 FW-1-019-902-C57W FW 1 I-S-NPBW-046 FW-1-102-901-C57W FW 1 I-S-NPBW-077 RC-1-135-909-C47W RC 1 I-S-NPBW-015 RC-1-135-907-C47W RC 1 I-S-NPBW-016 I-LS-4795 NI 1 I-S-NPBW-052 1-FT-156 NI 1 I-S-NPBW-025 FW-1-017-913-C47W FW 1 I-S-NPBW-010 MS-1-001-902-C77W MS 1 I-S-NPBW-017 MS-1-001-908-C67W MS 1 I-S-NPBW-004 FW-1-017-908-077W FW 1 I-S-NPBW-041 MS-1-003-904-C77W MS 1 I-S-NPBW-076 RNO-1 VA 1 I-S-NPBW-051 8"X18"-90 VA 1 I-S-NPOW-026 - -CB-830-1N-1R N/A ~ 1 I-S-NPGW-091 BSC SUB SMD-2 VA 1 I-S-NPBW-067 SG-1-852-1J-1AF N/A 1 1-5-NPBW-008 VME-1 VA 1

• RC - Reactor Coolant System; NI - Nuclear Instrumentation; MS -

Main Steam System; CC - Component Cooling Water System; VA - Heating, Ventilation, Air Conditioning; FW - Steam Generator Feedwater System; CT - Containment Spray System; AF - Auxiliary Feedwater System; and N/A - not applicable.

Status of NRC Inspection Activity The NRC inspector has witnessed 100 percent of the inspections performed on welding in the coated and uncoated condition. Listed below are thc NRC findings with respect to ERC's supplementary evaluation of visual welding inspection techniques:

. O e .

I-S-NPBW-063: ERC inspection of a 5/16" fillet weld was documented _

"accept" in the coated condition. After the weld coating was removed, the

' same weld was documented "reject" due to a 1/2" long segment of weld being approximately 1/32" undersize. This was documented on a DR and the cisposition of this finding is an open item (445/8603-0-16).

I-S-NPBW-014: ERC rejected, before removal of the coating, the surface of the weld joining item 1 to the support steel identified on Drawing FW-1-019-901A-C57W, in accordance with Ql-062, Revision 0, Attribute 5.2.0 which states "Verify surface of welds are sufficiently free of overlap, abrupt ridges and ripples so proper interpretation of radiographic and/or '

other required NDE could be accomplished." After removal of the coating, ERC documented the surface of weld condition as "Accept." The NRC inspector's examination of the subject weld surface, before and after removal of coating, identified that the weld surface condition was not suitable for NDE due to excessive ridges and ripples that could impair accurate interpretation of NDE results. An NRC review of fabrication records identified that the weld had been examined and accepted by the magnetic particle (MT) method of NDE by CBl. Subsequent to the NRC inspection, ERC obtained an independent NDE Level !!! examiner's opinion, who was contracted from the technical service division of Daniel International Corporation. Following thi: independent examination, ERC issued a DR documenting the weld surface condition as "Reject."

Acceptance of the weld surface condition by ERC, durinp inspections erformed as required by I-S-PWRE-006 and 1-S-NPBW-014, is a deviation p(445/8603-D-17).

I-S-NPBW-107: While witnessing performance of the reinspection, the ERC inspector identified that grinding at the toe of fillet welding exceeded the allowable undercut depth. The ERC inspector stated that the Q1 did not require inspection for base material defects and the finding would be documented as an "out-of-scope observation." An NRC evaluation of the purpose snd scope of Ql-029, tPe applicable Q1 for the population f rom which reinspection /verificatioi PKG-1-S-NPBW-107 was chosen, did not include a requirement to inspe:t base material. The failure of ERC engineering to identify and it clude base material defects as a safety significant attribute which r,an be reinspected, as required by paragraph 5.1 in Revision 2 of ERC's CPP-007, is a deviation (445/8603-D-18).

10. Exit Interview Exit interviews were conducted on March 4 and April 4.1986, with the applicant representatives denoted in paragraph 1 of this appendix. During t1ese interviews, the NRC inspectors sunnarized the scope and findings of the inspection. The applicant acknowledged the findings.

APPEf4 DIX D SPECIAL Utili 2 CABLE TRAY SUPPORT "AS-8UIL" aROGRAll IhSPECTION U.S. NL' CLEAR REGULATORY COMMISS10N REGION IV t

NRC Inspection Report: 50-446/86-02 Constructic, Permit: CPPR-127 Docket: 50-446 Category: A2 Applicant: Texas Utilities Electric Company (TUcC)

Skyway Tower 400 North Olive Street Lock Box 81 Dallds, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Unit 2 Inspection at: Glen Rose, Texas Inspection Conducted: December 11-12, 1985 Inspector: ),

R. [ ale.

d IV Consultant

/o/a/ac Date l

Participating NRR Personnel: R. Lipinski l Participating-NRR Consultants: V. Ferrarini - -

! T. Langowski C. Richards E. Solla Approved: s 8 -% /0A 4/ ~

I. Barnes, Chief, Region IV CP5E5 Group Date Inspection Sumary inspection Conducted: December 11-12,1985(Report 50-446/86-02)

Areas Inspected: Special, unannounced inspection of the Unit 2 safety-related cable tray slipport program.

Results: Within the one area inspected, one violation (seven examples of errors in ',he as-built inspection program, paragraph 3.b) was identified.

Pbfk k60 M 85080 45 0 PDR

-2 i

DETAILS ,

1. Persons Contacted

'J. F. Streeter, TUGCo QA Director  :

• C. R. Hooton, TUGCo Civil Engineering Supervisor

• 0. 2. Jones, TUGCo Unit 2 Project Engineer

• C. A. Biggs, TUGC0 Quality Engineer

• P. E. Halstead, TUGCo Quality Control Manager ,

• H. A. Harrison, TUGCo oroject Manager T. G. Tyler, TUGCo Comanche Peak Response Team Program Director

• J. D. Hicks, TUGCo Quality Control Supervisor

• J. Duncan, TUGCo Quality Engineer

• W. A. Kattness, TUGCo Quality Engineer  !

D. Mercier, TUGCo  ;

• E. J. Hee, TUGCo (Quality EngineerR.L. C1 cud and Associates *

• Denotes those present at the Dececber 12 4985, exit interview.

3

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The NRC inspectors also interviewed other employees of the applicant. ,

2. Safety-Related Cable Tray Support Inspection This inspection was peformed to verify the adequacy of the walkdown l as-built inspection program for Unit 2 safety-related cable tray supports.

i The bases used for this inspection were the following:

! a. TUGCo Procedure THE-AB-CS-3, Revision 0, dated September 3, 1985,  !

. "Cable Tray Hanger ' As-Designed' and ' As-Built' Drawing Development." l 8

j b. TUGCo Instruction Q!-QP-11.10-2A, Revision 5, dated September 12, [

1985, "Inspection of Cable Tray Supports in Unit !!." l i

i c. l

TUGCo Instruction "Installation QI-QP-11.2-1,!n of Hilti Orilled- Bolts."Revision 20. dated Octoh r 24, 1985 l

l d. TUGCo Instruction QI-QP-11.21-1, Revision 13 uated h'overrber 8,1985, "Rwquirements For Visual Weld Inspection."  ;

i

e. Appropriate drawings depicting cable tray cor. figurations and related inspection packages, j A total of 21 cable tray supports were selected by the NRC inspection team [

using a random number generator. The supports were broken down between  !

three buildings. The sar>ple included the following cable tray supports: [

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Reactor Build'ng CTH-2-11929 CTH-2-11592 CTH-2-10101 CTH-2-11516 CTH-2-9774 CTH-2-11529 CTH-2-10059 CTH-2-10119 CTH-2-11570 Safeguards Building CTH 2-10264 CTH-2-7137 CTH-2-10420 CTH-2-11391 CTH-2-11068 Diesel Generator Building I CTH-2-9650 CTH-2-9825 CTH-2-9947 CTH-2-9866 CTH-2-9901 CTH-2-9977 CTH-2-9926 As a result of this inspection, violations were identified in major attributes associated with the cable tray support as-built drawings and QC acceptance of these drawings. .

3. Sunrary of Violations A sunnary of findings from this inspection which are in violation of Criterion X of Appendix B to 10 CFR Part 50 and the appropriate TUGCo procedures or instructions are as follows:

a. Procedure Recuirement i Paragraph 3.2.3 in Revision 5 to TUGCo Instruction QI-QP-11.10-2A t  :

states, in part, "The is in accordance with QC inspector the work shall package verify (s)he drawing .~~completed support This verification '

shall include the following attributes . . . . Verification of dimension shown on the work package drawing (s) . . . . All dimensions shall have field measurement tolerances as follows . . . Modified structural shapes, field cut plates; etc; :1/8" . . . . Cable tray .

span and cantilever tolerance is 26 . . . unless spec!fic directions are given on the work package drawing (s) . . . . The gauge distance tolerance mensured from the center b.e of the bolt / hole to the heel of the angle is 21/4"; for all other shapes, the tolerance is 21/8" . . . . Tolerance for dimension between welded steel attachments on embedded plates is si" when the dimension is shown on the drawing . . . elevation . . . will be verified by Field Engineering (Surveyors)."

Paragraph 2.4 in Revision 0 to TUGCo Proceduro THE AB-CS-3 states, in part "The walkdown drawing shall correctly dtpict the in-field condition including all the information necessary for QC  !

verification. The drawing shall include . . . Support configuration  !

dimensions and material sizes . . . .' i

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l I

i

b. Findings (1) The as-butit drawing for support CTH-2-9774 did not show the vertical dimensienal location of the 3/8"X4"X5" plate in relation to the C-6 channel. Further, the dimensional location of the  ;

tray clamp plate in relation to the C-6 channel was missing.

~

(2) The as-built drawing for support CTH-2-10264 showed the base 4 plate for this support to be 1-3/4" east of support CTH-2-10263 while the field measurerent was actually 1-1/2" West.

(3) The as-built drawing for support CTH-2-10420 showed the location of the C-6 channel iron in Section B-B as being 4-3/8" from a *

, welded conduit support; however, the actual field measurerent was 5-3/4".

(4) The chart in the as-built drawing for support CTH-2-9850 showed

! the "U" dirension for "Clamps Type B" as 1-5/16" while the actual l field measurement was 1-7/8".

(5) The as-built drawir.g for support CTH-2-11510 showed the elevation l of the channel supporting the cable tray as being 846'-06", while the elevation ts measured in the field was 848'-0-1/2".

l (6) The as-built drawing for support CTH-2-10119 showed the gage I

dimension for bolt G1 to be 1"; however, the ac*ual field reasurement was 1.3/16".

(7) the as-built drawing for support CTH-2-9825, showed the "1.1" tray s)an as being 3'-0"; however, the actual dimension at measured in tie field was 5'-C5".

-These findir(4 constitute a violation (446/8602-V-14).

4 Sunnary of Unresolved Items

a. Gap Setween Base Angle and Concrete A gap of 1/16" existed between the base angle of support CTH-2-11570 and the concrete wall. Cable tray support procedures did not address this type of condition, and as a result, may not be reflected in the firial as built analysis. This condition is an unresolved item (446/8602-U-15).

b. The drawing for support CTH-2-7137 showed the adjacent cable tray support identification number as being .48796. Observation of the support showed the stamped nuirter 288796, which was subsequently determined to be the r.aterial heat number. The isometric drawing showed the correct support identification number to be CTH-2-7136.

The reason for the use of a material heat number in lieu of a support number could not be ascertained This item is unresolved (446/8602-U-16).

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5. Exit Interview

'An exit intarview was conducted on December 12, 1985, with the applicant ,

r. ,

representatives denoted h pira;raph 1 of this appendix. During this '

h ,

interview, the NRC insp.e. tors s ;mmarized the scope and findings.of the .

., inspection. The applicant ackn.wledged the findings. l i

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WTELErYNE ENGNEERING SERVICES TRIP REPORT NO. 2200

. PROJECT 6410T HVAC HANGER PROGRAM AUDIT COMANCHE PEAK FRIDAY, JANUARY 17, 1986 Atttendees: L. Shao - NRC R. Camp - TUGC0 D. Jeng - NRC J. J. Rivard - TES T. Westerman - NRC S. F. Superson - TES C. Hoffman - Brookhaven V. Ferrarini - EAS J. Streeter - TUGC0 The purpose of this audit was to determine the status of the HVAC sup-ports at Comanche Peak. Mr. John Streeter of TUGC0'gave an overview of the current status of the Unit I HVAC supports.

9 The following is a brief history of events in this area.

The NRC Construction Assessment Team (CAT) performed field inspections of the Comanche Peak HVAC supports during January, February and March of 1983. During this inspection, welds were inspected on fourteen supports, and nine additional supports were inspected for proper location, configura-tion, conformance to drawing, design and procedural requirements. .*, this time deviations were noted in 45 percent of the welds inspected, while five of the nine supports reviewed for' dimensions had deviations.

Due to the findings of the CAT aLdit of the HVA suppor;., TLGC0 issued a stop-work notice for all Bahnscn Service Company's (Bahnsan installed the HVAC supports) structural welding on March 3,1983. TUGC0 also began what resulted in a four-phase review of the HVAC supports.

Phase ! (3/83) consisted of a walkdown by Bahnsan of 10e random supports. Welds and member dimensions were looked at. Bahnsan reported a numcer of deviations with both welds and dimensions. This as-built infor-mation was transmitted to Corporate Consulting Limited (CCL). (CCL analyzed the HVAC ducts and supports.) CCL found that all the deviations were not safety significant. CCL did coment that all the supports

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%. 22m , -2 ENGINEERING SERVICEc reviewed had relatively low weld and memoer stresses and suggested that the review oe expanded to include supports with larger stresses. This resulted in Phase II.

? nase II (3/83) consisted of a review (no field walkdown) of all l

supports with weld stresses greater than one-half the SSE allowaole (14,000 psi). A total of 240 duct su'pports were identified. It was assumed that the welds of these supports were one-half the size and three-quarters the length of that shown on the design drawings. These reduced weld sizes were ba' sed on weld deviations found in Phase I. An analysis cased on the assumed welos indicated that three of the supports had stresses above the appropriate allowables. However, an analysis of the at-built condition of these three supports indicated strdses below the allowables. Due to the results of Phase I and II, the stop-work order was lifted at the end of April 1083 and work continued.

4 Phase !!! was conducted in June 1983. This phase consisted of a ccm-plete field review of CSS supports. Included n this group were the 180 accessible supports in Phase II and 100 additional supports with weld stresses between 9,000 psi and 14,000 psi. This review consisted of Bahnsan performing the as-builts of the supports and sending this as-built information to CCL for an as-built analysis. All supperts were found to be acceptable by CCL, Pnase IV performed in July 1983 consisted of a detailed review by CCL of the analysis of th6 Phase !! su; ports noted as being inaccessible.

3 Since these supports were inaccessible, CCL used a statistical approach for their evaluation and found these supports to be acceptable.

In addition to the four-phase review by TUGC0 (Bahnsan and CCL),

Evaluation Research Corportion (ERC) is inspecting HVAC supports as part of the Construction Adequacy Plan. ERC has reviewed 68 supports on Unit I 1 noting 202 deviations. The deviations include welding, support configura-tion, and duct-to-support attachment. There were no details of these attribute deviati.ons.

Trad Aeoort W TA rWNE

u. 22w -3 ENGNEERING SERVICES in orcer to complete the Seismic Qualification Report for the HVAC cm and suppor's, Sahtisan is required to send CCL an as-built of the HVAC supoorts to be analyzed by CCL. Preliminary results of the as-built anal-ysis for approximately 500 supports include the following deviations.

Based on analysis, between 50 and 60 of the supports reviewed should have the HVAC duct attached to the support. However, the design orawing contains no detail for the (ttachment.

Of the 50 to 60 supports requiring duct-to-support attachments, 10 have no attachments. The remaining 40 plus do have an attaen-ment in the field.

There is no design detail for the attachment of the duct to sup-port wnich is required by analysis.

There is no analysis for four supports in the Reactor Building.

Five supports have member-dimension deviations.

4 CCL did not receive all of the Bahnsan design changes.

This as-built support analys_is_ began in January.1985, and the project has not yet determined the full impact of these deviations. However, due to these findings, the status of CPSES Seismic Qualification Report of Seismic Category I Duct Work and Hangers was previously changed from "Approved" to "Not Approved" on January 21, 1986.

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__[ James d. Rivard YY hw-8tephenF.S/ person JJR:Jej 1 - Trip Report File 1 --S.O.

1 F. F. Superson Landers (TES(TES))

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APPENDIX E SPECIAL UNIT 2 HVAC DUCT SUPPORT "AS.8UILT" PROGRAM INSPECTION U.S. NUCLEAR REGULATORY COMMISSION l REGION IV NRC Inspection Report: 50-446/86-02 Construction Permit: CPPR-127 Docket: 50-446 Category: A2 Applicant: Texas Utilities Electric Company (TUEC)

Skywcy Tower <

400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Unit 2 Inspection At: Glen Rose. Texas Inspection Conducted: February 25 through March 7,1986 Inspectors: .

/o!&!&,

Date A. Dale.)tIV Consultant

$~ d 0 >--

D.~ L. Jew, RM Coni 0ltant whthv Date Participating NRR Consultants: G. Degrassi J. J. Rivard Approved: 8e I. Barnes, Chief Region IV CP5E5 Group

/oJ6/r4 Date i

Inspection Sunmary Inspection Conducted: February 25 through March 7,1986 (Report 50-446/8602)

Areas Inspected: Special, unannounced inspection of the Unit 2 HVAC duct supports as-built inspection program.

Results: Within the one area inspected, one violation (four examples of errors in the as-built inspection program, paragraph 3) was identified.

"At mAtogy R ^'?^A DOCK PDR G

05000445 PDR

DETAILS

1. Persons Contacted

• B. Farrawood, Project Manager, Corporate Consulting Limited (CCL)

• T. Chambers,ProjectManager,BahnsonServiceCompany.(BSC)

• J. Canup, QA Corporate Manager, BSC

• G. Benfer, Project QA Manager BSC

• W. Walker, QA Engineer, BSC

• C Nelson, Vice President, BSC

• C. G. Hughes, Vice President Operations, CCL

• J. Gore Subcontractor Supervisor, TUGCo

• J.MerrItt,DirectorofConstruction,TUGCo

• T. Brandt, Quality Engineering Supervisor, TUGCo

• J. Kralik, Unit 2 Project Manager, TUGCo

• V. Enolish, Subcontracts, Brcwn & Root

• J. Walsh, Quality Fngineer, TUGCo

• Denotes those persons who attended the exit interview.

The NRC inspectors also contacted other applicant employees during this inspection. .

2. HVAC Duct Support As-Built Inspection Program

a. Unit 1: On January 17, 1986, NRR performed a site audit to determine the status of the HVAC duct supports at Comanche Peak. An overview of the current Unit 1 status was presented by TUGCo.

Subsequent to the site audit, additional information was developed with respect to-the as-built support analysis program which began in --

January 1985. Preliminary results indicated that deviating conditions exist which may impact the existing analysis. Due to the identification of the deviating conditions, the status of CPSES Seismic Qualification Report of Seisinic Category I Duct Work and Hangers was changed by TUGCo from "Approved" to "Not Approved" on January 21, 1986.

A copy of the NRR trip report, which addresses the status, is contained in this Appendix as Attachment ..

b. Unit 2: This inspection was performed to verify the adequacy of the Unit 2 as-built inspection program for HVAC duct supports. The bases used for this inspection were the following:

(1) BSC Procedure QCI-CPSES-012, Revision 4, dated September 6, 1984, "Surveillance and Inspection of Concrete Anchor Bolt Installation Procedure."

(2) BSC Procedure QCI-CPSES-016, Revision 1, dated September 6, 1984, "Verification of Weld Size for Skewed Weld Joints Procedure."

(3) BSC Procedure QCI-CPSES-Oll, Revision 5, dated Septerter 24, 1985, "Visual Inspection of Welds Procedure."

(4) BSC Procedure QCI-CPSES-014, Revision 4, dated Septerber 13, 1985, "Seismic Duct Support Installation Inspection Procedure."

(5) BSC Procedure DFP-TUSI-003, Revision 10, dated itay 6,1985, "Duct Support Design Fat,rication and Installation. Procedure."

(6) BSC Procedure DFP-TUSI-004, Revision 10, dated April 17, 1984, "Drilled-In Expansion Bolts Installation Procedure."

(7) BSC Procedure DFP-TUSI-010, Revision 3, dated April 11, 1984, "Permanent Attachments to Embedded Weld Plates Procedure."

(8) BSC Procedure DFP-TUSI-016, Revision 0, dated April 11, 1985, "As-Built Procedure."

(9) BSC Procedure WP-TUSI-001, Revision 1, dated July 1,1985, "Welding Procedure."

(10) Appropriate Duct Suppert Design Change Requests (DSDCRs) and Duct Design Change Requests (DDCRs) to further clarify the procedures.

(11) Appropriate Deficiency and Disposition Reports that describe and provide disposition of discrepant conditions.

(12) BSC HVAC duct support drawings which had received final QC acceptance.

From a total of approximately 650 HVAC duct support drawings that had received final QC acceptance, the NRC selected the following 32 supports for inspection: ,

Safeguards Building Reactor Building SG-773-2H-WP2 RB-808-VR-21C SG-773-2H-4D RB-808 2A-WP2 SG-790-2H-1Q RB-808-2E-7A SG-790-2H-1B RB-808-20-C2 SG-790-2H-1AC RB-808-2D-1B SG-790-2J-1P RB-832-2E-1G SG-790-2H-RIE RB-832-VR-17D SG-790-2J-1B RB-860-VR-12A SG-790-2H-R1P RB-360-20-1Q

. -4 {

r SG-831-2J-1G - RB-860-VR-7H SG-852-2H-WP16 RB-860-2E-4H SG-852-2J-1AW RB-905-2D-1H

'RB-905-20-4AH Diesel Generator Building RB-905-VR-88 RB-905-RB2-PS-16 DG-844-2K-9A . .

DG-844-2K-1J DG-844-2K-1AA DG-844-2K-1AF 2K-PSS (Drawing No. 2323-M2-0659-01)

As a result of this inspection, one violation of Criterion X of Appendix B to 10 CFR Part 50 and two unresolved items were identified with respect to major attributes associated with the Unit 2 HVAC duct support final QC ,

accepted as-built drawings, and applicable BSC QC procedures and ,

specifications.

3. Summary of Violations to Criterion X of Appendix B to 10 CFR Part 50 (446/8602-V-17) f

a. Intermittent Fillet Welds  !

(1) Procedure Recuirenants (

Section 9.1 in WP-TUSI-001, Revision 1, states, in part, with respect to intermittent welds, "Weld increments shall begin and terminate within 1/8 inch of the ends of the joints or dimensioned length . . . ."

(2) Findings The following list of supports had intermittent fillet welds between the duct and the duct support, which did not begin or  ;

terminate within 1/8" from the joint ends: l SG-790-2H-1Q RB-832-VR-17D SG-790-2H-1AC RB-860-VR-7H  ;

SG-790-2J-1P DG-844-2K-1J SG-831-2J-1G l

b. Qualitative Measurement f (1) Procedure Requirements Section 6.5 in BSC Procedure QCI-CPSES-011. Revision 5, states, i "The quality representative shall make certain that the size,  !

length, and location of all welds conform to the requirements of QCI-CPSES-014andDFT-TUSI-003,andtothedetaileddrawingIds that no specific welds are omitted, and that no specific we have been added without engineering approval."  ;

t i

Section 6.3 in BSC Procedure OCl-CPSES-014, Revision 4, states, "Verify that all welding, (arrount, placement, and type) is in accordance with drawing."

(2) Findings

• HVAC duct support drawing No. 2K-PSS (ref, drawing No.2323-M2-0659-01) requires a 2" long, 1/4" filiat weld between the main support structure and the vertical direction brace. Inspection revealed this weld to be undersized by 50 percent; i.e., 1/8".

HVAC duct support drawing No. RB-905-RB2-PS-16 requires a 2-1/2" long,1/8" fillet weld between the main support structure and each of the two lateral braces. Inspection revealed these two fillet welds to be non-existent.

HVAC duct support drawing No. SG-790-2H-RIE requires a 1-1/2" long,1/8" fillet weld on both sides of the 6" Ivag 2X2X1/4 angle steel directly above the duct. Inspection revealed both welds to be 1-1/4" long,

c. Weld Quality (1) Procedure Recuirements Section 6.6 in BSC Procedure QCl-CPSES-011 Revision 5 states inpart,"WeldprofilesshallmeetthefoIIowingrequirements:

The faces uf fillet welds may be slightly convex, flat or slightly concave . . . Rejectable defects - welds shall be visually examined to determine if the following defects are evident: . . . Undercut shall not exceed 1/32" for material

' ~ ~

thicker than 1/4"."

(2) Findings

• HVAC duct support SG-852-2J-1AW consistinti of 1/2" members, contained 2-4"longfilletwelds'nwhich1/16" undercut was observed in over 50 percent of each weld length.

• HVAC duct support SG-852-2J-1AW contained a 1/4" and 3/8" fillet weld, in which grinding of the weld produced excessive convexity, resulting in an unacceptable profile.

4

d. Anchor Bolt Spacing (1) Procedure Requirements Note 2 in Attachment 4 to BSC Procedure DFP-TUSI-004, Revision 10, states, "Where the embedded steel plates are occupied by attachments within the minimum distance shown above (12 inches), the minimum clearance to Hilti anchors shall be as follows:

Hilti Anchor Nelson Stud Edse of Plate Size To Hilti Anchor To Filti Anchor 1" 9" 7 1/2" (2) Findings HVAC duct support DG-844-2K-1J had a 1" diameter Hilti 11" away from an attachment on an embedded steel plate. However, the Hilti was positioned 3/8" from the edge of the embedded plate rather than the required 7-1/2" minimum.

4 Sumary of Unresolved Items

a. Gap Between Concrete and Support Steel While performing the inspections, it was observed on three supports that the support steel which is bolted to a concrete wall with Hilti Bolts was not completely flush with the concrete wall. Details of gap conditions are listed below:

Support Gap Description _ ,

RB-832-VR-170 Gap existed for approximately 30 percent of the length of the 6X6X5/8 angle steel steel and measures up to .25". The gap encompassed the total area around one Hilti.

0G-844-2K-10 Gap existed for approximately 70 percent of the length of the 6X6X5/8 angle steel and varies up to .375". The gap encompassed the total area around one Hilti.

SG-852-2H-WP16 Intermittent gaps existed between concrete and C 6X8.2 channel steel on the East side. Total gap region encompassed 25 percent of the length and was prevalent at one Hilti, m

I . . .

1 i

From discussion with the applicant, BSC and CCL personnel, it was not apparent that inspection of gap cceditions had been considered as a necessary element for factoring into the CCL reanalysis of HVAC duct supports. This matter is an unresolved item pending clarification by theapplicant(446/8602-U-18).

b. Analysis of SoLare Groove Welds During the inspection, it was noted that certain BSC drawings, in which square groove welds were specified for seismic HVAC duct supports, did not specify applicable groove depths or the required effective throat dimensions. The applicable supports were RB-832-VR-170, RB-860-VR-7H, RB-905-20-4AH, RB-905-VR-8B, RB-905-RB2-PS16, SG-790-2H-1Q, and SG-790-2H-18. It was additionally noted that these attributes could not be verified by the current inspection program. This matter is considered an unresolved item pending additional NRC review (446/6602-U-19).

5. f.xitinterview j

An exit interview was conducted on March 6,1986, with the applicant representatives denoted in paragraph 1 of this appendix. During this interview, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the findings, i

APPENDIX F 4

SPECIAL UNIT 2 CONDUli SUPPORT "AS-EUILT" PROGRAM INSPECTION  !

U.S. HUCLEAR REGULATORY COPJilS$10N 4 REGION IV '

NRC Inspection Report: 50-446/86-02 Construction Permit: CPPR-127 l Docket: 50-446 Category: A2 Applicant: Texas Utilities Electric Company (TUEC)

Skyway Tower 4C0 North Olive Street Lock Box 81 Dallas, Texas 75201 ,

Facility Name: Comanche Peak Steam Electric Station (CPSES), Unit 2 l l

Inspection At: Glen Rose, Texas Inspection Conducted: March 24-27, 1986 l

Inspectors: . /0/M!Ad

. Dale.jRIVConsultant Date l

M1m1 ui 10l1LY8 4 D. L. Jew, RIFCongyTtant Dat'e Participating NRR Consultants: G. deGrassi E. Solla Approved By: 8%

I. Barnes, Chief, Region IV CP5E5 Group ax6./4%

Fate Inspection Susunary 1_nspection Conducted March 24-27, 1986 (Report 50-446/86-02)

Areas Inspected: Special, unannounced inspection of the Unit 2 safety-related conduit support "as-built" program. j l

Results: Within the one area inspected, two violations (five examples of errors l In the as-built inspection program, paragraph 3; and two examples of omissions '

in engineering docuinents, paragraph 3) were identified. I o 45 l G PDR l

-2 OETAILS

1. Persons Contacted

• J.Walsh,TUGCoQualityEngineer(QE)

• C. T. Brandt, TUGCo QE Supervisor

' *J. Morris, Unit #2 PFG Supervisor

• H. Harrison, TUGCo Project Manager .

• C. R. Hooten, TUGCo Nuclear Engineering (TNE) Civil Engineering Si pervisor

• W. Katness, TUGCo QE

0. Mercier, TUGCo QE

• P. Halstead, TUGCo Quality Control (QC) Hanager

• 0. B. Jones, THE Unit #2 Project Engineer

• J. Ferritt, TUGCo Director of Construction

• R. Shetty, Ebasco Unit #2 Supervisor

• D. Elliot, Brcwn and Root (B&R) Unit #2 Paper Flew Group

• R. lotti, Ebasco Unit #2

• Denotes those pr2sent at the March 27, 1986, exit meeting.

The NRC inspectors also interviewed other employees of the applictit.

2. Safety-Related Conduit Support Inspection Program This inspection was performed to verify the adequacy of the Unit

• 2 inspection program for safety-related conduit supports. The baset used for this inspection were the following:

a. TUGCo Procedure CP-QP-11.10, Revision 3, dated August 7, 1984,

_"Inspection of Electrical Raceway / Support Systems."

b. TUGCo Instruction QI-QP-11.0.15, Revision 10, dated November 22, 1985, "Verification of Base Plates for Grouting."

c. TUGCo Instruction Ql-QP-11.2-1, Revision 20, dated October 24, 1985, "Installation of Hilti Drilled-In Bolts."

d. TUGCo Instruction Ql-QP-11.10-1A, Revision 7, dated November 25, 1985, "Inspection of Class IE Conduit Raceway Systens."

e. TUGCo Instruction Q1-QP-11.21-1, Revision 14, dated February '.1, 1986, "Requirements for Visual Weld Inspection."

f. THE Procedure THE-AB-CS-E, Revision 0, dated September 3,19E i, "As-Built Procedure, Design Control of Electrical Conduit Rac ways."

g. B&R Procedure ECP-19A, Revision 2, dattd December 9,1985, "Installation of Class IE Conduit Rae,eway Systems."

3

h. Appropriate conduit isometric drawings depicting conduit support locations and generic drawing types.

From a total of 886 Unit 2 conduit runs which had been final inspected

and accepted by QC, a sample of 60 runs, broken down by building, was selected by a random number generator. This sample included the following l conduit runs with the number of supports shown in each run:

I Reactor Euilding Conduit Run No_. No. Supports Conduit Run No. No. Supports i C23631410 2 C24W12699 3

C22K05045 2 C24B08641 14 C23010070 11 C23031393 1 C24G12469 4 C24B05617 6 i

~

C23G07037 2 C23004447 3 C24WO9197 15 C23006319 1 C23G05453 2 C22G03862 8 i C23G02580 3 C22K03107 1

! C23K00063 2 C22K03102 4 C22K03687 2 C23G31411 1 4 C23004872 2 C23K03916 1 i C23002574 2 C24012311 4

C23G05559 3 C24012271 4 C23031405 4 C24R12707 8

) C24B12708 8 Safeguards Buildi,ng n

Conduit Run No. No. Supports Con _duit Run No. No. Supports 4

C23G06716 2 C23012854 5

! C22K09118 2 C24008085 6 i C23000358 2 C24008835 8 i C24YO8701 2 C22G06621 1 j C23G04735 2 C22K07021 8 i C23006037 2 C23604066 1 l C23010114 3 C23009079 2 4

C23604712 5 C23G05663 6

, C23608956 1 C22007319 3

C23004653 7 C23K00500 2 3

C23010596 4 C23G05671 2 C23606491 4 C23G09639 4 C23GC6356 5 C23009093 8 i C23G05035 4 C22010807 4 C23G04072 2 C23G04292 2 C04K11950 2

-4 As a result of this inspection, violations and unresolved items were identified with respect to major attributes associated with the Unit #2 conduit isometric drawings.

3. Sumary of Violations The following is a surrary of findings from this inspection which are in violation of Appendix B to 10 CFR Part 50 and the applicable TUGCo procedures:

a. Shim Plate Thickness (Criterion X)

(1) Procedure Recuirement Section 3.3.1 in TUGCo Instruction Ql-QP-11.10-1A, Revision 7, states, in part "The QC inspector shall verif the acceptabilityofthesupportinaccordancewit the isoiretric drawing and the applicablo procedures and instructions. The QC inspector shall inspect the support for the following:

a. Member (s) shape (i.e., angle, channel,etc.),sizeand dimensions . . . ."

(2) Findings Support No. 09492-01 on conduit run C23G09539 has a 1/2" thick shim plate installed while a 5/8" thick plate is shown as being required on the support drawing.

• Support No. 01-CSM-7a ! on conduit run C22K05045 has a 5/8" thick shim plate installed while a 1" thick plate is shown as being required on the support drawing (446/8602 V-20).

b. Intermittent Fillet Welds (Criterion Y)

(1) Procedure Requirement Section 3.2.2 in TUGCo Instruction QI-QP-11.10A, Revision 7 states, in part, "All welding and stud welding inspection shall beperformedinaccordancewithReference1-E(TUGC0 Instruction QI.QP-11.21-1,'RequirementsofVisualWeldInspection')."

Section 3.3.1.1 in TUGCo Instruction QI-QP-11.21-1, Revision 14, states, la part "Weld systols tven on design drawings shall be inaccordancewIthReference1- (Attachant13A&B)."

Attachment 132 specifies that the welding sys6cl for intermittent fillet welding should be in accordance with AWS 2,4-79.

(2) Findings The following conduit supports contained intermittent fillet welds between the gusset plates and the face plates; however, the required intermittent fillet welding symbol was not shown on the applicable typical support drawing No. CSM-6C-I and the asp 11 cable length and location.of welds were not clearly shown.

T,1ese supports had been final QC inspected and accepted (446/8602-V-21).

Conduit Run '

Supp,yt No.

C22K03102 01-CSM.Sc-1 C23010070 10-CSM-te-I C24WO9197 01-CSM-6t-1 C23G05559 03-CSM-6c.!

C24012311 01-CSM-6c-1 C24012271 02-CSM-6c-!

C23009079 05495-01,-02 C22K07021 06 ,07 , 08-CSM-6c-!

C23006037 01-CSM-6c-I C22G06356 04-CSM-6c-I C22010807 01-CSM-6c-I

c. Conduit Spans (Criterion X) i (1) Procedure Requirement

! Section 3.5.1 in TUGCo Instruction Ql-Qp 11.10-1A, Revision 7,

. states, in part, "Conduit spans shall be as indicated on the l isemetric drawing. Conduit span tolerance is 23".

A span is defined as the distarce measured along the centerline

, of the conduit from one attribute to another. Attributes us;d i

are as follows:

a. "Clamps - measure from centerline of clamp . . . ."

(2) Finding On conduit run C22010807 t

! 0?-CSM-7a-l!and03-CSMYahespanlengthbetweensupports!! is shown c .duit 1sometric drawing. The actual measured span length was

6 '/2", which was not within the span tolerance

(446/uuw.V-20).

I

+ .

d. Hilti Bolt Spacing (Criterion X)

(1) Procedure Requirements ,

Section 3.3.3 in TUGCo Instruction Ql-CP 11.10-1A, Revision 7, states, in part, "The QC inspector shall inspect the attachment of the support for the following:

a. "Hilti/ Richmond bolt per reference 1-H (' Installation of HiltiDrilled-inBolts'.)TUGCo Instruction QI-AP-11.2-1 ....

Section 3.4 in TUGCo Instruction QI-QP-11.2-1, Revision 20, states, in part, "The minimum spacing specified in Attachrent 5 shall be maintained for all Hilti Anchers, Nelson Studs, Richmond Insarts and embedded plate installation. When reasuring distance between bolts, it shall be measured from center to center of the bolts . . . ."

Attachment 5 shows that where embedded plates are occupied t,y attachn.ents within 12" of Hilti Bolts, then the minimum l clearance between a 3/8" and 1/2" Hilti Bolt and a Nelson l Stud will be 5-7/8" and 6-1/2", respectively.

(2) Findings

'A 3/8" Hilti Bolt on support No. 05-CSH-2a-!! in cenduit run No. C23G05663, was observed being 5-3/8" from a Nelson stud in an adjacent erbedded plate and 7" frem an l l attachment on the embedded plate, f ~

f 'A 1/2" Hilti Bolt on Support No. 01-CSM-2a-1 in conduit  !

l run No. C22K03107, was obserted being 4-3/8" from a Nelson Stud in an adjacent embedded plate and 8" from an attachment on the embedded plate (446/8502-V-20).

i

e. Missing or Invalid Information on Isometric Drawings (Criterion V)

(1) Procedure Requirements  !

l Section 2.4 in TUGCo Procedure THE-AB-CS-2, Revision 0, states in part. "The Field Engineer shall prepare a field isometric  ;

indicating the general routing and location of supports, '

and . . . shall include span lengths and configurations,

, . . decision points and locations . . . . Decision points are  ;

considered as places on a typical drawing for which two or core i options are acceptable for the same location." t

-7 (2) Finding A 3/8" Hilti bolt was observed installed in Support No. 01-CSH-2a-II in 2" diameter conduit No. C23G04066. Review of the applicable typical support drawing No. CSM-24-il showed that a 1/2" Hilti bolt was specified with the option of using a 3/8" Hiliti bolt, provided the support capacity is reduced.

Review of the isometric drawing revealed that the field engineer did not include this decision point. This action could preclude the required reduction in support capacity and validation of the support analysis by the design engineer (446/8602-V-21).

f. Conduit Support Identification (Criterion X)

(1) Procedure Requirer:ents Section 3.2.3 in Revision 7 of TUGCo Instruction QI-CP-11.10-1A states, in part, "Each support inspected on a raceway systen shall be assigned a number shown on the engineering isonetric drawing included in the conduit system werk packages . . . ."

(2) Finding Inspection revealed that a support in conduit run No. C24008835 was physically identified as No. 10624-05; however, the isometric drawing shows that support to be identified as No. 10624 04 (446/8602-V-20).

g. Conduit Configuration (Criterion X)

(1) Procedure Requirements Section 3.9 in Revision 7 of TUGCo Instructice QI-QP-11.10-1A states, in part, "The QC inspector shall verify the conduit supports have been installed in accordance with the requirements of the . . . isometric drawing . . . ." It further requires that ins Step (V)pectionresultsbedocumentedinaninspectionreport.

1.b in the inspection report states, "Verify conduit configuration." ,

(2) Finding Inspection revealed a bend near support No. 05 (CSM-11b-!) in conduit run No. 24B12708, which was cpposite to that which was shown on the isometric drawing and Step (V)1.b of the applicable inspection report was signed off by the QC inspector as being acceptable (446/8602-V-20).

8-

4. Suseary of Unresolved items

a. Conduit Separation NRC inspection revealed that a 5/64" gap existed between conduit run C23010070 and the sway strut for pipe support No. CS-2-235-467-C41R.

Hovement of the pipe causing the sway strut to move in excess of 5/64" in the northern direction could cause damage to the conduit.

Additional information will be required to assure that movement in excess of 5/64" does not occur in the northern direction. This condition is an unresolved ite:: (446/8602.U-22),

b. Baseplate Grouting Documentation could not be located f or the required baseplate greuting associated with the followlig supports:

Conduit Run No. Support No.

C23010070 03-CSM-2a-1 C24812708 C24B12708-07 C24812708 06-CSM 11b-1

, C23G05559 03-CSM-6c-1 l There were numerous support baseplates that required grouting. Per d.,cussions with TUGCo, these bar.eplates are to be subsequently grouted after identification in a room-by-roon inspection. it did not appear to the NRC inspectors, however, that the stated program would provide positive assurance that all required grouting wc,uld be accomplished. This item will remain unresolved pending receipt of additional information from the applicant (446/8602-UJ3).

5. fait Interview An exit interview was conducted March 27, 1986, with the applicant representatives identified in paragraph I of this appendix. During this interview, the SRC inspectors suserarized the scope and findings of the inspection. The applicant ackrewledged the findings, i

M Log # TXX 6388

=M File # 10130

- j iR 86 03

= IR 86 02 iteELECTRIC

% n, row April 24, 1987 U. S. Nuclear Regulatory Comission Attn: Document Control Desk Washington. 0.C. 20555

SUBJECT:

COMANCHE PEAX STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50 445 (ND 50 446 INSPECTION REPORT NOS. 50 445/86 03 AND 50 446/86 02 RESPONSE TO NOV ITEM H (50 446/8602 V 10)

Gentlemen:

Attached is our response to NOV Item H (50 446/8602 V 10). The response was due on February 20. 1987; however, due to the nature of the item, extensions were requested and granted to March 6, 1987, April 10. 1987 and to April 24 1987. The attachment also includes information on the CB&l practice of "pickup and reshoot."

Very truly yours, hh, , o 4 !!dt W. G. C sil , ,

By: \ '

t!

G. 5. Keeley C /-

"anager. Nuclete Lice [ sing GLB/gj c Mr, E, H. Johnson Region IV Mr. D. L. Kelley, RI Region IV Mr. H. S. Phillips. RI Region IV ac 3;w i w trida.'4

• WOCK i8 DH OLOOfj4 b AD %wf% (Wa.f NfTt't II SI b% {

_m

• 1AA bjod April 24, 1987 Page 1 of 4 UOT_ ICE OF V10lAT10B ITEM H (446/8602 V 10)

Criterion IX of Appendix B to 10 CFR Part 50 states, in part "Heasures shall be established to assure that special processes, including welding ... and nondestructive testing, are controlled in ac ordance with applicable codes, standards, specifications, criteria, and other special requirements." i Section CC 5521.1.1 of Code ACl 359, states, in part, "If the 12 in.

Radiograph in the 50 f t, long increment of weld does not meet the acceptance standards . . .the remaining portion of the 50 f t, increment of this weld shall be radiographed."

Contrary to the above, the required radiography of the remaining portion of a 50' increment of weld was not performed even though one of the two second 12" radiographs (No. 146T2) at seam P84 in the Unit 2 containment liner did not meet the acceptance standards.

M iP_031E 10 ITEM H (446/8602 V.101 We deny the alleged specific violation but admit to the related violations resulting from our investigation of the alleged specific violation for tne reasons that follow.

The film (146T2) referenced in the finding was originally evt.luated by the CB&l radiographic film interpreter who deternined that the area needed to be re radiographed to clarify an area of the film. The area of interest was re-radiographed (146T2 RSI) with the radiographic source centered over the area of interest, not over the entire 12 inch length of weld contained in the original (146T2). This was done to increase the radiographic sensitivity in the area of interest and enable the CB&l interpreter to clearly evaluate the indication in the area of interest. The film 146T2 as clarified by 146T2 R51, was interpreted to be acceptable by both a C811 and a Brown & Root level 111 examiner.  ;

Subsequent to the NRC expressing concerns, four other personnel who are  !

independent frem the original reviewers have evaluated the film. All of these personnel are currently certified as tevel !!! RT by their respective employers, and all four interpreters have accepted the film (146T2 R$1) for this area. Based on the initial evaluations and the substantiation of those ,

evaluations by our independent reviewers, the film in question (146T2 as clarified by 146T2 RSI) eeets the applicable acceptance standards; therefore, i additional radiography is not required. To further assure that no defects are present in the area, the paint was removed and the area in question was examined by ultrasenic testing (UT). This additional testing also confirmed an absence of rejectable indications. Since the 12 inch radiograph in question was determined to be acceptable, radiography of the remaininj portion of the 50' increment of the wel) was not required. j Although we do not agree that the alleged specific violation occurred, a r review of the alleged specific violation did reveal the following related '

violations: (1) eleven (11) instances where the description of the surface conditioning indicated on the CB&l RT Report was not a complete representation ,

of the surface conditioning that occurred, and (2) one (1) instance where a [

Code rejectable indication was repaired without performing required NDE. '

V

, Attachment TXX.6388

. April 24. 1987 Page 2 of 4 RESPONSE 10 ITEM H (446/8602 V 10) CQE'Q

l. Reason for. the Related Violatigt.

Regarding the incomplete records:

Either the Welding /QA Supervisor failed to indicate on the temporary record the surface conditioning that actually occurred, or the Welding /QA Supervisor failed to detect that the method of surface conditioning indicated on the temporary record was different than that indicated on the RT Report and update the RT Report.

Regarding the lack of performance of required NDE:

While performing radiography on the horizontal girth seam between the third and fourth rings (Seam Number 3A), a Code rejectable linear indication appeared in the film for film Number 1314. This indication was not in the weld being radiographed, rather in the intersecting vertical weld (Seam Number 3C). The repair was erroneously described on the XI P.eport as "Surface Pickup Made." A review of the records indicates that no PT or MT of the eucavated .rca was performed as required.

2. [arreriht$1tps Taken and Results Achityrd Regarding the incomplete records:

We have reviewed all cases where CB&l did not accept the original radiograph and did not classify any additional work as "repair". This review was of all cases where original radiography was rejected for

density, insufficleat grinding, picku," and reshoot, reshoot at customer sequest, etc. necessitating additional radiography. This review encompassed 111 areas in Unit I and 25 areas in Unit 2. The review revealed instances where it appears that filler metal was deposited yet the RT Report indicates only grinding was performed. This matter is without technical significance because the surface conditioning was

'inally accepted buth visually and by RT examination. Deficiency Report (DR) C87 2129 was initiated to document our corrective actions. No further corrective action is required.

Regardit.g the lack of performance of required NDE:

The purpose of the NDE (MT or PT) of the excavated area is to assure that the defect is entirely removed prior to rewelding the cavity, thereby precluding additional repair of the same defect. In this case, it is clear in the subsequent radiograph that the linear indiention was entirely removed. To ensure that this was an isolated instance, as stated above we have reviewed all cases where original radiography was rejected without

classifying additicnal work as "repair" and found no other cases where

! Code-rejectable indtrations were removed without performance of NDE of the i exc n nted cavity before rewelding. Nonconformance Report CM87 5551 was init ated to document our corrective actions. No further corrective action is requb ed.

l . Attachment l TXX 6388 l '

April 24. 1987 Page 3 of 4 RESPONSE 10 ITEM H (446/8602 V 101 CONT'D

3. Corrective Steos Which Will be Taken to Avoid Further Violations The installation of the Unit I and 2 containment liners is complete; therefore, no preventive actions are required.

4. Qate of Full Comoliance Full compilance has been achieved.

Sysolemental Information on a Related Issue Although not noted as an issue in the NRC Inspection Report, the details of the report appear to identify an open item involving the CB&l practice of "oickup and reshoot." The following is submitted to provide clarification of that practice. Radiographic examination requirements for weld seams of the containment liner are specified by Gibbs and Hill Specification 2323 55 14 "Containment Steel Liner." and Regulatory Guide 1.19. "Nondestructive Examination of Primary Containment Liner Welds." These requirements provide assurance of a uniform quality level of welds by assuring continued satisfactory welder performance.

The area originally radiographed as area 146 was rejected for slag and unacceptable porosity. Two tracer areas. 146T) and 146T2. were subsequently radiographed as a result of the original rejected radiograph. 146T1 was determined to be acceptable. 14612 was determined to be unacceptable and marked "pickup and reshoot"; however, the RT report does not note any weld defect as the reason for rejection, e.g., porosity, slag, linear indication, etc. The additional surf ace conditioning (i.e., a pickup) of the weld was necessary to properly interpret the film, and to assure that the area of high density in the film was neither a rejectable indication itself, nor masked a rejectable indication.

ASME Boiler and Pressure Vessel Code interpretation V 77 05 clarifles that surface defects such as undercut are not criteria for rejecting a radiograph.

These defects may, however, mask or hide an internal weld defect. To remcve doubt uf hidden defects. CB&l's practice war, to eliminate the undercut condition by performing "pickup." (Bil defines a "pickup" as a surface weld on defecti.e material or weld metal. The weld pass fills in low surface areas such as weld undercut, scars or similar surface conditions. The optimal time to identify and perform such surface conditioning is prior to the osiginal radiograph, thereby obviating subsequent radiography to clarify abrupt density changes in the film.

l The identification of the welder who performed t,he pickup is identified on the 1 RT report for the reshoot. The welding procedure used is specified on the record drawing. The process of surf ace conditic<ning (pickup /arinding),

including visual inspection of the finished surf ace, is controlled on temporary records. The records are reviewed by the Welding /QA Supervisor to assure all required work is coeplete and accepted prior to his signing the "Complete Checks and Examinations of Joint Completed and Accepted" column on the Record Drawing.

I o  ;

. . Attachment '

TXX 6388 April 24, 1987 Page 4 of 4 1

i l RESPONSE TO 11EE t._( d#3 ' V 10)_ CONT'C i

To a>sure that CB&l's practice'of pickup and reshoot was properly applied  !

l (i.e., the term "pickup" was not used in lieu of "repair" to avoid additional '

required NDE), we have reviewed all cases where the original radiograph was i rejected and subsequent work was not termed repair. (See discussion above). -

We have concluded as a result of this review that no cases exist where a I

, volumetric repair of a Code rejectable indication was made without subsequent '

l l radiography being performed (for reasons other than tha rejection of the area  !

In question) of the entire interval of weld. Therefo e, any concern regarding any incorrect classification of "repair" or "pickup" is rendered meet.

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Octcber 14, 1987 e s >

TU Electric ATTH: Mr. W. G. Counsil Executive Vice President 400 North Olive Street, Lock Box 81 Dallas, Texas 75201 Gentlemen Thank you for your letter dated September 8, 1987, which provides a supplementary response to Notice of Deviation, Item B. As a result of our review, we note that the Description Memorandum for Reinspection of Large Bore Pipe Supports-Non-Rigid, QA/QC-RT-313, Revision 1, excludes base material defects (i.e., excessive grinding) as an attribute for reinspection. The exclusion of the attribute is not consistent with inspections performed on another VII.c population (e.g., Pipe Wolds / Materials), where base material defects were inspected through paint. Accordingly, please clarify what actions will be taken to assure that the excluded attribute is not a concern relative to the Quality of Construction for pipe supports.

Sincerely, Oh!GINAL S!CNED By n,.F. WATNTC" R. F. Warnick, Assistant Director for Inspection Programs Comanche Peak Project Division office of Special Projects Cc:

(See attached)

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' WELECTRIC Ref.#10Cb5 201 w m c. r a December 31, 1987 e ., i ., w.

V 5. Nuclear Regulatory Convaission Attnt Document Control Desk Washington, D. C. 20555

$UBJECT: COMANCHE PEAK STEAM ELECTRIC STAil0N (CPSES)

DOCKET N05, 50 445 AND 50 446 INSPLCil0N R[ PORI 50-445/86 03 AND 50 446/86 02 BASE MAi[ RIAL DEFECT

REFERENCE:

ill Elect ric Let ter f xx-6964 f rom W. G. Counsil to NRC dated November 20, 1987 Gentlemen:

The referenced letter provided supplemental inforination concerning base material defects. IU Liectric Engineering personnel discussed with the NRC (Ellershaw and Graham) the field verification Method (CPE CPE TVH ME Il4) that will be used to validate (for base material defects due to grinding) nelds from a representative sample of 60 pipe supports. Completion of this worb activity has taken longer than the criginal estimated completion date of December 31. I')87. Accordingly, our date for completion of this work is hereby revised to February 12. 1988.

Very truly yours, lV $, bO84 a it I W. G Counsil By:

J. 57M7sNa11 - "~" "

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Supervisor, Generic Licen,ing MD/mlh c Mr. R. D. Hartin. Pe9 ton IV Resident inspectors. Cr5f5 (1)

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6. 5. Nuclear Regulatory Comission Attn Document Control Desk Washington, D. C. 20555 5UBJf.C T : COMANCHE Pt.tk $f EAM ELECTRIC STAil0N (CPSES)

DOCKET NOS. 50-440 AND 50 446 IN5PECil0N REPORT N05. 50-445/8603 AND 50 446/8602 REVISED DATE Of FULL COHPLIANCE FOR N0ilCE Of V10LA110N ITEtt 0.1 (446/8602 V 21)

REF: (1) TV Electric Letter fxX 6089 from W. G. Counsil to NRC dated January 12, 1987 (2) 10 Electric Letter fxx 6394 frcu W. G. Ccinsil to NRC thted May 6,1987.

Gentlemen:

Reference 2 transmitted our revised response to Notice of Violation item 0.1 (446/8602 V-21). Our revised response stated that ccepletion of the design verifteation of the subject Unit 2 conduit supports and closure of the as',ociated NCR 87-3742 was espected by December 31, 1987. In order to more ef ficiently utilize the resourco available to (PSES. we have found it l necessary to -eschedule the completion of these activities. Accordin i date for completion of the design verification and closure of NCR 87J742 gly, our is hereby revised to be no later than June 1,1989, i Very truly yours.

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W. G. Counsil By: ,

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4 U. 5. Nuclear Regulatory Cosenission i Attnt Document Control Desk i Washington, D. C. '0555 i

SUBJECT:

COMANCllE PEAK ST[AH tiFCTRIC STAil0N (CPSES) 00 Cit [T NOS, 50 4 45 AP'.0 50 446 IN5PtCil0N RtPORI 50 445/86 03 AND 50 446/86 02  !

BA5[ NEIAL DEFECl i i

R[f (1) Til Clectric letter TXx 6964 from W. fi. Counsil to  !

i NRC dAled Nov mber 20. 1987 l (2) 10 Electric letter IAA 1131 from W. G. Counsil to l i

NRC dated December 31. 1987

(.. n t l emen :  ;

l L the letter identified in reference 1 provided supplemental informv ion  !

tont.crning base materli.1 defects, ibe letter identified in referente 2 l Inovided information relativc to the Tield Verifiration Hethod ["

(t:PI CPI FVM.Ht ll1) used to validate (for base materiel deferts due in yr6nding) welds from a representativt sample of 60 pipe supports. Ihis ->rb activity has been completed, and based on the inspection criteria delineated in the FVM, no advtrse findings eelated to base material defects due to l grineling v.ere observed. A full report w,marising the inspart inn eesula is i d'allable ofi site inr your review. j D

Ver) t ru l,, c oie r s . .i  !

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U. i. Nuclear Regulatory Conni% ion AlIN: L'or.ument fontrol Desk Washington, O. C. 70555 SUBJECT- COMANCllE PEAK STEAM ELECIRIC stall 0N (CPSES)

DOCKf! N05. 50-445 AllD 50-446 INSPECil0N REPORIS N0' 50-445/86 03 A!40 50-446/86-02; 50 445/86-22 Allu 50-446/86-20 RLVISED DATE Of IULL COHi'll AllCE FOR flDilCE Of VI0lA110N (il0V) 'I(M [ (44f:/8602-V-17) AllD (110V) IIEM C {446/8670-V-07)

RLi llit tlCL : 1) !O L!cctric letter 19.- 6 3')4 f r orn 11. G . Counc i l t o ilRC datad iln 6, l')R 7

7) lli i lert ric l et t er I 2 l: 496 fi nm n . i . f onnsil t o i

NRf dated April ?/, l'J81

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L lief erenre (1) and (2) provided our re*,ponse to Not ice of Violation (fl0V) l item I (446/H60?-V-17) and (fl0V) Item r (446/86?0-V-0?) respectively. In I h.sse i esponses re si at vil that Ih* e nii et I ive as t isnis Ior lin il I anti e emnon llVAf ' ys t ems wou tri he romplet e,I by liart h 1988.

Also in Referenre (4), we statvil ihat t he llVAL i eves i f irat ion pi oyram fl00 (446/860/-D-17) woulti be ompleted by .lanuary 2'), 198H. fompletion of these actions ha', been i est.hedu l eil . Au.o rd i nu l y , oui iciponw to (fl0V) llem [ (146/0602 V 17) and (fl0V) 1Iem f (446/8670-V-0?) i, io,r..d io indirat<= Ihat iI," lin ii 1 and e emnon HVAr s ni s ee live at l ions will im ."mplutoit no latus than Innemboe 7 t, inHM.

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~~- = IR 86 03; 86 02 r r 1R 86 22; 86-20 y 3,,( Ref. # 10CFR2.201 July i, 1988 w n.m c c mu o ,,, ,,,n r o a., r,r,s.,

U. S. Nuclear Regulatory Commission Attn: Document Co7 trol Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50 445 AND 50 446 INSFECTION REPORT N05. 50 445/86 03 AND 50 446/86 02; 50 445/86 22 AND 50 446/86 20 REVISED DATE OF FULL COMPLIANCE FOR NOTICE Of VIOLATION (NOV) ITEM E (446/8602-V 17) AND (NOV) ITEM C (446/8620 V 02)

REF: 1) TV Electric letter TXX 6394 from W. G. Counsil dated May 6, 1987

2) TV Electric letter TXX 6396 from W. G. Cou', .11 dated April 27, 1987 Gentlemen:

Reference (1) and (2) provided our response to Notice of Violation (NOV)

Item E (446/8602 V-17) and (NOV) Item C (446/8620 V 02), respectively. In those responses we stated that the corrective action for Unit 2 HVAC would be complete by July 1988. Completion of this action has been rescheduled due to the reduced level of Unit 2 activities. Accordingly, our date for completing the corrective action for Unit 2 HVAC is revised to be prior to Unit 2 fuel load.

Very truly yours, (J.G. %2-W. G. Counsil Dy: -

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6 .. Woodlan Docket Licensing Manager ROD /grr c - Mr. R. D. Hartin, Region IV Resident inspectors, CPSES (3) g r 01 '

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