TXX-4848, Responds to NRC Re Violations & Deviations Noted in Insp Repts 50-445/85-18 & 50-446/85-15.Corrective Actions:Personnel Retrained in Existing Procedures Followed in Requesting Deviation from Design Documents
| ML20214C745 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/09/1986 |
| From: | Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20214C725 | List: |
| References | |
| TXX-4848, NUDOCS 8611210223 | |
| Download: ML20214C745 (22) | |
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s TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER e 400 NORTH OIJVE STREET, L.El. 81. I A1.LAS. TEXA8 75201 Log # TXX-4848 File # 10130 IR 85-18 85-15 WILLIAM G. COUNSIL EnscuTswa vics possiorm?
July 9, 1986 f,ygg>wmn n q
Mr. Eric H. Johnson, Director 999 ll yr Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 ghM[@kg Arlington, TX 76012
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION
/
INSPECTION REPORT NOS.:
50-445/85-18 AND 50-446/85-15 j
Dear Mr. Johnson:
We have reviewed your letter dated May 12, 1986, concerning the inspection conducted by Mr. T.F. Westerman and other members of the Region IV Comanche Peak Group during the period December 1-31, 1985. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2.
We requested and received a two week extension in providing our response during a telephone discussion on June 11, 1986. We requested and received a second two week extension on June 25, 1986.
We hereby respond to the Notice of Violation and Notice of Deviation in the attachments to this letter.
Very truly yours,
)fbw((
W. G. Counsil By: N, 6/
G. S. Keele Manager, Nuclear censing RSB/gj Attachments l
l 8611210223 961117 I
PDR ADOCK 05000445 l
g PDR l
A EHVISION OF' TEXAN tmUTIES ELECTRIC COMPANY
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c - Region IV (Original + 1 Copy)
Director, Inspection & Enforcement (15 copies)
U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. V. S. Noonan Mr. D. L. Kelley i
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NOTICE OF VIOLATION ITEM A (445/8518-V-03 AND 446/8515-V-02)
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 Plan (QAP), requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Paragraph 3.6.2.b of TUGCo Procedure CP-QP-2.1, Revision 18, states,
" Field Practical Examinations are administered by a cognizant individual certified to a Level III in that activity." Paragraph 3.8 of this procedure requires that waiver documentation for on-the-job training (0JT) specify those procedures for which the individual is certified that form the basis of the 0JT waiver.
Contrary to the above:
- 1. A field pratical examination for civil inspection instruction QI-QP-11.0-15 was administered to an inspector by a Mechanical Level III who was not certified in the activity of this procedure. The field practical examination was conducted on August 8,1985, as documented on Attachment 8 of CP-QP-2.1.
- 2. 0JT waiver forms in four inspector certification files failed to specify the procedures that formed the basis for the waiver; i.e.,
forms dated October 2 and October 28, 1985, for procedure QI-QP-11.10-2A; form dated September 5, 1985, for procedure QI-QP-11.0-15; and form dated November 1, 1985, for procedure QI-QP-11.10-1A.
RESPONSE TO ITEM A.1
- 1. REASON FOR VIOLATION The inidvidual had been certified per CP-QP-2.1 Rev.18, dated 8/19/86 by a Civil Level III; however, the Proficiency Demonstration was administered under CP-QP-2.1 Rev. 17 dat.M 10/30/84 and QI-QP-2.1-21 Rev. 2, dated 2/27/84 by a Mechanical Level III. At that time, the Program granted qualification to QI-QP-11.0-15 to Mechanical peronnel, however, CP-QP-2.1 Rev.18 did not clearly identify instances where there was a cross-over of qualification between disciplines (i.e. "Hilti Bolts" and " Verification of Baseplates for Grouting").
2.
CORRECTIVE ACTION TAKEN CP-QP-2.1 has been revised (Rev. 21) to provide for identification of crossover qualification responsibility and authority of Level III personnel involved in Training and Certification activities.
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RESPONSE TO ITEM A.1 (CONTINUED)
- 3. ACTION TO PREVENT RECURRENCE Corrective Action taken should prevent recurrence of this condition.
- 4. DATE OF FULL COMPLIANCE May 21, 1986 RESPONSE TO ITEM A.2 We do not agree that this is a violation. The requirements for issuance of a waiver are contained in Paragraph 3.8 of CP-QP-2.1, Rev.
18; "These waivers shall be documented per Attachment 14, to provide assurance that the individual does have " comparable" or " equivalent" competence to that which would have been gained from the item being waived." The Notice of Violation refers to procedures that formed a basis for the waiver. As shown above, procedures are not the only basis for a waiver. The example used in Paragraph 3.8 probably led to this misunderstanding.
The waivers in question adequately explain the basis for the waiver (as required by Paragraph 3.8) and each are supported by Level-III Proficiency Demonstration. The intent of the Proficiency Demonstration is to offer sufficient evidence that the individual possesses comparable competence to that which would have been gained via OJT.
CP-QP-2.1 has been revised to eliminate need for 0JT waivers.
Therefore, the conditions which precipitated the misunderstanding have been eliminated. This procedure revision was issued May 8, 1986.
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ITEM B (445/8518-V-01)
B.
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 QAP, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these d
instructions, procedures, or drawings.
Paragraph 4.4.5 of Gibbs and Hill (G&H) Electrical Erection 5
Specification 2323-ES-100, Revision 2, dated October 15, 1980, requires 4
electrical conduit installation to be in accordance with Drawings 2323-El-1701 and 2323-El-1702. Detail 18C of Drawing 2323-El-1701 limits the maximum length of conduit from an end device to its associated junction box to 15 feet.
Contrary to the above, the installed conduit lengths for primary l
coolant sample supply and return isolation solenoid valves 1HV-4631A j-and IHV-4631B were observed to be approximately 30 feet.
RESPONSE TO ITEM B 1.
REASON FOR VIOLATION i
Installation of electrical raceways for 1-HV-4631A & 1-HV-46318 is not in accordance with the requirements of the design.
Construction procedures require engineering authorization in the form of design documents to be issued for any deviations from the design. However, i
the raceway was installed without a change to a design document.
i QC Procedure QI-QP-11.3-28 did not adequately address the inspection requirements to detail 18C of Drawing 2323-El-1701 and 2323-El-1702.
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CORRECTIVE ACTION TAKEN
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- a. NCR E86-102718 has been issued.
Engineering will disposition the i
NCR addressing the subject deviation.
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- b. The scope of CAR 63 will be expanded to include a walkdown to identify any deviations from Detail 18C. Any deviations identified l
will be resolved as required by CAR 63.
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ACTION TO PREVENT RECURRENCE
- a. Applicable craft personnel will be retrained in the existing procedures to be followed in requesting deviations from the design documents.
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- b. QC Procedures QI-QP 11.3-28 was revised on March 7,1986, to include specific inspection requirements to Detail 18C of drawing 2323-El-1701 and 2323-El-1702, and revision training for appropriate QC Inspectors has been performed.
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RESPONSE TO ITEM B (CONTINUED)
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4.
DATE OF FULL COMPLIANCE TUGC0 will be in full compliance with the corrective action referenced in 2.b by December 31, 1986.
TUGC0 will be in full compliance with the preventative action referenced in 3.a by July 31, 1986. QC Procedure QI-QP-11.3-28 was revised on March 7, 1986.
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NOTICE OF VIOLATION ITEM C (445/8518-V-15)
C.
Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section 3.0, Revision 4, dated November 20, 1985, of the TUGCo QAP, states, in part, " Measures shall be established for the identification and control of design interfaces and for coordination among participating design organizations. These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces. Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design...."
Contrary to the above, design change control procedures did not provide for necessary review by and coordination among design interfaces with respect to performance of actions required by design change authorization (DCA) statements / justifications.
For example, DCA 13,023 dated April 20, 1982, replaced a general prohibition in G&H Specification 2323-MS-625 of contact of instrument tubing with galvanized surfaces with only a prohibition for tubing contact where redundant counterparts are routed through the same fire zone. The DCA engineering justification was based on performance of a damage study walkdown of safety-related tubing in fire zones and accomplishment of required corrective actions.
Engineering damage study walkdown procedures did not, however, require such a walkdown to be performed and the required DCA actions were not accomplished.
RESPONSE TO ITEM C 1.
REASON FOR VIOLATION Inadequate interface control and coordination at the time the DCA was written was the reason for the violation.
Informal communication between discipline leads was not adequately followed up to ensure procedures were written to address the concern.
Design review of the DCA was performed by Gibbs & Hill in New York without verification of the adequacy of site procedures to ensure that the requirements of the DCA were met.
2.
CORRECTIVE ACTION TAKEN DCA 13023 Revision 2 is in the process of being issued. The revision adds the required design control to the I&C Construction drawings to preclude any future construction activity violating the design requirements for the post-fire required instrumentation. Any changes to the instrument list of required instrumentation will result in changes to the I&C design documents via the DBD (Design Basis Document) interdiscipline review (IDR) process. An Engineering Walkdown will be performed to identify the nonconforming conditions to the revised DCA's requirements. A complete review is in progress of all CPSES erection specifications and their associated design change documents.
3.
ACTION TO PREVENT RECURRENCE The present site design review efforts, the formulation of a detailed design basis document program and significant improvements to the IDR process should prevent similar violations.
RESPONSE TO ITEM C (CONTINUED) 4.
DATE OF FULL COMPLIANCE Based upon the current schedule, all action should be completed by August 15, 1986.
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I NOTICE OF VIOLATIONS ITEM D (445/8518-V-11)
D.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section
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5.0, Revision 3, dated July 31, 1984, of the TUGCo QAP, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be acccomplished in accordance with these instructions, procedures, or drawings.
I Brown and Root Procedure CP-CPM 10.3, Revision 9, dated July 2, 1985, requires all thermo-lagged raceways to oe permanently identified in accordance with G&H Specification 2323-ES-100.
Paragraph 2.26.5 of G&H Specification 2323-ES-100, Revision 2, dated October 15, 1980, requires use of an alphanumeric code designation and color coding for safety-related conduits and cable trays.
l Contrary to the above:
- 1. No identification or color coding existed on the following thermo-lagged cable trays and conduits:
- a. cable trays T14GADG02-03, T13GACN02, and T12GA3Q15-16 in Room
.214 of the Unit 1 Auxiliary Building; i
- b. conduit near conduit C1301S570 near the entrance to Rooms 78 and 79 of the Unit 1 Safeguards Building; I
- c. conduit to cable tray T130 SCC in Room 88 of the Unit 1 Safeguards Building;
- d. cable tray T13GACD99 in Unit 1 Safeguards Building at elevation 790 feet (additional numbering problems existed in the adjacent tray section); and
- e. conduit which was partially identified as C14Y14 in the Unit 1 Safeguards Building at elevation 832 feet.
- 2. No color coding existed on the following thermo-lagged cable trays (designated by letter T) and conduits (designated by letter C):
- a. Unit 1 Safeauards Buildino j
T120SBC33, C13015570, C1305968, T12GSBG10
- b. Unit 1 Auxiliary Buildino C13G13636 C13G15200 C14030880 C14030881 T13GACD10, 24, 26, 38, and 99 T12GABF33 and 36 T130ACA35, 42, and 75 T120ABA13 and 17 i
T14YAEH19, 20, and 25 l
T14WAEF19 and 20 i
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RESPONSE TO ITEM D 1.
REASON FOR VIOLATION
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The reason for noncompliance with CP-CPM 10.3 was a verbal understanding by Building Management that Engineering considered thermo-lagged raceways (both conduit and cable tray) as not requiring alphanumeric code designation and color coding.
2.
CORRECTIVE ACTION TAKEN G&H Electrical Engineering has evaluated Specification 2323-ES-100 and determined that color coding for thermo-lagged raceways is a specification requirement.
Engineering has notified Building Management of the results of this evaluation.
Building Management will initiate NCR's to identify and track closure of items identified in NOV 445/8518-V-11.
3.
ACTION TO PREVENT RECURRENCE Due to rework and reinspection activities in Unit #1, all thermo-lag will require either reinspection and/or rework prior to fuel load.
Additional thermo-lag is not presently being installed in Unit #1 and none has been installed in Unit #2.
Prior to the beginning of thermo-lag installation, all craft personnel will be trained to the requirements of CP-CPM 10.3, inclusive of proper identification of thermo-lagged raceways.
4.
DATE OF FULL COMPLIANCE Training of personnel will be completed prior to initiation of thermo-lag installation.
Identification and color coding of thermo-lag will be completed prior to fuel load.
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NOTICE OF DEVIATION ITEM A (445/8518-D-05)
A.
Section D of Appendix E to the CPRT Program Plan, Revision 2,
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commits to classify, evaluate, and disposition each CPRT-identified construction or design deficiency, and to track and document each.
The CPRT elected to utilize an already established deficiency reporting system as implemented by CP-SAP-16, " Test Deficiency and Nonconformance Reporting," which is tracked by the CPSES Master Database.
In deviation from the above, the CPRT failed to document, disposition, and track discrepancies found during the CPRT Task Force review of drawing changes and their potential effect on related preoperational tests delineated in ISAP No. III.d. Upon followup inspection of the 60 sample sets randomly selected by the CPRT. the NRC inspector ascertained that 26 preoperational tests were conducted without the test procedure reference drawing sections having been updated as required by Section 4.9 of CP-SAP-21,
" Conduct of Testing."
RESPONSE TO ITEM A CP-SAP-21, " Conduct of Testing," contains the requirement for the review and update of test procedures. The administrative procedure was not explicit as to how the startup test engineer (STE) reviews and update should be documented. However, the STE was required to update the test procedure to be in accordance with the latest design information, but was left to his own discretion as to the method of documenting the update.
Close examination of the specific procedures revealed that they had, in fact, always been updated, but that sometimes the updates were recorded only in those sections of the test procedures containing the action statements (i.e., sections other than Section 3.0).
The 4
procedures had been updated by the Test Procedure Deviation form in j
accordance CP-SAP-12, " Deviations to Test Instructions / Procedures."
The CPRT third-party review team leader (RTL) concluded that the absence of specific notations to the reference section (Section 3.0) of the test procedures was neither a deviation nor indicative of a DCC or STE problem.
In those cases where the reference section had been updated, it was easy for the RTL to verify that the STE review I
and update had been accomplished.
In those cases where the I
reference section had not been updated, any design changes would i
have to be verified as being implemented in the remaining sections of the procedure.
In all cases, it was possible for the RTL to confirm that implementation had occurred.
Each design change requiring a response by the Startup organization was, in fact, i
incorporated into the test procedure.
Based on the foregoing, the objectives of the action plan were met and there is reasonable assurance that the document control problems which existed prior to 1984 did not adversely affect the testing program.
In light of the existing administrative controls governing the requirement to incorporate such revisions, the initial review of all the sampled test data packages attested to the compliance with those requirements.
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NOTICE OF DEVIATION ITEM B.1 (445/8518-D-26)
B.
Section 4 of CPRT Project Procedure for Issue-Specific Action Plan VII.c. No. CPP-009, Revision 3, states, in part, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions...."
In deviation from the above, the following examples were noted where field reinspections were not performed in accordance with approved instructions:
- 1. Attribute 1.d in Section 5.2.4 of QI-026, Revision 0, states, in part, " Ensure that the actual piping dimensions are in agreement with those shown on the piping isometric...." For Verification Package No. I-M-SBC0-022, bill of material item 17, a socket welded coupling, was delineated on the piping isometric with distinct linear dimensions.
The coupling was covered with insulation precluding verification of these dimensions.
- However, the checklist was signed off by the ERC inspector denoting that all linear dimensions were verified.
RESPONSE TO ITEM B.1 1.
REASON FOR DEVIATION The inspector did not reference on the checklist that the coupling location had not been measured because of instructions given in a 3-part memo dated September 5, 1985, from engineering during the performance of Verification Package I-M-SBC0-058 which stated that coupling locations for samples in this population need not be measured.
2.
CORRECTIVE ACTION TAKEN Subsequent to the NRC finding, it was determined i. hat coupling locations, when specified on the Brown & Root Piping isometric, would be verified.
Revision 2 to QI-026 was issued on April 21, 1986, to include this attribute.
All packages with couplings located on their associated isometric were submitted for reinspection per Revision 2 of QI-026 prior to June 6, 1986. The location of couplings for package I-M-SBC0-022 was found to be satisfactory. This inspection was completed on May 1, 1986.
3.
ACTION TO PREVENT RECURRENCE The corrective action serves as action to prevent recurrence.
RESPONSE TO ITEM B.1 (CONTINUED) 4.
DATE OF FULL COMPLIANCE The remaining verification packages were reinspected by June 30, 1986.
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NOTICE OF DEVIATION
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ITEM B.2 (445/8518-D-21)
B.
Section 4 of CPRT Project Procedure for Issue-Specific Action Plan VII.c. No. CPP-009, Revision 3, states, in part, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions...."
In deviation from the above, the following examples were noted where field reinspections were not performed in accordance with approved instructions:
- 2. Attribute 4.7 in Section 5.0 of QI-055, Revision 1, states, in part, " Verify that bolts are torqued to 70% of the requirements specified...." For Verification Package No. I-S-INSP-023, support 023D, 70 percent of the specified test torque requirement is 50 pounds and the ERC inspector signed the checklist that this attribute was acceptable. However, an independent inspection showed that the bolt was torqued to 40 pounds which is just 56 percent of the value specified in the QI.
RESPONSE TO ITEM B.2 1.
REASON FOR DEVIATION Reinspection confirmed inspector error.
2.
CORRECTIVE ACTION TAKEN A DR was written for this attribute in Verification Package I-S-INSP-023 on January 6, 1986.
The torque attribute was reinspected prior to June 6,1986, on five supports previously inspected by this inspector. This survey resulted in the identification of one additional inspector error.
These results will be combined with the information obtained from the Overview Inspection program to determine the extent of corrective actions for this inspector.
3.
ACTION TO PREVENT RECURRENCE An Overview Inspection program has been implemented to reinspect a sample of each Inspector's work on a continuing basis. Action is ongoing to analyze results of the Overview Inspection program, gather pertinent error data from other sources (i.e. NRC reinspections, etc.) and to effect required formal training of inspectors.
RESPONSE TO ITEM B.2
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(CONTINUED)
DATE OF FULL COMPLIANCE Corrective action will be completed commensurate with the completion of Overview Inspection results and reinspections deemed appropriate by the ERC QA Representative. This action is scheduled to be completed by August 29, 1986.
Preventive action involves a continuous program.
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NOTICE OF DEVIATION ITEM B.3 (445/8518-D-22)
B.
Section 4 of CPRT Project Procedure for Issue-Specific Action Plan VII.c. No. CPP-009, Revision 3, states, in part, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions...."
In deviation from the above, the following examples were noted where field reinspections were not performed in accordance with approved instructions:
- 3. Attribute 4.5 in Section 5.0 of QI-055, Revision 1, states with respect to spring nuts, " Verify that the serrated grooves align with the channel clamping ridge." For Verification Package No.
I-S-INSP-023, supports 023A and 023C, the ERC inspector documented "N/A" for this attribute. However, an independent inspection showed that spring nuts did indeed exist for these supports and, accordingly, were required to be inspected.
RESPONSE TO ITEM B.3 1.
REASON FOR DEVIATION Investigation revealed that the verification package contains several checklists. One for the stand and one for each support in the sample. A discussion with the inspector revealed that all spring nuts were accepted by the inspector and documented by sign-off on the stand checklist. Since the attribute was accepted on the stand checklist, the inspector marked the appropriate item "N/A" on the checklists for each support.
Inspectors are required by CPP-009 to indicate in the remarks column, why an attribute is marked N/A.
2.
CORRECTIVE ACTION TAKEN Verification Package I-S-INSP-023 was corrected on January 6,1986, to reflect acceptance of the Spring Nut attribute on a "per Support"
- basis, i
A review was conducted to identify any other packages for which all spring nuts had not been accepted on a "per support" basis, I-S-INSP-048 was identified and subsequently corrected.
3.
ACTION TO PREVENT RECURRENCE Information training was conducted by the lead inspector with all i
discipline inspectors on November 12, 1985, in which the lead inspector directed inspectors to accept spring nuts per individual 1
support on subsequent reinspections.
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RESPONSE TO ITEM B.3
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(CONTINUED)
Discipline inspectors were reminded in several subsequent informal training sessions by the discipline lead inspector to annotate all "N/A" entries with appropriate remarks.
4.
DATE OF FULL COMPLIANCE Full compliance has been achieved.
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NOTICE OF DEVIATION ITEM B.4 (445/8518-D-14)
B.
Section 4 of CPRT Project Procedure for Issue-Specific Action Plan VII.c. No. CPP-009, Revision 3, states, in part, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriated documents in accordance with approved instructions...."
In deviation from the above, the following examples were noted where field reinspections were not performed in accordance with approved instructions:
- 4. Attribute 1.1 in Section 5.0 of QI-012, Revision 0, states, in part, " Verify that the piping / tubing... material agree with the Bill of Materials shown on the Instrument Installation drawing. Note: Tubing is marked with longitudinal color coded marks for traceability. Use applicable drawing to identify tubing." Attribute 2.1 in Section 5.0 of QI-012, Revision 0, states, in part, " Verify that the instrument tag number is correct...." Attribute 1.4 in Section 5.0 of QI-012, Revision 0, states, in part, " Verify that the installed tubing has the proper slope."
For Verification Package No. I-E-ININ-053, independent inspection revealed that ERC inspectors had failed to identify the following conditions:
,i a.
The tubing was not marked for size by color coding; b.
The identification tag on the root valve was stamped with an incorrect instrument number; and c.
The tubing had an inverse slope near the root valve.
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RESPONSE TO ITEM B.4.a
.1.
REASON FOR DEVIATION i
l The investigation confirmed the NRC finding.
2.
CORRECTIVE ACTION TAKEN DR# I-E-ININ-053R-DRI dated March 5, 1986 was written to document the deficiency. A 100% reinspection of ININ packages has been completed as a result of NRC findings and changes deemed appropriate by the population engineer.
o' RESPONSE TO ITEM B.4.a (CONTINUED) 3.
ACTION TO PREVENT RECURRENCE An Overview Inspection program has been implemented to reinspect a sample of each inspector's work on a continuing basis. Action is ongoing to analyze results of the Overview Inspection program, gather pertinent inspector error data from other sources (i.e.,
NRC reinspections, etc.) and to effect required additional formal training of inpectors.
4.
DATE OF FULL COMPLIANCE Corrective action has been completed.
Preventive action involves a continuous program.
RESPONSE TO ITEM B.4.b.
QI-012 states " Verify that the instrument tag number is correct in accordance with the applicable drawings." Accordingly the instrument and the root valve are properly identified and therfore proper verification exists and the intent of the procedure has been accomplished.
This does not constitute a deviation in the ERC inspection. An Out-of-Scope observation has been written to document the incorrect instrument number on the instrument identification tag located on the flex portion of the instrument line.
Prior to fuel load of Unit 1 all system valve tags will be checked and documented against the latest drawing revision by TUGC0 Operations in accordance with 0WI-402.
RESPONSE TO ITEM B.4.c Investigation revealed that a short section of tubing from the root valve to a section of flex hose was sloped in the opposite direction to the rest of the tubing run. This short run of tubing is part of the flex hose. QI-012 does not require a slope verification for flex hose (ref. paragraph 5.1.8) and drawing 2323-1-002-R-03 note 12 states in part " Slope requirements do not apply to flex hoses however, low and high point pocketing should be avoided."
The slight change in slope of the short section of tubing does not constitute a deviation because the proper slope (i.e. low & high points) requirements were maintained. The inspection was satisfactorily performed in accordance with procedural requirements.
This does not constitute a deviation in the ERC inspection I
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NOTICE OF DEVIATION ITEM B.5 (445/8518-D-17)
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B.
Section 4 of CPRT Project Procedure for Issue-Specific Action Plan VII.c. No. CPP-009, Revision 3, states, in part, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions...."
In deviation from the above, the following examples were noted where field reinspections were not performed in accordance with approved instructions:
- 5. Section 5.5.2. A of QI-019, Revision 2, and Section 5.6.1.B of QI-029, Revision 1, state, in part, "... Verify weld size and length to the nearest 1/16 inch meets cr exceeds the minimum specified."
In deviation from the above, ERC inspectors failed to identify that a fillet weld attaching item 1 to item 2 6f pipe support MK.
No. CS-1-SB-0538-008-2 was 1/16 inch undersize for 25% of the joint length and that the two fillet welds attaching item 29 of pipe support MK. No. SI-1-104-001-C425 to existino pipe support MK.
No. SI-1-051-008-C42R were approximately 1 inch underlength.
These particular attributes were checked off as being acceptable on the applicable verification package checklists.
RESPONSE TO ITEM B.5 1.
REASON FOR DEVIATION Investigation confirmed the NRC findings of inspector error.
2.
CORRECTIVE ACTION TAKEN A DR was written for the undersize weld in Verification Package I-S-SBPS-040 on December 2, 1985.
A DR was written for the underlength weld in Verification Package I-S-LBSN-012 on January 28, 1986.
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RESPONSE TO ITEM B.5 (CONTINUED) 3.
ACTION TO PREVENT RECURRENCE The discipline lead inspector discussed the undersize weld condition with the affected inspector at the time the DR was written. He was cautioned to pay extra attention to close measurements.
The DR written against the underlength weld was subsequently invalidated by engineering and superseded by Program Deviation Report PDR-4 Issued April 29, 1986. This PDR was written to document a generic problem with weld length on tube steel. This generic problem concerns itself with engineering not specifying whether weld wrap around is required. As a result, there was no clear requirement presented to construction for wrapping the welds.
Such welds are no longer an inspectable attribute due to no identiflable installation criteria other than engineering memorandums. All affected Quality Instructions (QI-19, QI-27, QI-29) were revised via change notices to indicate that measurement of the length of " wrap around" welds on tube steel was exempt per QA/QC PDR-4. TUGCo has initiated CAR 78X to disposition " wrap around" welds on a generic basis.
4.
DATE OF FULL COMPLIANCE April 29, 1986.
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F. '
NOTICE OF DEVIATION ITEM C (445/8518-D-04)
C.
Section 5.1.1. of CPRT Project Procedure for Issue-Specific Action Plan VII.c No. CPP-008, Revision 1, states, in part, "Should an attribute appear on the generic checklist and not be applicable to the specified item, the engineer indicates 'N/A' and provides reasonable justification for the entry."
In deviation from the above, the engineer incorrectly indicated "N/A" for a checklist attribute which was applicable for Verification Package No. I-M-SBC0-022. As a result, attribute 1.i, dealing with dimensionally locating bolted flanges in accordance with the piping isometric, was not reinspected by ERC. During an independent inspection, it was observed that this attribute was applicable as evidenced by the presence of four bolted flanges.
In addition, no justification had been entered by the engineer onto the checklist for the indicated "N/A".
RESPONSE TO ITEM C 1.
REASON FOR DEVIATION Investigation confirmed the NRC finding. The checklist should not have been marked "N/A".
2.
CORRECTIVE ACTION TAKEN I-M-SBCO-022 was reinspected on February 6, 1986, for the four bolted flanges. The flange locations were found to be within the allowed tolerance for the criteria specified in QI-026.
3.
ACTION TO PREVENT RECURRENCE It has always been understood that the inspector should bring to the attention of the engineer any discrepancies between the checklist and the sample item.
In addition, a memo was distributed to the ERC inspection group on May 29, 1986, confirming that CPRT inspectors are required to bring to the attention of the engineer, any l
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within the sample boundary.
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DATE OF FULL COMPLIANCE 1
February 6, 1986.
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